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Managing a Major Hazard Installation by Ir Ahmad Nordeen Mohd Salleh. A Malaysian experience.

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MANAGING MAJOR HAZARD INSTALLATION IN MALAYSIA

MANAGING MAJOR HAZARD INSTALLATION,

MALAYSIA EXPERIENCE

Ir. Ahmad Nordeen Mohd SallehI. INTRODUCTION

There has been a rapid growth of industries over the past three decades, especially in oil, gas and petrochemical industries all over the country namely in Kerteh, Gebeng, Bintulu, Pasir Gudang and Gurun industrial estates. Like other industrial nations, these industries are huge, modern and more sophisticated types of industries, utilizing complex processes operating at high pressure and temperature, producing continuously and using hazardous substances. Major industrial accidents had happened in the past and are likely to occur again in the future if no initial attention and precautions taken to manage and control these installations. Flixborough, Bhopal and Mexico City are known place synonymous with disasters that had occurred, resulting catastrophe to human beings, properties and the environment. Bright Sparklers Firework explosion in 1991 and Tiram Kimia Depot Chemical explosion in 1992 are two examples in Malaysia with these kinds of major hazardous accidents.

II. GOVERNMENTS CONCERN

The Government has now enacted and enforced Occupational Safety and Health [Control of Industrial Major Accident Hazards (CIMAH)] Regulations in 1996, which made it mandatory for industries, exciting or new to comply with the regulations.

By definition, major hazard installation means an industrial activity which produces, processes, handles, uses, disposes of or stores, whether temporarily or permanently, one or more hazardous substances or categories of substances in quantities equal to or exceed the threshold value determined in the regulations (please see Attachment I on the threshold quantities). And major accidents means an occurrence including a major emission, fire or explosion resulting from uncontrolled development in the course of an industrial activity, which leads to serious damage to persons, whether immediate or delayed, inside or outside an installation or to the environment and involving one or more hazardous substances. The regulations ensure that the management of a major hazard installation is required to control its activity in a safe manner without endangering the workers, public, properties and the environment. The regulations apply to all installations except nuclear installations, an installation under the armed forces, transportation of hazardous substances, and an industrial activity installation having hazardous substances less than 10% of the stated threshold quantity.

III. DUTIES OF A MAJOR HAZARD INSTALLATION

With the enforcement of the regulations, a major hazard installation is responsible and accountable to the following:

1. Preparing a safety report

2. Providing workers with relevant safety information and training

3. Providing information to the neighboring public and local authority

4. Talking sufficient steps to prevent or minimize major accidents

5. Preparing Emergency Response Plan / Procedure

IV. SAFETY CASE REPORT

This report will contain specific information on four major elements, namely all the hazardous substances, the name and quantity, hazard and properties of the substances involved. Details of installation include a site map, scale plan of site showing locations and quantities of hazardous substances stored, process description and conditions, number of persons on site, population in the vicinity and nearest emergency services. Safety Management System refers to safety planning, safety organizational structure and committees, different safety responsibilities assigned to individuals safe standards and operating procedures, employees training safety assessment and performance measurements and management review and ERP preparedness and drills. While risk assessment focus on the description and analysis of potential hazards and associated risks, conditions and events, resulting in detail description of risk measures to control and minimize the emergency consequences in the premises and to the surroundings.

Detailed information to be included in the safety report is given in schedule 6 of the regulations. The report has to be prepared by a CIMAH competent person, registered with Department of Occupational Safety and Health (DOSH) Malaysia. A copy of such report will be sent to the Director General of DOSH - 3 months before commencing the industrial activity or 12 months for existing industry of the installation. A further written report by the competent person is required if the industrial activity has to be modified, a copy of such report will be sent to the Director General against 3 months before making the modification.

V. ON-SITE EMERGENCY PLAN

The manufacturer/industry which has to prepare the safety report must also submit on site emergency response plan to the Director General. The preparation of the plan must be done together with the competent person, in order to make sure that it is up to date and adequate, detailing on how major accidents would have to be dealt with during the emergency.

VI. OFF-SITE EMERGENCY PLAN

A manufacturer, having control of an industrial activity, to which this aspect applies, must also inform the local authority or port authority of the area if his industrial activity is capable of producing a major accident hazard that require an off-site emergency plan for the area surrounding the site which is likely to be affected by a major accident. The local authority or port authorities upon receiving the information will prepare and keep on up-to-date and adequate off-site emergency plan relevant to the site.

VII. INFORMATION TO THE PUBLIC

A manufacturer, having control of an industrial activity, after knowing that persons outside the site are likely to be affected by a major accident occurring at the site, must also inform the surrounding community. Items of information to be communicated to the surrounding community are given in the Regulations - Schedule 3.

VIII. CONCLUSION

CIMAH Regulations 1996 as described above give us an assurance that it would be able to meet two clear objectives:

1. Preventing major industrial accident, and

2. Minimizing the adverse effect or impact even if a major accident happens.

The approach to control specified by CIMAH is similar to those implemented elsewhere worldwide and is in line with the requirements proposed by International Labour Organization (ILO). In short, the basis of major accident hazard control promoted by CIMAH is in accordance to three basic elements: They are Identification, Prevention and Control. Managing major hazard installation in Malaysia, in accordance to CIMAH requirements is a correct solution to major accident prevention.

Attachment 1

CIMAH Regulations 1996: Schedule 2 Part 1 - Some Examples

Threshold Quantity

Group 1 - Toxic Substances (Quantity ( 1 tonne)

1Arsenic hydride10 kg

2Benzidine1 kg

3Methyl isocyanate150 kg

4Phosgene750 kg

Group 2 - Toxic Substances (Quantity > 1 tonne)

1Acrylonitrile20 tonnes

2Ammonia100 tonnes

3Chlorine10 tonnes

4Hydrogen cyanide20 tonnes

5Tetraethyl lead50 tonnes

Group 3 - Highly Reactive Substance

1Ethylene oxide5 tonnes

2Hydrogen10 tonnes

3Oxygen500 tonnes

4Propylene oxide50 tonnes

5Sodium Chlorate20 tonnes

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