APPROACH TO SAFETY AUDIT-040113.pptx

This is a Safety Auditor Training Programme

This is An Approach to safety and Basic Elements

This is not a Routine Safety Training programme

An Introduction to Very Basics of Factories act, or IS 14489

APPROACH TO SAFETY AUDIT

HINDUSTAN ZINC LIMITED

Chanderiya Lead Zinc Smelter

The Journey continues

60 years of the Factories Act, 1948.

The Journey continues…… !

CSR2012 ASSOCHAM CSR Excellence award for FY 2012

HSE2012 'Innovative Environmental Project' award at the CII Environmental Best Practices Award 2012

2012 Rajasthan Energy Conservation Award 2011

Quality2012 IMC Ramakrishna Bajaj National Quality Award – 'Performance Excellence Trophy' (RBNQA – 2011)

2012 Best Prax Compass Award 2011

2012 SAP ACE award 2011 in the category of 'Best run IT organisation'

2012 'Silver Certificate of Merit' by the jury of ET's IMEA 2011 in partnership with Frost & Sullivan

The Journey continues…… !

Business Week - September 15, 2008

Hindustan Zinc positioned at no. 17 in Asia Business Week top 50 copies.

HZL 6th Indian company from the top to figure in the top 50 list

HZL No. #1 in the Metals and Mining Category in India

HZL No. # 2 in the Metals and Mining Category in Asia

HZL No. worlds single largest integrated Lead Zinc Manufacturer

INDEX to contents

1. Definitions 2. The need for safety audit & Purpose 3. Role in safety Management4. Audit Objectives5. Types of Safety audit its merits & demerits6. Motivation for Audits 7. Authorization, Scope &Frequency of Safety Audit 8. Surveillance techniques9. The Methodology of safety audit10. STATUES, Rules & CODES11. Technical Elements of Safety Audit12. Introduction to IS14498 & Records to be maintained for Compliance 13. Case study on report writing.

DEFINITION

SAFETY AUDIT-

IS0 19011 : 2002Systematic, independent & documented process for obtaining audit evidence and evaluating it objectively to determine the extent to which audit criteria are fulfilled

IS 14489Systematic examination to determine whether activities& arrangements are implemented effectively to prevent accidents

DEFINITION

SAFETY AUDIT-

1) It is a systematic ,objective approach to verify both safety compliance and the systems in place to manage safety responsibilities

2) Overall safety performance improvement

3) Co-operative effort between plant personnel &audit team

TOM- Top of The Mind

Audit is Systematic

Inspection is RANDOM

Audit Criteria is Standard

SAFETY AUDIT-

1) Respect to legislation

2) Compliance to standards

3) Management Tool to assess

4) Standard Methodology

5) Viewed by Outside parties

6) Done By Unbiased Audit team

7) Open & transparent system

Purpose of Safety audit

PurposeMinimize Losses

Prevent InjuriesUnsafe act

elimination

Hazard Recognition&

Control

Periodic Monitoring &

appraisal

Self Evaluation&Accident Prevention

Role in safety Management

Safety Performance is evaluated by indicators like LTIFR ,Severity rates& Losses in financial &Man hours

Indicators are quantitative in nature

Safety audit is a methodology that evaluates Qualitative performance and indicates the Character of overall Safety ,Programme/Performance

Judges it’s effectiveness

“An audit is Technique designed to ensure that standards achieved at any given place of work and other places affected by work activities conform as closely as possible to the objectives specified by the management for the control of risk of injury and ill health, and damage to property, plant &equipment and environment and to provide information to the management to justify continuation of same strategy or change of course”

The vibration analysis reveals it’s out of

balance.At 7 mm/sec it’s only

slightly rough.

That’s good!We can continue

operations but plan maintenance.

SAFETY FIRST

Audit Objectives

Audit Objectives1. Identify Deviations fro planned operating

&Maintenance procedures and Standards

2. Identify plant conditions or operating procedures that could lead to an accident and significant losses in life or property

3. Ensure that the plant &operating procedures match the design ,intent standards

4. Keep operating personnel alert to the process hazards

5. Review of operating procedures for necessary revisions

Audit Objectives

6. Seek to identify equipment or process changes that could lead to new hazards

7. Initiate application of new technology to existing hazard mitigation

8. Review adequacy of safety inspection

9. Look for major risk situations and

10. Recommend measures to improve overall safety performance of the plant

Types of Audit

External(Consultant/Third Party) Internal((Corporate/In house)

From Other Units

Local Plant Personnel

Other Deptt. Personnel

ODSO/NDO/OWSO

Internal Audit

These comprise in company teams that addressPlant safety inspections carried out by Trained EngineersInternal safety Audits conducted by Multi functional & Multi disciplinary officersPlant Inspections by safety Committee membersAudit Team from sister units in multi unit organizations

External Audit

External audits are done by Independent &third Party agencies ,they are

1. Government: Central &Regional Labour Institutes of

DGFASLI organization2. Public Sector Undertakings: Leading Engineering &Consultancy

organisations like EIL(Engineer’s India Limited,) FACT Engineering &design organization etc.

External Audit

3. Semi Government &Autonomous Body/Professional body associations:

They are like National Safety Counil, (NSC) Loss Prevention Association of India.

4. Private Consultants:

Many private company's are available in the field works

External Audit -Merits & De-Merits

3. Merits : Free from Bias Independent Evaluation Backed up by professional status &expertise Wide range of experience Better knowledge of statutory Provisions Brings industry standard good practices

Demerits Recommendations may be more general in Nature Constraints in implementation

Internal Audit -Merits & De-Merits

4. Merits : Familiarity with the technology Long Years of experience &detailed knowledge of operations Better probing Greater detailing &Easy implementation. Better knowledge of statutory Provisions specific to industry Demerits Limited Exposure of the best in class standards Unwillingness to change

Internal Audit -External audit

At HZL –CSC we Have both Safety systems of audit in Practice & place

PARALELLS

FINANCIAL AUDIT SAFETY AUDITSTATUTORY REQUIREMENT VOLUNTARY ACTION

ANNAULLY DONE NO FIXED FREQUENCY(.PLANNED?UNPLANNED)

ATTESTATION TO A STATEMENT STATUS CONFORMANCE WITH MANAGEMENT EXPECTATIONS

EXTERNAL FUNCTION BY EXTERNAL PERSNNOEL INTERNAL FUNCTION BY INTERNAL / EXTERNAL PERSONNLE

CONDUCTED IN ACCORDANCE WITH GENERALLY ACCEPTED STANDARDS OF PRACTICE

VARIATION IN APPROACH

FOCUS ON FINANCIAL ACCOUNTS FOCUS ON SAFETY ISSUES

1) DEPENDANCE ON STATNADARD METHODOLOGY2) USE OF SOUND AUDTING TECHNIQUES3) EMPHASIS ON VERIFYING COMPLIANCE AGAINST

STANDARDS

Motivation for Audits

Initiative of Local management Unit Management decides to have an

independent assessment To institute improvement Motivation reflects Confidence in The

management of organisation’s safety programmes

Direction from External agencies As directed by Factories inspectors while processing for Clearances required

for expansion of plants Sought by financial institutions Mandatory under Certification process

Direction from Top management Amended safety &environment legislations

place responsibility on Top Management Top management are keen in third party

Inspections Directives from specific to nature of Industry

Authorization, Scope &Frequency of Safety Audit

Authorization

Organization’s policy &unit management directivesClearly spelt objectives & policy statement

Allocation of Resources & Manpower

Commitment to implement changes

Scope of Safety audit

All activities as per objectives

To gain employee involvement

Encourage comments & suggestions related to safety

Invite co operation

Discover condition that need correction

bringing to an approved safety standard

It is an appraisal

Frequency of Safety Audit

General Guide is Normally once in a year

In chemical &Maintenance functions its periodic in nature

More Frequent inspections in the areas of Specific to certain activities Eg Boilers, Hoists etc.

Based on accident &injury records the high risk areas are to be prioritized and require frequent inspection

Surveillance techniques

Surveillance Audit Techniques

1. Safety Audit2. Safety Survey3. Safety Inspection4. Safety Tour5. Safety Sampling6. Hazard and Operability Studies (HAZOP)

Safety Audit1. subjects each area of a company’s activity to a

systematic critical examination with the object of

minimizing loss.2. Every component of the total system is included.

– aims to disclose the strengths and the weaknesses - the main areas of vulnerability or risk- is carried out by appropriately qualified personnel,- including safety professionals. - A formal report and action plan is subsequently

prepared and monitored.

Safety Survey

A safety Survey is a detailed examination in depth of a narrower field of activity, e.g. major key areas revealed by Safety Audits,

individual plants, procedures or specific problems common to a work as a whole.

These too are followed by a formal report, action plan and subsequent monitoring.

• A routine, scheduled inspection of a unit or department which carried out by personnel within the unit, possibly accompanied person from outside.

• The inspection would check maintenance standards, employee involvement, work practices, and that work is carried out in accordance with procedure etc.,

Safety Inspection

Safety Tour

An unscheduled examination of work area,

Carried out by any one of a range of personnel from works managers to safety committee members,

To ensure that e.g. standards of housekeeping are at an acceptable level, obvious hazards are removed and in general that safety standards are observed.

Safety Sampling

• A specific application of Safety Inspection/Tour designed to measure by random sampling the accident potential by counting safety defects.

• Trained observers record the number of safety defects seen while touring specified location by a prescribed route. Typically, tour last only 15 minutes and are conducted at weekly intervals.

• The un weighted count of defects is used to portray trends in the safety situation.

• The application of a formal critical examination to the process and engineering intensions of new facilities to assess the hazard potential of mal-operation or mal-functioning of individual items of equipment and the consequential effects on the facility as a whole.

• Remedial action is then usually possible at a very early stage of the project with maximum effectiveness and minimum cost.

• The techniques can also be applied to existing assets.

Hazard and Operability Studies (HAZOP)

STATUES, Rules & CODES

Statues Applicable

1. THE FACTORIES ACT,1948 / THE ANDHRA PRADESH FACTORIES RULES

2. Environment &pollution Control StatuesWater (prevention &control of Pollution act)Air (prevention &control of Pollution act)The Environment Protection act

3. Indian Electricity Act , Rules &Boilers Act4. ICMA Guide lines5. NFPA fire Protection Hand book6. Indian Standards on safety 7. National building Code

THE FACTORIES ACT,1948 / THE ANDHRA PRADESH FACTORIES RULES

Rule 55

Rule 55 Hoists and lifts should be examined by a competent person once in a year. In addition, regular examination must be done by a responsible person. Equipment must have a test certificate before it is taken into use.

Rule 55

Rule 55 Hoists and lifts should be examined by a competent person once in a year. In addition, regular examination must be done by a responsible person. Equipment must have a test certificate before it is taken into use.

Broken Strands

Crushed Rope

Rule 56 Rule 56 : pressure Vessels are to be fitted with:-Effective pressure relieving device of adequate capacity.-A suitable pressure gauge with maximum pressure indication- Suitable stop valves for isolating the vessel.-A suitable drain valve.-A pressure reducing device from the source of pressure. A pressure vessel can be taken into use only after Hydrostatic test is be conducted by a competent person.- A pressure vessel cannot be used at a higher pressure than the designed pressure which is the maximum permissible pressure.- Every pressure vessel shall be thoroughly examined externally once in 76 months and internally once in 12 months.- If due to process exigency, it is not possible to carry out internal examination every year, it may be replaced by a Hydrostatic test once in 2 years.- In case of continuous process industries, where the vessel cannot be frequently opened Hydrostatic Test may be done once in 4 years This should be supplemented by ultrasonic thickness test etc.-Special provisions are made for pressure vessels with thin walls and provision for reducing the maximum working pressure by 5% every year has been made.

Rule 56

Rule 56A Rule 56-A gives provisions to be complied with in case of water sealed gas holders.

Rule 57 Rule 57 prescribes weights to be handled by persons working in a factory

Pl discuss what is the weight???

Class Exercise pl?

Rule 58

Rule 58 prescribes that suitable eye protection should be provided for persons working in various process operations like Grinding, Turning, Drilling etc.

Rule 59 Rule 59 gives th minimum dimension of Manholes provided for chambers, tanks, vats etc.

Rule 61 Rule 61 gives details with regard to requirements of fire fighting provisions

Sub-section of this rule prescribes measure for tackling

fire protection against lightning, handling of explosives protection

against ignition, handling of gas cylinders, storage of flammable liquids

, First-Aid, Fire Fighting Arrangements, classes of fire

and other fire fighting equipments.

Rule 61A

Rule 61 A prescribes provisions of Safety belts for working at heights and specification of the belt.

Rule 61A

Rule 61 A prescribes provisions of Safety belts for working at heights and specification of the belt.

Rule 61AA Rule 61AA lays down requirement of safety officials to be appointed and their qualifications and experience etc.

Class Discussion please ?

Rule 61C Rule 61 C prescribes conditions for working on fragile roofs and provisions for crawling boards etc. For working on such roofs.

Rule 61B-G Rule 61B-G give guidelines for building and structures, plant and machinery, methods of work, stacking and storage of materials etc.,

Rule 61J Rule 61 J prescribes conditions to be complied with in case of reactors and vessels and kettles where there is likelyhood of over pressure being created.

Rule 61K Rule 61K prescribes that persons operating cranes, locomotives, forklift trucks, should be examined for eye sight and color blindness at least once in 2 years.

Rule 61L Rule 61L lays down conditions for railways which are laid inside the factory (private railway sidings)

Rule 61M Rule 61 M deals with safety committee to be created in factories.

Every factory shall have safety committee consisting equal number of representatives from management and employees with the minimum of 6 persons. They will review measures to be taken to ensure the health and safety of the workers and co-ordinate functions to improve these measures.

Rule 63&64

Rule 63 prescribes types of First-Aid appliances to be maintained in different classes of industries and inventory to be kept in the First-Aid boxes.

Rule 63&64

Rule 63A and 64 prescribe notification of First-Aid services persons in charge of First -Aid Ambulance Room with details of facilities to be provided

Rule 95 Rule 95, Chapter 10 under Section 87 of the act6 gives special provisions regarding dangerous operations carried out in an industry.

30 different processes have bend classified a dangerous operations and persons working in these factories shall be examined by a certified surgeon, as required by various schedules.

Rule 102A Rule 102A gives permissible levels of certain chemical substances in the work environment in any factory where such chemicals are handled by workers. Arrangement shall be made to monitor the same and maintain levels below the minimum level.

Rule 96

Rule 96 prescribes that any accident taking place in a factory should be intimated to the Chief Inspector,. This also gives guidelines for further notification in the event of lost time accident and reporting resumption of work. This also gives schedule of notifiable accidents.

Rule 97

Rule 97prscribes requirements of notification to the Chief Inspector regarding poisoning and some diseases caused due to the work environment. Complete set of forms in which compliance of rules as given in the prescribed paragraphs is also given in the Factories Act where by Manager of the factory should report to the Chief Inspector the various compliances.

Technical Elements

The following Technical Elements are to be looked into in detail while carrying out the Safety Audit

1. Building and Structures

2. Operational Safety and Procedures

3. Process In-built Safety

4. Handling and Storage of Hazardous Chemicals

5. Fire and Explosion Hazards

6. Material Handling

Technical Elements

The following Technical Elements are to be looked into in detail while carrying out the Safety Audit

7. Inspection and Testing of Pressure Vessels, Pipe-Lines and Storage Tanks

8. Personal Protective Equipment

9. Electrical Hazards

10. Preventive Maintenance

11. Pollution Abatement

12. Emergency Preparedness

Building and Structures

1) Location and lay-out

ii) Conforming to standards

iii) Stability certificate

iv) Ventilation

v) Lightning and illumination

vi) Escape routes and exits

vii) Fire proof construction and flame proof fitting

viii) Lighting arrestor

Operational Safety and Procedures

i) Availability and compliance of operating and safety manuals.

ii) Control of operational parameters.

iii) Start-up and shut-down procedures.

iv) Venting/scrubbing systems.

v) Running of emergency equipment during power failure

vi) Cleaning and tank entry procedures.

vii) Work permit systems.

viii) Precautions against endothermic/exothermic/runaway reactions

Process In-Built Safety

i) Interlock devices for critical operations and equipments.

ii) Over pressure relief devices.

iii) Continuous operation of neutralization system and connecting it with diesel generating set incase of power failure

iv) Connecting critical equipments with diesel generating set incase of total power failure

v) Alarm warning system incase of emergency.

vi) Indication and alarm systems for process parameters control.

vii) Installation of fail-safe instruments.

Handling and Storage of Hazardous Chemicals

i) Site selection

- Storage area away from buildings or structures.

- Distance as per the statutory regulations.

- Well ventilated area.

- Easy access from the control room.

ii) Statutory requirements –

- Fencing of 9 meters or 30 meters as the case may be.

- Distance between the two tanks

- Orientation/Direction of the dished, ends of the tank.

- Provision of dyke wall with drainage facilities

- Display of caution notice.

- Marking on pressure vessels.

- Fitting on the pressure vessels like pressure and temperature gauges, level indicators, weight measurements etc.

- Safety valves and isolating valves.

iii) Alarms & Indicators-

- High levels and high level alarms

- High pressure and high temperature alarm

- Isolation of the tank

- Remote control valve

iv) Safety valves discharge connection to the neutralization system/flare.

v) Flame proof fittings.

vi) Electrical grounding of the vessels and pipelines.

vii) Gas leakage and control –

- Gas detection sensors

- Dumping tank

- Covering of the exposed area

viii) Diesel generating set connecting to the emergency power supply.

ix) Minimizing of inventory.

x) Storage of chemicals under low pressure.

xi) Good house keeping.

xii) Fire fighting arrangement and provision of static water.

xiii) Extension of liquid inlet line to avoid static charge.

xiv) Personal protective equipments.

xv) Hydraulic testing and inspection of pipelines.

xvi) Installation of tanks above ground level.

Fire and Explosion Hazards

i) Location and capacity of fire hydrant pump.

ii) Booster pump and stand-by pump

iii) Hydrant pump starting system and procedures

iv) Static water quantity

v) Fire hydrant system –

- Layout of lines

- Space between the hydrants

- Water jet monitors

- Hydrant boxes

- Foam requirement

vi) Fire Extinguishers

- Fire siren system

- Fire fighting training

- Mutual aid scheme

vii) Fire prevention –

- No smoking and restricted areas

- Periodic checking and continuity of earthing

- Preventing spillages

- Water sprinklers

- Fire alarms

- Lightning arrestor

- Flame proof fittings

- Flame arrestor

- Static charge

- Fire exits

Fire and Explosion Hazards

Material Handling

i) Manual handling –

- Procedures

- Handling aids

- Condition of material handling areas

ii) Lifting tackles/cranes/hoists

- Selection

- Design criteria

- Inspection, testing and discarding

- Compliance with standards

- Periodic checking and maintenance

- Storage

- Safe working load, identification marking etc.

- slinging practices

iii) Material Handling procedures –

- Stacking and de stacking procedures

- Compliance with standards

- Load bearing capacity

- Stacking stability

- Safe handling procedures for chemicals and explosives

- Storage facilities (adequacy and stability) including pallets

- Clearance and passages

- Provision of aisles

Material Handling

Inspection and Testing of Pressure Vessels, Pipelines and Storage Tanks

i) Schedule of inspection and testing

ii) Testing and inspection reports

iii) Compliance with standards

iv) Inspection and testing of pressure relief valves

Personal Protective Equipment

i) Selection and stability

ii) Proper use

iii) Display

iv) Inspection and testing

v) Maintenance

vi) Proper storage

Electrical Hazards

i) Area classification

ii) Selection and use of electrical appliances

iii) Overload and short-circuit devices

iv) Power isolation procedures

v) Electrical fire-fighting devices

vi) Flame proof fitting

vii) Lightning arrestor

viii) Earthing/Earth leakage circuit breaker

Preventive Maintenance

i) Schedule

ii) Maintenance check list/reports

iii) Equipment change –over schedule

iv) Review of equipment failures

Pollution Abatement

i) Effluent treatment plant

ii) Air pollution control and monitoring

iii)Hazardous wastes treatment and disposal

iv)Noise pollution

v) Water management and water cess

Emergency preparedness

i) Organizationii) Emergency planningiii) Emergency control centreiv) Escape routesv) Assembly pointsvi) Evacuation proceduresvii) Identification of hazardous areasviii) Communication with in the plantix) Key personnelx) Emergency response equipments

xi) First aid and medical facilityxii) Communications (Authorities and public)Xiii) Dispersion modelsxiv) Training and drills

Emergency preparedness

Technical Elements of Audit

Ensure wearing of all PPEs

TOE Guard

TOE Guard – please discuss

Do’s & don’ts

Electrical safety – issues please discuss

Sump Coverings

Sump Coverings – Please discuss

What is the problem ????

oil Spillages

oil Spillages dos &don’ts

Please discuss –What is the problem?

Openings on floor to be watched

LPG safety- what to see?

Guarding Fan BladesWhen the periphery of the blades of a fan is less than 7 feet above the floor or working level, the blades must be guarded with a guard having openings no larger than 1/2 inch.

Thumb rule !!!

Abrasive Wheel Machinery

Work rests on offhand grinding machines must be kept adjusted closely to the wheel with a maximum opening of 1/8-inch to prevent the work from being jammed between the wheel and the rest, which may result in wheel breakage.

Abrasive Wheel MachineryThe distance between the wheel periphery and the adjustable tongue must never exceed 1/4-inch.

Abrasive Wheel Machinery- What is the problem ???

Gas Cylinder rules to be studied

Power-Transmission Apparatus

Power-transmission apparatus (shafting, flywheels, pulleys, belts, chain drives, etc.) less than 7 feet from the floor or working platform must be guarded.

Unguarded beltand pulley

Power-Transmission Apparatus – Please discuss

Power-Transmission Apparatus- Please discuss

For Technical Please discuss

Introduction to IS 14498 and Records to be maintained for

Compliance

1. Occupational safety & health policy

2. OS&H organizational set-up

3. education and training

4. Employees participation in OS&H Management.

5. Motivational and promotional measures for OS&H

6. Safety manual and rules

7. Compliance with statutory requirements

8. New equipment review/inspection

9. Accident reporting analysis investigation and implementation of recommendations.

IS 14489:1998, (Clauses 2.1 and 4.2.4), ELEMENDTS OF OCCUAPTIONAL SAFETY AND H EALTH

SYSTEM (OS&H)

10.Risk assessment including hazard identification

11.Safety inspections.

12.Health and safety improvement plan/targets.

13.First aid facilities – occupational health centre.

14.personal protective equipment.

15.Good house keeping.

16.Machine and general area guarding.

17.Material handling equipment.

18.Electrical and personal safeguarding.

19. Ventilation, illumination and noise.

IS 14489:1998, (Clauses 2.1 and 4.2.4), ELEMENTS OF OCCUAPTIONAL SAFETY AND HEALTH

SYSTEM (OS&H)

20.Work environment monitoring system

21.prevention of occupational diseases including periodic medical examination

22.Safe operating procedures

23.Work permit systems.

24.Fire prevention, protection and fighting system.

25.Emergency preparedness plans (on-site/ off-site).

26.Process/plant modification procedure.

27.Transportation of hazardous substances.

28.Hazardous waste treatment and disposal.

29.Safety in storage and warehousing.

IS 14489:1998, (Clauses 2.1 and 4.2.4), ELEMENTS OF OCCUAPTIONAL SAFETY AND H EALTH

SYSTEM (OS&H)

30.Contractor safety systems

31.Safety for customers ( including material safety data sheets)

IS 14489:1998, (Clauses 2.1 and 4.2.4), ELEMENTS OF OCCUAPTIONAL SAFETY AND H EALTH

SYSTEM (OS&H)

IS 14489:1998, (Clause 4.3.3.1), TYPES OF RECORDS TO BE EXAMINED DURING THE

SAFETY AUDIT

1.OS&H Policy

2.Safety organization chart

3.Training records on safety fire and first-aid

4.Records of plant safety inspections

5.Accident investigation reports

SAFETY AUDIT

6. Accident and dangerous occurrences – statistics and analysis

7. Record of tests and examinations of equipment and structures as per statutes

8. Safe operating procedures for various operations

9. Record of work permits

10.OS&H Policy

11.Safety organization chart

12.Training records on safety fire and first-aid

13.Records of plant safety inspections

14.Accident investigation reports

SAFETY AUDIT

14. investigation reports

15. Accident and dangerous occurrences – statistics and analysis

16. Record of tests and examinations of equipment and structures as per statutes

17. Safe operating procedures for various operations

18. Record of work permits

SAFETY AUDIT

19.Minutes of safety committee meetings

20.Approval of layouts; and other approval from statutory authorities

21.Records of any modifications carried out in plant or process

22.Maintenance procedure records

23.Calibration and testing records

SAFETY AUDIT

24. Shut down maintenance procedure

25. In service inspection manuals, records including that of material handling

26. Safety budget

27. Inspection books and other statutory records

28. Records of previous audits

29. Safety in transportation of hazardous substances

Thanks

AADHO RAMA THAPO VANANU GAMANAM, HATHWA MRUGAM KANCHANAM

VAIDEHI HARANAM, JATAYU MARANAM, SUGREEVA SAMBHASHANAM,

VALI NIGRAHANAM, SAMUDHRA THARANAM, LANKA PUREEM DAHANAM,

PASCHAD RAVANA KUMBHA KARNA MADHANAM, ETHAT ITHI RAMAYANAM

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