Safety Science 159 (2023) 106006

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Safety Science
journal homepage: www.elsevier.com/locate/safety

Sustainability reporting pathway – Is it a true reflection of organisational

safety culture: Insights from oil and gas and process sector of India
Sutapa Pati
XIM University, Plot No:12(A), Nijigada, Kurki, Harirajpur, Odisha 752050, India

A R T I C L E I N F O A B S T R A C T

Keywords: Sustainability reporting across companies continues to be diverse, with many variations on the specific di­
Sustainability reporting mensions that companies may choose to report under the voluntary reporting standards. A standardized pathway
Safety and well-being at work for safety related information is built with special relevance for India and its suitability to reflect organizational
Global Reporting Initiative (GRI)
safety culture explored through a review of ten oil and gas and process sector companies. The review attempts to
Business Responsibility and Sustainability
Report (BRSR)
find a balance between priority accorded to safety and safety performance indicators across organizations
Safety culture through a multi-dimensional index encompassing management commitment and operational performance
standards. Organizations are classified across three levels of safety culture reporting: high, medium and low. The
findings show that sustainability reporting across the multi-dimensional index is at best inconsistent across the
selected organizations. This illustrates the need for companies to adopt comprehensive and standardized
reporting before sustainability reporting may function accurately as a pathway for understanding an organiza­
tion’s safety information system, and, as a reflection of organizational safety culture.

1. Introduction leading Indian public and privately owned companies. The findings
indicated considerable diversity among reporting practices of com­
In recent decades, sustainability reporting has gradually emerged as panies on environmental and social dimensions.
the new norm for corporate accountability to stakeholders. Reporting on Among social dimensions of sustainability, safety and the well-being
sustainability issues allows companies to go beyond traditional financial of employees has also emerged as a critical area with World Health
reporting of profit and loss and include metrics related to environment, Organization (WHO), International Labour Organization (ILO), and
social and governance (ESG). Globally, many sustainability reporting Sustainable Development Goal 8 (SDG) highlighting the scope of
tools allow stakeholders to understand and compare companies based on workplace interventions for ensuring safe and decent work for all. WHO,
non-financial disclosures. Siew (2015) carried out a comprehensive re­ in 2007, adopted the Global Plan of Action on Workers’ Health and
view of sustainability reporting tools, classifying these into the major thereafter, introduced a WHO Healthy Workplace Framework and
categories of frameworks; standards; ratings and indices. Some of the Model (Burton, 2010; Kortum and Burton, 2010). Effective health, safety
principles and reporting frameworks under active discussion include UN and environment practices have become synonymous with good busi­
Global Compact Principles, Global Reporting Initiative (GRI), Sustain­ ness (Margetts, 1998; Lemkowitz et al., 2001). Reporting on safety and
ability Accounting Standards Board (SASB), and Integrated Reporting well-being has emerged as a viable methodology for assessing organ­
(IR). There is considerable discussion around merging some reporting isational safety culture and the priority accorded to safety in daily
frameworks and consolidating associated standards. The introduction of management practices (Evangelinos et al., 2018). The oil and gas and
materiality, GRI, and other integrated reporting tools have allowed for process industries have emerged as leaders in the safety discussion
the inclusion of several non-financial reporting aspects and contributed space, given the catastrophic impacts that non-adherence to safety issues
significantly to this trend (Petera, and Wagner, 2015; Calabrese et al., may result in, thus highlighting the need for companies to comply with
2019). For instance, Roca and Searcy (2012) analysed indicators safety standards and initiatives. In this context, we need to understand
detailed in corporate sustainability reports prepared by 94 Canadian the importance of corporate accountability on safety and analyse the
companies, most of which followed the GRI standards. Yadava and Sinha potential of sustainability reporting as a viable pathway.
(2016) used the GRI 2011 indicators to compare reporting practices of Workplace safety and the well-being of employees and other

E-mail address: sutapa.pati@xim.edu.in.

https://doi.org/10.1016/j.ssci.2022.106006
Received 30 March 2022; Accepted 8 November 2022
Available online 1 December 2022
0925-7535/© 2022 Elsevier Ltd. All rights reserved.
S. Pati Safety Science 159 (2023) 106006

stakeholders are crucial for manufacturing organizations with indis­ management and so on (Mannan et al., 2005). After the incident, mul­
pensable use of hazardous substances and/ or intensive processes. tiple legislative and regulatory changes ensured the country’s progres­
Notable examples of such organizations include the oil and gas industry, sion towards a safety culture, with the most recent shift aligning with the
chemicals and fertilizers, or basic materials. Within this framework, prevalent concept of Vision Zero. However, India has no comprehensive
process-based sectors have certain common characteristics, such as their legislation targeted at workers and other stakeholders in process-based
dependencies on chemicals, continuous operations, excessive heat and manufacturing organisations (similar to USA’s OSHA PSM that covers
noise, and high levels of workforce exposure to hazardous substances, process safety management).
processes or activities. For instance, Oil and Gas operations necessitate The relevant legislations in India included the Factories Act, 1948,
using hazardous, corrosive and toxic feedstocks. Most production, the Mines Act, 1952, the Employees’ State Insurance Act, 1948 and the
handling, storage and transport processes often require high tempera­ Employees Compensation Act, 1923. The first two are now subsumed
ture and pressure ratios. Similarly, companies operating in the agro­ under the Occupational Safety, Health and Working Conditions Code,
chemicals and fertilizers domain, particularly ammonia and volatile 2020, while the last two have been subsumed under The Code on Social
substances and acids producing and using plants, are placed on the Security, 2020. Newer rules and guidelines (Pingle S., 2012; Mannan
higher side of the continuum of health and safety due to the inclusion of et al., 2015) have placed significant focus on process and chemical in­
hazardous substances and extreme operational conditions (with resul­ dustries, including, for instance, Chemical Accident Rules, Manufacture,
tant hazards such as explosions and spillage). Further, process industries Storage and Import of Hazardous Chemical Rules (MSIHC), the Emer­
often function as continuous, semi-continuous or batch industrial pro­ gency Planning, Preparedness and Response to Chemical Accidents
cesses and thus have higher associated risk functionality. Such organi­ (EPPRCA) Rules and Public Liabilities Insurance Act, and recently,
zations have been specified as belonging to multiple risk-based guidelines for hazardous waste disposal (Raja and Sathaye, 2016; Sen­
categories such as major hazardous industries (MHI), high–risk facilities, gupta et al., 2016). India is yet to ratify the three fundamental con­
high-reliability organizations, and, complex socio-technical systems. ventions on OHS, i.e., the Occupational and Safety Convention (1981)
These companies are expected to prioritize safety and well-being as a and its protocol (2002), the Convention on Occupational Services (1985)
material issue in their sustainability reporting. and the Promotional Framework of the Occupational Health and Safety
In light of the high priority accorded to safety, reliability and sus­ Convention (2006) (Patel and David, 2016; ILO, 2021). It has, however,
tainability issues in process-based industries, they have been at the ratified the Benzene Convention (1971) and the Prevention of Major
centre of management, operational and organizational safety issues Industrial Accidents Convention (1993) with a direct bearing on the
research. Occupational Health and Safety (OHS) are two arms of well- process-based industries. A 2005 Supreme Court Writ Petition high­
being for which organizations are accountable to their stakeholders. lighted workers’ occupational health and safety in Coal-fired thermal
Occupational health essentially refers to employees’ well–being over power plants across the country (SC WP 79/2005) (Supreme Court,
time, including the prevention of hazards, accidents, illnesses and in­ 2005). Based on the SC orders, a NIOSH report was made detailing the
juries. Consequently, traditional metrics such as injury rates and hazards severe conditions and serious health hazards in 2011. This was one of
experienced across the chosen industries are crucial parameters of India’s few comprehensive studies undertaken in occupational health
operational safety as well as organizational sustainability. In other and safety (NIOSH, 2011).
words, stakeholder confidence in these organizations is significantly Over the years, Government has taken up measures for simplifying
influenced by the organization’s ability to ensure process safety and and consolidating labour laws and bringing in the concept of self –
sustainability along with its efforts towards ensuring the safety and se­ regulation, with the hope that management commitment slowly replaces
curity of its workforce and adjoining communities. Therefore, unsafe the compliance linked perspective that was in prominence earlier. The
acts, human error, extenuating circumstances, or a mix of these may lead 2009 National Policy on Safety, Health and Environment at the Work­
to tragic implications. place (NPSHEW) is yet to be implemented in accordance with its vision
In this study, we have assessed the existing organizational initiatives and objectives. It called for a national legislation on safety, health and
from the perspective of institutional and operational safety and the environment at the workplace, to replace current piecemeal legislations
health and well-being of employees (including the contract workforce) limited to manufacturing, mining, ports, and construction sectors. India
and discussed the scope for companies operating in the process sector. is also amid a transformational shift with the passage and adoption of
For this, we applied a content analysis methodology to occupational the Occupational Safety, Health and Working Conditions Code, 2020.
health and safety disclosures and their alignment with GRI 403 criteria The code shall extend provisions related to safety, health, welfare, and
on OHS and India’s BRSR Reporting guidelines. In doing so, we have working conditions to all establishments with 10 or more employees
gone beyond the conventional matrix of occupational diseases, injuries (this was limited to only 9 major sectors earlier). It also provides for
and man-day losses. We have adopted the GRI OHS criteria and the setting up the National Occupational Safety and Health Advisory Board
Business Responsibility and Sustainability Report (BRSR) initiative of as a tripartite body representing trade unions, employer associations and
the Securities and Exchange Board of India (SEBI) for comprehensive­ state governments. Additionally, the National and corresponding State
ness while inserting several aspects related to organizational safety Advisory Boards should bring forth enabling provisions for framing
culture as well. The final set of criteria was applied to sustainability rules, regulations, standards, and bye-laws as per different sectors’
reports of 10 Indian companies belonging to the oil and gas, fertilizer requirements.
and chemical industries.
3. Review of literature
2. Background
3.1. Material issues in sustainability reporting
2.1. Evolution of OSH policy framework in India
There have been two major areas of discussion within sustainability
India has been at the forefront of the global discourse on OSH reporting – one focuses on the need for sector-specific materiality and
courtesy of the 1984 Bhopal chemical disaster at the Union Carbide reporting standards (Eccles, Krzus, Rogersand Serafeim, 2012). The
industrial unit. Worldwide, and especially in India, the Bhopal incident other references the concept of integrated sustainability reporting (i.e.,
subsequently led to the formulation of specific legislations and regula­ integrating financial and non-financial reporting methodology). Adams
tions related to various aspects of incident management such as emer­ and Evans (2004) discussed the concerns in non – financial reporting,
gency response, post-event insurance for peripheral communities and viz. its lack of completeness and consequently, of credibility. Over the
residents, mandatory hazardous waste management by concerned years, stakeholder engagement and materiality in company reporting

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has emerged as a precondition for ensuring that a) companies’ reports work (operational safety), wherein four dimensions of “safety work”
should be both comprehensive and provide a balanced overview of their have been suggested: social safety (rituals, values, and opportunities for
performance in the reporting period (i.e., all activity areas and issues discussion); demonstrated safety (assurance, regulation, standards with
raised by stakeholders are adequately covered) and b) that the issues and activities including risk assessment, demonstrating evidence); adminis­
concerns given significance in the report have been termed material by trative safety (routines, role requirements, internal compliance and
its stakeholders. Here, internal stakeholders include employees, share­ audits, safety management systems); and physical safety (physical bar­
holders and investors whereas external stakeholder groups commonly riers, alarms, testing, controls) (Rae and Provan, 2019).
include customers, suppliers, contractors and partners, Government and
regulatory bodies, communities and NGOs. The process of company 3.3. Occupational health and safety in process based sectors
engagement with stakeholders and, as a step forward, preparing its
materiality matrix is crucial for understanding its sustainability over­ Oil & Gas Industry: Among the selected process industries, the oil
view and its current and future initiatives. and gas industry requires several processes such as drilling, cementing,
Engaging with key stakeholders and ensuring their views have been completion, stimulation, and production. These processes utilize many
considered is a prerequisite for preparing the company’s materiality chemicals, esp. with a high complexity of compositions. Cottle and
matrix (Manetti, 2011, GRI G4 Reporting Principles and Standard Dis­ Guidotti, 1990 studied the various industrial processes and chemical
closures, 2020). The materiality matrix essentially helps the company typologies used in the oil and gas industry to highlight the potential
prioritize the relevant issues for sustainability. There is a need to reflect occupational hazards . Taiwo, 2010, in a study of the oil and gas industry
upon the various aspects of materiality mapping within the organisa­ in Nigeria, included the following aspects as contributing positively or
tion. These aspects include a) the process through which the organisa­ negatively to employee productivity: airflow and temperature, humid­
tion engages with stakeholders for materiality mapping, b) the channels ity, adequate light, noise management, employee personal aspects,
and methods used to engage them, and c) the role played by stake­ contaminants and hazards in the working environment, as well as types
holders (information gathering, monitoring, advisory, participative, of sub- environment. Lan et al. 2004 established hematotoxicity from
involvement in decision making) (see Manetti, 2011; Beske et al., 2019). exposure to Benzene even at air levels of 1 part per million (ppm) or
below. Apart from chemical hazards, there are multiple categories of
3.2. Organizational safety culture and climate occupational hazards associated with the Oil and Gas industry. Al-Masri
and Suman, 2003 in their study of the Syrian oil industry identified three
Organisational safety culture discussions have continued for the last categories of Naturally Occurring Radioactive Materials (NORM) waste
two decades. Cooper, 2000 defined safety culture as a subset of organ­ in multiple equipment and storage that need appropriate treatment or
isational culture which specifically compass beliefs and values oriented disposal. These wastes typically occur from the 232Th and 238U series
towards health and safety. Since then, a number of studies have looked and may be in the form of scale and sludge, solid residue or production
at employee attitudes , management commitment to safety culture and water (Al-Masri and Suman, 2003).
the distinction between safety climate and safety culture (Choudhry Occupational hazards in other process companies: Reddy and Yar­
et al., 2007; Mearns and Yule, 2009) . It is suggested that culture sub­ rakula (2016) analysed 70 major accidents in chemical process in­
sumes and extends beyond organisational systems and processes and has dustries across 30 countries from 1998 to 2015. Their findings indicated
a significant impact on daily practices. It thus includes, apart from that most incidents involved hydrocarbons and toxic chemicals, with
organizational systems, processes and standards, the softer aspects of substantial explosion and fire cases due to hydrocarbons’ flammable and
behaviours, actions, and ones’ feelings and perceptions on safety (Gul­ explosive nature. Prasher et al., 2002 discussed the impact of mixed
denmund, 2000). Safety climate, as per some researchers, refers to exposure to both industrial chemicals and a noisy environment towards
psychological aspects such as perceptions, attitudes and values (see enhancing the potential risks in workers for hearing loss and balance.
Zohar, 1980; Coyle et al., 1995; Williamson et al., 1997; Fin et al., 2000; Hormozi et al. (2017) specifically reviewed the additional risk of hear­
Neal and Griffin, 2004; Kouabenan, Ngueutsa and Mbaye, 2015). ing loss in workers with occupational exposure to organic solvents with
Reason (2000) proposed a number of main elements of an organi­ or without concurrent exposure to noise.
sation with an effective safety culture including a) safety information Improving the physical conditions of operation is thus one of the
system b) culture of reporting where people are encouraged to report prominent means to ensure process safety and improve employee pro­
errors mistakes and violations c) culture of trust where people are ductivity. The suggested means include noise control, contaminants and
encouraged to report or provide safety related information d) flexibility hazard control, an improved work environment with ventilation and
within the organisation specially in context of organisational structure temperature optimization, protective clothing, first aid facilities and
versus dynamic task environment and e) organisational willingness and other basic considerations for physical safety (See Taiwo, 2010). Finally,
competence to evaluate and to reform for best safety results. there is a clear indication of the need for organization-level intervention
Studies of safety culture have focused on safety related attitudes and in employee health and management involvement in OHS initiatives
management actions, including safety management systems and (Montano, Hoven and Siegrist, 2014).Work-related injuries, fatalities, or
behaviour-based safety (see Clarke 1999; Glendon and Stanton, 2000; diseases have multiple impacts on the organization including human,
Hopkins, 2006; Choudhry, Fang and Mohamed, 2007). Some earlier social, and financial consequences such as wage loss, treatment costs,
studies have focused on the incident reporting system as a dimension of compensation and legal fees, regulatory fines and penalties, operational
safety culture, thus, influencing organizational level safety-related be­ losses including productivity dips and direct expenditures such as in
haviours (Clarke 1999). Westrum 2004 developed a typology of cultures retraining, recruitment and preventive and mitigating measures for
reflecting management of information flow on safety issues and illus­ avoiding recurrence (O’Neill et al., 2013).
trating higher levels of advancement. His three levels, pathological,
bureaucratic and generative were further classified into five levels by 3.4. Occupational health and safety studies in India
Parker, Lawrie and Hudson in 2006. These five levels included patho­
logical, reactive, calculative, proactive and generative. Zanko and Researchers have continued the efforts on understanding the overall
Dawson (2012) presented a comprehensive review of OHS management process safety environment in India. Vinodkumar and Bhasi (2009)
in organisations in 2012. In this review, the authors’ focus was on un­ found that safety climate factors varied significantly across across eight
derstanding five categories of OHS literature including culture, climate major industrial units in the state of Karnataka (Vinodkumar & Bhasi,
and high reliability studies. Further, researchers have also distinguished 2009). Yet, the scenario differs across companies. Studies have shown
between safety work (for improving institutional safety) and safety at that safety management practices were less than adequate among small

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and medium enterprises (SMEs) in India (Unnikrishnan et al., 2015). The c) Participation of non – management workforce in site-level commit­
barriers to safety identified by the sample study included financial tees and process sustainability initiatives, including risk assessment,
constraints, poor awareness, resistance to change, and deficient training safety committees, trainings (and training materials)
mechanisms for employees. Vijalpura (2019) attempted to understand d) The priority accorded to safety culture and management system via
the correlation between safety climate and safety system factors re­ safety culture, board accountability, policies and standards, SOPs,
ported by a survey sample of 1029 employees of major hazardous in­ and safety awards.
dustries operational in the state of Karnataka. Behera and Hassan (2019)
reviewed 982 fatal ‘factory accidents’ in 2001–16 in the state of Odisha.
They found evidence that learning from accident analysis was helpful in
4.1. Intent and performance parameters
accident reduction, provided safety aspects were given priority via
management, people’s participation and employee accountability. Pin­
For the first research question, we focus on indicators that are partly
gle 2012 identified major OHS risks in India including accidents,
adapted from GRI 403 and as stated in principle 3 of BRSR reporting.
pneumoconiosis, musculoskeletal injuries, chronic obstructive pulmo­
These indicators include setting up of HSE policy, following acceptable
narydiseases (COPD), the impact of pesticides, and hearing loss induced
standards, safety committees etc. For the second research question, we
by noise.
highlight performance indicators such as providing health services,
safety and health awareness, capacity building or training materials,
4. Materials and methods
worker participation and health and safety incidents etc. The discussions
on the second research question also involve performance indicators,
Content analysis methodology for analysiing companies’ sustain­
thus highlighting OHS practices’ integration into the daily work
ability reports was adopted for this study (Heras-Saizarbitoria et al.,
environment.
2022; Macellari et al., 2021; Pati et al., 2016). Aggarwal and Singh 2018
We adapted the criteria available in GRI OHS 403 and under prin­
carried out content analysis of Business/ CSR/ Sustainability reports of
cipal 3 of BRSR. Table 1 shows the indicators available under GRI OHS
60 major Indian corporates. They used a multidimensional index to
403 and principle 3 of BRSR that were chosen to measure companies’
compare differences in reporting by organization’s size, sector, di­
intention as also reporting of performance related indicators. In all,
mensions of sustainability, ownership and profit aspects. Okeke 2021
there were 30 parameters that were brought into consideration for
also analysed annual reports (1 5 0) of fifteen Oil and Gas companies
measuring intentions and performance.
across America, Asia and Europe to understand the companies’
perspective on sustainability across their supply chains.
This paper specifically focussed on analysing sector-specific areas
linked to process sustainability and OHS through structured content Table 1
analysis of sustainability and company-specific reports (See also Isaks­ Criteria for selection of the multi-dimensional index and its sub-dimensions.
son and Steimle, 2009; Manetti, 2011). The analysis of the information
Code Dimension Sub-dimension Selection Criteria
was done through the following steps: Selection of the critical standards,
OMS Organization Safety Safety Management Principle 3(10a)
i.e., GRI OHS 403 and Principle 3, BRSR; Preparation of the analysis
Management System System
framework based on these; Selection of keywords and synonyms for Safety Days Principle 3(12)
retrieval of information; Selection and Collation of relevant reports; Safety Awards
Categorisation of the retrieved information and scoring; Analysis and Board-level monitoring
interpretation of information. The extraction and collation of informa­ SOPs
RA Risk Assessment HAZOP/ HIRA Principle 3(10b, 14)
tion was conducted for the selected company reports with the help of
methodology QRA
specialised qualitative data analysis software (MaxQDA Analytics Pro Safety audit (external)
2020) and confirmed with a manual search. A set of diverse keywords Safety audit (internal) GRI 403–4; Principle
was derived from the analysis framework or index (such as “Safety 3(10b, 14)
Worker participation in GRI 403–4
Culture,” “Behaviour-based Safety”, “Training,” “Participation,” “Risk,”
risk assessment
etc.) for the structured keyword search protocol. Through review of WP Workers’ Participation Safety Culture Principle 3(12)
sustainability reporting practices in the oil and gas and process sector Safety Committees GRI 403–1
industries, we specifically focus on the following questions: Formal representation GRI 403–1
safety committee
Percentage of workers GRI 403–1
1. To what extent do companies in the selected industries highlight
covered
their performance when it comes to occupational health and safety Safety in supply chain Principle 3:
2. To what extent do companies in the selected industries prioritize Leadership indicator
safety culture and what are some of the ways in which steps are taken (5,6)
for integrated safety culture in day-to-day practices HS Health Services Health Services Principle 3(10d)
Health Checks
IEC Materials on safety GRI 403–4
Accordingly, we selected certain parameters linked to the specific OHS Health manual GRI 403–4
aspects of process safety, security and sustainability for this analysis, Emergency Health Care Principle 3(10d)
listed below. WT Workers’ Training Safety Training Man- GRI 403–4; Principle
Days 3(8)
Induction Training
a) Stakeholder engagement and materiality assessment in the context of On-job Training
sustainability and importance accorded to process safety and Occu­ Refresher Training
pational Health and Safety therein Behaviour based Safety Principle 3(12)
b) Process safety parameters reported by the company (including lost PS Policies and Standards OHSAS 18,001 Principle 3(12)
OISD/PNGRB/
days, fatalities, occupational diseases, and preventive medical check- International Standards
ups and facilities). The OHS parameters specified under Global ISO 9001:2008
Reporting Initiative (or GRI G4) and in BRSR were taken into ISO 14001:2004
consideration. Health Safety &
Environment Policy

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S. Pati Safety Science 159 (2023) 106006

Dimension 1: OHS/ safety management system (OMS): sub in­

dicators included mention of a) safety management system b) safety
days c) safety awards d) Board level safety monitoring and e) Standard
Operating Procedures on safety within the organisation.
Dimension 2: Risk assessment methodology (RA) followed by the
organisation including a) reference to or adoption of methodology such
as HAZOP, HIRA, etc., b) QRA c) Safety audits conducted by external
parties d) Safety audits conducted internally and e) worker participation Fig. 1. Levels of organizational performance on the multi-dimensional index.
in risk assessment.
Dimension 3: Worker participation in OHS (WP) including a)
mention of safety culture b) setting up of a single or multiple levels of
safety committee c) formal representation of non-management work­ Dimension 5: Workers and Safety Training (WT) focused on various
force in safety committee d) percentage of workers covered and e) Pri­ training aspects under which workers were covered. This included
ority according to safety across the supply chain. reporting on a) safety training man days b) induction training c) On Job
Dimension 4: OHS Health Services (HS) a) access to health services b) Training d) Refresher Training and e) Behaviour based safety.
regular health check-ups focusing on occupational health hazard pre­ Dimension 6: covered the conventional reporting on incidents/ac­
vention c) availability of IEC materials on OHS and safety d) preparation cidents/fatalities/injuries. However, this dimension was not included in
of an OHS health manual and e) provision of emergency health care the final review process as there was considerable inconsistency across
services. organisations on the degree of reporting. The parameters included
numbers of fatalities, rate of fatalities, number of high-consequence
work related injuries, rate of high-consequence work related injuries,
number of recordable work related injuries, rate of recordable work
Table 2 related injuries, main types of work related injury, LTIF, lost days, near
Scoring scale for all sub-dimensions of the prepared index. miss and absentee days.
Code Sub-dimension Scoring (binary scale)
Dimension 7: This dimension covered policies and standards adopted
by the organisation (PS) including but not limited to a) OHSAS 18001, b)
OMS1 Safety Management System 0 = no SMS system in place
OISD / PNGRB standards or relevant international safety standards, c)
OMS2 Safety Days 0 = safety days not reported
OMS3 Safety Awards 0 = no safety awards reported ISO 9001: 2008, d) ISO 14001: 2004 environment management and e)
OMS4 Board-level monitoring 0 = no Board level committee for safety Health Safety and Environment policy of the organization.
OMS5 SOPs 0 = safety related SOPs not reported The content analysis involved a keyword search based on the
RA1 HAZOP/ HIRA 0 = HAZOP/ HIRA not reported
description of each indicator as provided in Table 2 , including syno­
RA2 QRA 0 = QRA/ similar methods not reported
RA3 Safety audit (external) 0 = 3rd party safety audits not reported nyms to reduce undercounting errors. Nominal data (0 or 1) was
RA4 Safety audit (internal) 0 = internal safety audits not reported collected from organizational reports to make up a composite index of
RA5 Worker participation in risk 0 = nil worker involvement in Risk intent and functional parameters. We calculated the score for each sub-
assessment Assessment processes criteria and the overall composite score was stated. The overall score is
WP1 Safety Culture 0 = reference to safety culture not found
considered by dividing the number of indicators found in the specific
WP2 Safety Committees 0 = safety committees not reported
WP3 Formal representatives in 0 = no worker involvement in safety report by the total number of indicators. Thus, the maximum score for
safety committees committees each company covering intention and performance would be 1. The
WP4 Percentage of workers covered 0 = no workers covered via agreement score calculation assumes that each indicator is equal in weight. Table 2
on joint committees
below illustrates details of the scoring scale. Based on the final score, the
WP5 Safety in supply chain 0 = safety systems across suppliers not
reported
company’s performance is categorised as per the different levels pre­
HS1 Health Services 0 = no health services for workers sented in Fig. 1.
HS2 Health Checks 0 = no periodic health checks As indicated in Fig. 1, companies may be divided into three perfor­
HS3 IEC Materials on safety 0 = no IEC materials communicating mance levels based on the aggregate scores: Low (10 to 40 percent);
safety
Medium (40 to 70 percent) and High (70 to 100 percent). Below 10 per
HS4 OHS Health manual 0 = OHS health manual not reported
HS5 Emergency Health Care 0 = no provisions for emergency cent scoring would imply missing data or non reporting of safety data as
healthcare per selected parameters.
WT1 Safety Training Man-Days 0 = no details on safety training man-
days
4.2. Company selection process
WT2 Induction Training 0 = safety related induction trainings not
reported
WT3 On-job Training 0 = safety related on-job trainings not Oil and Gas and process sector companies were selected by virtue of
reported their inclusion in the top 150 Indian companies as per Fortune 500 2018
WT4 Refresher Training 0 = safety refresher trainings not in Table 3. In addition to annual reports and sustainability reports,
reported
company website and sector reports from multiple years (2015–16 to
WT5 Behaviour based Safety 0 = behaviour-based safety interventions
not reported 2018–19) were included in the analysis. Sector wise companies selected
PS1 OHSAS 18001 0 = facilities not covered under OHSAS from a) Oil and Gas industries (exceptions being Reliance Industries due
PS2 OISD/ PNGRB/ International 0 = facilities not covered under to its high diversified nature) b) Fertilizers and Agrochemicals and c)
Safety Standards international safety standards
Basic Materials. Of these, nine are public sector companies, one co-
PS3 ISO 9001:2008 0 = facilities not covered under ISO
9001:2008
operative and three are private companies. Of these, MRPL was
PS4 ISO 14001:2004 0 = facilities not covered under ISO excluded as it is a subsidiary of ONGC. Essar Oil (since then renamed as
14001:2004 Nayara Energy) and IFFCO were excluded due to the inadequacy of in­
PS5 Health Safety & Environment 0 = no HSE or similar policies prepared formation available due to non–filing of the GRI/ BRR report. Thus, ten
(HSE) Policy and approved by the Board
companies were available for content analysis and review.

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Table 3
List of selected indian oil and gas and process companies.
Company Name Private/ Fortune 500 (2018 rank) Industry sector Report Year GRI Compliance (Core/ Comprehensive)/ BRR
Public

1 Indian Oil Corporation Public 1 O&G 2018–19 Comprehensive

2 Oil & Natural Gas Corp Public 3 O&G 2018–19 Core
3 Bharat Petroleum Public 6 O&G 2018–19 Comprehensive
4 Hindustan Petroleum Public 7 O&G 2018–19 GRI G4
5 Essar Oil (Nayara Energy) Private 22 O&G NA NA
6 GAIL (India) Public 31 O&G 2018–19 GRI G4
7 MRPL ONGC subsidiary 34 O&G NA Core
8 Chennai Petroleum Public 44 O&G 2017–18 BRR
9 Petronet LNG Public JV 48 O&G 2015–16 Core
10 IFFCO Co-operative 68 F&A NA None
11 UPL Private 86 F&A 2017–18 Comprehensive
12 Oil India Public 116 O&G 2018–19 Core
13 Tata Chemicals Private 124 BM 2018–19 GRI and AA1000

5. Findings and risks; workers’ involvement in hazard and risk reporting; providing
access to workers on non-occupational medical and health care services;
In India, the emergence of business responsibility reporting has third party assessments of health and safety practices and working
increased the credence of GRI and other sustainability reporting mea­ conditions; and extension of such assessments to encompass value chain
sures, given the recently mandatory nature of the national guidelines for partners. In addition, the BRSR also includes details of the numbers of
the top 1000 listed companies (Mani, Agrawal and Sharma, 2015). The safety related incidents; complaints filed by workers on working con­
slow emergence and acceptance of the guidelines as an ESG standard for ditions and health and safety; and finally, life insurance or compensa­
the country have been well noted (Srinivasan and Venkatachalam, 2021; tions awarded to employees or workers in the event of fatalities. Further,
Sarangi, 2021). reporting under BRSR goes above and beyond the provisioning of a safe
Under the new business responsibility and sustainability reporting and healthy workplace environment. It also includes aspects such as the
format, Principle 3 discusses the role of businesses in promoting the rehabilitation of workers who may have suffered high consequence work
well-being of all employees including across the value chain, i.e., sup­ related injury, ill-health, or fatalities, and who have either been reha­
pliers, vendors and other actors involved in the value chain. Within bilitated or they or another family member placed in suitable employ­
Principle 3, Section 10 focuses specifically on the health and safety ment. Thus, some critical aspects under consideration include the
management systems. The parameters within Section 10 include the following:
following aspects: setting up of an internal health and safety manage­
ment system; assessment processes used to identify work-related hazards

Table 4
Company specific scoring details as per the multi-dimensional index.
IOC ONGC BPCL HPCL GAIL Chennai Petroleum Petronet LNG UPL Oil India Tata Chemicals

OMS1 1 1 1 1 1 1 1 1 1 1
OMS2 1 1 1 1 1 1 1 0 0 1
OMS3 – 1 1 1 1 – – 1 1 1
OMS4 1 1 – – 1 – – – 1 1
OMS5 1 1 1 – 1 – – – – 1
RA1 1 – 1 – – – – 1 1 1
RA2 1 – 1 – – – – – – 1
RA3 1 1 1 – 1 1 1 – – 1
RA4 1 1 1 1 1 1 1 1 1 1
RA5 1 – – – – – – – – –
WP1 1 – 1 1 1 – – 1 1 1
WP2 1 – 1 1 1 – – 1 1 1
WP3 1 – 1 1 1 – – 1 – 1
WP4 1 – 1 1 – 1 – – – –
WP5 1 1 1 1 1 – – – – 1
HS1 1 1 1 1 1 1 1 – – 1
HS2 1 1 1 1 1 1 – 1 – 1
HS3 1 1 1 1 1 – 1 – – –
HS4 1 1 – – 1 – – – 1 –
HS5 1 1 1 1 1 1 1 – – 1
WT1 1 1 1 – 1 1 – 1 – 1
WT2 – – – – – – – – – –
WT3 1 1 – 1 1 – 1 1 1 1
WT4 – – 1 – 1 – – – – –
WT5 – 1 1 1 1 – – – – 1
S1 1 1 1 1 1 1 1 1 1 1
S2 1 – – – – – – – 1 1
S3 1 1 1 1 1 1 1 1 1 1
S4 1 1 1 1 1 1 1 1 1 1
S5 1 1 1 1 1 1 1 1 1 1
Total 26 20 24 19 24 13 12 14 14 24
Composite Score 0.86 0.66 0.8 0.63 0.8 0.43 0.4 0.46 0.46 0.8

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- Whether selected organizations have adopted multi – stakeholder both of which receive guidance from the Safety Head/Site Head.
engagement in their OHS approach? Reporting on the dimensions on worker participation in risk assess­
- Is OHSconsidered a material issue by the organization? ment, joint committees, and capacity building/ training was inconsis­
- Is there evidence of management involvement in OHS in Indian tent. The inconsistency has specific relevance for preparing a positive
process organizations? safety climate and inculcating a strong and positive safety culture that is
- To what extent is standardization demonstrated in OHS specific pa­ more bottom-up rather than top-down.
rameters reported by the organizations? Almost all organizations have institutionalized preventive medical
- What are the hazard/ risk/ safety management systems stated in the check-ups in the form of half yearly or annual health check-ups for all
organizational reports? workforces, and, in some cases, specific check-ups for personnel working
- Whether organizations follow a continuous improvement approach in refineries, or, those exposed to ammonia. Most selected companies
& higher OHS standards? consistently reported health services, including periodic check-ups and
- Are process and safety management systems aligned with global emergency healthcare services. The only exception, in this case, was the
standards? sub-dimension on OHS health manual, reported inconsistently.
Policies and standards were scored highly by almost all of the
Table 4 presents the scores received by the selected companies on the selected companies. Apart from OHSAS 18001, these standards included
six selected dimensions. other parameters such as ISO 9001:2018 and ISO 14001: 2004. All
The first step of analysis involved an assessment of stakeholder companies also reported having a health, safety and environment policy
engagement and the presence of OHS in the materiality matrix prepared in place though the naming conventions varied across companies. Only a
by the selected companies. Of the ten companies, seven had placed few companies additionally reported following international safety-
Occupational health and safety as a high-level material issue in their based protocols or systems such as Oil Industry Safety Directorate’s
materiality matrix, while two placed it in the medium category. The sole (OISD) Guidelines on Safety Management System in Petroleum Industry
exception was Chennai Petroleum Limited which did not have a mate­ (GAIL).
riality matrix available as part of the reporting. It is to be noted that
companies followed individual timelines for formal stakeholder 6. Discussion and conclusion
engagement and preparation of the materiality matrix. Petronet LNG
undertook this process in 2012–13 followed by a revision in 2015–16. The findings from above indicate considerable diversity in the
Most companies had undertaken the exercise in 2018–19 or in the pre­ standards companies adopt for sustainability reporting and the specific
ceeding years. metrics reported . Within metrics too, companies are flexible in terms of
While the process companies that have not aligned their reporting the level of detail provided, thus making standardization and compari­
with GRI did not report about any of the conventional parameters, other son across companies and sectors challenging.
companies, too, provided incomplete and patchy data on the occupa­ The multidimensional index can classify the selected companies into
tional injury status of their workforce. For instance, some other selected high, medium and low level of OHS reporting based on the details
organizations did not report any safety linked process parameters. The provided in sustainability/ BRSR reporting. The findings indicated that
parameter with minimal reporting is workers with high incidence or the selected companies were distributed in high and medium reporting
disease risk, which refers to GRI G4-LA7. This parameter requires the categories with no occurrence of low reporting. This is significant, even
organizations to identify whether occupational activities performed by though conventional incidence reporting measures were not considered
their workforce have a higher disease liability. Significantly, majority of due to the substantial variation in reporting. Four companies success­
the organizations reported not having any incidence of occupational fully met the criteria for high reporting levels while the other six could
diseases. Since each company has a differently sized workforce, only reach a medium level. The results stem from the diversity in metric
comparing parameters such as lost days or near misses, and even fatal­ wise reporting seen across indicators and the selected companies.
ities is not prudent, except for commending the high priority accorded to One of the first in-depth studies on the meeting ground between OHS
occupational injuries and incident reporting and prevention. In addition and CSR or sustainability reporting was in Koskela, 2014. The author
to the parameters mentioned above, many companies highlighted LTI carried out a content analysis of reports on three companies, retracing
free days or incident free periods. the reports over five years. The main finding was a similarity in the
Safety Management System was present in all the ten selected com­ companies’ approach to reporting on OHS issues.
panies. However, a few companies did not refer to indicators such as Hubbard, 2011, brought out the inconsistencies in the quality of
Safety Day/ week/ month celebration by the company. Several com­ sustainability reporting after a study of 30 sustainability reports from
panies also stated with pride and achievement that they had won safety the most prominent companies across the world distributed across three
awards (given both by private entities and Government agencies such as work sectors. The author submitted that most reports indicated gaps
Oil Industry Safety Award, National Safety Award, and so on. Only half such as clarity in policies, low adherence to materiality in reporting, and
of the selected companies detailed Board level committees, providing limited quality assurance. Sector-specific research of sustainability
evidence of the diverse board monitoring compositions for occupational reporting have also been evidenced in the work of Schneider, Wilson and
safety. A similar number of companies mentioned SOPs on occupational Rosenback (2010); with particular reference to oil and gas industry
safety in their reporting. Thus, these parameters assisted in gaining (Schneider, et al., 2013), and mining industry (Perez and Sanchez, 2009;
insight into management commitment to safety. Fuisz-Kehrbach, 2015; Boiral and Henri, 2017). The sector-wide adop­
In a significant number of selected companies, the responsibility of tion of OHSAS has made a difference in industry perceptions of safety,
OHS has been vested with installation/ plant/ location/ unit level HSE yet companies continue to differ in their understanding and uptake of
committees. Such committee formation, with a joint representation of the standard. The existing literature thus indicates the current status and
non – management workforce and management representatives has gaps in reporting. It also presents the potential for comprehensive
been mandated under Factories Act, 1948. Alternatively, some com­ reporting and the preparation of a unified framework.
panies have recruited safety officers, while others have placed overall Evaluating work health and safety related performance of an orga­
responsibility with the Head of the Safety and Environment Department. nization is conventionally done through a number of process parame­
Finally, some companies reported setting multiple levels of hierarchical ters. Though process safety parameters are crucial from the perspective
mechanisms for safety. One example is Tata chemicals, which has of employee health and well-being, there is a visible lack of standardi­
layered responsibilities, including, at the first level, the works/central zation in the measures used even within a sector for recording opera­
safety committee, and then the plant/ department safety committee, tional parameters for occupational health and safety. O’Neill, for

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S. Pati Safety Science 159 (2023) 106006

instance, analysed ten corporate organizations and found that the sustainability standards such as GRI and BRSR. It is the author’s humble
selected firms used diverse definitions and units for reporting on health submission that such an index that adopts institutional actions for safety,
and safety aspects (see O’Neill, 2011, Siew, 2015). The current study has management commitment, and aspects of operational safety will add
also found much diversity in traditional incident-based metrics. much-needed depth to current reporting standards. Doing so will help
Comprehensive process parameters have been a part of GRI’s G4 demonstrate company adherence to safety compliance while presenting
OHS parameters, chiefly lost time injury (LTI) metrics, including injury a true reflection of the organisational safety culture.
rates and LTI rates. These parameters though are not without limita­ The study’s limitations include its context dependence, as indicated
tions: for instance, see O’Neill et al., 2013 for limitations of LTI rates. by its focus on a specific sector and policy scenario within India, the
Another limitation has been the absence of priority to disabilities on small number of companies, and the need for expert validation. One
account of work – related injuries (O’Neill et al., 2013) with an impact in limitation is its sector-specific nature, and the few companies that
addition to the combined effect of short and long – time absences from comprehensively report on all dimensions of safety, including both
work(O’Neill et al., 2013). As an indicator, O’Neill also discusses the intent and functional parameters. It is hoped, that with BRSR reporting
need to differentiate between low and high consequence injuries as these becoming mandatory for the top 1000 listed companies from the current
differ considerably and thus need specific recognition. year onwards, some of these limitations may soon be overcome. The
Researchers have explored process safety management’s changing present study is the first step in establishing the multidimensional index
contours, especially in intensive process industries. For instance, they via theory and contemporary thinking with the potential for acceptance
recognize the limited success of traditional analytic tools such as and adoption in India. The author hopes to continue with efforts to
HAZOP, FTA, LOPA, etc for identifying and controlling potential haz­ further validate the multidimensional index with inputs from industry
ards. Current research and thinking have suggested the necessity of experts and company representatives.
moving beyond traditional safety metrics that place excessive reliance
on incident and accident–based reporting (Lofquist, 2010). The pre­ CRediT authorship contribution statement
dominance of lagging indicators, such as reporting on near misses and
incidence, may result in a reduced focus on ensuring that health and Sutapa Pati: Conceptualization, Data curation, Formal analysis,
safety within the workplace are genuinely prioritised. Researchers sug­ Methodology, Writing – original draft, Writing – review & editing.
gested that this may lead to inferior performance via the current
emphasis on safety audits (Blewett and O’Keeffe, 2011). They explain Declaration of Competing Interest
this as a consequence of management’s efforts to obtain a good audit
performance instead of cleaning a holistic vision of improving work­ The authors declare that they have no known competing financial
place health and safety. One seminal study of preparing an advanced interests or personal relationships that could have appeared to influence
company-specific safety culture that goes beyond traditional command the work reported in this paper.
and control management systems recognised the need for flexibility,
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