Theme Module -14

Off-site Emergency Management Plan (OffSEMP)

industrial Disaster Risk Management

Contents

1. Planning Principles for an Emergency Plan (EMP)

2. Intention of the module

2.1. Off-site Emergency Management Plan (OffSEMP)

2.2. Approach for OffSEMP

3. Emergency control organisation and responsibilities

3.1.Need for Incident Response System (1RS)

3.2.Important Roles and Responsibilities of various stakeholders

3.3. Incident Response System (IRS)

4. Emergency Operation Centre (EOC)

5. Coordination with NDRF and SDRF

6. Coordination with neighbouring states

7. Conclusion

8. Annexure

9. Glossary

10. References

Main objectives of Off-site Emergency Management Plan (OffSEMP)

The objective in emergency management planning is to ensure that everyone knows: what are the hazards and risk in the district what and how to do in the event of an chemical emergency; and preparations for potential and unexpected incidents in the industries located in the district.

The types of emergencies to plan for include fire, explosion, toxic releases, injuries and rescues in the event of hazardous substances.

OffSEMP improves local, district, state and national capacity to respond to disasters and public health emergencies, scaling up the actions with vulnerable communities in health promotion, disease prevention and disaster risk reduction.

As per our Indian regulations we have regulatory provisions that On-site Emergency Management Plan (OnSEMP) will be prepared by industrial units and Off-site Emergency Management Plan (OffSEMP) by District Collector for his/her respective District. Both modules have some overlaying parts hence where we feel to highlight the issues in the interest of readers those have been highlighted or repeated in both the modules ThemeModules i.e.13 and 14.

The present Module ThemeModule 14 deals with the OffSEMP and module ThemeModule 13 deals with the OnSEMP. We advice readers to read these two modules in conjunction to have an over all understanding of the on- and off-site emergency management plans.

The emphasis is given on what should be the response and command structure. It also provides new way of thinking for OffSEMP

The module does not cover multi-hazard analysis in terms of both natural and man-made and hence the earthquake and flood scenario consideration areexcluded.

1. Planning Principles for an Emergency Plan (EMP)

An OffSEMP covers designated actions that the civil administration must take to ensure the safety of deceased plant and local community from chemical fire and other emergencies. All civil local, district and state departments are required to establish an emergency action plan under regulations and guidelines developed by Ministry of Environment and Forests (MOEF) and National Disaster Management Authority (NDMA).

OffSEMP need different approach in comparison to OnSEMP. OECD (Organisation for Economic Co-operation and Development ) has suggested this cycle in its "guiding principles for chemical accident prevention, preparedness and response" to address the wide range of issues that need to be dealt with, in order to ensure effective chemical safety, i.e., the actions that should be taken by industry (including labour), public authorities, communities and other stakeholders to:

Fig-1 Emergency/Disaster Management Cycle

  • minimise the likelihood that an accident will occur (prevention);
  • mitigate the consequences of accidents through emergency planning, land-use planning and risk communication (preparedness/mitigation/risk reduction); and
  • limit the adverse consequences to health, environment and property in the event of an accident (quick response/recovery).

It also includes lessons that need to be learnt from the experiences of past accidents and other unexpected events (follow-up) in order to reduce future incidents (prevention).

It is often difficult to clearly delineate which issues and actions come within each of these stages, and there is significant overlap among them. Therefore, the entire process is sometimes described as a "Safety Continuum" or "Emergency/Disaster Management Cycle" (see Fig - 1). In general, industrial disaster mitigation focuses on control at source of the causes leading to emergencies through prevention, preparedness and response so that response comes into play only if all efforts fail.

2. Intention of the module

The intention of this module is to help District collector in developing an effective OffSEMP with following:-

(a)to develop an OffSEMP that should be concise and informative so that responsible person of the emergency control organisation should be able to quickly refer to the action plan to determine important functions that are being carried out;

(b)and not to use the OffSEMP just as telephone directory but should be able to manage an emergency and shall be made applicable

  1. to prevent casualties - both on-site and off-site;
  2. to reduce damage to property, machine, public and environment;
  3. to develop a state of readiness for a prompt and orderly response to an emergency and to establish a high order of preparedness (equipment, personnel) commensurate with the risk;
  4. to provide an off-site incident management organogram with clear missions and lines of authority (incident command system, field supervision, unified command) in line of Incident Response System;
  5. to ensure an orderly and timely decision-making and response process (notification, standard operating procedures);
  6. to maintain good public relations;
  7. (v) to provide reliable and useful information in hazard and risk to civil authorities to help them in development of preventive and response mechanism;
  8. to help district authority in development of response in off-site incident management organogram with clear missions and lines of authority (incident command system, field supervision, unified command);
  9. to disclose the information to local community and coordination with NDRF.

2.1 Off-site Emergency Management Plan (OffSEMP)

It shall be the duty of the concerned authority [District Collector or District Emergency Authority designated by the State Government, Chief Inspector of Mines appointed under the Mines Act, 1952, Chief Inspector of Dock Safety appointed under the Dock Workers (Safety, Health and Welfare) Act, 1986, Chief Controller of Explosives appointed under the Indian Explosive Act and Rules, 1983, etc. ], as identified in MS and IHC rules, to prepare and keep up-to-date an adequate off-site emergency plan containing particulars specified in Schedule 12 (shown as annexure 1) of MS and IHC rules 1989 and detailing how emergencies relating to a possible major accident on that site will be dealt with and in preparing that plan the concerned authority shall consult the occupier, and such other persons as it may deem necessary.

For the purpose of enabling the concerned authority to prepare the emergency plan, the occupier shall provide the concerned authority with such information relating to theindustrial activity under his control as the concerned authority may require, including the nature, extent and likely effects off-site of possible major accidents and the authority shall provide the occupier with any information from the off-site emergency plan which relates to his/her duties under rule.

The concerned authority shall prepare its emergency plan

(a)In the case of a new industrial activity, before that activity is commenced;

(b)In the case of an existing industrial activity, within six months of coming into operation to these rules.

The concerned authority shall also ensure that a rehearsal of the off-site emergency plan is conducted at least once in a calendar year. Mock drills provide opportunity to review the various aspects of the preparedness and response and it is advised to update the level of preparedness. However a paragraph in the present modules highlights the importance of the mock drills.

Disaster Management Act 2005 has been enacted and there are some provisions which are common for all types of disasters but for chemical (industrial) disaster management the provisions are made under Environment (Protection) Act 1986 through MS and IHC rules and CA (EPPR) rules. The role of Factory Inspectorate and Labour Department should not be diluted rather State Crisis Group (SCG) and District Crisis Group (DCG) should play a role of advisor to State Disaster Management Authority (SDMA) and District Disaster Management Authority (DDMA) for chemical (industrial) disastermanagement issues.

The effort of the module is to provide a fresh view about the preparation of the OffSEMP, monitoring, enforcement of the effective prevention and response system. The module ThemeModules 10, 11, 12, 13 and 153 should be considered with this module for betterunderstanding.

2.2 Approach for OffSEMP

OffSEMP is made to prevent the disasters and if happen then to reduce the losses by quick post-disaster response. The Schedule 12 of MS & IHC is only a guidelines but we are free to make OffSEMP more effective and that is only possible if pre- and post -disaster situations are visualised and are addressed professionally.

  1. A.Pre-Emergency Planning Hazard identification.
  1. The first step towards OffSEMP shall be to identify potential on-site and off-site hazards such as gas leaks, spills, fire, explosion, transportation incident, pipeline ruptures, equipment failure, natural calamities, etc. and the types of damage caused by them. The hazard identification shall include:

(a)information on toxicological, physical, and chemical properties of the substances being handled in the format of Material Safety Data Sheet (MSDS);

(b)identification of potential impact on downwind air quality or downstream water quality from an incidental release and possible danger to human, fFlora and fFauna and animal health;

(c)hazards to the installation shall also include nNatural perils such as floods, earthquakes, cyclones or landslides etc.

  1. The hazards identification can be done by the following steps:
  • In a district from chemical angle the following popular hazardous chemicals should be given priority as these chemicals are frequently being stored in bulk and used for various common purposepurposes:

→LPG , Propane (under pressure in liquid phase) -POL (Petroleum, Diesel, Kerosene, Lubricants, etc.) products -Ammonia (under pressure/refrigeration in liquid phase) -Chlorine (under pressure in liquid phase)

→Hydrogen (under pressure in gases)

→CS2 (Carbon disulphide)

→CO + H20 + CH4 ( Blast furnaces, LD gases, etc)

However, there may be many other chemicals. They have to be assessed by the occupier in OnSEMP and reported to the authorities.

  • Identification of the parking areas of trucks transporting hazardous chemicals like, toxic gases gases, (Ammonia, Chlorine, etc.); .), inflammable gases (LPG, propane, hydrogen, etc.); .), POL (Petrol, Diesel, Kerosene, etc.). Parking places of tankers etc. as shown in Photo-1.
  • Bulk storage areas of hazardous chemicals like, toxic gases (Ammonia, Chlorine, etc.); inflammable gases (LPG, propane, hydrogen, etc.); POL (Petrol, Diesel, Kerosene, etc.) as shown in Photo-2a and 2b.

Photo-1 Parking Places of LPG Trucks

Photo-2a LPG bulk storage Photo-2b Bulk storage of blastfurnace gases

Risk assessment.

The second step of the OffSEMP process is to determine the risk of an incident associated with each hazard (see also ThemeModules-11 and -12). The basic procedure in a risk analysis shall be as follows:

(a)identify potential failures or incidents (including frequency);

(b)calculate the quantity of material that may be released in each failure, estimate the probability of such occurrences;

(c)evaluate the consequences of such occurrences based on scenarios such as most probable and worst case events;

(d)the combination of consequences and probability will allow the hazards to be ranked in a logical fashion to indicate the zones of important risk. Criteria should then be established by which the quantified level of risk may be considered acceptable to all parties concerned;

(e)after assessing the risk, the "maximum tolerable criterion" must be defined and above which the risk shall be regarded as intolerable;

(f)the risk should also be made "as low as reasonably practicable" (ALARP) and least impacting the neighbourhood.

The risk of disasters is either due to engineering failure or due to human failure or and due to sabotage and it can be done simply by identifying the following points:

  1. What are the hazards and risk?
  2. What may go wrong?
  3. How it may go wrong?
  4. How likely is its occurrence?
  5. What would be the impacts?
  6. What maintenance schedule would reduce its likelihood of occurrence?

All these steps should be performed by using the following logical sequence as shown in Fig-2.

Fig-2 Sequence to know the probability of accident risk

The security threats in the district should also be identified and risk reduction should be considered by proper intelligence. For example the high lands near to bulk storage of chemicals should be under the surveillance of the district administration for further action.

Photo-3 Security threats

Photo-3: Area to be identified from security angle, the red circle shows the point which is threat to security and safety. A missile can target the bulk storage of LPG Horton spheres.

In addition to the above requirement, District administration should identify the areas where hazardous chemicals are stored or processed in bulk on priority because these places may cause major emergency. These areas may lead to challenges to the administration due to the release of the chemicals, which may lead to fire or and explosion or and toxic fumes generation. It may have the following consequences:

(a)The consequences of an incident may be confined within the premises or may spill off-site triggering escalating the effects.

(b)The consequences of an incident are fire explosion, deflagration, blast waves, fast spreading flames, BLEVE, UVCE resulting in direct effects like damage to buildings/ property, burns, fatalities. However, an iIncident in the neighbourhoods may sometimes cascade into an on-site emergency. It should be prevented or managed to avoid major emergency. (Photo-4 and 5).

(c)The consequence of toxic release will lead to off-site if not controlled immediately. Smoke is also one of the toxic releases and is responsible for an off-site situation.

For[J1]OffSEMP the authority should identify the following facilities on priority for pre-emergency preparedness and should ensure that these hazardous industries have OnSEMP based on hazard and risk assessment with consequence maps (see also ThemeModule-12 “Consequence Analysis”):

Photo -5 Off-site vulnerable zone of incidence

  • Places of bulk storages of LPG/Propane, example LPG bottling plants;
  • Fertiliser plants using Ammonia as raw material, example Urea fertiliser plants;
  • Bulk storage areas of Petrol, Diesel, and Kerosene, example POL depots;
  • Chlorine manufacturing and municipal water supply plants where Chlorine gas is used;
  • Paper and pulp plants, Staple fibres plant, Pharmaceutical plant, Pesticides plants;
  • Petroleum refineries, metallurgical (both ferrous and non-ferrous) plants;
  • Parking places of trucks engaged in transporting the hazardous chemicals;
  • Bulk transportation of hazardous chemicals by pipes;
  • Identification of pipelines is another task as these pipelines are causing the off-site emergency. Photo-6 shows the pipelines from big industry, these pipelines are the most vulnerable places for release of chemicals leading to fire, explosion and toxic release.

The following reasons may lead to big disasters in the facilities discussed above:

Photo-6 Pipelines also creates disasters

-Human errors, -Material and machine failure -Organisational failure -Natural causes

Road accidents (Photo-7) are another challenge to the civil administration (see also ThemeModule-2 “Safety in Transportation of Hazardous Substances by Road”). This may happen either due to the following reasons:

  • Condition of transport vehicle
  • Training and education of the driver
  • Road condition and speed of the vehicle
  • Training and education of first responders e.g. traffic police and regional transport officer (RTO)

Monitoring of risk assessment should be the first step by the civil authorities to reduce or control the root causes of the accidents at source. The review for the effective response mechanism should be the second step to minimise the effect of the disasters.

B. Emergency Mitigation Measures

The Civil Administration needs to review the following overall preparedness/mitigation measures of incidence prevention at all industries:-

  1. health safety and environment (HSE) policy;
  2. proper layout and inter facility distances (the layout should not have any crisscross movement of men and materials);
  3. safety committees with fair participation of Union leaders and workers;
  4. safety audits and risk assessment should be carried out as per the Indian standard;
  5. work permit system (including confined space entry permit);
  6. early warning alarm system in the installation (gas monitoring system, heat detection, high level alarms, low pressure/high pressure alarms etc.) especially in the vicinity of storage tanks, filling station, delivery points and along with periphery with the indication in the central control room;
  7. in-built safety interlocks system in design such as safety relief valves (SRVs), thermal safety valves (TSVs), non-returning valves (NRVs), remote operated valves (ROVs) and other various emergency trip systems in Installations;
  8. fire protection (preferably automatic) and HSE Management system;
  9. drill for visitors including assembly procedure and escape route, do's and don'ts written instructions before entry, etc;
  10. setting up of safety MIS [J2]system and sending Exception reports to the head of organisations;
  11. all standby equipments should be tried and operated periodically and recorded. Similarly back up power for safety equipment and instrument should be checked periodically and observations be recorded;.

Photo-7 Road accidents

C. Mutual Aid

Since combating major emergencies might be beyond the capability of individual unit, it is essential to have mutual aid arrangements with neighbouring industries. Consideration shall be given to the following while preparing mutual aid arrangements:-

(a)Written mutual aid arrangements are to be worked out to facilitate additional help in the event of Level-II emergencies by way of rendering man power, medical aid or fire fighting equipments, etc.