Environmental monitoring for compliance to EHS requirements
Dr. Nilesh. S. Amritkar, Managing Director, Envirocare Labs Pvt. Ltd., Thane
Ph.D. in MicrobiologyVice President – Association of Food Scientist & Technologist of India, Mumbai Chapter
“Pollution free world is every man’s birth-right”, one would say but to put things into perspective is it really the case? We have been granted the gift of pristine world at the very origin of our species, but our inquisitive mind has exploited every nook and corner of this planet. Yet we are saying – ‘yeh dil mange more’. This want of more has been creating environmental challenges to mankind in form of Global Warming and Pollution related health concerns. It is now unto us to prevent further deterioration of our mother earth by having stricter environmental legislations and following the best practices to monitoring various environmental aspects. This article talks about basic environmental regulatory compliance to be followed by Industry
KEYWORDS: Pollution, Environment, Workplace, Monitoring
Environmental pollution dates back to prehistoric era and archaeologists have found evidence of indoor air pollution in pre-historic caves in the form of soot deposits on ceilings. Roman and Greek era too depicted heavy metal contamination, especially in the form of lead. Catastrophic effects of emissions of radioactive and chemical warfare in World War II left all mankind in a poignant state. With this war, effects of environmental pollution became more and more evident.
Dark fog engulfed London on the eve of 5th December 1952 and killed over 12,000 civilians. Who knew that coal that was supposed to keep you warm at night would kill you! This catastrophe brought London to a standstill and eventually came to be known as the “Great Smog”, repercussions of which would never be forgotten.
The British Parliament passed two Clean Air Acts as a measure towards curbing air pollution, thus giving impetus to environmental legislations. Another major incident that brought mayhem was the Chernobyl Accident that took place on 26th April 1986. Explosion at Chernobyl, Ukraine wreaked havoc killing over 28 workers at the nuclear reactor due to exposure to radiation and approximately 6000 cases of thyroid cancer may be linked to this disastrous incident. History implicitly states that with the evolution of mankind, environmental effects too will evolve. Right from pre-historic times, man has exploited nature to meets his own avarice, climate change, global warming and resource depletion is nature’s vengeance for our deeds. As Charles Darwin says “It is not the strongest of the species that survive, nor the most intelligent, but the one most responsive to change”, we must change and protect our environment.
The 1960’s saw implementation of legislations for environmental protection globally, United States adopted National Environmental Policy Act in 1969 and in 1971 US Environmental Protection Agency (US EPA) was formed. International organizations such as US-EPA, World Health Organization (WHO), European Commission (EU), Australia and New Zealand Guidelines are constantly developing and amending environmental standards and guidelines.
India too has been struck by environmental cataclysm, most ruthless of all being the “Bhopal Gas Tragedy” also known as the worst industrial disaster of all times. At the dusk of 2nd December 1984, misery struck Bhopal where an accident at a pesticide plant released tons of highly noxious gas “methyl isocyanate”. What began as nausea, burning eyes and throat, ended in death for around 15,000 people over the years. Till today, the after effects are felt with the birth of a mentally or physically disabled child.
The genesis of environmental law in India was in 1974 with the Water (Prevention and Control of Pollution) Act of 1974. Central Pollution Control Board (CPCB) was established in 1974 under this act to prevent and control water pollution, key target of this act being industrial wastes. Another vital legislation was implemented in 1981 known as the Air (Prevention and Control of Pollution) Act, an outcome of the United Nations Conference held at Stockholm in June 1972. The prime function of this act was to curb atmospheric pollution.
The Ministry of Environment, Forest and Climate Change (MoEFCC), an Indian government ministry was founded in 1985 to plan, promote and coordinate the enforcement of forestry and environmental programmes. Despite the provisions of earlier environmental laws in the Indian Penal Code, Factories Act and The Indian Forest Act, need for a general legislation was felt due to lack of control over environmental quality and coordination between various legislations, ultimately resulting in the enactment of Environment (Protection) Act in 1986.
The cardinal purpose of this act was to protect and improve environmental quality and implement uniform laws across the nation. CPCB is the apex statutory organization and technical provider for the MoEF as per the provision of the Environment Protection Act (EPA). With the establishment of the EPA act, new functions were added to CPCB.
As the adage goes “With great power comes great responsibility”, EPA has vested Central Government with critical powers to ensure abatement of pollution and industrial debris. With the central objective to reduce environmental pollution significantly, Central Government has the power to enroot national programmes. In this regard, the board initiated National Air Monitoring Programme (NAMP) wherein ambient air quality is monitored in a vast network consisting of 332 operating stations encompassing 25 states and 4 union territories.
The principle goal of NAMP is to determine current air quality status. Based on this data, NAMP develops mitigation strategies in areas manifesting a rise the level of pollutants. CPCB also implemented Water Quality Monitoring Programme (WQMP), with the goal to collect statistical data on water quality.
This monitoring network comprises of 2500 stations that collects, collates and interprets water pollution data from various rivers, lakes, ponds, canals, creeks, wells as well as water treatment plants. Environmental protection entails protection of all biodiversity on Earth cognizant of this, the Central Government has power to restrict certain areas from industrial activities. Central Government is entitled with the most critical function i.e. the inspection of plants, premises and industrial sites to ensure compliance. Government officers can enter any facility and send samples to an environmental laboratory for analysis. Section 5 of this act gives an officer the right to prohibit or liquidate a facility on the grounds of non-compliance, however if any individual is aggrieved by this direction they can file an appeal to the National Green Tribunal. Technically sound statutory regulations are a must, hence central government also sets guidelines and manuals. CPCB along with State Boards organizes awareness programmes for knowledge dissemination to feed the goal of developing an environmentally pure country. However, the success of all these regulations and enforcement will depend on we the people – we need to have the concept of self-compliance rather than imposed-compliance by government officials. Putting environment first would only help sustainable growth of any business.
2. ENVIRONMENTAL MONITORING
Let us now understand monitoring requirements to ensure Environmental Health and Safety (EHS). Monitoring involves estimation of the level of pollutants in air, water, soil and biota to gauge the status of environmental health. Not only does it help establish baselines, trends and cumulative effects of these pollutants, but also helps ensure compliance to various regulatory requirements and also in planning mitigation strategies.
As per Environment (Protection) Rules (1986) section 14, every individual carrying out an industry, process or operation that requires consent from the State Pollution Control Board (SPCB) as per Water (Prevention and Control of Pollution) Act, 1974 or the Air (Prevention and Control of pollution) Act, 1981 or authorization under Hazardous Wastes (Management and Handling) Rules, 1989 must submit an “Environmental Statement” for the financial year ending 31st March in Form V to the concerned SPCB on or before the thirtieth (30th) day of September every year. State Pollution Control Board (SPCB) issues a consent for specific industry or establishment based on this Environmental Statement and also specifies regulatory requirements based on the type of activity the industry carries out.
The industrial setup can take place only after obtaining clearance from the respective SPCB. Any individual who wants to undertake a new project or modernization or expansion of an industry included in Schedule I of EPA must submit an application to the Secretary, MoEF. The application must be accompanied by Environment Impact Assessment Report and Environment Management Plan as per the requirements of MoEF. EIA involves prediction of environmental consequences of any developmental project and is an indispensable asset.
Diverse types of pollutions and pollutants have emerged with the progress of man and his innovations. Industrial revolution all over the world lead to the advancement in our technologies and lifestyle, however the most severe adverse effect of this revolution was pollution. Almost all types of pollutants found on this planet are traceable to some industry or the other including the agriculture industry. Diverse forms of industrial wastes be it gases, liquids or solids are ultimately released into the environment either in the air, water bodies or into landfills. Air pollution is ranked as the most severe type of pollution of all, resulting in approximately 4.6 million deaths annually as per WHO. Large amounts of noxious gases such as Carbon monoxide (CO), Sulphur dioxide (SO2) and Nitrogen dioxide (NO2) are released from industries and on inhalation manifest in the form of respiratory disorders like asthma, bronchitis and emphysema. EPA has laid down statutory limits for atmospheric pollutants in ambient air in the form of “National Ambient Air Quality Standards (NAAQS)” (Schedule VII).
These standards also give emphasis to something called Respirable Particulate Matters (RSPMs), PM10 and PM2.5. Solid and liquid emissions from industries form mixtures in the air, resulting in the formation of aerosols, the particle form in these aerosols are referred to as “particulate matter” (PM). Fine particles such as PM10 and PM2.5 have high chances of gaining access to the respiratory and cardiovascular system, ultimately resulting in asthma, bronchitis, cardiovascular disorders and even death. Schedule VI of EPA has specifications for general emission standards, equipment based standards as well as load based standards that are pertinent while carrying out stack monitoring. Apart from these norms, Schedule I of EPA stipulates specific standards for around 104 diverse industries.
Noise is a by-product of anthropogenic activities however, it has become a kind of pollution, in fact World Health Organization (WHO) ranks noise as the third most hazardous environmental pollution. Monitoring noise levels is extremely critical for protection of humans and other life forms. Schedule III of EPA specifies standards for ambient air quality with respect to noise, by classifying the area as Industrial, Commercial, Residential or Silence Zone. It also differentiates between the day time and night time limits considering the time weighted average of the sound level and energy mean of noise level in decibels.
Industrial effluents pose immense threat to the quality of surface and subsurface water, soil as well as humans. Every industry is attributed with its own unique effluent or a combination of effluents, monitoring and controlling their level is critical. Schedule VI of Environment (Protection) Rules 1986 specifies regulatory limits for marine coastal areas, public sewers, land under irrigation and inland surface water. These norms also give emphasis to the toxic effect of effluents on fishes in the form of bioassay test wherein 90% survival in 100% effluent is a must. EPA regulations are becoming more and more stringent with time, especially for highly toxic substances such as heavy metals. EPA Fifth Amendment Rules 2016 brought in the regulatory norms for all textile units in terms of critical environmental indicators such as BOD, phenolic compounds, TDS and SAR. These rules also state that CPCB may make Zero Liquid Discharge mandatory for all large-scale textile units in critical areas. EPA Sixth Amendment 2016 brought a change in the regulations for effluent discharge from slaughter house and meat processing units.
Industries like textiles, chemicals, petroleum and those involved in metal fabrication account significantly to hazardous waste. Hazardous Wastes (Management and Transboundary Movement) Rules were laid down in 2008, under section 6, 8 and 25 of EPA, however they have now been superseded by Hazardous and Other Wastes (Management and Transboundary Movement) Rules 2016. Any waste that has physical, chemical, biological, toxic, reactive, explosive or corrosive traits that are liable to be dangerous to health or environment are known as hazardous wastes. Schedule I of this act enumerates hazardous wastes released by diverse industries, Schedule II however lists out hazardous wastes based on their classification into Class A, B and C. These rules stipulate all the procedures for handling, storage, transport, import and export of these hazardous wastes. Every individual that is associated with collection, handling, use, storage, transport or in any other way with hazardous waste must send an application to SPCB in Form I and obtain an authorization.
Waste generated by hospitals, nursing homes, pathological laboratories, clinics, animal houses and research facilities during diagnosis, immunization and treatment of animals or humans and during research is termed as “Biomedical waste”. Handling, storage, transport, treatment as well as disposal of such waste is regulated by the Bio-medical Waste (Management & Handling) Rules, 1998 under section 6, 8 and 25 of EPA.
These rules have now been superseded by the Bio-medical Waste Management Rules, 2016. Section 3 specifies that the waste must be segregated in colored bags or containers in the manner that has been specified in Schedule I. Yellow, red, white, and blue bags are to be used based on the type of waste specified and it must be treated and disposed in the manner specified in this schedule.
The occupier of the facility must report all major accidents while handling of bio-medical waste in Form I to the prescribed authority. Disposal of bio-medical waste must be done as per the standards specified in Schedule II, including standards for incineration, autoclaving and other methods of sterilization.
About 900 million tonnes of solid waste is generated annually from municipal, agricultural, mining and industrial processes in India. Management and treatment of this waste is crucial due to the number of health effects posed by these waste on humans as well on the environment. Solid waste accounts for all solid or semi-solid domestic, commercial, sanitary, industrial or any non-residential waste generator in areas as specified in section 2 of these rules.
These rules specify duties of all local, state and central authorities that regulate waste as well as the duties of all sectors that generate solid waste. Standards have been laid down for disposal of solid wastes in sanitary landfills in Schedule I of these rules, with stringent limits for heavy metals and phenolic compounds. Schedule II of Solid Waste Management Rules, 2016 focuses on the standards for treatment and processing of solid waste based on the type of processing it undergoes. Waste generated via construction and demolition activities such as rubble, building materials and debris also needs to be treated and disposed properly. Municipal Solid Waste (Management and Handling) Rules were implemented for this purpose in 2000, however these rules have been superseded by the Construction and Demolition Waste Management Rules, 2016.
These rules apply to all waste generated by demolition, construction and repair activities and has specifications for all waste generators, pollution control boards and other regulatory bodies. EPA has stipulated the criteria for site selection in order to store, process or recycle the waste generated by construction and demolition in Schedule I and also specifies various application processes for by-products of the this waste.
As man explores environment, novel pollutants keep on appending to the existing list and so do the regulatory norms for these pollutants. Plastic is one of the pollutants that has created a nuisance to all, India alone generates 5.6 million metric tons of plastic waste annually. Not only does plastic get accumulated, it is also most of the times non-biodegradable. In 2011, EPA implemented the Plastic Waste (Management and Handling) Rules, now known as the Plastic Waste Management Rules, 2016.
As per rule 5, recyclable plastic waste, must conform to Indian Standard: IS 14534:1998, in case of compostable plastics the degree of degradation and degradability should conform to the Indian Standards as listed in Schedule I of these rules. Ordinary use products such as paints too are being regulated. Recently, EPA enacted Regulation on Lead Content in Household and Decorative Paints Rules, 2016 prohibiting lead in paints and surface coating materials over a concentration of 90 ppm. Electronic waste “E-waste” is regulated by the E-Waste Management Rules, 2016.
We can clearly see that environmental monitoring is an abyss, the more discoveries man makes more we have to monitor and control.
3. WORKPLACE MONITORING
Employees are frequently subjected to occupational hazards, an exemplar of this would be the Kodaikanal poisoning wherein Unilever, a thermometer manufacturing company averted using proper protocol for disposal of waste and ended up exposing the employees to Mercury poisoning.
The occupational hazard soon become a global environmental concern when the complete geographical area was found to be contaminated with high levels of mercury. Regulatory norms for worker safety are critical. In US, Occupational Safety and Health Administration (OSHA) and National Institute for Occupational Safety and Health (NIOSH) sets standards for ensuring safety of employees in all occupations. In India, the Factories Act was enacted in 1948 for the same purpose. Schedule 2 of Factories Act, specifies permissible exposure limits in work environment for around 116 chemicals and VOCs.
This act also specifies standards for ventilation, illumination and sound at a facility. Section 45 of this act states that the occupier of a factory must provide drinking water for employees, this water must comply with quality requirements of Bureau of Indian Standards (BIS) and the employer must get it tested from a government approved laboratory in a frequency of 6 months.
Laws for curtailment of environmental pollution evolve with evolving pollutants. It will take years to undo what has already been done, but you can certainly prevent it. Continual improvements in monitoring and analysis of these pollutants will not only decide intervention limits but also help actionable steps for a green and safe future.
Would like to thank Ms Anuprita Raichurkar, Quality Executive at Envirocare Labs, who was instrumental in compilation and penning down the thoughts in scientific manner.