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HomeCommercial LawsPractical Academic: Proposed Amendments to the PNGRB (ERDMP) Regulations: A Review

Practical Academic: Proposed Amendments to the PNGRB (ERDMP) Regulations: A Review

inkinccorporation@gmail.com
By inkinccorporation@gmail.com
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The last post in this blog delved on the PNGRB (ERDMP) Regulations, 2010. On 28 November 2025, the Petroleum and Natural Gas Regulatory Board (PNGRB) has invited comments on the proposed draft PNGRB (Codes of Practices for Emergency Response and Disaster Management Plan) Second Amendment Regulations, 2025 (“Proposed Amendments”). This post comments on the amendments proposed. 

Changes to Regulation 6: Regulation 6 of the ERDMP Regulations deals with classification of emergencies. The Proposed Amendments seek to correct a typographical error in that the Note to Regulation 6 classified the emergencies in terms of Roman numerals I, II and III (“Note : Level-I and Level-II shall normally be grouped as onsite emergency and Level-III as off-site emergency.”) while Regulation 6 referred to it in Indian numerals 1, 2 and 3. This typographical error has been sought to be corrected:

Existing

Proposed

6. Classification of emergencies.–

Emergencies can be categorized into three broad levels on the basis
of seriousness and response requirements, namely; –

(a) Level 1 : This is an emergency or an incident which

(i) can be effectively and safely managed, and contained within the
site, location or installation by the available resources;

(ii) has no impact outside the site, location or installation.

6. Classification of emergencies.–

Emergencies can be categorized into three broad levels on the basis
of seriousness and response requirements, namely; –

(a) Level I : This is an emergency or an incident which

(i) can be effectively and safely managed, and contained within the
site, location or installation by the available resources;

(ii) has no impact outside the site, location or installation.

(b) Level 2 : This is an emergency or an incident which
–

(i) cannot be effectively and safely managed or contained at the
location or installation by available resource and additional support is
alerted or required;

(ii) is having or has the potential to have an effect beyond the
site, location or installation and where external support of mutual aid
partner may be involved;

(iii) is likely to be danger to life, the environment or to
industrial assets or reputation.

(b) Level II : This is an emergency or an incident
which –

(i) cannot be effectively and safely managed or contained at the
location or installation by available resource and additional support is
alerted or required;

(ii) is having or has the potential to have an effect beyond the
site, location or installation and where external support of mutual aid
partner may be involved;

(iii) is likely to be danger to life, the environment or to
industrial assets or reputation.

(c) Level 3: This is an emergency or an incident with
off-site impact which could be catastrophic and is likely to affect the
population, property and environment inside and outside the installation, and
management and control is done by district administration. Although the
Level-III emergency falls under the purview of District Authority but till
they step in, it should be responsibility of the unit to manage the
emergency.

(c) Level III: This is an emergency or an incident with
off-site impact which could be catastrophic and is likely to affect the
population, property and environment inside and outside the installation, and
management and control is done by district administration. Although the
Level-III emergency falls under the purview of District Authority but till
they step in, it should be responsibility of the unit to manage the
emergency.

Correction of Errors reg. SIC & CIC: Regulation 14.2 of the ERDMP Regulations deals with the roles and responsibilities of the Chief Incident Controller (CIC) and the Site Incident Controller (SIC). Both CIC and SIC are appointed by the concerned entity.

CIC is defined in Reg. 2(1)(d) of the ERDMP Regulations to mean “the person who assumes absolute control of the unit and determines action necessary to control the emergency;” Reg. 14.2.1 provides that the CIC “shall have overall responsibility to protect personnel, site facilities, and the public before, during, and after an emergency or disaster.”

SIC is defined in Reg. 2(1)(ab) of the ERDMP Regulations to mean “the person who goes to the scene of the emergency and supervises the actions necessary to overcome the emergency at the site of the incident;“. 

The below diagram in Reg. 14.1 of the ERDMP Regulations provides the organisational chart for emergency response:

The next major amendment in the Proposed Amendments is to correct a typographical error  in Reg. 14.2.2 which actually lists the responsibilities of SIC but wrongly states that the responsibilities “of the Chief Incident Controller…”. The responsibilities of the CIC are already listed in Reg. 14.2.1:

Existing

Proposed

14.2.2 Site Incident Controller (SIC)

The Site Incident Controller shall be identified by the Site
Incident Controller and will report directly to him. SIC should be nominated
by the entity in each shift 24 hrs. Responsibilities of the Chief
Incident Controller shall include but not limited to the following…

14.2.2 Site Incident Controller (SIC)

The Site Incident Controller shall be identified by the Chief
Site Incident Controller and will report directly to
him. SIC should be nominated by the entity in each shift 24 hrs.
Responsibilities of the Chief Site
Incident Controller shall include but not limited to the following:

Changes to Siren Codes: Regulation 14.2.5.9(c) dealt with Siren Codes. While dealing with Emergency Level III, the Regulation wrongly stated that “waiting siren” had to be given. It was supposed to be a “wailing siren”. This has been corrected:

Existing

Proposed

14.2.5.9           Siren
Codes.

…

(2)       Emergency siren code
should be as follows, namely:

…

(c)        Emergency Level III-
Same type of siren as in case of Level-II but the same will be sounded for
three times at the interval of one minutes i.e. (waiting siren 2min +
gap 1min + siren 2min +gap 1min +waiting siren 2min) total duration
of disaster siren to be eight minutes.

14.2.5.9           Siren
Codes.

…

(2)       Emergency siren code
should be as follows, namely:

…

(c)        Emergency Level III-
Same type of siren as in case of Level-II but the same will be sounded for
three times at the interval of one minutes i.e. (wailing siren of
2min + gap of 1min + wailing siren of 2min + gap of 1min +waiting siren of
2min) total duration of disaster siren to be eight minutes.

Also, there was a duplication in Regulation 14.2.5.9(c). Hence the clause in sub-regulation after the emergency siren code and remaining clauses in this sub-Regulation have been renumbered:

Existing

Proposed

14.2.5.9           Siren
Codes.

…

(2)       Emergency siren code
should be as follows, namely:

…

(c)        ALL
CLEAR: Straight run siren for two minutes.

(d)       TEST:
Straight run siren for two minutes at frequency at least once a week

(e)        Public
address system should be provided with message.

14.2.5.9           Siren
Codes.

…

(2)       Emergency siren code
should be as follows, namely:

…

(d)       ALL
CLEAR: Straight run siren for two minutes.

(e)        TEST:
Straight run siren for two minutes at frequency at least once a week

(f)        Public
address system should be provided with message.

Changes to Cl. 19 reg. Medical Facilities: It was not clear from the existing Reg. 19 if details of burn treatment wards with number of beds are to be provided in the emergency response plan. It is now proposed to be clarified this these details are also to be included:

Existing

Proposed

19.0     Medical Facilities.

Details of medical facilities to be provided in the ERDMP as per the
following:-

19.0     Medical Facilities.

Details of medical facilities (including details of Burn
treatment wards with number of beds) to be provided in the
ERDMP as per the following:-

Changes in Regulation 24: Reg. 24 (Action after reporting of incident by the entity) contains substantive amendments. The existing Reg. 24(6) is sought to be deleted and replaced by a new Reg. 24(6) on actions to be taken by an entity after an incident. These amendments require the entity to submit explanation for lapses/ violations that resulted in/ caused the Major incident, constitute an internal committee, take appropriate disciplinary or administrative action against the personnel
or contractor/agency found responsible and disburse compensation in case of incidents involving any fatality or permanent disability:

Existing

Proposed

 

24.0     Action after
reporting of incident by the entity

…

(6) Entity shall ensure the following in case of each Major incident:

a. Submit explanation for lapses or violations that resulted into or
caused the Major incident, within two months from submission of the Final
Incident Investigation Report.

b. Constitute of an internal committee to fix responsibility for each
major incident and accountability for lapses or violations, at the grassroot,
managerial, and executive levels, within one month from submission of the
Final Incident Investigation Report. This internal committee should submit
its report to concerned Director of entity, within four months from date of
its constitution.

c. Take appropriate disciplinary or administrative action against the
personnel or contractor/agency found responsible within three months from
submission of internal committee report as per clause (b) above.

d. Disburse adequate compensation in case of incidents involving any
fatality or permanent disability.”

The new Reg. 24(7)(a) provides for complying with the recommendations of the Incident Investigation Committee at all its locations within time bound
manner and to undertake all necessary measures to prevent recurrence of
incidents. The new Reg. 24(7)(b) provides for action taken report.

Existing

Proposed

24.0     Action after
reporting of incident by the entity

…

(6) The entity shall take necessary measures to prevent the
recurrence of such incidents, and forward the action taken report to be the
part of the report of such enquiry committee duly vetted by the Board of
Directors of the entity of the Board.]

24.0     Action after
reporting of incident by the entity

…

“(7) (a)The entity shall ensure compliance of all recommendations of
the Incident Investigation Committee at all its locations within time bound
manner and to undertake all necessary measures to prevent recurrence of
incidents.

(b) Nominated Director of the entity shall ensure submission of the
Action Taken Report (ATR) on compliance of recommendations, measures taken to
prevent recurrence of incidents, action w.r.t. sub-regulation (6) above, etc.
along with the Final Incident Investigation Report, for deliberation of the
Board of Directors (of the entity) and submit
the Minutes of Meeting (MoM)/outcome of the meeting, to the Board (PNGRB) as
per following timelines:

 

S No.

Details

Timeline (from the date
of submission of Final Incident Investigation Report)

1

Action w.r.t.
sub-regulation (7)(a) as above

Two months

2

Action w.r.t.
sub-regulation (6)(a) as above

Two months

3

Action w.r.t.
sub-regulation (6)(c) & (d) as above

Nine months

In sum, substantial amendments have been made in Reg. 24 of the ERDMP Regulations. 



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