Post on 08-Apr-2018
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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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2.0 MATERIAL BALANCE
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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2.0 MATERIAL BALANCE
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.