UNIVERSITI TUNKU ABDUL RAHMAN

FACULTY OF ENGINEERING AND GREEN TECHNOLOGY

UGPA2173: Occupational Safety and Health in Petrochemical Plant

Assignment 1 (10%):

OSH standards and regulations for petrochemical plant

Part 1: Overview of OSH Act of Malaysia for petrochemical plant

Petrochemicals are organic chemicals extracted from crude oil and natural gas and
refined through industrial processes. Examples of primary petrochemicals include ethylene,
propylene and benzene. Ethylene-based petrochemicals produce plastics, coolant and cosmetic.
Propylene makes styrofoam and benzene produces the synthetic fibre nylon. These
petrochemicals are exported to other country in order to increase the income of the country. In
this era of globalisation, Petronas is one of the worldwide leading companies in petrochemical
industry. It has a revenue of over RM438.8 billion and total assets of more than RM605.74
billion. Petronas provides approximately 30% of the Malaysian government's revenue. Moreover,
Malaysia is the worlds 16th largest natural gas reserves and the 28th largest crude oil reserves.
Malaysia also hosts one of the world's largest productions of liquefied natural gas facilities in a
single location. From being an importer of petrochemicals, Malaysia is today an exporter of
major petrochemical products.
 Statistic obtained from government official website shows that manufacturing industry
has the highest fatality and injury cases compared to others. Unfortunately, petrochemical plant
is categorized under manufacturing industry. The process plant involves various type of
reactions, accident could happen anytime in petrochemical plant if the process is out of control.
Social Security Organization (SOCSO) recorded an upsetting increase in the number of accidents
occurring at the construction sites in Malaysia including permanent disabilities and fatalities
from year 1996 to 2016 (Using AHP for Determining Priority in a Safety Management System,
2016). Moreover, Department of Occupational Safety and Health Malaysia under the Ministry of
Human Resources state that the fatality rate and incident rate in 2015 is 4.84 and 2.8
respectively. Statistics is shown in Table 1. Therefore, extra efforts should be made to reduce the
risk of accident and minimize the damage cause by accidents. In Malaysia, all the petrochemical
plants are strictly instructed to follow the Occupational Safety and Health standards and
regulations of the government.

Occupational Safety and Health standards and regulations are a standardized system that
creates balancing between the profit earned by employer and the health and safety of workers. It
is enforced by the Department of Occupational Safety and Health Malaysia under the Ministry of
Human Resources since 1994 until today. According to the Law of Malaysia, it is a must to
follow the system in order to operate a petrochemical plant.

The main purpose of OSH act is to protect the health and safety of workers. Several
regulations are added under the OSH act 1994 in order to reduce the hazard caused. It also
provides actions needed to be taken in any emergency situation. Accidents that commonly
happen in a petrochemical plant is fire and explosion. With the purpose to protect personnel and
properties in petrochemical plant from fire risk, Fire Service Act 1988 (The Commissioner of
Law Revision, 2006) is necessary. According to section 3 of this act, Fire Service Department
must be present in petrochemical plants. The department duties are stated in section 5. Besides,
water and fire hydrant are extremely important when there is a fire; Part IV section 22 to 25
highlighted the methods on the management and usage of water and fire hydrant.
 Next, malfunction of processing equipment like broken transportation pipeline can lead to
severe accidents like the gas explosion in Kaohsiung on 31 st of July 2014. 32 people were killed
and more than 300 people faced injuries (BBC News, 2014). Therefore, section 40 of Factories
and Machinery Act 1967 (The Commissioner of Law Revision, 2006) emphasized the good
condition of the equipment in order to reduce the risk of fire and explosion. Methods on how to
evaluate equipment can be obtained from Special Scheme for Inspection (Risk-Based Inspection)
regulation under this act (Dato Sri Richard Riot anak Jaem, Minister of Human Resources,
2014). The purpose of Factories and Machinery Act 1967 (FMA 1967) is to provide solutions in
factories control on the machinery that are related to the health and safety of workers. All
petrochemical plants must abide by it.

Exposure to the chemicals as mentioned in the first paragraph in working environments

can be hazardous to human. By taking ethylene glycol as an example, it may cause irritation to
skin. Ingestion of this chemical leads to depression of central nervous system which may be
followed by nausea, vomiting and abdominal cramps. Therefore, Use and Standards of Exposure
of Chemicals Hazardous to Health regulation 2000 under OSH Act 1994 has been introduced.
Regulation 6 and 7 state the responsibility of employers to ensure that the workers do not exceed
the reference exposure limit based on the type of chemical exposed during work. The table of
type of exposure limit is included in Schedule 1 (Datuk Dr Fong Chan Onn, Minister of Human
Resources, 2000). According to Table 2 in the appendix, employees cannot be exposed to more
than 0.05ppm in eight-hour-weighted average airborne concentration and 1ppm in ceiling limit
airborne concentration. Other than setting exposure limit, action on how to control the exposure
is equally important and it is available in regulation 14 to 19 in the same act.

Hearing is essential for well-being and safety. Exposure to unacceptable noise level will
eventually lead to reduce in hearing sensitivity, cardiovascular effects, rise in blood pressure and
coronary artery disease. Noise induced hearing loss (NIHL) is the highest reported occupational
disease in Malaysia. In 2015, 5366 cases out of total cases of 5960 of occupational disease had
been reported were NIHL as shown in table 3. NIHL contributes more than 90% in occupational
disease occurred in Malaysia (Wahab, 2016). In order to reduce the amount of NIHL cases,
Factories and Machinery (Noise Exposure) Regulations 1989 has been implemented under FMA
1967. It contains the permissible exposure limit which determines the noise level and duration
that a worker can work when exposed to loud noise. Other than that, it also includes the exposure
monitoring and methods of compliance in order to minimise the number of cases (Encik Lee
Kim Sai, Minister of Labour, 1998).

In a nutshell, occupational accidents are preventable and safety measures can reduce the
severity of occupational injuries. Improvement in occupational safety and health requires actions
from tri-parte namely workers, employers and the government. Cooperation between three
parties must be emphasized. In fact, the technical and engineering aspects of plant operation are
found to be important causes of accidents in the petrochemical process industry. Hence, a
combination of rules from the government, attitudes from the workers and good practices
initiated by the employers will create a positive safety culture at workplace.

Part 2: Recommendation for further improvement

It is suggested that few amendments shall be made in the Factories and Machinery (Noise
Exposure) regulation 5(1) 1989 (Encik Lee Kim Sai, Minister of Labour, 1998). The maximum
limit for noise level exposed continuously to the employee shall reduce from 90 decibels to 85
decibels. According to World Health Organization (WHO), 85 decibels is considered the highest
safe exposure level on human ear. Besides, it is suggested that the permissible exposure limits
from First Schedule shall be redesign. This is because the exposure duration of noise level of 85
decibels in the schedule is twice the duration limit suggested by WHO. The maximum exposure
duration limit for 85 decibels is 8 hours (World Health Organization (WHO): Make Listening
Safe Campaign - Factsheet, 2015). Next, improvement can be made in the same act (Part III) by
providing the guidance for the employer on the presentation of information about noise levels
generated by plant. The guidance can refer to the National Code of Practice of Noise
Management Australia (The National Occupational Health and Safety Commission, 2004).

Ventilation plays an important role in removing air pollutants from the breathing zone of
workers. In Malaysia, the information of Local Exhaust Ventilation (LEV) system provided in
the guideline is very limited and some relevant parts are separated under another guideline. In
example, (the testing, inspection, examination and maintenance) is put under Guidelines on the
Inspection, Examination and Testing of Exhaust System (Dosh.gov.my, 2001). It is suggested
that LEV system should have its own guideline like Local Exhaust Ventilation (LEV) Guidance
from Health and Safety Authority (HSA), Ireland (Health and Safety Authority, 2014). In this
guideline, there are 18 chapters that provide sufficient knowledge to the employer. In example,
chapter 3 describes the crucial elements that a LEV system should have and the consequences of
poor design of LEV system. Chapter 12 gives guidance on the key points regarding examination
and performance monitoring like the elements which routine check up must include and
questionnaire for physical examination before flow measurement.

A safety officer develops and provides measures for assuring personnel safety and
analyzes the danger level of a situation. Therefore, experience and knowledge possessed by a
safety officer is extremely important to determine the safety of petrochemical plant. In Malaysia,
anyone possessed the qualification stated in the Safety and Health Officer regulations 1997 under
OSH act 1994 may registered as a safety officer. The qualification of registration shall raise its
level of requirement by changing the section 6(1) (Dosh.gov.my, 1997). The minimum
requirement of educational level shall change from diploma to degree. Other than that, it is
suggested that Malaysia should creates its own board of certification of safety officer like The
Board of Certified Safety Professionals (BCSP) (Bcsp.org, 2016). The board created will provide
training to those who are qualified and series of examination for them to pass. New regulation
shall be introduced so that government agencies rely on it and other companies include it in
position standards.

According to Malaysia OSH act part VIII, it stated that the Director General may appoint
one or more persons of engineering, medical or other appropriate skills or expertise to serve as
assessors in any such inquiry. The minimum amount of person who in charge which have
appropriate skill should have at least two or more who have different knowledge in order to think
something out of the box, have discussions and find out mistakes or slips before accidents
happen. For example, a chemical engineer works with a safety engineer can exchange their own
knowledge and experience in order to have a better prevention before accidents happen.

Moreover, Malaysia OSH act which under Medical surveillance stated that persons below
the age of sixteen years are or are about to be employed in work which may cause risk of injury
to their health. The age for this dangerous exposure should have increase to 18 years old and
only allowed person who above age of 18 to work under unrestricted condition. This is because
person who under 18 years old are still not consider as a legal individual who are still under
parents or guardian restriction. In most of the modern countries such as Germany, Iceland,
Sweden and Taiwan allowed individual to work unrestricted at least age of 18 years.
(En.wikipedia.org, 2016)

APPENDIX
Table 1: Statistic of occupational accidents by sector September 2016
Table 2: Chemicals and their maximum exposure limit.
Table 3: Occupational Diseases & Poisoning (Type of Diseases) Received & Investigated
REFERENCES

Dato Sri Richard Riot anak Jaem, Minister of Human Resources, (2014). Factories and
Machinery (Special Scheme of Inspection) (Risk-Based inspection) regulations 2014. Kuala
Lumpur: Percetakan Nasional Malaysia Berhad, pp.9-12.

Datuk Dr Fong Chan Onn, Minister of Human Resources, (2000). Occupational Safety and
Health (Use and Standards of Exposure of Chemicals Hazardous to Health) Regulation 2000.
Kuala Lumpur: Percetakan Nasional Malaysia Berhad, pp.6, 23.

The Commissioner of Law Revision, (2006). FACTORIES AND MACHINERY ACT 1967
(REVISED - 1974). Kuala Lumpur: Percetakan Nasional Malaysia Berhad, p.27.

The Commissioner of Law Revision, (2006). Fire Act 1988. Kuala Lumpur: Percetakan National
Malaysia Berhad, pp.11-12, 19-20.

Using AHP for Determining Priority in a Safety Management System. (2016). Industrial
Management & Data Systems, 104(5), pp.430-445.

BBC News. (2014). Taiwan gas blasts in Kaohsiung kill at least 25 - BBC News. [online]
Available at: http://www.bbc.com/news/world-asia-28594693 [Accessed 17 Nov. 2016].

Encik Lee Kim Sai, Minister of Labour, (1998). Factories And Machinery (Noise Exposure)
Regulations 1989. Kuala Lumpur: Percetakan Nasional Malaysia Berhad, pp.5,6,13.

World Health Organization (WHO): Make Listening Safe Campaign - Factsheet. (2015). Make
Listening Safe. [online] Available at:
 http://www.asha.org/uploadedFiles/ASHA/Buds/WHO-Make-Listening-Safe-Campaign-
Factsheet.pdf [Accessed 23 Nov. 2016].

The National Occupational Health and Safety Commission. (2004). National Code of Practice for
Noise Management and Protection of Hearing at Work [NOHSC: 2009(2004)] 3rd Edition.
[online] Available at:
http://www.safeworkaustralia.gov.au/sites/swa/about/publications/Documents/279/NationalC
odeOfPractice_NoiseManagementAndProtectionOfHearingAtWork_3rd
%20Edition_NOHSC2009-2004_PDF.pdf [Accessed 23 Nov. 2016].

Health and Safety Authority. (2014). Local Exhaust Ventilation (LEV) Guidance. [online]
Available at:
http://www.hsa.ie/eng/Publications_and_Forms/Publications/Occupational_Health/Local_Ex
haust_Ventilation_LEV_Guidance.pdf [Accessed 23 Nov. 2016].

Dosh.gov.my. (2001). Guideline On the Control Chemicals Hazardous to Health. [online]

Available at: http://www.dosh.gov.my/index.php/en/legislation/guidelines/chemical/623-06-
guidelines-on-the-control-of-chemicals-hazardous-to-health-2001/file [Accessed 23 Nov.
2016].

Bcsp.org. (2016). About | Board of Certified Safety Professionals. [online] Available at:
http://www.bcsp.org/About [Accessed 23 Nov. 2016].

Dosh.gov.my. (1997). Occupational Safety And Health (Safety And Health Officer) Regulations
1997. [online] Available at: http://www.dosh.gov.my/index.php/en/legislation/regulations-
1/osha-1994-act-154/524-04-occupational-safety-and-health-safety-and-health-officer-
regulations-1997/file [Accessed 23 Nov. 2016].

Wahab, N. (2016). Website Department of Occupational Safety and Health Malaysia -

Occupational Diseases and Poisoning Investigation. [online] Dosh.gov.my. Available at:
http://www.dosh.gov.my/index.php/en/osh-info-2/occupational-health/392-occupational-
diseases-and-poisoning-investigation [Accessed 23 Nov. 2016].
En.wikipedia.org. (2016). Legal working age. [online] Available at:
https://en.wikipedia.org/wiki/Legal_working_age [Accessed 24 Nov. 2016].