environmental safety management

8/6/2019 environmental safety management

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Environmental

compliance


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Environmental Issues In Industry

Industrial Environmental Issues

IndustrialPollution

Air, Water, SW

& HW

Chemical Accidents

Process safetyHandling , Storage

and Hazardous

materials

Occupational

healthprocessing

handling

emissions

Impacts on Ecosystems and the economy

Impacts on communities

and property

Impacts on

workers


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Why Environmental Laws?

The basic intention is to provide a level playing field forindustry so that it can contribute to a better quality of life

without depleting resources or damaging the environment.

Attention to permitting systems.

Evolving self-regulatory system.

Monitoring compliance needs.

To look for new trends & opportunities for maximizing

compliance and its effectiveness.

To help MoEF in meeting obligations under international

agreements like Basel Convention, Montreal Protocol etc.

To achieve this, Industry need to set up a Effective

Compliance and Enforcement Program incorporatingfollowing key elements-


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ENVIRONMENTAL REGULATIONS IN INDIA

Public Liability Insurance (PLI) Act 1991,& rules thereunder

Water (P & C P) Act, 1974, & rulesthereunder.

Water (P & C P ) Cess Act, 1977, & rules

thereunder.Air (P & C P) Act, 1981, & rulesthereunder.

Environment (Protection ) Act,1986, AnUmbrella Act, & rules thereunder.


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Solid Wastes (Management & Handling) Rules

2000.

Rules under the Environment (Protection )Act,1986

Hazardous Wastes (Mgt & Handling) Rules

1989 with amendment rules, 2000.

MSIHC (manuf, stor & import of haz. Chem.)

Rules 1989, with amendment rules, 2000.Bio-Medical Waste (Management & Handling)

Rules 1998.

Ozone Depleting Substances (Regulation and

Control) Rules, 2000.


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BatteryWastes (Management &Handling) Rules 2001.

Industrial siting guidelines

Clean technology guidelines

EMP guidelines etc.Coastal Regulation zone notification

Submission of Environmental Statement

(Audit) Report to SPCB.

Guidelines & Notifications:

Noise Pollution (Regulation and

Control) Rules, 2000.


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EIA notification and Policy issues

Securing Environmental Clearances (EC)

for the projects listed in the schedule. (list of 29industry type)

Compliance to EIA notification, rapid &

detailed EIA report submission. (including EMP, DMP,Health surveillance issues etc.)

Public Hearing as a part of EC. (involving public indecision making)


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The Factories Act & RulesMotor Vehicles Act & Rules,

The Petroleum Act & Rules, 1976

The Inflammable Substances Act, 1952

Import (Control) Act, 1947Dock Workers (Safety, Health & Welfare)

Act, 86.

The Explosives Act & Rules

Gas Cylinders Rules, 1981

Static and Mobile Pressure Vessel(unfired) Rules, 1981

Boiler Act etc.

Other Environment related regulations


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ENVIRONMENTAL TREATIES

Framework Convention

Vienna Convention (Ozone Layer)

Montreal Protocol (ODS)

Basel Convention (trans boundary movement of Haz. Wastes)

Convention on Biological Diversity

Convention on International Trade in Endangered Species

Convention on Conservation of Nature in the South Pacific Draft Basel Rules of Procedure

1994 Draft Declaration ... Human Rights and the Environment

Decisions Adopted by the Conference of the Parties to the Basel

Convention

UN Law of the Sea Convention 1982

WRI- International Agreements and Conventions on

Environment

Rio Declaration

Multilateral Environmental Treaties

Environmental Treaties and Resource Indicators Service


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Policy Statement for Abatement of Pollution

Issued in 1992 by MoEF

Stress on the preventive aspects

Technological inputs to reduce industrialpollution

Integrate environmental considerations at alllevels of decision making


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Policy Statement for Abatement of Pollution

Steps to meet these objectives are:-

Prevent pollution at source (3p)

Encourage, develop & apply the bestavailable practicable solutions

Ensure that polluter pays for the pollutioncontrol arrangement (3p)

Focus protection on heavily polluted areas

Involve the public in decision making(public hearing)

Increase the safety of industrial operations


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Preamble (Water Act, 1974):

An Act to provide for the prevention &Control of water pollution and themaintaining or restoring of wholesomenessof water bodies.

Ground water

River water

Lakes

Estuaries, creeks and sea water


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Compliance needs (i.e. Checklist)

has C to E (Sec. 25)

needs EC and has EC (EIA notification)

Whether the industry

meets compliance under other

environment related regulations (Factories Act,Explosives Act,Boiler act, Petroleum Act, CRZ notification if applicable etc.)

meets the siting guidelines


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holds valid consent(validity G,O, R)

Uses water in compliance to figuresprovided under Cess Act (Water uses, inter-relations)

Figures of product manuf, water uses,

WW discharges match with consentedfigures (often reference to old consent needed)

Installs/runs the treatment facility tomeet stds.

Installs & runs the disposal facility &meets stds. (values & designated mode)


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meets monitoring conditions (establishing Env.Cell, frequency, parameters, proper sampling, MINAS, CAP etc.)

Develops green belt in accordancewith the condition of consent (33% of the landuse)

Submits report to the Board/Government as per stipulations.

Past record of Legal notices if any.(habitual defaulter, refusal, withdrawl, suspension of consent, Pendency oflaw suits in the court of law. )

meets other conditions of consent

(relating to compliance to other acts, rules etc.)


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Powers Under Water (P & C. P. ) Act 1974

State water laboratory(sec. 17 (2))

Powers of Closure (Sec. 33 A)Sec. 18 : Powers to give directions

2[1)] In the performance of its functions

(a) the Central Board shall be bound by such directionsin writing the Central Government may give to it; and

(b) every State Board shall be bound by such directionsin writing as the Central Government or the State

Government may give to it:

Construction of ETP or making mandatory tobecome a member of CETP (Sec. 30)

Power of Entry(sec. 23)


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Powers Under Air (P & C. P. ) Act 1981

Sec. 19 : Power to declare air pollution controlareas,

Sec.20 : Power to give instructions for ensuring

standards for emission from automobiles.

Sec.21 : Restrictions on use of certain industrial

plants (C to E and C to O).

Sec.22A : Power of Board to make application to

court for restraining person from causing airpollution.

Sec.24 : Power of entry and inspection


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Sec. 28 : State Air Laboratory

(a) establish one or more State Air Laboratories; or

(b) specify one or more laboratories or institutes as

State Air Laboratories to carry out the functions

entrusted to the State Air Laboratory under this Act.

Sec.26 : Power to take samples of air or emission

Sec.31 A : Power to give directions

Sec.25 : Power to obtain information


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Environmental Audit


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Submission of environmental audit report.

Every person carrying on an industry, operation or process

requiring

!consent under Sec.25 of the Water (P and C P) Act, 1974 or!Consent under section 21 of the Air (P and C P) Act , 1981 or

both

!or authorization under the Hazardous Wastes (Management

and Handling) Rules, 1989

shall submit an environmental statement (audit) report for the

financial year ending the 31st March in Form V to the concerned

State Pollution Control Board every year.

Rule 14. Of EP Act 86


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What is meant by Environmental Audit ?

Environmental Audit is defined as-

A basic management tool comprising asystematic, documented, periodic andobjective evaluation of how wellenvironmental organization, management

systems and equipment are performing.

(source UNEP: Industry& Environment)


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Audit

- Not designed to criticize or blame

- No procedures are perfect_ need changeperiodically

- QA, QC & EMS forms the basis for improving.

Quality of product or

to ensure to improve the procedures to

improve the quality

Meet statutory compliance's

Image of the Company


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PLANNING THE AUDIT

AuditManual

Check Lists AuditorTraining

Conducting the Audit

Audit Report

Audit Recommendations &Implementation


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STEPS IN WASTE AUDITING

THREE STEPS :

1.0 PRE -ASESSMENT

2.0 MATERIAL BALANCE

3.0 SYNTHESIS

AN OUTCOME IS A WASTE REDUCTIONPLAN (WRP)


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1.0 PRE -ASESSMENT

Audit & Preparation

Listing unit operations

Constructing a process flow diagram


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Dr. S. R. Choudhari, Consultant & Advisor

Pre Assessment is basically a collection ofinformation of the type:

Mat rial t rage

Wastest rageManufacturing Waste lendingWasteair emissi ns Waste ater emissi nsOther releases (noise,

W, Wetc)

Waste treatment anddisposal

Recycling Processcategories

Processdescription,physical material add

Equip listspecifications

Operatingmanuals Piping instrument

diagramsFacility layoutplans

QA QC labs

Utilities, material and

energybalance

Plant, cleanupsteps

operations


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Step 1

Determining inputs

Recording water usages

Measure current levels of waste R & R

Quantifying process outputs

Accounting for off-site wastes , R & RAccounting for WW

Assembling input & out put informationfor unit operations

Accounting for gaseous emissions


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Step 2

Designing a preliminary Material

balance for unit operations

Evaluating the Material Balance

Refining the Material Balance


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Examining possible waste reduction measures

Targeting & characterizing problems of waste

management

Segregation

Developing Long Term Waste Mini options

Environmental and Economic Evaluation of Waste

Reduction Options

Developing and Implementing an EnvironmentalAction Plan (EAP)

Reducing Waste and Increasing production

Efficiency

3.0 SYNTHESIS


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Steps to prepare Environmental Statement :

1.0 Formation of an EnvironmentalExamination Team.

2.0 Listing of unit operations & constructingProcess Flow Diagrams.

3.0 Material balance, balancing process inputsand outputs.

4.0 Synthesis & Identification of avenues forwaste reduction.

5.0 Ensuring compliance with the law.


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Form V under Rule 14 of the EP Rules


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Waste management rules are extremely

complex, and the facility can be subjected toseveral sets of environmental regulations,on Central, State, and Local levels.

Documentation and record keepingrequirements have now become extensive.

It is a widelyheld belief in the industry thatwith such complexities, a diligent and well-

trained inspector can find non-complianceissues at any facility, given sufficient timeand effort.


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Thorough reading of the consent letter(compliance to environment related Laws)

Thorough Examination & Analysis ofEnvironmental Audit Report (IER, Legal Register)

Checking compliance w.r.to the consentconditions and provisions of the Acts

Achieving 100% compliance is difficult

Ignorance of Law (Battery Rules, operation w/o valid consent &willful approach)

Non compliance's under environment relatedlaws ( accidents, rupture of tanks, accidental discharges)

Observation of general Conditions ( Green Belt,TREMCARD, authorized transporter, submission of reports, manifest etc.)


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Ensuring compliance is not the job of theGovernment alone.

Improper maintenance of Pollution ControlEquipments and treatment /disposal

facilities. (contravening the conditions of consent)

Ignoring siting policy(A1 zone, bank of the river, CRZ area &,sensitive area)

Habitual default (avoiding Pollution control costs, willfuldischarges of metal wastes, fraudulent intentions)

PIL/Human rights, Calling attention ofNGOs (illegal dumping, illegal traffic)

Indiscriminate disposal of solid andhazardous wastes. (Ground water pollution)


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Industry managers have an important role to play inmeeting these compliance need.

They need to install self-monitoring systems &develop internal EMS in particular, auditing &reporting schemes.

Failure results in litigation in what so ever form i.e. -Legal notice

-Withdrawal, suspension of permits-Refusal to renewal of permits-Directions under the appropriate provisions of the act/s-Prosecutions etc,

depending on the nature of non compliance and itsseverity.

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