ENVIRONMENTAL HEALTH AND SAFETY MANAGEMENT

SYSTEM (HSMS) FOR MICRO, SMALL AND MEDIUM

SCALE INDUSTRIES

A PHASE II REPORT

Submitted by

ALTON LEE M
Register No: 612619423004

in partial fulfillment for the award of the degree of

MASTER OF ENGINEERING IN
INDUSTRIAL SAFETY ENGINEERING

THE KAVERY COLLEGE OF ENGINEERING, MECHERI

DEPARTMENT OF AUTOMOBILE ENGINEERING
ANNA UNIVERSITY: CHENNAI-600025
March 2021
 ANNA UNIVERSITY, CHENNAI
BONAFIDE CERTIFICATE

Certified that this project report titled “ENVIRONMENTAL HEALTH AND

SAFETY MANAGEMENT SYSTEM (HSMS) FOR MICRO, SMALL AND MEDIUM
SCALE INDUSTRIES” is the bonafide work of ALTON LEE M (RegNo: 612619423004)
at is carried out under my supervision for the partial fulfillment of the requirements for the
award of the degree of MASTER OF ENGINEERING IN INDUSTRIAL SAFETY
ENGINEERING. Certified further that to the best of my knowledge that the work reported
herein does not form part of any other report on the basis of which a degree or award was
conferred on an earlier occasion on this or any other candidate.

SIGNATURE SIGNATURE

Mr.R.BASKARAN. M.E, M.B.A., Mr.S.BALAMURUGAN,ME,

ASSOCIATE PROFESSOR / HEAD ASSISTANT PROFESSOR IN SUPERVISOR
Department of Automobile Engineering Department of Automobile Engineering
The Kavery College of Engineering The Kavery College of Engineering
Mecheri- Salem-636453 Mecheri- Salem-636453

Submitted for the Project report Phase-II held on ______________at __________

INTERNAL EXAMINER EXTERNAL EXAMINER

ii
iii
 ABSTRACT
Safety Management System is a proactive and systematic approach to the
identification, evaluation, mitigation, prevention and control of hazards that could
occur as a result of failures in process procedures and equipment. Increased industrial
accidents, loss of lives and properties, public scrutiny, stationery requirement, aging
facilities and intense industrial process, all contribute to a growing need for safety
management programs to ensure safety and risk management. The ILO (International
Labour Organization) constitution stipulates that workers should be protected from
sickness, diseases and injuries arising from their employment. The economic
development of any nation depends primarily on the important role played by micro,
small and medium scale Enterprises (MSMEs) which help in the process of export-led
industrialization in the developing world. Many micro-, small- and medium
enterprises do not follow legislations and have no safety training programs that are
conducted to ensure the awareness of safe working procedures in industry. The code
of practice on safety management system will be very useful for industries in order to
eliminate hazards and to provide safe work environment to the employees. The
EHSMS shall be enhanced in all the above industries for protecting workers, staff and
management staff as well as protecting the society at large.

iv
 சுருக்கம்

பாதுகாப்பு மேலாண்மே அமேப்பு என்பது செயல்முமை

நமைமுமைகள் ேற்றும் உபகரணங்களில் ம ால்விகளின்

விமளவாக ஏற்பைக்கூடிய ஆபத்துக்கமள அமையாளம் காணு ல்,

ே ிப்பீடு செய் ல், ணித் ல், டுப்பு ேற்றும்

கட்டுப்படுத்துவ ற்கான ஒரு செயலில் ேற்றும் முமையான

அணுகுமுமையாகும். அ ிகரித் ச ாழில்துமை விபத்துக்கள்,

உயிர்கள் ேற்றும் சொத்துக்கள் இழப்பு, சபாது ஆய்வு,

எழுதுசபாருள் ம மவ, வய ான வெ ிகள் ேற்றும் ீவிர

ச ாழில்துமை செயல்முமை ஆகியமவ பாதுகாப்பு ேற்றும் இைர்

நிர்வாகத்ம உறு ிப்படுத் பாதுகாப்பு மேலாண்மே

ிட்ைங்களின் வளர்ந்து வரும் ம மவக்கு பங்களிக்கின்ைன.

ஐ.எல்.ஓ (ெர்வம ெ ச ாழிலாளர் அமேப்பு) அரெியலமேப்பு,

ச ாழிலாளர்கள் ங்கள் மவமலயிலிருந்து எழும் மநாய், மநாய்கள்

ேற்றும் காயங்களிலிருந்து பாதுகாக்கப்பை மவண்டும் என்று

வி ிக்கிைது. எந் சவாரு ம ெத் ின் சபாருளா ார வளர்ச்ெியும்

மு ன்மேயாக வளரும் நாடுகளில் ஏற்றுே ி மலமேயிலான

ச ாழில்ேயோக்கல் செயல்முமைக்கு உ வும் மேக்மரா, ெிறு

ேற்றும் நடுத் ர நிறுவனங்கள் (எம்.எஸ்.எம்.இ) வகிக்கும் முக்கிய

பங்மகப் சபாறுத் து. பல மேக்மரா, ெிறு ேற்றும்

நடுத் ரநிறுவனங்கள் ெட்ைங்கமளப் பின்பற்றுவ ில்மல ேற்றும்

ச ாழிலில் பாதுகாப்பான மவமல நமைமுமைகள் குைித்

விழிப்புணர்மவ உறு ி செய்வ ற்காக நைத் ப்படும் பாதுகாப்பு

பயிற்ெி ிட்ைங்கள் எதுவும் இல்மல. பாதுகாப்பு முகாமேத்துவ

முமைமேயின் நமைமுமைக் குைியீடு ச ாழில்களுக்கு

ஆபத்துக்கமள அகற்றுவ ற்கும் ஊழியர்களுக்கு பாதுகாப்பான

v
பணிச்சூழமல வழங்குவ ற்கும் ேிகவும் பயனுள்ள ாக இருக்கும்.

ச ாழிலாளர்கள், ஊழியர்கள் ேற்றும் நிர்வாக ஊழியர்கமளப்

பாதுகாப்ப ற்கும் ெமூகத்ம சபருேளவில் பாதுகாப்ப ற்கும்

மேற்கண்ை அமனத்து ச ாழில்களிலும் ஈ.எச்.எஸ்.எம்.எஸ்

மேம்படுத் ப்படும்.

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 ACKNOWLEDGEMENT

At this pleasing movement of having successfully completed our project work report,
we wish to convey our sincere thanks and gratitude to the management of our college and
Hon. Chairman & Advisor Prof.Dr.A.K.NATESAN. M.com., MBA., M.Phil., Ph.D., and
Chairman Thiru.A.ANBALAGAN., M.A., who provided all the facilities to us.

I express our thanks to Secretary Prof.S.K.ELANGOVAN., M.Sc., B.Ed., and Co-

ordinator Mrs.S.V.REVATHY ELANGOVAN for their inspiring support.

I would like to express our sincere thanks to our Principal Prof.Dr.

K.P.KARUPPANNAN., M.E., Ph.D., for forwarding us to do our internship and offering
adequate duration in completing our in project work.

I also grateful to the Head of Department Mr.R.BASKARAN., M.E., M.B.A., for his
constructive suggestions & encouragement during our in project work with deep sense of
gratitude.

I extend our earnest sincere thanks to Guide Mr. S.BALAMURUGAN,M.E., Asst.

Professor in Automobile Engineering for his valuable guidance and encouragement to
complete this in project work.
I also express our indebt thanks to our teaching staff and other staff members of
Automobile Engineering Department for rendering their valuable support.

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 TABLE OF CONTENTS
CHAPTER TITLE PAGE NO
NO
ABSTRACT (ENGLISH &TAMIL)
ACKNOWLEDGEMENT
I INTRODUCTION 1
1.1 Introduction 1

1.2 Aim Of The Study 4

II LITERATURE REVIEW 5
2.1 Studies On Accidents, Hazards And Risks In Industries 5
III ENVIRONMENTAL HEALTH AND SAFETY 6
MANAGEMENT SYSTEM
3.1 Brief Description Of EHSMS 6
3.1.1 Occupational Safety & Health Policy 6

3.1.2 Safety Education And Training 13

3.1.3 Need Of Safety Education And Training 14
3.2 Major Elements Of Environmental Health And Safety 16
Management System (EHSMS)
3.3 First Aid & Occupational Health Centers 17
(OHC)
3.4 Personal Protective Equipment (PPE) 17
3.5 Environmental Health, Hazard Identification And 18
Control
3.5.1 Environmental Impact Assessment (EIA) 18
3.5.2 Legal Provisions 19
3.5.3 Purpose Of Hazard Identification And Control 19
IV ELEMENTS OF SAFETY MANAGEMENT SYSTEM 23
4.1 Elements Of Safety Management 23
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 4.2 Provisions Relating To Health 24
4.2.1 Ventilation And Temperature 24
4.2.2 Dust And Fumes 25
4.3 Provisions Relating To Safety 25
4.4 Plan Safety Inspection 27
4.5 Risk Assessment Including Hazard Identification 27
4.6 Safety Department 29
4.7 Safety Committee 29

V HEALTH AND SAFETY SYTEM FOR SMALL, 34

MICRO AND MEDIUM SCALE INDUSTRIES
5.1 Strength And Weakness Of Micro, Small And Medium 34
Industries
5.2 The Osh Performance 36
5.3 Three Main Strategies For Osh Management 37
5.3.1 The Risk Management Strategy 37
5.3.2 Compliance With Professional Standards 39
5.3.3 Outsourcing Osh 39

5.4 Consequences Of Osh Management 40

VI SAFETY POLICIES 42

6.1 Safety Information From India 42

6.2 The National Policy Highlights 46
6.2.1 Preamble 46
6.2.2 Goals 47
6.2.3 Objectives 48
VII CONCLUSION 49
REFERENCES 50

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 LIST OF FIGURES

FIGURE NO. DESCRIPTION PAGE NO

4.1 Organizational Structures of EHSMS Elements 23
4.2 Environmental Health and Safety Management System 24
4.3 Process flow for Plant safety Inspection 27
4.4 Hierarchy hazard controls in MSMEs 28

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 1

CHAPTER I

INTRODUCTION

1.1 INTRODUCTION

In today’s hazardous industrial organization, safety is of prime

importance (Akyuz and Cedik, 2014) as a failure of such systems may have
wide devastating on sequences for worker’s safety and the society in which such
organizations are located (Reiman, 2007). Since the beginning of the present
century, psychologists, sociologists and industrial engineers have been playing a
major role in addressing employee safety and health problems at work and in
advising on how to achieve safe and reliable operations in the industrial
organization (Azadh et al., 2012; Battaglia et al., 2015).
The terminologies relevant to environmental, health, safety management
system need to be briefed in order to understand the arising discussion on the
current subject of the thesis. The term “safety” refers to the control of
recognized hazards to achieve an acceptable level of risk. The term
“environment” refers to work place. Nowadays, the incorporation of
environmental sustainability issues into organizational-wide programs has-been
one of the most prominent success stories worldwide among the organizational
researchers. With success stories largely documented in the quality area, and
with a promise of success in the safety area, the current researcher finds it
potentially rewarding to invest into the integration of environmental
management system with the safety and health system to obtain environmental,
health safety and management system (EHSMS)currently being pursued in the
current thesis.
The term “system” is an interacting combination, at any level of
complexity of people, materials, tools, machines, software, facilities and
producers designed to work together for some common purpose, in this case,
health and safety.
 2

The term “management” refers to the act of getting people together to

accomplish desired goals objectives using available resources efficiently and
effectively, comprising of planning, organizing, staffing, leading or directing,
and controlling, in an effort to accomplish a specific setoff desirable goals.
From the foregoing, EHSMS, in an important organization’s management
system, which manages the activities, products and services of an organization
(in this case in the micro-, small-, and medium- scale enterprises) with respect
to environmental, safety and health aspects through the implementation of
policies, plans and action implementation incompliance with those laid out by
the governments‟ regulatory agencies.
Industrial safety is state of freedom from dangers/risks/hazards in an
industrial activity. It is important to understand that safety is relative.
Eliminating all risk, if even possible, would be extremely difficult and very
expensive. A safe situation is one where risks of injury or property damage are
low and manageable.
Safety is often seen as one of a group of related disciplines: Quality,
reliability, availability, maintainability and safety. (Availability is sometimes
not mentioned, on the principle that is a simple function of reliability and
maintainability). These issues tend to determine the value of any work and
deficits in any of these areas are considered to result in a cost, beyond the cost
of addressing the areas in the first place; good management is then expected to
minimize total cost.
Safety is the responsibility of all managerial personnel, supervisory staff
and workers in any organization. Top management’s commitment to welfare of
employees and formulation and implementation of safety policy is increased
productivity. Safety measures result in achieving reduced level of occupational
stress and improved quality of work life.
 3

Safety management can be defined as the accomplishment of safety

objectives by first establishing the safety objectives and then by attaining them
through process of planning, organizing, staffing, directing and controlling i.e.
motivating and coordinating all efforts to attain those objectives and also
innovating to improve them for future.
For the purposes of defining safety management, safety can be defined as
“the reduction of risk to a level that is as low as is reasonably practicable”.
There are three imperatives for adopting a safety management system for
an industry- these are ethical, legal and financial.

a. There is an implied moral obligation placed on an employer to ensure that

work activities and the place of work to be safe.
b. There are legislative requirements defined in just about every jurisdiction
on how this is to be achieved.
c. There is a substantial body of research which shows that effective safety
management (which is the reduction of risk in the workplace) can reduce
the financial exposure of an organization by reducing direct and indirect
costs associated with accident and incidents.

To address these three important elements, an effective EHSMS should

a. Define how the organization is set up to manage risk,
b. Identify workplace risk and implement suitable controls,
c. Implement effective communications across all levels of the organization,
d. Implement a process to identify and correct non-conformities; and
e. Implement a continual improvement process.
 4

“Safety management system is a formal framework for integrating safety

into day-to-day operations and includes safety goals and performance targets,
risk assessments, responsibilities and authorities, rules and procedures and
monitoring & evaluation processes”. In India there are 29 states and
675districts, depending upon the cultural, climatic condition, availability of raw
materials, labour and transportation facility, there are different varieties of
industries like production, automobile, steel, oil and gas, textile, ceramic,
distilleries, construction, etc.
On December 3rd 1984, the worst ever industrial disaster in history took
place in Bhopal. Large quantity of methyl-iso- cyanate probably of order of
20,000 kilograms was discharged into atmosphere which travelled as a cloud of
disaster, around 2,000 peoples were killed, over 1,17,000 were injured and
12,000 were hospitalized. This led to the major development of EHSMS in
India.

The company was founded by Mrs. Meera Chari in the year 1977 in a
small shed in Chennai manufacturing wire wound resistors and later on shifted
to an Industrial shed in Arumbakkam. Over the course of years it grew and
diversified its manufacturing to automobile and electronic components and sub-
assemblies with two more Industrial sheds in Chennai. It further diversified
itself to two wheeler components and sub-assemblies in the year 1994 setting up
two factories in Hosur.

RAJSRIYA GROUP OF INDUSTRIES is TS 16949 certified, automobile

assemblies manufacturing company engaged in design, manufacturing and
assembling of wide range of products used in automotive vehicles Viz., Two
wheelers, three wheelers, passenger cars, Light commercial vehicles & Heavy
commercial vehicles.

The objective of our group is to serve the Indian industries by providing them
advanced technologies and superior quality components so as to stay
competitive in domestic and international markets.
Line of Activity

Pressed, Fabricated, Machined, Powder coated, Automobile High Precision

Light Engineering & Auto Electric Assemblies.
 5

Future plans:
Rajsriya aims to emerge as the primary source of precision quality assemblies
and components to the automobile and engineering industry. Our present
expansion plans are connected with the Steering columns for four wheelers &
mud guards for two wheelers.

1.2 AIM OF THE STUDY

The medium and small-scale industries are playing a major role in our
Indian economy. They are not aware of the safety measures to be followed in
the industries. The main aim is to study the environmental and safety
management system in micro, medium and small-scale industries.
 6

CHAPTER 2

LITERATURE REVIEW

2.1 STUDIES ON ACCIDENTS, HAZARDS AND RISKS IN

INDUSTRIES

In 1920, Heinrich proposed a theory of accident causation known as

“DOMINOS THEORY” based on the examination of thousands of insurance
records of industrial accidents. He was the first comprehensive effort by anyone
to explain the industrial phenomena scientifically. Before Heinrich, people
believed that industrial accidents were a matter of fate. In his first book,
Industrial Accident Prevention, published in 1931, Heinrich conceptualized a
domino theory of accident caution which states that injuries are caused by
accidents, unsafe act and unsafe conditions cause accidents, Unsafe acts and
conditions are caused by the faults of persons, Faults of persons are caused by
the social environment and ancestry.
Heinrich attempted to show that removing any one of these four dominos
in the sequence could interpret the accident sequence. Furthermore, He stated
that the bull’s eye of the accident prevention target was the unsafe act of a
person or a mechanical or physical hazard.
Many researchers felt that Henrich‟s theory attributed too much cause to
factors internal to workers and neglected the importance of external factors. In
1973, Frank E.Bird, a researcher with the International Loss Control Institute,
revised Heinrich Domino Theory (Bird & O Shell, 1973).
Bird’s model was a simple revision, but it was an important insight,
because it introduced the thought of managerial error into the accident causation
sequence. Bird’s updated Domino theory was not widely accepted by the
industrial managers as Henrich‟s model, probably because Hen rich let them off
the hook.
 7

Blaming workers is easier and less costly than training workers, changing
how an operation is performed or making environment modifications. Bird’s
updated Domino theory state that injuries are caused by accidents. For every
accident there are immediate causes that are related to operational errors,
operational errors are not only symptoms of deeper underlying or basic causes
related to management errors, the absence of system of effective control permits
the existence of the factors referred to as basic causes.

Reveille (1980) studied the safety training methods in industries in industries

and suggested the following as the requirements of any safety and health
training:
First aid and emergency procedures should be done. Hazardous
conditions and practices should be reported. Methods of avoiding hazardous job
should be undertaken, procedures, precautions, safeguards and personal
protective equipment’s necessary to protect the workers from hazardous of job.

Dawson & Stevens (1983) studied the safety programs of eight petrochemical
facilities in Great Britain. They proposed a safety management model designed
around technical controls and motivational controls. They defined technical
controls as those employed against specific hazards. They might involve
modifying physical or technical characteristics of the working environment;
modifying specifying behavioral patterns of individuals, or restructuring the
way workers and the environment interact.
 8

The World Health Organization (1997) estimated that 10 to 30 %of workers

in developed countries up to 30 % of workers in developing countries are
exposed to physical hazards, and found that accidents in industries can be
reduced by 50 % with the adoption of safety system, changes in behavioral and
management practices. It has also estimated that250 million occupational
injuries and 3, 30,000 fatalities occur each year.

The Safety Management (1997) reported that one in four work-place deaths in
England are the result of a fall from height. National Occupational Health and
Safety Commission, Australia (1997) estimated that around 2900 work-related
fatalities occur in Australia, each year.

Tolley (1997) found that two-fifth of all major injuries is caused by falls from a
height and it is the most common cause of fatality for workers. The National
Occupational Health and Society Commission, Australia (2000)reported that
the percentage of deaths due to fall from height is 12 % of all fatal accidents and
60 % of the fall are involved with a height of five meters or less between 1982
to 1989 in Australia.

The Safety Management (2000) reported that over 25,000 workers leave work
everyyear and 5, 00,000 workers take time off work each year in England,
becauseof work-related condition.

Geller in presented through participation as a critical tool toachieve optimal

performance, yielding prevention of occupational injuriesfrom the daily
dedicated involvement of all line workers.
 9

The author explained self-efficacy, response efficacy, and outcome-expectancy

with an example that if a person has the self-confidence to meet a challenge
(self-efficacy),believes that a certain technique or strategy will produce a
desired outcome(response-efficacy), and the consequence one expects to receive
from practicing the technique is positive, then a feeling of being empowered
will follow.
Geller delved deeper into the strength of empowerment, relating to
personal control and optimism. Employees are noted to be the most likely to use
the safety tools and methods they are taught if they believe that the process will
increase their personal control. Dr. Geller also deals with the interpersonal side
of safety, nothing that interpersonal and intrapersonal aspects of what we say,
how we say it and the impact of conversation are important.

The Health and Safety Executive (2002) found that the rate of fatal and non-
fatal injury are higher in men than women workers. The national Occupational
Health and Safety Commission, Australia (2002) estimated that work-related
traumatic death was a major problem with between 500 and 600 people dying
each year in Australia.

Elangovan (2003) determined pre-level of awareness score and post-level of

awareness score on industrial safety following a well designed and implemented
safety education program. The study revealed that there were significant
differences in mean achievement scores obtained in the pretest and post-test due
to the effect of implementation of the designed safety education program. The
author also studied the head injury accident pattern and suggested an ergonomic
design of safety helmet to increase its acceptability by the workers.
 10

Chen et al. (2009) carried a survey in PCB manufactures and to be reported that
the implementation of OHSAS 18001 in the PCB industries was driven by
customers was noted that the most essential factor which influence the
successful achievement of OHSAS in implementation practices was the top
management commitment and support. On the other hand, poor collaboration
among company personnel was identified as the main failure of OHSAS. The
authors asserted that the frequency of unsafe conduct by employees, the level of
top managements‟ commitment, the completion rate of corrective and
preventive measurement as well as the frequency of subcontractor rule
violations and level of fire-fighting system are key performance metrics for the
operation accepts.

Fan et al. (2014) carried out a review of 128 articles which focused on
occupational health and safety (OHS) issues in operations management. The
central focused of the review was an understanding of the distribution of articles
by journal type, the year in which articles where published, the methodologies
utilized and the research contexts. It was concluded that four major research
domains are OHS issues existed. Further, it was reported that future research
opportunities exist for each research domain of OHS from the view point of
operations management research.

Battagha et al. (2015) reported an analysis of the maturity level of the

occupational health and safety (OHS) management system in Italian municipal
waste companies. It was shown that the three most developed aspects of the
system are the training, involvement of employees as well as operational
activates while the OHS policy and performance measurements were weakly
emphasized in the system. It was concluded that companies had well-developed
level of maturity with respect to their OHS management system.
 11

Koivupalo et al. (2015) mentioned kind health and safety management

practices as well as tools to efficiency run a global steel company. The result of
the investigation was that all the sites had a health and safety management
system hinged on the requirements of OHSAS 18001requirements. It was
reported that although the local health and safety management practices and
tools had variations of significant anoints similar backgrounds were evident
from the study results. In conclusion it was ascertained that a continuously
changing organization could be managed in terms of health and safety.

Nair et al. (2015) discussed how practitioners deal with safety evidence
management for computer-based systems. Ramli et al. (2011)evolved an in
intelligent data analysis in which possibility regression was used. This was
hinged on a convex hull approach that was used as pillar of support for factors
that influence occupational health and safety management system (OHSAS).
 12

CHAPTER 3

ENVIRONMENTAL HEALTH AND SAFETY MANAGEMENT

SYSTEM

3.1 BRIEF DESCRIPTION OF EHSMS

3.1.1 OCCUPATIONAL SAFETY & HEALTH POLICY

The organization’s top management shall define, document, endorse and
review its OH&S policy which is appropriate to the nature, scale and the
hazards and risk of its activities. The top management shall ensure that the
policy includes a commitment to:
a. Recognizing OH&S as an integral part of its business performance.
Achieving continual improvement in its OH&S performance, with
commitment to compliance of relevant legal requirement and to other
requirements to which the organization subscribes, as the minimum to
ensure safety at work.
b. Setting, reviewing and publishing of OH&S objectives and targets even if
only by internal notification.
c. Place management of OH&S as a prime responsibility of the
organization.
d. Ensure its communication, understanding and maintenance at all levels in
the organization.
e. Ensure that employees at all levels receive appropriate training and are
competent to carry out their duties and responsibilities ,and To provide
adequate and appropriate resources to implement the policy,
communicate the policy to all its employees and to make it available to
public.
 13

The organization should have a health and safety policy. It should also
cover corporate safety policy. The safety officer should sign the health and
safety policy and should prepare as per guidelines of the statutory provisions.
The safety policy should be updated once in six months and should be made
known to all. It should be scrutinized by outside expert agency and it should be
mentioned in the annual report.

Performance Objectives: The organization will develop and implement an

integrated, comprehensive SMS for its entire organization and will incorporate a
procedure to identify and maintain compliance with current safety-related legal,
regulatory, and statutory requirements.

General Design Expectations: Safety management will be included in the

complete scope and life cycle of the organization’s systems including:
SMS processes will be
a. Documented
b. Monitored
c. Measured
d. Analyzed.
SMS outputs will be
a. Recorded
b. Monitored
c. Measured
d. Analyzed.
It is expected that
a. The organization will promote the growth of a positive safety culture.
b. If the organization has a quality policy, top management will ensure that
the quality policy is consistent with the EHSMS
 14

c. The EHSMS will include a means to comply with policy, legal,

regulatory and statutory requirements applicable to the EHSMS
d. The organization will establish and maintain a procedure to identify
current policy, legal, regulatory and statutory requirements applicable to
the EHSMS
e. The organization will establish and maintain procedures with measurable
criteria to accomplish the objectives of the safety policy
f. The organization will establish and maintain supervisory and operational
controls to ensure procedures are followed for safety related operations
and activities
g. The organization will establish and maintain a safety management plan to
describe how it will achieve its safety objectives.

3.1.2 SAFETY EDUCATION AND TRAINING

Training to the workers is the key element of an environmental health and
safety management system. Employers must communicate with workers so that
they understand that health and safety is considered to be an important part of
the work process, and they are aware of how to do their jobs safely. Well
trained and competent workers not only perform their job safely, but also, more
productive. Training will pay-off immediately. Employers should also be aware
that some training is required by law. That if the work being carried out is
considered hazardous, the employer must ensure the workers is competent or is
under the direct supervision of a competent worker.
Every factory shall establish training programs which may include, but
not limited to the following,
a) Refresher training of experienced workers to highlight the specific changes
and issues.
b) Training of safety committee members to familiarize them with the basic
understanding and knowledge of the roles and functions of safety committee.
 15

c) Training on basic first aid.

d) Training for fire watchmen or Attendant.
e) Training for safety inspector, in particular, fees hot work certification.
f) Training for safety officers.
g) Instruction for requirements and the effective use of personal protective
equipment.
Just as safety engineering is the most effective way of preventing
accidents involving unsafe mechanical and physical conditions, safety education
is the most effective tool in preventing accidents by human causes. Through
adequate instruction, personnel gain useful knowledge and development of safe
attitudes. Training is particularly important in accident prevention control; it
gives each employee a personal safety tool by developing habits of safe practice
and operation.

3.1.3 NEED OF SAFETY EDUCATION AND TRAINING

Training is one the most important components within our company’s
safety management system. It gives employees an opportunity to learn their jobs
properly, bring new ideas into the work place, reinforce existing ideas and
practices, and it helps to put our safety and health program into action.
Everyone in that company will benefit from safety and health training through
fewer work place injuries and illness.
Safety training program will focus on health and safety concern that
determine the best way to deal with particular hazards. When a hazard is
identified, the safety department personnel first try to remove it entirely. If that
is not feasible, they will then train workers to protect themselves, if necessary,
against the remaining hazards.
 16

Employees: At a minimum, employees must know the general safety and health
rules of work site, specific site hazards and the safe work practices needed to
help control exposure, and the individual’s role in all types of emergency
situations. The company should ensure all employees understand the hazards to
which they may be exposed and how to prevent themselves and others from
exposures to these hazards.
The management should organize available resource to ensure the
employees to receive safety and health training during the following:
a. Whenever an employee is given a new job assignment/new product – during
formal classroom training and again, when the supervisor provides specific task
training. It is extremely important that supervisor emphasize safety during the
initial task assignment.
b. Whenever a new work procedure is begun, during formal classroom training
and supervisor on the job training.
c. Whenever new equipment is installed, if new hazards are introduced.

Shift Supervisor: Shift supervisor will be given special training to help them in
their leadership role. They will be taught to look for hidden hazards in the work
under their supervision, insist on the maintenance of the physical protection in
their areas and reinforce employee hazard training through performance
feedback and consistent enforcement when necessary.
The occupier should commit necessary resources to ensure supervisor
understand the following responsibilities and reasons for them:
a. Detecting and correcting hazards in their work areas before they result in
injuries or illnesses.
b. Providing physical resources psychosocial support that promotes safe work.
c. Providing performance feedback and effective recognition and discipline
techniques
d. Conducting on- the- job training.
 17

Plant Managers: All the respective departmental managers must understand

their responsibilities within the safety and health program. This may require
classroom training and other form of communication that ensure that managers
understand their safety and health responsibilities. Formal classroom training
may not be necessary. The subject can be covered periodically as a part of
regular management meetings.
Mangers should be trained in the following subject areas,
a. The elements of the safety, health and environmental safety management
system and the positive impact of the various processes within the system can
have on corporate objectives.
b. Their responsibilities to communicate the safety health and environmental
program goals, objectives to their employees, and their role that includes
making clear assignments of safety and health program responsibilities,
providing authority and resources to carry out assigned tasks, holding
subordinate managers and supervisors accountable.

3.2 MAJOR ELEMENTS OF ENVIRONMENTAL HEALTH AND

SAFETY MANAGEMENT SYSTEM (EHSMS)
The major elements are as follows
i. Occupational Health & Safety Policy
ii. Safety Education and Training
iii. Motivational and Promotional Measures for OS & H
iv. Safety Manual and Rules
v. Compliances with Statutory Requirements
vi. New Equipment Review / Inspection
vii. Accident Reporting Analysis Investigation and Implementation of
Recommendations
viii. Risk Assessment including Hazard Identification
ix. Safety Inspections
 18

x. Health and Safety Improvement Plan / Targets

xi. First aid Facilities – Occupational Health Centre
xii. Personal Protective Equipment(PPE)
xiii. Good Housekeeping
xiv. Machine and General Area Guarding
xv. Material Handling Equipment
xvi. Electrical and Personal Safeguarding
xvii. Ventilation, Illumination and Noise
xviii. Work Environment Monitoring System
xix. Prevention of Occupational Diseases Including Periodic
xx. Medical Examination

3.3 FIRST AID & OCCUPATIONAL HEALTH CENTERS

(OHC)
The industry must have adequate first aid boxes. There must be a
qualified or trained person should always be available in each shift. Providing
safety and health centre in the organization itself or should sign MOU with the
nearest hospital for emergency purpose. Pre-medical examination should be
carried out when the employee joined the industry.

3.4 PERSONAL PROTECTIVE EQUIPMENT (PPE)

Workers needing to wear personal protective equipment (PPE) and
persons9 working in high risk situations will need special training. Supervisor
and workers alike must teach the proper selection, use and maintenance of PPE.
Since PPE sometimes can be cumbersome, employees may need to be
motivated to wear it in every situation where protection is necessary. Therefore,
training will begin with the clear explanation of why the personal protective
equipment is necessary, how it is used will benefit the wearer and what its
limitations are.
 19

Reminder should be made to employees to protect them and of their

efforts, not only to eliminate and reduce the hazards, but also, to provide
suitable PPE when being asked to wear it. Individual employee will become
familiar with the PPE is being asked to wear. This is done by handling it and
putting it on. Training will consist of showing employees how to put the
experiment on, how to wear it properly, and how to test

for proper fit and how to maintain it. Proper fit is essential if the
equipment is to provide the intended protection. Safety department will conduct
periodic exercises in finding, donning and properly using emergency personnel
protective equipment and devices.

3.5 ENVIRONMENTAL HEALTH, HAZARD IDENTIFICATION AND

CONTROL
3.5.1 ENVIRONMENTAL IMPACT ASSESSMENT (EIA)
The Environmental inventory is a complete description of the
environmental. as it exists in an area where a particular proposed action, like
setting up a chemical factory, is being considered, the environmental impact
assessment is an attempt to evaluate the consequences of a proposed action on
each of the descriptions in the environmental inventory.
The essential steps in an environmental impact assessment are:
a. Prediction of the anticipated change in an environmental
descriptor.
b. Determination of the magnitude or scale of the particular change.
c. Application of an importance or significance factor to the change.
 20

3.5.2 LEGAL PROVISIONS

Safety: Various Indian statutes on safety are as follows
a. The Factories Act 1948
b. The Chemical Accidents (Emergency Planning, Preparedness and
Response) Rules, 1996
c. Manufacture, Storage and Import of Hazardous Chemical Rules,
1989
Health: Various Indian statutes on health are as follows
a. The Factories Act 1948
b. The Public Liability Insurance Act, 1991
c. The Disaster Management Act, 2005
Environment: Various Indian statutes on Environment are as follows:
a. The Environment (Protection) Act 1986
b. The Environmental (Protection) Rules, 1986
c. The Water (Prevention and Control of Pollution) Act, 1974
d. The Air (Prevention & Control of Pollution) Act, 1981
e. Environmental Impact Assessment of Development Project,
Notification
f. Hazardous Wastes (Management and Handling) Rules, 1989
g. Manufacture, Storage and Import of Hazardous Chemical Rules,
1989

3.5.3 PURPOSE OF HAZARD IDENTIFICATION AND CONTROL

A hazard identification and risk assessment processes used to identify and
evaluate both existing, potential hazards on a worksite and the methods used to
control or eliminate the hazards identified.
 21

The assessment process must be completed prior to the start of all jobs to
identify existing or potential hazards to workers and eliminate or control these
hazards through the use of engineering or administrative controls, proper
training or the use of personal protective equipment. All company staff and
contractors are required to take a proactive approach to managing and reporting
hazards. When they observe a hazard, they are required to take steps to manage
that hazard directly (provided they are adequately knowledgeable / trained to
safely do so) – eliminate the hazarder get assistance from appropriate persons to
do so whenever reasonably possible. Where hazards cannot be eliminated
immediately, take necessary steps to warn others of the hazard. Report
hazardous or potentially hazardous conditions and acts to a supervisor or your
site contact if a contractor.

STEP 1: IDENTIFY THE HAZARDS

The first main important work of a supervisor is to start the hazard
identification process before the job begins by identifying hazards that are
known to exist on site and documenting them. By identifying hazards early, the
supervisor may be able to implement controls before any workers arrive on site.
To ensure the process is thorough the supervisor should:
Look at all aspects of the work; include non-routine activities such as
maintenance, repair, or cleaning, look at accident / incident / near miss records,
include people who work "off site" either at home, on other job sites, drivers,
tele-workers, with clients, etc., look at the way the work is organized or "done"
(include experience and age of people doing the work, systems being used, etc),
look at foreseeable unusual conditions (for example: possible impact on hazard
control procedures that may be unavailable in an emergency situation, power
outage, etc.),
 22

Examine risks to visitors or the public, Include an assessment of groups

that may have a different level of risk such as young or inexperienced workers,
persons with disabilities, or new or expectant mothers.

STEP 2: ASSESS THE RISK

Ranking or prioritizing hazards is one way to help determine which
hazard is the most serious and thus which hazard to control first. Priority is
usually established by taking into an account of the employee exposure and the
potential for accident, injury or illness.
By assigning a priority to the hazards, the following factors play an
important role:
a. Percentage of workforce exposed,
b. Frequency of exposure,
c. Degree of harm likely to result from the exposure, probability of
occurrence.

STEP 3: DEVELOP SAFE PRACTICES

Once the risk has been assessed, the appropriate controls need to be put
into place.
The main ways to control a hazard include:
a. Elimination (including substitution): Remove the hazard from the
workplace.
b. Engineering Controls: includes designs or modifications to plants,
equipment, ventilation systems, and processes that reduce the source of
exposure.
c. Administrative Controls: Controls that alter the way the work is done,
including timing of work, policies and other rules, and work practices such as
standards and operating procedures(including training, housekeeping, and
equipment maintenance, and personal hygiene practices).
 23

d. Personal Protective Equipment: Equipment worn by individuals to

reduce exposure such as contact with chemicals or exposure to noise.

STEP 4: COMMUNICATE THE CONTROLS AND TRAIN THE

WORKERS
Once the control has been put into place, the workers need to be trained
in how to use it. This applies whether it is an engineering control such as a
guard or interlock or an administrative control such as a safe work procedure for
cold weather or particular PPE when handling a chemical. Training records
and/or documented sign-offs are required to show that the workers have been
made aware of the hazards and the controls.

STEP 5: SAFETY REVIEW PERIODICITY

Repeat the hazard assessment process every 2 years or when site
conditions change, when new tasks are added or when new workers join the
crew, in order to prevent the development of unsafe working condition.

New equipment review: The system is would be affected for any change in
existing plants, equipment or processes. It should be approved by the
appropriate competent authority of Safety Communication.
Safety Communication is often the single most important area to be
improved in a company. One conclusion from most organizational assessments
is that, there is not enough and relevant information available, and that the two-
way information flow is inadequately arranged. The messages that top
management wishes to communicate are not always the ones employees receive
or see as relevant. On the other hand, it is common that employees feel that their
own ideas and needs are not sufficiently heard of the higher levels.
 24

CHAPTER 4

ELEMENTS OF SAFETY MANAGEMENT SYSTEM

Safety Management System: Safety Management System is an Organized

and structured means of achieving and maintaining high standards of safety
performance.

Figure 4.1 Organizational Structures of EHSMS Elements

4.1 ELEMENTS OF SAFETY MANAGEMENT

Administrative and Management Element
a. Management Leadership and Commitment
b. Organizational Communications and System Documentation
c. Assessments, Audits and Evaluations
Operational and Technical Elements
a. Hazard Recognition, Evaluation and Control
b. Workplace Design and Engineering
c. Operational Safety and Health Programs
 25

Cultural and Behavioral Elements

a. Employee involvement
b. Motivation, Behavior and Attitudes
c. Training and orientation

Figure 4.2 Environmental Health and Safety Management System

4.2 PROVISIONS RELATING TO HEALTH

4.2.1 Ventilation and temperature
Effective and suitable provisions are to be made in every factory for
adequate ventilation for circulation of fresh and maintenance of temperature that
will provide the workers reasonable condition of comfort and prevention of
injury to health.
 26

The occupier may take necessary steps to improve the condition by using
suitable material for marking walls and rooms so that the temperature inside
shall be as low as practicable. Where the manufacturing process produces
excessive temperature, measures have to be taken to protect health of the
workers by suitable engineering control. The standards of ventilation prescribed
the state government have to be maintained in work places and necessary
records as prescribed for the purpose also have to be maintained and produced
for inspection.

4.2.2 Dust and Fumes

If the manufacturing process carried on in a factory gives rise to dust or
other impurity to such an extent as are injurious to health of workers, effective
measures are to taken to prevent accumulation of such or fume in any work
room and also inhalation of the same by the workers. If any engineering control
is required to be provided that shall be applied at the sources of production of
such dust or frame. This section prohibits the operations of any stationary
internal combustion engine in closed room unless arrangements have been made
to conduct the exhaust in the open air.

4.3 PROVISIONS RELATING TO SAFETY

Precautions Regarding the Use of Portable Electric Light
Portable electric appliances operating at voltages more than 24 volts are
not permitted for use inside confined spaces until adequate safety measures are
taken.
In Case, inflammable gas, fume etc. are likely to be present in this
section requires the use of electrical appliances of flame proof construction
Precautions in case of fire: Precautions are to be taken in every factory to
prevent out-break of fire and its spread.
 27

This section also lays down certain requirements regarding safe method
of escape and facilities for extinguishing of fire. It also empowers the chief
inspector of factories to order addition measures to be taken in a particular
factory to prevent outbreak of fire and also the protection of workers against
such fires.
Power to Require Specification of Defective Parts or Test of Stability: if any
plant or machinery in a factory is in a condition dangerous to human life or
safety, the Inspector is empowered under this section to call for drawing and
specification to determine the safety of such plant or machinery. He is also
empowered to ask the management to carry out such tests which he may specify
and to inform him of the results.
Safety of Buildings and Machinery: If any building, machinery or plant in a
factory is proving dangerous to human life, the inspector, under this section can
ask management to take remedial measures within a specified date. If any
imminent danger is involved, he may even prohibit the use of such machinery,
plant or building until they have been properly repaired.
Maintenance of Buildings: Under this section, an inspector is empowered to
ask the occupier of a factory or the manager to carry out, within a specified
date, urgent repairs to any building or part of building in the interest of the
safety and health of the workers.
Safety Officers: Every factory employing 1000 workers or more or carrying
out process involving risk of bodily injury shall appoint safety officer under this
section, if required by the state government through a notification.
This section also lays down, power of the state government to prescribe
duties and qualifications for safety officers.
 28

4.4 PLAN SAFETY INSPECTION

Plant safety inspection is carried out by the safety officers to identify
unsafe acts and conditions and to suggest corrective actions.

Figure 4.3 Process flow for Plant safety Inspection

4.5 RISK ASSESSMENT INCLUDING HAZARD IDENTIFICATION

To establish a system to apply and maintain recognized methods to
identify, evaluate, control and mitigate hazards and potential hazards.
These methods shall include elimination or reduction of the risk and
consequence of the hazards to as low as is reasonably practicable.
 29

Figure 4.4 Hierarchy hazard controls in MSMEs

A hazard analysis shall be applied to the following

a. Factory and Process design
b. Operations
c. Equipment employed
d. Materials and chemical used
e. The factory shall establish and maintain a program for the identification
and assessment of the hazards.
The program shall aim at:
a. Identification and recording of known hazards,
b. Identification and recording of new and potential hazards,
c. Assessment of the hazards using qualitative or quantitative appropriate
techniques,
d. Analysis of the effects or potential effects
 30

e. Development and implementation of the means to eliminate or to control

and manage the hazard in a manner that is as low as reasonably
practicable.
f. Development and implementation of emergency or contingency plan.
The factory shall ensure that persons responsible for the hazard analysis
and for determining the means of eliminating, reducing and controlling the risks
are;
a. Technically competent
b. Given the management supports to effectively perform their\duties
c. Given the authority to implement the approved procedures

4.6 SAFETY DEPARTMENT

Each and every organization or industry should have safety department
and the head of the safety department must possess the required qualifications
and experience regarding the safety issues of company where he is working.
The safety officer must report to the chief executive officer regularly regarding
the safety measures available with the industry and the requirements needed.
The safety personal updating the recent trends and techniques of the total safety
management system.

4.7 SAFETY COMMITTEE

Every industry has safety committee at the management level
,supervisory level and workers level. In management level safety committee,
there will be one person from top the management and rest of the people should
be from all the departments. At the supervisory level committee, there will be a
one person from each and every department, including the safety officer. At
worker level committee, there will be one person or two senior operators from
each department including the safety officer.
 31

The meeting of safety committee will be organized at the regular

intervals, the problems faced by the supervisors, workers and management staff
regarding safety should be discussed at the meeting and corrective measures to
be taken.
The minutes of the meeting should be forwarded to the chief executive
and occupier. The Rewards and awards should be given to the safety committee
members frequently. To avoid accidents; a full-fledged safety department
maybe created with a senior man as its chief executive and a no. of persons
under him at different levels. It has been observed that whenever safety
committees are available, lower rates of accidents have been reported. It
develops a safety consciousness to the gross-roots.
The factory shall establish a safety committee for the purpose of
improving. Promoting and reviewing of all matters relating to the safety and
health of employees. The safety committee also acts as a channel for
communicating and imparting knowledge and best practices on safety and
health to all personnel. The safety committee shall have a clearly defined
character with prescribed functions and responsibilities. The composition,
functions and duties of the safety committee shall be in accordance with the
Factories Act and the Factories (Safety Committees) Regulations. The Safety
Committee shall be effectively led by the senior management of the factory.
The Safety Committee shall be given the necessary support and resources
so as to achieve the Committee’s safety and health objectives.
Tool Box Meetings: Tool Box Meetings involving supervisors and workers
should be held regularly such as before the commencement of work to provide
opportunity for operators and workers to discuss safety and health issues in
relation to their work. During the meeting, the supervisor should review the
work to be carried out to highlight the potential hazards and necessary safety
precautions to be taken, such as issues pertaining to the use of Personal
Protective Equipment.
 32

Safety Improvement Teams: The factory should set-up group based Safety
Improvement Terms to work through safety and health related
projects for the purposes of improving the physical work environment and to
reduce unsafe human behaviors in the factory.
The management shall ensure that the personnel participating in the
above meetings are
a. Competent for their tasks
b. In full understanding of their roles and functions
c. Committed to the improvement of safety and health in the workplace. It is
important that all workers are inculcated with positive attitudes towards
safety and health promotional activities.
d. Given the necessary support so that they can effectively perform their
duties.
e. The factory shall establish a mechanism whereby the decisions and
actions proposed by the various groups are effectively communicated to
persons responsible for their implementation. The mechanism shall also
ensure that all
f. Outstanding actions are effectively followed through and implemented.

Importance: Health and safety committees should be established for the

following purposes:
1. To acquiring knowledge in safety issues and maintain the interest of
employees in health and safety issues
2. To convince managers, supervisors and employees through awareness
and training activates that they are primarily responsible for the
prevention of workplace accidents.
3. To help make health and safety management system has an integral part
of the organizations operating procedures, culture and programs.
 33

4. To provide an opportunity for the free discussion of health and safety

problems and possible solutions.
5. To inform and educate employees and supervisors about health and
safety issues, new standards, research findings, etc.
6. To help reduce the risk of work-place injuries, illness and health issues.
7. To help insure compliance with federal and state health and safety
standards.

Roles and Responsibilities: In order to achieve these objectives, the successful

health and safety committee should:
1. To develop a written missions statement and charter.
2. Mention the duties and responsibilities of officer and general members
clearly.
3. Identify and prioritize goals and establish action plans to achieve each
goal.
4. Receive the representation from different levels and areas of the
organization and the records to be maintained.
5. Arrange for meetings at least quarterly / monthly.
6. Record and disseminate minutes of each meeting, documenting
attendance, problems and issues and corrective action proposed and
action taken to address each internal newsletter issue.
7. Make attendance mandatory with the penalty of removal for repeated
absence.
8. Include new innovative ideas, methods in order to increase and maintain
safety awareness.
9. Organize special sub-committees to address specific issues and new
project reviews.
10.Communicate and should meet with all the employees purpose, activities
and accomplishments of the committee regularly and periodically.
 34

4.8 SAFETY BUDGET

Organization should allocate some amount of money for the safety
purpose for their annual budget. These budgets should be utilized periodically
and effectively for training, training aids, safety posture, new product review,
safety health and environment, occupational health issues and safety audit.
This safety budget should be reflected in annual report of the company.

4.9 SAFETY CULTURE

The safety culture of an organization is the product of individual and
group values, attitudes, perceptions, competencies and pattern of behavior that
determine the commitment and the style and proficiency of an organizations
health and safety management. Furthermore, organization with a positive safety
attitude is characterized by communications founded on mutual trust by shared
perception of the importance of safety and by confidence in the preventive
measures.
 35

CHAPTER 5
HEALTH AND SAFETY SYTEM FOR SMALL, MICRO AND MEDIUM
SCALE INDUSTRIES

Small and medium-sized enterprises (SMEs) provide employment to a

majority of the workforce. They are also regarded as the ‘motor’ of the
economy and as indispensable for innovation and the development of the
knowledge economy. Small and micro organizations have, however, other
characteristics (i.e. strengths and weaknesses) than larger organizations (which
are often regarded implicitly as the standard, both in policy making and in
research). Unfortunately, the models developed for larger corporations have
proved to be ineffective for most SMEs
In fact there are two very different ways in which small enterprises are
perceived: as strong, innovative and a major economic force, or as organizations
that struggle for survival, focus on short-term issues only, and lack resources
and knowledge (especially for tackling long-term issues like occupational safety
and health). Both views are based on evidence. This ambiguity towards SMEs
may stem from the fact that SMEs form a very diverse group. Thinking about
SMEs is all too often based on generalizations. Due to the enormous diversity in
small companies, there are a variety of challenges, requiring a range of potential
solutions for OSH management.

5.1 STRENGTH AND WEAKNESS OF MICRO, SMALL AND MEDIUM

INDUSTRIES

The owner-manager of a small company is usually the person who has to

take personal responsibility of most management matters, e.g. sales,
procurement, accounting, production planning, and personnel – all issues, which
are crucial for the survival of the firm. In this context, OSH might seem only a
peripheral matter.
 36

The personal values and priorities of the owner/founder of the enterprise

(which may differ greatly among small companies) are key determinants of the
culture, values and social relations in the enterprise, including those relevant for
OSH.

The tasks that contribute to the short-term survival of the business are
most likely to be given high priority. Small firms are vulnerable financially.
This makes OSH investments less attractive, because the short-term financial
benefits of prevention are limited.

Small enterprises give priority to solving acute problems and urgent

tasks. As a consequence, safety is usually not a priority, and the same is true for
the prevention of chronic health problems. It is known that many owners
consider health and safety to be part of the professionalism or craftsmanship of
the workers, and therefore primarily the responsibility of the employees
themselves. The time available for learning about health and safety is very
limited. As a consequence OSH expertise in small enterprises is often very
limited or even absent.

Strength of small enterprises is that communication lines are short and

personal, and that simple solutions can be implemented at short notice. The
owner-managers and the employees often have personal contact on a daily
basis. Indeed, the owner-managers offer the employees a close social
relationship and often a great range of autonomy.

As a consequence of the specific strengths and weaknesses of small

enterprises, OSH management in small companies has specific characteristics. It
differs from that of larger enterprises (which is often - implicitly- regarded as
the ‘norm’ for good OSH Management.
 37

5.2 THE OSH PERFORMANCE

Small enterprises have an increased risk of accidents compared to large

enterprises. In firms with fewer than 50 workers the fatal accident rate is around
double that of larger companies. It is most likely that there is also a higher risk
of less severe accidents, but the statistical data are not very reliable for this
category, probably due to underreporting. Even though the prevalence of
occupational accidents is statistically significantly higher in small companies
than in others, accidents are a rare experience for individual small firms.

The occupational health performances of small firms are diverse. The

owner-entrepreneur usually considers long-term exposure as a hypothetical risk
and beyond control. There are clear indications of higher exposures to
chemicals. Long-term exposure is only considered relevant if individual
employees experience health-related problems such as low-back pain or
headaches from toxins. Then the owner-managers express willingness to adjust
the workplace in order to avoid aggravation. Noise, is widely accepted as a
relevant issue in small firms; probably because chronic exposure is a constant
nuisance to all. Even so, noise at the workplace is usually reduced to a question
of wearing hearing protection.

Perhaps surprisingly, the exposure to psychosocial risks seems lower in

small enterprises. This might be the result of the relatively large autonomy for
the workers, and greater variation in tasks due to a less strict division of labour.

This also implies shorter exposure times to other health risk (compared to
those working in larger organizations), which reduces such risks. Owner-
managers see the psychosocial working environment mainly as a matter of
having a friendly atmosphere, which they consider important for daily
operations. They see it as important that people speak respectful and friendly to
each other, and cooperate well. Generally, small enterprises do not
systematically identify risks and take preventive action accordingly.
 38

This is especially relevant for long-term risks that are not tangible, like
chemical exposure, or safety risks. For several reasons, OSH management
systems are not very attractive for small firms.

Social control is tighter than in larger firms. When and individual

employee in a small enterprise is not able to work, this significantly affects the
work planning and production. The financial consequences for the firms may
often change at short notice. Colleagues working in a team should support each
other, both for the complementary competencies that may occur and for social
reasons. As a result, workers in small firms are likely to experience greater
social pressure to keep working when they are not fully fit. An external trend is
that large enterprises centralize power but decentralize work (outsourcing,
subcontracting and off-shoring). In many cases, this leads to poor working
conditions in small enterprises. It seems a trend that large enterprises become
‘leaner and meaner’, which by implication leads to more SMEs. It often also
implies that the most dangerous activities are outsourced, thereby pushing the
risk down to the small enterprises. As a response, it is now increasingly
regarded as a responsibility of larger enterprises to prevent the ‘externalization
of risks’ as part of their corporate social responsibility strategy.

5.3 THREE MAIN STRATERGIES FOR OSH MANAGEMENT

There are three main strategies for OSH management in small and micro
firms: to develop risk management, to comply with professional standards, and
to outsource OSH.

5.3.1 The risk management strategy

Risk management, when performed well, engages the employer and the
employees in reducing risks and improving OSH. The approach is generic and
can be used in all companies regardless of sector or type of risks.
 39

Risk management also implies the opportunity to priorities between

different hazardous operations, which can help to make OSH management cost-
effective. It is therefore quite obvious why the EU legislation takes risk
management as its starting point for legislation.

However in small firms risk management can only be successfully

implemented (as a semi-continuous activity) under certain conditions: e.g.
relevant easy to use information, practical tools and competency should be
available. Examples of good practices are needed as solutions for the OSH
problems identified. Economic incentives play a role in the implementation.
External support might be needed to capture the knowledge that is needed in the
enterprise, but that is not readily available.

More than 80% of small establishments (between 10-20 employees) in

the EU-27 reported that they carry out checks as part of a formal or informal;
i.e. risk assessment. This percentage seems rather high, and might be biased as a
socially desirable response. In the 12% of establishments not carrying out
regular health and safety checks, the most frequently cited reason (71%) is that
they are ‘not necessary because we do not have major problems’.

As this reason is most common among the smallest establishments, it

raises the question of whether smaller enterprises are less likely to have major
problems or whether they are less aware of OSH issues. The ESENER project
did not address micro firms, but it can be expected from research in several
countries that in micro enterprises the risk management approach is less often
followed.

Indeed, from the perspective of micro and small enterprises, the risk
management strategy has several disadvantages. Risk management is relatively
time consuming. In small companies time consuming activities are deprioritized
unless they are perceived as important for the survival of the company.
 40

The knowledge needed for good quality risk management is often not
available in small companies. Poor risk management may result in a false sense
of safety.

5.3.2 Compliance with professional standards

The second strategy is to comply with professional standards. Good OSH

is therefore considered to be part of the craftsmanship or professionalism of the
enterprise and its workers. If so, OSH can be managed as a natural part of daily
work and professionalism. This implies an orientation on identification and
following ’the state of the art’, or good practices.

Again, a problem can be that there is not sufficient time available to identify
professional standards or good practices. However, this is more closely related
to the core activities of the enterprise than risk management.

In debates on the reduction of the administrative burden of legislation,

representatives of the small companies often say: ‘Just tell us what to do, and
we will do it.’ This means that they would like to get detailed demands for
specific control measures. They do not mean that they want to be told to
identify and assess the risks, which by themselves do not provide a solution.

On the other hand, even if good practice is easily available, small

companies seldom use this advice, but rather turn to personal contacts for
advice instead.

5.3.3 Outsourcing OSH

As small enterprises are busy with their core business and have little time
for OSH, it is understandable that the third strategy is outsourcing OSH. Across
the EU, 36% of establishments – particularly the smaller ones – outsource risk
assessments to external providers (often to occupational health and safety
services.
 41

Occupational safety and health risk assessment

methodologies and occupational health and safety services. However, between
individual countries the figure varies widely, e.g. in Denmark, outsourcing is
the exception even among the smallest establishments surveyed. It is important
to note, however, that the basic legal responsibilities of the employer and the
individual workers can never be outsourced completely.

5.4 CONSEQUENCES OF OSH MANAGEMENT

It is important to realize that the motivators to improve OSH are different

for small companies compared to larger ones. Especially business related
factors are important. SMEs are motivated more by the requirements or through
encouragement from their key customers than by the influence of legislation.
This is probably because owner-managers perceive that the working
environment is an issue in the daily operation of their business. The importance
of good leadership in occupational safety and health Factors that motivate
SMEs to invest in OSH are:

a. Avoiding the costs of ill-health,

b. Avoiding the expense of accidents
c. Seeing that health and safety is an integral part of being a ‘good business’
d. Maintaining their reputation
e. Achieving higher productivity - especially by reducing absence
f. Keeping within the law, hence avoiding punitive action from government
bodies
g. Containing insurance costs
h. Meeting client demands
i. Being a ‘good’ employer.
 42

It is therefore vital to communicate that good health and safety is

beneficial (both financially and in terms of well-being). Nevertheless, health
and safety investments often face two major obstacles: the cost–benefit ratio is
often unclear and difficult to express in real money; and it is often not clear
whether interventions will directly improve the performance of the core tasks of
the organization the economic dimension of occupational safety and health
management. Consequently, management ignores frequently suggestions for
interventions, even when the investment would realize a suitable return.

Other issues than economic drivers are also important, especially the
occurrence of a serious accident, or when the manager has experience as a co-
workers in the same business. Finally, most of the owners-managers seem
motivated to pursue compliance with generally accepted OSH standards for
their sector (the good practices in their sector are more tangible than the more
abstract legislative requirements, and they also contribute to their
professionalism).

When searching for successful OSH strategies, it is important to consider

not only the quality of the strategy in itself, but also how likely it is to succeed
in implementation in small organizations. A good strategy that is not
implemented is not useful.

The ESENER report showed that ‘having a formal OSH policy ‘ appears
to be less frequent among smaller enterprise. Enterprises that do not have an
OSH policy cite that they lack the expertise. Or that it is not necessary (due to
absence of relevant OSH risks). The latter may reflect either the real absence of
risks or lower levels of risk awareness in SMEs.
 43

CHAPTER 6

SAFETY POLICIES

6.1 SAFETY INRORMATION FROM INDIA

The Government of India, Ministry of Labour & Employment has
formulated and declared a National Policy on “Occupational Safety, Health and
Environment at Workplace” on 20th February, 2009 with the strong
commitment to enhance the Occupational Safety and Health measures at the
workplace. The Policy provides the stake holders a platform to plan and deliver
the message of OSH at appropriate levels. Efforts are also being taken to
upgrade the OSH standards of industrial workers by organizing state level
programmers through the Inspectorates of Factories to effectively and
efficiently implement the National Policy. The DGFASLI is committed to
provide its support for effective implementation of the Policy at the National
level through Central Labour Institute, Mumbai and Regional Labour Institutes
located at Chennai, Kolkata, Kanpur and Faridabad.
a. The Constitution of India provide detailed provisions for the rights of the
citizens and also lays down the Directive Principles of State Policy which
set an aim to which the activities of the state are to be guided.
b. These Directive Principles provide :
• For securing the health and strength of employees, men and
• women;
• That the tender age of children are not abused
• That citizens are not forced by economic necessity to enter
• avocations unsuited to their age or strength
• Just and humane conditions of work and maternity relief are
 44

• Provided Government shall take steps, by suitable legislation or in

any other way, to secure the participation of employee in the
management of undertakings, establishments or other organizations
engaged in any industry.
a) On the basis of these Directive Principles as well as international
instruments, Government is committed to regulate all economic activities for
management of safety and health risks at workplaces and to provide
measures so as to ensure safe and healthy working conditions for every
working man and woman in the nation. Government recognizes that safety
and health of workers has a positive impact on productivity and economic
and social development. Prevention is an integral part of economic activities
as high safety and health standard at work is as important as good business
performance for new as well as existing industries.
b) The formulation of policy, priorities and strategies in occupational safety,
health and environment at work places, is undertaken by national authorities
in consultation with social partners for fulfilling such objectives. A critical
role is played by the Government and the social partners, professional safety
and health organizations in ensuring prevention and in also providing
treatment, support and rehabilitation services.
c) Government of India firmly believes that without safe, clean environment as
well as healthy working conditions, social justice and economic growth
cannot be achieved and that safe and healthy working environment is
recognized as a fundamental human right. Education, training, consultation
and exchange of information and good practices are essential for prevention
and promotion of such measures.
 45

d) The changing job patterns and working relationships, the rise in self-
employment, greater subcontracting, outsourcing of work, homework and
the increasing number of employees working away from their establishment,
pose problems to management of occupational safety and health risks at
workplaces. New safety hazards and health risks will be appearing along
with the transfer and adoption of new technologies. In addition, many of the
well-known conventional hazards will continue to be present at the
workplace till the risks arising from exposure to these hazards are brought
under adequate control. While advancements in technology have minimized
or eliminated some hazards at workplace, new risks can emerge in their
place which needs to be addressed. Particular attention needs to be paid to
the hazardous operations and of employees in risk prone conditions such as
migrant employees and various vulnerable groups of employees arising out
of greater mobility in the workforce with more people working for a number
of employers, either consecutively or simultaneously.
e) The increasing use of chemicals, exposure to physical, chemical and
biological agents with hazard potential unknown to people; the
indiscriminate use of agro-chemicals including pesticides, agricultural
machineries and equipment; industries with major accident risks; effects of
computer controlled technologies and alarming influence of stress at work in
many modern jobs pose serious safety, health and environmental risks.
 46

f) The fundamental purpose of this National Policy on Safety, Health and

Environment at workplace, is not only to eliminate the incidence of work
related injuries, diseases, fatalities, disaster and loss of national assets and
ensuring achievement of a high level of occupational safety, health and
environment performance through proactive approaches but also to enhance
the well-being of the employee and society, at large. The necessary changes
in this area will be based on a coordinated national effort focused on clear
national goals and objectives. Every Ministry or Department may work out
their detailed policy relevant to their working environment as per the
guidelines on the National Policy.
g) The Government firmly believes that building and maintaining national
preventive safety and health culture is the need of the hour. With a view to
develop such a culture and to improve the safety, health and environment at
work place, it is essential to meet the following requirements
• Providing a statutory framework on Occupational Safety and Health in
respect of all sectors of industrial activities including the construction
sector, designing suitable control systems of compliance, enforcement and
incentives for better compliance.
• Providing administrative and technical support services.
• Providing a system of incentives to employers and employees to achieve
higher health and safety standards.
• Providing for a system of non-financial incentives for improvement in
safety and health.
• Establishing and developing the research and development capability in
emerging areas of risk and providing for effective control measures.
• Focusing on prevention strategies and monitoring performance through
improved data collection system on work related injuries and diseases.
 47

• Developing and providing required technical manpower and knowledge in

the areas of safety, health and environment at workplaces in different
sectors.
• Promoting inclusion of safety, health and environment, improvement at
workplaces as an important component in other relevant national policy
documents including safety and occupational health as an integral part of
every operation.
The policy seeks to bring the national objectives into focus as a step
towards improvement in safety, health and environment at workplace. The
objectives are to achieve:-
a) Continuous reduction in the incidence of work related injuries, fatalities,
diseases, disasters and loss of national assets.
b) Improved coverage of work related injuries, fatalities and diseases and
provide for a more comprehensive data base for facilitating better
performance and monitoring.
c) Continuous enhancement of community awareness regarding safety,
health and environment at workplace related areas.
d) Continually increasing community expectation of workplace health and
safety standards.

6.2 THE NATIONAL POLICY HIGHLIGHTS

6.2.1 Preamble
The preamble contains Directive Principles of state policy under the
constitution of India relating,
• Securing the health and strength of employees, men and women;
• Non-abuse of the tender age of children,
• Citizens are not forced by economic necessity to enter avocations unsuited
to their age or strength,
• Just and human conditions of work and maternity relief
 48

• Suitable steps to secure the participations of employees in the

management.
• It also deals with the following-
• Commitment of the Government to regulate all economic aspects for the
management of safety and health risks at workplaces.
• To provide measures so as to ensure safe and healthy working conditions
for every working man and woman in the nation.
• Safety and healthy working environment is recognized as a fundamental
human right.
• Particulars attention needs to be paid to the hazardous operations and of
employees in risk prone conditions such as migrant employees.
The fundamental purpose of the National Policy on Safety, Health and
Environment at workplaces, is not only to eliminate the incidence of work
related injuries, diseases, fatalities, disaster and loss of national assets and
ensuring achievements of a high level of occupational safety, health and
environment performance through proactive approaches but also to enhance the
well-being of the employee and society at large.

6.2.2 Goals
The goals are set to meet the requirements such as
• Providing a statutory framework on Occupational Safety and Health in
respect of all sectors of industrial activities including the construction
sector, designing suitable control systems of compliance, enforcement and
incentives for better compliance.
• Providing administrative and technical support services.
• Providing a system of incentives to employers and employees to achieve
higher health and safety standards
• Providing for a system of non-financial for improvement in safety and
health.
 49

• Establishing and developing the research and development capability in

emerging areas of risks and providing for effective control measures.
• Focusing on prevention strategies and monitoring performance through
improved data collection system on work related injuries and diseases.
• Developing and providing required technical manpower and knowledge in
the areas of safety, health and environment at workplaces in different
sectors.
• Promoting inclusion of safety, health and environment, improvement at
workplaces as an important component in other relevant national policy
documents.
• Including safety and occupational health as an integral part of every
operation.

6.2.3 Objectives
The National objectives of the policy are
• To achieve continuous reduction in incidence of work related injuries,
fatalities, diseases, disasters, loss of national assets,
• To improve the coverage of work related injuries, fatalities and diseases
and provide for a more comprehensive data base for facilitating better
performance and monitoring.
• Continuous enhancement of community awareness regarding safety,
health and environment at workplace related areas.
• Continually increasing community expectation of workplace health and
safety standards.
 50

CHAPTER 7
CONCLUSION

There is large scale of improvements in the environmental, health and

safety management system globally in the MSMEs. It becomes imperative on
Indian industries irrespective of the size to adapt environmental, health and
safety management system as measure towards social commitment, legal
compliance, meeting supplier and end user requirements. Sensitization and
awareness building among all the stake holders such as employers, employer
and government are essential for successful implementation of EHSMS. Small
and micro enterprises employ more than 50% of the workers within the EU, and
so are responsible for more than 50% of the European OSH situation. Good
OSH management is a real challenge for this group of firms. There is broad
variation in small firms and in their OSH performance. For various reasons
supportive structures are indispensable to give OSH management in small firms
a boost. There are three main strategies for OSH management in small and
micro organizations to develop risk management, to comply with professional
standards, and outsourcing OSH. These require different forms of external
support.Due to the enormous diversity of small firms, there is a need for a broad
range of supportive activities, ranging from adequate and practical information
and training to personal advice, covering all relevant OSH risks. The success of
the supportive structure depends for a great deal on a good ‘match’ between the
support supplied and the variety of needs on small firms, whereby the demand
side should be leading. This forms a challenge for OSH experts and policy
makers, as up till now, the thinking about OSH management is determined by
the experiences with and in large enterprises.
 51

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