MSIHC Rules, 1989: Practical Guide for Indian Factories

The Manufacture, Storage and Import of Hazardous Chemicals Rules, 1989: A Practical Guide for Indian Factories

The MSIHC Rules, 1989 apply to hazardous chemicals based on their properties, quantities and the type of industrial installation involved. This practical guide explains how Indian factory EHS professionals can check applicability, understand the schedules, calculate maximum chemical quantity and maintain safety reports, plant controls and emergency plans.

A factory stores solvent in a bulk tank, transfers it through pipelines and receives fresh material through road tankers.

But when someone asks the EHS officer, “Do the MSIHC Rules apply to this site?”, the answer is often based on monthly consumption or a few Safety Data Sheets.

That is the wrong starting point.

MSIHC applicability depends on:

• the actual chemical;
• its hazardous properties;
• its concentration;
• the type of installation;
• the maximum quantity that can be present.

The full name of the law is the Manufacture, Storage and Import of Hazardous Chemicals Rules, 1989, commonly called the MSIHC Rules.

These Rules focus mainly on preventing major chemical accidents and reducing their impact on workers, nearby people and the environment.

They do not apply in exactly the same way to every factory handling a dangerous chemical.

Some responsibilities are basic chemical-safety duties. Other requirements apply only when a specified chemical or quantity threshold is involved.

“Start with the chemical, its hazard and the maximum quantity that can be present.”

Chemical Accidents Rules, 1996: A Practical Guide for Indian EHS Officers with latest ammendments and checklist for EHS Professionals

MSIHC Quick Reference

Depending on applicability, the MSIHC Rules may require a factory to:

• identify major accident hazards;
• take steps to prevent accidents;
• control the consequences of an accident;
• maintain correct chemical information;
• label hazardous chemical containers;
• notify the applicable industrial activity or site;
• prepare a safety report;
• carry out a safety audit;
• prepare an On-site Emergency Plan;
• provide information for Off-site emergency planning;
• report a major accident;
• inform people who may be affected;
• comply with hazardous chemical import requirements.

The exact duties depend on the chemical, quantity, installation and applicable schedule.

This guide explains how an EHS officer can approach these requirements practically.

The MSIHC Rules were originally notified on 27 November 1989. The consolidated Rules include the corrigendum and amendments notified in 1990, 1994 and 2000. This article is based on the amended consolidated text available as of July 2026.

What Are the MSIHC Rules, 1989?

The Manufacture, Storage and Import of Hazardous Chemicals Rules, 1989 are Indian environmental rules for preventing major chemical accidents. They require applicable occupiers to identify chemical hazards, control accident risks, provide chemical safety information and, where specified thresholds are crossed, complete requirements such as site notification, safety reports, safety audits and On-site Emergency Plans.

What Does MSIHC Mean?

MSIHC stands for Manufacture, Storage and Import of Hazardous Chemicals.

The MSIHC Rules, 1989 apply to specified hazardous chemicals, industrial activities, isolated storage and pipelines based on the applicable chemical properties and threshold quantities.

1. What Is a Hazardous Chemical Under the MSIHC Rules?

A chemical should not be assessed only by its trade name.

The purchase department may use a commercial name. Stores may use the supplier’s product name. Operators may use a local name.

But an MSIHC assessment normally requires the actual chemical identity.

The EHS officer should collect:

A chemical may come within the MSIHC Rules because:

1. It meets the hazardous-property criteria given in Schedule 1.
2. It is specifically listed in the schedules.

The relevant hazardous properties can include:

• toxicity;
• flammability;
• high flammability;
• extreme flammability;
• explosiveness.

The assessment should consider the actual chemical grade and concentration used at the factory.

An SDS for a similar product is not enough.

Hazardous Chemical and Hazardous Waste Are Not the Same

A hazardous chemical and hazardous waste may involve the same substance at different stages, but they are separate compliance subjects.

For example:

• fresh solvent received as raw material may be a hazardous chemical;
• spent solvent generated after use may become hazardous waste;
• unused acid in a storage tank is a chemical inventory;
• contaminated acid sludge may be hazardous waste.

The factory may therefore need to manage:

• the fresh or in-process chemical under chemical-safety requirements; and
• the waste generated from it under hazardous-waste requirements.

Do not enter every hazardous chemical in the hazardous-waste register.

Similarly, do not assume that a hazardous-waste authorization covers the risks from raw materials, fuels, toxic gases or process chemicals.

Maintain separate but connected records for:

• hazardous chemicals;
• hazardous waste;
• emergency planning;
• chemical storage;
• chemical movement;
• disposal or recovery of waste.
• Read more about Hazardous waste management rules

2. How to Read the MSIHC Schedules

The schedules are where many EHS officers get stuck.

A copy of the Rules may be available, but the reader may not know which schedule answers which question.

The schedules serve different purposes. One schedule alone may not decide complete applicability.

Schedule 1: Hazard Criteria and Listed Chemicals

Start with Schedule 1 to understand whether a substance falls within the hazardous chemical definition.

Schedule 1 covers:

• hazardous-property criteria; and
• specifically listed hazardous chemicals.

The assessment may require information such as:

• toxicity;
• flash point;
• boiling point;
• explosive characteristics;
• physical state;
• chemical concentration.

The SDS is an important source of information, but it should match the exact chemical and concentration used at the site.

Schedule 2: Isolated Storage Thresholds

Schedule 2 provides threshold quantities for isolated storage.

Isolated storage is not decided only by physical distance. It is also not decided only by whether a tank directly feeds a process.

Under MSIHC, isolated storage broadly means covered hazardous chemical storage that is not associated with a Schedule 4 installation on the same site and involves the applicable Schedule 2 quantity.

For example:

• a standalone bulk chemical storage facility may need to be checked under Schedule 2;
• storage forming part of a listed manufacturing or processing installation may need to be assessed through Schedules 3 and 4.

Where the classification is unclear, document:

• the site arrangement;
• storage purpose;
• process connection;
• chemical quantity;
• installation type;
• technical basis used for the decision.

Obtain a competent applicability review where required.

Do not describe a storage tank as isolated merely because it is located away from the production building.

Schedule 3: Thresholds for Industrial Activity

Schedule 3 is important for factories carrying out industrial activities involving specified hazardous chemicals.

It contains chemical names and threshold quantities connected with different requirements under the Rules.

Do not check only whether the chemical appears in Schedule 3.

Also verify:

• the correct chemical entry;
• the concentration, where relevant;
• the applicable threshold column;
• the maximum quantity that can be present;
• the requirements linked to that threshold.

A factory may cross one threshold without crossing another.

This is why site notification, safety reporting and emergency-planning duties should not be assumed to apply at the same quantity in every case.

Schedule 4: Specified Industrial Installations

Schedule 4 lists types of industrial installations covered for the purpose of the relevant MSIHC provisions.

These may include specified manufacturing, processing, production or storage installations.

The EHS officer should assess both:

• the hazardous chemical and its quantity; and
• the type of activity or installation where it is present.

Schedule 5: Authorities and Their Duties

There is no single authority responsible for every MSIHC requirement.

Schedule 5 identifies concerned authorities and assigns duties to them.

Depending on the activity and requirement, the authority may be connected with:

• factories;
• pollution control;
• district administration;
• ports;
• explosives;
• other specified government functions.

Before submitting any MSIHC document, verify:

• the applicable authority;
• the correct office;
• current state-level practice;
• online or physical submission requirements;
• required annexures;
• acknowledgement arrangements.

Do not rely only on what another factory submitted.

Two sites may handle different chemicals, quantities or installations. Their authority mapping may not be identical.

Schedules 6 to 12: Information and Plan Requirements

The later schedules provide information formats or required details for important MSIHC submissions.

These schedules should not be treated only as forms to fill.

The information should match:

• actual chemical stock;
• actual plant layout;
• current process conditions;
• available emergency equipment;
• present contact details;
• current organisational responsibilities.

3. Use a Practical MSIHC Applicability Flow

The following decision flow can help an EHS officer approach applicability systematically.

Step 1: Identify the Actual Chemical

Collect:

• chemical name;
• CAS number;
• composition;
• concentration;
• physical state;
• hazard information.

Do not complete the assessment using only the trade name.

Step 2: Check Whether the Chemical Is Covered

Review Schedule 1 and the relevant SDS information.

For mixtures, check:

• the hazardous constituent;
• its concentration;
• the properties of the mixture;
• the applicable schedule wording.

Step 3: Calculate the Maximum Quantity

Identify the highest quantity that can be present at one time.

This may include storage, process and connected quantities.

Step 4: Identify the Installation Type

Determine whether the chemical is associated with:

• an industrial activity;
• isolated storage;
• a process plant;
• a warehouse;
• a pipeline;
• a tank farm;
• another covered installation.

Step 5: Check the Applicable Threshold

Review the correct Schedule 2 or Schedule 3 entry.

Use the correct threshold column.

Step 6: Identify the Triggered Duties

Depending on applicability, the factory may need to address:

• basic major accident prevention;
• site notification;
• safety reporting;
• safety audits;
• On-site Emergency Planning;
• Off-site planning information;
• major accident reporting;
• information to people who may be affected;
• import-related requirements.

Step 7: Identify the Concerned Authority

Use Schedule 5 and confirm the current local process.

Maintain evidence of:

• applicability review;
• management approval;
• submission;
• acknowledgement;
• queries;
• replies;
• document revision.

4. Prepare a Chemical Applicability Register

A general chemical inventory tells the factory what chemicals are present.

An MSIHC applicability register should go further.

It should connect each chemical with:

• its hazard;
• its quantity;
• the relevant schedule;
• the applicable threshold;
• the duties triggered;
• the concerned authority.

A practical register can include:

Illustrative Applicability Exercise

Suppose a factory uses one hazardous liquid.

The purchase department reports monthly consumption of 15 tonnes.

But the site also has:

• a main storage tank;
• a day tank;
• drums in the warehouse;
• chemical inside process equipment;
• quantity in connected transfer lines.

Monthly consumption does not answer the applicability question.

The EHS officer should:

1. Identify the chemical correctly.
2. Confirm its concentration.
3. Check the relevant schedule entry.
4. Calculate the maximum quantity that can be present.
5. Compare that quantity with the correct threshold.
6. Identify the duties triggered.
7. Record the decision and technical basis.
8. Review it again after any change.

The purpose is not to add every small pipe volume without judgement.

The purpose is to avoid considering only one convenient number while ignoring significant storage or process quantities.

5. Calculate Maximum Quantity Correctly

Purchase quantity, monthly consumption and maximum inventory are different numbers.

A factory may consume a large quantity every month but keep only a small stock at one time.

Another factory may use very little each month but store a large quantity in a bulk tank.

The assessment may need to consider:

Bulk and Warehouse Storage

• main storage tanks;
• day tanks;
• drums;
• cylinders;
• bags;
• containers;
• standby stock;
• temporary storage;
• stock in separate departments.

Process Quantity

• reactors;
• mixing vessels;
• process tanks;
• receivers;
• columns;
• connected equipment;
• chemical held during shutdown;
• campaign-production stock.

Transfer Quantity

• connected pipelines;
• transfer vessels;
• unloading lines;
• tanker contents during transfer;
• intermediate tanks.

“Consumption shows how much was used. Applicability may depend on how much can be present.”

Design Capacity and Operating Quantity

A tank may have a design capacity of 50 kilolitres but normally operate below that level.

Do not select one figure without recording the basis.

Check:

• design capacity;
• safe filling limit;
• maximum permitted operating level;
• actual operating practice;
• level indicator;
• high-level alarm;
• overflow protection;
• purchase controls;
• unloading controls.

Where applicability depends on maintaining stock below a certain quantity, that limit must be controlled in practice.

A note in an Excel file is not enough.

The factory may need:

• a written operating limit;
• tank-level markings;
• alarm settings;
• stock controls;
• purchase restrictions;
• unloading permission;
• supervisor verification;
• periodic review.

Do Not Separate or Combine Quantities Casually

Do not automatically treat every container as an independent installation.

At the same time, do not combine completely unrelated installations without understanding the Rule.

Consider:

• physical separation;
• process connection;
• common containment;
• common unloading system;
• connected pipelines;
• common accident scenario;
• possible interaction during fire or leakage;
• installation definition;
• schedule wording.

Where the conclusion is not clear, document the basis and obtain competent technical review.

6. Convert the Rule Into Visible Plant Controls

MSIHC compliance does not begin with preparing an emergency-plan file.

It begins with preventing the chemical from escaping, reacting, catching fire or exposing people.

The occupier is expected to identify major accident hazards and take steps to:

• prevent accidents;
• limit their consequences;
• provide relevant information;
• maintain proper safety arrangements;
• prepare workers for emergencies.

These responsibilities should be visible on the factory floor.

Chemical Identification and Labelling

Tanks, containers and important pipelines should be clearly identified.

Check:

• chemical name;
• tank or vessel number;
• capacity;
• hazard warning;
• direction of flow;
• emergency information;
• condition of the label.

Temporary and decanted containers also need identification.

Do not allow an unknown chemical to remain in an unlabelled:

• bucket;
• bottle;
• drum;
• sample container;
• transfer vessel.

Labels should remain readable despite:

• sunlight;
• rain;
• chemical splash;
• dust;
• routine cleaning;
• physical wear.

A label that cannot be read from a safe position is of little value during an emergency.

Safety Data Sheets

The SDS should:

• match the exact chemical;
• match the concentration or grade;
• be current;
• be accessible;
• be understandable;
• support training and emergency response.

Keeping one large SDS file in the EHS office is not enough.

Relevant information should be available near use and storage areas.

Operators should understand:

• the main hazard;
• required personal protection;
• first response to exposure;
• incompatible materials;
• fire risk;
• basic spill response;
• when not to approach;
• whom to inform.

The SDS supports training. It does not replace training.

Chemical Accident Emergency Response Guide for Indian Factories by EHSShala

Safe Storage and Compatibility

Review whether the storage arrangement is suitable for the chemical.

Check:

• tank and container material;
• chemical compatibility;
• ventilation;
• temperature control;
• ignition control;
• access control;
• secondary containment;
• drainage isolation;
• leak detection;
• fire protection;
• emergency access;
• inspection and maintenance.

Incompatible chemicals should not share the same storage or containment arrangement without proper assessment.

A common dyke can create a bigger incident if leaked chemicals react with each other.

Secondary Containment

Dyke walls and containment areas should remain available for their intended purpose.

Common gaps include:

• cracks;
• open drain valves;
• rainwater accumulation;
• stored scrap;
• blocked access;
• pipe openings through walls;
• damaged flooring;
• reduced free capacity;
• vegetation growth.

A dyke filled with rainwater has reduced containment capacity.

A drain valve kept permanently open defeats the purpose of the dyke.

Rainwater removal should follow a controlled procedure.

Before releasing water, check whether it is:

• visibly contaminated;
• oily;
• discoloured;
• odorous;
• chemically affected.

Tanks, Vessels and Pipelines

Inspection should not focus only on the main tank shell.

Review:

• corrosion;
• leakage;
• foundations;
• supports;
• flanges;
• valves;
• vents;
• gauges;
• alarms;
• interlocks;
• pressure-relief systems;
• pumps;
• flexible connections;
• earthing;
• insulation;
• pipeline identification.

Leaks commonly begin at smaller points such as:

• pump seals;
• sample points;
• drain valves;
• flexible hoses;
• level-gauge connections;
• transfer couplings;
• corroded flanges.

Emergency Isolation

Operators should know how to stop or isolate the chemical safely.

Emergency isolation may include:

• remote shut-off valves;
• emergency-stop buttons;
• pump trips;
• power isolation;
• process shutdown;
• automatic interlocks;
• manual isolation points.

These controls should be:

• accessible;
• clearly marked;
• periodically tested;
• included in drills;
• understood by shift operators.

Do not design emergency isolation around the assumption that one experienced person will always be available.

Tanker Unloading

Chemical unloading temporarily connects the tanker, hose, pump, pipeline and factory storage system.

This creates an additional period of risk.

The unloading process should be controlled in three stages.

Before Connection

Verify:

• tanker identity;
• chemical name;
• delivery documents;
• available storage capacity;
• correct unloading point;
• hose compatibility;
• hose and coupling condition;
• valve alignment;
• tanker positioning;
• wheel chocks;
• ignition controls;
• earthing or bonding, where relevant;
• communication between driver and operator.

Unloading should not begin until the receiving tank has enough capacity.

Do not depend only on the transporter’s statement.

The factory operator should verify the tank level.

During Transfer

Maintain:

• continuous supervision;
• tank-level monitoring;
• communication with the driver;
• control over vehicle movement;
• access to emergency isolation;
• observation for leakage;
• pressure monitoring, where relevant;
• overflow prevention;
• drain protection;
• readiness of spill-control equipment.

The driver and operator should not leave the unloading point unattended.

After Unloading

Complete:

• pump stopping;
• valve isolation;
• safe depressurisation or draining, where required;
• careful hose disconnection;
• closure of caps and connections;
• leak inspection;
• area cleaning;
• quantity recording;
• abnormality reporting.

The emergency plan should consider credible unloading scenarios such as:

• hose rupture;
• wrong connection;
• overfilling;
• flange leakage;
• tanker movement while connected;
• fire near the unloading point;
• toxic release;
• chemical entering a drain.

Contractor Integration

Contract workers may be present near hazardous chemical areas.

This includes:

• tanker drivers;
• unloading helpers;
• maintenance workers;
• security guards;
• housekeeping staff;
• warehouse workers;
• transporters;
• civil contractors.

They should know:

• how to raise the alarm;
• whom to contact;
• what not to touch;
• where not to enter;
• the safe escape route;
• the assembly point;
• the meaning of the emergency alarm;
• the limit of their emergency role.

A contractor may be the first person to notice a leak.

Excluding contractors from chemical emergency awareness creates a practical gap.

7. Use Management of Change Before Changing the Plant

Many MSIHC gaps begin with a change that never reaches the EHS department.

Production may introduce a new solvent.

Projects may increase tank capacity.

Purchase may buy a higher-concentration chemical.

Maintenance may shift a pipeline.

Stores may increase maximum inventory.

Each change may appear small to one department. But it can change:

• MSIHC applicability;
• threshold calculations;
• accident scenarios;
• emergency arrangements;
• authority submissions.

This is why the factory needs a Management of Change process.

Management of Change means checking safety and compliance before changing a chemical, process, tank, pipeline, quantity or plant layout.

An MSIHC review should be triggered before:

Chemical Changes

• introducing a new chemical;
• changing chemical grade;
• changing concentration;
• changing supplier where composition may differ;
• replacing one solvent with another;
• using a new additive or catalyst.

Quantity and Storage Changes

• increasing tank capacity;
• increasing stock limits;
• adding a day tank;
• adding cylinders;
• converting drums to bulk storage;
• increasing warehouse inventory;
• shifting a chemical storage area.

Process and Equipment Changes

• changing temperature or pressure;
• modifying a process;
• adding a reactor;
• changing transfer pumps;
• modifying pipelines;
• changing an unloading point;
• changing containment;
• removing an alarm or interlock.

Layout and Emergency Changes

• changing plant layout;
• blocking or shifting emergency access;
• changing assembly points;
• modifying drainage;
• shifting the emergency control centre;
• discontinuing emergency equipment.

The change review should check whether there is a need to update:

• the applicability register;
• threshold calculation;
• site notification;
• safety report;
• risk assessment;
• On-site Emergency Plan;
• operating procedure;
• SDS;
• labels;
• training;
• inspection schedule;
• emergency equipment;
• authority communication.

A Simple Change-Control Workflow

1. The department proposing the change raises a request.
2. EHS checks chemical and major-accident implications.
3. Engineering reviews equipment and safety controls.
4. Applicability and quantity calculations are updated.
5. Required approval or notification is identified.
6. Documents and emergency arrangements are revised.
7. Employees and contractors are trained.
8. The change is physically verified before start-up.
9. Start-up permission is recorded.
10. Performance is reviewed after implementation.

This need not become a complicated corporate procedure.

A controlled one-page change form is better than an undocumented modification.

8. Understand Site Notification, Safety Reports and Safety Audits

Site notification, safety reports and safety audits are connected requirements.

But they are not the same.

Their applicability should be checked against the relevant rules and threshold quantities.

Site Notification

Site notification provides the concerned authority with information about the applicable industrial activity.

The information may include:

• occupier details;
• site address;
• industrial activity;
• hazardous chemicals;
• maximum quantities;
• process information;
• storage details;
• site surroundings;
• major accident potential;
• safety arrangements;
• worker strength;
• plant layout.

The notification should reflect the current plant.

Common gaps include:

• outdated occupier details;
• old tank capacities;
• discontinued chemicals;
• missing new chemicals;
• changed processes;
• outdated layouts;
• increased storage quantities;
• old emergency contacts.

Maintain:

• signed submission;
• covering letter;
• annexures;
• drawings;
• proof of delivery;
• online acknowledgement;
• authority queries;
• factory replies;
• revised submissions.

Safety Report

A safety report is more than a general risk-assessment document.

It should explain:

• the installation;
• hazardous chemicals;
• possible major accident scenarios;
• preventive controls;
• consequence-control arrangements;
• emergency preparedness.

It may include information on:

• site details;
• surrounding area;
• industrial activity;
• construction and design;
• separation distances;
• process description;
• chemical properties;
• storage conditions;
• process conditions;
• abnormal situations;
• possible releases;
• fire, explosion or toxic effects;
• control systems;
• emergency arrangements;
• organisational responsibilities.

A consultant may help prepare specialised studies.

But the factory remains responsible for confirming that the report matches the actual site.

Before accepting the report, verify:

• chemical inventory;
• tank capacities;
• process conditions;
• drawings;
• accident scenarios;
• control systems;
• emergency equipment;
• nearby sensitive areas;
• contact details;
• recommendations.

Do not keep a safety report that describes an older version of the plant.

Safety Audit

A safety audit checks whether the chemical-safety arrangements are adequate and working.

The audit should examine both:

• documents; and
• physical plant conditions.

After the audit, maintain an action tracker.

“An audit action closes only when the plant condition has changed and the change has been verified.”

A written reply is not closure.

A purchase order is not closure.

Material arriving at the factory gate is not closure.

The final plant condition should be checked.

9. Prepare an On-site Emergency Plan That Works

An On-site Emergency Plan explains how the factory will respond to a major emergency beginning within the site.

It should not be copied from another factory.

The plan should be based on:

• actual chemicals;
• actual quantities;
• current processes;
• actual storage locations;
• credible accident scenarios;
• available people;
• available equipment;
• surrounding conditions.

Identify Credible Emergency Scenarios

Group scenarios according to the site’s real risks.

Loss of Containment

• tank leakage;
• pipeline rupture;
• hose failure;
• valve leakage;
• cylinder leakage;
• tank overfilling;
• chemical entering a drain.

Fire and Explosion

• tank fire;
• pool fire;
• vapour fire;
• explosion;
• fire affecting chemical storage;
• ignition during transfer.

Toxic and Reactive Events

• toxic gas release;
• runaway reaction;
• incompatible chemical mixing;
• uncontrolled pressure rise;
• cooling failure;
• loss of utility.

Transfer and Maintenance Events

• tanker unloading failure;
• wrong chemical connection;
• leakage during maintenance;
• release during line opening;
• failure during sampling.

For each selected scenario, define:

• how it may begin;
• how it may be detected;
• who raises the alarm;
• immediate safe actions;
• isolation method;
• likely affected area;
• protective equipment;
• evacuation requirement;
• external support;
• environmental-control action.

Do not add every possible event only to make the plan look comprehensive.

Focus on scenarios that can reasonably occur at the site.

Define Emergency Roles

The plan should identify key personnel and responsibilities.

Typical roles may include:

• Site Main Controller;
• Incident Controller;
• emergency control centre team;
• firefighting team;
• rescue team;
• first-aid team;
• communication coordinator;
• security team;
• utility isolation team;
• environmental-control team;
• head-count coordinators.

Each person should know:

• when the role becomes active;
• where to report;
• whom to contact;
• what authority they have;
• what actions they must not take;
• who acts as backup.

Do not assign all important roles only to day-shift managers.

Every critical role should have shift-wise backup.

Alarm and Communication

The emergency alarm should be:

• audible in relevant areas;
• different from routine alarms;
• explained to employees and contractors;
• tested periodically;
• supported by backup communication.

The plan should cover:

• internal emergency number;
• alarm activation;
• public-address system;
• radios or phones;
• communication with security;
• communication with management;
• contact with outside agencies;
• communication during power failure.

The person calling an outside agency should be able to state:

• factory name;
• location;
• chemical involved;
• type of incident;
• current condition;
• possible outside impact;
• wind direction, where relevant;
• help required;
• safe approach route;
• gate contact.

Emergency Control Centre

The emergency control centre should remain usable during an emergency.

It should contain or provide access to:

• plant layout;
• chemical-storage map;
• drainage layout;
• emergency contacts;
• SDS;
• emergency plan;
• wind-direction information;
• utility-isolation details;
• firefighting layout;
• nearby hospital details;
• communication equipment;
• employee and contractor information.

Do not locate the only emergency control point inside the most likely affected area.

Identify an alternate control location where needed.

Evacuation and Assembly

The plan should define:

• who orders evacuation;
• primary evacuation routes;
• alternate routes;
• assembly points;
• head-count method;
• visitor accounting;
• contractor accounting;
• missing-person reporting;
• re-entry permission.

Assembly points should not be selected only because open land is available.

Consider:

• chemical location;
• wind direction;
• fire and explosion risk;
• smoke movement;
• tanker routes;
• emergency vehicle access.

Environmental Control During Emergencies

Chemical emergency planning should also cover pollution control.

Possible actions include:

• closing stormwater drains;
• isolating contaminated runoff;
• using emergency holding tanks;
• protecting soil;
• collecting contaminated firefighting water;
• preventing unauthorized discharge;
• arranging safe recovery;
• monitoring air or water;
• recording the quantity released.

Do not direct every spill into the ETP.

The ETP may not be designed to receive:

• concentrated acids or alkalis;
• toxic chemicals;
• solvents;
• flammable liquids;
• large firefighting-water loads;
• incompatible chemicals.

The impact on the ETP should be assessed before diversion.

Read more about Environmental Laws applicable to Indian factories in India

First Aid and Medical Support

The plan should identify:

• trained first aiders;
• emergency showers;
• eyewash stations;
• ambulance arrangements;
• nearby hospitals;
• treatment information;
• decontamination arrangements;
• emergency transport routes;
• antidotes, where technically required.

Do not assume that every nearby hospital can manage chemical exposure.

Where practical, share relevant chemical information with the selected medical facility.

On-site and Off-site Emergency Plans

The factory does not independently prepare the complete district Off-site Emergency Plan.

However, the occupier should provide accurate information and cooperate with the concerned authorities.

The information may include:

• hazardous chemicals;
• maximum quantities;
• accident scenarios;
• possible affected areas;
• warning arrangements;
• firefighting resources;
• medical resources;
• emergency contacts;
• safe approach routes;
• mutual-aid support.

Conduct Realistic Mock Drills

A mock drill should test whether the plan works.

It should not be conducted only to produce:

• attendance sheets;
• photographs;
• a completed checklist.

A useful drill should examine:

• detection time;
• alarm time;
• role activation;
• isolation;
• communication;
• firefighting preparation;
• spill control;
• first aid;
• evacuation;
• head count;
• contractor response;
• external communication;
• equipment availability.

Test different operating conditions:

• night shift;
• weekend;
• minimum manpower;
• heavy rain;
• blocked route;
• failed communication;
• unavailable key person;
• contractor-heavy shift.

After the drill, record:

• what worked;
• what failed;
• delays;
• unsafe behaviour;
• missing equipment;
• communication gaps;
• required action;
• responsible person;
• target date;
• closure evidence.

10. Major Accident Reporting and Emergency Records

A major accident should be communicated and reported through the applicable process.

The factory should not wait for every fact to become clear before beginning internal escalation.

At the same time, information shared outside the site should be factual.

Avoid:

• guessing the quantity released;
• giving unsupported causes;
• blaming individuals;
• hiding known information;
• changing the incident timeline;
• giving different figures to different authorities.

Preserve relevant records such as:

Process and Control Records

• control-room logs;
• alarm records;
• process data;
• tank-level records;
• interlock history;
• shutdown records.

Visual and Physical Evidence

• CCTV footage;
• photographs;
• damaged parts;
• samples;
• equipment condition;
• weather and wind information.

People and Work Records

• shift records;
• permit-to-work documents;
• maintenance history;
• training records;
• operator statements;
• contractor details.

Response and Impact Records

• emergency actions;
• communication records;
• quantity estimates;
• monitoring results;
• medical information;
• waste generated during cleanup;
• contaminated water handling;
• environmental observations.

Initial Communication and Detailed Investigation

The first communication may provide:

• what happened;
• where it happened;
• chemical involved;
• current status;
• injuries, if known;
• possible outside impact;
• actions taken;
• support required.

The detailed investigation can later establish:

• immediate cause;
• root cause;
• equipment failure;
• human factors;
• management-system gaps;
• control failure;
• quantity released;
• environmental impact;
• corrective actions;
• preventive actions.

Do not delay immediate communication only because root-cause analysis is incomplete.

Information for People Who May Be Affected

Where applicable, relevant safety information should be available to people who may be affected by a major accident.

It should explain:

• the nature of the hazard;
• how warning may be given;
• basic protective action;
• what people should not do;
• where instructions will come from;
• whom to contact.

Use simple language.

Emergency communication should reduce confusion, not create panic.

11. Import of Hazardous Chemicals

Factories directly importing hazardous chemicals should review the import provisions of MSIHC.

The importer may need to provide prescribed information relating to:

• importer details;
• chemical identity;
• quantity;
• port of entry;
• transport arrangements;
• storage arrangements;
• safety information;
• handling precautions;
• destination;
• intended use.

A factory importing through a trader should still ensure that it receives correct chemical information.

Maintain:

• current SDS;
• chemical composition or specification;
• import documents;
• shipping details;
• container identification;
• emergency information;
• transporter details;
• quantity received;
• storage location;
• supplier communication.

The EHS department should be informed before a new imported chemical is ordered.

Do not allow the first safety and applicability review to happen after the material reaches the factory gate.

12. Common Factory Gaps and What They Reveal

The following patterns are commonly seen during chemical-safety reviews, audits and emergency-plan checks.

What May Be Checked During an Inspection or Audit?

Different officers and auditors may focus on different areas.

Common verification points can include:

Applicability and Records

• chemical inventory;
• schedule mapping;
• threshold calculations;
• site notification;
• safety report;
• safety audit;
• action closure;
• Management of Change records.

Plant Conditions

• actual stock;
• tank capacities;
• labels;
• pipelines;
• storage compatibility;
• secondary containment;
• alarms;
• interlocks;
• leak-control systems;
• unloading arrangements.

Emergency Preparedness

• On-site Emergency Plan;
• emergency roles;
• mock-drill records;
• operator knowledge;
• contractor awareness;
• emergency equipment;
• external contacts;
• accident-reporting process.

The most common weakness is not always one missing document.

It is a mismatch between:

• the document;
• the actual plant condition;
• the chemical quantity;
• the operator’s explanation.

13. A Practical Monthly MSIHC Review

MSIHC compliance should not be reviewed only before an inspection or annual audit.

A short monthly review can detect changes early.

Chemical Review

Check:

• newly introduced chemicals;
• discontinued chemicals;
• supplier or grade changes;
• changed concentration;
• maximum stock;
• tank and warehouse quantities;
• SDS updates;
• labels;
• pipeline identification;
• chemical compatibility.

Storage and Equipment Review

Inspect:

• tanks;
• drums;
• cylinders;
• valves;
• flanges;
• hoses;
• pumps;
• dyke walls;
• drain valves;
• ventilation;
• fire protection;
• leak-control systems;
• emergency access.

Emergency Review

Verify:

• emergency contact numbers;
• shift-wise role availability;
• alarm condition;
• emergency control centre;
• firefighting equipment;
• spill-control material;
• breathing equipment, where provided;
• eyewash stations;
• emergency showers;
• first-aid arrangements;
• assembly points;
• wind-direction indicators;
• contractor awareness.

Action Review

Review:

• safety-audit observations;
• mock-drill actions;
• incident actions;
• near-miss actions;
• equipment-inspection findings;
• overdue maintenance;
• Management of Change requests;
• safety-report recommendations;
• authority queries.

Document Review

Confirm that the following remain current:

• chemical applicability register;
• threshold calculation;
• SDS;
• site notification;
• safety report;
• safety-audit report;
• On-site Emergency Plan;
• training records;
• drill records;
• accident-reporting procedure;
• import records, where applicable.

14. Final MSIHC Checklist for Factories

15. MSIHC and Other Safety Requirements

MSIHC is made under the Environment (Protection) Act.

Factories may also have separate duties under:

• occupational safety requirements;
• factory safety requirements;
• fire requirements;
• petroleum requirements;
• gas-cylinder requirements;
• explosives requirements;
• chemical transport requirements;
• pollution-control requirements.

The same chemical tank or activity may be covered by different requirements for different reasons.

For example:

• MSIHC may focus on major accident hazards and emergency planning.
• Occupational or factory safety requirements may focus on worker protection.
• Fire requirements may focus on fire prevention and emergency access.
• Petroleum or gas-cylinder requirements may apply to specified products.
• Pollution-control requirements may address emissions, effluent and accidental releases.

Compliance with one requirement does not automatically replace the others.

The EHS officer should maintain one coordinated chemical-safety system.

Documents prepared under different requirements should not contradict each other.

The same chemical quantity, tank capacity, layout and emergency contact should remain consistent across:

• consent records;
• factory records;
• fire documents;
• safety reports;
• emergency plans;
• chemical registers;
• authority submissions.

Final Takeaway

MSIHC compliance becomes manageable when the factory follows a clear sequence:

1. Identify the chemical correctly.
2. Understand its hazardous properties.
3. Calculate the maximum quantity properly.
4. Check the correct schedule and threshold.
5. Identify the duties and concerned authority.
6. Maintain practical plant controls.
7. Review every chemical and process change.
8. Prepare emergency plans around real scenarios.
9. Train employees and contractors.
10. Test the system under realistic conditions.
11. Close findings through physical correction.

Do not begin with the safety-report file.

Do not begin with the mock-drill photographs.

Do not begin only by asking, “Which form do we have to submit?”

Begin with what is actually present inside the factory.

“Chemical safety does not begin with the emergency plan. It begins when the factory correctly identifies what is stored, how much is present and what can go wrong.”

Good chemical compliance does not require panic.

It requires correct information, practical controls and regular review.

MOEF MSIHC Rules

FAQ Section

1. What is the full form of MSIHC?

MSIHC means Manufacture, Storage and Import of Hazardous Chemicals. The MSIHC Rules were notified in 1989 under the Environment (Protection) Act.

2. Do the MSIHC Rules apply to every factory using chemicals?

Not automatically. Applicability depends on the chemical’s hazardous properties, whether it is listed in the schedules, the maximum quantity present and the type of industrial installation or storage arrangement.

3. Is monthly chemical consumption used for MSIHC applicability?

Monthly consumption alone may not be enough. The factory should check the maximum quantity that can be present in tanks, warehouses, process equipment, day tanks and other relevant locations.

4. What is a hazardous chemical under the MSIHC Rules?

A hazardous chemical can be a chemical meeting the hazard criteria in Schedule 1 or a chemical listed in Schedule 1, Schedule 2 or Schedule 3.

5. What is the difference between Schedule 2 and Schedule 3?

Schedule 2 contains threshold quantities relating to isolated storage. Schedule 3 contains threshold quantities relating to specified industrial activities and different duties under the Rules.

6. What is isolated storage under MSIHC?

Isolated storage broadly refers to covered hazardous chemical storage that is not associated with a Schedule 4 installation on the same site and involves the relevant Schedule 2 quantity.

7. When is a safety report required under MSIHC?

A safety report is required when the applicable chemical, industrial activity and threshold conditions specified under the Rules are met. The factory should check the relevant Schedule 2 or Schedule 3 entry.

8. Who prepares the On-site Emergency Plan?

The occupier of the applicable industrial activity prepares and keeps the On-site Emergency Plan updated.

9. Who prepares the Off-site Emergency Plan?

The concerned authority prepares the Off-site Emergency Plan in consultation with the occupier and other relevant persons or agencies. The factory must provide the required site and accident information.

10. Are hazardous chemicals and hazardous waste the same?

No. A fresh chemical used as a raw material may be a hazardous chemical. After use, the resulting spent material may separately become hazardous waste.

11. Is an SDS enough for MSIHC compliance?

No. An SDS provides chemical safety information, but MSIHC compliance may also require quantity assessment, plant controls, site notification, safety reports, audits and emergency planning.

12. Should tanker unloading be covered in the emergency plan?

Where chemical unloading presents a credible release, fire, overflow or wrong-connection scenario, it should be considered in the site risk assessment and On-site Emergency Plan.

13. When should MSIHC applicability be reviewed again?

Review it whenever there is a change in the chemical, concentration, quantity, tank capacity, process, pipeline, unloading point, storage location or plant layout.

14. What records should be maintained for MSIHC compliance?

Important records can include the chemical inventory, applicability register, SDS, threshold calculations, site notification, safety report, audit findings, emergency plan, mock-drill reports, training records and Management of Change documents.

15. What is an MAH installation?

MAH means Major Accident Hazard. An MAH installation involves hazardous chemicals at or above the applicable threshold quantities specified under the MSIHC Rules.

Author's Note

Reviewed from a practical Indian factory EHS perspective. Readers should verify chemical-specific thresholds, applicable authorities and state submission procedures before making a compliance decision.