The On-Site and Off-Site Emergency Plans

In one line

One plan is written by the occupier for inside the fence and the other by the authority for outside it, and both must be rehearsed.

In the wording a student can write in an examination: rule 13 of the Manufacture, Storage and Import of Hazardous Chemical Rules 1989 requires an occupier to prepare and keep up to date an on-site emergency plan containing the details specified in Schedule 11 and detailing how major accidents will be dealt with on the site, including the name of the person responsible for safety on the site and of those authorised to take action under the plan, to take account in it of any modification in the activity, to inform every person on the site affected by the plan of its relevant provisions, to prepare it before a new activity is commenced or within ninety days of the rules coming into operation for an existing activity, to conduct a mock drill of it every six months and to make a detailed report of the drill immediately available to the concerned authority; and rule 14 imposes on the concerned authority identified in Column 2 of Schedule 5 the duty to prepare and keep up to date an adequate off-site emergency plan containing the particulars specified in Schedule 12, in consultation with the occupier and such other persons as it deems necessary, to prepare it before a new activity commences or within six months of the rules coming into operation for an existing activity, and to ensure that a rehearsal of it is conducted at least once in a calendar year.

Why there are two plans

Because a major accident has two sides of a fence and the people on each side need different things.

Inside the fence the people are employees, they are trained, they know the plant, and the plan is about isolating a release, fighting a fire, evacuating a unit and treating exposure. Only the occupier can write it because only he knows the plant.

Outside the fence the people are a town. They are not trained, they do not know what is stored, and the plan is about warning, evacuation routes, hospitals, traffic, water supply and the coordination of the police, the fire service, the district administration and the medical services. Only the authority can write it because only it commands those services.

Bhopal is the reason the distinction exists. There was no plan of either kind, and the people who died were outside the fence.

Rule 13, the on-site emergency plan

Who. The occupier.

What. An on-site emergency plan containing the details specified in Schedule 11 and detailing how major accidents will be dealt with on the site on which the industrial activity is carried on.