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GAIL (India) Limited Corporate HSE Department IOM Ref. No. GAIL/NOIDA/HSE/18/2018-19/ Dated:28 th May 2018 SUB: MONTHLY HSE SCORE REPORT APRIL 2018 HSE Score Report for the month of April 2018 containing inter alia HSE Score for the following Installations / Plants is sent herewith for your kind perusal & information please. 1. HVJ and Regional Natural Gas Pipeline Installations 2. LPG Pipeline Installations 3. Process Plants Overall HSE Score stands at 89.20 for the month of April 2018. S P Garg Executive Director (HSE) To : All OICs (as per the mailing list) CC: for favor of information to: C&MD Director (Projects)/ Director (HR) / Director (Finance) / Director (Mktg)/CVO ED (O&M-CO)/ED (O&M-NR)/ED (PC-Pata)/ED(O&M-CR)/ED (WR)/ED (O&M- SR)/CGM (O&M-WR)

GAIL (India) Limited Score_April_18.pdfGAIL Vaghodia and Gandhar acknowledged with “Prasansha Patra Safety Award” from National Safety Council Mumbai. The award is given by Sh

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Page 1: GAIL (India) Limited Score_April_18.pdfGAIL Vaghodia and Gandhar acknowledged with “Prasansha Patra Safety Award” from National Safety Council Mumbai. The award is given by Sh

GAIL (India) Limited Corporate HSE Department

IOM

Ref. No. GAIL/NOIDA/HSE/18/2018-19/ Dated:28th May 2018

SUB: MONTHLY HSE SCORE REPORT – APRIL 2018 HSE Score Report for the month of April 2018 containing inter alia HSE Score for the following Installations / Plants is sent herewith for your kind perusal & information please.

1. HVJ and Regional Natural Gas Pipeline Installations 2. LPG Pipeline Installations 3. Process Plants

Overall HSE Score stands at 89.20 for the month of April 2018.

S P Garg Executive Director (HSE)

To : All OICs (as per the mailing list) CC: for favor of information to:

C&MD

Director (Projects)/ Director (HR) / Director (Finance) / Director (Mktg)/CVO

ED (O&M-CO)/ED (O&M-NR)/ED (PC-Pata)/ED(O&M-CR)/ED (WR)/ED (O&M-SR)/CGM (O&M-WR)

Page 2: GAIL (India) Limited Score_April_18.pdfGAIL Vaghodia and Gandhar acknowledged with “Prasansha Patra Safety Award” from National Safety Council Mumbai. The award is given by Sh

Corporate HSE Department

Monthly HSE Score Report April 2018

Highlights

GAIL Vaghodia and Gandhar acknowledged with “Prasansha Patra Safety

Award” from National Safety Council Mumbai. The award is given by Sh.

Santosh Gangwar, Honourable Labour Minister, Government of India at

SCOPE Complex, New Delhi on 27th April 2018.

Fire Service Week was observed from 14th April to 20th April 2018.

HSE Study and Gap Analysis of Jamnagar Loni LPG Pipeline were carried

out by M/s DNVGL from 09th to 13th April 2018.

Exception Report on Monthly Safety Day was reviewed by Director (Projects)

and Director (HR)/Acting Director (BD).

Group HSE Score: April 2018

SN Category HSE Score

01 HVJ NATURAL GAS PIPELINE 89.40

02 REGIONAL PIPELINES 88.30

03 PROCESS PLANTS 89.90

04 LPG PIPELINES 89.40

OVER ALL HSE SCORE 89.20

For optimization of Internal Safety Audit System by bringing in reduction in number of Safety Audits, Management has approved following revision:

1. Proactive Safety Audit (Internal / self-check audit) to be conducted by Multidisciplinary Team on yearly basis. The team will be constituted by respective ED & Safety Audit Calendar will be declared at the start of the year.

2. Corporate O&M Department to act as nodal point for Internal Safety Audits to meet PNGRB regulations and other policies and guidelines and statutory requirements. Corporate O&M in consultation with Corporate HSE will constitute a Multidisciplinary Team for Internal Audits and declare audit calendar at the start of the year.

Page 3: GAIL (India) Limited Score_April_18.pdfGAIL Vaghodia and Gandhar acknowledged with “Prasansha Patra Safety Award” from National Safety Council Mumbai. The award is given by Sh

Improvement Areas

OISD Audit Analysis (2017-18): During the last year, OISD had carried out External Safety Audits of Vijaipur Kota Pipelines,

Dadri Bawana Nangal Pipelines, Dabhol Bangalore Pipeline and Ramgarh Pipelines.

On analysis of the OISD recommendations it was found that 61% of the total

recommendations were pertaining to Operation and Maintenance related issues. 25% of

the recommendations were related to Fire Prevention and Fire Protection System.

The remaining 14% were pertaining various other areas like Statutory, Design etc.

SCADA, Leak

Detection

Attributed mainly by short bolting, eathing,

UT, display of set points, SLD, earthing diagram etc, calibration, P&ID, PSV setting,

Foot Patrolling Reports, Tagging, Testing of

tools and tackles, Illumination, Lamp

indication, Non flame proof junction box etc.

Operation

al of

Detectors

Pipeline

Patrolling,

Pipeline

Boundary Wall, Vent Height, SCADA,

Leak Detection System, Gas Detection,

Inter Distances etc. Layout of FWN, Mock Drill, Internal Safety Audit, Hand

Operated Siren, Non Operational of Detectors,

Hydro-testing of Fire

Extinguishers, Training, PPEs,

Work Permit System etc.

Pigging, Cathodic

Protection/Coating, Corrosion,

Encroachment, Pipeline Patrolling,

Pipeline Support, Valve/Pig

Launcher & Receiver and General

O&M etc.

Page 4: GAIL (India) Limited Score_April_18.pdfGAIL Vaghodia and Gandhar acknowledged with “Prasansha Patra Safety Award” from National Safety Council Mumbai. The award is given by Sh

The 61% of recommendations pertaining to Operation & Maintenance are attributed to

aspects like Pigging, Cathodic Protection/Coating, Encroachment, Pipeline Patrolling,

Pipeline Support, Valve/Pig Launcher & Receiver and General O&M.

Further analysis of the O&M recommendations (61%), it is noted that more than 72% fall

under the category of General O&M, which could be identified and corrected through

Safety Observations/Inspections at Pipeline Areas. The general O&M points included

mainly Attributed mainly by short bolting, eathing, UT, display of set points, SLD, earthing

diagram etc, calibration, P&ID, PSV setting, Foot Patrolling Reports, Tagging, Testing of

tools and tackles, Illumination, Lamp indication, Non flame proof junction box etc.

OIC/WIC/HODs may identify and report such observations during their visits at Installations, so necessary corrective action be taken accordingly. Employees may also be encouraged to report such safety observations on regular basis. Safety Suggestions: The employee HSE Suggestion Program provides a mean to encourage all employees to

take part in improving the Health, Safety and Environment and effectiveness of our

operational and maintenance. Employees should encourage to improvement areas beyond

regulatory stipulations and general O&M practices along with possible solutions to improve

workplace safety.

Emergency Exercise: Testing and mock drills for onsite emergency plan shall be carried once in three months and for offsite emergency plan twelve months. Each site should hold drills on the night shifts, change shifts as well as during the day as mandated.

***

Page 5: GAIL (India) Limited Score_April_18.pdfGAIL Vaghodia and Gandhar acknowledged with “Prasansha Patra Safety Award” from National Safety Council Mumbai. The award is given by Sh
Page 6: GAIL (India) Limited Score_April_18.pdfGAIL Vaghodia and Gandhar acknowledged with “Prasansha Patra Safety Award” from National Safety Council Mumbai. The award is given by Sh
Page 7: GAIL (India) Limited Score_April_18.pdfGAIL Vaghodia and Gandhar acknowledged with “Prasansha Patra Safety Award” from National Safety Council Mumbai. The award is given by Sh

Report on Deduction of HSE Score

SN LOCATION ELEMENT

DESCRIPTION MAX.

SCORE SCORE

EARNED COMMENTS

1 AbuRoad Behaviour Based Safety (BBS) Review

1 0 Steering Committee Review Meeting was not conducted as scheduled.

2 AbuRoad Safety Observations (Unsafe Acts/Conditions)

4 2 Less reporting of safety observations in SAP

3 AbuRoad Operational & Safety Training

6 4 Training not conducted as per annual plan

4 AbuRoad

Near Miss Incidents:(Any incident having potential for minor/major loss of any kind)

6 4 Less reporting and non performing investigation of near misses

5 AbuRoad OISD/T4S Audit 6 5.5 Non-compliance of recommendation beyond 2 years

6 Agartala Safety Observations (Unsafe Acts/Conditions)

4 0 Less reporting of safety observations

7 Agartala HAZOP 2 0 Non-compliance of recommendations as per target date

8 Agartala

Near Miss Incidents:(Any incident having potential for minor/major loss of any kind)

6 3 Less reporting and non performing investigation of near misses

9 Agartala On Site Emergency Exercise (Quarterly)

3 1 Mock drill in odd hours has not been conducted during last year

10 Agartala OISD/T4S Audit 6 0 Non-compliance of recommendations as per target date

11 Bengaluru Safety Suggestion from Employees

1 0 Non submission of safety suggestion

12 Bengaluru Safety Observations (Unsafe Acts/Conditions)

4 0 Failure to identify Unsafe Acts/Conditions

13 Bengaluru SOPs/SWPs Compliance Check

2 0 Non checking SOPs for compliance

14 Bengaluru

Near Miss Incidents:(Any incident having potential for minor/major loss of any kind)

6 2 Less reporting and non performing investigation of near misses

15 Bengaluru OISD/T4S Audit 6 5 Detailed compliance action plan not submitted

16 Chhainsa Safety Suggestion from Employees

1 0 Subject suggestion falls under category of safety observation

17 Chhainsa Safety Observations (Unsafe Acts/Conditions)

4 0 Less reporting of safety observations

18 Chhainsa SOPs/SWPs Compliance Check

2 0 Non checking SOPs for compliance

19 Chhainsa

Near Miss Incidents:(Any incident having potential for minor/major loss of any kind)

6 0 Less reporting near misses

20 Chhainsa Internal Safety Audit (Including Internal Technical Audit)

3 2 Non-compliance of audit recommendations beyond one year

Page 8: GAIL (India) Limited Score_April_18.pdfGAIL Vaghodia and Gandhar acknowledged with “Prasansha Patra Safety Award” from National Safety Council Mumbai. The award is given by Sh

21 Dibiyapur Safety Suggestion from Employees

1 0 Subject suggestion falls under category of safety observation

22 Dibiyapur Safety Observations (Unsafe Acts/Conditions)

4 2 Less reporting of safety observations

23 Dibiyapur

Near Miss Incidents:(Any incident having potential for minor/major loss of any kind)

6 1 Less reporting and non performing investigation of near misses

24 Dibiyapur On Site Emergency Exercise (Quarterly)

3 1 Mock drill in odd hours has not been conducted during last year

25 Dibiyapur OISD/T4S Audit 6 4 Non-compliance of recommendation beyond 2 years

26 GKonduru Safety Suggestion from Employees

1 0 Non submission of safety suggestion

27 GKonduru Safety Observations (Unsafe Acts/Conditions)

4 0 Less reporting of safety observations

28 GKonduru

Near Miss Incidents:(Any incident having potential for minor/major loss of any kind)

6 3 Less reporting and non performing investigation of near misses

29 GKonduru On Site Emergency Exercise (Quarterly)

3 1 Mock drill in odd hours has not been conducted during last year

30 GKonduru OISD/T4S Audit 6 0 Non-compliance of recommendation as per target date

31 Gandhar Safety Suggestion from Employees

1 0 Subject suggestion falls under category of safety observation

32 Gandhar Safety Observations (Unsafe Acts/Conditions)

4 2 Less reporting of safety observations in SAP

33 Gandhar SOPs/SWPs Compliance Check

2 0 Non checking SOPs for compliance

34 Gandhar

Near Miss Incidents:(Any incident having potential for minor/major loss of any kind)

6 1 Less reporting and non performing investigation of near misses

35 Gandhar Internal Safety Audit (Including Internal Technical Audit)

3 0 Non-compliance of audit recommendation as per target date

36 Hazira Safety Suggestion from Employees

1 0 Subject suggestion falls under category of safety observation

37 Hazira Safety Observations (Unsafe Acts/Conditions)

4 2 Less reporting of safety observations in SAP

38 Hazira Safety Committee Meeting (Quarterly)

3 1 Non-compliance of recommendation as per target date

39 Hazira On Site Emergency Exercise (Quarterly)

3 1 Mock drills in odd hours has not been conducted during last year

40 Jamnagar Safety Suggestion from Employees

1 0 Subject suggestion falls under category of safety observation

41 Jamnagar Safety Observations (Unsafe Acts/Conditions)

4 0 Less reporting of safety observations

Page 9: GAIL (India) Limited Score_April_18.pdfGAIL Vaghodia and Gandhar acknowledged with “Prasansha Patra Safety Award” from National Safety Council Mumbai. The award is given by Sh

42 Jamnagar

Near Miss Incidents:(Any incident having potential for minor/major loss of any kind)

6 4 Less reporting near misses

43 Jamnagar OISD/T4S Audit 6 5.5 Non-compliance of recommendation beyond 2 years

44 Jhabua Safety Suggestion from Employees

1 0 Subject suggestion falls under category of safety observation

45 Jhabua Behaviour Based Safety (BBS) Review

1 0 Steering Committee Review Meeting was not conducted as scheduled.

46 Jhabua Safety Observations (Unsafe Acts/Conditions)

4 3 Less reporting of safety observations in SAP.

47 Jhabua Operational & Safety Training

6 4 Training not conducted as per annual plan

48 Jhabua On Site Emergency Exercise (Quarterly)

3 1 Mock drill in odd hours has not been conducted during last year

49 Jhabua Internal Safety Audit (Including Internal Technical Audit)

3 0 Non-compliance of audit recommendation as per target date

50 Kailaras Safety Suggestion from Employees

1 0 Subject suggestion falls under category of safety observation

51 Kailaras Safety Observations (Unsafe Acts/Conditions)

4 0 Less reporting of safety observations

52 Kailaras

Near Miss Incidents:(Any incident having potential for minor/major loss of any kind)

6 0 Less reporting near misses

53 Kailaras On Site Emergency Exercise (Quarterly)

3 1 Mock drill in odd hours has not been conducted during last year

54 Kailaras OISD/T4S Audit 6 4 Non-compliance of recommendations beyond 2 years

55 Kailaras Internal Safety Audit (Including Internal Technical Audit)

3 0 Non-compliance of audit recommendations as per target date

56 Kandla Safety Suggestion from Employees

1 0 Subject suggestion falls under category of safety observation

57 Kandla Behaviour Based Safety (BBS) Review

1 0 Steering Committee Review Meeting was not conducted as scheduled.

58 Kandla Safety Observations (Unsafe Acts/Conditions)

4 0 Less reporting of safety observations

59 Kandla

Near Miss Incidents:(Any incident having potential for minor/major loss of any kind)

6 2 Less reporting and non performing investigation of near misses

60 Kandla On Site Emergency Exercise (Quarterly)

3 1 Mock drill in odd hours has not been conducted during last year

61 Kandla OISD/T4S Audit 6 5.5 Non-compliance of recommendation beyond 2 years

Page 10: GAIL (India) Limited Score_April_18.pdfGAIL Vaghodia and Gandhar acknowledged with “Prasansha Patra Safety Award” from National Safety Council Mumbai. The award is given by Sh

62 Khera Safety Suggestion from Employees

1 0 No suggestion received

63 Khera Safety Observations (Unsafe Acts/Conditions)

4 0 Less reporting of safety observations

64 Khera

Near Miss Incidents:(Any incident having potential for minor/major loss of any kind)

6 2 Less reporting and non performing investigation of near misses

65 Khera Internal Safety Audit (Including Internal Technical Audit)

3 1 Non-compliance of audit recommendation beyond one year

66 Kochi Behaviour Based Safety (BBS) Review

1 0 Steering Committee Review Meeting was not conducted as scheduled.

67 Kochi Safety Observations (Unsafe Acts/Conditions)

4 2 Less reporting of safety observations

68 Kochi On Site Emergency Exercise (Quarterly)

3 1 Odd hours emergency exercise was not conducted during last year.

69 Kochi Internal Safety Audit (Including Internal Technical Audit)

3 1.5 Non-compliance of audit recommendations beyond one year

70 LoniRegion Safety Suggestion from Employees

1 0 Subject suggestion falls under category of safety observation

71 LoniRegion Safety Observations (Unsafe Acts/Conditions)

4 2 Less reporting of safety observations in SAP

72 LoniRegion

Near Miss Incidents:(Any incident having potential for minor/major loss of any kind)

6 4 Non performing investigation of near misses

73 LoniRegion On Site Emergency Exercise (Quarterly)

3 1 Mock drill in odd hours has not been conducted during last year

74 LoniRegion Internal Safety Audit (Including Internal Technical Audit)

3 0 Non-compliance of audit recommendations as per target date

75 Mansarampura Behaviour Based Safety (BBS) Review

1 0 Steering Committee Review Meeting was not conducted as scheduled.

76 Mansarampura Safety Observations (Unsafe Acts/Conditions)

4 3 Less reporting of safety observations in SAP

77 Mansarampura

Near Miss Incidents:(Any incident having potential for minor/major loss of any kind)

6 4 Less reporting and non performing investigation of near misses

78 Mansarampura OISD/T4S Audit 6 0 Non-compliance of recommendations as per target date

79 Mumbai Safety Observations (Unsafe Acts/Conditions)

4 0 Less reporting of safety observations

80 Mumbai Operational & Safety Training

6 4 Training not conducted as per annual plan

81 Mumbai

Near Miss Incidents:(Any incident having potential for minor/major loss of any kind)

6 4 Non investigation of near misses

82 Mumbai External Safety Audit (Other than OISD/T4S Audit)

4 2.5 Non-compliance of recommendations beyond 2 years

Page 11: GAIL (India) Limited Score_April_18.pdfGAIL Vaghodia and Gandhar acknowledged with “Prasansha Patra Safety Award” from National Safety Council Mumbai. The award is given by Sh

83 Mumbai Internal Safety Audit (Including Internal Technical Audit)

3 0 Non-compliance of audit recommendations as per target date

84 NCR Safety Suggestion from Employees

1 0 Subject suggestion falls under category of safety observation

85 NCR Safety Observations (Unsafe Acts/Conditions)

4 0 Less reporting of safety observations

86 NCR

Near Miss Incidents:(Any incident having potential for minor/major loss of any kind)

6 2 Less reporting and non performing investigation of near misses

87 NCR OISD/T4S Audit 6 4 Non-compliance of recommendations beyond 2 years

88 Nasirabad Safety Suggestion from Employees

1 0 Non submission of safety suggestion

89 Nasirabad Behaviour Based Safety (BBS) Review

1 0 Steering Committee Review Meeting was not conducted as scheduled.

90 Nasirabad

Near Miss Incidents:(Any incident having potential for minor/major loss of any kind)

6 4 Non investigation of near misses

91 Nasirabad OISD/T4S Audit 6 4 Non-compliance of recommendations beyond 2 years

92 Nasirabad External Safety Audit (Other than OISD/T4S Audit)

4 3.5 Non-compliance of recommendation beyond 2 years

93 Pata Safety Observations (Unsafe Acts/Conditions)

4 3 Less reporting of safety observations in SAP

94 Pata External Safety Audit (Other than OISD/T4S Audit)

4 0 Non-compliance of recommendation as per initial target date

95 Puduchhery Safety Suggestion from Employees

1 0 Subject suggestion falls under category of safety observation/audit

96 Puduchhery Behaviour Based Safety (BBS) Review

1 0 Steering Committee Review Meeting was not conducted as scheduled.

97 Puduchhery Safety Observations (Unsafe Acts/Conditions)

4 0 Less reporting of safety observations

98 Puduchhery On Site Emergency Exercise (Quarterly)

3 1 Mock drill in odd hours has not been conducted during last year

99 Puduchhery Internal Safety Audit (Including Internal Technical Audit)

3 0 Non-compliance of audit recommendation as per target date

100 Rajahmundry Safety Observations (Unsafe Acts/Conditions)

4 2 Less reporting of safety observations in SAP

101 Rajahmundry

Near Miss Incidents:(Any incident having potential for minor/major loss of any kind)

6 1 Less reporting and non performing investigation of near misses

102 Samakhiali Safety Suggestion from Employees

1 0 Subject suggestion falls under category of safety observation

Page 12: GAIL (India) Limited Score_April_18.pdfGAIL Vaghodia and Gandhar acknowledged with “Prasansha Patra Safety Award” from National Safety Council Mumbai. The award is given by Sh

103 Samakhiali Behaviour Based Safety (BBS) Review

1 0 Steering Committee Review Meeting was not conducted as scheduled.

104 Samakhiali Safety Observations (Unsafe Acts/Conditions)

4 0 Less reporting of safety observations

105 Samakhiali

Near Miss Incidents:(Any incident having potential for minor/major loss of any kind)

6 0 Less reporting near misses

106 Samakhiali OISD/T4S Audit 6 5.5 Non-compliance of recommendation beyond 2 years

107 Usar Safety Suggestion from Employees

1 0 Subject suggestion falls under category of safety observation

108 Usar Safety Observations (Unsafe Acts/Conditions)

4 0 Less reporting of safety observations

109 Usar

Near Miss Incidents:(Any incident having potential for minor/major loss of any kind)

6 1 Less reporting and non performing investigation of near misses

110 Usar On Site Emergency Exercise (Quarterly)

3 1 Mock drill in odd hours has not been conducted during last year

111 Vadodara Safety Suggestion from Employees

1 0 Non submission of safety suggestion

112 Vadodara Safety Observations (Unsafe Acts/Conditions)

4 0 Less reporting of safety observations in SAP

113 Vadodara

Near Miss Incidents:(Any incident having potential for minor/major loss of any kind)

6 0 Less reporting near misses

114 Vadodara OISD/T4S Audit 6 4 Non-compliance of recommendations beyond 2 years

115 Vadodara External Safety Audit (Other than OISD/T4S Audit)

4 3 Non-compliance of recommendations beyond 2 years

116 Vadodara Internal Safety Audit (Including Internal Technical Audit)

3 2 Non-compliance of audit recommendations beyond one year

117 Vaghodia Safety Suggestion from Employees

1 0 Subject suggestion falls under category of safety observation

118 Vaghodia Safety Observations (Unsafe Acts/Conditions)

4 0 Less reporting of safety observations in SAP

119 Vaghodia

Near Miss Incidents:(Any incident having potential for minor/major loss of any kind)

6 1 Less reporting and non performing investigation of near misses

120 Vaghodia_CS Safety Suggestion from Employees

1 0 Subject suggestion falls under category of safety observation

121 Vaghodia_CS Safety Observations (Unsafe Acts/Conditions)

4 2 Less reporting of safety observations

122 Vaghodia_CS

Near Miss Incidents:(Any incident having potential for minor/major loss of any kind)

6 4 Non investigation of near misses

Page 13: GAIL (India) Limited Score_April_18.pdfGAIL Vaghodia and Gandhar acknowledged with “Prasansha Patra Safety Award” from National Safety Council Mumbai. The award is given by Sh

123 Vijaipur Safety Observations (Unsafe Acts/Conditions)

4 0 Less reporting of safety observations in SAP

124 Vijaipur

Near Miss Incidents:(Any incident having potential for minor/major loss of any kind)

6 4 Non investigation of near misses

125 Vijaipur OISD/T4S Audit 6 5.5 Non-compliance of recommendation beyond 2 years

126 Vijaipur Internal Safety Audit (Including Internal Technical Audit)

3 0 Non-compliance of audit recommendations as per target date

127 Vijaipur_CS Safety Observations (Unsafe Acts/Conditions)

4 0 Less reporting of safety observations in SAP

128 Vijaipur_CS

Near Miss Incidents:(Any incident having potential for minor/major loss of any kind)

6 4 Non investigation of near misses

129 Vijaipur_CS OISD/T4S Audit 6 5.5 Non-compliance of recommendations beyond 2 years

130 Vijaipur_CS Internal Safety Audit (Including Internal Technical Audit)

3 2 Non-compliance of audit recommendations beyond one year

131 Vizag Safety Observations (Unsafe Acts/Conditions)

4 2 Less reporting of safety observations

132 Vizag

Near Miss Incidents:(Any incident having potential for minor/major loss of any kind)

6 1 Less reporting and non performing investigation of near misses

133 Cherlapalli Safety Suggestion from Employees

1 0 Subject suggestion falls under category of safety observation

134 Cherlapalli Safety Observations (Unsafe Acts/Conditions)

4 0 Less reporting of safety observations in SAP

135 Cherlapalli Operational & Safety Training

6 4 Training not conducted as per training calender

136 Cherlapalli

Near Miss Incidents:(Any incident having potential for minor/major loss of any kind)

6 0 Less reporting and non performing investigation of near misses