ISO 14001:2004 AND OHSAS 18001:2007

COMPLIANCE STATUS REPORT

OF

BATTERY SUPPLIERS AND RECYCLERS OF

IDCOL SHS PROGRAM

March, 2014

Prepared by

Infrastructure Development Company Limited

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1. INTRODUCTION

Infrastructure Development Company Limited (IDCOL) is committed to comply with required

environmental and social safeguards. It has adopted an Environmental and Social Safeguards

Management Framework (ESMF) of for its solar home system (SHS) program. According to this

ESMF, all approved battery suppliers in IDCOL SHS program have to be ISO 14001:2004 and

OHSAS 18001:2007. ISO 14001:2004 is an internationally recognized standard about

environmental management and OHSAS 18001:2007 is worldwide accepted standard for

maintaining occupational health and safety aspects. The basic requirements of these two

standards are mentioned in Annex –1 of Appendix -A. There are 17 battery suppliers of which

16 are local and the remaining one is Japan Solar Tech, which sells imported batteries. In

addition, there are three en-listed expired battery recyclers in IDCOL SHS Program, who also

require to be ISO 14001:2004 and OHSAS 18001:2007 compliants. These requirements are in

addition of the requirements of the Department of Environment, Bangladesh.

To assess the status of implementation of environmental and occupational health safety

management system, the respective official of IDCOL half-yearly visits all three recycling plants.

In case of battery manufacturing plant, there is a requirement to monthly visit. Based on the

primary findings and secondary information as are provided by the battery manufacturers and

recyclers, this Compliance Status Report has been prepared.

2. OBJECTIVES

The objectives of this compliance status Report are as follows:

To assess the commitment of management of manufacturers and recyclers about

environmental and occupational health safety sytem;

To assess the availability of required infrastructure like ETP and ATP;

To assess the status of documentation of required guidelines;

To assess the availability of medical facility;

To assess the gap in respect of the actual scenario and desired level;

To assess the areas where relevant stakeholders can support the recyclers and

manufacturers to implement environmental and occupational health safety system in a

satisfactory manner.

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2. LOCATION AND AREA OF BATTERY MANUFACTURING PLANTS

Among the aforesaid 16 (sixteen) battery suppliers, 13 battery suppliers have their battery

manufacturing factories in Dhaka Division, two are in Khulna Division and only one is in Sylhet

Division. HAMKO Battery has the largest battery manufacturing and recycling plant in respect of

area (an area of about7.5 acres) and scale of production But the smallest manufacturing unit is

owned by Z by A Corporation (an area of about 0.05 acre). In the following Table 01, the

location and area of the factory of 16 battery suppliers are provided.

Table 1: Location and area of battery manufacturing and recycling plants

Battery supplier Location of factory Area in acre

Rahimafrooz Accumulators Ltd.

West Panisail, Zirani Bazar, Gazipur 4.00

Panna Batteries Ltd. West Rasulpur, Kamrangir Char, Dhaka-1211 6.50

HAMKO Batteries Ltd. BSCIC I/A Shiromoni, Khulna 7.50

Electro Batteries Co. Ltd.

Boro Rangamatia, Durgapur, Ashulia, Savar, 5.00

Rimso Batteries Ltd. Plot#21, Kadamtoly Road Shyampur I/A, Dhaka-1204 0.20

Euro Battery Varardi, Kachkura Bazar, Uttar Khan, Uttara, Dhaka-1230

0.50

Z by A Corporation 403-404, Tejgaon I/A, Dhaka-1208 0.05

White Products Ltd. Plot 1142-1143, Nowjore, Gazipur 3.30

ECO Batteries Ltd. Uzilab, Sripur, Gazipur 1.00

JCo. Batteries Ltd. Plot no. S-6 , BSCIC I/A , Ruhitpur, Keranigonj, Dhaka. 0.25

Navana Batteries Ltd. CDA Plot No. – 3(P) & 4(P), Fouzderhat I/A, Chittagong

3.80

SunTec Batteries Ltd. BSCIC I/E, Khadimnagor, Sylhet 0.25

Gel Tec Batteries Ltd. Raj Fulbaria, Savar 0.20

Tamim Batteries Ltd. 111, Pobahati Road, Jhenidah-7300 1.20

A&P Batteries Ltd. Chaparbandh (Adampur), 2nd gate to Sonargaon Museum Road, Sonargaon, Narayanganj

0.75

Confidence Batteries

Ltd.

Brahmmanbagh, Mohajampur, Narayanganj 3.00

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3. PRODUCTION PROCESS

The production process of lead-acid battery in respect of required materials, basic chemistry

and manufacturing steps are briefly described in the following sections.

Required materials

For manufacturing a lead-acid batteries a number of materials are required including Sulfuric acid, Lead (red, pure, antimonial) Acrylic fiber, Carbon black, Expander, TK Oil and so on. The requirements of these materials varies with the capacity of batteries. In the following Table 02, a list of major materials are presented in respect of various capacity of batteries.

Table 02: Location and area of battery manufacturing and recycling plants

Sl. No.

Materials Capacity of battery in AH 30 55 80 100 130

01 Red Lead 0.5 kg 0.90 kg 1.30 kg 1.90 kg

2.80 kg

02 Pure Lead 3.8 kg 6.2 kg 8.7 kg 11.6 kg

14.0 kg

03 Antimonial Lead

4.5 kg 8.0 kg 10 kg 11.5 kg

11.7 kg

04 Sulfuric Acid 6.6 L 8.0 L 11 L 13 L 15 L

Source: Informal (Engr. Sahhidul Islam, Engineering Complex Limited)

Basic Chemistry

The basic chemistry of lead-acid battery is mainly the chemical reaction among lead di-oxide, lead and sulfuric acid as is depicted in Figure 01.

Figure 01: Basic chemistry of lead-acid battery

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Battery manufacturing process

Manufacturing of a lead-acid battery includes a number of steps as are shown in the following Figure 02.

Figure 02: Manufacturing process of al lead-acid battery

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3. BRIEF DESCRIPTION OF MANUFACTURING PLANTS

A brief description of IDCOL en-listed battery manufacturing plants is provided in the following section in light of some relevant parameters.

Number of Workers

At present the highest number of workers is operating in Panna Batteries Ltd (585). Thereafter, it is HAMKO and Rahimafrooz having about 500 full time workers. The detail list of workers in terms of gender is provided in the following Table 03. In case of Rahimafrooz, HAMKO and Panna Battery Ltd. the number of workers include both manufacturing plant and recycling plant

Table 03: Number of workers based on gender

Factory Number of staff Total Male Female

Rahimafrooz Ac. Ltd. 500 500 -

Panna Batteries Ltd. 585 550 35

HAMKO Batteries Ltd. 500 470 30

Electro Battery Co. Ltd 230 230 -

RIMSO Battery 150 130 20

Z by A Corporation 30 30 -

Euro Battery Ltd. 54 52 2

White Products Ltd. 202 201 01

ECO Batteries Ltd. 33 33 -

JCo. Batteries Ltd. 33 25 8

Navana Batteries Ltd. 220 220 -

SunTec Batteries Ltd. 177 167 10

Gel Tec Batteries Ltd. 38 37 1

Tamim Batteries Ltd. 45 45 -

A&P Batteries Ltd. 77 72 5

Confidence Batteries Ltd. 330 330 -

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Capacity of production

At present the highest number of battery is manufactured by HAMKO Battery. Their monthly production is about 70,000. But in consideration of manufacturing the solar batteries, it is Panna (30,000). The production of battery and the amount of required lead is depicted in the following Table 04 as is collected informally.

Table 04: Average monthly production and required lead

From the above Table 04, it is difficult to correlate with the quantity of required lead and quantity of battery production. Because different suppliers produce battery of varying capacity requiring different capacity of lead as is depicted in Table 02. In addition, the use of automatic technology is another factor to determine the amount of required lead. All of the battery suppliers were found to use manual and semi-automatic process except Rahimafrooz, Panna, Sun Tec, Electro and HAMKO Batteries. Their manufacturing plant seems to be mostly automated. But the most satisfactory automated technology has been observed in Confidence Batteries Ltd.

Factory Type of battery production

Average total Production /month

Production of solar battery/month

Required lead/month

Rahimafrooz Ac. Ltd. Solar, easy bike and IPS

40,000 15,000 450

Panna Batteries Ltd. Solar, auto and easy bike, IPS

65,000 30,000 750

HAMKO Batteries Ltd. Solar, auto, easy bike, auto, IPS

70,000 20,000 1000

Electro Battery Co. Ltd Solar 5,000 5,000 90

RIMSO Battery Solar, IPS 8,000 6,000 110

Z by A Corporation Solar 500 500 10

Euro Battery Ltd. Solar 3,000 300 50

White Products Ltd. Solar, Auto 6,000 2,000 120

ECO Batteries Ltd. Solar, IPS 1000 750 25

JCo. Batteries Ltd. Solar, IPS 2,500 2,000 40

Navana Batteries Ltd. Solar, IPS, Auto 30,000 4,000 275

SunTec Batteries Ltd. Solar, IPS, easy bike, rickshaw, auto

9,500 500 150

Gel Tec Batteries Ltd. Solar 1,000 500 20

Tamim Batteries Ltd. Solar 1,000 1,000 26

A&P Batteries Ltd. Solar 5,000 5,000 60

Confidence Batteries

Ltd.

Solar, IPS, easy bike, rickshaw, auto

30,000 10,000 450

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Among the 16 battery suppliers Rahimafrooz, Panna, HAMKO, RIMSO, A&P, White Products,

J.Co, Sun Tec and Gel Tec have female staff, of which mostly are engaged in low labour

intensive areas like filling, pasting. In addition, in a number of plants , female staff were found to

work in kitchen and dining.

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4. ISO 14001: 2004 AND OHSAS 18001:2007 COMPLIANCES

The ISO 14001:2004/2005 and OHSAS 18001:2007 compliance status in terms of certification

agency, date of issuance and expiration of 16 Battery manufacturing plants are mentioned in the

following Table 05.

Table 05: List of accreditation agency in respect of battery manufacturing plant

Battery supplier

Accreditation agency Accreditation issue date Accreditation validity date

Parent Subsidiary

ISO 14001:2004

OHSAS 18001:2007

ISO 14001:2004

OHSAS 18001:2007

Rahimafrooz Ac. Ltd.

IAF

Bureau Veritas 28 Jun 2010 15 Sep 2011 27 Jun 2013 13 Jun 2014

Panna Batteries Ltd.

AJA 6 Jul 2011 1 Nov, 2010 31 Oct, 2013

6 Jul 2014

HAMKO Batteries Ltd.

ANAB SAI Global 18 Jan 2012 22 Dec 2011 15 Jan 2015 22 Dec 2014

Electro Battery Co. Ltd.

IAF ISOQAR 5 Mar 2012 5 Mar 2012 5 Mar 2015 5 Mar 2015

Rimso Battery AJA 7 Dec 2011 6 Jan 2012 23 Sep 2014 6 Jan 2015

Euro Battery Ltd.

URS 13 Jan 2012 13 Jan 2012 12 Jan 2015 12 Jan 2015

Z by A Corporation

AIAO BMQR 22 Dec 2011 22 Dec, 2011 21 Dec, 2014

21 Dec 2014

White Products Ltd.

DNV 17 May 2011 17 Dec 2011 17 May 2014

16 Dec 2014

ECO Batteries Ltd.

URS

17 Sep 2013 17 Sep 2013 16 Sep 2016 16 Sep 2016

JCo. Batteries

Ltd.

AJA 1 Feb, 2012 4 Jun, 2012 28 Jan 2015 4 Jun, 2015

Navana

Batteries Ltd.

Bureau Veritas 27 Mar 2012 2 Jul 2012 26 Mar 2015 01 Jul 2015

SunTec

Batteries Ltd.

AJA 9 Oct 2012 7 Oct 2012 2 Oct 2015 7 Oct 2015

Gel Tec

Batteries Ltd.

Care Certification

24 Mar 2012 24 Mar 2012 23 Mar 2015 23 Mar 2015

Tamim

Batteries Ltd.

AIAO BMQR 18 Jun 2012

19 Jun 2012 18 May 2015

19 May 2015

A&P Batteries

Ltd.

IAF AJA 23 Dec 2012 23 Dec 2012 22 Dec 2015 22 Dec 2015

Confidence

Batteries Ltd.

DAS Certification

15 Jan 2014 15 Jan 2014 14 Jan 2017 14 Jan 2017

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5. MEDICAL FACILITY

It is appreciable that the battery manufacturers and recyclers aware about the medical facility of workers. All battery manufacturers have arranged weekly medical check-up facility except Gel Tec, ECO and Z by A Corporation. Z by A has arranged monthly check-up facility. ECO Batteries and Gel Tec are in the process of engaging doctor.

Table 0 6: Arrangement of medical facility

Battery supplier Arrangement of Medical Facility

Medicine facility

Rahimafrooz Ac.Ltd. Two times per week medical check-up

All medical facility

Panna Batteries Ltd. Weekly Basic medicine

HAMKO Batteries Ltd. Weekly Basic medicine

Electro Battery Co. Ltd.

Weekly

Basic medicine

Rimso Battery Ltd. Weekly

Basic medicine

Euro Battery Bi-weekly Basic medicine

Z by A Corporation Weekly Basic medicine

White Products Ltd. Weekly Basic medicine

ECO Batteries Ltd. In the process of engagement

Basic medicine

JCo. Batteries Ltd. Weekly Basic medicine

Navana Batteries Ltd. Weekly Basic medicine

SunTec Batteries Ltd. Weekly Basic medicine

Gel Tec Batteries Ltd. In the process of engagement Basic medicine

Tamim Batteries Ltd. Part-time Basic medicine

A&P Batteries Ltd. Weekly Basic medicine

Confidence Batteries

Ltd.

Weekly Basic medicine

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6. RECYCLING FACILITY

At present Rahimafrooz, Panna Battery and HAMKO have independent recycling facility

with ISO 14001:2004/2005 and OHSAS 18001:2007 compliant. The list of accreditation

agency, date of issuance of compliance certificate and date of expiration are mentioned

in the Table 7.

Table 7: List of accreditation agency in respect of battery recyclers

Battery supplier

Accreditation agency Accreditation issue date Accreditation validity date

Parent

agency

Subsidiary agency

ISO 14001:2004

OHSAS 18001:2007

ISO 14001:2004

OHSAS 18001:2007

Rahimafrooz IAF

Bureau Veritas 8 Mar 2013 8 Mar 2013 7 Mar 2016 7 Mar 2016

Panna Battery Ltd

AJA 5 Jan 2013 6 July 2013 7 Jan 2016 6 Jul 2014

HAMKO Battery Ltd.

ANAB SAI Global 18 Jan 2012 18 Sep 2012 15 Jan 2015

2 Aug 2015

HAMKO has two rotary furnaces of which one is with capacity of 5 ton and the other one is 8

ton. There are 2 kettles with capacity of 10 ton lead. The monthly capacity is 500 ton, with an

assumption car battery 70% and 30% is inverter, solar and others. Batteries are coming without

acid, breaking is manually done outdoors and under roof.

In Rahimafrooz, there are one rotary furnace with capacity of 10 ton and two kettles with 10 ton

capacity. The monthly capacity is 250 ton lead per month.

In Panna Battery, there are two rotary

furnaces with capacity of 8 ton and two

kettles with capacity of 10 ton. The monthly

capacity is 500 ton lead per month, 20 ton

lead per day and 5 days per week.

Breaking of batteries is done without roof,

very dusty working condition.

For recycling, the other suppliers have

made formal agreement with these three

recyclers, which conforms that the

recyclers will recycle the expired batteries

as are submitted by these suppliers.

In case of EHS compliance, there was requirement to significantly improve the recycling plant of

Panna. Accordingly, they have been found to adopt required mitigation measures as are shown

in Appendix-C (Annex-4).

Figure 03: Basic recycling process

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The Plastic casing of expired batteries are broken manually by using hammer. Thereafter, the

remaining electrolyte is pour in a tank having water to neutralize the acid. After that, the

neutralize acid is let out through a drain to the nearby tertiary collector like canal. The lead bar is

then taken to the recycling plant for melting and casing is crushed to for plastic chips as are

required for manufacturing a new battery casing. The expired battery breaking process is shown

as follows through Photographs 01-04.

Photograph 01: Separation of cover by

manually Photograph 02: Pouring the electrolyte to

neutralization tank

Photograph 03: A view of neutralization tank Photograph 04: Separation of lead bar and

separator

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7. EFFLUENT TREATMENT PLANT

All manufacturing plants have effluent treatment plant (ETP) facility. But there is difference

among technology, efficiency and effectiveness. In this regard, there could be an environmental

audit to assess these ETP and formulate required improvement initiatives. The arrangement of

ETP in terms of capacity and sludge disposal arrangement is shown in Table 08.

Table 08: Arrangement of ETP

Battery supplier Capacity in m3/day Sludge management

option

Rahimafrooz Ac. Ltd. 40 Use as landfill

Panna Batteries Ltd. 10 Do

HAMKO Batteries Ltd. 40 Do

Electro Battery Co. Ltd. 20 Do

Rimso Battery 5.0 Do

Euro Battery 2 Do

Z by A Corporation 0.5 Do

White Products Ltd. 24 Do

ECO Batteries Ltd. 5.0 Do

JCo. Batteries Ltd. 15 Do

Navana Batteries Ltd. 3.5 Do

SunTec Batteries Ltd. 8.0 Do

Gel Tec Batteries Ltd. 2.0 Do

Tamim Batteries Ltd. 10 Do

A&P Batteries Ltd. 2.0 Do

Confidence Batteries Ltd 30

DO

8. AIR TREATMENT PLANT

All battery supplies and expired battery recyclers of IDCOL SHS have made available of air

treatment facility. But there is difference of technology and effectiveness. So, there is necessity

of providing training support on this aspect.

9. STATUS OF BASIC EMS AND OHS COMPLIANCE

Table 9: Compliance of basic EMS and OHS aspects

NIP=Need improvement (1), MS=Moderately satisfactory (2), S=Satisfactory (3)

The status of EMS and OHS compliances by manufacturers and recyclers in respect of some

basic parameters are shown in the abovementioned Table 9, where NIP, MS and S stand for

Need Improvement, Moderately Satisfactory and Satisfactory respectively with a sample value

1, 2 and 3 respectively. Based on the Table 9, it can be said that Euro Battery, Z by A, Gel Tec

and Tamim Batteries Ltd. need significant effort to reach the level of satisfaction.

Battery suppliers and

recyclers

Application of PPE

Status of housekeeping

Training on EMS

and OHS

Availability of trained

professional

Status of documentation

Operation of ETP

and ATP

Arrangement of fire

fighting

Score

Rahimafrooz Accumulators Ltd.

S S S S S S S 21

Panna Battery Ltd.

S MS S S S MS S 19

HAMKO Battery Ltd.

MS S MS MS S S S 16

Electro Battery Co. Ltd.

MS S S MS S S S 19

Rimso Battery Ltd.

NIP MS S MS S MS MS 15

Euro Battery NIP MS MS NIP S MS MS 13

Z by A Corporation

MS MS MS NIP NIP MS MS 12

White Products Ltd.

MS MS MS MS S S S 17

ECO Batteries Ltd.

MS MS NIP MS MS S S 15

JCo.

Batteries Ltd.

MS MS MS S S MS MS 16

Navana

Batteries Ltd.

S MS S S MS MS MS 17

SunTec

Batteries Ltd.

S MS S MS S MS S 18

Gel Tec

Batteries Ltd.

MS MS NIP NIP MS MS MS 12

Tamim

Batteries Ltd.

MS MS NIP MS MS S MS 14

A&P

Batteries Ltd.

MS S MS MS S S S 15

Confidence

Batteries Ltd.

S S S MS S S S 19

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10. RECOMMENDATIONS AND CONCLUSIONS

In general, the response of battery manufacturers and recyclers on EMS and OHS have been

observed as significantly positive. They have installed ETP, ATP and tried to ensure PPE

properly. But it assumes that in general there is inadequacy of trained professional on EHS in

Bangladesh. So, to reach a complete level of satisfaction, the relevant stakeholders are

requested to think over the following aspects because Figures 01-04, give clear message

about the adverse impact of improper management of lead:

To audit the capacity and effectiveness of ETP and ATP

To train about proper application of PPE

To aware about safe disposal of ETP sludge

To orient them with EHS management practice of developed countries

To monitor the lead content in blood of the workers working in the higher lead exposed area.

Figure 04: Impact of long term exposure to lead Figure 05: Early symptoms of lead

poisoning

Figure 06: Impact of lead poisoning to women Figure 07: Impact of lead poisoning to

children

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Appendix-A

Requirements of ISO 14001:2004 and OHSAS 18001:2007

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Annex-1: Major requirements of ISO 14001 and OHSAS 18001

Clause no.

Requirement Major issues in brief

4.1 General Requirements This clause requires to clarify whether the EMS system of client is properly adopted, maintained and updated?

4.2 Environmental Policy This clause requires to clarify whether the EMS system of client is communicated with well structured EMS Policy as is to be adopted and authorized by the top management of client?

4.3 Planning This clause requires to clarify whether the EMS system of client is based on a systematic planning like written procedures, hierarchy of risk management measures, process to disseminate information and regulations and so on ?

4.4 Implementation and Operation

This clause requires to clarify whether the EMS system of has made adequate arrangement to ensure proper implementation and operation through deployment of adequate number of competent personnel, regular capacity building arrangement, emergency preparedness measures and so on ?

4.5 Checking and Corrective Action

This clause requires to clarify whether the EMS system of has made adequate arrangement for continual improvement through proper regular checking and adopting corrective actions? In this regard, it is expected that there will be arrangement of performance measurement and monitoring mechanism; accidents, incidents, noncompliance and corrective and preventive actions review procedure; arrangement of keeping records and above all internal audits.

4.6 EMS Management Review

This clause requires to clarify whether the EMS system of has made adequate arrangement of keeping regular communication with the top management through regular management review meeting and keeping minutes of the meeting.

NB. The above table provides requirement of ISO 14001: 2004. However, the requirements of OHSAS are almost same but in case of environmental management system it deals with occupational health safety issues.

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Appendix-B

EHS Compliance of Battery Manufacturing Plants as have

been enlisted after July, 2012

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Annex 1- EHS Compliance of Tamim Batteries Ltd.

Photograph : Checking the first aid facility Photograph : Monitoring the operation of ETP

Photograph : A view of ETP Photograph : Aview of fume exhaust arrangement

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Annex 2- EHS Compliance of A&P Batteries Ltd.

Photographs : Different views of ATP system

Photograph: Application of PPE Photograph : A view of emergency exit plan

21

Annex 3- EHS Compliance of ECO Batteries Ltd.

Photographs: Different views of ATP system

Photographs: Different views of ETP system

22

Photograph: External fire fighting arrangement

Photograph: Internal fire fighting arrangement

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Annex 3- EHS Compliance of Confidence Batteries Ltd.

Photographs: Different views of ETP system

24

Photographs: Different views of ATP system

A-S Type Foam Type CO2 Type

Photographs: Fire fighting arrangement

25

Photograph: Evacuation Plan during disaster

Photograph: Application of signage

26

Photograph: Disclosure of compliance standard

Photographs: General washing and prayer facility

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Appendix-C

EHS Compliance of Panna Recycling Plant

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Annex 4- EHS Compliance of Panna Battery Recycling Plant

Photographs: Different views of Panna Recycling Pant