The MHA on May 09, 2020 had issued a set of guidelines (“Guidelines”) for manufacturing industries (“Industries”) to adhere to upon restarting their operations post the lockdown period. The Guidelines are split into the following heads:
1.Generic Guidelines
1.1. Industries should consider the first week as a trial or test run period and shall ensure that all safety protocols are in place and that the establishments shall not try to achieve high production targets in this trial or test period. Employees who work on specific equipment are sensitized and made aware of the need to identify abnormalities like strange sounds or smell, exposed wires, vibrations, leaks, smoke, abnormal wobbling, irregular grinding or other potentially hazardous signs which indicate the need for an immediate maintenance or if required shutdown.
1.2. Industries shall ensure inspection of all equipment as per the safety protocols during the restart phase.
1.3. Industries shall especially during the Covid-19 times, ensure all lockout and tagout procedures are in place on a daily basis, however the same shall not be applicable for units running 24hrs.
1.4. In case the industry has any difficulty in managing crucial backward linkages that may be critical for their safe functioning, they should approach the local district administration for specific assistance. District Magistrates may be instructed to ensure that in such instances, the industrial unit may be facilitated to run their end to end operations, in the overall interests of industrial security.
2. For Specific Industrial Processes
2.1. Storage of Raw Materials: Industries shall
2.1.1. Ensure that HAZMAT Chemicals in the storage shall be checked for chemical stability before using for any processes.
2.1.2. Ensure ventilation and proper lighting before entering the storage areas.
2.1.3. Check the storage building for any signs of distress and damage to the roof.
2.1.4. Sense for abnormalities like strange sounds or smell, exposed wires, leaks and smoke.
2.1.5. Inspect the storage facilities for any signs of spills, wear and tear during the lockdown.
2.1.6. Check for already opened storage vessels/containers/bags/silos for possible oxidation/chemical reaction/ rusting/ rotting etc.
2.1.7. Check supply pipelines/valves/conveyor belts for any signs of damage/wear & tear.
2.2. Manufacturing Processes: Industries shall:
2.2.1. carry out a complete Safety Audit of the entire unit before starting any activity.
2.2.2. ensure cleaning of pipelines, equipment and discharge lines. Mechanical cleaning shall be followed by air /water flushing and chemical cleaning based on the type of the process equipment.
2.2.3. check supply pipelines/valves/conveyor belts for any residual material and wear and tear. All the pipelines / valves for obstructions/ pressure levels / pressure & temperature gauges shall be checked to ensure that they are clean and functional.
2.2.4. check Boilers/ furnaces/ heat exchangers for lining and signs of wear and tear.
2.2.5. perform Run-in of rotatory equipment under supervision.
2.2.6. perform a Tightness test whereby process units which handle combustibles or toxic substances (or both) shall be checked for any leakages and to ensure that they comply with the required tightness before start-up.
2.2.7. perform a Service test for all water, compressed air, and steam piping and equipment with normal operating fluids. The system shall be first, pressurized with operating fluids and then checked for leakage. For air lines, leaks can be found using soap solution. For water and condensate lines, the leakage can be observed visually. Leakage points found during the test shall be retightened. The test is deemed successful if no foam is observed from soap solution, or if no water or condensate is observed visually.
2.2.8. perform Vacuum hold test for all of its vacuum systems. Air inside the system is first evacuated to attain the required vacuum. The best way is to start at one end of the section and work through to the other end, checking flanges, valves, fittings, instruments, and other equipment. Each leak shall be tagged, making it easy for the maintenance team and personnel of the next shift to continue with the work.
2.2.9. ensure trial testing shall be carried out before commencing full-fledged production.
2.2.10. Ensure a round-the-clock emergency crews/ professional technical teams provided with MAH and cluster of MAH is ready. They should have an extended coverage of 200 km to reach transport accident spots for help.
2.3. Storage of products
2.3.1 Industries shall check the storage facilities / silos for any damage or wear and tear.
3. Guidelines for the workers
3.1. Ensure 24 -hour sanitisation of the factory premises. Factories shall maintain a sanitisation routine every two-three hours especially in the common areas that include lunch rooms and common tables which will have to be wiped clean with disinfectants after every single use.
3.2. Ensure that in the case of accommodation, sanitisation shall be performed regularly to ensure worker safety and reduce spread of contamination.
3.3. Provide COVID 19 health and prevention tips to its staff including precautions to be taken at a personal level.
3.4. Ensure Quarantine measures for supply and storage of goods such as sterilization of boxes and wrapping brought into factory premises, isolate and sanitize finished goods as appropriate and delivery of goods in shifts.
3.5. Adhere to Physical distancing measures by creating physical barriers to ensure the physical distance within the work floor and dining facilities and by providing face protection shields along with masks and PPEs.
3.6. allow employees to work in shifts as follows
3.6.1. Factories that work 24 hours at full production capacity should consider one-hour gap between shifts, except factories/plants requiring continuous operations.
3.6.2. Managerial and administrative staff should work one shift at 33 per cent capacity as per MHA guidelines; but while deciding which particular person to be included in 33% at any given point of time, overriding priority should be given to personnel dealing with safety.
3.6.3. Ensure no sharing of tools or workstations to the extent possible. Provide additional sets of tools if needed.
3.7. Prepare a scenario plan upon discovering a positive case including preparation of accommodation to isolate workers, if needed. The Industrial Establishment’s HR has to help manage the whole process for individual, all travelling employees also to undergo a mandatory 14-day quarantine.
3.8. Ensure that workers involved in dealing with hazardous material must be skilled and experienced in the field. No compromise on deployment of such workers should be permitted when an industrial unit is opened up.
In addition to the Directive and Guidelines, state governments have also introduced certain guidelines for restarting of Industrial Establishments. For example, the Tamil Nadu Government on May 03, 2020 vide G.O (Ms) No. 217 (“G.O”) had issued a list of standard operating procedures (“SoPs”) to be adhered by industrial establishments who are restarting their operations. The SoPs issued are more or less similar to the Guidelines, however certain key points are as follows:
(i) No Employee from containment zones shall be allowed to work. Additionally, updated containment zones shall be displayed at the entry gate.
(ii) Management shall ensure that there are separate entry and exit to the factory premises and strict control measures shall be enforced by the management in accordance with the G.O.
The G.O specifies the minimum required medical facilities to be present in the premises as follows:
All buildings and work surfaces shall be cleaned twice a day with 2.5% Lysol (1 Litre Lysol in 19 Litres of water). Floors shall be cleaned with 1% Hypochlorite solution. Additionally, the G.O also spells out the procedure to be followed in the event of employee being identified as covid-19 positive, which are as follows:
(a) The information shall be intimated to the office of the deputy directorate of health services of the district. The identified individual shall be admitted to a covid-19 hospital.
(b) All close contacts shall be tested and quarantined as per standard protocols. The area in which the individual was working shall be thoroughly disinfected for three days and then can be put back in use. Additionally, the entire site shall also be disinfected.
All Industries should mandatorily comply with the Directives, Guidelines, MOFHW Guidelines and SoPs of the Central Government and respective state governments, in addition to the health and safety requirements under applicable laws including the Factories Act, Shops and Establishments regulations and other applicable labour laws. Any non-compliances with the Directives will be considered as serious offences and will attract penalties under the DM Act and the Indian Penal Code.