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Factory inspections – IV

As an extension of the activities of the proposed Labour Institute at the provincial level, even regional labour institutes can be set up at Hyderabad, Hub, Faisalabad and at Hattar in Khyber Pakhtunkhwa. These institutes should be modelled on the pattern of the Central or provincial labour institutes though the facilities provided can be on a reduced scale and should comprise:-

1. Industrial Safety, Health and Welfare Centre;

2. Industrial Hygiene Laboratory;

3. Library cum Information Centre; and

4. Training Centre.

In the future, Five-Year plans of the country, it be proposed to set up four more institutes in the other industrial estates which would, more or less, take the form of Industrial Safety, Health and Welfare Centres with training facilities and could help to spread the activities of the Regional Labour Institutes further. When these institutes develop to the full extent, they will provide a specialised service for the worker in his working environment and will also help to create a favourable atmosphere for the acceptance of various measures aimed at ensuring the safety and health and promoting the welfare of the man at work since these are essential elements in the efforts directed towards increasing the effectiveness of labour and improving the productivity. The activities of the proposed labour institutes can supplement the pioneering work that may be done in the field of industrial health proposed by the Pakistan Institute of Public Health and Hygiene, the Industrial Hygiene Division of the Central Public Health Research Institute and various sections of the Central Mining Research Station, which may deal with the different aspects of safety, health and efficiency in mines. This is essential as coal mining in Thar, copper and gold mines and coal mines in Balochistan and salt and other mines in Punjab may assure, importance in future.

Now, coming to the questions of progress in present occupational health, the position its review indicates that until a few years back, there was very little information relating to occupation health problems covering any sizeable cross-section of the industry was available. Since the proposed Central Labour Institute can be closely associated with industry and the Factory Inspection Service, it will be possible to carry out industrial hygiene surveys, not as mere ad hoc projects, but on an industry-wise basis. While the present studies present a very sad picture of the high incidence of occupational disease in Pakistan they are equally a reflection on the standard of compliance of the statutory provisions relating to safety and health in the country. The difficulties in detecting and evaluating conditions leading to occupational ill-health and occupational diseases seem to have been no less complex than those confronting the detection of the diseases themselves. This only emphasises that factory inspection is a team-work and that in ensuring an environment in which an individual can work safely and efficiently, it has to draw upon the knowledge and experience of various disciplines.

Let me now turn to the perspective of occupational health. Any development has to be viewed in its perspective, not of mere shining idealism, but in the light which can reasonably be hoped to brighten from the glimmers of the present. Further, a perspective stretched from the position from which one looks ahead. Occupational health in Pakistan today is an unmapped territory for exploratory venture. As a result of observations, analysis and study hereinafter, we can obtain a wealth of information about manufacturing, processes and industrial hazards. With the development of instrumentation technology to which I have already referred, we can have the advantage of fine instruments and precise methods for the evaluation of industrial health problems. The establishment of standards for use throughout the world, such as threshold limit values for air-born concentration of substances and standard x-ray classification for silicosis can help to enlarge the sphere of operations of the technicians in the industrial health. We can establish institutions and agencies such as All Pakistan Institute of Hygiene and Public Health, the Provincial Public Health Research Institute, the Provincial Mining Research Station and the Labour Institutes, which should be equipped to carry out the studies on problems of industrial health. The national Laboratories of the Pakistan Council of Scientific and Industrial Research with their wide-range of industrial research facilities, if available, can be of great assistance in studying the problems of a more fundamental nature. It will thus be seen that we have today some basic facilities which can cover a wide-range of activity and what is now needed is a concerted plan of action which would help these organisations to come together in a common endeavour. The pooling of the resources, experience and expertise can make a significant contribution to the promotion of occupational health in each province of Pakistan.

The factory and mines legislation in our country should be amended from time to time to meet the needs felt in a developing economy. Presently, Factories Act 1934 is in force in Pakistan. India promulgated new law in 1948. There should be a statutory provision enabling the Inspection Services to carry out industrial hygiene surveys with the required co-operation of employers and employees. Again, it is also proposed to have Safety Officers wholly charged with the responsibility of ensuring safe working conditions. The WHO/ILO Regional Conference on Industrial and Occupational Health held in India in 1958 had recommended that every large industrial enterprise employing 1,000 or more workers should have a full-time industrial physician. Although, at the moment, the shortage of trained medical personnel is a limiting factor, a time may soon come when we can hope that the recommendations should be given effect to. In fostering occupational health, what is more essential than legislation is the lead that can be given by progressive employers and the pressure from workers through dedicated honest leaders. Equally important is developing public opinion, for, it is the public support and co-operation that sets the standard and pace of progress in any country. Pakistan is no exception.

What augurs well for the development of occupational health is the increasing awareness among employers that the promotion of industrial health, while being basically a humanitarian endeavour, has strong economic overtones. It is also to be appreciated that the promotion of industrial health serves to protect the ‘tremendous investment in people – especially in their skills, experience and know-know” – a protection of supreme importance in a developing economy like Pakistan where the hiatus between the requirements and availability of skill and experienced manpower is very wide and would remain so for quite some time since the development of technology is apt to outpace the development of skills. It is an encouraging trend that an increasing number of enterprises are coming forward with requests for assistance in conducting comprehensive industrial hygiene surveys, to enable them to make a scientific appraisal of working conditions and to take appropriate measures.

The Report of the Committee of Experts from the Dyes Panel of the Development Council for Organic Chemical Industries on the manufacture and use of Dye-Intermediates which are carcinogenic in India is another example of manufacturers’ growing interest in industrial health. The committee was set up on the recommendation of the council to suggest measures for protecting the health of the workers engaged in the manufacture and use of dye-intermediates which are carcinogenic, to draw up a safety code for use in such establishments and to examine to what extent the safety measures could be enforced in small-scale dye-stuff factories. The committee made a detailed survey of the industry obtaining the assistance made available by one of the industrial hygiene laboratories. The committee has made valuable suggestions applicable to the industry as a whole which will, perhaps, form the basis of special regulations covering the hazard. In the industrially advanced countries, it is precisely this trend which has helped to progressively reduce the time lag between the institution of measures for ensuring the health and safety of the workers and the development of new hazardous manufacturing processes. In organised industries, this awareness of the economic significance of industrial health can be translated into such changes in the workplace as are conducive to the wellbeing of the man at work because it is in a position to avail itself of the facilities offered by instruments, institutions and if need be expertise. The difficulty is in the field of small-scale industry where the limiting factor of finance is really serious. A small-scale industry is apt to consider the expenditure on industrial health a luxury it can ill-afford – a consideration often rooted in genuine economic difficulty. In the sphere of small-scale industry, a purposeful beginning can be made in the industrial estates because they do not suffer from the infirmities of their individual components. The fact that the concept of industrial estates has come to stay brightens the hopes for the development of occupational health in the field of small-scale industry.

It has earlier referred to the immense help we can derive from industrial hygiene techniques and instrumentation developed in other countries. It is accepted that the threshold limit values are to be considered as practical guides in the control of health hazards and should not be regarded as fine lines between safe and dangerous exposure levels. In spite of the use of threshold limit values for control of health hazards, the important factor of individual susceptibility makes continual medical supervision an essential element in the promotion of industrial health. It is therefore, evident that whatever might be the extent of assistance derived from established norms and standards, the medical profession has a purposeful role to play in occupational health. In this context the contribution which the industrial medical officers can make on the research as well as the clinical side is considerable.

In the Society for the Study of Industrial Medicine established again in India with the membership spread over the entire country and covering a very representative cross-section of industry, that country has an organisation which can undertake the study and solution of industrial health problems and the advancement of occupational health through research, surveys and allied activities. Perhaps Pakistan may follow suit. A significant advantage of an organisation of this representative character is that it has, as members, medical officers associated with a number of units of each type of industry. Such groups of industrial medical officers could, with society acting as a co-ordinating agency, embark as a team on a programme of research on any industry-wise basis. In such research work, they could, wherever necessary, obtain the assistance from the various Institution and Industrial Hygiene Laboratories set up throughout the Provinces. Studies by such a team could, because of their immediate association with the man at work and their working environment and the advantages of detailed follow-up, be more purposeful than any study or analysis that can be carried out by an outsider agency. When the problem of occupational health is viewed in perspective, the Society for the Study of Industrial medicine so established can act as a leaven in evolving a plan of action in which the efforts of different organisations are directed towards a common objective – the well being of the man at work.

The Factories Act presently in force in Pakistan lays down the basic minimum requirements for ensuring the safety, health and welfare of workers. The legislation should progressively elaborate and improve upon by incorporating the knowledge gained on environmental conditions and occupational diseases emanating from the researches carried out in the various parts of the world. Most countries have drawn upon the experience of the industrially advanced countries in framing their Factory Legislation. Thus, statutory provision exists in the Factory Laws of most countries to safeguard against known hazards and risks and for improving working conditions in general. Workers Employers Bilateral Council of Pakistan which representatives’ leadings Federations and Trade Unions in Pakistan and employers could will take the initiative in this behalf.

If we review the gradual development of the Factory Inspection Services in this country and the changes that has to be effected in the organisation to meet the ever-changing situation brought about by technological developments in industry, it will be apparent that in the industrially advanced countries, how to prevent the heavy toll of accidents in industry each year stands out as a problem of tremendous national importance, and this is so, in spite of the efforts to mitigate the hazards of factory system of manufacture on the part of the Factory Inspection Services and various other agencies over a period of more than a century, not so in this country. No sooner are control measures evolved to deal with accidents of a particular nature than others of a differing type have generally been found to occur, this can be due to the technological development leading to the introduction of newer types of machinery and the evolution of a newer processes to meet fresh needs bringing in their wake hazards which were practically known before. Measures for ensuring the safety and health of the workers disclose an every-recurrent series of problems to be met and it is doubtful if finality can ever be achieved in the matter. Thus, emphasis during the years immediately following the Industrial Revolution in the West, when steam engines were the source of power, was on the guarding of transmissions machinery and improvement of physical working conditions. The introduction of electricity as a source of power in industry brought new hazards in its train. With the rapid technological advances that have taken place in recent years, modern industry is ever growing in complexity. The introduction of gigantic machines working at enormous speeds and the evolution of newer processes of manufacture involving a huge array of new and hazardous chemicals, many of them of a complex nature, have tended to bring with them a stream of new and rapidly changing problem affecting the safety and health of the workers, each with a special risk and calling for detailed study and research in evolving remedial measures.

To meet this changing situation in industry in Pakistan, the complexion of he proposed Factory Inspection Services, has also to be modified from time to time. May so in the earlier years, the Factory Inspection Services will be more concerned with the guarding of machinery. Later, with the recognition resulting from analysis of accident records that the human factory entered in a majority of the accidents, the guarding of machinery and education in caution may become the two significant factors in accident prevention. With the increase in mechanisation and the development of new processes of manufacture, the proposed Factory Inspection Services may feel themselves unequal to the task before them and will have to be strengthened by the addition of specialists drawn from different profession and disciplines. This is recognition of the fact that factory inspection is team-work, and not a money minting venture. It will soon be realised that the inspection services, however, well-equipped and organised, alone could not effectively deal with all the problems that they will be confronted with and recourse necessarily to be taken to obtain the co-operation of scientists and technical experts as also the help and assistance of technical and scientific organisations, research institutions and various other agencies including trade unions and trade associations in evolving measures for mitigating the hazards met with in modern manufacturing industries. This will result in the drawing up of specific regulations or codes of safe practices covering a variety of industries and industrial processes and this will possibly lead to efforts on the part of industry to police itself in accident prevention work.

Reference may be made to a very comprehensive review of the industrial safety movement in the Encyclopaedia of Social Sciences, which states that from the point of view of content, the safety movement can be developed in five distinct stages:-

Firstly, experience in the West seemed to indicate that accidents were caused by inadequate safeguarding of machines and other physical conditions – emphasis should, therefore, be placed on provision of guards and improvement of working conditions. Important as these are, it will soon be perceived that accidents may not be reduced to the degree anticipated.

The second stage can be based on the recognition, resulting from analysis of record, that human factors of carelessness, ignorance, inexperience, inadequate skill and improper supervision entered into a majority of the accidents, further advances therefore depend on the education of supervisors and workers in the conditions and principles of self-preservation. This may lead to formation of “Safety Committees” in factories, meetings of workers to create safety consciousness, safety bulletins, prizes for good safety records and various other inducements towards adoption of habits of care. Perhaps in the proposed Factories Act in the provinces after the 18th Amendment, such provisions be incorporated. With the full development of the programme, there was marked reduction in the accident frequency and service rates. The guarding of machines and education in caution can become the two significant principles in advancing the safety movement.

The third stage will consist of the refinement through better organisation of the safety functions in labour-management departments, the extension, improvement and engineering analysis of statistical records, the increased regard for safety factor in process and job analysis; provision of better supervision, establishment of medical units, and the introduction of psychological studies.

The fourth stage may be characterised by a greater attention to the problems of safety and health on the part of major executives, elevation of the movement from second rank to first rank status and its inclusion among questions of general administrative policy – thereby bringing to an integrated whole the related problems of organisation and management methods; the guarding of machinery, the selection and assignment of personnel and their training; education in self-preservation; statistics and research, industrial medicine and psychology. The prevailing attitude towards industrial accidents progressed from the supposition that these were entirely a matter of individual responsibility and risk to recognition of the social and industrial advantages to be derived from accident prevention.

The fifth stage will be the preparation of safety codes to be incorporated in the new Factories Act in each province of the country. The appreciation of the fact that the safety codes should be created by the industries themselves may lead to definite effort on industry’s part to police itself in accident prevention work. This, in effect, will be a recognition of the fact that the health, safety and welfare of the workers employed is a primary function of management. The internal safety and health regulations can be worked out jointly by the Factory Safety and Health Services and the operatives. This will ensure almost general acceptance of the regulations being adopted and will be an additional factor in good human relations.

These changing concepts of modern management with regard to safety and health will lead to the setting up of various departments specifically charged with the responsibility for ensuring the safety and health of the workers, Personnel Department, Medical Department, Safety Department, Industrial Hygiene Department and Training Department. These various departments and services may not be found even in many of the large industrial establishments, but the functions which they exercise will inevitably present in every modern factory to a greater or lesser degree. The functions of these departments so far as safety and health is concerned, can be broadly divided into two categories for practical purposes: (1) control of specific hazards due to the use of certain substances or certain processes carried on in the factories; and (2) promoting the general health of the workers and protecting them from ailments that may be due to abnormal environmental conditions, such as defects in ventilation, excessive noise, heat and humidity, which affect all workers. The control of the specific hazards is the prime duty of the Inspector of Factories enforcing the legislation. Unfortunately, however, these inspectors have badly failed in their obligations so far. While items under the second category are, to a certain extent, controlled by legislation, they are largely influenced by the human factor and would come more within the purview of the services provided by the factory. The function of Factory Inspection should be to enforce the statutory provisions for ensuring the safety, health and welfare of employees. If this is effectively done in Pakistan, it will provide initially a satisfactory working environment. The Factory Inspection cannot, however, provide day-to-day inspection that is needed to see that the facilities provided are effectively made use of and the methods of working are not such as to render ineffective the protective and preventive measures taken, and here the organisation within the factory has the most significant part to play in providing the day-to-day supervision. Such day-to-day inspections will have to be jointly carried out by employers and collective bargaining agents. It is high time our labour leaders will have to come out of their hibernation, and full up their sleeves and do what is really expected of them to do.

(Concluded) (The writer is Advocate of Supreme Court of Pakistan)

Mahmood Abdul Ghani, "Factory inspections – IV," Business recorder. 2013-01-14.
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