Sr.

No Observations Reference Classification Status

1. No Legal Compliance Checklist established. To create Legal BOCW Act,  To provide the checklist and conduct
Compliance Checklist and to conduct the evaluation of 1996 – Section evaluation every 6 month.
compliance in frequent basis. 39, Factories
Act, 1948 –  Labor laws (BOCW Act, Factories Act, EPF
Section 7A Act, Contract Labor Act, etc.)
 Environmental regulations (EPA Act, Air &
Water Pollution Acts, Hazardous Waste
Rules, etc.)
 Workplace safety laws (OSHA, IS standards,
fire safety, electrical safety, etc.)
 Statutory permits and approvals applicable to
the project.

 Assign a compliance officer to oversee

2. During a site inspection, gaps in the Health & Safety Factories Act,  A comprehensive H&S maintenance
(H&S) Maintenance System were identified, such as: 1948, IS inspection must be conducted immediately to
13367:1992, identify defective equipment and initiate
 Lack of preventive maintenance for machinery, and ISO corrective actions.
tools, and safety equipment. 45001:2018  All maintenance activities must comply with
 No structured inspection or maintenance Factories Act, 1948 & ISO 45001:2018 to
tracking system. ensure workplace safety and regulatory
 Workers using defective or poorly maintained compliance.
equipment, increasing accident risks.  Digital system must be implemented to track
 Violation of legal requirements (Factories Act, H&S maintenance schedules and ensure
1948, IS 13367:1992, and ISO 45001:2018 for timely servicing of equipment.
OHS Maintenance).  All workers must receive training on safe
equipment usage and the importance of
reporting maintenance issues.

3. During a site review, gaps in the Incident Management BOCW Act,  Ensure compliance with BOCW Act, 1996 &
System were identified, such as: 1996 & ISO ISO 45001:2018.
45001:2018  Develop & train workers on an Em Conduct
 Lack of a structured reporting and investigation Root Cause Analysis (RCA) for all incidents
process for workplace incidents. emergency Response Plan.
 Delayed or incomplete response to incidents,  Implement a digital incident tracking system
leading to repeated safety failures.
 No root cause analysis (RCA) conducted for
previous incidents.
 Violation of safety regulations (Factories Act,
1948, BOCW Act, 1996, ISO 45001:2018).

4. During a site review, it was gaps that Monthly ISO  Monthly HSE Walkthrough must be
HSE Management Walkthrough Reports were 45001:2018 conducted on the first week of every
not updated, leading to: & Factories month, and reports should be
Act, 1948 completed within 48 hours.
 Lack of documentation on workplace  Digital HSE reporting system must be
hazards, near misses, and safety implemented to track walkthrough
improvements. findings, corrective actions, and
 Failure to track safety compliance, closure status.
increasing risk of repeated violations.  HSE Walkthrough Reports must be
 Non-compliance with safety regulations maintained as per ISO 45001:2018 &
(BOCW Act, 1996, Factories Act, 1948, Factories Act, 1948 for regulatory
ISO 45001:2018). compliance.
 Reduced accountability in identifying  Each hazard identified during the
and resolving health, safety, and walkthrough must have an assigned
environmental (HSE) issues. responsible person and a completion
deadline for corrective actions.
 Conduct training for staff on
walkthrough reporting
 Schedule monthly walkthroughs &
follow-up inspections.
5.

6. No evidence of the roles and responsibilities communicated BOCW Act, The briefing will be conducted at the next Safety
to all of the project’s personnel. 1996 & ISO committee Meeting to all Site Staff committee and will
To conduct briefing to all project personnel during the 45001:2018 be include into minute meeting.
toolbox talk,HSC meeting and etc.
7. During a review, it was observed that the Environmental, BOCW Act,  Prepare a structured EHSS
Health, Safety & Security (EHSS) organization chart was 1996- Section organization chart defining roles,
neither submitted officially for approval nor updated as 39 & Factories reporting lines, and key
per project requirements. Key concerns include: Act, 1948 – responsibilities.
Section 40B  Submit the chart for official
 Lack of clarity on EHSS roles and ISO approval to management and
responsibilities, leading to mismanagement of 45001:2018- relevant authorities.
safety duties.  Ensure compliance with company
 No formal structure to define authority and policies, project safety
accountability for EHSS functions. requirements, and industry
 Failure to comply with regulatory requirements standards.
(BOCW Act, 1996, Factories Act, 1948, and ISO
45001:2018).
 Reduced effectiveness of safety management and
incident response due to unclear reporting
structures.

8. During a site inspection, Health & Safety (H&S) Risk BOCW Act,  Perform a Hazard Identification & Risk
Management gaps were identified, leading to: 1996-Section 40 Assessment (HIRA) for all work activities.
& ISO  Use qualitative & quantitative risk
 Unidentified workplace hazards, increasing the 45001:2018- assessment methods (e.g., risk matrix, JSA).
risk of accidents and injuries. Section 7A  All identified high-risk activities must have
 Lack of a structured risk assessment process, strict control measures, such as fall protection
causing non-compliance with safety regulations. for working at height.
 Inadequate control measures, resulting in unsafe  All risk management processes must comply
working conditions. with BOCW Act, 1996-Section 40 & ISO
 Violation of regulatory requirements (BOCW 45001:2018-Section 7A to ensure workplace
Act, 1996, Factories Act, 1948, ISO 45001:2018 safety.
for OHS Management).  All workers must attend risk management
training sessions every six months to improve
 hazard awareness.
 Maintain a Risk Register & implement digital
reporting.
 Review & update the Risk Management Plan
based on incidents.
9. Training Evaluation/ feedback system is not available with ISO 45001 L  Develop a basic pre- and post-training test.
most agencies.  Conduct training and distribute feedback
forms.
 Collect and analyze feedback
10. Post-employment health check-up of contractor workers are 223 of BOCW M  Include post-employment medical tests in
not done. rule 1998 contractor agreements.
 Identify high-risk job categories and required
medical tests.
 Maintain health surveillance records.
11. Consequence management system is not available for any Industry Best L  Develop a Contractor Performance Scorecard
contractor. Practice covering.
 Safety Compliance (e.g., PPE use, incident
rates).
 Quality of Work (e.g., meeting deadlines,
defects).
 Environmental Compliance (e.g., waste
management, pollution control).
 Regulatory Adherence (e.g., ISO, EPA
compliance).
 Establish KPIs (Key Performance Indicators)
for each category.
12. Lead and lag indicators are not proper maintained by the ISO 45001 L  Ensures consistency in data collection and
agencies. analysis.
 Establish clear definitions of Lead
Indicators (proactive) and Lag Indicators
(reactive).
 Use international safety standards (e.g.,
ISO 45001) to define indicators.
13. Behavioral safety management is not adequately followed. Industry Best M  Implement a Behavioral-Based Safety (BBS)
Practice Program.
 Use Positive Reinforcement for Safe
Behaviors.
 Conduct Regular Behavioral Safety Training
 & Simulations.
 Establish a Behavioral Safety Observation &
Feedback System
14. Site specific safety committee not established by most Sr. No. 7.3.4 of L  Mandate Safety Committees as a Legal &
agencies. BPREP/EIL Contractual Requirement.
HSE Plan for  Establish a Clear Meeting Schedule &
Site operations Agenda.
 Assign Responsibilities & Accountability for
Safety Actions.
 Implement a Safety Issue Reporting &
Resolution System.
 Train Safety Committee Members on Roles &
Responsibilities
15. Few agencies established site safety committees but meeting Sr. No. 7.3.4 of L  Implement a Standardized Meeting
were not evidenced. BPREP HSE Documentation Process.
Plan for Site  Require Mandatory Attendance Records &
operations Signatures.
 Establish a Meeting Schedule & Compliance
Tracking System.
 Require Senior Management Review & Sign-
Off on Meeting Minutes.
16. Mass meeting / Mass TBT meetings are not conducted by Industry Best L  Make Mass Meetings & Toolbox Talks
most of the agencies. Practice Mandatory.
 Establish a Fixed Schedule for Mass
Meetings & daily TBTs.
 Standardized Toolbox Talk Topics Based on
Site Risks.
17. Supervisors, Managers & RCM do not participate in Industry Best L  Ensure leadership participation in safety
safety reward programs Practice programs
 Develop a structured Safety Motivational
Program and
 Every month, supervisors will
nominate a Safety Champion, who will be
awarded by the project manager.
 Implement safety leaderboards &
performance tracking
18. Child labour engaged for construction work The child labour H  Immediately remove the child from the site &
(prohibition and report the incident.
 regulation) act,  Enforce compliance with Child Labour Act,
1986 1986 & BOCW Act, 1996.
 Strengthen access control to prevent
unauthorized entry.
 Display "Child Labor Prohibited" signboards
at all site entry points.
 Conduct surprise inspections to check for
child labor violations
19. Guarding was not available for rotating part of several R-37, 66 of H  Install fixed or adjustable guards on all
machines. BOCW rule rotating parts (pulleys, belts, gears, shafts,
1998, Non- flywheels).
compliance with  Use interlocking guards that stop the
M.P. Factories machine if removed.
Rules, 1962  Apply mesh guards or enclosures for larger
moving parts.
20. Unsafe practice of compressed gas cylinders handling / Gas Cylinders L  Violation of Factories Act, 1948, Gas
transportation at site. Rules, 2016 Cylinder Rules, 2016.
 Follow Gas Cylinder Rules, 2016, which
specify storage, handling, and transport
guidelines.
 Store cylinders upright and secure them with
chains or clamps.
 Keep oxygen cylinders at least 6 meters (20
feet) away from fuel gases.
 Ensure Material Safety Data Sheets
(MSDS) are available for each gas type.
21. Rubber mat, fire extinguishers not available in electrical IS: 15652:2006, M  Place IS 15652-certified rubber mats in
booth. CEA Regulation front of all electrical panels.
2010  Install CO2 (Carbon Dioxide) or Class C
fire extinguishers to combat electrical fires.
 Conduct visual inspections to verify
installation compliance.
 Conduct monthly inspections of rubber
mats and fire extinguishers.
22. Deep excavation adjacent to road, no hard barication or regulations H  Ensure compliance with BOCW Act, 1996
signage provided. (BOCW Act, & IS 3764:1992
1996 & IS  Install strong barricades (steel, concrete, or
3764:1992 wooden planks) at least 1.2 meters high
 around excavation edges.
 Use reflective safety signage such as
"DANGER – DEEP EXCAVATION
AHEAD" in regional languages.
 Implement traffic safety measures and
pedestrian access control.
 Conduct safety training for workers &
supervisors.
 Conduct emergency response drills for
excavation incidents

23. Worker Taking rest near Electrical Panel area. Factories Act, H  Clearly mark electrical panel areas as "No
1948 & CEA Unauthorised Access.
Safety  Relocate resting areas to safe zones away
Regulations, from high-voltage equipment.
2010  Install physical barriers (fencing or
partitions) around electrical panels to
prevent unauthorized access.
 Comply with Factories Act, 1948 – Section
32, which mandates protection from electrical
hazards.
 Train workers on electrical hazard
awareness & safe workplace behavior.
 Display "DANGER – High Voltage"
signage near electrical panels.

24. No ID Card, No Indication displayed near all Contractors Factories Act, H  All contractor workers must be registered as
areas. 1948 – Section per BOCW Act, 1996, ensuring identification
92 and compliance with safety standards.
Industry Best  Follow Factories Act, 1948 – Section 92,
Practice requiring employer identification and safety
measures at worksites.
 Ensure all contractor workers have valid ID
cards with photo, name, company, and job
role.
 Train workers and supervisors on the
importance of ID card usage & site
signage.
25. Cable joints are on handrail, may cause short circuit or (CEA H  Immediately relocate cable joints away from
electrocution. Regulations, metal handrails.
2010, IS  Use proper cable trays, conduits, or cable
732:2019) ducts for routing electrical cables safely.
 Ensure all cable joints are enclosed in
insulated, waterproof junction boxes to
prevent short circuits.
 Follow IS 732:2019 – Code of Practice for
Electrical Wiring Installations, which
mandates proper cable jointing and routing.

26. Earth pit in poor condition, no identification or ohm value IS: 3043.2018, H  Follow IS 3043:2018 – Code of Practice for
mentioned. CEA Regulation Earthing, which mandates proper earthing
2010 system design and maintenance.
 Comply with CEA (Central Electricity
Authority) Safety Regulations, 2010, which
require periodic testing and record-keeping
of earthing systems.
 Ensure connection of all equipment
grounding to properly maintained earth
pits.
 Conduct quarterly inspections of earth pits
to check for damage or loose connections.
 Mark each earth pit with identification
numbers and install signage
27. Compressed gas cylinders were laid in many elevations and Gas Cylinders M  Follow Gas Cylinder Rules, 2016, which
ground. Rules, 2016 require safe storage and handling of gas
cylinders.
 Use IS 7653:1975 standards for gas
cylinder storage to ensure proper separation
and identification.
 Designate a separate, ventilated storage
zone for gas cylinders.
 Install proper racks, chains, and protective
enclosures for cylinder security
28. Lifting area there is no Barricading and no signal Man. Factories Act, H  Follow IS 13367-1:1992 – Safe Use of
1948 & IS Cranes & Lifting Equipment for proper
13367-1:1992 lifting procedures.
 for lifting  Ensure compliance with Factories Act, 1948
operations – Section 32, which mandates safety
measures in material handling.
 Lifting operations must comply with IS
13367-1:1992 and include barricading and
proper signal communication at all times.
 Train crane operators, riggers, and signal
men on proper lifting techniques and
communication.
 Conduct daily toolbox talks on lifting
hazards & safety procedures.
 Ensure all lifting personnel are certified
and competent.
29. Emergency switch of DG set (SCIPL and VRC) was not IS 15663:2006 H  Conduct monthly testing of all emergency
working. & CEA Safety stop switches to verify functionality.
Regulations,  Assign a qualified electrical engineer to
2010 inspect DG controls and emergency systems.
 All DG operators must be trained on
emergency shutdown procedures, and
emergency stop instructions must be
displayed at the DG site.
 Conduct mock emergency drills to simulate
DG failure scenarios.
 Ensure compliance with IS 15663:2006 &
CEA Safety Regulations, 2010
30. Most of the place it was observed that there was a gap in the IS 4912:2010 H  Follow IS 4912:2010 – Code of Practice for
platform. Site operations Safety in Walkways and Platforms,
ensuring no gaps.
larger than 12 mm.
 Ensure compliance with Sec 29 CFR
1910.28, which requires fall protection for
elevated work surfaces with gaps.
 Conduct platform safety training for workers.
 Display warning signs & restricted access
barriers near unsafe platforms
31. Toilets VRC,SEEPL,SCIPL were not in usable condition or BOCW Act, L  Follow BOCW Act, 1996 – Section 32,
locked. 1996 & which mandates proper sanitation for
Factories Act, construction workers.
 1948 Section 19  Ensure compliance with Factories Act, 1948
– Section 19, which requires clean and
accessible toilets for workers.
 Maintain separate toilets for male and
female workers, as required by law.
 Install temporary portable toilets if
permanent restrooms are inadequate.
 Ensure at least one toilet for every 20
workers, as per labor law recommendations.
 Place toilets at convenient locations with
proper lighting and ventilation.
32. The road is very poor condition, Ambulance may stuck H  Unlock all toilets and repair any broken
during emergency. fixtures.
 Implement a daily toilet cleaning &
maintenance schedule.
 Ensure compliance with BOCW Act, 1996 &
Factories Act, 1948
 Display toilet maintenance logs and hygiene
posters
33. Few flammable material stored inside Stores in Factories Act, H  Follow NBC 2016 (National Building
VRC,SEEPL,SCIPL and RSB. 1948 – Section Code) – Part 4: Fire and Life Safety,
37 NBC 2016 & which mandates proper storage of
IS 2190:2010 flammable substances.
 Identify and relocate flammable materials
to a designated fireproof storage area.
 Install fire extinguishers and ensure
proper ventilation in storage rooms.
 Implement a fire inspection &
maintenance checklist.
 Display fire hazard signs and emergency
procedures in storage areas.
 Conduct quarterly fire evacuation drills to
ensure emergency preparedness.
 Maintain a minimum 10-meter distance
between flammable materials and
ignition sources (electrical panels,
welding areas, etc.).
34. Wire rope slings are in damaged condition and being used. IS 2762:2009, H  Immediately remove all damaged wire rope
 OSHA 29 CFR slings from service.
1910.184 &  Tag defective slings as “DO NOT USE” and
Factories Act, store them separately to prevent reuse.
1948  Ensure lifting operations align with Factories
Act, 1948 – Section 32, which mandates
worker safety during material handling.
 Train workers on correct sling usage, load
limits, and damage identification.
 Store wire rope slings off the ground in dry,
ventilated areas to prevent rust and wear.
 Conduct monthly lifting equipment safety
audits
35. Scaffolding erecting not proper and there is no tag system Rule 127 of H  Stop work on all improperly erected
observed. BOCW Central scaffolding & ensure proper installation
Rules, 1986  Implement scaffold tagging system (Green,
Yellow, Red) at all sites.
 Conduct daily scaffold inspections before use.
 Maintain scaffold inspection records &
corrective action logs.
 Conduct surprise audits to verify scaffold
compliance