NDMA issues guidelines on restarting manufacturing industries post lockdown

In wake Vishakapatnam incidents where gas leak at an LG polymer plant led to the death of 12 persons, the National Disaster Management Authority (NDMA) came out with precautions to be observed while starting the manufacturing units.

While reiterating its guidelines, NDMA said, “When Lockout/Tagout procedures are not in place, many energy sources can prove to be hazardous to operators/supervisors who are servicing or maintaining electrical, mechanical or chemical equipment.”

The authority also added, “When heavy machinery and equipment are not maintained periodically, they can become dangerous for the operators/engineers. Combustible liquids, contained gaseous substances, open wires, conveyor belts and automated vehicles make manufacturing facilities a high-risk environment. Improper enforcement of safety codes and improperly labelled chemicals can further pose serious health hazards.”

• The authority further asserted that “While restarting the unit, consider the first week as the trial or test run period; ensure all safety protocols; and not try to achieve high production targets.
• To minimize the risk it is important that employees who work on specific equipment are sensitized and made aware of the need to identify abnormalities like strange sounds or smell, exposed wires, vibrations, leaks, smoke, abnormal wobbling, irregular grinding or other potentially hazardous  signs which indicate the need for an immediate maintenance or if required shutdown,” the NDMA added.
• While factories have also been instructed by the Union home ministry to exercise due precaution and social distancing measures to combat the spread of covid-19, the NDMA added, “Especially during the Covid-19 times, ensure all lockout and tag-out procedures are in place on a daily basis; Inspection of all equipment as per the safety protocols during the restart phase. In case the industry has any difficulty in managing crucial backward linkages that may be critical for their safe functioning, they should approach the local district administration for specific assistance.”

• At the same time, the Centre and District Magistrates have also tied up to ensure that in such instances, the industrial unit may be facilitated to run their end to end operations, in the overall interests of industrial security

Guidelines for Restarting Manufacturing Industries after Lockdown.

• In an early response to COVID-19, the nationwide lockdown was ordered with effect from 25th March. As the lockdown is being gradually released in some zones, certain economic activities are being permitted as per NDMA orders No.1-29/2020-PP dated 1st May 2020 and MHA order No. 40- 3/2020-DM-I(A) dated 1st May 2020.
• Due to several weeks of lockdown and the closure of industrial units during the lockdown period, it is possible that some of the operators might not have followed the established SOP. As a result, some of the manufacturing facilities, pipelines, valves, etc. may have residual chemicals, which may pose risk. The same is true for storage facilities with hazardous chemicals and flammable materials.

National Disaster Management Authority has issued 

• Guidelines on Chemical Disasters, 2007;
• Guidelines on Management of Chemical (Terrorism) Disasters, 2009; and 
• Strengthening of Safety and Security for Transportation of POL Tankers, 2010, which are relevant for chemical industries.

• The Manufacture, Storage and Import of Hazardous Chemical Rules, 1989 under Environment Protection Act, 1086 provide the statutory requirements for these industries.

When Lockout/Tagout procedures are not in place, many energy sources can prove to be hazardous to operators/supervisors who are servicing or maintaining electrical, mechanical or chemical equipment. When heavy machinery and equipment are not maintained periodically, they can become dangerous for the operators/engineers.

• Combustible liquids, contained gaseous substances, open wires, conveyor belts, and automated vehicles make manufacturing facilities a high-risk environment. Improper enforcement of safety codes and improperly labeled chemicals can further pose serious health hazards. When an unexpected event occurs, managing rapid response becomes challenging. In order to minimize the risk and to encourage a successful restart of the industrial units, the following guidelines are being issued.
• State Governments shall also ensure that the off-site disaster management plan of the respective Major Accidental Hazard (MAH) units is up to date and preparedness to implement them is high. It is also advised that all the responsible officers of the district shall ensure the Industrial On-Site Disaster Management Plans are also in place and cover Standard Operating Procedures for safe re-starting of the industries during & after COVID 19 lockdown.

Generic guidelines:

• While restarting the unit, consider the first week as the trial or test run period; ensure all safety protocols; and not try to achieve high production targets.
• To minimize the risk it is important that employees who work on specific equipment are sensitized and made aware of the need to identify abnormalities like strange sounds or smell, exposed wires, vibrations, leaks, smoke, abnormal wobbling, irregular grinding or other potentially hazardous signs which indicate the need for immediate maintenance or if required shutdown.
• Especially during the Covid-19 times, ensure all lockout and Tagout procedures are in place on a daily basis (not applicable for units running 24hrs).
• Inspection of all equipment as per the safety protocols during the restart phase
• In case the industry has any difficulty in managing crucial backward linkages that may be critical for their safe functioning, they should approach the local district administration for specific assistance. District Magistrates may be instructed to ensure that in such instances, the industrial unit may be facilitated to run their end to end operations, in the overall interests of industrial security.

For specific industrial processes:

1. Storage of raw material,
2. Inspect the storage facilities for any signs of spills, wear, and tear during the lockdown.
3. Check for already opened storage vessels/containers/bags/silos for possible oxidation/chemical reaction/ rusting/ rotting etc
4. HAZMAT Chemicals in the storage need to be checked for chemical stability before using for any processes
5. Ensure ventilation and proper lighting before entering the storage areas
6. Sense for abnormalities like strange sounds or smell, exposed wires, leaks, and smoke
7. Check supply pipelines/valves/conveyor belts for any signs of damage/wear & tear

• Check the storage building for any signs of distress and damage to the roof.

Manufacturing Processes

• Carry out a complete Safety Audit of the entire unit before taking up starting activities
• Cleaning of pipelines, equipment and discharge lines: Mechanical cleaning followed by air /water flushing and chemical cleaning based on the type of the process equipment
• Run-in of rotatory equipment under supervision
• Boilers/ furnaces/ heat exchangers to be checked for lining and signs of wear and tear
• Check supply pipelines/valves/conveyor belts for any residual material and wear and tear. Also check all the pipelines / valves for obstructions/ pressure levels.
• Ensure all pressure, temperature gauges are functional
• Tightness test Many process units handle combustibles or toxic substances (or both), the leakage of which could result in disaster, damage, or economic loss. To prevent the occurrence of such incidents, it is necessary to confirm that the plant complies with the required tightness before start-up.
• Service test need to be performed for all water, compressed air, and steam piping and equipment with normal operating fluids. The system is first pressurized with operating fluids and then checked for leakage. For air lines, leaks can be found using soap solution. For water and condensate lines, the leakage can be observed visually. Leakage points found during the test are retightened. The test is deemed successful if no foam is observed from soap solution, or if no water or condensate is observed visually.
• Vacuum hold test: All vacuum systems must be leak tested. Air inside the system is first evacuated to attain the required vacuum. The best way is to start at one end of the section and work through to the other end, checking flanges, valves, fittings, instruments, and other equipment. Each leak is tagged, making it easy for the maintenance team and personnel of the next shift to continue with the work.
• Trial testing be carried out before the full-fledged production is initiated with full human resources

• Ensure the arrangement for round-the-clock emergency crews/ professional technical teams provided with MAH and cluster of MAH should have an extended coverage of 200 km to reach transport accident spots for help

Storage of products

• Check the storage facilities / silos for any damage or wear and tear

4. Guidelines for the workers

Ensure 24 -hour sanitisation of the factory premises.

• Factories need to maintain a sanitization routine every two-three hours especially in the common areas that include lunch rooms and common tables which will have to be wiped clean with disinfectants after every single use.
  For accommodation, sanitization needs to be performed regularly to ensure worker safety and reduce the spread of contamination

1.  Entrance health checks
2. Temperature checks of all employees to be done twice a day.
3. Workers showing symptoms should not report to work.

1. Provisions of hand sanitizers and masks to all employers.
2. Providing gloves, masks and hand sanitizers to be done at all factories and manufacturing units

1. COVID 19 health and prevention staff education
2. Education on safety steps to take from entry to exit in the factory
3. Measures to take precautions at personal level

• Quarantine measures for supply and storage of goods
• Sterilise boxes and wrapping brought into factory premises
• Isolate and sanitize finished goods as appropriate
• Delivery of good in shifts
• Physical distancing measures
• Create physical barriers to ensure the physical distance within the work floor and dining facilities
• Provide face protection shields along with masks and PPEs.

• Working in shifts
• Factories that work 24 hours at full production capacity should consider one hour gap between shifts, except factories/plants requiring continuous operations.
• Managerial and administrative staff should work one shift at 33 percent capacity as per MHA guidelines; but while deciding which particular person to be included in 33% at any given point of time, overriding priority should be given to personnel dealing with safety.
• Ensure no sharing of tools or workstations to the extent possible. Provide additional sets of tools if needed.
• Scenario plan on discovering a positive case
• Factories have to prepare accommodation to isolate workers if needed.
• HR has to help manage the whole process for the individual, all traveling employees also to undergo a mandatory 14-day quarantine

• Presence of skilled workers

Workers involved in dealing with hazardous material must be skilled and experienced in the field. No compromise on the deployment of such workers should be permitted when an industrial unit is opened up. Source of economics times