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By Rajiv Shah
The Gujarat government’s just-released high-level report, “Gujarat State Chemical Disaster Management Plan (CDMP)”, has said that while formation of new rules and regulations as also enactment of new laws is important to fight chemical disasters, a more serious and immediate concern is regarding existence of what it calls a “serious gap” in enforcing existing rules and regulations to fight them. The problem has arisen particularly because, says the report, “currently, no single agency or department is made responsible for coordinated response for chemical emergency. In practice, the collector is expected to fulfill the role of coordinating response.”
Pointing out that “the international best practices are to have a single agency responsible for coordinating response of multiple response agencies during disasters, ensuring that individual response agencies are prepared to required level, and develop integrated response capability for the state”, it wants the Gujarat State Disaster Management Authority (GSDMA) to do role as a “response coordinating” agency. It underlines, “Such single emergency response office /agency is advised not only for chemical emergencies but for all hazards.”
Recommending the establishment of a chemical cell within the GSDMA, the report suggests, it should be based on international model approaches and International Labour Organisation (ILO) guidelines, and should be “helpful in preparing guidelines and procedures for the inspection, enforcement, and legal compliance by the industry, and serve as a key knowledge resource in planning for and responding to chemical emergencies.” It adds, “This cell can advise the training courses for its staff on chemical emergency management and monitor the training effectiveness. This cell can even itself conduct internal training of regional and field staff on special chemical emergencies related topics not covered in a formal training institute.”
The report simultaneously recommends that the Directorate of Industrial Safety and Health (DISH) and the Gujarat Pollution Control Board (GPCB) with the support of GSDMA should develop guidelines for the industry to report chemical leaks on basis of “quantity leaked” without waiting for the emergency to become offsite. It says, “Incidents should be reported even when they threaten environment and ecology, pointing to the type of leaks that should be reported: (i) A release of any hazardous chemical or petroleum product (in any amount) to water bodies (lake, rivers, dams, canal, sea, creek, etc.) within the state of Gujarat, and (ii) a release of any hazardous chemical or petroleum product, in a quantity of 95 litres or more, to the surface of the land (whether or not there is evaporation or fire).
At the same time, the report insists, “A state-level survey has to be done to obtain information on resource infrastructure (contact, equipment, location, etc.), critical or sensitive installations (schools, government offices, etc.), routes (chemical transportation routes, evaluation, road traffic/ condition information), and industry specific information (chemicals, location, quantity). This information must be available in interactive GIS format. The GIS database is not a one-time activity but need to be updated and maintained regularly. The most effective strategy to ensure this is that the local authorities, response agencies, and the industry are entrusted with regular updating of information.”
Referring to the poor state of fire safety in Gujarat because of lack of any central regulatory authority, the report states, “Our assessment of fire stations identifies that fire departments in larger municipal corporations such as Ahmedabad and Surat are comparatively well equipped, staffed, and trained, but all lacked sufficient trained man power and equipment as discussed in the gap analysis report and response mechanism report. Because the fire departments are attached to the municipalities, we also find lack of standardization in procedures related to staffing, training, equipment, and response between different fire departments.”
Dishing out figures, the report underlines, “Currently, only 35% of the required number of fire stations is available in the state. In addition to lack of adequate number of fire stations, even the existing fire stations have limited manpower, equipment, vehicles and training. For example, currently Gujarat has manpower of 1,447 people which is only 7.5% of the required strength of 19,222; the requirement will be higher if new fire stations are built.”
Pointing out that it is “important to build capacity of fire fighting and emergency service in Gujarat as a precursor to having chemical emergency response capability of international standard”, the report says, “At present, fire services can deal with normal fires, and their knowledge base has yet to be upgraded with an understanding and capability to handle the various types of chemical fires. A comprehensive training programme for fire department personnel is needed including but not limited to the following: Basic awareness of chemical emergency response (toxic, explosion, and fire hazards), personal decontamination and mass decontamination, coordinated response with police, search and rescue in chemical emergencies, preservation of evidence for criminal investigation, and first aid.”
In fact, the report underlines, there should basic fire structural (coat and trousers) or work uniform, a hard hat, chemical work gloves, safety glasses, safety shoes/boots, and a personal alert safety system (PASS) device, basic liquid splash and minimum respiratory protection for known chemical hazards includes, chemical specific protective coverall or two-piece suit, chemical gloves, safety glasses, safety boots, and an air-purifying respirator (APR) with appropriate cartridge or self-contained breathing apparatus (SCBA). nitrile gloves both outer and inner, neoprene and butyl rubber outer gloves, chemical resistant boots and chemical resistant booties, first aid kit monitoring equipment, electronic pulse and blood oxygen monitor, oral digital temperature thermometer, basic four gas monitor – includes cartridges for oxygen (O2), carbon monoxide (CO), Lower Explosive Limit (LEL), and choice of common toxic gas like hydrogen sulphide (H2S), sulphur dioxide (SO2), or chlorine (Cl2), and so on.
The report underlines that the need to form a special state emergency response team (SERT), which should be the most advanced hazardous chemical response team. “The key safety concern for this team is to be able to identify when an event exceeds their capacity and seek external (national/ international) support as needed.” SERT, it says, “would be primarily responsible for responding to high-risk, high-volume, and thus, less frequent incidents that surpass capacity of local or regional response agencies”. Local and regional response teams should be trained sufficiently to:
• Recognize events that may surpass local capacity to respond
• Rapidly collect information needed to define the situation and organize the appropriate response resources
• Support local incident command functions as the incident escalates.
Pointing out that a specialist regional response team (RRT) for chemical emergencies should be established from a core of the most capable local fire departments, the report states, “It will be a state level asset that can be officially mobilized for fail-proof and speedier communication. It will respond to the higher-toxicity, higher-volume chemical release incidents, releases of unknown chemicals, and complex or long duration events that require more resources than local teams are able to support. The regional response team will not replace but will augment local response capacity, and will be trained to identify events that necessitate the request for state-level (e.g., SERT) or national-level resources (e.g., NDRF).”
Then, there would be local emergency response teams (LERTs) for district or block levels, the report states, adding, “There should be at least one LERT in an industrial pocket area. LERT may draw from the local fire department and other public agencies that can provide on-scene response. LERT can include members of the industry, provided these ‘private’ resources are officially and bindingly committed and involved in planning, practice, and training. LERT should be well trained and well equipped to deal with small scale and frequent local emergencies (90% of chemical incidents).”
Finding yet another “critical gap” in fighting chemical disasters in Gujarat, the report states, this is regarding lack of “mutual aid between industries”. It says, the small industries are particularly hard-pressed as they do not have their own resources to respond to chemical emergencies. “The primary reason for this is that large industries in the mutual aid seek commensurate level of reciprocity from other member industries. Large industries do provide help to smaller units on request from them or district authorities, but as a benefactor and not under a formal or binding agreement. Considering this, we recommend a replication of Disaster Prevention and Management Centre (DPMC) model, as it exists in Ankaleshwar, for other industries’ pockets in Gujarat to serve smaller industries. “DPMC can also serve larger units in addition to mutual aid assistance from other large industries”, the report says.
Other recommendations of the report include having a structure for mock drills at local, district and state levels; Chemical Emergency Community Awareness and Preparedness (CECAP) and Chemical Emergency Community Awareness and Preparedness (CECAP) Outreach programmes to tailor to each community’s needs; Quick Reaction Medical Teams (QRMTs) to reach the accident site immediately along with resuscitation, protection, detection, and decontamination equipment and materials; a special Toxic Risk Reduction Programme, which should be “tailored to identify priority toxic chemicals in fixed industrial installations; and a special land use policy for buffer zone around major accident hazard (MAH) installations (handling/ storing extremely/ highly toxic chemicals).
Recommending a major policy change by having a buffer zone around MAH units, the report states, “Under the Central Pollution Control Board (CPCB) guidelines and also under industrial policy these installations are permitted to be set up only 25 kilometres away from major population hubs (five lakh) in case of environmental guidelines and (10 lakh) in case of industrial policy guidelines. It is necessary to have in place a mandatory mechanism by which the concerned authorities are able to regulate the development of population settlements in the proximity of the installations.”
The report recommends, “A no-population buffer zone of 500 meters around the perimeter of the MAH installations is to be set up for future installations. There should be a specific provision in the central legislation on land use planning requiring the concerned authorities in the (centre or state as the case may be ) to maintain a no population buffer zone of approximately a 500 meter width around the perimeter of an MAH installation. After the provision suggested above is made in the land use planning legislation, the necessary amendment shall be made in the rules and the environmental impact assessment notification 2006 to give necessary effect for implementation.”
The report adds, “The time to provide effective response to chemical emergencies is a key determination for buffer zone dimensions. For example, even with rapid and qualified response, population within a certain zone cannot be protected. On other hand, without a qualified response, a buffer zone of 500 meter may not be adequate. Therefore, the land use planning and permissions for new infrastructure development should consider existing hazards and vulnerability to them… Additionally, the environment department and the GPCB may consider chemical vulnerability assessment as a part of chapter on disaster management in the environmental impact assessment report as a key decision factor to permit new industry.”
The Gujarat government’s just-released high-level report, “Gujarat State Chemical Disaster Management Plan (CDMP)”, has said that while formation of new rules and regulations as also enactment of new laws is important to fight chemical disasters, a more serious and immediate concern is regarding existence of what it calls a “serious gap” in enforcing existing rules and regulations to fight them. The problem has arisen particularly because, says the report, “currently, no single agency or department is made responsible for coordinated response for chemical emergency. In practice, the collector is expected to fulfill the role of coordinating response.”
Pointing out that “the international best practices are to have a single agency responsible for coordinating response of multiple response agencies during disasters, ensuring that individual response agencies are prepared to required level, and develop integrated response capability for the state”, it wants the Gujarat State Disaster Management Authority (GSDMA) to do role as a “response coordinating” agency. It underlines, “Such single emergency response office /agency is advised not only for chemical emergencies but for all hazards.”
Recommending the establishment of a chemical cell within the GSDMA, the report suggests, it should be based on international model approaches and International Labour Organisation (ILO) guidelines, and should be “helpful in preparing guidelines and procedures for the inspection, enforcement, and legal compliance by the industry, and serve as a key knowledge resource in planning for and responding to chemical emergencies.” It adds, “This cell can advise the training courses for its staff on chemical emergency management and monitor the training effectiveness. This cell can even itself conduct internal training of regional and field staff on special chemical emergencies related topics not covered in a formal training institute.”
The report simultaneously recommends that the Directorate of Industrial Safety and Health (DISH) and the Gujarat Pollution Control Board (GPCB) with the support of GSDMA should develop guidelines for the industry to report chemical leaks on basis of “quantity leaked” without waiting for the emergency to become offsite. It says, “Incidents should be reported even when they threaten environment and ecology, pointing to the type of leaks that should be reported: (i) A release of any hazardous chemical or petroleum product (in any amount) to water bodies (lake, rivers, dams, canal, sea, creek, etc.) within the state of Gujarat, and (ii) a release of any hazardous chemical or petroleum product, in a quantity of 95 litres or more, to the surface of the land (whether or not there is evaporation or fire).
At the same time, the report insists, “A state-level survey has to be done to obtain information on resource infrastructure (contact, equipment, location, etc.), critical or sensitive installations (schools, government offices, etc.), routes (chemical transportation routes, evaluation, road traffic/ condition information), and industry specific information (chemicals, location, quantity). This information must be available in interactive GIS format. The GIS database is not a one-time activity but need to be updated and maintained regularly. The most effective strategy to ensure this is that the local authorities, response agencies, and the industry are entrusted with regular updating of information.”
Referring to the poor state of fire safety in Gujarat because of lack of any central regulatory authority, the report states, “Our assessment of fire stations identifies that fire departments in larger municipal corporations such as Ahmedabad and Surat are comparatively well equipped, staffed, and trained, but all lacked sufficient trained man power and equipment as discussed in the gap analysis report and response mechanism report. Because the fire departments are attached to the municipalities, we also find lack of standardization in procedures related to staffing, training, equipment, and response between different fire departments.”
Dishing out figures, the report underlines, “Currently, only 35% of the required number of fire stations is available in the state. In addition to lack of adequate number of fire stations, even the existing fire stations have limited manpower, equipment, vehicles and training. For example, currently Gujarat has manpower of 1,447 people which is only 7.5% of the required strength of 19,222; the requirement will be higher if new fire stations are built.”
Pointing out that it is “important to build capacity of fire fighting and emergency service in Gujarat as a precursor to having chemical emergency response capability of international standard”, the report says, “At present, fire services can deal with normal fires, and their knowledge base has yet to be upgraded with an understanding and capability to handle the various types of chemical fires. A comprehensive training programme for fire department personnel is needed including but not limited to the following: Basic awareness of chemical emergency response (toxic, explosion, and fire hazards), personal decontamination and mass decontamination, coordinated response with police, search and rescue in chemical emergencies, preservation of evidence for criminal investigation, and first aid.”
In fact, the report underlines, there should basic fire structural (coat and trousers) or work uniform, a hard hat, chemical work gloves, safety glasses, safety shoes/boots, and a personal alert safety system (PASS) device, basic liquid splash and minimum respiratory protection for known chemical hazards includes, chemical specific protective coverall or two-piece suit, chemical gloves, safety glasses, safety boots, and an air-purifying respirator (APR) with appropriate cartridge or self-contained breathing apparatus (SCBA). nitrile gloves both outer and inner, neoprene and butyl rubber outer gloves, chemical resistant boots and chemical resistant booties, first aid kit monitoring equipment, electronic pulse and blood oxygen monitor, oral digital temperature thermometer, basic four gas monitor – includes cartridges for oxygen (O2), carbon monoxide (CO), Lower Explosive Limit (LEL), and choice of common toxic gas like hydrogen sulphide (H2S), sulphur dioxide (SO2), or chlorine (Cl2), and so on.
The report underlines that the need to form a special state emergency response team (SERT), which should be the most advanced hazardous chemical response team. “The key safety concern for this team is to be able to identify when an event exceeds their capacity and seek external (national/ international) support as needed.” SERT, it says, “would be primarily responsible for responding to high-risk, high-volume, and thus, less frequent incidents that surpass capacity of local or regional response agencies”. Local and regional response teams should be trained sufficiently to:
• Recognize events that may surpass local capacity to respond
• Rapidly collect information needed to define the situation and organize the appropriate response resources
• Support local incident command functions as the incident escalates.
Pointing out that a specialist regional response team (RRT) for chemical emergencies should be established from a core of the most capable local fire departments, the report states, “It will be a state level asset that can be officially mobilized for fail-proof and speedier communication. It will respond to the higher-toxicity, higher-volume chemical release incidents, releases of unknown chemicals, and complex or long duration events that require more resources than local teams are able to support. The regional response team will not replace but will augment local response capacity, and will be trained to identify events that necessitate the request for state-level (e.g., SERT) or national-level resources (e.g., NDRF).”
Then, there would be local emergency response teams (LERTs) for district or block levels, the report states, adding, “There should be at least one LERT in an industrial pocket area. LERT may draw from the local fire department and other public agencies that can provide on-scene response. LERT can include members of the industry, provided these ‘private’ resources are officially and bindingly committed and involved in planning, practice, and training. LERT should be well trained and well equipped to deal with small scale and frequent local emergencies (90% of chemical incidents).”
Finding yet another “critical gap” in fighting chemical disasters in Gujarat, the report states, this is regarding lack of “mutual aid between industries”. It says, the small industries are particularly hard-pressed as they do not have their own resources to respond to chemical emergencies. “The primary reason for this is that large industries in the mutual aid seek commensurate level of reciprocity from other member industries. Large industries do provide help to smaller units on request from them or district authorities, but as a benefactor and not under a formal or binding agreement. Considering this, we recommend a replication of Disaster Prevention and Management Centre (DPMC) model, as it exists in Ankaleshwar, for other industries’ pockets in Gujarat to serve smaller industries. “DPMC can also serve larger units in addition to mutual aid assistance from other large industries”, the report says.
Other recommendations of the report include having a structure for mock drills at local, district and state levels; Chemical Emergency Community Awareness and Preparedness (CECAP) and Chemical Emergency Community Awareness and Preparedness (CECAP) Outreach programmes to tailor to each community’s needs; Quick Reaction Medical Teams (QRMTs) to reach the accident site immediately along with resuscitation, protection, detection, and decontamination equipment and materials; a special Toxic Risk Reduction Programme, which should be “tailored to identify priority toxic chemicals in fixed industrial installations; and a special land use policy for buffer zone around major accident hazard (MAH) installations (handling/ storing extremely/ highly toxic chemicals).
Recommending a major policy change by having a buffer zone around MAH units, the report states, “Under the Central Pollution Control Board (CPCB) guidelines and also under industrial policy these installations are permitted to be set up only 25 kilometres away from major population hubs (five lakh) in case of environmental guidelines and (10 lakh) in case of industrial policy guidelines. It is necessary to have in place a mandatory mechanism by which the concerned authorities are able to regulate the development of population settlements in the proximity of the installations.”
The report recommends, “A no-population buffer zone of 500 meters around the perimeter of the MAH installations is to be set up for future installations. There should be a specific provision in the central legislation on land use planning requiring the concerned authorities in the (centre or state as the case may be ) to maintain a no population buffer zone of approximately a 500 meter width around the perimeter of an MAH installation. After the provision suggested above is made in the land use planning legislation, the necessary amendment shall be made in the rules and the environmental impact assessment notification 2006 to give necessary effect for implementation.”
The report adds, “The time to provide effective response to chemical emergencies is a key determination for buffer zone dimensions. For example, even with rapid and qualified response, population within a certain zone cannot be protected. On other hand, without a qualified response, a buffer zone of 500 meter may not be adequate. Therefore, the land use planning and permissions for new infrastructure development should consider existing hazards and vulnerability to them… Additionally, the environment department and the GPCB may consider chemical vulnerability assessment as a part of chapter on disaster management in the environmental impact assessment report as a key decision factor to permit new industry.”
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