Framework for Safety Culture -CONTINUAL IMPROVEMNENT

Framework for Safety Culture

The organization's culture provides the framework for introducing safety education and safe practices. Organizational culture is not something that you can photograph or download from the Internet. However, you can see traces of it, and you can feel it when you enter some workplaces. Here are some clues that you can use to identify your organization's "culture".

Language/customs/rituals

Every organization has its own "language"Â\ terms that are part of what goes on within the nonprofit. These words and ideas also signify the way people are expected to behave in your workplace and with clients. "Customs" can be described as the routines for giving and obtaining service, and "rituals" describe the events that take place on a regular basis, such as an annual volunteer recognition event, a fundraiser or a board retreat. Is "safety" part of the language of your nonprofit? Or is safety considered something that is just the cleaning crew's, building engineer's or safety coordinator's job?

Being part of a team Â\ group norms

Group norms describe the ways in which people are expected to work together in groups?what behaviors are OK, what is not OK, and what is completely taboo. Behavioral expectations are some of the key aspects of organizational culture. What types of behavior is expected in the realm of safety?
Values and beliefs

An organization's mission reflects the nonprofit's core values and beliefs. Treatment of clients, community outreach and the stewardship of resources all reflect these values and beliefs. Is safety part of your nonprofit's value structure? Are people rewarded in a tangible, visible way for promoting safety and working safely?

Rules of the game

These are the rules that are not written down, but must be understood if a person is to get along in the organization. These "rules" also indicate what is considered of value within the organization. Are good safety practices among the unwritten rules of your nonprofit?

Climate

"Climate" describes the feeling that is conveyed by the physical layout and the way in which members of the organization interact with each other, clients, donors and members of the public. How does the physical layout of your nonprofit make a statement about your commitment to safety? Are safety concerns evident in the interaction among employees and volunteers and in staff interaction with clients, donors and members of the public?

The Way Things Are Done Â\ Patterns of Problem Solving

The ways people are "shown the ropes" of the organization including how problems are identified and solved within the organization illustrate patterns of problem solving. How are newcomers told about the nonprofit's commitment to safety? Are new employees briefed on safety procedures? Do they know that there are consequences for ignoring safety practices or engaging in unsafe behavior? Are the consequences enforced?

Checklist

Answer "Yes" or "No."

"Safety" is part of the language of the nonprofit.

Safety is part of your nonprofit's value structure.

Safety is considered something that is the cleaning crew's, building engineer's or safety coordinator's and everyone else's job.

People are rewarded in a tangible, visible way for promoting safety.

Safe practices are part of the unwritten rules of your nonprofit.

Safety concerns are evident in the interaction among staff and volunteers and in their interaction with clients, donors and members of the public.

New employees are briefed on safety procedures.

New employees know that there are consequences for ignoring safety practices or engaging in unsafe behavior.

Consequences for ignoring safety practices or engaging in unsafe behavior are enforced.

Facility ____________________ Area ___________________

Auditor ___________________ Date __________

Area	Satisfactory	Action Required	Corrective Action (date)
Employee Knowledge
Last date of training
Normal Operating Procedures
Emergency Operating Procedures
Program Administration
Last audit date
Written Program
Boiler Supervisor Assigned
Records
Training
Inspections - Weekly
Inspections - Internal
Inspections - External
Water chemistry records
Test records
Relief valve test records
Fuel tests
Safeguards
Engineering Safeguards
Administrative Safeguards
Training Safeguards
Equipment Inspection
Controls
Alarms
Pumps
Valves
Blowers
Insulation
Area Inspection
Chemical storage
No leaks
Lighting
No flammable material
Notes

INDUSTRIAL HYGIENE

Sampling and monitoring equipment is available to quantify exposures to contaminants, noise, radiation, and heat. Correct sampling strategy and interpretation are essential elements of an industrial hygiene survey. Confined spaces, ventilation changes, the performance of collection systems, and pressure relief valves are all items of concern for exposure evaluation.

Industrial hygiene is defined as the recognition, evaluation, and control of workplace hazards. Its origins are based on limiting personal exposures to chemicals, and have evolved to address the control of most other workplace hazards including over-exposure to noise, heat, vibration, and repetitive motion.

Occupational exposure to chemicals is still considered one of the most wide spread hazards in industry. The use of engineering controls is the preferred method of limiting these exposures. Dilution and capture ventilation are two important methods to control occupational exposure. The design and position of hoods and vents, and amount of air infiltration can substantially change exposure conditions. Material Safety Data Sheets and other documentation provide a basis for predicting adverse effects, disposal needs, and fire and ignition concerns.

The selection of appropriate personal protective equipment for exposure control often requires both an understanding of the limitations of the equipment, and the expected exposure parameters as determined by an industrial hygiene evaluation. Engineering controls are considered the preferred method of control, but personal protective equipment plays an important role for health, safety, and rescue, especially when using confined space entry procedures. The potential for misuse or misapplication of these devices should be evaluated.

The Occupational Safety and Health Administration, the American Conference of Governmental Industrial Hygienists, and the National Institute of Occupational Safety and Health are three organizations which establish many of the rules governing allowable workplace exposures. Permissible exposure limits for noise, chemicals, heat, and other workplace stressors have been established and often include safety factors.

HAZARD & OPERABILITY STUDIES

INTRODUCTION

The technique of Hazard and Operability Studies, or in more common terms HAZOPS, has been used and developed over approximately four decades for 'identifying potential hazards and operability problems' caused by 'deviations from the design intent' of both new and existing process plants. Before progressing further, it might be as well to clarify some aspects of these statements.

Potential Hazard AND Operability Problems

You will note the capitalised 'AND' in the heading above. Because of the high profile of production plant accidents, emphasis is too often placed upon the identification of hazards to the neglect of potential operability problems. Yet it is in the latter area that benefits of a Hazop Study are usually the greatest. To quote an example, a study was commissioned for a new plant. Some two years previously, and for the first time, a similar study had been carried out on different plant at the same site which was then in the process of being designed. Before the latest review commenced, the Production Manager expressed the hope that the same benefits would accrue as before, stating that "in his twenty years of experience, never had a new plant been commissioned with so few problems, and no other plant had ever achieved its production targets and break-even position in so short a time".

Deviation from design intent

To deal firstly with 'design intent', all industrial plant is designed with an overall purpose in mind. It may be to produce a certain tonnage per year of a particular chemical, to manufacture a specified number of cars, to process and dispose of a certain volume of effluent per annum, etc. That could be said to be the main design intent of the plant, but in the vast majority of cases it would also be understood that an important subsidiary intent would be to conduct the operation in the safest and most efficient manner possible.

With this in mind equipment is designed and constructed which, when it is all assembled and working together, will achieve the desired goals. However, in order to do so, each item of equipment, each pump and length of pipework, will need to consistently function in a particular manner. It is this manner which could be classified as the 'design intent' for that particular item. To illustrate, imagine that as part of the overall production requirement we needed a cooling water facility. For this we would almost certainly have cooling water circuit pipework in which would be installed a pump as very roughly illustrated below.

A much simplified statement as to the design intent of this small section of the plant would be "to continuously circulate cooling water at an initial temperature of xºC and at a rate of xxx litres per hour". It is usually at this low level of design intent that a Hazop Study is directed. The use of the word 'deviation' now becomes more easy to understand. A deviation or departure from the design intent in the case of our cooling facility would be a cessation of circulation, or the water being at too high an initial temperature. Note the difference between a deviation and its cause. In the case above, failure of the pump would be a cause, not a deviation.

Industries in which the technique is employed

Hazops were initially 'invented' by ICI in the United Kingdom, but the technique only started to be more widely used within the chemical process industry after the Flixborough disaster in 1974. This chemical plant explosion killed twenty eight people and injured scores of others, many of those being members of the public living nearby. Through the general exchange of ideas and personnel, the system was then adopted by the petroleum industry, which has a similar potential for major disasters. This was then followed by the food and water industries, where the hazard potential is as great, but of a different nature, the concerns being more to do with contamination rather than explosions or chemical releases.

The reasons for such widespread use of Hazops

Safety and reliability in the design of plant initially relies upon the application of various codes of practise, or design codes and standards. These represent the accumulation of knowledge and experience of both individual experts and the industry as a whole. Such application is usually backed up by the experience of the engineers involved, who might well have been previously concerned with the design, commissioning or operation of similar plant.

However, it is considered that although codes of practise are extremely valuable, it is important to supplement them with an imaginative anticipation of deviations which might occur because of, for example, equipment malfunction or operator error. In addition, most companies will admit to the fact that for a new plant, design personnel are under pressure to keep the project on schedule. This pressure always results in errors and oversights. The Hazop Study is an opportunity to correct these before such changes become too expensive, or 'impossible' to accomplish.

Although no statistics are available to verify the claim, it is believed that the Hazop methodology is perhaps the most widely used aid to loss prevention. The reason for this can most probably be summarised as follows:

It is easy to learn.
It can be easily adapted to almost all the operations that are carried out within process industries.
No special level of academic qualification is required. One does not need to be a university graduate to participate in a study.

THE BASIC CONCEPT

Essentially the Hazops procedure involves taking a full description of a process and systematically questioning every part of it to establish how deviations from the design intent can arise. Once identified, an assessment is made as to whether such deviations and their consequences can have a negative effect upon the safe and efficient operation of the plant. If considered necessary, action is then taken to remedy the situation.

This critical analysis is applied in a structured way by the Hazop team, and it relies upon them releasing their imagination in an effort to discover credible causes of deviations. In practice, many of the causes will be fairly obvious, such as pump failure causing a loss of circulation in the cooling water facility mentioned above. However, the great advantage of the technique is that it encourages the team to consider other less obvious ways in which a deviation may occur, however unlikely they may seem at first consideration. In this way the study becomes much more than a mechanistic check-list type of review. The result is that there is a good chance that potential failures and problems will be identified which had not previously been experienced in the type of plant being studied.

Keywords

An essential feature in this process of questioning and systematic analysis is the use of keywords to focus the attention of the team upon deviations and their possible causes. These keywords are divided into two sub-sets:

Primary Keywords which focus attention upon a particular aspect of the design intent or an associated process condition or parameter.
Secondary Keywords which, when combined with a primary keyword, suggest possible deviations.

The entire technique of Hazops revolves around the effective use of these keywords, so their meaning and use must be clearly understood by the team. Examples of often used keywords are listed below.

Primary Keywords

These reflect both the process design intent and operational aspects of the plant being studied. Typical process oriented words might be as follows. The list below is purely illustrative, as the words employed in a review will depend upon the plant being studied.

	Flow	Temperature
	Pressure	Level
	Separate (settle, filter, centrifuge)	Composition
	React	Mix
	Reduce (grind, crush, etc.)	Absorb
	Corrode	Erode

Note that some words may be included which appear at first glance to be completely unrelated to any reasonable interpretation of the design intent of a process. For example, one may question the use of the word Corrode, on the assumption that no one would intend that corrosion should occur. Bear in mind, however, that most plant is designed with a certain life span in mind, and implicit in the design intent is that corrosion should not occur, or if it is expected, it should not exceed a certain rate. An increased corrosion rate in such circumstances would be a deviation from the design intent.

Remembering that the technique is called Hazard & OperabilityStudies, added to the above might be relevant operational words such as:

	Isolate	Drain
	Vent	Purge
	Inspect	Maintain
	Start-up	Shutdown

This latter type of Primary Keyword is sometimes either overlooked or given secondary importance. This can result in the plant operator having, for example, to devise impromptu and sometimes hazardous means of taking a non-essential item of equipment off-line for running repairs because no secure means of isolation has been provided. Alternatively, it may be discovered that it is necessary to shut down the entire plant just to re-calibrate or replace a pressure gauge. Or perhaps during commissioning it is found that the plant cannot be brought on-stream because no provision for safe manual override of the safety system trips has been provided.

Secondary Keywords

As mentioned above, when applied in conjunction with a Primary Keyword, these suggest potential deviations or problems. They tend to be a standard set as listed below:

	Word	Meaning
	No	The design intent does not occur (e.g. Flow/No), or the operational aspect is not achievable (Isolate/No)
	Less	A quantitative decrease in the design intent occurs (e.g. Pressure/Less)
	More	A quantitative increase in the design intent occurs (e.g. Temperature/More)
	Reverse	The opposite of the design intent occurs (e.g. Flow/Reverse)
	Also	The design intent is completely fulfilled, but in addition some other related activity occurs (e.g. Flow/Also indicating contamination in a product stream, or Level/Also meaning material in a tank or vessel which should not be there)
	Other	The activity occurs, but not in the way intended (e.g. Flow/Other could indicate a leak or product flowing where it should not, or Composition/Other might suggest unexpected proportions in a feedstock)
	Fluctuation	The design intention is achieved only part of the time (e.g. an air-lock in a pipeline might result in Flow/Fluctuation)
	Early	Usually used when studying sequential operations, this would indicate that a step is started at the wrong time or done out of sequence
	Late	As for Early

It should be noted that not all combinations of Primary/Secondary words are appropriate. For example, Temperature/No (absolute zero or -273ºC !) or Pressure/Reverse could be considered as meaningless.

HAZOP STUDY METHODOLOGY

In simple terms, the Hazop study process involves applying in a systematic way all relevant keyword combinations to the plant in question in an effort to uncover potential problems. The results are recorded in columnar format under the following headings:

DEVIATION	CAUSE	CONSEQUENCE	SAFEGUARDS	ACTION

In considering the information to be recorded in each of these columns, it may be helpful to take as an example the simple schematic below. Note that this is purely representational, and not intended to illustrate an actual system.

Deviation
The keyword combination being applied (e.g. Flow/No).

Cause
Potential causes which would result in the deviation occurring. (e.g. "Strainer S1 blockage due to impurities in Dosing Tank T1" might be a cause of Flow/No).

Consequence
The consequences which would arise, both from the effect of the deviation (e.g. "Loss of dosing results in incomplete separation in V1") and, if appropriate, from the cause itself (e.g. "Cavitation in Pump P1, with possible damage if prolonged").

Always be explicit in recording the consequences. Do not assume that the reader at some later date will be fully aware of the significance of a statement such as "No dosing chemical to Mixer". It is much better to add the explanation as set out above.

When assessing the consequences, one should not take any credit for protective systems or instruments which are already included in the design. For example, suppose the team had identified a cause of Flow/No (in a system which has nothing to do with the one illustrated above) as being spurious closure of an actuated valve. It is noticed that there is valve position indication within the Central Control Room, with a software alarm on spurious closure. They may be tempted to curtail consideration of the problem immediately, recording something to the effect of "Minimal consequences, alarm would allow operator to take immediate remedial action". However, had they investigated further they might have found that the result of that spurious valve closure would be over pressure of an upstream system, leading to a loss of containment and risk of fire if the cause is not rectified within three minutes. It only then becomes apparent how inadequate is the protection afforded by this software alarm.

Safeguards
Any existing protective devices which either prevent the cause or safeguard against the adverse consequences would be recorded in this column. For example, you may consider recording "Local pressure gauge in discharge from pump might indicate problem was arising". Note that safeguards need not be restricted to hardware… where appropriate, credit can be taken for procedural aspects such as regular plant inspections (if you are sure that they will actually be carried out!).

Action
Where a credible cause results in a negative consequence, it must be decided whether some action should be taken. It is at this stage that consequences and associated safeguards are considered. If it is deemed that the protective measures are adequate, then no action need be taken, and words to that effect are recorded in the Action column.

Actions fall into two groups:

Actions that remove the cause.
Actions that mitigate or eliminate the consequences.

Whereas the former is to be preferred, it is not always possible, especially when dealing with equipment malfunction. However, always investigate removing the cause first, and only where necessary mitigate the consequences. For example, to return to the "Strainer S1 blockage due to impurities etc." entry referred to above, we might approach the problem in a number of ways:

Ensure that impurities cannot get into T1 by fitting a strainer in the road tanker offloading line.
Consider carefully whether a strainer is required in the suction to the pump. Will particulate matter pass through the pump without causing any damage, and is it necessary to ensure that no such matter gets into V1. If we can dispense with the strainer altogether, we have removed the cause of the problem.
Fit a differential pressure gauge across the strainer, with perhaps a high dP alarm to give clear indication that a total blockage is imminent.
Fit a duplex strainer, with a regular schedule of changeover and cleaning of the standby unit.

Three notes of caution need to be borne in mind when formulating actions. Do not automatically opt for an engineered solution, adding additional instrumentation, alarms, trips, etc. Due regard must be taken of the reliability of such devices, and their potential for spurious operation causing unnecessary plant down-time. In addition, the increased operational cost in terms of maintenance, regular calibration, etc. should also be considered (the lifetime cost of a simple instrument will be at least twice its purchase price… for more complex instrumentation this figure will be significantly greater). It is not unknown for an over-engineered solution to be less reliable than the original design because of inadequate testing and maintenance.

Finally, always take into account the level of training and experience of the personnel who will be operating the plant. Actions which call for elaborate and sophisticated protective systems are wasted, as well as being inherently dangerous, if operators do not, and never will, understand how they function. It is not unknown for such devices to be disabled, either deliberately or in error, because no one knows how to maintain or calibrate them.

Considering all Keywords - The Hazop procedure

Having gone through the operations involved in recording a single deviation, these can now be put into the context of the actual study meeting procedure. From the flow diagram below it can be seen that it is very much an iterative process, applying in a structured and systematic way the relevant keyword combinations in order to identify potential problems.

Chemicals have become a part of our life for sustaining many of our day-to-day activities, preventing and controlling diseases, and increasing agricultural productivity etc. An estimation of one thousand new chemicals enter the market every year, and about 100000 chemical substances are used on a global scale. These chemicals are mostly found as mixtures in commercial products. Over one million such products or trade names are available.

The chemical industrial sector is highly heterogeneous encompassing many sectors like organic, inorganic chemicals, dyestuffs, paints, pesticides, specialty chemicals, etc. Some of the prominent individual chemical industries are caustic soda, soda ash, carbon black, phenol, acetic acid, methanol and azo dyes. Chemical manufacturing sector in India is well established and has recorded a steady growth in the overall Indian industrial scenario. The Chemical and allied industries have been amongst the faster growing segments of the Indian industry. The Indian chemical industrial sector had a turnover of around Rs.1200 billion in 2001-2002. The chemical exports also accounts for more than 16.20% of the total Indian exports during 2001-2002.

The risks associated with the chemical industry are commensurate with their rapid growth and development. Apart from their utility, chemicals have their own inherent properties and hazards. Some of them can be flammable, explosive, toxic or corrosive etc. The whole lifecycle of a chemical should be considered when assessing its dangers and benefits. Though many of chemical accidents have a limited effect, occasionally there are disasters like the one in Bhopal, India, in 1984, where lakhs of people were affected and LPG explosion in Vizag refinery where huge property damage in addition to 60 deaths was experienced. Therefore chemicals have the potential to affect the nearby environment also.

· Design and Pre-modification review : Improper layout like location of plant in down wind side of tank farm , fire station near process area , process area very close to public road and wrong material of selection had caused severe damages to the work and outside environment

· Chemical Risk Assessment: Not assessed for new chemicals from the point of view of compatibility, storage, fire protection, toxicity, hazard index rating, fire and explosion hazards

· Process Safety Management: HAZOP, FTA, F&E Index calculation, reliability assessment of process equipment, incorporating safety trips and interlocks, scrubbing system, etc. not done before effecting major process changes, lack of Management of Change procedure (MoC), etc.

· Electrical Safety: Hazardous area classification , protection against static electricity , improper maintenance of specialized equipment like flameproof etc were ignored.

· Safety Audits: Periodical assessment of safety procedures and practices, performance of safety systems and gadgets along with follow up measures were not carried out.

· Emergency Planning: Lack of comprehensive risk analysis indicating the impact of consequences and specific written down and practiced emergency procedures along with suitable facilities had increased the severity of the emergency situations.

· Training: Safety induction and periodical refresher training for the regular employees and contract workmen were not carried out.

· Risk Management & Insurance Planning: Thorough identification and analysis of all risks and insurance planning were not done so that interruption risks and public liability risks could also be managed effectively.

A. Risk Management

Following specialized risk management services are required to chemical industries, considering the kind of risks that exists in these plant operations:

1. STANDARD CONFORMANCE and PERFORMANCE EVALUATION (SCOPE)

SCOPE would evaluate the existing measures / system based on applicable national / international standards.

A few SCOPE reviews that we recommend for chemical manufacturing plants are:

1.1 SCOPE-FP (Fire Protection)

Indian Standards

· IS 2189 - Standard for automatic fire detection and alarm system

· IS 2190 - Code of practice for selection, installation and maintenance of first aid fire extinguishers

· IS 3844 - Code of practice for installation and maintenance of internal fire hydrants and hose reels

· IS 6382 - Carbon dioxide fire extinguishing system - fixed, design and installation

TAC Standard

Tariff Advisory Committee recommendations on hydrant and sprinkler system for fire protection.

Oil Industry Safety Directorate

· OISD 117 - Fire Protection Facilities for Petroleum Depots and Terminals

· OISD 142 - Inspection of fire fighting equipment and systems

· OISD 158 - Recommended Practices on Storage and Handling of Bulk Liquefied Petroleum Gas

NFPA Standards

· NFPA 12 Carbon Dioxide Fire Extinguishing Systems

· NFPA 654 Prevention of Fire & Dust in Pharmaceutical Industries

· NFPA 1600 Disaster Management

· NFPA 921 Fire & Explosion Investigation

· NFPA 45 Fire protection for Laboratories using Chemicals

1.2 SCOPE - OHS (Occupational Health and Safety)

· IS 14489 Code of Practice for Occupational Safety & Health Audit

· NFPA 101 Life Safety Code

1.3 SCOPE-ER (Electrical Risk)

· Hazardous Area Classification (base standard: IS 5572)

· Selection of Electrical Equipment for Hazardous Areas (base standard: IS 5571)

· Lightning Protection (base document: IS: 2309 /NFPA 780 /BS 6651)

· NFPA 70 BRecommended Practice for Electrical Equipment Maintenance

· NFPA 70 EStandard for Electrical Safety in Employee Work places

2.0 PROCESS SAFETY MANAGEMENT

· Hazard & Operability (HAZOP) studies

· Failure Tree Analysis (FTA)

· Event Tree Analysis (ETA)

· Primary Hazard Analysis (PHA) using Dow Index

· Risk Assessment (with risk ranking technique)

3.0 ELECTRICAL RISK ASSESSMENT

· Review of Hazardous Area Classification

· Lightning Protection Risk Assessment

· Identification & Control of Electro-Static Hazards

· Review of electrical Preventive Maintenance System

· Electrical Risk Assessment (fire, shock explosion) using Semi-Quantitative Risk Ranking (SQRR) technique

4.0 FIRE RISK ASSESSMENT

· Identification & assessment of fire risks during operations in receipt, storage, transfer and handling of chemicals (raw materials and finished products)

· Identification & control of ignition sources in areas where flammable chemicals are stored / handled / transferred

o Review of chemical compatibility in storage areas and to suggest appropriate fire loss control measures

o Review of fire detection measures adopted in the plant & to suggest suitable improvement measures

o Review of the various active (fire hydrant, sprinkler, portable fire extinguishers) and passive fire protection requirements for chemical storage and handling areas and to suggest improvements as necessary

o Review of contractor safety awareness (chemical spill, fire fighting, emergency communication, knowledge of plant hazards & safety regulations) and to recommend suitable improvement measures to enhance contractor safety

o Review of safety awareness and safety training requirements ( training identification and efficacy) of plant employees with respect to hazards present in the plant

Fire risk assessment will be carried out based on techniques like Matrix method, Hani Raafat Risk Calculator. The consequence, likelihood and exposure of each hazard are arrived using a systematic approach and will help to determine the relative importance of hazard and focus on significant risks.

5.0 RISK ANALYSIS & EMERGENCY PLAN

· Identification of scenarios of potential disasters / emergencies leading to loss of life , property damage etc. and qualitative assessment of their likelihood.

· Quantitative risk assessment for selected scenarios of major credible events.

· Recommendations for risk control measures wherever applicable.

· Preparation of onsite emergency preparedness plan

6.0 RISK MANAGEMENT & INSURANCE PLANNING

Identification of all major internal and external pure risks including the natural risks and analysis of the impact of above risks
Review of existing risk control measures and offering comments
Scrutiny of all existing major insurance policies in respect of:

Rationalization of basic rate of premium and widening of covers
Applicability / eligibility of discounts in premium
Application of suitable clauses, warranties and conditions

Identification of possible areas for refund of premium and suggestions regarding procedure for the same
Selection of insurance coverage on the basis of risk analysis
Providing guidelines for fixation of sum insured and illustrate the same on a selected equipment
Evaluation of business interruption exposure due to identified risks
Providing guidelines on documentation requirements, procedures for claims under various policies, evaluation of insurers

B. Risk Management Training

Specialized and focussed training, if imparted effectively, can contribute significantly to Risk Management. Expert faculty, carefully selected training module, interactive and participate approach, useful training material, case studies and syndicate exercises could help in having effective risk management system in place. The training topics for bulk drug industry could be:

· Chemical Safety

· Safety with Compressed gases

· Solvent Safety

· Hazard Identification Techniques

· Industrial Risk Management

· Fire Prevention and Protection

· Electrical Risk Management

· Emergency Preparedness

· Safety Management system

· Accident Prevention

· Personal Protective Equipment