1.

0 PURPOSE:

To describe the procedure for Emergency Preparedness and response identifies

potential for and response to incidents or emergency situations arising out of
operations & activities of the company.

2.0 SCOPE:

This procedure is applicable to any incidents, accidents & other emergency situations
arising out of company's operations and activities including distribution of products or
associated risks further preventing and mitigating the likelihood of illness or injury
associated with them.

3.0 RESPONSIBILITY :

Location Head : Approval of ON SITE/OFF SITE emergency plan.

Location Head : As site main controller, he shall have ultimate responsibility at the
time of any onsite/ off-site emergency.
He shall be responsible for giving preventive mechanisms for any incidences
occurring in the organization.

Factory Manager: Responsible for review the On Site/Off Site Emergency Plan and
ensure mock drills are conducted timely, results of mock drills are taken in to account
while reviewing the plan. Co-ordination for mutual aid agreements with neighboring
industries. Ensure proper delegation of responsibilities towards emergency
preparedness. Submission of updated On Site/Off Site Emergency Plan to Directorate
of Industrial Safety & Health (DISH) and State Pollution Control Board (SPCB).

HOD-HSE: Responsible for implementation of the procedure. Implementation and

review of ON-SITE/ OFF-SITE emergency plan, reporting the performance of
emergency preparedness to management. Check functioning of HSE management
system . Review of addition / modification work orders, Organizing safety committee
meeting and taking corrective actions on points generated.

Section Head (Safety): Prepare On Site/Off Site Emergency Plan, Training to

employees and contractors on usage of Personal protective appliances. Conducting
mock drills . Decontamination and up keep of safety appliances, Regular checkup and
preventive maintenance of Fire Hydrant System, Emergency Siren etc. Ensure
adherence to work permit system and conducting safety promotional activities. Also,
ensuring proper upkeep of spark arresters.

Head (P&A): Ensure pre and postemployment medical checkup and record upkeep as
per requirements of Factory Act. Organize awareness training of on-site emergency
plan to all employees. Ensure head counts are available at any moment. Responsible
to co-ordinate all communications with external agencies/ Press in case of major ON/
OFF-SITE emergencies

Head (Security& Administration): Regular checkup and preventive maintenance of

fire extinguishers, emergency alarm systems etc. Ensuring fitting of spark arresters on
vehicles and up keep of ambulance.
 HOD- Engineering: Preventive maintenance and calibration of safety mountings like
safety valves, vents, PRV’s, interlocks, rupture disc of various circuits related to
reactors, panels, vessels. Also ensuring electrical safety by proper selection,
installation, operation and maintenance of electrical installations.

4.0 METHOD:

4.1 IDENTIFICATION OF PROBABLE EMERGENCY SITUATIONS AND

PREVENTIVE MEASURES:

4.1.1 Each Section Head/ HOD identifies environmental aspects and OH&S risks which
have potential for developing into emergency situation in format for emergency
identification (F:EMS:SYS: 13). Preventive measures to avoid such emergency
situations are also identified in the same format.

4.1.2 Such preventive measures to avoid emergency situations are included in work
instructions wherever applicable. Preventive maintenance and calibration of safety
mountings like safety valves, vents, PRV’s, interlocks, rupture disc of various circuits
related to reactors, panels, vessels is regularly done as per respective process maps for
Preventive Maint. and Instrument Calibration.

4.1.3 Inspection of all the Safety Equipment & appliances (fire extinguishers, SCBA sets,
Safety showers & fire hydrant system) is carried out at least every six month either
internally or with the help of external agency. The remarks of the inspection will be
notified to the HOD-HSE and the deficiencies shall be corrected.

4.1.4 Emergencies are broadly grouped into following categories:

a. Fire
b. Heavy Leakage/spillage/overflow of haz. Chemical
c. Run away reaction and reactor/vessel over pressurization or bursting
d. Emergency shutdown of plant operations due to other emergencies like
earthquake or major cyclone or flood.
e. Transportation accidents involving Product and Employees
f. Fire/Toxic release where emergency may have off-site implications

4.1.5 To control emergencies related to fire, fire extinguishers of suitable type have been
provided at all critical locations depending upon type of fire. Fire Hydrant network
has been provided to control emergencies related to fire. Personnel working in the
area have been trained for use and selection of the right type of fire extinguishers.

4.1.6 For emergency related to leakage and spillage work instructions for spillage and
leakage control have been prepared in all plant areas.

4.1.7 For emergencies related to runaway reaction and reactor and vessel pressurization
conditions responsible for such emergencies have been identified and preventive
measures are taken. EMP’s/OHSMPs have been prepared wherever found necessary.
Various preventive and control measures are also listed in onsite emergency plan.
Testing of pressure vessels is done and records maintained.
4.1.8 For emergency shutdown of the plant due to emergency situations arising out of any
catastrophe like earth quack, cyclone or any offsite emergency, an emergency
shutdown procedure exists for all critical activities.

4.1.9 To deal with emergencies related to transportation, drivers are given TREM Card and
they are trained to handle any emergency situation while on road. Venders supplying
raw material and other chemicals are also insisted to provide TREM card and training
to their drivers while carrying material.

4.1.10 Emergencies related to fires and Toxic releases are dealt in accordance with On-site /
Off Site emergency plan.

4.2 ON SITE/OFF SITE EMERGENCY PLAN:

4.2.1 On site/Off Site emergency plan is prepared to handle any emergency situation within
the company considering all identified emergency conditions. Guidelines of Factories
Act are also followed while preparing onsite/off Site emergency plan.

4.2.2 HOD-HSE updates the Onsite/Off Site emergency plan this is approved by Location
Head. Approved On site/ Off Site emergency plan is sent to DISH and SPCB for their
approval also.

4.2.3 For any emergency situation like fire, major toxic gas release etc., the action plan
given in On-site/Off-site emergency plan is followed.

4.2.4 Identified process hazards in different sections in the company are also listed with
their preventive and control measures available, in the on-site/ off site plan.

4.2.5 Statutory safety audit is conducted for individual plants to identify prevailing unsafe
conditions in plant. Also, plant safety inspection is done by Safety Officer through
inspection rounds in each plant as per the schedule. Findings of such audits are
reviewed and Corrective action is taken to remove such unsafe conditions.

4.2.6 On-site/Off Site emergency plan is amended as and when need arises and reviewed
every 2 years for continued suitability. The findings of Mock Drill rehearsals &
findings from actual emergencies are recorded and included in the emergency plan,
wherever necessary.

4.2.7 In case of On-site or Off-site emergency arising in nearby industry, Location Head
shall provide requested assistance to the industry in possible ways if asked to do so by
concerned industry.

4.2.8 Factory Manager shall co-ordinate with neighboring industries for mutual aid and
maintains updated list of such industries.

4.2.9 HOD-HSE shall ensure that emergency control center is equipped with items as
mentioned in ON-SITE plan on continuous basis.

4.2.10 Inspection of all the Safety Equipment & appliances (fire extinguishers, SCBA sets,
Safety showers & fire hydrant system) shall take place at least every six month either
 internally or with the help of external agency. The remarks of the inspection will be
notified to the HOD-HSE and the deficiencies shall be corrected.

4.3 RESPONSE TO ACCIDENT/ INCIDENT INVOLVING TRANSPORTATION/

STORAGE/ DISTRIBUTION OF THE COMPANY'S PRODUCTS :

4.3.1 All drivers of carriers shall be provided necessary information for chemicals in
distribution, in the form of TREM-Card by materials dept. while leaving the premises.

4.3.2 On receiving the information regarding any emergency situation during distribution of
product , Location Head shall arrange to send a trained person (team) to mitigate the
emergency situation & implement suitable corrective action to prevent emergency
situation (i.e. during transportation from factory to customer to the extent feasible ) in
the future.

4.4 PLAN FOR TESTING OF EMERGENCY PROCEDURES:

4.4.1 Plan for testing the emergency procedure or mock drill is prepared by Safety Officer/
HOD-HSE, which is communicated to concerned persons. If emergency related to
offsite effects is being considered, intimation for conducting drills is communicated to
neighboring industries and concerned officials. Areas to address for conducting drills
shall be listed in Mock-Drill Calendar tentatively prepared for 3 years and firmed up
plan for current financial year. The Prioritization shall be based on certain risk
assessment. If necessary, Inputs for such plan shall be taken from following :

a. Transportation Accidents
b. Fire Exposure.
c. Emergency shutdown of plant operations
d. Annexure: 5 (Identified Emergency Conditions) of ON-SITE/OFF SITE
EMERGENCY PLAN.
e. Any other procedure related to emergency situation.

4.4.2 Mock drills to test the implementation of the written emergency response plan, are
conducted Quarterly and findings are recorded in mock drill observation record
F:EMS:SYS:14 and Deviations on plan shall be approved by Site Main Controller.
Inputs for recording observation in F:EMS:SYS:14 shall also be taken from
Mock-Drill Time assessment report F:EMS:SYS:48. In light of Mock-drill
observations, Risk Register or Aspect Impact Register shall be reviewed and revised,
if necessary.

4.4.3 HOD-HSE along with Safety Officer shall arrange for related training program for
key persons responsible for communications in the event of emergency at regular
intervals.

4.4.4 HOD-HSE along with HOD- P &A arranges training for awareness about onsite
emergency plan and OH&S risks to all company employees

4.4.5 List of key personnel and ERT members is available in on-site/Off-site emergency
plan.
4.4.6 List of updated telephone numbers to be used during emergency is displayed at
security Gate, ECC.

4.5 MITIGATION OF ENVIRONMENTAL ASPECT OR HEALTH HAZARD

DURING & AFTER ACTUAL EMERGENCY :

4.5.1 The mitigation of Environmental Aspect or H&S hazard in such conditions is done as
per relevant work instruction of leakage/ spillage and ON site/Off-site Emergency
Plan.

4.5.2 While mitigating all environmental aspects and health hazards generated during
Emergency, efforts shall be made to minimize their impacts and risks. Emergency
Response Team (ERT) has been formed to reduce impact and contain the risks at the
time of emergency and is specified in onsite/off-site emergency plan.

4.5.3 Inspection of plant by HOD-HSE and Incident controller is done after actual
emergency, based on the feedback on status, Site Main Controller shall declare
conditions fit for restart. In case of Off-Site emergency, Site Main Controller
coordinates with the Govt. authorities for re-start up.

4.6 EMEREGENCY REPORTING:

4.6.1 HOD-HSE is responsible to prepare a consolidated report of any emergency taking

place in the organization, detailing sequence of event leading to the emergency.

4.6.2 Management shall review these with all persons covered to provide preventive
measures like revision of the relevant work instructions, providing additional
preventive measures and improving knowledge on emergency control to all
employees, as deemed necessary.
4.6.3 Environmental impact or OH&S risks arising out of emergency shall be assessed by
HOD-HSE in consultation with Location Head.

4.6.4 HOD-HSE shall report about the relevant emergency incidents to relevant Govt.
authorities appropriately within reasonably practical time without compromising on
statutory provisions..

4.6.5 HOD-HSE shall ensure that all accidents/incident happening in the organization are
analyzed and preventive measures are taken to avoid possibility of any loss of health,
life or property turning into an emergency. Analysis is carried out and corrective and
preventive action is taken.

5 REFERENCE:

1. ON-SITE/OFF-SITE Emergency Plan

2. Safety Manual.
3. Work Instruction for spillage control
4. TREM card – To include information & declaration of associated Risks.
5. Safety information card : To include information and measures to be taken by visitors
entering in company premises.
6. Site specific relevant Process Maps for preventive maintenance –

6 RECORDS :

Name of record No Retention Location

period
Emergency identification F:EMS:SYS:13 2 years Respective Dept.
Plant audit for environment safety -------- 2 years HOD-HSE
Onsite emergency plan 2 years HOD-HSE
Mock drills observations F:EMS:SYS:14 2 year HOD-HSE
Mock drills time assessment F:EMS:SYS:48 2 year HOD-HSE
report
7 REVISION HISTORY:

Revision No Details of changes Reason for change

06 Amended as per requirement towards alignment and To align with other
adequacy. manufacturing site
requirement
07 Amended as per Audit observation and corrected in Audit Observation
emergency section
08 HSE Manual section reference changed Amendment in
Manual

Signature Date
Prepared By: MR&A 01.12.2017

Approved By : Location Head 01.12.2017