HIRARC

Hirarc is stand for Hazard Identification, Risk Assessment and Control. According to
the law on Occupational Safety and Health (OSH), HIRARC has became extremely
important because of with HIRARC we will be able to identify hazard, analyze and
assess its associated risk and then apply the suitable control measures. OSH also
comes out with the guidelines for us to follow, with the Guideline is supposed to provide
guidance on methodology of conducting HIRARC, it should be simple enough to be
used by small and medium industries and should be versatile enough to be used by
all in various economic sectors, either in the manufacturing sector, construction
sectors or any other economic sectors. The methodology of HIRARC as proposed in
the Guidelines is intended for the assessment of physical hazards. Those who intend
to assess health hazards in their workplaces, should make use of other risk
assessment guidelines designed specifically for such purposes. The purpose of th3
guideline is to provide a systematic and objective approach to assessing hazards and
their associated risks that will provide an objective measure of an identified hazard as
well as provide a method to control the risk. It is one of the general duties as prescribed
under the Occupational Safety and Health Act 1994 (Act 514) for the employer to
provide a safe workplaces to their employees and other related person.

The purpose of HIRARC are :

i. to identify factors that may cause harm to employees and others (the
hazards)
ii. to consider what the chances are of that harm actually be falling anyone in
the circumstances of a particular case and the possible severity that could
come from it (the risks)
iii. to enable employers to plan, introduce and monitor preventive measures to
ensure that the risks are adequately controlled at all times.

How HIRARC activities should be plan and conducted :

a) for situation – i. where hazard appear to pose significant threat

ii. uncertain whether existing controls are adequate
iii. before implementing corrective or preventive measures.
b) by organization intending to continuously improve OSH Management System.
It should be the duty of the employer to assign a trained personnel to lead a
 team of employees associated with one particular process or activity to conduct
HIRARC.
The process of HIRARC are :
a. classify work activities
b. identify hazard
c. conduct risk assessment (analyze and estimate risk from each
hazard), by calculating or estimating :
i. likelihood of occurrence and
ii. severity of hazard
d. decide if risk is tolerable and apply control measures (if
necessary).

Classify work activities in accordance with their similarity, such as :

i. geographical or physical areas within/outside premises

ii. stages in production/service process
iii. not too big e.g. building a car;
iv. not too small e.g. fixing a nut; or
v. defined task e.g. loading, packing, mixing, fixing the door.
The purpose of hazard identification is to highlight the critical operations of tasks.
Those tasks posing significant risks to the health and safety of employees as well as
highlighting those hazards pertaining to certain equipment due to energy sources,
working conditions or activities performed.

Hazards can be divided into three main groups :

i. health hazards
ii. safety hazards, and
iii. environmental hazards

Health hazards

An occupational health hazard is any agent that can cause illness to an individual. A
health hazard may produce serious and immediate (acute) affects, or may cause long-
term (chronic) problems. All or part of the body may be affected. Someone with an
occupational illness may not recognize the symptoms immediately. For example,
noise-induced hearing loss is often difficult for the affected individual to detect until it
is well advanced. Health hazards include chemicals (such as battery acid and
solvents), biological hazards (such as bacteria, viruses, dusts and molds), physical
agents (energy sources strong enough to harm the body, such as electric currents,
heat, light, vibration, noise and radiation) and work design (ergonomic) hazards.

Safety hazards

A safety hazard is any force strong enough to cause injury, or damage to property. An
injury caused by a safety hazard is usually obvious. For example, a worker may be
badly cut. Safety hazards cause harm when workplace controls are not adequate.
Some examples of safety hazards include, but are not limited to:

i. slipping/tripping hazards (such as wires run across floors)

ii. fire hazards (from flammable materials)
iii. moving parts of machinery, tools and equipment (such as pinch and nip
points)
iv. work at height (such as work done on scaffolds)
 v. ejection of material (such as from molding)
vi. pressure systems (such as steam boilers and pipes)
vii. vehicles (such as forklifts and trucks)
viii. lifting and other manual handling operations and
ix. working alone

Environmental hazards

An environmental hazard is a release to the environment that may cause harm or

deleterious effects. An environmental release may not be obvious. For example, a
worker who drains a glycol system and releases the liquid to a storm sewer may
not be aware, of the effect on the environment. Environmental hazards cause harm
when controls and work procedures are not followed.

Hazard identification technique

The employer shall develop a hazard identification and assessment methodology

taking into account the following documents and information :

i. any hazardous occurrence investigation reports

ii. first aid records and minor injury records
iii. work place health protection programs
iv. any results of work place inspections
v. any employee complaints and comments
vi. any government or employer reports, studies and tests concerning the
health and safety of employees
vii. any reports made under the regulation of Occupational Safety and Health
Act,1994
viii. the record of hazardous substances and
ix. any other relevant information

Hazard identification and assessment methodology

The hazard identification and assessment methodology shall include :

A. Steps and time frame for identifying and assessing the hazards. One must define
the steps for the identification of hazards and a time frame for this identification. The
following information should be included :

i. who will be responsible for the identification: for example, it may be the work
place health and safety committee, or an individual or individuals appointed by
the committee
ii. the way in which the identification reports are processed: for example, they may
be compiled and processed by the commit tee, or by individuals appointed by
the committee; and
iii. the identification time frame: for example, the identification of hazards for
workshop A must be completed in December, for workshop B in April and for
workshop C in November.

B. The keeping of a record of the hazards. After having identified the hazards, one
must establish and maintain an identification record, either in print or electronic format.

C. A time frame for reviewing and, if necessary, revising the methodology. The date
for the review of the identification: for example, the review of the identification method
will be carried out every three years. To complete hazard identification, one can use
techniques to identify hazards. Some examples of techniques include, but are not
limited to :

i. work place inspections

ii. task safety analysis or job hazard analysis
iii. preliminary investigations
iv. potential accident factors
v. failure analysis
vi. accident and incident investigations. It is in your interest to adopt your own
process and your own identification techniques so that they match oner
management procedures and the size of business. The identification method
may vary depending on the size of the work place.

Analyze and estimate risk

Risk is the determination of likelihood and severity of the credible accident/event
sequences in order to determine magnitude and to priorities identified hazards. It can
be done by qualitative, quantitative or semi quantitative method.

Qualitative analysis uses words to describe the magnitude of potential severity and
the likelihood that those severity will occur. These scales can be adapted or adjusted
to suit the circumstances and different descriptions may be used for different risks.
This method uses expert knowledge and experience to determine likelihood and
severity category.

In semi-quantitative analysis, qualitative scales such as those described above are

given values. The objective is to produce a more expanded ranking scale than is
usually achieved in qualitative analysis, not to suggest realistic values for risk such as
is attempted in quantitative analysis.

Quantitative analysis uses numerical values (rather than the descriptive scales used
in qualitative and semi-quantitative analysis) for both severity and likelihood using data
from a variety of sources such as past accident experience and from scientific
research. Severity may be determined by modeling the outcomes of an event or set of
events, or by extrapolation from experimental studies or past data. Severity may be
expressed in terms of monetary, technical or human impact criteria, or any of the other
criteria. The way in which severity and likelihood are expressed and the ways in which
they are combined to provide a level of risk will vary according to the type of risk and
the purpose for which the risk assessment output is to be used. In this guidelines
qualitative and semi quantitative method uses as an example.

Likelihood of an occurrence

This value is based on the likelihood of an event occurring. You may ask the question
“How many times has this event happened in the past?” Assessing likelihood is based
worker experience, analysis or measurement. Likelihood levels range from “most
likely” to “inconceivable.” For example, a small spill of bleach from a container when
filling a spray bottle is most likely to occur during every shift. Alternatively, a leak of
diesel fuel from a secure holding tank may be less probable. Table A indicates
likelihood using the following values :
Severity of hazard

Severity can be divided into five categories. Severity are based upon an increasing
level of severity to an individual’s health, the environment, or to property. Table B
indicates severity by using the following table :
Risk assessment

Risk can be presented in variety of ways to communicate the results of analysis to

make decision on risk control. For risk analysis that uses likelihood and severity in
qualitative method, presenting result in a risk matrix is a very effective way of
communicating the distribution of the risk throughout a plant and area in a workplace.
Risk can be calculated using the following formula :

L x S = Relative Risk

L = Likelihood

S = Severity

To use this matrix, first find the severity column that best describes the outcome of
risk. Then follow the likelihood row to find the description that best suits the likelihood
that the severity will occur. The risk level is given in the box where the row and column
meet. The relative risk value can be used to prioritize necessary actions to effectively
manage work place hazards. Table D determines priority based on the following
ranges :
Hazards that “High Risk” must have immediate actions, to resolve risk to life safety
and or the environment. Individuals responsible for required action, including follow up
must be clearly identified. A further detail risk assessment method may require such
as quantitative risk assessment as means of determine suitable controls measures.

Control Definition

Control is the elimination or inactivation of a hazard in a manner such that the hazard
does not pose a risk to workers who have to enter into an area or work on equipment
in the course of scheduled work.

Hazards should be controlled at their source (where the problem is created). The
closer a control to the source of the hazard is the better. This method is often referred
to as applying engineering controls. If this does not work, hazards can often be
controlled along the path to the worker, between the source and the worker. This
method can be referred to as applying administrative controls. If this is not possible,
hazards must be controlled at the level of the worker through the use of personal
protective equipment (PPE), although this is the least desirable control.
Selecting a suitable control

Selecting a control often involves :

i. evaluating and selecting short and long term controls

ii. implementing short-term measures to protect workers until permanent
controls can be put in place; and
iii. implementing long term controls when reasonably practicable. For
example, suppose a noise hazard is identified. Short-term controls might
require workers to use hearing protection. Long term, permanent
controls might remove or isolate the noise source.

Types of Control at the source of the hazard

A. Elimination - Getting rid of a hazardous job, tool, process, machine or substance is

perhaps the best way of protecting workers.

For example, a salvage firm might decide to stop buying and cutting up scrapped bulk
fuel tanks due to explosion hazards.

B. Substitution - Sometimes doing the same work in a less hazardous way is possible.

For example, a hazardous chemical can be replaced with a less hazardous one.
Controls must protect workers from any new hazards that are created.

Engineering control

i. Redesign - Jobs and processes can be reworked to make them safer.

For example, containers can be made easier to hold and lift.
ii. Isolation - If a hazard cannot be eliminated or replaced, it can some times
be isolated, contained or otherwise kept away from workers. For
example, an insulated and air-conditioned control room can protect
operators from a toxic chemical.
iii. Automation - Dangerous processes can be automated or mechanized.
For example, computer-controlled robots can handle spot welding
operations in car plants. Care must be taken to protect workers from
robotic hazards.
iv. Barriers - A hazard can be blocked before it reaches workers. For
example, special curtains can prevent eye injuries from welding arc
 radiation. Proper equipment guarding will protect workers from con
tacting moving parts.
v. Absorption - Baffles can block or absorb noise. Lockout systems can
isolate energy sources during repair and maintenance. Usually, the
further a control keeps a hazard away from workers, the more effective
it is.
vi. Dilution - Some hazards can be diluted or dissipated. For example,
ventilation systems can dilute toxic gasses before they reach operators.

Administrative controls

a. Safe work procedures - Workers can be required to use standardized

safety practices. The employer is expected to ensure that workers follow
these practices. Work procedures must be periodically reviewed with
workers and updated.
b. Supervision and training – Initial training on safe work procedures and
refresher training should be offered. Appropriate supervision to assist
workers in identifying possible hazards and evaluating work procedures.
c. Job rotations and other procedures can reduce the time that workers are
exposed to a hazard. For example, workers can be rotated through jobs
requiring repetitive tendon and muscle movements to prevent
cumulative trauma injuries. Noisy processes can be scheduled when no
one is in the workplace.
d. Housekeeping, repair and maintenance programs - Housekeeping
includes cleaning, waste disposal and spill cleanup. Tools, equipment
and machinery are less likely to cause injury if they are kept clean and
well maintained.
 e. Hygiene - Hygiene practices can reduce the risk of toxic materials being
absorbed by workers or carried home to their families. Street clothing
should be kept in separate lockers to avoid being contaminated by work
clothing. Eating areas must be segregated from toxic hazards. Eating
should be forbidden in toxic work areas. Where applicable, workers
should be required to shower and change clothes at the end of the shift.

Personal protective equipment

Personal protective equipment (PPE) and clothing is used when other controls
measures are not feasible and where additional protection is needed. Workers must
be trained to use and maintain equipment properly. The employer and workers must
understand the limitations of the personal protective equipment. The employer is
expected to require workers to use their equipment whenever it is needed. Care must
be taken to ensure that equipment is working properly. Otherwise, PPE may endanger
a workers health by providing an illusion of protection.

Monitoring controls

The effectiveness of controls must be checked regularly. Evaluate and monitor hazard
controls during inspections, routine maintenance, and other activities. Ask the
following questions :

a. have the controls solved the problem?

b. is any risk to workers posed by the controls contained?
c. are all new hazards being identified?
d. are significant, new hazards appropriately controlled?
e. are accident reports being analyzed?
f. are any other measures required? Document control activities to track
their effectiveness, if necessary re-evaluate hazards and implement new
control measures.
Safe work procedures

Through the completion of a Job Hazard Analysis, sometimes hazards are identified
and cannot be eliminated or engineered out of a particular task. Safe Work Procedures
are step by step instructions that allow workers to conduct their work safety when
hazards are present. A Safe Work Procedure identifies the materials and equipment
needed, and how and when to use them safety.

Safe Work Procedures are generally prepared for :

i. critical high risk jobs where accidents have or could result in severe
injuries
ii. hazardous work where accidents occur frequently
iii. new or altered tasks have been introduced
iv. new equipment has been added to a process
v. a job that requires many detailed tasks
vi. where two or more workers required for a job, and each must perform
specific tasks simultaneously; and
vii. specific tasks are done infrequently

Safe Work Procedures must include :

i. regulatory requirements
ii. necessary personal protective equipment
iii. required training
iv. worker responsibilities
v. specific sequence of steps to follow to complete the work safely
vi. required permits; and
vii. emergency procedures

An example of a task that requires the development of a safe work procedure is

confined space entry. Individuals who must work within confined spaces must ensure
that safe work procedures are developed and followed to maximize life safety.

Personal protective equipment (PPE)

Personal protective equipment means any equipment which is intended to be worn or

held by a person at work and which protects him against one or more risks to his health
or safety and any additional accessory designed to meet that objective. PPE is usually
chosen to provide protection appropriate to each of type of hazard present. There are
specifications for the types of PPE used for protecting an individual’s head, eyes,
footwear, limb and body, fire retardant clothing, respiratory, hearing, and personal
flotation devices. It may also include required apparel for example when traffic hazards
are present high visible and distinguishable “vests must be worn”.

Documenting HIRARC

Responsibility and accountability Proper management of hazards sporadically

identified in the workplace can be done through effective process. Ultimately, the
individual or team who identified the hazard must ensure proper communication of the
hazard to the appropriate workplace authority (manager, department head, or
designated person). Each HIRARC must be fully documented. The HIRARC form must
be completed by the HIRARC team and signed by the in charge personnel of the area.
Departments responsible for the hazards and their control are required to maintain all
records of assessments for at least 3 years. (In some cases, legislative requirements
will determine the minimum time to retain records). The appropriate authority is
responsible for ensuring that effective and timely controls are applied to the hazard
and communicating the results back to the originator. Management or employer must
endorse and approve the HIRARC results. Employer must communicate all HIRARC
to employees, monitor the follow up action and keep the records. The HIRARC Form
(see APPENDIX C) is an example to document the HIRARC process.

Documenting process Instructions to team leader and persons conducting HIRARC :

 complete HIRARC Form. It is recommended to use a single form for

each work process
 record the names and designation of HIRAC team members
 outline the process workflow and indicate in the form under ‘process/
location column
 list all activities ( routine and non-routine) for each work process under
the “Work Activity” column
 identify the hazards associated with each activity and record in “Hazard”
column
 determine the effect of each hazard identified and record in “Effect”
column
 record any existing hazard control measures
 determine likelihood (L) from Table A and severity (S) from Table B for
each hazard. Assign P and C rating in respectively column. The existing
control measures should be take into consideration while determine (L)
and (S)
 by using Risk Matrix ( Table C and D ) assign one risk and record in
“Risk” column
 based on the risk assigned, recommend appropriate risk control
measures ( see Table D)
 assign a suitable person to implement the recommended risk control and
indicate the follow up action date and status
 repeat the HIRARC for other activities and process
 conduct another round of HIRARC after control measures have been
implemented; and
 review HIRARC for every three years or whenever there are changes in
process or activities.
Consultation

If practicable, there must be consultation with the relevant health and safety
representative(s) when identifying, assessing and controlling risks. Consulting directly
with employees and drawing on their experience and knowledge is more effective in
reducing risk.

Training

Information, instruction and training provide employees with the skills and knowledge
to perform their work in a manner that is safe and without risks to health. It enables
them to:

i. follow health and safety procedures

ii. use risk controls set in place for their protection; and
iii. have an appreciation of the nature of the hazard; the risks associated
with their use; and the reason why risk controls are used.

Managers, Supervisors Health and Safety Representatives and others who may be
required to perform risk assessments by agreement with management shall be trained
in hazard identification risk assessment and control methods. They must be trained in
the risk assessment process and be familiar with :

i. the regulations associated with the hazard

ii. have a practical understanding of the work hazards; and
iii. consult with the Health and Safety Representative.
APPENDIX E

Example of Hazard Identification Technique

A. Job Hazard Analysis

Definition

Job Hazard Analysis (JHA) breaks a job or task into specific steps, analyzes each step
for specific hazards, develops safe work procedures to eliminate or reduce those
hazards, and integrates safe work procedures into safety and health programs. JHAs
must be developed for each job or task. Supervisors and workers must complete the
JHA together.

Procedure

Basic Steps - Job Hazard Analysis is broken down into 6 major steps :

a. Select the job task to be analyzed. Prioritize which job tasks to analyze.
Those job tasks where accidents and injuries are occurring should be
analyzed first. Look at job tasks where there is a potential for serious
 injury. Look at new job tasks, these are important if a new process
requires the development of new procedures and job tasks
b. Identify the major sequence of steps for each step (Specific job step
Description). Once a job task has been chosen, it must be broken down
into logical steps. Limit the number of steps in a JHA to a manageable
number. Most jobs can be described in ten or less steps. The job steps
must be kept in their proper sequence to ensure a proper analysis. The
opportunity to make recommendations will come later in the analysis.
c. Identify the potential hazards for each step (Hazard Identification) Once
the job steps have been chosen, the potential hazards for each step can
be identified. Whatever can go wrong may go wrong! What are the
potential hazards as a result of each task step? Is the worker exposed
to hazardous chemicals? Is the worker subject to poor workstation
design? There may only be one, or there may be a large number for each
job step.
d. Determine preventative measures to protect against the hazards
(Required Precautions)
 The most important aspect of the job hazard analysis is to determine preventive
measures to control or eliminate the identified hazards. What actions must be
taken to control or eliminate the hazard?
 Eliminate the Hazard - Substitute with less hazardous substance/ material
 Contain/Enclose the Hazard - Use a fume hood or proper shielding
 Revise Safe Work Procedures - Adding additional steps
 Reduce Worker Exposure - This is the least effective option in most cases, but
may have to be used when permanent work process change is impossible or
impracticable. Examples of this option include job rotation, where worker
exposure is reduced, and the provision of personal protective equipment (PPE)
to workers.

e. Develop a worker-training program Reformat the job hazard analysis into

a training program to help the employee eliminate or reduce hazards.
f. Re-evaluation Re-evaluate the job descriptions and modify the job
hazard analysis’ accordingly
B. Example - Job Hazard Analysis

 Selecting Jobs for Analysis

A job hazard analysis can be performed for all jobs in the workplace, whether the job
task is “special” (non-routine) or routine. Even one-step jobs—such as those in which
only a button is pressed—can and perhaps should be analyzed by evaluating
surrounding work conditions. To determine which jobs should be analyzed first, review
your job injury and illness reports. Obviously, a job hazard analysis should be
conducted first for jobs with the highest rates of disabling injuries and illnesses. Also,
jobs where “close calls” or “near misses” have occurred should be given priority.
Analyses of new jobs and jobs where changes have been made in processes and
procedures should follow. Eventually, a job hazard analysis should be conducted and
made available to employees for all jobs in the workplace.

 Involve the Employee

Once you have selected a job for analysis, discuss the procedure with the employee
performing the job and explain its purpose. Point out that you are studying the job
itself, not checking on the employee’s job performance. Involve the employee in all
phases of the analysis—from reviewing the job steps and procedures to discussing
potential hazards and recommended solutions. You also should talk to other workers
who have performed the same job.

 Conducting the Job Hazard Analysis

Before actually beginning the job hazard analysis, take a look at the general conditions
under which the job is performed and develop a checklist. Below are some sample
questions you might ask ;

a. Are there materials on the floor that could trip a worker?

b. Is lighting adequate?
c. Are there any live electrical hazards at the jobsite?
d. Are there any chemical, physical, biological, or radiation hazards associ ated
with the job or likely to develop?
 e. Are tools—including hand tools, machines, and equipment - in need of repair?
f. Is there excessive noise in the work area, hindering worker communication or
causing hearing loss?
g. Are job procedures known and are they followed or modified?
h. Are emergency exits clearly marked?
i. Are trucks or motorized vehicles properly equipped with brakes, overhead
guards, backup signals, horns, steering gear, and identification, as necessary?
j. Are all employees operating vehicles and equipment properly trained and
authorized?
k. Are employees wearing proper personal protective equipment for the jobs they
are performing?
l. Have any employees complained of headaches, breathing problems, dizziness,
or strong odors?
m. Is ventilation adequate, especially in confined or enclosed spaces?
n. Have tests been made for oxygen deficiency and toxic fumes in confined
spaces before entry?
o. Are work stations and tools designed to prevent back and wrist injuries?
p. Are employees trained in the event of a fire, explosion, or toxic gas release?

Naturally this list is by no means complete as each worksite has its own requirements
and environmental conditions. You should add your own questions to the list.
Photographs, if appropriate, may be used in creating a more detailed analysis of the
work environment.

 Breaking the Job Down

Nearly every job can be broken down into job tasks or steps. In the first part of
the job hazard analysis, list each step of the job in order of occurrence as you
watch the employee performing the job. Be sure to record enough information
to describe each job action, but do not make the breakdown too detailed. Later,
go over the job steps with the employee.
 Identifying Hazards
After you have recorded the job steps, next examine each step to determine
the hazards that exist or that might occur. Ask yourself these kinds of questions
:
 i. Is the worker wearing personal protective clothing and equipment, including
safety harnesses that are appropriate for the job?
ii. Are work positions, machinery, pits or holes, and hazardous operations
adequately guarded?
iii. Are lockout procedures used for machinery deactivation during mainte nance
procedures?
iv. Is the worker wearing clothing or jewelry that could get caught in the machinery
or otherwise cause a hazard?
v. Are there fixed objects that may cause injury, such as sharp machine edges?
vi. Is the flow of work improperly organized (e.g., Is the worker required to make
movements that are too rapid)? vii. Can the worker get caught in or between
machine parts?
vii. Can the worker be injured by reaching over moving machinery parts or
materials?
viii. Is the worker at any time in an off-balance position?
ix. Is the worker positioned to the machine in a way that is potentially dangerous?
x. xi. Is the worker required to make movements that could lead to or cause hand
or foot injuries, or strain from lifting— the hazards of repetitive motions?
xi. Can the worker be struck by an object or lean against or strike a machine part
or object?
xii. xiii. Can the worker fall from one level to another?
xiii. xiv. Can the worker be injured from lifting or pulling objects, or from carrying
heavy objects?
xiv. xv. Do environmental hazards—dust, chemicals, radiation, welding rays, heat,
or excessive noise—result from the performance of the job? Repeat the job
observation as often as necessary until all hazards have been identified.
BHOPAL TRAGEDY

This cases happen on December 3 1984. This cases are regarding of 40 tons of
methyl isocyanate gas leaked from a pesticide plant in Bhopal, India that
immediately killing at least 3,800 people and causing significant morbidity
and premature death. The company involved became the worst industrial
accident in history and immediately tried to dissociate itself from legal
responsibility. Eventually it reached a settlement with the Indian
Government through mediation of that country's Supreme Court and
accepted moral responsibility. It paid $470 million in compensation, a
relatively small amount of based on significant underestimations of the
long-term health consequences of exposure and the number of people
exposed. The disaster indicated a need for enforceable international
standards for environmental safety, preventative strategies to avoid similar
accidents and industrial disaster preparedness. This review examines the
health effects of exposure to the disaster, the legal response, the lessons
learned and whether or not these are put into practice in India in terms of
industrial development, environmental management and public health.
The company built the plant in Bhopal because of its central location and
access to transport infrastructure. The specific site within the city was
zoned for light industrial and commercial use, not for hazardous industry.
The plant was initially approved only for formulation of pesticides from
component chemicals, such as MIC imported from the parent company, in
relatively small quantities. However, pressure from competition in the
chemical industry led UCIL to implement "backward integration" – the
manufacture of raw materials and intermediate products for formulation of
the final product within one facility. This was inherently a more
sophisticated and hazardous process.
In 1984, the plant was manufacturing Sevin at one quarter of its production
capacity due to decreased demand for pesticides. Widespread crop failures
and famine on the subcontinent in the 1980s led to increased indebtedness
and decreased capital for farmers to invest in pesticides. Local managers
were directed to close the plant and prepare it for sale in July 1984 due to
decreased profitability. When no ready buyer was found, UCIL made plans
to dismantle key production units of the facility for shipment to another
developing country. In the meantime, the facility continued to operate with
safety equipment and procedures far below the standards found in its sister
plant in Institute, West Virginia. The local government was aware of safety
problems but was reticent to place heavy industrial safety and pollution
control burdens on the struggling industry because it feared the economic
effects of the loss of such a large employer.
On December 2nd, while most of the one million residents of Bhopal slept,
an operator at the plant noticed a small leak of methyl isocyanate (MIC) gas
and increasing pressure inside a storage tank. The vent-gas scrubber, a
safety device designer to neutralize toxic discharge from the MIC system,
had been turned off three weeks prior. Apparently a faulty valve had
allowed one ton of water for cleaning internal pipes to mix with forty tons
of MIC. A 30 ton refrigeration unit that normally served as a safety
component to cool the MIC storage tank had been drained of its coolant for
use in another part of the plant. Pressure and heat from the vigorous
exothermic reaction in the tank continued to build. The gas flare safety
system was out of action and had been for three months.
On December 3rd, loud rumbling reverberated around the plant as a safety
valve gave way sending a plume of MIC gas into the early morning air.
Within hours, the streets of Bhopal were littered with human corpses and
the carcasses of buffaloes, cows, dogs and birds. An estimated 3,800 people
died immediately, mostly in the poor slum colony adjacent to the UCC
plant.
Local hospitals were soon overwhelmed with the injured, a crisis further
compounded by a lack of knowledge of exactly what gas was involved and
what its effects were [1]. It became one of the worst chemical disasters in
history and the name Bhopal became synonymous with industrial
catastrophe.
Estimates of the number of people killed in the first few days by the plume
from the UCC plant run as high as 10,000, with 15,000 to 20,000
premature deaths reportedly occurring in the subsequent two decades.
The Indian government reported that more than half a million people were
exposed to the gas. Several epidemiological studies conducted soon after
the accident showed significant morbidity and increased mortality in the
exposed population. Table 1. summarizes early and late effects on health.
These data are likely to under-represent the true extent of adverse health
effects because many exposed individuals left Bhopal immediately
following the disaster never to return and were therefore lost to follow-up.
Immediately after the disaster, UCC began attempts to dissociate itself from
responsibility for the gas leak. Its principal tactic was to shift culpability to
UCIL, stating the plant was wholly built and operated by the Indian
subsidiary. It also fabricated scenarios involving sabotage by previously
unknown Sikh extremist groups and disgruntled employees but this theory
was impugned by numerous independent sources.

The toxic plume had barely cleared when, on December 7, the first multi-
billion dollar lawsuit was filed by an American attorney in a U.S. court. This
was the beginning of years of legal machinations in which the ethical
implications of the tragedy and its affect on Bhopal's people were largely
ignored. In March 1985, the Indian government enacted the Bhopal Gas
Leak Disaster Act as a way of ensuring that claims arising from the accident
would be dealt with speedily and equitably. The Act made the government
the sole representative of the victims in legal proceedings both within and
outside India. Eventually all cases were taken out of the U.S. legal system
under the ruling of the presiding American judge and placed entirely under
Indian jurisdiction much to the detriment of the injured parties.
In a settlement mediated by the Indian Supreme Court, UCC accepted
moral responsibility and agreed to pay $470 million to the Indian
government to be distributed to claimants as a full and final settlement. The
figure was partly based on the disputed claim that only 3000 people died
and 102,000 suffered permanent disabilities. Upon announcing this
settlement, shares of UCC rose $2 per share or 7% in value. Had
compensation in Bhopal been paid at the same rate that asbestosis victims
where being awarded in US courts by defendant including UCC – which
mined asbestos from 1963 to 1985 – the liability would have been greater
than the $10 billion the company was worth and insured for in 1984. By the
end of October 2003, according to the Bhopal Gas Tragedy Relief and
Rehabilitation Department, compensation had been awarded to 554,895
people for injuries received and 15,310 survivors of those killed. The
average amount to families of the dead was $2,200.

At every turn, UCC has attempted to manipulate, obfuscate and withhold

scientific data to the detriment of victims. Even to this date, the company
has not stated exactly what was in the toxic cloud that enveloped the city on
that December night. When MIC is exposed to 200° heat, it forms degraded
MIC that contains the more deadly hydrogen cyanide (HCN). There was
clear evidence that the storage tank temperature did reach this level in the
disaster. The cherry-red color of blood and viscera of some victims were
characteristic of acute cyanide poisoning. Moreover, many responded well
to administration of sodium thiosulfate, an effective therapy for cyanide
poisoning but not MIC exposure. UCC initially recommended use of sodium
thiosulfate but withdrew the statement later prompting suggestions that it
attempted to cover up evidence of HCN in the gas leak. The presence of
HCN was vigorously denied by UCC and was a point of conjecture among
researchers.

As further insult, UCC discontinued operation at its Bhopal plant following

the disaster but failed to clean up the industrial site completely. The plant
continues to leak several toxic chemicals and heavy metals that have found
their way into local aquifers. Dangerously contaminated water has now
been added to the legacy left by the company for the people of Bhopal.

The tragedy in Bhopal revealed that expanding industrialization in

developing countries without concurrent evolution in safety regulations
could have catastrophic consequences. The disaster demonstrated that
seemingly local problems of industrial hazards and toxic contamination are
often tied to global market dynamics. UCC's Sevin production plant was
built in Madhya Pradesh not to avoid environmental regulations in the U.S.
but to exploit the large and growing Indian pesticide market. However the
manner in which the project was executed suggests the existence of a
double standard for multinational corporations operating in developing
countries [1]. Enforceable uniform international operating regulations for
hazardous industries would have provided a mechanism for significantly
improved in safety in Bhopal. Even without enforcement, international
standards could provide norms for measuring performance of individual
companies engaged in hazardous activities such as the manufacture of
pesticides and other toxic chemicals in India. National governments and
international agencies should focus on widely applicable techniques for
corporate responsibility and accident prevention as much in the developing
world context as in advanced industrial nations. Specifically, prevention
should include risk reduction in plant location and design and safety
legislation.

Local governments clearly cannot allow industrial facilities to be situated

within urban areas, regardless of the evolution of land use over time.
Industry and government need to bring proper financial support to local
communities so they can provide medical and other necessary services to
reduce morbidity, mortality and material loss in the case of industrial
accidents.

Public health infrastructure was very weak in Bhopal in 1984. Tap water
was available for only a few hours a day and was of very poor quality. With
no functioning sewage system, untreated human waste was dumped into
two nearby lakes, one a source of drinking water. The city had four major
hospitals but there was a shortage of physicians and hospital beds. There
was also no mass casualty emergency response system in place in the city.
Existing public health infrastructure needs to be taken into account when
hazardous industries choose sites for manufacturing plants. Future
management of industrial development requires that appropriate resources
be devoted to advance planning before any disaster occurs. Communities
that do not possess infrastructure and technical expertise to respond
adequately to such industrial accidents should not be chosen as sites for
hazardous industry.

Following the tragedy of December 3 1984 environmental awareness and activism in

India increased significantly. The Environment Protection Act was passed in 1986,
creating the Ministry of Environment and Forests (MoEF) and strengthening India's
commitment to the environment. Under the new act, the MoEF was given overall
responsibility for administering and enforcing environmental laws and policies. It
established the importance of integrating environmental strategies into all industrial
development plans for the country. However, despite greater government
commitment to protect public health, forests, and wildlife, policies geared to
developing the country's economy have taken precedence in the last 20 years [19].

India has undergone tremendous economic growth in the two decades since the
Bhopal disaster. Gross domestic product (GDP) per capita has increased from $1,000
in 1984 to $2,900 in 2004 and it continues to grow at a rate of over 8% per year.
Rapid industrial development has contributed greatly to economic growth but there
has been significant cost in environmental degradation and increased public health
risks. Since abatement efforts consume a large portion of India's GDP, MoEF faces
an uphill battle as it tries to fulfill its mandate of reducing industrial pollution. Heavy
reliance on coal-fired power plants and poor enforcement of vehicle emission laws
have result from economic concerns taking precedence over environmental
protection.

With the industrial growth since 1984, there has been an increase in small scale
industries (SSIs) that are clustered about major urban areas in India. There are
generally less stringent rules for the treatment of waste produced by SSIs due to less
waste generation within each individual industry. This has allowed SSIs to dispose of
untreated wastewater into drainage systems that flow directly into rivers. New
Delhi's Yamuna River is illustrative. Dangerously high levels of heavy metals such as
lead, cobalt, cadmium, chrome, nickel and zinc have been detected in this river which
is a major supply of potable water to India's capital thus posing a potential health
risk to the people living there and areas downstream.

Land pollution due to uncontrolled disposal of industrial solid and hazardous waste
is also a problem throughout India. With rapid industrialization, the generation of
industrial solid and hazardous waste has increased appreciably and the
environmental impact is significant.

India relaxed its controls on foreign investment in order to accede to WTO rules and
thereby attract an increasing flow of capital. In the process, a number of
environmental regulations are being rolled back as growing foreign investments
continue to roll in. The Indian experience is comparable to that of a number of
developing countries that are experiencing the environmental impacts of structural
adjustment. Exploitation and export of natural resources has accelerated on the
subcontinent. Prohibitions against locating industrial facilities in ecologically
sensitive zones have been eliminated while conservation zones are being stripped of
their status so that pesticide, cement and bauxite mines can be built. Heavy reliance
on coal-fired power plants and poor enforcement of vehicle emission laws are other
consequences of economic concerns taking precedence over environmental
protection.

In March 2001, residents of Kodaikanal in southern India caught the Anglo-Dutch

company, Unilever, red-handed when they discovered a dumpsite with toxic mercury
laced waste from a thermometer factory run by the company's Indian subsidiary,
Hindustan Lever. The 7.4 ton stockpile of mercury-laden glass was found in torn
stacks spilling onto the ground in a scrap metal yard located near a school. In the fall
of 2001, steel from the ruins of the World Trade Center was exported to India
apparently without first being tested for contamination from asbestos and heavy
metals present in the twin tower debris. Other examples of poor environmental
stewardship and economic considerations taking precedence over public health
concerns abound.
The Bhopal disaster could have changed the nature of the chemical industry and
caused a reexamination of the necessity to produce such potentially harmful
products in the first place. However the lessons of acute and chronic effects of
exposure to pesticides and their precursors in Bhopal has not changed agricultural
practice patterns. An estimated 3 million people per year suffer the consequences of
pesticide poisoning with most exposure occurring in the agricultural developing
world. It is reported to be the cause of at least 22,000 deaths in India each year. In
the state of Kerala, significant mortality and morbidity have been reported following
exposure to Endosulfan, a toxic pesticide whose use continued for 15 years after the
events of Bhopal.

Aggressive marketing of asbestos continues in developing countries as a result of

restrictions being placed on its use in developed nations due to the well-established
link between asbestos products and respiratory diseases. India has become a major
consumer, using around 100,000 tons of asbestos per year, 80% of which is
imported with Canada being the largest overseas supplier. Mining, production and
use of asbestos in India is very loosely regulated despite the health hazards. Reports
have shown morbidity and mortality from asbestos related disease will continue in
India without enforcement of a ban or significantly tighter controls.

UCC has shrunk to one sixth of its size since the Bhopal disaster in an effort to
restructure and divest itself. By doing so, the company avoided a hostile takeover,
placed a significant portion of UCC's assets out of legal reach of the victims and gave
its shareholder and top executives bountiful profits. The company still operates
under the ownership of Dow Chemicals and still states on its website that the Bhopal
disaster was "cause by deliberate sabotage".

Some positive changes were seen following the Bhopal disaster. The British chemical
company, ICI, whose Indian subsidiary manufactured pesticides, increased attention
to health, safety and environmental issues following the events of December 1984.
The subsidiary now spends 30–40% of their capital expenditures on environmental-
related projects. However, they still do not adhere to standards as strict as their
parent company in the UK.

The US chemical giant DuPont learned its lesson of Bhopal in a different way. The
company attempted for a decade to export a nylon plant from Richmond, VA to Goa,
India. In its early negotiations with the Indian government, DuPont had sought and
won a remarkable clause in its investment agreement that absolved it from all
liabilities in case of an accident. But the people of Goa were not willing to acquiesce
while an important ecological site was cleared for a heavy polluting industry. After
nearly a decade of protesting by Goa's residents, DuPont was forced to scuttle plans
there. Chennai was the next proposed site for the plastics plant. The state
government there made significantly greater demand on DuPont for concessions on
public health and environmental protection. Eventually, these plans were also
aborted due to what the company called "financial concerns".
The tragedy of Bhopal continues to be a warning sign at once ignored and heeded.
Bhopal and its aftermath were a warning that the path to industrialization, for
developing countries in general and India in particular, is fraught with human,
environmental and economic perils. Some moves by the Indian government,
including the formation of the MoEF, have served to offer some protection of the
public's health from the harmful practices of local and multinational heavy industry
and grassroots organizations that have also played a part in opposing rampant
development. The Indian economy is growing at a tremendous rate but at significant
cost in environmental health and public safety as large and small companies
throughout the subcontinent continue to pollute. Far more remains to be done for
public health in the context of industrialization to show that the lessons of the
countless thousands dead in Bhopal have truly been heeded.

https://www.utm.my/oshe/files/2016/08/ROADSHOW-KKP-HIRARC-JHA-SOP.pdf

https://www.utm.my/oshe/hirarc-form/