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    IntroductionSafety is freedom from danger or risk and isgenerally practised by all human beings as anatural instinct. However, we see so many unsafeacts being done everyday and accidents taking

    place causing injury, death, loss of property ordamage to environment. The reason for unsafe

    acts can be either lack of awareness of the dangerand its consequences, or lack of skill for doingthe job or not following the laid down procedure.There is need, therefore, for bringing about

    awareness, imparting proper training and

    regularly reminding ourselves of the importanceof safety in carrying out our job, particularly ahazardous job. The type of programme that weare going through to-day is one effort towardsthat objective.

    There was a time when safety in industrialoperations meant safe handling of electrical andmechanical machines and appliances. However

    with the advent of chemical industry whichinvolves handling of various hazardous chemicals

    in large quantities the risks associated with

    handling of such chemicals have been a major

    8Th Endowment Lecture on Chemical Process Safety

    R. K. Garg

    Retired, Chairman & Managing Director, Indian Rare Earths Ltd.

    Table 1: Chemical Accidents World

    YEAR PLACE PLANT/

    TRANSPORT

    CHEMCIAL EVENT DEATHS /

    INJURIES

    1917 LONDON, UK MUNITIONS TNT HIGH

    EXPLOSIVE

    69 DEATHS

    426 INJURIES

    1921 OPPAU, GERMANY CHEMICAL

    WORKS

    AMMONIUM

    NITRATE

    NITRATE

    EXPLOSION

    561 DEATHS

    1928 HAMBURG,

    GERMANY

    STORAGE TANK PHOSGENE TOXIC

    RELEASE

    10 DEATHS

    1933 NEUNKIR,

    GERMANY

    Gasholder TOWN GAS EXPLOSION 65 DEATHS

    100 INJURIES1942 TESSENDERLOO

    NELGIUM

    CHEMICAL

    WORKS

    AMMONIUM

    NITRATE

    NITRATE

    EXPLOSION

    100 DEATHS

    1948 LUDWIGSHAFEN,

    FRG

    RAIL TANK CAR DIMETHYL

    ETHER

    VAPOUR

    EXPLOSION

    207DEATHS

    3818 INJURIES

    1959 GEORGIA, USA RAIL TANK CAR LPG VAPOUR

    EXPLOSION

    23 DEATHS

    1974 FLIXBOROUGH, UK CAPROLACTUM CYCLO

    HEXANE

    VAPOUR

    EXPLOSION

    28 DEATHS

    104 INJURIES

    1976 SEVESO, ITALY REACTOR TCDD INTERNAL

    EXPLOSION

    Toxic Release

    EXTENSIVE

    CONTAMINA

    -TION

    1984 MEXICO CITY TERMINAL LPG BLEVE, FIRE 650 DEATHS

    6400 INJURIES

    1988 PIPER ALPHA,

    North Sea

    OFFSHORE OIL HYDROCARBO

    N

    VAPOUR

    EXPLOSION

    167 DEATHS

    1989 PASADENA USA POLYETHYLENE ISOBUTANE VAPOUR

    EXPLOSION

    235 DEATHS

    103 INJURIES

    1990 BANGKOK,

    THAILAND

    ROAD TANKER LPG VAPOUR

    FIRE

    68 DEATHS

    103 INJURIES

    1994 DRONKA, EGYPT FUEL STORAGE AVITATION,

    DIESEL

    FIRE 410 DEATHS

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    concern. If we have a look at the accident history

    of chemical industry world over, we find a

    number of major accidents, which caused damageto health, life and property. Some of the major

    accidents, which are tabulated in Table-1 and 2catalysed the need for analysing and improving

    safety systems and procedures in the handlingand processing of chemicals. The Bhopal accident

    of 1984, involving a pesticide intermediate, is evennow mentioned in all chemical process safety

    forums. It was one of the worst accidents in the

    history of chemical industry, causing a large

    number of deaths and injuries.

    The hazards in the handling or processing ofchemicals arise due to:

    i) their inherent properties like flammability,explosivity, toxicity or corrosivity,

    ii) reactions between them which may go out ofcontrol and release large amount of energy

    leading to mechanical failure and resultingin release of the hazardous material which

    may cause fire, explosion or toxic dispersionin the environment.

    The key element in ensuring safety in handlingchemicals is, therefore, containment integrity

    during storage and reactions.

    Safety in Indian Chemical Industry

    As compared to other industrialised countries thegrowth of chemical industry in India has beenmore recent. Safety in the industry became amatter of great concern for everybody including

    industry owners, professionals, government andthe public especially after the Bhopal accident of

    1984. After this the Factories Act was amendedin 1987 to include safety in handling and use ofchemicals as an important section. TheManufacture, Storage, and Import of Hazardous

    Chemicals (MSIHC) rules were also framed in

    Table 2: Chemical Accidents IndiaYEAR PLACE PLANT/

    TRANSPORT

    CHEMCIAL EVENT DEATHS /

    INJURIES

    1974 ALLAHABAD RAIL TRANSPORT FIRE WORKS EXPLOSION 42 DEATHS

    1980 MANDIRASO

    D

    CHEMICAL PLANT

    STORE

    EXPLOSIVE EXPLOSION 50 DEATHS

    1984 BHOPAL STORAGE TANK METHYLISOCYANATE

    TOXICRELEASE

    3000 DEATHS

    1985 MUMBAI CAUSTIC

    CHLORINE PLANT

    CHLORINE TOXIC

    RELEASE

    1 DEATH

    150 INJURIES

    1985 NEW DELHI CAUSTIC

    CHLORINE PLANT

    OLEUM TOXIC

    RELEASE

    1 DEATH

    150 INJURIES

    1987 BHOPAL PLANT AMMONIA TOXIC

    RELEASE

    20,000

    EVACUATIO

    N

    1990 NAGOTHANE ETHYLENE PLANT ETHANE,

    PROPANE

    VAPOUR

    CLOUD

    EXPLOSION

    31 DEATHS

    1991 KOLKATA LEAKAGE FROM

    PIPELINE

    CHLORINE TOXIC

    RELEASE

    200 DEATHS

    1992 NEW DELHI CHEMICAL

    WAREHOUSE

    HAZARDOUS

    CHEMICAL

    EXPLOSION 43 DEATHS

    20 INJURIES

    1994 NEW DELHI STORE HAZARDOUS

    CHEMICAL

    FIRE 500 INJURY

    1995 CHENNAI TRANSPORT

    ACCIDENT

    FUEL FIRE 100 DEATHS

    23 INJURIES

    1997 34 DEATHS

    31 INJURIES

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    1989 under the Environment Protection Act, 1986.

    Immediately after the Bhopal accident in 1984, a

    Committee was appointed by the Maharashtra

    Government to evaluate the safety and

    environment status of process industries in the

    state. The Committee visited about 50 industries

    and prepared a report pointing out the

    deficiencies and the remedial steps to be taken.

    Mr. P.K. Ghosh who assisted the Committee at

    my request, had perhaps the maximum

    contribution to the Committees work although

    as Chairman I got the maximum credit so much

    so that the Committee is known by my name.

    After that I have had the opportunity of

    continuing my association with the chemical and

    allied industries not only in Maharashtra but alsoin other parts of the country as well. On the basis

    of my observation I can confidently say that the

    attitude of industry in respect of safety and

    environment protection and the ground situation

    are vastly improved. This is not to say that all is

    well and one can relax. The target of zero accident

    rate in all process units is still a long way to

    achieve. Only a few industries have been able toachieve a consistently accident free operation fora number of years. I am happy to mention thatsome industrial units and power plants under the

    Department of Atomic Energy come under thiscategory and have been winning safety awards

    of the National Safety Council and DirectorateGeneral Factories Advice Services and LabourInstitute.

    If a comparison of the safety record (human

    safety) of chemical industry vis a vis otherindustrial sectors is made (Table 3) it is observedthat the chemical industry finds a place aroundthe middle. In view of the higher awareness forsafety and the fact that the industry (particularly

    the large and medium units) is run by wellqualified persons, the accident rate should bemuch lower and this industry should be the rolemodel. For this to happen industry managers

    have to recognise that simply reacting to accidentsand then determining where additional safety

    systems are needed cannot be the strategy, sincethe potential effects of accidents can be very

    Table 3: Incidence Rate (Per 100 Workers Employed) Industry Wise

    Source Labour Bureau Pocket Book of Labour Statistics

    1995 2000SL.N

    O

    INDUSTRY

    FATAL NON-

    FATAL

    FATAL NON-

    FATAL

    1. ALL TEXTILES 0.12 36.44 0.04 9.63

    2. WOOD & WOOD

    PRODUCTS

    0.14 4.87 0.11 2.88

    3. PAPER & PAPER

    PRODUCTS

    0.33 13.61 0.11 2.88

    4. CHEMICALS &

    CHEMICAL PRODUCTS

    0.26 8.07 0.11 1.76

    5. NON-METALLIC

    MINERAL PRODUCTS

    0.22 12.46 0.13 3.04

    6. BASIC METALS 0.40 19.11 0.17 5.05

    7. FABRICATED METAAL

    PRODUCTS

    0.22 13.23 0.05 2.71

    8. MACHIENRY &

    EQUIPMENT

    0.07 9.09 0.04 2.77

    9. MOTOR VEHICLES,

    TRAILERS

    0.15 16.54 0.03 0.69

    10. ELECTRICITY, GAS &

    STEAM

    0.42 12.57 0.05 1.29

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    damaging. A proactive approach to safety isrequired. Accidents, apart from causing human

    injuries, fatalities, economic loss or damage toenvironment, have a long term impact of affectingthe image of the concerned organisation as well

    as the industry as a whole. Our economic activity

    and life style are so much dependent on productsof chemical process industries which encompasspetroleum refining, production of petrochemicals,fertilisers, pesticides, drugs and pharmaceuticals,health care products, nuclear material processing,

    to name a few. It is, therefore, incumbent on all ofus associated with these industries to strive to

    make them accident free.

    Planning For Safety

    When we talk of process safety it is implied that

    it includes:

    i) Safety of personnel working in the plant

    ii) Safety of equipment and structures

    iii) Safety of environment and the persons

    outside the plant

    The planning for safety has to cover all stages of

    a facility starting from conceptual design tositing, detailed design, construction, operation

    and maintenance, temporary shutdown and final

    dismantling/decommissioning. To this shouldalso be added transportation of hazardous

    materials. Temporary shutdown phase has been

    included with the emphasis that it is often a

    neglected phase, but a number of accidents with

    serious consequences including the accident atBhopal occurred during this phase. Another

    accident occurred in Mumbai in a chlor alkaliplant a few months later after the Bhopal

    accident in a shutdown plant. In order toeliminate/reduce the chances of accidents and

    to ensure safety in a process, it is necessary toidentify and evaluate the hazards associated

    with the process. Thus, the safety plan for aprocess involves the following two step

    approach:

    i) Identification and evaluation of the hazardsin the process

    ii) Providing equipment, systems and

    procedures commensurate with the nature

    and magnitude of the risk.

    Before proceeding further let me say a few words

    about hazard and risk which are often used

    interchangeably. There is a subtle differencebetween the two. Hazard has been defined as a

    characteristic of the system/plant/process that

    represents a potential for an accident. It is the

    combination of a hazardous material and the

    operating environment such that certain

    unplanned events could result in an accident.

    Another way it has been defined as a chemical

    or physical condition that has the potential for

    causing damage to people, property or

    environment

    Where as Risk is a measure of potential human

    injury, environmental damage or economic loss

    in terms of both the incident likelihood and the

    magnitude of the loss or injury, if it occurs.

    Hazard Evaluation Techniques

    Coming back to hazard identification and

    evaluation as the first step to safety planning a

    number of procedures are in use, viz

    Preliminary Hazard Analysis

    Process/Systems check lists

    Relative Ranking Dow and Mond Hazard

    Indices

    Safety Review

    What If Analysis

    Hazard and Operability Studies (HAZOP)

    Failure Mode, Effect & Criticality Analysis

    (FMECA)

    Fault Tree Analysis

    Event Tree AnalysisCause-Consequence Analysis

    Human Error Analysis

    One or more of these procedures can be used

    depending upon the purpose, the stage of the

    facility (conceptual, design, construction etc) and

    the available skill. For hazard evaluation at

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    What if analysis is not a very structured procedureand its purpose is to consider the results of

    unexpected and unintended events that wouldproduce an adverse consequence. The methodinvolves examination of possible deviations and

    uses questions such as

    What if the wrong material is delivered?

    What if pump A stops running during start up?

    What if operator opens valve B in place of A?

    Safety review is a tool for ensuring that the plant

    and operating and maintenance procedures matchthe design intent and standards. The review team

    looks at applicable codes and standards; detailedplant description including piping adinstrumentation drawings and flow sheets;

    procedures for start-up and shutdown, normaloperation and emergencies; personnel injuryreports; hazardous incident reports; maintenance

    records such as critical instruments checks, pressurerelief valve tests, pressure vessel inspections; processmaterial characteristics (i.e. toxicity, reactivity) etcand carries out a detailed inspection of the plant.

    Quantitative risk assessment (QRA) Qualitative

    information on the failure of component or system

    and its likelihood and consequences, is generally

    sufficient to decide on making safetyimprovements. However, for deciding on major

    safety modifications involving substantial

    expenditure, quantitative cost/benefit

    information is sometime required by themanagement. QRA is expected to provide

    information on the expected frequency and theconsequences of accidents that could occur. It is

    based on available information, from pastexperience, on component/system failure rates.

    More over What is an acceptable risk is a

    difficult question to answer and is highlysubjective. It is also not easy to estimate long term

    risk to workers or the public from chronic

    exposures to potentially harmful substances oractivities. In view of this and the uncertainty in

    the results, QRA can only be a complimentary toolto other safety assurance methods and can not by

    itself be the basis for decision making.

    For getting an estimate of the impact of a toxic

    release or of flammable material release and itsignition, readymade models are available and arebeing used. They can be a good guide to providingdistances between vulnerable sections of the plant

    and of the plant from the public domain.

    Safety Management

    An effective safety management system has to

    ensure that safety is the overriding considerationat all stages of the plant, starting from site

    selection to plant design, layout, equipmentselection, fabrication, construction,commissioning, operation and maintenance and

    shutdown. Safety management calls for an in-depth knowledge of the process, all the plantcomponents, systems and procedures. As a

    general guide it is based on the followinginformation about the plant and reviewingadequacy of the various safety systems in the light

    of the hazard evaluation study.

    i) Process technical data: It includes chemicaldata in respect of raw materials, intermediateproducts and products (from Material Safety

    Data Sheet (MSDS) or other literature);reaction chemistry, reaction kinetic data,

    temperature and pressure condition of the

    reactions, operating limits, controlphilosophy, material and energy balances,

    waste generated, process flow diagram withflow rates, piping and instrumentationdrawings.

    ii) Plot plan: It should show major process

    equipment and storage in the site, indicating

    special design considerations such asseparation distances, underground piping

    and services, zones along with electricalclassifications.

    iii) Equipment specification: Specifications forprocess equipment such as pumps,

    compressors, tanks, vessels, heat exchangersetc. showing material of construction, design

    process conditions, protection systems (reliefvalves, fire suppression systems, scrubbers,condensers) and mechanical details with

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    design codes and standards used. Pipingspecifications include the materials, type and

    size, fittings, valves, gasket materials for thechemicals expected to be handled.Information on hydrostatic test reports,

    manufacturing inspection reports, weld

    radiographs, stress relieving records etc.should be available. For highly toxic andhazardous materials or for meeting specificprocess requirements, special not socommonly used equipment/systems may be

    required, e.g. diaphragm type pumps andcompressors and bellow sealed valves for

    zero gland leakage, all welded pipelineswithout jointing, non-lubricated machinery(for oxygen service), inerting with nitrogenfor exclusion of oxygen, exclusion of water,

    protection for shock sensitive materials, andagainst electro-static charge generation.

    iv) Instruments: A list of all the instruments in theprocess which are important for maintainingprocess safety should be avaiable. Theyinclude sensors (for temperature, presure,flow, level etc.), transmitters, controllers,control valves, pressure reducers etc. alongwith specification sheets, design conditions,material of construction (for components incontact with process fluids). Instruments formonitoring of emission from vents/stacks,work environment, and ambient airmonitoring should also be available.Arrangements for calibration of instrumentsare also to be provided. Many of todays largeand medium size plants are controlled andmaintained by programmable controllers anda computer. The specifications of the hardwaresystem including UPS and the softwaredocumentation should be available and shouldbe kept securely under management control.

    v) Operation procedures: An operation manualgiving the detailed procedure for day to dayoperation of the plant should be available tothe operators. It should clearly provideinstructions for conducting all the activitiesin each process step in a safe manner andshould cover all phases viz. Start-up, normal

    operation, emergency operations (including

    emergency shutdown) and normalshutdown. It should give the operating limits,the consequences of deviations, steps to betaken to correct deviation and safety systems

    in place to handle deviation. Safety related

    information like hazardous properties ofchemicals used, special instructions, if any,

    in inventory control, and quality control

    procedures should be included. The

    operating manual should be kept upto-date

    and the procedure for changes to be made inthe manual should be well-defined.

    vi) Maintenance procedures: They should be

    well documented and a system of keeping

    records of all maintenance jobs should be in

    place. Safety instructions for on-linemaintenance and for removal of the

    equipment for maintenance, e.g. draining andflushing the system to completely remove all

    hazardous material before taking up anymaintenance job, use of personal protective

    equipment (PPE) should be provided. Many

    serious accidents involving fire as well as

    toxic release have taken place during

    maintenance due to hazardous materials notfully removed from the system.

    vii) Training: Initial as well as refresher trainingof the operational and maintenance staff is

    the most important factor, which can

    contribute to process plant safety. It is

    gratifying to note that a lot of emphasis is

    given to this aspect in the DAE units and incritical areas there is even a licensing

    requirement. However in many otherindustries training needs greater attention.

    viii)Accident investigation: A system of accident

    reporting and analysis forms anotherimportant part of safety management. Basedon these investigations safety systems can be

    further strengthened. Efforts should also be

    made to get reports of near-miss incidents so

    that preventive steps can be taken and further

    accidents can be avoided. Some plants have

    already introduced this practice.

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    ix) Regulatory aspects: In addition to theFactories Act 1948 (amended in 1987) which

    is applicable to all factories there are rulesmade in respect of plants handling hazardouschemicals, under the Environment Protection

    Act, 1986. These include:

    a) Notification of the Ministry of

    Environment and Forests, 1994 forcarrying out an Environmental Impactassessment (EIA) study before setting upa new plant or for expansion of existing

    units of certain size. The procedure forenvironmental clearance by the Ministry

    of Environment is under review.

    b) Manufacture, storage and import ofhazardous chemicals (MSIHC) Rules,

    1989.

    c) Hazardous waste (Management and

    Handling) Rules, 1989

    d) Public liability insurance Rules, 1991

    e) Emission standards for gaseous, liquid

    effluents prescribed by the CentralPollution Control Board and the StatePollution Control Boards.

    The MSIHC Rules call for preparation of Safety

    Report, Safety Audit and preparation of On-siteand Off-site emergency plans and conductingdrills periodically.

    All the above regulations are applicable to DAE

    installations also.

    Thus ensuring safety and environment protectionin a process plant is not only required from socio-economic considerations and is voluntary but is

    also an obligation under the laws of the land.

    Conclusion

    In conclusion, I would again state my view of the

    status of safety in the Indian chemical industry over

    the years. Along with the growth of the industry,

    there has been considerable improvement in the

    awareness, attitude and performance of the

    chemical plants in respect of safety. Hopefully this

    trend will continue. The importance of safety can

    be gauged from the fact that even financial

    institutions critically examine the safety andenvironmental protection systems of a project before

    providing financial support. I would also like to

    make one more comment, which the audience here

    will be happy to hear. I feel that now the safety

    professionals have a greater respectability than what

    they used to enjoy earlier. The Department of

    Atomic Energy has been an exception in that safety

    activity has always been considered as important

    as any other. This should serve as a motivation to

    safety professionals in other industries to put in

    more efforts to reach the goal set by a safety expertthat every one in the plant from top to the bottom

    becomes a safety officer.