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NUCLEAR FUEL COMPLEX SAFETY ENGINEERING DIVISION. PRESENTATION BY G.P.SAISANATHAN SCIENTIFIC OFFICER (SAFETY). MANAGEMENT OF OCCUPATIONAL HEALTH AND SAFETY ASPECTS AT NFC. A comparison of NFC safety aspects with IS 18001:2000 standards.
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NUCLEAR FUEL COMPLEX SAFETY ENGINEERING DIVISION PRESENTATION BY G.P.SAISANATHAN SCIENTIFIC OFFICER (SAFETY)
MANAGEMENT OF OCCUPATIONAL HEALTH AND SAFETY ASPECTS AT NFC A comparison of NFC safety aspects with IS 18001:2000 standards
Bureau of Indian Standards The National Standards body of India through its Industrial Safety Sectional Committee, CHD 8 has formulated IS 18001 : 2000 Occupational Health and Safety Management System – Specification with guidance for use.
IS 18001 provides the industry a systematic, structured and documented framework to address OH&S issues effectively and in an auditable manner. NFC is an ISO:9001 organization since 2001.
The standard specifies the requirement of OH&S Management System for assessment and certification purpose. 4.1 - General Requirements
IS 18001:OH&S System Covers five general areas: 4.2 Commitment and Policy 4.3 Planning 4.4 Implementation and Operation 4.5 Measurement and Evaluation 4.6 Management Review
IS 18001:OH&S System CONTINUAL IMPROVMENT Commitment and Policy Management Review • Planning • OHS risk assessments. • Legal • Objectives • OH&S Mgt.programs ACT P L A N • Measurement and • Evaluation • Performance measurement • Incidents / Non-conformance • corrective / preventive action • Records • OHSMS audits • Implementation and • Operation • Structure, responsibility • training, awareness • Consultation & Commn. • Documentation, control • Operation control • Emergency preparedness DO CHECK
4.2 Commitment and Policy Top management’s objectives for and commitment to improve OH&S performance
NFC management accords utmost importance to safety – industrial, radiological, personnel as well as environmental. NFC Management firmly believes and is committed to prevent all injuries. Safety is regarded as a line management responsibility and gets precedence over other production objectives.
Safety Policy of NFC • Provides safe working facilities to the • workers. • Effluents are neutralized and dumped in (Solar Evaporation Ponds) SEP. • Used water is treated and reused for gardening. • Toxic gases are scrubbed before released • into the atmosphere (as per PCB standards)
OH&S management systems requires the senior management of an organization to define, document and endorse its OH&S policy ensuring the commitment to achieve a high level of OH&S performance. NFC Management is committed to
Observe national and international regulations on safety as applicable. • Create and maintain a safe and healthy work place • Establish safe work practices • Ensure effective safety training • Create interest and enthusiasm in safety • Develop personal responsibility for safety NFC Management believes that every job can be done safely and without affecting the health of employees.
NFC has a written Safety Policy. Published in three Languages viz., Telugu, Hindi and English. • INITIALLY DRAFTED IN NOVEMBER, 1990. • FIRST REVISION WAS MADE IN AUGUST 1997. • SECOND REVISION IN AUGUST 2002.
4.2.1 Leadership and commitment – to define and demonstrate its leadership and commitment to OH&S by allocation of adequate resources ensuring continual improvement in its OH&S performance;
Agencies • Chief Inspectors of Boiler • Pollution Control Board • Electricity Authority • Hazardous Chemicals Transport (M.V. Act) • Chief Controller of Explosive, etc.,
NUCLEAR FUEL COMPLEX (NFC) PLANTS ARE GOVERNED BY: • ATOMIC ENERGY REGULATORY BOARD (AERB) • SAFETY REVIEW COMMITTEE FOR OPERATING • PLANTS (SARCOP) • CORPORATE SAFETY COMMITTEE (CSC) • CIVIL ENGINEERING SAFETY COMMITTEE FOR • OPERATING PLANTS (CESCOP)
4.2.2 Initial OH&S review - to carry out an initial review of the existing arrangements for management of OH&S. Initial review not done we are in the process of doing the same.
4.3 Planning 4.3.1 Planning for hazard identification, risk assessment and risk control • Elimination / substitution • Engineering control • Administrative control • Personnel Protective Equipment
Safety management started on the principle of 4E concepts. • Engineering • Enforcement • Education • Elimination
4.3.2 Identification of hazards and assessment and control of risks – the organization shall establish and maintain procedures to identify hazards and assess and control risks related to its activities over which it has control influence. ONSITE Emergency plans are available for LPG Ammonia Chlorine
General and obvious hazard identification is done for few activities. • Formal hazard identification / risk control procedures are to be developed. • Hazard assessment and consequence analysis done. • - Anhydrous ammonia storage system • - LPG storage system • - Hydrogen storage system • - Chloride storage system
The identification of hazard, risk assessment and control is the most important part of this standard. A. Safety Engineering Division is involved right from the design stage for any process modification. B. Safety clearance is necessary for installation of new machines, processes and plants. C. Work permits are mandatory.
D. An authorizing system is in practice for drivers of forklifts, jumbos and crane operations[Ref:File NO.S-57] E. ON-Site emergency plans for major hazardous substances like LPG, Ammonia, Chlorine, are drawn up [Ref:File NO.S-76] F. Several safety regulations are issued by SED. SED promotes safe working as per various safety acts / rules. G. Safety manuals / code of practice for several operations are prepared.
4.3.1 Responsibility and Accountability – the organization shall define, designate, document and communicate OH&S responsibilities, accountabilities, authority to act and reporting relationships for all levels of functionaries; The Safety Policy/ Standing Fire Orders document defines the responsibilities of individuals in writing. Copies distributed among the employees.
4.3.3 Legal and other requirements – the organization shall establish and maintain procedures to identify, have access to and understand all legal and other requirements to which the organization subscribes and that are directly attributable to the OH&S aspects of its activities. The organization shall keep track of the changes of the legal requirements to maintain regulatory compliance’s. Enforcement of various rules and regulations are in vogue.
Enforcement of various rules and regulations are in vogue. • APPLICABLE DOCUMENTS • Safety Policy • Technical Specifications. • Standing Fire Orders • Factories Act, 1948. • AERB (Factories) Rules 1996. • Environment Protection Act and Rules • Explosives Act and Rules. • IE Act and Rules. • Other Statutory requirements.
4.3.4 Objectives, targets and performance indicators - the organization shall establish and maintain documented OH&S objectives and targets at each of its relevant function and level. When the objectives and targets are set, the organization shall consider establishing measurable OH&S performance indicator with a view to evaluate OH&S performance; and Our Target is to achieve “ZERO“ Accident Status Frequency Rate Severity Rate Injury Index
4.3.5 Initial and on-going planning – the organization shall establish and maintain programme(s) for achieving its objectives and targets. It shall include not only the designation of responsibility for achievement of objectives and targets but also the means and time frame by which they are to be achieved. Time to time various types of safety programmes are conducted.
4.4.1.2 Training, awareness and competence – to identify the training needs, the competency standards and to meet them through training programme. The organization shall provide adequate training to those whose work may affect OH&S aspects of its activities. In-plant training programmes are conducted trade wise.
4.4.2 Support action – establish and maintain procedures for channels of communications and also for relevant and timely reporting of information required for monitoring and continual improvement of OH&S and performance. Management supports and cooperates in all activities of Safety programmes.
4.4.2 Document control - to establish procedures for control of documents required by these management system. All statutory test and examination records are maintained. Statutory medical checkups are done and records are available.
All safety related Unusual Occurrences / Incidences and Accidents (minor and major) and non-injury are well documented. AERB.SM/IS-1 Data Base Management Guidelines 4.4.2 Documentation – to establish and maintain procedures for documentation on paper or on electronic forms.
4.4.2.5 Record and information management – to establish procedure for record and information management to ensure effective and quick identification, collection, retrieval, indexing, retention and disposition of pertinent OH&S management system
4.4.3 Operational control – to identity those operations and to established and maintain documented procedures to cover situations where their absence could lead to deviations from the OH&S policy and the objectives and targets. Technical Specification, Plant Safety Manuals are available. Preventive maintenance records.
4.4.3.1 Design and engineering – to ensure that health and safety is considered at the initial design and planning phase. Where the hazard cannot be eliminated or substituted for one that presents lower risks, engineering control shall be adopted. Master Scheme Services Group. (MSSG clearance) Safety Clearance - from Safety Engineering Division.
4.4.3.2 Purchasing – to establish procedures for purchasing of goods and services including maintenance under contract to others to ensure that purchased goods and services conform to the organizations OH&S requirement. AERB/SG/IS-3 - Guidelines for PPE. Products confirming to National and International Standards are purchased.
AERB/S/IRSD-1 Standards for Fire Protection System of Nuclear Facilities. Mock Drills conducted regularly. Guidelines 4.4.3.3 Contingency preparedness and response – to establish procedure for contingency preparedness and response and to plan for contingency to advance; and
AERB/SG/EP-3 On-site Emergency Preparedness Plans Guidelines 4.4.3.4 Critical incidents, recovery plan – to establish procedure for critica incident recovery plan to aid in plant employee recovery as soon as possible after the cessation of the event. CIRP allows the plan to minimize the time required to return to normal operation and to assist employees who are not injured but who have witnessed an incident, to cope up with the trauma.
4.5.1 Inspection and testing - to establish procedures for planning and conducting on-going inspection, testing and monitoring on regular basis; • All statutory inspections. • ISI is being done for critical equipment. • Hazardous substances storage installation. • Sprinkler testing of LPG. • Fire hydrant system.
4.5.2. Internal audit - to establish procedures for periodic OH&S system audits to be carried out internally and Non conformance, corrective and preventive actions - in light of the findings, non conformances, conclusions and recommendations as a result of monitoring, audits and other reviews of OH&S -MS procedure for corrective and preventive actions to be established.
Plant safety inspections are carried out by SED. Corporate Safety Committee (CSC). Safety Review Committee for Operating Plants (SARCOP). Regulatory Inspection Team of AERB. Safety Related Deficiencies detected during these inspections are communicated to plant. The responsibility for overcoming the Safety Related Deficiencies (SRDs) lies with the respective plants / line managers.
4.6 - Management review Top management review OH&S to ensure continuing suitability, adequacy and its effectiveness. The management review shall consider. Corporate Safety Committee (CSC). Safety Review Committee for Operating Plants (SARCOP). Regulatory Inspection Team of AERB.
Regular reviewed by NFC Management in various forums The overall performance of the OH&S management systems. The performance of individual elements of the systems. The finding of audits; and Internal and external factors, such as changes in organizational structure, legislation pending, introduction of new technology, etc, and shall identify what action is necessary to remedy any deficiencies.
Important management concepts incorporated in IS 18001 Standards • Management by objectives (MBO) • Management by group risk assessment • Management by walking about • Deming’s PDCA cycle • Continual improvement
