2.0 APPLICABLE DOCUMENTS
INM-03-001 Environment, Health and Safety Policy
3.0 APPLICABLE FORM
INM-03-008-01 Accident / Injury Report
INM-03-008-02 Learning Incident Report
INM-03-008-03 Spill Report Form
This process is applicable to Xxx (India) Pvt. Ltd. Xxx plant only.
Note: This plan will be reviewed and updated at least annually by end of Q1.
To outlay procedures to ensure minimum or no injury/loss of life and property during emergencies. The guidelines for emergency situation includes- Natural disasters, Bomb and telephone threats, Fire incidents, Spill occurrences.
This procedure defines the individual responsibilities and procedures for anticipated crisis
situations with attitude, logical approach and without panic.
7.0 RESPONSIBLE DEPARTMENT
9.1 Disaster is an emergency that is not adequately anticipated and controlled.
9.2 Emergency: A condition that is out of the normal operating conditions and which cannot be controlled by normal operating procedures and which has detrimental effects on the health and safety of personnel, and which endangers life and property.
9.3 Emergency readiness means that you are prepared to react promptly to save lives and protect property if your plant is threatened by an emergency of any type.
9.4 Emergency Response Operation Center: A location where a control station will be established and response actions will be directed during a crisis. The guardroom at the entrance gate will be the emergency response-operating center during crises/emergency situation. The control desk will be established under the direction of the Emergency Coordinator. The guardroom will have the following:
9.4.1 Facility layout drawings
9.4.2 Heavy-duty flashlights
9.4.3 Battery powered megaphones
9.4.4 Emergency lighting
9.4.5 Personal Protective Equipment-gumboot, cotton gloves, helmets, eye goggles and respiratory mask
9.4.6 First aid supplies
9.4.7 Updated list of telephone contacts
9.5 First Aid Stations: Designated locations stocked with first aid materials at which First -Aiders are to approach for first aid requirements during a crisis. Refer to Section 10.13 Facility Site Plans, Appendix VIII, ‘Locations of First Aid Kit.’
9.6 Reporting and Information Center: An area established remote of the Emergency Response Center from where news will be released to media, governmental agencies, and families. The EHS and HR departments, depending on the prevailing site conditions will decide the location of the Reporting and Information Center.
9.7 Designated Assembly Areas: Areas are pre-established and marked to where employees are to proceed after a building evacuation. Refer to Section10.13, Facility Site Plans, Appendix III, ‘List of locations of hazard and fire fighting equipments with plant drawing showing emergency exits and designated assembly area for evacuation’.
9.8 Emergency Phone List: A list of emergency contacts including management personnel. The list is updated yearly and distributed to the key personnel and the emergency responders within Xxx India. The HR function is responsible for updating existing list of emergency contact numbers. Refer Section 10.13, Facility Site Plans, ‘Appendix-I, Emergency Organizational Contact List’.
The emergency response and contingency plan covers following aspects:
10.1 Emergency Organization and Contacts
10.2 Emergency response team and their functions
10.3 Emergency Responsibility by Title
10.4 Plant warning system
10.5 Emergency Equipment
10.6 Emergency Evacuation Plan
10.7 Drills & Exercise
10.8 Fire / Explosion Response Plan
10.9 Spill Response Plan (Control and Countermeasures)
10.10 Bomb Threat Plan
10.11 Written and Telephone Threat
10.12 Power failure
10.13 Facility Site Plans
10.14 Emergency reporting system
10.1 Emergency Organization and Contacts
10.1.1 The emergency organization and contacts list will include the names and telephone numbers (office and residence) of the following list. The names and telephone numbers will be updated on a yearly basis .The HR function is responsible for updating existing list of emergency contact numbers. It will be posted at the security post. Also all the emergency personnel listed in item 10.1.2 in their offices and home will maintain the updated list.
10.1.2 Xxx India Management:
a. Director – Manufacturing
b. Works Manager
c. Quality Assurance Head
d. Human Resource Head
e. Logistic Head
f. Executive Engineer
g. IT Personnel.
10.1.3 Community Response Centers:
10.1.4 Insurance Company - United India assurance Company
10.1.5 Neighboring factory contacts
10.2 Emergency Response Team and their functions:
The emergency response team will consist of three sub teams:
a. Emergency Coordinator b. Backup Emergency Coordinator
c. Evacuation team
a. Emergency Coordinator (EC) –
For directing the Shift Emergency Responder for plant emergency operations like shut down and lock out procedures (partial or complete as necessary to prevent loss of man and material). Interface with Backup Emergency Coordinators. Activate Reporting and Information.
b. Backup Emergency Coordinators (BEC)-
i) EHS Coordinators - For emergency response, Safety and First-aid
ii)Plant Engineer - He will coordinate with Emergency Coordinator for providing technical assistance during any emergency situation.
iii)Human Resource & Security - For Facility Coordination, Telecommunications, Security, Public Communications, and External Assistance.
iv)Shift Emergency Responder (SER) - The area in charge at that particular shift / time of work for the coordination with the Manager Operation and plant engineer.
c. Evacuation Team-
Members of the Safety Committee (Possibly 02 persons from each department)
To facilitate evacuation during emergency situations.
10.3 Emergency Responsibility by Title
10.3.1 Emergency Coordinator (EC)- -(Shift superindant)
a. Pre-Emergency Responsibilities: Co-ordinate drills, ensures the testing of emergency equipments in his area. Ensure adequate staffing and safety training of each employee.
b. Emergency Responsibilities: Assumes charge and directs remedial measures. Designate a responsible person of his team for correct and quick communication with Back-up Emergency team. Assess nature of emergency and coordinate with the EHS department. Help the evacuation team (Safety Committee members). Direct the Shift emergency responder for plant emergency operations like lock out procedures (partial or complete as necessary to prevent loss of man and material). Interface with Backup Emergency Coordinators. Activate Reporting and Information. He along with Plant Engineer is responsible for providing technical advice and assist the emergency coordinator during emergencies. His duty is to provide plant drawing for fire protection system and utilities.
b. Post Emergency Responsibilities: Determine extent of damage; assess the nature of loss and arrange for the resources required for restoration of normal operating conditions. Co-ordinate review meetings to critique emergency response action. Handle the regulatory, and Division notifications. Conduct an investigation of the accident and revise plant operations to prevent a repeat occurrence. Inventorise and replace all used emergency equipment with the help of EHS personnel.
10.3.2 Backup Emergency Co-ordinator (BEC)-
The backup emergency coordinator team will consist of:
a. EHS Manager & Coordinator
b. Shift Engineer
c. HR & Security personnel
d. Shift Emergency Responder(security guard on duty at main gate)
10.3.3 EHS Manager & Coordinator-
a. Pre-Emergency Responsibilities: Co-ordinate drills and exercises on an annual basis. Conducts debrief and discuss improvement opportunities. Ensures the testing of emergency equipments in the plant. Ensure safety and emergency training of the employees and record them. Report any unsafe activity that may result in damage to men, materials and environment to the manager responsible for the area. Aid EHS Manager in handling the regulatory affairs and division notifications related to matters of environment, health and safety.
b. Emergency Responsibilities: Should assist the emergency coordinator in his responsibilities during emergency. In the absence of emergency coordinator, takes charge. First responder assumes charge and directs remedial measures. Assist the emergency coordinator, evacuation team in his responsibilities, coordinate with the HR and Security personnel.
c. Post Emergency Responsibilities: Assist the emergency coordinator in his responsibilities. In the absence of the emergency coordinator, take charge.
10.3.4 Human Resource & Security –
a. HR personnel are responsible for facility coordination, security, telecommunications, and public communications. Arrange for external assistance like fire, police, or medical etc. coordinate with emergency coordinator and EHS coordinator.
b. Shall ensure that a copy of the emergency response plan, emergency contact numbers is maintained with security personnel.
c. Maintain contact with the press and civil authorities (government, police, etc.) and ensure that accurate information concerning the incident is given to the media. Obtain approval of the Plant Manager or their representative for release of any information requiring security clearance.
a. Keep (designated) company representatives informed of the incident.
b. Maintain necessary communication with employees.
c. The security guard shall be responsible for providing security during an emergency to prevent unauthorized access. He shall follow the instructions and respond efficiently. If fire is reported to the Security Guard Station, Security personnel shall immediately contact the EHS Personnel or HR Department. Upon direction , Security Personnel shall call Police, Contact Fire Station and confirm that the Police Force is notified and that a fire engine is on the way and provide the following information:
-- Name of the organization
-- Location of fire within the building
-- Size and extent of fire
-- Number of injured persons
-- Name of the hazardous material involved
d. Whenever the alarm is noticed, the security guard shall:
- Check the physical location of the fire
- Inform the Emergency Coordinator, Backup Emergency Coordinator, or EHS Department about the location of the fire.
10.3.5 Shift Emergency Responders(SER)
a. Responsibility: First responders during the respective shift.
b. Pre-Emergency Duties: Attend annually the training on emergency response. Aid the emergency coordinator.
c. Emergency Duties: Upon receiving the call from Security or as soon as he comes to know about the emergency, notify emergency coordinator, back-up emergency coordinator or EHS coordinator, in the same order of priority as directed in Appendix- IV, Emergency event reporting system. Participate in plant emergency response actions until relieved by the emergency coordinator or backup. Assure that the emergency area is secured.
d. Post emergency duties: Report to and assist the emergency coordinator or backup in their post-emergency duties.
10.3.6 Shift Engineer
a. Pre-Emergency Responsibilities: Co-ordinate drills, ensures the testing of emergency and all other equipments in his area. Ensure safety training of each employee in his department. Aid the working of the emergency coordinator. Provide procedures for plant emergency operations like shut down and lock out procedures (partial or complete as necessary to prevent loss of man and material).
b. Emergency Responsibilities: In absence of the emergency coordinator, assumes charge and directs remedial measures along with the EHS personnel. Ensure correct and quick communication with Back-up Emergency Coordinators. Assess nature of emergency and coordinate with the EHS department. Help the evacuation team (Safety Committee members). Ensures that the shift emergency responder follows the instructions of the emergency coordinator correctly and also the procedure provided for shut down, startup and lock out are correctly followed. Interface with Backup Emergency Coordinators. Assists to activate reporting and information. He along with emergency coordinator (Manager Operations) is responsible for providing technical advice and assists him during emergencies. His duty is to provide plant drawing for fire protection system and utilities.
c. Post Emergency Responsibilities: Determine extent of damage; assess the nature of loss and arrange for the resources required for restoration of normal operating conditions. Co-ordinate review meetings to critique emergency response action. Follow the regulatory and Division notifications. Conduct an investigation of the accident and revise plant operations to prevent a repeat occurrence. Inventorise and replace all used emergency equipment with the help of EHS personnel
10.4 Plant Warning System
During emergency plant warning system will activate. The plant will be warned through the alarm. Refer Facility Site Plan Section 10.13, Appendix-III-‘List of locations of hazard and fire fighting equipments with plant drawing showing emergency exits and designated assembly area for evacuation’.
10.4.1 The alarm will warn each employee and guest against the emergency. The employees (non-emergency response team) and guests are to follow the nearest escape root and collect at the assembly point. While the Emergency Responding Team will actively start functioning.
10.4.2 It is the responsibility of the host to ensure that his/her guests follow the instructions and ensure their safe evacuation, if required during emergency.
10.5 Emergency Equipment:
Emergency equipment is tested and maintained on a regular basis as indicated below. The maintenance department updates emergency evacuation routes that are posted.
EQUIPMENT FREQUENCY OF TEST DEPT IN CHARGE
Fire hoses and sprinklers Semi annual Maintenance
Fire extinguishers Monthly H R
Alarms Semi annual Maintenance
First Aid Kits Upon use H R
Personal Protective Equipment Quarterly/upon use EHS Department
10.4 Emergency Evacuation Plan
Emergency response and evacuation drills are conducted once annually. Every exit and the doors leading to it are numbered. If possible each department or area has a minimum of two routes for evacuation. Designated assembly areas are identified and marked on the schematics. Refer to Section 10.11 Facility Site Plans, Appendix III - ‘List of locations of hazard and fire fighting equipments with plant drawing showing emergency exits and designated assembly area for evacuation’.
10.4.1 Conduct debriefs and discusses plant personnel improvement activities.
10.4.2 The Emergency Evacuation Team (Safety Committee Members) has the following responsibilities during an emergency:
a. Upon hearing the fire alarm, ask the employees to evacuate; instruct employees and guests to calmly walk to the designated assembly area. The evacuation team will aid in the evacuation in the areas.
b. Ensures employees not to go to the lockers or return to the building for personal items during the emergency until the ‘all clear’ order is given.
c. Upon meeting at the designated area, instruct employees not to leave the premises. Take a head count to ensure that no employees are missing. Report missing employees to the emergency coordinator or EHS coordinator and wait for further instructions from the EHS coordinator or backup emergency coordinator.
d. Once the 'ALL CLEAR’ order is given by the emergency coordinator and EHS Manager, the EHS coordinator and the backup emergency coordinators will jointly assist employees and guests to reenter the building and maintain order.
10.6.3 Employees have the following responsibilities during a crisis:
a. Upon hearing the fire alarm or the paging system instructing to evacuate, calmly evacuate through the nearest exit in an orderly fashion and as per the instruction of the EHS coordinator and emergency evacuation team.
a. Assemble at the designated area and report to the emergency coordinator or EHS manager.
b. Remain in the designated area until instructed by the EHS coordinator and backup emergency coordinator.
10.6.4 Emergency Evacuation
It will be executed with the help of the evacuation team(members of the safety committee) and assisted by emergency coordinator, backup emergency coordinators. A decision on evacuation (complete or partial) must be made after all information has been gathered by four or at least any two of the following:
a. Work's Manager
b. Director Manufacturing
c. QA Head
10.6.5 Elements to be considered are:
a. Evaluation of data collected (all information available on threat).
b. Cause of evacuation- Big Fire, local bomb threat, natural disaster (climatic conditions, earthquake etc.)
c. Date of week
d. Total employee number
e. Time of shift
f. If an evacuation is to take place, Head of the department or his designee must ensure that all employees leave quickly and safely by the available emergency exits.
g. Police, fire, or other available bomb experts must be utilized for any search activities.
h. In the event an emergency when arises to such magnitude that an immediate evacuation of the plant is warranted, the Facility Alarm System should be used to notify all persons in the Plant to make other employees aware/convey the news of emergency situation evacuate immediately.
i. Reporting will be done as early as possible, after normalization of the operations/functions through the related form.
Note: The assembly points and emergency exits are marked in the lay out drawing attached with Appendix –III ‘List of locations of hazard and fire fighting equipments with plant drawing showing emergency exits and designated assembly area for evacuation’.
10.7 Drills & Exercises
Drill and exercise are conducted annually. The primary function is to provide the means of testing the adequacy of the emergency response plan and the level of readiness of response personnel and to learn improvement opportunities.
a. The EHS Manager with assistance from the various response coordinators is responsible for coordinating the development of and assisting in the conducting of drill and exercise.
b. Respective Employees are the responsibility to escort the Visitors and Contractors to calmly walk to the nearest exit.
10.7.3 Types of Exercise/Training:
The following types of drills and exercises are to be used:
a. Full Scale Training
This level of exercise requires the coordination of EHS Coordinator and the members of safety committee. The intent is to evaluate the operational capability of the Plant Emergency Organization and the adequacy of this Plan.
Frequency: Conducted annually involving all emergency response personnel and in cooperation with the community.
Respective department manager will review the emergency response and contingency, six months after full-scale training
i) Preparation for a drill or exercise will vary depending on the type and scope involved. However, preparation and planning should include:
- Plan review and identification of possible problem areas
- Establishing objectives
- Identifying resources and personnel involved
- Assigning and training controllers and evaluators
- The scenario used will be realistic and based upon current operating conditions. The primary event (fire, spill, etc.) to be determined will be based on the objective of the exercise.
ii) A sequence of major events list will be developed to help stimulate an actual emergency incident. Expected responses for each major event are to be determined. Conditions are simulated as closely as possible to the actual emergency situations.
c. Follow up
i) Results of drills and exercises are to be reviewed by all participants. The management team and the involved emergency response coordinators will identify the areas such as deficiencies, in the plan, training, personnel or equipment.
ii) The EHS manager is required to prepare a final report and submit it to the Management for corrective actions.
d. Fire Drills:
- EHS Coordinator shall conduct a fire drill annually.
- Designated associate to ensure that their employees move in an orderly fashion to the designated exits
- Do not break the seals and open the doors
- Departmental head/designated representatives are to ensure that all their employees are accounted for.
- Drills are to be taken seriously, as it is a practice, which will save people during a crisis.
- Do not panic and run as such acts can kill/injure more people than an actual fire.
- A team will be asked to evaluate the drill. EHS coordinator will determine when the drill is over and will direct the employees to return to the building.
10.8 Fire / Explosion Response Plan
Guidelines for reporting and responding to a facility fire.
10.8.2 Fire Incident:
The primary role is to – Sound the nearest fire alarm (if the smoke detectors did not detect and the hooters do not blow automatically). Evacuate people from the building as per the instructions of the Evacuation team and follow the nearest emergency root / exit Refer Appendix- IV, Plant lay out drawing showing emergency escape doors and assembly point. However if a small fire is present and can be safely extinguished by a trained employee using a portable, hand fire extinguisher then to do so:
a. Identify the type of fire; locate and use the nearest appropriate/suitable fire extinguisher before the emergency. Refer to Section 10.13 Facility Site Plans and Appendix III – ‘List of locations of hazard and fire fighting equipments with plant drawing showing emergency exits and designated assembly area for Evacuation’.
b. Notify Section Head, EHS department, and the security guard. Report location, size and extent of fire, and whether any hazardous materials were involved.
c. Notify Facilities/Maintenance and related emergency organization and contact person, Refer Section 10.12, Appendix –I, II, &V
d. After the fire is out, ventilate smoke from the area.
e. The head (or designee) of the department involved with fire shall:
- Ensure a calm and orderly evacuation out of the building and to the designated assembly area. He may take help form Evacuation team (Safety Committee members) also.
- Take a head count to ensure that all the department employees have evacuated.
f. Ensure that the employee(s) involved with the fire report the following information to Security Guard:
- Location of fire, size and extent of fire
- Any injured or missing persons
- Any hazardous materials involved
- If reporting by phone, do not hang up until told to do so.
- If there is time and if there is no danger, close all the windows and doors.
- Stop any machinery or motors
- Disconnect electrical equipment
- Shut off fuel supply to any open flames, if safe to do so.
- Check if the fire hoses at the zone have been tampered. If so, report and close nozzle.
- Submit an accident, injury or incident report to the EHS Department.
10.8.3 The emergency coordinates and/or his backup or the emergency responders will meet the Fire Department, relay the information and direct them to the place of accident; will implement emergency response duties as described in Section 10.3 "Emergency Responsibilities by Title".
10.8.4 The emergency coordinator and the backup emergency coordinator will assist when hazardous materials are involved and will also make the necessary corporate and regulatory notifications and reports.
10.8.5 The fire protection equipment/system available at the facility and their locations are as per – Appendix III-‘ list of location of hazard and fire fighting equipments with plant drawing showing emergency exits and designated assembly area for evacuation’ and Appendix-VI’ List of fire protection and fire fighting equipments.
10.8.6 Shift, Weekend and Holiday Fire Emergency: In the event of a fire emergency, associate will call the Security Guard and provide the information. The security guard shall then call the emergency coordinator, the member from the emergency backup team or the EHS coordinator (whoever is present or can be contacted easily). Upon direction from the emergency coordinator the member of the emergency backup team or EHS Coordinator (whoever is informed by the security guard), the security guard shall call Fire Station / Police Force / medical assistance (do as directed as directed). The emergency coordinator shall then call the EHS manager or coordinator and provide the same information. Refer to Section 10.13, Appendix-I ‘Emergency Organizationtional Contact list’.
10.8 Spill Response Plan
The purpose of this plan is to outline the Facility's response to Hazardous Materials Spill and the minimum requirements that must be considered when dealing with responses. A complete list of chemicals used in the facility, the maximum quantity stored on site and location of storage is kept available with the EHS Manager.
a. Hazardous Materials: Substances, which are classifiable under the classification system as specified in THE FACTORY ACT SEC. 2 (cb). Hazardous substances also include empty receptacles or packages, which have contained hazardous substances, unless such receptacles or packages have been decontaminated.
b. Hazardous Materials Incident: A hazardous materials spill in quantities typically used in operations.
c. Hazardous Materials Emergency: A material spill greater than the quantity typically used in operations or a smaller spill which is not easily controlled by a department hazardous material spill responder, given the materials and training provided.
10.9.3 Hazardous Material Spill Responders:
Employees should be trained to respond to spills in their own areas. These employees shall be given the basic training on handling and dispensing of solvents and waste solvents. They are trained to handle only lab quantity levels of solvent spills.
10.9.4 Hazardous Materials Incident:
a. Employees Responsibility: Any employee having information regarding an actual, or suspected non-routine release of hazardous material into air, sewer, storm water, ground water or ground shall immediately contact the supervisor or designee.
b. Head of the Department’s Responsibilities: The HOD shall ensure that at least 2 department employees are fully trained at all times to respond to accidental releases in their departments.
i) Ensure that spill kits are provided where hazardous chemicals are used. The kit will contain absorbers, neutralizers, pillows, dikes, chemical resistant gloves & clothing, goggles, respirators, waste collection cans/bags; spill report form.
The emergency coordinator or backup and the security officer Stationed at employee entrance lobby shall be contacted immediately.
If the condition creates a hazard to employees or others working in the area, the supervisor will instruct the employees to evacuate the area as outlined in Section 10.6" Emergency Evacuation Plan".
ii) Responders Responsibilities:
If necessary, advise the supervisor to isolate and evacuate the immediate spill area and surrounding area.
Notify EHS manager.
Determine the identity of the hazardous substance and assess the materials hazard as per the material safety data sheet (MSDS) and other pertinent data available. MSDS are available in each department.
Warning signs will be posted at the site/location of spill – ‘Spillage here-Do not come near’ to avoid any accident due to spill that has occurred.
If any person(s) is injured or overcome by exposure, the supervisor shall arrange for emergency medical help. Refer to Section 10.1, "Emergency Organization and Contacts" and Appendix I-‘ Emergency Organizational Contact List’ for telephone number.
Wear personal protective equipment as advised by MSDS.
Never clean up a spill alone. Ensure that another spill responder is nearby.
Use pads, dikes, pillows and absorbent to absorb hazardous material.
Once absorbed, place the material in the waste bags.
Clean up the residue on surface with soap and water. Place all the cleaning material in the waste bags.
Fill up the Spill Report (Form # INM-03-004-01) and send it to EHS coordinator.
Request for replacement spill kit contents.
If the situation becomes an Emergency/Crisis, i.e. the spill cannot be contained, evacuate the immediate and surrounding areas and contact Security.
The Security guard shall immediately contact the Emergency Co-ordinator or backup (shift responders during shift) immediately and relay the message.
The emergency coordinator or back up or the emergency responders shall assess the type of chemical spilled and extent of spill.
The emergency coordinator or backup or the shift responders shall ensure that area is properly isolated, demarcated and affected employees are evacuated. Evacuate the area or building as outlined in Section10.6, "Evacuation Plan". Then call the outside responders for assistance.
Work with the outside response team to ensure clean up.
iii) EHS Co-ordinator's Responsibilities:
Upon learning of an incident/emergency, the emergency coordinator will obtain the basic facts and make an initial assessment of the situation.
If the released material is spreading or is in danger of spreading to a larger area and poses a threat to the health and safety of persons outside the facility, the Police Force shall be contacted immediately. The
Checklist of Xxx Emergency Response Resources in the Xxx Environmental Manual shall be reviewed to determine any division or corporate personnel should be notified.
Once the safety and health of personnel is assured and the emergency has been brought under control, the licensing officer as defined in THE FACTORY ACT, 1948, SECTION 2 (c, b) shall be furnished with a detailed report in writing as to the circumstances of the accidental release of the hazardous substance and the subsequent action taken in relation thereto. If there are any injured persons then the Department of Industrial Safety shall also be notified of the accident. The Division Environmental Manager will also be furnished with a detailed report.
iv) To prevent or minimize the effect of spills:
Keep containers closed when not in use.
Do not store materials together where it is incompatible and store it in the appropriate storage areas.
Practice good house keeping
Know your responsibilities in the event of an emergency.
Emergency Coordinator shall conduct a hazardous material spill response drill annually to determine the effectiveness of the response plan.
A weekly inspection of the hazardous materials and waste storage areas will be undertaken by the EHS coordinator and documented to ensure that everything is in order.
v) Techniques that can be used to detect presence of Hazardous Concentrations of Chemicals:
Observations of visible fumes for chemicals which exhibit this property.
Knowledge of the odor threshold of the chemical.
Observance of liquid pools of the chemicals.
Air monitoring results from direct reading of the monitors.
Results from automatic continuous monitors
10.9.5 Specific Spill Prevention, Control and Counter- Measure Plan
This Spill Prevention, Control and Counter measure Plan (SPCCP) is prepared for the prevention and containment of oil, IPA, spills. The oil spill referred to herein in the plan refers only to the Furnase.Oil meant for the Boiler. The lubricating oils, hydraulic oils etc., will be handled as per Section 10.8, Hazardous Material Spill Response.
b. Tank and Spill handling equipments Location:
The tank location and the nearby spill handling equipment are listed in the Appendix- VI, “Facility Site Plans”, Section 10.11.
c. Spill Protection Provisions:
The fuel oil tank is placed inside a dike area that has concrete floors and walls that are sufficiently impervious to contain spilled oil. The capacity of the secondary containment is 20% more than the capacity of the tank. In addition brooms and absorbents will be kept to nearest approach for controlling any spills/leaks.
10.8.6 Procedures for Checking and Receiving Bulk Fuel:
a. A facilities associate shall be present for the entire duration of the filling.
b. Upon the tanker arrival, the associate shall check that all the seals at the discharge valves and hatch covers are intact. The seal number must tally with the number stated in our delivery order.
c. The facilities associate, prior to filling, shall ensure that adequate spill response material is available.
d. The facilities associate shall visually check the transfer equipment for integrity and ensure that it is properly connected to the tank.
e. If everything is in order, the facilities associate shall start pumping.
10.8.7 Dike Drainage:
Dikes and other containment areas are designed to contain spills. However, they also collect storm water that needs to be drained. The following precautions shall be taken for dike drainage:
a. The dike valve shall be locked when dike is not being drained.
b. Prior to draining the dike, the associate shall visually inspect for any oil in the water. If there is oil in the water, the technician shall use the oil adsorbent from the spill kit to adsorb the soil prior to draining the dike. The adsorbent shall be disposed off as hazardous waste.
c. A written note should be sent to EHS Department before disposal of the waste.
10.8.8 In the event of an oil spill:
a. The security guard shall activate the emergency contact list, Section 10.1- Emergency Organization and Contacts.
b. The oil spill will be handled as per Section 10.7, Hazardous Material Spill Response and refer Appendix VII- ‘Location of spill controlling equipments’.
c. Training: All persons involved in the oil filling operation and responders shall undergo annual SPCC training plan as outlined.
d. Security: In case of a shut down of the facility, all outlet and drain valves on the bulk storage tank shall be locked in the closed position and capped.
10.10 Bomb Threat Plan
To provide a plan of organized action to be taken upon receipt of a bomb threat during and after normal working hours. Consequently, prior planning to meet the threat must include contact with the local police department.
10.10.2 Specific Guidelines
This procedure is to be used in the event of bombs or bomb threats. Threats or calls relating to bombs should not be disregarded.
a. In the event of a bomb threat, the determination whether to evacuate or not to evacuate the facility is a managerial decision. The source of the threat, the frequency of threats, effectiveness of search procedures, occupancy of building, and weather conditions, are factors that should be considered in this determination.
b. In case of evacuation, the evacuation procedure as per -10.6 Emergency Evacuation Plan will be followed.
10.10.3 Authority for decision of evacuation
A decision on evacuation (complete or partial), Order and direct search, facility shutdown re-entry or re-occupancy after evacuation must be made after all information has been gathered by four or at least any two of the following:
a. Manager Operations
b. Plant Manager
c. Director Manufacturing
d. QA & RA Manager
10.10.4 If suspected device is found:
i. If not already done, evacuate the area as per Section 10.6, Evacuation Plan.
ii. Anything done to minimize damage from explosion (Examples: Shut down nearby operating machinery. Remove sources of combustion and combustibles, shut all interior fire doors) will be done as per the instructions given by Emergency Coordinator, EHS Personnel and the plant Engineer.
iii. If not already done, call the Xxx Police Department when a suspicious item is found. DO NOT TOUCH ANY SUSPICIOUS ITEM. The police department will contact the Bomb Disposal Squad to handle the disposal of bomb.
10.11 Written and Telephone threats
The purpose is to define specific procedure of responding to any threat -written or telephone
a. Written Threats:
i) The person receiving a written threat should:
Handle the envelope or package as little as possible since examination by trained investigators may reveal fingerprints or provide clues as to the identity of the sender. Preserve the entire message, including the envelope, until released to the investigator.
Contact the Security Officer at employee entrance lobby immediately.
10.11.2 Telephone Threats:
a. Telecommunications Operator (8.00 a.m. - 5.00 p.m.)
i) As soon as it is clear that the caller is making a bomb threat, LET HIM FINISH HIS MESSAGE WITHOUT INTERRUPTION. If any response is essential, keep it to one or two words. The following should be observed:
- Background noise
- Caller’s voice: Male/Female, Soft/Loud/Course, etc.
- Caller’s attitude: Vulgar, passive, normal, calm
- Noticeable speech defect
i) These observations may be helpful to the police department.
i) After the caller has finished giving his message, record all the information. Note whether the caller repeated his message or any part of it. Note the exact time of its receipt. Write the message down immediately after the call, EXACTLY AS YOU RECEIVED IT; then fill in the other details you were able to get.
Contact the security officer and inform about the bomb threat.
The Security officer shall immediately contact the EHS coordinator or backup and give information about the bomb threat.
a. Telephone Threats during Shift, Off Hours and Weekends:
i) Person receiving the telephone threat should:
Contact the Security Officer. The security officer shall immediately contact the emergency coordinator, EHS coordinator or emergency shift responder of that shift and back up emergency coordinators and give information about the bomb threat.
ii) Shift Emergency responder, responding to the call from the telecommunications operator, talk to Plant Manager or emergency coordinator on phone. Strictly, follow the instructions received by them for:
Deciding whether to contact Police force and other community responders.
Deciding whether to implement evacuation. If evacuation is necessary, employees will be notified by:
-- Telephone by security personnel
-- Sounding the fire alarm
-- Activate Section10.6” Evacuation Plan”
Deciding whether to form search teams. The search team shall consist of employees familiar with the area(s) to be searched.
10.12 Power Failure
At the time of power failure, the procedure mentioned below is to be followed:
POWER FAILURE RESPONSE PROCEDURE
Activate the back up power generators.
Plant electrical staff to identify / rectify the cause of failure
a) Main incoming power supply failure
b) High tension electrical supply failure
c) Low tension electrical supply failure
Follow Plant Evacuation Procedure if a major fault has been detected that may result in risk to man and material.
Main Incoming Failure
Inform Plant Engineer
Xxx Power Sub Stattion
Xxx Power supply person will detect, rectify fault and resume power supply.
(H T) failure
Inform Plant Engineer
Plant Engineer will identify cause of H T failure
If unable to reset, Plant Engineer will isolate faulty circuit.
(L T) Failure
Plant Electrical personnel to identify cause of failure
Reset breaker immediately
If unable to reset, isolate faulty circuit and turn on unaffected system
Upon L T reset: - Check & identify facility
Emergency Power Supply
Check emergency supply to essential equipment
P A system, Fire Pump.
Isolate all power supply to chillers, pumps, to prevent power surge when supply resume.
Power Supply Restored
Staggered power turn on for facility systems
Check all Facility system back to normal
Evacuated staffs return to production / office upon safety clearance
Incident Report Form
Facility to submit incident report to Safety Specialist.
Corrective action must be included in report
Follow up TNEB or Plant Engineer. Report in case of Main Incoming or H T failure.
10.13 Facility Site Plan
To identify facility sites and respective buildings including emergency contingency requirements
10.13.2 The lists / drawing of the following are as below:
a. Appendix I Emergency Organizational contact list
b. Appendix II Accident/injury and first-aid Reporting System
c. Appendix III List of locations of hazard and fire fighting equipments with plant drawing showing emergency exits and designated assembly area for Evacuation
d. Appendix iV Emergency event reporting system
e. Appendix V List of fire protection/fire fighting equipments
f. Appendix VI Location For Spill Controlling Equipments
g. Appendix VII Location for First – aid Kit
h. Appendix Viii List of telephone contacts of Neighboring Factories, Hospitals/Nursing Homes, Fire station and Police Station