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Of the four, except Sl No 1, other three are valid observations. I recommend you working on them. You can clear emergency exit in 2-3 days, conduct the medical examination of workers, specially for contagious diseases within a fortnight and install handrails to the staircase in maximum one month.
I recommend you writing them back tell them that the you need one month's time to clear point Sl No 2 to 4. Once the changes are made, send a follow up letter with photographs stating that work on each point has been completed.
As far as replacing fans with AC is concerned, it is a costly solution. Find out whether you can change the position of fans or install additional fans so that workers do not sweat. In coming month, you should be able to clear this point also.
When government officials visit, it is important that they raise some objection of other. Do not expect zero observations. Therefore, no need to get perturbed as such on these observations. At the same time do not take lightly their observations.
By the way, do you have safety officer in your company. Why things came to such a pass where Factory Inspector had to issue notice on emergency exit? Emergency exit should be obstacle free this is a very basic safety requirement. Possibly observation on this point reflects that your company needs to improve safety awareness amongst the employees. I request you to take this as wake up call.
Thanks for your response.
I am working in small scale organisation.employee strength 60.
Concept as HR introduced after my joining 6 months back.
I have experience of big manufacturing org.which helped me to operate here individually.
1.Obstacle of emergency exit removed immediately.
2. For medical examination,I have started process.
3.Handrails - Contacted person.
But, In case of AC, inspector just gave us 15 days ( we asked him more time,but he refused).
Fans are not guarded and located at low height, any person can be injured.He asked to remove fans(50 in Quantity) immediately.
Can we use Any other mode of ventilation other than AC? Inspector said , for medical equipment manufacturing AC is first requirement.Is it true?
It seems the clarification by Shri Dinesh Divaekar is the fit to adhered,
You please send reply in the following format,
1) For observation (1) now the Fans are fitted rightly to the place duly consulting the safety authorities, and you should have a safety authority for the factory premises as such the observation is met and duly rectivied.
2) Handrails are being replaced by stair case and this can be done without harm as hand rails are not suitable either in near future. Thus the observation pointed is rectified by stair case and necessary steps initiated and you can bargain time for one month in replacing the same.
3) Medical examination of employees be done which will not take more than two days and a report attached in reply to the show cause. Medical examination is done to our employees on (give date).
4) Now the emergency exit is obstacle free, as no obstacles found near by the exit. (Please remove the obstacles kept nearby)
All the observations(in the same note as you have mentioned) are not that much punishable that can be easily rectified..
best of luck...
What is the difficulty Rupali. Don't you have any nursing home/hospital or even a Doctor in your place. Have a tie up with them and complete requirement by paying some fees to them and close the matter. Afterall this a requirement and various options are all available. Instead of replying with "non-compliance report" to the SCN you should try to send a "fully complied with" reply to the authorities and try to close the matter. Don't try to make it as a complicated issue by dragging it too much. See that violations are rectified to the extent possible. Otherwise you have to incur hefty "B" for closing the matter.
You are ready with solution for three of the four points.
Regarding FANS, discuss with your top technical person and see if a safety guard can be fitted.
You can even try to get an external help.
Once you are successful the idea can be replicated for other fans.
Then you can request the factory inspector for a reasonble time to complete the rest of the jobs
Another alternative, slightly costly, would be locate the fans outside and take the air through ducts inside.
Air conditioning could be last the resort.
If Air conditioning is a MUST, please check with similar type companies, if it is so.
You can also see if it is specified for your type of industry in the factory act.
I received show cause notice from Factory Inspector in regarding to contravention of Section 21.
i.e. Fencing of Machinery.
Kindly help me out and send me the reply letter format.
mailid - email@example.com