Occupational Health, Safety and Environment Risk

Assessment Procedure

1. Purpose
The purpose of this procedure is to define mechanism and responsibilities for ongoing
identification of Safety, Environment and Occupational Health hazards and their associated
risks.

2. Scope
This procedure is applicable to the identification of hazards and their risks as a result of
activities and processes of AEPL.
It is applicable for:
 Initial risk assessment
 Annual Review for updating the information
 Conducting risk assessment at the time of change in existing activities and processes.

3. Responsibility
 EHS Manager is responsible for the implementation of this procedure.
 Zonal Incharges are responsible for identification of OH&S and environmental hazards and
risks in their respective areas.

4. Procedure

4.1 Risk Assessment Team

The OH&S and Environment hazards of activities, process and products at AEPL are identified
through risk assessment process conducted by the EHS Task Force.
The EHS Task Force comprises of EHS Manager, Zonal Incharges and employee. The team
members must be familiar with the processes and situations to be assessed (eg; location,
equipment, task).

4.2 Competency and Training of members of Risk Assessment Team

EHS Manager ensures before initiating the risk assessment exercise, the members of the task
force must be competent to perform the risk assessment process.
The members must have sufficient knowledge of:
 the area, department, or activity to be assessed
 the risk assessment process
 an understanding of hazards and the ability to identify hazards

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 current health and safety practices

 when and how to seek specialist advice.
The competency requirements must be fulfilled through one day formal training on the risk
assessment process. The training contents covers:
(a) Types of OH&S and Environment hazards
(b) Identification of hazards
(c) Risk assessment methodology
(d) Knowledge of common OH&S and Environment Operational Controls

4.3 Occupational Health & Safety Hazard Identification and Risk Assessment Process

The hazard identification and risk assessment covers:

i. Routine & non-routine activities/processes (normal, startup, shutdown, abnormal/
emergency conditions);
ii. Activities of all personnel having access to the work place (including subcontractors and
visitors);
iii. Facilities at work place whether provided by AEPL or others; such as contractor,
customer etc.

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4.3.1 Occupational Health & Safety Hazards

The hazards identification is carried out for the following hazards:
1. Ergonomics (Physical)
2. Mechanical (Associated with power driven machine)
3. Falling
4. Impact & Acceleration
5. Heat & Temperature
6. Pressure
7. Electrical
8. Fire
9. Toxicity & Explosion
10. Radiation
11. Noise
12. Vibration
13. Biological

While conducting the hazard identification, the information regarding the hazards and the risk
involved is determined from any of the following sources:
 Interviewing people associated with the process/ activity
 Self-examination, observation, results of measurements and monitoring
 Examination of existing management practices and procedures
 Feedback from previous incidents/ accidents
 Views of interested parties (if any)
 Applicable Legal and Regulatory requirements.
The hazards associated with the location and equipment are listed on „OH&S Risk Assessment
Sheet‟ EHS-P 01-F 01.

Note: For Common and Specific tasks „Task Hazard Analysis‟ (THA) methodology is followed.
(Refer Section 4.5)

4.3.2 Evaluation of Occupational Health & Safety Risks

The OH&S risks are determined by rating them in two phases, i.e. with existing controls (HRN I)
and with additional control (HRN II) if risk exceeds the tolerable limits.
(a) Hazard Rating Number (HRN I)
In HRN I the OH&S risks are assessed keeping in view the existing “operational controls”.

The OH&S risks are determined on the basis of following parameters:

i. Likelihood of occurrence (a)

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ii. Frequency of Exposure (b)

iii. Degree of Possible Harm to Human Life (c)
iv. Degree of Possible Harm to asset (d)
v. No. of Persons at Risk (s) (e)

The factors are rated on the scale of 0, 1,2,3.., as per criteria defined in the „Rating Criteria for
OH&S Risk Assessment‟ (APPENDIX I).
The overall significance of risks is determined by putting the above mentioned five factors in the
following formula.

OH&S Risk = a × b × (c + d) × e

All OH&S risks having rating above „20‟ shall be treated as “Significant Occupational Health &
Safety Risks”.

The significant OH&S risks require control measures to eliminate or reduce the risk of loss to a
tolerable level.

Basis for categorizing significant risk are:

 Potential for violation of AEPL‟s OH&S Policy
 Potential for legal violation
 Potential for fatalities or multiple injures or significant asset loss or damage to environment.
The record of OH&S Risk Assessment (HRN I) is maintained on „OH&S Risk Assessment Sheet‟
EHS-P 01-F 01.

The hazards with significant risks are controlled by establishing Objective and Targets and or
through application of „additional operational controls‟ by considering the following hierarchy:
i. Elimination
ii. Substitution (reduction)
iii. Isolation (enclosure)
iv. Defenses (protection)
v. PPEs

The record of additional operational controls on significant OH&S risks is maintained on OH&S
Risk Assessment Sheet EHS-P 01-F 01.

(b) HRN II (Significant Risks that requires Additional Controls)

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After application of “additional operational controls” on the significant risks identified in HRN I,
their risks are re-determined, in accordance with the same formula as used for HRN I {refer
section 4.3.3 (a)}.
The record of HRN II (risk rating with additional controls) is maintained on OH&S Risk
Assessment Sheet EHS-P 01-F 01.

4.4 Evaluation of Environmental Hazards & Risks

4.4.1 Environmental Hazards

While conducting Environmental hazards assessment, the hazards considered will be the
following:
1. Emissions to air
2. Water Discharges
3. Solid non-hazardous waste
4. Solid Hazardous Waste
5. Consumption of natural resources/ Energy
6. Noise
7. Heat
8. Odor
9. Dust
10. Vibration
11. Effect on visual/ aesthetics
12. Use of Ozone depleting substances
13. Use of radioactive/ nuclear material
For identification of environmental hazards and risks, each process/ activity, product and service
is assessed for its inputs and out puts. The inputs can be raw materials, utilities etc. The out
put can be atmospheric emissions, liquid effluents, noise, waste, products etc.

4.4.2 Evaluation of Environment Risks

The environmental risks are determined by rating them in two phases, i.e.; with existing
controls (HRN I) and with additional control (HRN II), if risk exceeds the tolerable limits.
(a) Hazard Rating Number (HRN I)
In HRN I the environmental risks are assessed keeping in view the existing “operational
controls”.

The following formula is used for environmental risk assessment:

a) Likelihood of occurrence (X)
b) Severity (Y)
Severity
The associated factors considered for Severity are:

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 Health effects (A)

 Safety hazards (B)
 Effect on air quality (C)
 Effect on land (D)
 Effect on water quality (E)
 Size of impact (F)
 Extent of regulatory violation (G)
 Effect on the public image of the organization (H)
 Cost of correcting the impact (I)
Severity (Y )= (A + B + C + D + E) × F × G × H × I
The factors are rated on the scale of 0, 1,2,3.... as per criteria defined in „Criteria of
Environmental Risk Assessment‟ (APPENDIX II).
The overall significance of risks is determined by using the formula.

Environmental Risk = Likelihood of Occurrence X Severity

The results of environmental risk assessment (HRN I) will be maintained on „Environmental
Risks Sheet‟ EHS-P 01-F 02.
All environmental risks having rating equal to or above „30‟ shall be treated as “Significant”.

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Significant Environmental Risks are those which are not tolerable due to any of the following
reasons:
 Violation of AEPL‟s policy, objectives and targets.
 Violation of legal or regulatory requirements.

The significant environmental risks require control measures to eliminate or reduce the risk of
impact to a tolerable level either establishing objective or through application of additional
controls by considering the 4R methodology i.e; Reduce, Reuse, Recover, Recycle.

The record of additional operational controls on significant environmental risks is maintained on

„Action Plan for Significant Environmental Risks‟ EHS-P 01-F 02.

(b) HRN II (Significant Environmental Risks that requires Additional Controls)

After application of “additional operational controls” on the environmental hazards with
significant risks identified in HRN I, their risks are re-determined, in accordance with the same
formula as used for HRN I {refer section 4.4.2 (a)}.
The results of environmental risk assessment (HRN II) will be maintained on „Register of
Environmental Risks‟ EHS-P01-F 02.

4.5 Task Hazard Analysis (THA)

For common and specific tasks „THA‟ is conducted. The methodology for conducting the THA is
defined below:
(a) Clearly define the task.
(b) Break down the task into sequence of steps.
(c) Identify Hazards Associated with each step and harm/ loss that may result from each
hazard.
(d) Identify existing controls

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(e) The risk is evaluated by using formula Severity X Likelihood. The criteria for rating has
been defined in the appendix 3. All risks having rating equal to or above „24‟ shall be treated
as “Significant”.
OR
The risk can also be calculated in accordance with the procedure defined in para 4.3.3 of
the procedure. In such cases the significant risk rating will be 15.
The hazards with significant risks are controlled by establishing Objective and Targets and or
through application of „additional operational controls‟
The record OH&S risks of tasks and their controls is maintained on „Task Hazards Analysis
Record‟ EHS-P 01-F 03.

4.6 Risk Assessment Update

EHS Manager ensures that hazards and risk related to the activities/processes, tasks and
equipment are kept current by conducting the same assessment:

 After every year- (to update the system) and

 Before change in existing activities/ Processes/products/ facility/ equipment.

 Change in laws & regulations.

5.0 Records to be maintained

Number Records Retention Maintained by

Period
Location, Process, Task and Ongoing EHS Manager
Equipment Inventory Record
EHS-P 01-F 01 OH&S Risk Assessment Sheet Ongoing EHS Manager
Action Plan for Significant OH&S Ongoing EHS Manager
Risks/Management Program
Environmental Impact Assessment Ongoing EHS Manager
EHS-P 01-F02
Sheet
Action Plan for Significant Ongoing EHS Manager
Environmental Risks / Management
Program
EHS-P 01-F 03 Task Hazard Analysis Sheet Ongoing EHS Manager
 on going means only current record shall be maintained.

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Reviewed by: Date:

EHS Manager

Approved by: Date:

Plant Manager

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APPENDIX I (Rating Criteria for OH&S Risks)

LIKELIHOOD OF OCCURRENCE (a)

SCALE
Impossible --cannot happen 0
Almost Impossible --Possible in extreme circumstance 0.1
Highly Unlikely --though conceivable 0.5
Unlikely --could happen but only rarely 1
Possible --but unusual 2
Even Chance --could happen 5
Probable--Not surprised 8
Likely--To be expected 10
Certain ---No doubt 15

SEVERITY OF RISK

FREQUENCY OF EXPOSURE (b)

SCALE
Infrequently 0.1
Annually 0.2
Monthly 1
Weekly 1.5
Daily 2.5
Hourly 4
Constantly 5

DEGREE OF POSSIBLE HARM TO HUMAN LIFE (c)

SCALE
Scratch or bruise 0.1
Laceration or mild ill-health effect 0.5
Break of a minor bone, or minor temporary occupational
1
illness
Break of a major bone, or minor permanent occupational
2
illness
Loss of one limb, one eye, or serious temporary
4
occupational illness
Loss of limbs, eyes, or serious permanent occupational
8
illness
Fatality 15

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DEGREE OF POSSIBLE HARM TO ASSET (d)

SCALE
No effect / Insignificant 0
Negligible damage to asset / facility that can be repaired in very less
1
time.
Minor damage -- to a facility or equipment 2
Major damage -- Cause complete damage to a part of facility or
3
equipment
Catastrophic--cause complete damage to the facility 4
No. of PERSONS AT RISK (e)
SCALE
0-2 persons 1
3-7 persons 2
8-15 persons 4
16-50 persons 8
More than 50 persons 12

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APPENDIX 2 (Rating Criteria for Environmental Risks)

LIKELIHOOD OF OCCURRENCE
CLASSIFICATION RATING
Amost Impossible- Possible in extreme circumstances 1
Highly Unlikely- though conceivable 2
Possible- but unusual 3
Even chance- could happen 4
Likely- to be expected 5
Certain- no doubt 6
SEVERITY
(A) HEALTH EFFECT
SEVERITY
CLASSIFICATION OF
IMPACT
No significant effect 0
Cause only irritation on exposure 1
Temporary incapacitation or injury due to continued exposure 2
On short exposure cause serious temporary or residual injury 3
Kill/deform people or animals on very short exposure 4
(B) SAFETY HAZARDS
SEVERITY
CLASSIFICATION OF
IMPACT
Not combustible 0
Must be pre heated before ignition can occur 1
Materials that must be moderately heated or exposed to 2
relatively high ambient temp. before ignition occurs
Materials can be ignited under almost ambient temperatures 3
Materials can be rapidly or completely vaporize at atmospheric 4
temperatures

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(C) EFFECT ON WATER QUALITY

CLASSIFICATION SEVERITY OF
IMPACT
No impact 0
Contaminate water but no long term effect and or effect
aquatic life
May have long term effect on water quality 2
Poison to aquatic and human life 3
(D) EFFECT ON LAND
CLASSIFICATION SEVERITY OF
IMPACT
No impact 0
Causes minor soil contamination rectifiable in short term 1
Cause ground water contamination 2
Long term effect on land 3
(E) EFFECT ON AIR QUALITY
CLASSIFICATION SEVERITY OF
IMPACT
No impact on air quality 0
Contaminate air and produce odor but immediately reversible
1
impact
Contaminate air and impact reversible in medium to long term 2
Poison to life 3
(F) SIZE OF IMPACT
CLASSIFICATION SEVERITY OF
IMPACT
No significant effect 1
Confined within plant boundaries/localize boundary 2
Effect nearby area 3
Within city 4
Country/Global 5

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( G) EXTENT OF REGULATORY VIOLATIONS

CLASSIFICATION SEVERITY OF
IMPACT
Not mentioned in the regulations/ No Violation 1
Partial violation of laws/regulations 2
Violation due to process constraint 3
Complete violation 4
(H) EFFECT ON PUBLIC IMAGE OF THE COMPANY

CLASSIFICATION SEVERITY OF
IMPACT
No effect 1
City/local repute 2
Country wide repute 3
International repute 4
(I) SOCIAL & ECONOMIC COST
CLASSIFICATION SEVERITY OF
IMPACT
Cost impact insignificant 1
Low 2
Medium 3
High 4

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APPENDIX 3 Rating Criteria for THAs

Consequences (S)
Multiple Death 10

Single Death 8

Major injury , Disabling illness, major damage 6

Loss time injury , illness, damage 4

Minor injury, minor damage 2

Delay only 1

Likelihood (L)
Certain on imminent 10

Very likely 8

Likely 6

May happen 4

Unlikely 2

Very Unlikely 1

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