Make in India – Make “SAFELY” In India

This article was originally published in Exim Newsletter’s The New Year Special Supplement 2016 – VOL 2

Prime Minister of India’s ambitious initiative of Make in India has generated positive outlook across all the sectors of International & domestic, Indian, Industries. Through this initiative India is encouraging domestic and international players to manufacture their products in India. Among various sectors in the industry this initiative will include Automobiles, Chemicals, Pharmaceuticals, Textiles, Leather, bio-technology, electronics, mining, ports etc.

Bulk Carrier at Karwar Port
Bulk Carrier at Karwar Port

Whatever produced need to be transported, for production raw materials need to be transported. Transportation infrastructure must grow in a faster pace to meet this objective and transportation must always be in a safe way.

Performance of selected Major Chemicals (Group-Wise) during 2006-07 to 2013-14 at a Glance (Figures in 000'MT)
Performance of selected Major Chemicals (Group-Wise) during 2006-07 to 2013-14 at a Glance (Figures in 000’MT)

(Source Ministry of Chemicals & Fertilizers Government of India)

Exports of Major Chemicals (Group Wise) during 2006-07 to 2013-14 (QTY. IN MT; VALUE IN RS. LAKH)
Exports of Major Chemicals (Group Wise) during 2006-07 to 2013-14 (QTY. IN MT; VALUE IN RS. LAKH)

(Source Ministry of Chemicals & Fertilizers Government of India)

As India increase the market share in production and export of chemicals we need to look at strict adherence to regulations which includes Transport Regulations and import countries’ domestic regulations. Our major trading partner countries have adopted Globally Harmonized System of Classification through national legislation. Chemicals, including dangerous goods, which are falling within the criteria need to have safety data sheet (SDS) prepared as per the import countries GHS requirement. A chemical may be considered skin irritant in one country, but not another. Or it may be considered flammable in one country, but not another. Government of India should publish its national policy on GHS and dispense same to all chemical sectors for compliance.

When we look at transport regulations, in multimodal transport, our export of chemicals and dangerous goods must meet India domestic, road & rail, international by sea and destination countries’ domestic regulations. Regulations varies in different modes of transport and destination countries’ may have different or additional compliance requirement.

IMDG Code 37th Amendment came into force. How prepared is our industry for compliance to new regulations which are changing periodically?

We have and are experiencing some serious shortcomings in compliance which have resulted in penalties by enforcement authorities in U.S. & Europe. Mostly related to stuffing of container, marking, labelling, placarding & Documentation. What else is remaining? Segregation??

Some of our acid containers ended up leaking due to insufficient blocking and bracing. Some tanks leaked due to failure in valve. As a significant number of containers leaked certain shipping lines have made is strict for Indian acid exports by making a rule that Indian acid will only be accepted in ISO Tanks and shipper has to give in writing that degree of filling of tank is in accordance with relevant formulae as per IMDG Code.

Export containers must meet every provision of IMDG Code in letter and spirit for safety in transport and protection of environment.

Storage and Segregation of Dangerous Goods in Port Areas and CFS’ ICDs also need paramount attention for safety. Improper storage disregarding required segregation may end up in unimaginable losses in case of an accident. Remember Tianjin blast!

Another area where India needs urgent and clear improvement is with respect to Port regulations for handling Dangerous Goods. Now if a user, exporter or importer, want to know whether ‘x’ commodity is permitted to be loaded from a port he has to check with a shipping line who may ask him to come with a firm booking. Our ports need to revise the existing regulations considering quantitative risk analysis and publish them on their websites differentiating rules for Load, Discharge, Transit and Transshipment for every UN Number published in the regulations. We cannot be working with old penultimate rules such as “all explosives prohibited” which will even stop importing Air bags and Seat belts for automobile industries or exporting charges for fire extinguishers.

Above all, every player in the industry, be it an organization or an individual, must rise above time for safety and regulatory compliance to make “Make in India” successful.

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