5

Notes
Unit 2 __________________
__________________
Regulatory Regime __________________
__________________
__________________
__________________
__________________
__________________
Objectives __________________

After reading this unit, you will be able: __________________

 To know the latest regulatory requirements in the area of health,

safety and environment pertaining to petroleum operations.

 To know various regulatory agencies involved in framing HSE

rules and regulations and other organizations working in HSE
area

 To be aware of the various permits, permissions and clearances

required to be taken from different agencies for setting up a new
project or carrying out major expansion or modifications in the
existing operations

 To understand the limitations of regulatory agencies and the need

to have self-discipline to maintain a high HSE standard.

Introduction
Since petroleum industry is a hazardous industry, a
number of regulations have been framed by various statutory
/regulatory authorities in the country to safeguard the
interest of workers, public and environment. Sustainable
development and environmental safeguards are important
societal issues. These regulations specify minimum
mandatory requirements to be complied by the industry.
The industry should take these regulations in the right
spirit and be fully committed in their compliance.
These regulations should not be considered contrary to
the interest of business and hindrance to its
development.
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Notes Regulatory/Statutory Agencies

__________________
Following is a list of various regulatory/statutory agencies
__________________
having jurisdiction over the petroleum industry:
__________________
__________________  Central Pollution Control Board (CPCB) under the
__________________ Ministry of Environment & Forests
__________________  Respective State Pollution Control Board under the
__________________ Ministry of Environment of the State
__________________
 Chief Controller of Factories of the respective State
__________________
(CIF) under the Ministry of Labour
__________________
 Chief Controller of Explosives (CCE), Ministry of Heavy
Industries, Dept. of Explosives

 Chief Inspector of Boilers of the respective state (CIB)

under the Ministry of Labour

 Chief Electrical Inspector of the respective state (CEI)

under the Ministry of Power

 Director General of Civil Aviation (DGCA) under the

Ministry of Civil Aviation, National Airport Authority
of India

 Tariff Advisory Committee (TAC) under the Association

of Insurance Companies

 Bhaba Atomic Energy Commission (BARC) under

Ministry of Atomic Energy

 Director General Mines Safety (DGMS) under the

Ministry of Mines

 Regional Transport Authority (RTA) under the Ministry

of Surface Transport

 Director General of Dock Safety (DGDS) under the

Ministry of Shipping

 International Maritime Organization (IMO) under

United Nations

 Oil Industry Safety Directorate (OISD) under the

Ministry of Petroleum and Natural Gas
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UNIT 2 Regulatory Regime 7
Various Regulations/Requirements Notes
__________________
The different agencies listed above have framed various
__________________
regulations under their purview. Needless to say that over
__________________
the years, these regulatory agencies have played a significant
__________________
role in promoting industrial safety and environmental
protection in the hydrocarbon industry. Important __________________

regulations are briefly discussed below: __________________

__________________
Petroleum Act, 1934 __________________

The statutory requirements of petroleum are governed by __________________

Petroleum Act, 1934 and Petroleum Rules, 1976 under the __________________
jurisdiction of Chief Controller of Explosives. These rules
deal with the safety guidelines / regulations for import,
transport, storage, refining, blending and testing of
petroleum and its fractions/hydrocarbons. Under the
Petroleum Act, the petroleum products are classified into
class-A having flash point below 23 degrees Celsius, class-B
with flash point between 23 to 65 degrees Celsius and
class-C having flash point between 63 to 93 degrees Celsius.
Petroleum products with flash point above 93 degrees Celsius
are exempted petroleum and do not fall under the purview
of petroleum rules.

The Petroleum Rules, 1976 detail the procedures and safety

norms to be observed for approval of containers, import,
delivery and dispatch, loading, transport, storage, refining
and blending of petroleum and requirement for storage and
safety distances, testing and maintenance of pipelines,
electrical apparatus and degree of safety, and licence/
approval procedures. Under these rules, licence is required
for:

 Import, storage and refuelling

 Transport by ships/vessels in bulk

 Transport by mechanically propelled vehicles by road

of class-A or B in bulk

 Decanting from tank trucks in unlicensed premises

 Transport by pipelines
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Notes  Refining and blending

__________________
 Fabrication of tank trucks
__________________
__________________  Manufacture of safety fittings
__________________
 Construction of tanks
__________________
__________________  Design of containers
__________________
The Indian Explosives Act, 1884
__________________
__________________
The compressed or liquefied gas filled in containers under
pressure are notified by the Government of India as
__________________
explosives and brought under the purview of Explosive Act,
1884 in 1938. The Chief Controller of Explosives administers
the statutory provisions of this Act. Various rules framed
under the Act are contained in:

 Indian Explosives Rules, 1981

These Rules regulate the manufacture, possession, use,

sale, transport and export/import of all types of
explosives used for various purposes like mines/rock
blasting, crackers, etc.

 The Static and Mobile Pressure Vessels, SMPV

(unfired) Rules, 1981

These Rules stipulate various safety guidelines for the

storage and transport of compressed and liquefied gases
filled in pressure vessels (exceeding 1000 litres capacity)
at a pressure exceeding 1.5 kg/cm2 15 degrees Celsius
or 2.0 kg/cm2 at 55 degrees Celsius. Under these rules
the storage and transport vessel should be designed for
the specific gas, maximum operating temperature and
working pressure, proper material of construction,
capacity, shape, size etc., according to IS 2825 or any
other approved code. The Chief Controller of Explosives
should approve its design/drawings. The vessel should
be fabricated by an approved fabricator and installed
as per the safety distances stipulated in the rules. The
rules call for periodic re-examination/testing of the
pressure vessel and its fittings.
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UNIT 2 Regulatory Regime 9
 The Gas Cylinder Rules, 1981 Notes
__________________
The provisions of these Rules pertain to the filling,
__________________
storage, handling and transportation of gases in gas
__________________
cylinders exceeding pressures of 1.5 kg/cm2 at 15 degrees
Celsius or 2.5 kg/cm2 at 50 degrees Celsius. The rules __________________

regulate the manufacture of cylinders, valves and __________________

regulators; marking, stamping and colour coding of __________________
cylinders; import of gas cylinders; storage, handling, __________________
transportation and use of gas cylinders; testing of __________________
cylinders and the procedure for appointing the __________________
competent person authorized to undertake the testing
__________________
and inspection of gas cylinders.

The Factories Act, 1948

The provisions of this Act contained in different chapters on
Health, Safety and Welfare are administered by the Chief
Inspector of Factories in the respective state. Each state has
its own Factories Rules. The Act was revised in 1987 to
include hazardous chemical factories and some other
amendments brought in the Factories Rules of many states
in 1995.

The Factories Act makes the occupier of a factory fully

responsible for providing and maintaining the plant and the
systems of work that are safe and without risks to the health
and safety of workers and general public. General
responsibilities of the occupier are listed below:

 Declaring Safety Policy of the organization.

 Providing the Material Safety Data Sheet (MSDS) of

each hazardous chemical.

 Every factory should have a well-written On-site

Emergency plan clearly defining the role of different
persons in case of any emergency. The plan should be
rehearsed every year and updated from time to time.

 Disclosure of information to workers, public and

authorities. This should include declaration of
dangers/ health hazards and measures to overcome such
hazards.
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Notes  A safety committee having equal representation of

__________________ workers and management should be in place. The
__________________ meeting of this committee should be held at least every
__________________ quarter.
__________________  To maintain limits of exposure of chemicals and toxic
__________________ substances below the limit prescribed under the rules.
__________________
 Medical check-up of workers–once before employment,
__________________
then once every six months for health status in case of
__________________ specific hazards.
__________________
 Setting up a Medical/Occupational Health Centre
__________________
suitably equipped with equipment and qualified medical
personnel.

 Inspection, testing, examination and certification of

equipment and vessels, etc., by competent persons
approved by CIF.

 Permit to Work system should be in place with approved

safety and rescue equipment. All work associated with
entry or work into confined spaces, working at heights,
hot work, cutting and welding, excavation and other
dangerous activities should have predetermined safe
work procedure and should be undertaken under a
written work permit signed by a qualified supervisor.

 Provide adequate fire protection system as per rules.

 An emergency communication system–alarm, siren, etc.,

should be in place and everybody should know what to
do in case of an alarm.

 Safety Manual containing the different safety procedures

applicable to the installation should be available to the
workers.

 Providing Personal Protective Equipment to workers

depending on the nature of hazard involved.

 Display necessary precautionary notices and

instructions at prominent places to educate and warn
the workers and visitors against hazard involved.

 Appointing a qualified Safety Officer in the premises

as per rules.
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UNIT 2 Regulatory Regime 11
 Providing welfare amenities like drinking water Notes
facilities, washing facilities, mess room, toilets, etc. __________________
__________________
 Sending any accident report and notice of any poisoning
or occupational disease. __________________
__________________
Environmental Legislation __________________

Sustainable development and environmental management __________________

are important issues for the development of society. Keeping __________________
this in view, Government of India enacted the various __________________
environmental legislations related to industrial projects/ __________________
activities. These include: __________________

A. The Water (Prevention and Control of Pollution) Act,

1974

B. The Water (Prevention and Control of Pollution) Cess

Act, 1977

C. The Air (Prevention and Control of Pollution) Act, 1981

D. The Environment (Protection) Act, 1986

 The Environment (Protection) Rules, 1986

 Manufacture, Storage and Import of Hazardous

Chemicals Rules, 1989

 Hazardous Wastes Management (Management and

Handling) Rules, 1989

 Environmental Clearance of Project Notification,

1994

 Chemical Accidents (Emergency Planning,

Preparedness and Response) Rules, 1996

 Biomedical Waste (Management and Handling)

Rules, 1998

E. The Public Liability Insurance Act, 1991 and the Public

Liability Insurance Rules, 1991

The critical requirements of this legislation for petroleum

industry are discussed separately in Unit 3.
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Notes The Indian Boilers Act, 1923

__________________
The central government and the state governments
__________________
independently, except Jammu and Kashmir where this Act
__________________
does not apply, frame the Act. Each state has its own boilers
__________________ regulations. It is obligatory for an owner to get his boiler
__________________ registered under this Act. Chief Inspector of Steam Boilers
__________________ in the state is the registering authority. The Act stipulates
__________________ requirements for safety of steam boilers and steam pipes.
__________________ For the purpose of the Act, a ‘boiler’ means any closed vessel
exceeding 22.75 litres in capacity which is used exclusively
__________________
for generating steam under pressure and includes any
__________________
mounting or other fittings attached to such vessel which is
wholly or partially under pressure when steam is shut off.
A ‘Steam Pipe’ under the Act means any pipe through which
steam passes from a boiler to a prime mover or other user if
the pressure at which steam passes through such pipe
exceeds 3.5 kg/cm2 above atmosphere or such pipe exceeds
254 mm in internal diameter.

These regulations cover the design, construction and

workmanship of boilers and connected mountings, fittings
and piping. The regulations specify the stages and
procedures for inspection of new boilers and inspection
frequency of boilers in operation. The regulations also lay
down procedure for testing and qualifying welders who are
to work on boilers.

A registered boiler is permitted for use for a maximum

period of one year. A working certificate showing validity
period, maximum allowable pressure, etc. is issued after
every annual inspection by the boiler inspector. The boiler
owner is required to display the certificate so that boiler
attendants and other employees associated with boiler
operation and maintenance get familiar with the certificate.

As per the Act the owner should provide qualified person(s)

to take charge of a boiler(s). A second class boiler attendant
can take charge of a single boiler or battery of three boilers,
the total heating surface of which does not exceed 150 sq.
metres. A first class boiler attendant can take charge of a
battery of boilers, the total surface area of which does not
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UNIT 2 Regulatory Regime 13
exceed 700 sq. metres. A proficiency engineer should be Notes
appointed for boilers larger than the above sizes. __________________
__________________
The following acts/omissions are treated as cognizable offence
__________________
under the Act:
__________________
 If it is not registered or not having the valid certificate __________________

 Operating the boiler at pressure higher than that __________________

allowed in the certificate __________________
__________________
 Absence of duly qualified boiler attendant
__________________
 Carrying out structural alteration, addition or renewal __________________
in or to a boiler without prior sanction of Chief Inspector

 Failure to report any accident to boiler or steam pipe to

the Inspector within 24 hours

 Tempering with safety valves

 Allowing a person to go inside the boiler without

effecting disconnection

 Fraudulent engraving of registry on a boiler

The Indian Electricity Act, 1910

In exercise of the powers conferred by Section 37 of the Indian
Electricity Act, 1910, the Central Electricity Board
formulated the Indian Electricity Rules (I.E. Rules) in 1937
followed by amendments in 1956. The objective of the I.E.
Rules is to regulate the generation, transmission, distribution
and use of electricity in a safe manner. The provisions of
these rules are enforced in each state by the Chief Electrical
Inspector of the state. It is mandatory that all the electrical
installations should conform to the requirements of the
Indian Electricity Rules.

The I.E. Rules do not stipulate specific requirements of

electrical equipment and lines and due to this, the
interpretation of the rules by electrical inspectors vary from
state to state. Also, the I.E. Rules do not cover the special
requirement for electrical equipment in hazardous locations
encountered in petroleum installations.
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Notes The Oil Mines Regulations, 1984

__________________
These regulations were framed under Section 57 read with
__________________
Section 59 of the Mines Act, 1952 and enforced in 1984 in the
__________________
oil industry. Consequently, all the oil and gas exploration,
__________________ drilling, production and transportation facilities including
__________________ general safety and health education are governed by these
__________________ regulations under the competent authority of the Director
__________________ General of Mines Safety (DGMS). Although the basic safety
__________________
requirements are stipulated in Oil Mines Regulations, 1984,
the specific requirements for certain systems like work
__________________
permit, fire fighting facilities, etc. are not fully covered.
__________________
The Indian Aircraft Rules, 1937
In exercise of the powers conferred by Sections 5,7.8 and 9A
of the Indian Aircraft Act, the Aircraft Rules were framed
in 1937, which were amended several times; the latest
edition was updated in 1985. An installation, which is in
proximity to the aerodromes, is covered under the purview
of these rules. The relevant rules in case of statutory
clearance for the design of tall structure and buildings are
framed under provision 9A of the said act.

It is mandatory that clearance be obtained from the National

Airport Authority of India, under the Ministry of Civil
Aviation while planning to construct any tall structure or
building. Air warning lights as stipulated in the Rules to be
complied with by owners of such buildings. The owner has
to forward the layout drawings showing the elevation
details, dimensions and other details of structures/buildings
in the prescribed format and submit to the nearest
Aerodrome Officer. Only after the receipt of approval, the
construction can be taken up.

International Maritime Organization (IMO)

It was originally known as IMCO, Inter-Governmental
Maritime Consultative Organization established in 1948 as
a specialized agency of United Nations, which was later
changed to IMO to reflect its wider functions. IMO primarily
works for development of maritime regulations and
standards for promoting maritime safety and prevention of
pollution from ships. These regulations and standards are
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UNIT 2 Regulatory Regime 15
adopted in diplomatic conferences and published by IMO. Notes
Some important milestones achieved are: __________________
__________________
 Convention on the safety of life at sea in 1974
(SOLAS’74) __________________
__________________
 International convention for prevention of pollution
__________________
from ships in 1973/78 (MARPOL 73/78)
__________________
 Convention on standards of training, certification and __________________
watch keeping for seafarers, 1978 (STCW 78) __________________

These conventions formed an important vehicle for the __________________

development and international spread of knowledge, __________________

recommendations, codes of practice and protocols regarding
maritime safety throughout the world. A wide range of topics
covering all maritime activities for handling different types
of dangerous goods are dealt in the publications from these
conventions and seminars. However, adoption and
implementation of these regulations are not uniform in all
parts of the world.

Dock Workers (Safety, Health and Welfare) Act,1986

The Dock Workers’ (Safety, Health and Welfare) Regulations
were framed in 1990 under the above mentioned Act. Factory
Inspectorate does not have jurisdiction on the ports and
docks. Director General of Dock Safety enforces safety
requirements at ports/docks where crude and petroleum
products moving through ships and barges are handled.

Atomic Energy Act, 1962

The Atomic Energy Rules were framed in 1971 (revised in
1996) under the Atomic Energy Act, 1962. Under these rules,
Atomic Energy Regulatory Board, AERB under Bhaba
Atomic Energy Commission, regulates the use of any
radioactive source in the country. Radioactive sources are
used in many petroleum installation in radiography
equipment, x-ray machines, nucleonic level gauges and smoke
detectors. The use of any radiation (radioactive) source
including its storage, handling, transportation and disposal
must comply with the statutory requirements of AERB.
Any installation using radiation sources must have an
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Notes authorized Radiological Safety Officer (RSO), trained,

__________________ validated and certified by Radiation Protection Service
__________________ Division of Bhaba Atomic Energy Commission. The RSO
__________________ liaisons with AERB on all matters concerning radiation
__________________ sources.
__________________
Motor Vehicles Act, 1988
__________________
__________________
The transportation of hazardous products by road is governed
by Central Motor Vehicles Rules, framed in 1989 (amended
__________________
in 1993), enacted under the Motor Vehicles Act, 1988. Salient
__________________
features of the rules include:
__________________
 Educational qualifications of drivers of goods carriages
carrying dangerous or hazardous goods. Every driver
of such vehicles must have passed the mandatory three
days training course from a recognized school in addition
to having his heavy vehicle driving licence.

 Every vehicle carrying hazardous goods must display

mark of the class label appropriate to the type of
dangerous goods. The vehicle should be marked with
emergency information panel at three places on the
vehicle. This panel contains product’s technical name,
UN identification number, HAZCHEM code, emergency
phone no., etc.

 The vehicle must have a TREM card-transport

emergency card available in the driver’s cabin.

 Every vehicle carrying hazardous goods must be

equipped with the prescribed safety equipment for
preventing fire, explosion or escape of hazardous goods.
Every such vehicle should be fitted with a spark arrester
and a techograph (an instrument to record the lapse of
running of the vehicle, time speed maintained,
acceleration/deceleration, etc.).

 Responsibilities of consignee, transporter and driver.

Oil Industry Safety Directorate

Oil Industry Safety Directorate, OISD, is an advisory body
under the Ministry of Petroleum and Natural Gas. Set up in
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UNIT 2 Regulatory Regime 17
1986 after Bhopal disaster, the directorate advises the oil Notes
and gas industry in India on all matters of health, safety and __________________
environment. All public sector (PSU) oil companies are __________________
members of OISD. Private oil companies can also become __________________
members in case they desire. Unlike other regulatory
__________________
agencies, OISD helps the member oil and gas companies
to enhance their level of safety through self-regulation. __________________
OISD has published a number of standards/recommended __________________
practices in siting of petroleum installations, operating __________________
philosophies, inspection, maintenance, fire protection, __________________
etc. It is obligatory for the member companies to use
__________________
these standards and recommended practices for new
installations and installations in operation. Many other __________________
statutory agencies like CCE and others cite OISD standards/
recommended practices in their procedures and
requirements.

OISD has also published guidelines for internal and external

safety audits. Based on these guidelines, formal safety audits
of oil/gas installations of various PSUs under Ministry of
P&NG are conducted periodically by an external team under
the leadership of OISD. Petroleum organizations can use
these guidelines for their own internal audits. OISD has also
made a model disaster management plan that can be used
by an installation as guideline for developing its own disaster/
emergency management plan.

Tariff Advisory Committee

Tariff Advisory Committee, TAC, is an advisory body formed
to regulate rates, terms and conditions of business of general
insurance companies in India. TAC approves and monitors
various fire fighting facilities and electrical installations in
the industry. Fire Protection Manual first brought out in 1903
by Calcutta Fire Association was revised, updated and issued
by TAC in 1982 in two parts – Part I and II. These manuals
lay down guidelines for design and operation of private fire
fighting facilities to be maintained by the industry. These
guidelines have been used extensively in petroleum
installations. Based on the degree of compliance to the
recommendations of these manuals, TAC advises the
rebates in the insurance premiums. TAC makes periodical
inspections of those installations where rebates have been
given.
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Notes Permissions and Approvals for New Projects

__________________
Before setting up any oil or gas installation, the following
__________________
statutory approvals/permissions have to be taken by the
__________________
organization. Some of these approvals/permissions are also
__________________ applicable for undertaking a major expansion or revamp of
__________________ existing installations.
__________________
Under Factories Act–from CIF
__________________
__________________  Permission to construct, extend or take into use any
__________________ building as a factory
__________________  Approval of site and building plans

 Approval of site (only for hazardous process units) by

State Site Approval Committee

 Certificate of stability of factory building

 Application for registration and notice of occupation

 Application for Licence/Renewal of licence of a factory

Under Environment Protection Act–from MOEF and State

PCBs
 Notification of site in respect of hazardous chemicals

 Environmental Impact Assessment

 Environmental Clearance from Ministry of Environment

and Forests

 NOC from State Pollution Control Board

 Consent for discharge of trade effluents

 Consent for operation of plants (in air pollution control

areas)

 Authorization for handling hazardous waste in quantity

exceeding regulatory values

Under Explosives and Petroleum Acts–from CCE

 Licence for manufacture, possession, use, sale, transport
and importation of explosives

 Licence to import/store petroleum

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UNIT 2 Regulatory Regime 19
 Licence to carry petroleum by land Notes
__________________
 Licence for installing static and mobile pressure vessels
__________________
 Licence for filling and possession of gas cylinders with __________________
compressed gases __________________
 Licence for transporting cylinders filled with __________________
compressed gas __________________
__________________
Other Approvals/Permissions/Clearances
__________________
Besides the above, permissions/approvals/clearances/ __________________
consents from other agencies listed below have to be taken:
__________________
 Certificate of authorization for use of boilers from the
state’s Chief Inspector of Boilers

 Certificate of authorization for use of electrical

equipment from state’s Chief Electrical Inspector

 Public Liability Insurance by owners handling hazardous

substances

 Authorization from BARC (under the Ministry of Atomic

Energy) for use of equipment/instruments using
radiation sources

Regulatory Compliance
No doubt, the various regulations as discussed above go in a
long way to increase the industrial safety standards, which
is very important for hazardous industry like petroleum
operations. But the regulations will be useful and bring
results only when they are implemented in the right spirit.
It is the responsibility of the owner/occupier of an
installation and their authorized officials to ensure that the
requirements of various regulations are fully complied with.
Besides taking the necessary approvals, permissions,
consents and clearances from the concerned authorities and
maintaining the conditions specified therein, it is also
required by some of these agencies to send them regular
reports of compliance. In the recent past, the law has put lot
of accountability and liability on the part of senior
management of an organization in the compliance of various
regulations. Non-compliance can attract heavy penalties,
sanctions, and closure of the installation. The owner/occupier
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Notes and other officials may even be put behind the bars in serious
__________________ violations. Even the public awareness about the safety
__________________ hazards and environmental pollution from industrial
__________________
activities has increased significantly over time. It is very
easy these days for any person to file a PIL (public interest
__________________
litigation) suing an organization for violation of any
__________________ regulatory requirement. The affected organization may get
__________________ involved in lengthy litigation costing lot of money,
__________________ harassment and loss of image and reputation. The
__________________
management of every installation therefore should ensure
that the required regulations are fully complied with.
__________________
__________________ Limitations of Regulatory Agencies
Needless to say that over the years the regulatory agencies
have played a significant contribution in the promotion of
industrial safety in the petroleum industry in India. With
due respects to their role, it may be worthwhile to look into
some of the inherent limitations of these agencies. And this
is the most important reason why organizations should have
voluntary own self-discipline and regulation to have a high
level of safety standard. Some limitations are:

Minimum Requirements
Most of the regulatory agencies lay down rules / regulations
which are the minimum basic requirements that are very
important in the safe design and operation of industrial
units.

They do not go into details of so many other requirements

pertaining to safe management of an installation. For
example, sound and safe engineering practices are equally
important but are not addressed in these requirements.

Change is Slow
Technological developments and social awareness bring in
new problems and challenges to the industry. Adequate
protection of society against new technological hazards
would depend upon the speed with which these regulatory
agencies can identify the new problems and change the rules.
Since the provisions of these agencies cover a wide spectrum
of industry and any amendment has to go through a lengthy
legislative procedure, the statutory and law enforcing
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UNIT 2 Regulatory Regime 21
agencies are generally slow in updating their rules and Notes
requirements to keep pace with technological and social __________________
changes. Some of the requirements set forth in the regulations __________________
long ago may not be relevant in the present context. For
__________________
example, Factory Act, since its inception in 1948, underwent
__________________
amendments only in 1954, 1976 and in 1987. Petroleum Rules
were last revised in 1976. Environment Protection Act came __________________
into being only in 1986. The Indian Electricity Rules and __________________
Indian Boiler Regulations have not seen any revision for more __________________
than 15 years.
__________________

Inadequate Infrastructure __________________

__________________
Many regulatory agencies do not have adequate facilities and
manpower to monitor and control the safety performance of
the industry on a continuous basis. For example, the number
of Boiler Inspectors and Factory Inspectors in most states is
far less than required to undertake regular and meaningful
inspection visits to a large number of industrial units under
their jurisdiction. Further, with the background and training
that many Factory Inspectors have, their visits to factories
are restricted to checking basic amenities like first-aid
boxes, machine guards, personal protective equipment,
drinking water and canteen facilities, etc. They probably do
not have the right training and background for identifying
many serious process hazards, which may not be so obvious.
It is only after Bhopal disaster that some improvements with
respect to quantity and quality of inspectors in these agencies
have taken place.

Nominal Penalty for Violations

Some regulatory agencies provide for penalty to the industry
for violating the rules and compensation to the worker in
case of injuries and fatalities. Though in the recent past there
have been some changes in the amount of these penalties
and compensations, still these are nominal in most cases,
with the result that there is little pressure on the industry
compelling them to spend money in making an installation
inherently safer and non-polluting. It appears, under the
present situation, that the companies would prefer to violate
some of the safety rules and pay the penalty rather than
implement these rules by additional investment. The logic
may, however, look very strange, but it is a reality in some
cases where the management is not fully committed and lacks
 OLEUM &
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22 Health, Safety and Environmental (HSE) Challenges fo
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Notes in self-discipline to make the installation safe and non-

__________________ polluting. In contrast to this, very heavy penalties and
__________________ sanctions are imposed for violation of health, safety and
__________________ environment regulations in USA, Europe and Japan.
__________________
General and Subjective Provisions
__________________
__________________ Certain provisions of regulatory agencies are very general
__________________
and subjective in nature. This leads to ambiguities and
confusions in their interpretations by users and the
__________________
inspectors. Besides, it is observed that a large number of
__________________
cross-references to a particular provision of the regulation
__________________
are mentioned, but not listed in the text.

Summary
Latest regulatory requirements on health, safety and
environment pertaining to petroleum industry were
briefly discussed in this unit. A list of various permits
and permissions required for new projects or major
modifications and expansions have also been given. Why
only regulatory requirements are not enough for
maintaining a high level of health, safety and
environment was also discussed.

Review Questions
1. List out the requirements of environmental clearance
of your installation and find out the status of its
compliance.

2. List out three main limitations of regulatory agencies.

3. When was the last visit of the factory inspector to your

installation? Find out the compliance to various points
he recorded in the inspection register.

4. Make a list of various permits, permissions, clearances

etc. pertaining to your installation. Are these up to date?
When is the next renewal date of each of these
documents?