EIA Report
EIA Report
EIA Report
Conducted By:
Conducted By
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Environmental Impact Assessment (EIA)
Prepared By Approved By
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Environmental Impact Assessment (EIA)
Table of Content
Abbreviation
Glossary
Executive Summary
Introduction
1.0 Background
1.1 Purpose of the Environmental Impact Assessment (EIA) Study
1.2 Principle of Environmental Impact Assessment
1.3 The EIA Process
1.3.1 Definition of EIA
1.3.2 EIA Methodologies
1.3.3 Methodology of the existing EIA
1.4 Scope of Study and Limitations
1.4.1 Study Scope
Chapter 1 1.4.2 Benefits & Flows of /EIA Study
1.5 Study Area
1.6 Scoping
1.6.1 Terms of reference (TOR)
1.7 The EIA Team
Policy and Legal Considerations:
2.0 Policy and Legal Consideration
2.1 Introduction
2.2 Bangladesh Legal Framework
2.2.1 Environmental Guide lines for projects in Bangladesh
2.3 Relevant National Polities and Legislation
2.3.1 National Conservation Strategy (NCS) 1992
2.3.2 National Environmental Management Action Plan (NEMAP) 1995
2.3.3 Forest Policy (1994)
Chapter 2
2.3.4 Industrial Policy (1999)
2.3.5 National Water Policy (1999)
2.3.6 Environmental Policy (1992)
2.3.7 Bangladesh Wildlife Preservation Act (1973; Amended in 1974)
2.3.8 The Bangladesh Environmental Conservation Act (1995;Amended in 2000)
2.3.9 The Environmental Conservation Rules (1997)
2.3.10 The Protection and Conservation of Fish Rules (1985)
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4.3.4 Fisheries
4.3.5 Endangered and threatened species
4.4 Socio-economic profile of the project area
4.4.1 General
4.4.2 Population and social structure
Potential Environmental Impacts
5.0 Potential Environmental Impacts
5.1 Construction phase
5.1.1 Physical and chemical
5.1.1.1 Geology and Soils
5.1.1.2 Topography and Landforms
5.1.1.3 Climate and Meteorology
5.1.1.4 Air Quality
5.1.1.5 Noise
5.1.1.6 Hydrology
5.1.1.7 Water Quality
5.1.1.8 Solid Waste
5.1.2 Biological
5.1.2.1 Flora & Fauna
5.1.2.2 Ecosystems
Chapter 5 5.1.3Socio Economic
5.1.3.1Demographic
5.1.3.2 Land Use
5.1.4Occupational Health & Safety
5.2Operation Phase
5.2.1Physical & Chemical
5.2.1.5 Noise
5.2.1.6 Hydrology
5.2.1.7 Water Quality
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List of Tables:
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List of Figures
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Environmental Impact Assessment (EIA)
ABBREVIATION
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Glossary
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Evaluation: The process of looking back at what has been really done or accomplished.
Erosion: Process in which wind and water removes materials from their original place; for
substance, soil washed away from an agricultural field.
Environmental effects: The measureable changes, in the natural system of productivity
and environmental quality, resulting from a development activity.
Environmental Impact: An estimate or judgement of the significance and value of
environmental effects for natural, socio-economic and human receptors.
Environment Management Plan (EMP): A plan to undertake follow-up activities which
provide for the sound environmental management of a project/intervention so that adverse
environmental impacts are minimized and mitigated; beneficial environmental effects are
maximized; and sustainable development is ensured.
Emergency: It is defined as a situation where the resources out pass the demand. This
highlights the typical nature of emergency. Situations of this kind are avoidable but it is not
possible to avoid them always.
Emergency preparedness: It is one of the key activities in the overall management.
Preparedness, though largely dependent upon the response capability of the persons
engaged in direct action, will require support from others in the organization before, during
and after an emergency.
Environmental Management: Managing the productive use of natural resources without
reducing their productivity and quality.
Field Reconnaissance: A field activity that confirms the information gathered through
secondary sources. This field study is essentially a rapid appraisal.
Fauna: A collective term denoting the animals occurring in a particular region or period.
Flora: All of the plants found in a given area.
Hazard: It is defined as a physical situation, which may cause human injury, damage to
property or the environment or some combination of these criteria.
Household: A household is identified as a dwelling unit where one or more person live and
eat together with common cooking arrangement. Persons living in the same dwelling unit
having spate cooking arrangement constitute separate household.
Habitat: The natural home or environmental for a plant or animal.
Important Environmental component (IEC): These are environmental components of
biophysical or socio-economic importance to one or more interested parties. The use of
important environmental components helps to focus the environmental assessment.
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Executive Summary
Mondol Intimates Ltd., is a 100% export oriented manufacturer & exporter of readymade
Knit garments factory which produces ladies Under Garments / lingerie. The Company is
established in January, 2013. The factory is situated at Shirir Chala, Bager Bazar, Gazipur,
Bangladesh. The total floor area of the factory is 135,000 Sq. ft. and land area is 26459.53
Sq. ft. This factory the EIA has been conducted for Mondol Intimates Ltd., which is already
built and located in mixed zone.
The industry is adding to the present ready-made garments production of the country as
well as providing employment to a substantial number of personnel. The total manpower of
the Mondol Intimates Ltd. Is 2300 including staff and workers. The production capacity of
the factory is 20,00000 (2 Million) pieces per month. According to the DOE, the factory is
considered under the Orange-B category of the Environmental consecration Rules, 1997
(Schedule 1, Clause C, item 61) [Page 200].
EIA is considered as a project management tool for collecting and analyzing information on
the environmental effects of a project. This Environmental Impact Assessment (EIA) is
conducted to provide information on the potential negative and positive environmental and
social impacts of the existing factory which will help them to run their operation in an
environmental friendly way by adopting proper environmental management plan. It also
aims to make recommendations for the mitigation of the potential negative impacts and
enhancement of the positive ones. A field survey of the existing site was conducted and
potential environmental impacts of the current industry’s activities were identified,
assessed, and documented. This report describes the baseline environmental analysis of
the surrounding area of the existing factory, impacts on the environment and environmental
management plan of the existing facility. The present report describes the environment and
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social impacts of the industrial unit and at the same time proposes mitigation measures to
overcome the adverse impact to an extent to make the factory an environmentally sound
one.
Impacts that are identified during the study reveal that fire hazards, environmental and
occupational health hazard and accidents, safety and emergency are only the major
impacts of the project and the facility have already implemented all necessary action to
reduce impacts to certain allowable limit. The potential ecological impacts identified in the
operation of the plant are: (i) Water pollution related to disposal from wet household waste
discharge (ii) Air pollution resulting from the stack emissions (iii) water pollution from oil
type wastes and/or spills used for the maintenance of equipment (iv) noise pollution
resulting from the operation of generators and other equipment operation. All these issues
with potential impacts on the environment are treated with most recent technology available
in accordance with the relevant national and international legal framework. Mondol
Intimates Ltd., contributes positively by developing local community & adding foreign
currency to the economy of Bangladesh.
A number of mitigation measures are recommended against the adverse activities during
the operation phases of the factory. As the factory is already built thus this EIA has been
conducted to evaluate the current impacts of the industry on environment i.e. to find out
that the factory is environmentally friendly or not. During the operation phase, emphasis
has been given on controlling the emission levels and minimizing air pollution by emitting
flue gas through chimney, abatement of noise pollution by adopting canopy system or
insulating the generator room for generators and satisfactory maintenance of related
equipment treatment before discharge and possible Air pollution from oil wastes which is
treated with employing proper handling and storage of oils/oil wastes and stringent
management of oil spills, all of which are assured with periodic monitoring of noise and
emission levels and drinking water quality.
Analyzing all information & evaluating the environmental impacts of this factory, it can be
concluded that the existing facility Mondol Intimates Ltd., is not creating any major
environmental impact and the factory is committed to work as an environmental friendly
organization in future.
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Chapter 1
Introduction
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Background
The garments industry has played an important role in Bangladesh’s economy for long time.
Mondol Intimates Ltd. is a 100% export oriented readymade Knit garments factory. It is
situated at Shirir Chala, Bager Bazar, Gazipur, Bangladesh. Mondol Intimates Ltd., is
situated in a mixed zone and according to ECR 19 Rules, 1997 (Schedule 1, Clause C,
item 61) [Page 200]. It falls under Orange-B category. The production capacity of the
factory is 20,00000 (2 million) pieces per month. The factory produces high quality
garments products for some prominent brands.
It is a well-recognized fact that each development activity has an impact on the natural
molding of the environment. As development activities are of prime importance for the
economic growth and fulfillment of basic needs of the society, the environmental aspects
of development activities must be taken to account and due attention must be paid to
protect the environment. Proper location/ sitting, its process and waste abatement and
control are very important for an industry to be environmentally sound.
To Ensure this, an Environmental Impact Assessment (EIA) is a very effective tool, which
delineates what needs to be done to make an industrial unit suitably located and operate
in an environment friendly way.
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On one hand, the garments industry contributes a lot to Bangladesh economy on the other
hand indication of garment gives them to a variety of environmental as well as health and
safety consents. Environmental impact Assessment (EIA) is generally carried are if she
only planning stage of any project so that planning can be done to reduce the industrial
environmental impacts policy.
This report presents the findings of an Environment impact Assessment (EIA) of the
industries namely Mondol Intimates Ltd., which have different kinds of readymade
garments manufacturing facilities. The objective of the study is to provide an examination
and assessment of the principal environmental impacts of the industry. The outline of an
environmental management plan also suggested with an indication of the extent of work to
be done to keep the development and environment compatible to this context, it should be
noted that the term ‘environment’ and its derivatives have been used in a wide sense, which
not only physical and chemical aspect but also the human measurement.
However garments and manufacturing industry industries generally deal with buyers
around the world. These buyers have their own code of conduct (CoC) and the
manufacturing facilities must bone to fulfill the requirement of all related national,
international general and buyers CoC to be complaint and also to compete with other with
other manufacturers. Though, DoE does not require EIA studies for garment manufacturing
facilities in these case the factory proponent as a positive step require EIA study.
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practice is applied internationally to both developed and developing countries (EIA Centre,
1995).
There are eight guiding benefits that given this entire process of EIA and they are as
follows:
Transparency: All assessment elements and their basis should be open and accessible.
Certainly: The process and timing of the assessment should be agreed in advanced and
followed by all participations.
Participation: An appropriate and timely access to the process for all interested parties.
Practically: The information and outputs provided by the assessment process are readily
usable in decision making and planning.
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Flexibility: The assessment process should be able to adapt to deal efficiently with any
proposal and decision making situation.
Cost -Effectiveness: The assessment process and its outcome will ensure environmental
protection of the least cost to the society.
Accountability: The decision maker are responsible to all parties for their action and
decisions under the assessment process.
b) Munn (1979) defines EIA as a need “to identify and predict the impact on the
environment and on man’s health and well-being of legislative proposals, policies,
programs, projects and operational procedures and to interpret and communicate
information about the impact”
c) Clark (1979) defined EIA as “as the systematic examination of the environmental, social
and economic consequences of projects, plans and polices”.
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d) The IAIA (International Association of Impact Assessment) has defined EIA very simply
as “Future consequences of Development actions”.
a) Checklists
b) Matrices
c) Networks
d) Environmental Evaluation System (EES)
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Networks generally consider only adverse impacts on the environmental and hence
decision making in terms of the cost and benefit of a development project to a region is not
amenable to network analysis.
Environmental Evaluation System (EES): The EES is used to evaluate the expected
future conditions of the environmental quality, both “with” and “without” the project. A
difference in Environmental Impact Units (EIU) between these two conditions constitutes
either an adverse impact, which corresponds to a loss in EIU units, or a beneficial impact
which corresponds to a gain in EIU units.
For identifying the environmental impact of Mondol Intimates Ltd., Descriptive Checklist
method has been used.
Impact Prediction: The purpose of or impact prediction exercise is “to estimate the extent
of changes and to quantity them as far as practicable. Prediction scientifically characterizes
the cause and effects of impact and its secondary and synergistic consequence for the
environment and the local community. Prediction follows an impact due to a project activity
and investigates its subsequent effects on the environmental components and aspects
such as strain on available infrastructure, adverse impacts on crops, forests, fisheries,
economic effects on fishing villages and resulting socio-cultural changes. For prediction we
need to use data on physical, biological, socio-economic and anthropological aspects and
resort to experimental/mathematical techniques, in qualifying impacts it may employ
mathematical models, economical models, experiments or expert judgments.
All prediction techniques, by their nature, involve some degree of uncertainty. Hence along
with quantifying an impact uncertainty of prediction should be mentioned in terms of
probabilities of margins of error. It is necessary that social and cultural impacts be given
the prominence they deserve in describing the changes expected to result from major
development projects. It is the socio-cultural impacts which the local community will feel
most acutely in their everyday lives.
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Impact Evaluation: The evaluation step in EIA calls for conversion of the predicated
values for various environmental parameters to comparable set of units some system of
normalization. Battelle Environmental Evaluation System (BEES) is a useful method of
impact evaluation.
The EIA has been conducted at Mondol Intimates Ltd., following the DoE guideline &
complying national & international regulation. The report has been prepared on the basis
of gathered information about the activities of Mondol Intimates Ltd., supplied by the
factory management personal as well as obtained from field survey. The EIA team has
been built comprising multi-disciplinary experts who have performed site visits & made
reconnaissance based on information gathered from the factory, field survey data, adopting
necessary method & using some secondary data.
The interaction between the project activity and the significant environmental impact has
been identified based on a descriptive checklist Method. This checklist was prepared
following the DOE guidelines and using some international guideline. For predicting &
evaluating impact experts judgment has been used. For prediction some data on physical,
biological, socio-economic and anthropological aspects and resort to
experimental/mathematical techniques has been applied.
The environmental data were collected from the factory site, substations, conduction a part
of survey outside the factory are and communicating with local people, workers through an
environmental questionnaire. Stakeholder consultation was also made to obtain the
people’s view, as suggested in the EIA guidelines. Environmental data from different
sources (B.B.S, DOE, Department of Meteorology, BEDB, Agro climatic survey of
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Bangladesh and some other international publication) of the proposed project are were
collected to prepare an environmental baseline profile. The consultant’s multi-disciplinary
team of experts made a visit to visualize the condition of the project site and its
surroundings and to identify alternate sites for investigation. As the factory is already built
in mixed zone and does not create any major adverse impact on environment thus no
alternate site need to consider for the current industry.
This EIA report identifies probable environmental impacts due to the existing unit, describes
existing baseline conditions, identifies important environmental components through
scoping, identified potential impacts; prepare an outline for mitigation measures of potential
negative impacts and enhancement of positive environmental impacts including
preparation of an outline management plan.
An IEE/EIA is generally carried out an integral part of the Feasibility study (FS) or together
with it and before going into the final design phase and into the constriction phase of a
particular development project. So the findings of the EIA could be incorporated in the
project design, overall planning and budget and that the project could be implemented
accordingly. When an EIA is conducted separately as just an add-on, often it does not get
due importance in the overall implementation of the project, which undermines the role of
the EIA sand can contribute to environmental damages.
The scope of Environmental Impact Assessment includes the following:
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In case of Mondol Intimates Ltd., the EIA has been prepared at the stage where the
facilities are already built in. As the time for environmental study was really short, the
consultants were forced to use secondary available data. Though the EIA has been
prepared after wards, all the significant Environmental Impacts that may arise has been
identified in EIA for the above project and conclusions for environmental clearance has
been made accordingly.
Services performed by the consultants are conducted in a manner consistent with that level
of care and skill generally exercised by members of the engineering and consulting
profession. The report may not exhaustively cover an investigation of all possible aspects
and circumstances that may exist. However, an effort is made to discover all meaningful
areas under the stipulated time available.
In evaluating subject site, consultant relies in good faith on information provided by client’s
management or employees. The consultants assume that the information provided is
factual, accurate and accepts no responsibility for any deficiency, or mistakenness
contained in this report as a result of omission or misrepresentation of any person
interviewed or contacted. However, the consultant notified the contradictions and errors in
the data, where it seems appropriate. It should be recognized that the information given in
the report is time specific and with the passage of time the relevancy of data and analysis
may suffer. Specific circumstances and condition of site can change due to which
conclusion and opinions may also change.
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Benefits Flaws
Provides an effective mechanism for Coordination Unavailability for reliable data (mostly in developing
Environmental integration Negotiations Feed back countries)
1.6 Scoping
The primary function of scoping also referred to as setting the Terms of Reference (ToR)
of an EIA, is to establish the environmental priorities and set the boundaries for the study.
The objective of ToR is to make the assessment process concise & focused. Various tools
have been used in scoping, such as questionnaire, checklist, comparison with other similar
project.
The description of the environment and social baseline conditions are made encompassing
all relevant current baseline data on the environmental and social characteristics including
physical, biological, ecological and social environments of the study area i.e. Mondol
Intimates Ltd., In the backdrop of the above, scenarios, the relevant regulations and
standards governing environmental quality, health and safety, protection of sensitive areas,
protection of endangered species, land use control, land acquisition, compensation, etc. at
every level are described.
In action to the above, an analysis was conducted of reasonable alternatives in meeting
the ultimate objects of the project including the “no action” alternative, alternative means of
meeting the energy requirements, alternative methods of construction including cost and
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reliability factors. Viewed against these, all significant impacts were identified and
evaluated including atmospheric emissions and changes in ambient air quality, ambient
water quality impacts, changes in ambient noise and local land use patterns, impacts due
to land acquisition, impacts of the project and its activates on the community’s access to
social infrastructure (e.g. potable water, health centers, school, irrigation and extension
services), and local developments.
Following identification of potential impacts, efforts have been taken to distinguish between
positive and negative impacts, direct and indirect impacts including impacts from possible
accidents and long-term impacts. Attempts are made to describe the impacts quantitatively
in terms of environmental and social cost and benefits and assigning economic values
where feasible.
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This EIA has been conducted by an experienced team of Green Tech which comprised EIA
consultant, Environmental Expert, Chemists and Field Assessors. The team was assisted
by the factory professionals providing information, some secondary data etc.
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Chapter-2
Policy and Legal Consideration
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2.1 Introduction
Development projects are governed by some legal and institutional requirements. So,
assessment of relevant legal provisions, policies, strategic and institutional issues are very
important for any project proponent or developer before they actually execute a program
or plan. The proponent has to be well aware of these requirements and comply with the
provisions as applicable and necessary. The following sections review the relevant national
legislations and polices along with some international laws. Mondol Intimates Ltd., is
conduction and will conduct its operations in compliance with local, national and
international legislation. In other words, the proposed projects will be executed and
operated in accordance with Bangladesh legislations and international agreements to
which Bangladesh is a party.
Garments industry is one of the most regulated sectors in the world in terms of quantity
control. The Environmental aspects of garments projects are governmental by the
Environmental conversation Act (ECA), 1995; the Environmental conservation rules (ECR).
1997; and the forest Act, 1927; and the forest Act, 1927 (applicable only when forest land
is diverted) the requirement for undertaking environmental studies has been specified
under the ECA 1995 and the ECR 1997. Section 12 of ECA 1995 stipulated that “No
industrial unit or project shall be established or undertaken without obtaining environmental
clearance from the Director General, Department of Environment (DG, DoE) in the manner
prescribed by the rules”. Further, Section-20 of the Act has bestowed rule-Making powers
on the Government and Clause (2) (f) of this section requires that rules be made to
“Evaluate and review the environmental impact assessment (EIA) of various projects and
actives, and procedures be established for approval”. All these requirements have been
promulgated in the ECR 1997 certain criteria and conditions have also been established
by the Department of Environment (DoE) for industrial plant. These are as follows:
The industry should be in an area that is/will be designated as an industrial zone, under the
town and country planning regulations. Forest and mine agricultural and should be avoided
as far as practicable. The plant should be alternatively provide should not be located in the
vicinity of a recharge. While selecting sites for test and arrange categories a few
consideration are to be kept in mind environmentally otherwise sensitive areas nearest
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Forest and Prime agricultural land should be avoided as far practicable, the plant should
alternatively provide for storage of solid wastes, treatment of wastewater use of treated
whatever (if feasible) and a green belt around the parameter.
It is advisable to shortlist a few potential sites keeping in mind the above criteria.
Table 2.1: Environmental issues and relevant laws and regulations in Bangladesh.
Enforcing
Issues Laws/Regulations Regulated/Enforced items
Agency
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MoEF/DOE
Pesticides and The Agricultural Pesticides Ordnance, Approval of permissible
MoEF/DOE
fertilizers 1971 pesticides
ECA, 1995 Declaration of Ecologically
Forest MoEF/DOE
ECR 1997 critical areas Reserve forest,
conservation
The Forest Act 1927 protected forest village forest.
Wildlife ECA. 1995
Conservation ECR 1997 Declaration of Ecologically
MOEF/DOE
and national The wild life (Preservation) Critical Areas
parks Amendment) Act, 1974
Depending on the extent of impact on the environment, industries and projects are
classified in four different categories under the ECR 1997. The four categories are: Green,
Orange A, Orange-B and Red. The procedures for obtaining ‘Environmental Clearance
(EC)’ for different categories of projects are also provided in the ECR. Green category
industries are to be granted EC within 15 days. The Green Category Schedule does not list
specific projects. For other categories, schedules containing lists of industries and projects
are provided in the ECR. For Orange A & B and Red category of industries and projects,
an application for EC must include a ‘Feasibility Report (FR)’ and an ‘Initial Environmental
Examination (IEE)’ report. A process flow diagram and a layout plant are also needed for
industries. IEE report must include a terms of Reference’ for the Environmental impact
assessment (EIA) for Red Category industries and projects. An EIA report is mandatory for
final approval and issuing of an ‘Environmental Clearance’ for Red Category industries and
projects. The ECR, 1997 lists the contents required for both IEE and EIA Reports. Table
2.2 lists project types included in the ECCR and categories. Although, it is not clearly
specified in the rules, DOE does provide clearance to EMF for projects with multiple sub -
projects having small environmental footprints.
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Amendments of the existing laws (acts, rules and regulations) relating to the forestry sector
and creation of new laws for sector activities have been recognized as important conditions
for achieving the policy goals and objectives. The forestry policy also recognized the
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The Environment Policy mark out the Department of Environment (DOE), as the approving
agency for all such IEE/EIA’s to be undertaken in the country. Policies of fifteen sectors are
described in the policy.
The Bangladesh Wildlife (preservation) Act of 1973 provides for the preservation
conservation and management of wildlife in Bangladesh. The earlier laws on wildlife
preservation, namely, the elephant preservation Act 1879, the wild bird and animal’s
protection act 1912, and the Rhinoceros preservation Act 1932 have been repeated and
their provisions have been suitably incorporated in this law.
This Act encompasses a range of different activities including hunting and fishing although
the provisions of greatest significance relate to the establishment of National parks, Wildlife
Sanctuaries and Game reserves by the Ministry of Environment and Forest (MOEF). Such
designations have enormous significance for the types of developments that may take
place. This legislation does not provide scope for creation of a strong organization, which
can adopt appropriate measures to protect wildlife. The importance of wildlife could have
been highlighted in the legislation, which it does not do. Punitive provisions are not readily
usable.
The types of endangered and ecologically valuable animals/birds could have been
highlighted in the legislation. It should have asked for active participation and specific action
from local administration to protect wildlife. It also does not prescribe season when certain
animal/birds cannot be hunted or captured.
An executive order issued in 16 June 1996 Bangladesh wildfire Preservation order of 1973
has imposed for five years on hunting of any form of wildlife.
2.3.8 The Bangladesh Environment Conservation Act (1995; Amended 2000, 2006 &
2010)
The Bangladesh Environmental Conservation Act of 1996 (ECA 95) is currently the main
legislation in relation to environment in Bangladesh. The act is promulgated for environment
conservation, environment pollution control and abetment stud attrition. It has responses
environment pollution control Ordinate of 1977.
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These are the first set of rules, promulgated under the environmental conservation Act of
1995 (so far there have been four amendments to this set of rules. October and August
2002, April 2003 and 2010). The environment Conservation rules of 1997 has provided
categorization of industries and projects and identified types of environmental assessments
needed against respective categories of industries or projects.
Among other things, these rules set (i) the national environmental Quality standards for
ambient air, various types of water, industrial effluent, emission, noise, vehicular exhaust
etc. (ii) the requirement for and procedures to obtain environmental clearance, and (iii) the
requirement for IEE/EIA’s according to categories of industrial of industrial and other
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development interventions. The rules are not explicit for garments sector. Rather, this is
covered under the broader heading of “Readymade Woven Garment Production “under the
Orange-B Category Projects.
The proposed project, according to the DOE, is considered under the orange -B of the
Environmental conservation rules, 1997 (item 61, Woven Garment Production) [Page 200,
A Compilation of Environmental Laws, and October 2002). The rules also determine the
Environmental standards for air to which and industry has to adhere. As there are no
specific standards promulgated for garment manufacturing projects in Bangladesh, the
general standards used across sectors are applicable. The standards for ambient air, stack
emission, ambient noise and odor are illustrated in tables 2.3, 2.4, 2.5, 2.6 and 2.7
respectively.
and often causes hindrance to the smooth execution of the project. Legal provision covering
adequate compensation to the project affected persons, particularly disadvantaged groups
such as women & squatters and such other vulnerable groups are yet to be framed.
Table 2.3: Bangladesh Standards for Ambient Air (in microgram per cusec meter).
Sulphur
Serial Carbon Oxides of
Categories of Area Dioxide
No. Monoxide (CO) Nitrogen (NOx)
(SO2)
4 Sensitive 30 1000 30
Notes:
At the national level, a sensitive area includes monuments, health centers, hospitals,
archaeological site, educational institutions and government designated areas (if any).
Industrial units located in areas not designated as industrial areas shall not discharge
pollutants which may contribute to exceeding the standards for air surrounding the areas,
specified at sl. nos. ‘c’ and ‘d’ above.
Suspended particulate matter means airborne particles of a diameter of 10 microns or less.
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Notes:
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is sufficiently irrigated by waste water taking into consideration the quantity and quality of
such for cultivation of selected crops on that land.
Inland surface water standards shall apply to any discharge into a public sewerage system
or to a land, if the discharge does not meet the requirements.
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Notes:
Standard values
Day Night
1 Silent Zone 45 30
2 Residential Area 50 40
4 Commercial Area 70 60
5 Industrial Area 75 70
Sources: Schedule-4, Environment Conservation Rules, 1997 Bangladesh
Notes:
The time from 6 AM to 9 PM is counted as daytime
The time from 9 PM to 6 AM is counted as night-time.
Area up to a radius of 100 meters around hospitals or educational institutions or special
institutions/establishments identified/to be identified by the government is designated as a
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“silent Zone” where the use of horns of vehicles or other audio signals and loudspeakers
are prohibited.
Acetaldehyde 5.0-0.5
Ammonia 5.0-1.0
Mercaptan-Methyl 0.20.02
Styrene
0.07-0.005
Amine-methyl-Tri
Notes:
The following regulatory limits shall be generally applicable to emission/exhaust outset
pipes with a height of above 5 meters;
Q=0.108X Het Cm (where Q=gas emission rate in Nm3/hr.)
He=Height of exhaust outlet pipe in meter
Cm=above mentioned limit in ppm
In cases where a special parameter has been mentioned, the lower limit shall be applicable
for warning purposes and the upper limit shall be applicable for prosecution purposes or
punitive measures.
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changes and the wages to mitigate them, as well as first experience or standard operating
practices. The, EIA procedure carries out a detailed examination of impacts by conducting
relent surveys and monitoring studies, applying impacts, prediction tools and insuring
effectiveness of mitigation and enhancement measures.
2.4.1 Screening
Bangladesh follows a normative screening process. Accordingly, industries have been
divided into four categories: Green, Orange (A), Orange (B) and Red. The Environment
Conservation Rules, 1997 place formulation facilities, garments and sweater production in
Orange (B) Category, while basic drug manufacturing facilities, dying and chemical
processing fall under the Red Category. Orange B Projects are required to undertake and
IEE, while Red category project are required- to undertake both IEE and EIA. The current
factory falls in Orange B Category.
2.4.3 Scoping
In Bangladesh, garments projects are required to submit project feasibility repots along with
the lEE report, and also the proposed terms of reference (ToR) is then used by the project
proponent to undertake ElA. The department recommends that government officials,
people affected by the project, and other interested parties should be involved in scoping.
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For this purpose, scoping sessions may be organized and records of such meetings should
be annexed to the lEE report.
Only the DG, DoE has the authority issue an Environmental Clearance Certificate (ECC).
The project proponent should apply to the concerned Divisional officer of the DoE along
with the appropriate fee (as specified in schedule 13 of ECR 1997), for industries classified
under RED category, such as garment manufacturing facilities the following documents are
required to be submitted along with the application:
Report of the feasibility of the industrial unit or project.
Report on the initial Environment Examination (IEE) of the industrial unit/project, and
also the process flow diagram, layout plan (showing the location of the ETP (if
required), design of the ETP, and information about its effectiveness.
Report of the EMP of the industrial unit/project.
No objection certificate from the local authority.
Emergency plan relating to adverse environmental impacts and the plan for
mitigation of pollution effects.
Outline of relocation and rehabilitation plan (where applicable)
Other necessary information (if applicable)
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For industries classified under the Red category, the following should be attached
with the application:
o Report on the feasibility of the project.
Report on the IEE of the project and the terms of reference (TOR) for the
Environmental Impact Assessment of the project and its process flow diagram,
OR
The environmental Impact Assessment (EIA) report prepared on the basis of the
ToR approved by the Department of Environment, along with the layout plan,
process flow diagram and design and time schedule.
Report of the Environmental Management Plan (EMP) for the project.
No objection certificate from the local authority.
Emergency plan relating to adverse environmental impacts and plan for mitigation
of the effects of pollution.
Outline of relocation and rehabilitation plan (where applicable).
Other necessary information (where applicable).
May undertake activities for land development and infrastructure development; shall apply
for an Environment Clearance Certificate upon of activities without the Environmental
Clearance Certificate, a project proponent cannot have a gas line connection, and cannot
start production in the industrial unit; and, shall submit for the approval of the DoE the EIA
report prepared on the basis of the program outlined in the IEE report, along with the time
schedule (applicable only for Red category projects.)
In case of the present factory the EIA has been conducted due to the requirement of the
proponent. As the factory is already built thus no alternative has been suggested here but
proper mitigation measures are suggested which will help the factory to continue its
operation in an environmental friendly way.
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Chapter 3
Factory Description
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E-mail momin@mondol.net
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Mondol Intimates Ltd., are using ground water for both industrial & household (drinking &
sanitation) purpose which is supplied by deep tube well. The maximum Energy
consumption in manufacturing is 13796609.07 TK (Average) bill per Year. The factory
also has generators for electricity generation. The fuel used in the industry is diesel. The
sanitary liquid waste of the factory is stored in septic tank.
The major pollution caused by the factory’s operation are- air pollution by generator and
boilers effluent gas emission, noise pollution created during the operation of generator and
other vibration creating machines. Besides this the ambient air polluted by dust, due to the
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other industries beside the factory. Solid waste is generated at Mondol Intimates Ltd.,
form the kitchen/canteen water, air and the liquid waste from household & sanitation
process. The solid waste such as, wastage food, broken machine parts is handed over to
local waste buyer. Although the factory causes some pollution but also has a positive side
and that is the factory has created employment for many people, due to this factory local
community has built up daily.
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Chapter 4
Baseline of the Existing Environment
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For EIA study of the existing unit emphasis is given on the environmental features that are
of particular significance to the present factory. Considerations are given to both the
environment and ancillary area that seems to be affected.
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Mondol
Intimates Ltd.
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Mondol Intimates Ltd., is using underground water for its sanitation, drinking and other
process requirement if needed.
The quality of drinking water from deep tube well is tested by the factory after a regular
interval. The physical, chemical & bacteriological analysis of drinking water is attached in
annexure.
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Result shows that all the parameters remain within allowable limit of drinking water value
as per Environmental Quality Standards for Bangladesh. So the drinking water is safe for
workers.
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Indoor air quality of the factory has been monitored for the parameters of CO, CO 2, NO2,
H2O, SO2, NO, H2S, VOC, Hydrocarbon & O2 following Continuous Emission Monitoring
System (CEMS) by using an air analyzers. The analyzers are designed to meet BS 8494/
EN 50270:2006 standard. CO, NO2, SO2, H2S & CH2O are monitored using electrochemical
method and CO2 is monitoring following Non-Dispersive Infra-red (NDIR) method.
Hydrocarbon & VOC are monitored using plus-in catalytic bead and O2 is measured by
capillary controlled concentration sensor.O2 is monitored using automatic span upon
activation. The Suspended Particulate Matter (SPM) of different sizes as PM 0.3, PM0.5,
PM 1, PM 2.5, PM 5, PM 10, has monitored by handheld particle counter at different
sections of the factory. The Indoor air quality monitoring data is presented below:
1. CO ppm 0 0 0 50
3. NO ppm 0 0 0 5
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From the analysis it has been observed that in most of the sections the value of CO, CO 2,
NO2, CH2O & SO2 are within the maximum permissible limit of ECR 97 Schedule 2
(amendment 2005), US EPA and OSHA guidelines. The Particulate Matter Concentration
of some area has exceeded the optimum SPM limit according to ECR97.
The standard permissible limit of different air pollutants are given in below table:
Pollutant’s Concentration
Agency
CO CO2 NO2 SO2 CH2O
Pollutants Concentration
Agency
NO H2S VOC Hydrocarbon O2
ECR97,
Schedule 2,
NYS NYS NYS NYS NYS
Amendmen
t 2005
AEGL 1 AEGL 2 AEGL 3
0.33 17 31
For 8 Hour Monitoring
*AEGL- Acute Exposure Guidelines Levels.
(AEGLs), which is indicate the
concentrations of the chemical in air above
which different types of health effects could 5% (Assuming
US EPA NYS begin to occur in an environment. NYS a Methane NYS
AEGL 1< there may be some discomfort, environment)
odor, irritation, but effects, if any, are not
impairing and only temporary.
AEGL 2< effects become more significant
and may impair ability to escape, be long
lasting, or permanent.
AEGL 3< increasingly severe effects and
possible death without treatment.
19.5 – 22 % (for
25 20 ppm
employee)
OSHA pp (50 ppm for 10 min once if no other NYS NYS
19.5 – 23.5 %
m measurable exposure occurs.)
(Atmospheric)
*NYS – Not Yet Set
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Stack Air Emission of the factory has been analyzed. There are one generator in the factory
which operate to produce electricity. The factory has boiler for stream generation. Diesel
used in the generator & boiler is Natural gas. The emission data of generator & boiler are
presented below:
Measured pollutants
Run
(10 Minutes interval) CO CO2 NO NOx SO2 O2
Mg/Nm3 % Mg/Nm3 Mg/Nm3 Mg/Nm3 %
Run-1 1090 5.1 276 239 233 12.3
Run-2 1010 5.1 243 238 246 12.4
Run-3 1046 5.1 232 237 238 12.2
Run-4 1047 5.1 287 230 257 12.3
Run-5 1002 5.1 277 238 238 12.4
Run-6 1063 5.1 292 238 243 12.3
P Index 2.25
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Run-1 2 1 1 26 28 27 85
Run-2 2 1 1 27 25 23 79
Run-3 1 0 0 31 29 32 93
Run-4 2 1 1 30 28 27 89
Run-5 1 1 1 30 27 28 88
Run-6 2 1 1 27 29 26 86
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Run-1 3 2 2 23 26 29 85
Run-2 2 3 2 25 29 32 93
Run-3 3 2 3 27 29 33 97
Run-4 2 1 2 29 30 26 90
Run-5 3 3 2 26 29 32 95
Run-6 1 2 3 25 27 31 89
The Stack Emission from the stack point of the generator & Boiler has been analyzed for
the parameter of NO2, SO2 & CO2 to evaluate the effect of the plant’s emission. From the
analysis, it has been observed that the emission of CO and SO2 is within the standard limit
of DOE, US EPA and World Bank.
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The work place noise level of “Mondol Intimates Ltd.” has been found satisfactory in most
of the sections in comparison to the Ambient Noise quality. However, as the measured
noise level of Generator Room Area (Ground Floor, Generator Room) has been exceed
both the Noise level Standard of OSHA and ECR 97.
Noise level must has to be less than 75 dB because worked working under a condition
more than 85 dB is harmful for health in short and long term. Mainly personal working at
the acceptable limit of Environment Bangladesh (DoE) and World health Organization. So
the following recommendations are suggested to reduce the adverse effect:
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Comparative
Location of Measured Light
S.L Name of Sections Standard
Sections Level (LUX)
(LUX)
1 Dining Room 8th Floor, Main Building 310
The work place light condition has been found satisfactory in the sections in comparison to
the ambient light level standard. However, as the measured light level in all Spot Removing
Room has been found lower than the standard limit, thus it is recommended to improve
light facility of the relevant sections to ensure comfortable working condition.
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Temperature Level
Temperature Level measured in °C by semiconductor sensor based instrument. Ambient
Temperature is measured by changes in electrical resistance due to heat, which is shown
Celsius. The inspection has been carried out according to the standard Operating
Procedure SOP-10.
Measured
Comparative
S.N Name of Sections Location of Sections Temperature in
Standard (°C)
(°C)
1 Dining Room 8th Floor, Main Building 32.1
8 Spot Removing Room 5th Floor, Main Building 32.3 Optimum Range:
Between 20°C and
9 Sewing Section 4th Floor, Main Building 32.1 26° C Depending
on the time of
10 Finishing Section 4th Floor, Main Building 32 year and clothing
worn.
11 Cutting Section 4th Floor, Main Building 32.4
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The work place temperature level at some section of the factory has found satisfactory.
According to Bangladesh weather condition. Although the recommended temperature for
workplace given by ASHARE has been exceeded for many sections but considering the
Climatic condition of Bangladesh, this temperature is usual. However it is safe for the
Worker. To reduce the temperature level suitable ventilation and thermal insulation of Heat
source could be provided. Suitable ventilation can be provided by using mechanical
ventilation system like fans/air conditioning, or by natural ventilation like open windows,
Doors etc. Employers may allow a sensible dress code and ensure the supply of enough
drinking water in working water in floor to make the workers more comfortable to work in a
hot weather.
Humidity Level
Humidity Level is measured in %HR by Semiconductor sensor based instrument. Relative
humidity is measured by changes in electrical resistance caused by changes in moisture.
The inspection has been carried out according to the standard Operating procedure SOP-
10.
Measured
Comparative
S.N Name of Sections Location of Sections Humidity in
Standard (%RH)
(%RH)
1 Dining Room 8th Floor, Main Building 55%
2 Sample Section 7th Floor, Main Building 56%
3 Training Room 7th Floor, Main Building 59% Optimum
Range:
4 Sample Office Room 7th Floor, Main Building 62% Between 40%
and 60%
5 Sewing Section 5th Floor, Main Building 59%
6 Finishing Section 5th Floor, Main Building 53% Maximum
Acceptable
7 Cutting Section 5th Floor, Main Building 52% Range:
Between 30%
8 Spot Removing Room 5th Floor, Main Building 51%
and 70%
9 Sewing Section 4th Floor, Main Building 65%
According to
10 Finishing Section 4th Floor, Main Building 56% the CSA
Standard
11 Cutting Section 4th Floor, Main Building 60%
CAN/CSA Z412-
12 Spot Removing Room 4th Floor, Main Building 62% 00 (2005)-
‘’Office
13 Sewing Section 3rd Floor, Main Building 54% Ergonomics’’
14 Finishing Section 3rd Floor, Main Building 60%
15 Cutting Section 3rd Floor, Main Building 59%
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The Humidity Level present in Mondol Intimates Ltd., found within the acceptable limit in
all area.
Summer/per-monsoon-March to May
Rainy season/monsoon-June to October
Winter-November to February
The summer is hot and dry interrupted by occasional heavy rainfall. The rainy season is
also hot and humid having more than 80 percent of the annual rainfall. The winter is
predominantly cool and dry. The average low temperature occurs in November to January
while the average high temperature may be occurring in March to May. The normal
maximum temperature is 33.3 oC and lowest 12.2 oC according to Bangladesh Metrological
Department.
4.2.7 Rainfall
The proposed line lies in the catchment of the Dhaka meteorological substations. The
Dhaka station has been considered for Rainfall data analysis. Data from 2001 to 2011 has
been used for the analysis and the data source is Bangladesh Meteorological Department
(BMD). The annual average rainfall in this area is about 2161 mm/yr. The monthly average
maximum rainfall was recorded as 433 mm in the month of July and the monsoon rainfall
was about 1742 mm (Figure 4.6).
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Figure 4.6: Monthly Average Rainfall of Last Ten Years (BMD, 2001 to 2011).
4.2.8 Temperature
The Dhaka station has been considered for Temperature data analysis. The Bangladesh
meteorological data at the Dhaka station from 2001 to 2011 shows that the monthly average
maximum temperature in months varies from 24oC to 24oC. The monthly average
temperature varies from 19oC to 29oC. The monthly minimum temperature ranges from
13oC to 26oC and the minimum temperature (December to January) is around 13oC (Figure
4.7).
Figure 4.7: Monthly Average Temperature Last Ten Years (BMD, 2001 to 2011).
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The Monthly maximum and maximum temperature recorded at Dhaka in 2012 has been
shown in table 4.9 and 4.10 respectively.
Months Jan Feb Mar Apr May Jun July Aug Sep Oct Nov Dec
Temperature
23.4 28.7 32.1 33.5 33.4 32.6 32.3 31.1 32.4 32.7 29.7 25.0
(oC)
Source: Bangladesh Metrological Department
Months Jan Feb Mar Apr May Jun July Aug Sep Oct Nov Dec
Temperature
12.4 16.7 21.1 23.5 24.4 26.6 26.7 26.4 26.2 24.7 19.7 15.0
(oC)
Source: Bangladesh Metrological Department
Humidity
Dhaka station has been considered for Relative Humidity data analysis. The monthly
average relative humidity varies from 60% to 81% in last ten years (2001 to 2011). In the
summer, Average relative humidity varies from 60% to 72% in the Monsoon, 81% to 71%
and in the Winter, it again decreases up to 71 to 60% (Figure 4.8). Due to high level of
humidity, the Monsoon more sweating occurs.
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4.2.9 Wind:
The average wind speed becomes high in the monsoon season and low in the dry season
for last ten years (2001 to 2010, Source BMD). The monthly average wind speed is
2.4Km/day in the summer, 3.5Km/hr in the Monsoon and 2.9Km/hr in winter (Figure 4.9).
The maximum wind speed occurs in July to September.
Figure 4.9: Monthly Average Wind Speed of Last Ten Years (BMD, 2001 to 2011).
4.2.10 Seismicity
The seismic-tectonic map of Bangladesh shows the epicenter locations have conformity
with the present knowledge of faulting and other structural behaviors of the region.
Earthquake events in the shelf-zone are random and follow the occurrence of the surface
faults.
Bangladesh has been divided into three generalized seismic zones. Zone-1, Zone-II and
Zone-III on the basis of the distribution of earthquake epicenters and morph tectonic
behavior of the different tectonic blocks. Zone-I comprising the northern and eastern region
of Bangladesh is the most active zone with basic seismic co-efficient of 0.08. The project
area under the zone-II represents the region of recent uplift Pleistocene & blocks of the
Briand and the western extension of the folded belt with moderate seismic co-efficient 0.05.
Zone-III is seismically quiet zone with estimated basis seismic co-efficient of 0.04.
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4.2.1 Introduction
This section describes the floral and faunal diversity of the project area. Experts of flora
and fauna have visited the project area to collect hand data and information (both primary
and secondary) to prepare the EIA report. Varieties of plant species and with animals have
been identified and recorded during the preliminary survey. Every species play an important
role in its natural community and ecosystem and removal of that species is likely to have
adverse impact. Bio-habitat of the study area may be divided in two major type’s terrestrial
and wetland habitat.
I. Terrestrial flora
Terrestrial flora is classified according to their habitats. In the project area terrestrial floras
are present mainly in the have stead regions read sheds, village gloves, playgrounds high
cultivated lands. Human being as well as whittle uses these flora species for different
purposes. They play an important role in the socio-economic and ecological balance. From
a rapid field survey covering different terrestrial habitats of the factory surrounding area a
number of flora species have identified as shown in Table 4.11.
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8.
9. Jolpai Gach Common
10. Gojari Gach Common
11. Taal Gach Common
12. Salvia Common
13. Dopata E Common
14. Enka Gada Common
15. Datia Common
16. Panpata Common
17. Selasia Common
18. Golap Common
19. Gate Ful Common
* Source: Field survey database & secondary Data
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1. Choroi Common
2. Doyel Common
3. Kak Common
4. Bok Common
5. Shalik Common
6. Babui Common
7. Machranga Common
8. Ghughu Common
9. Tia Common
10. Cacania F. Common
11. Pencha F. Common
12. Munia Common
13. Kathihokra Common
Source: Field survey database & secondary Data; F=Fairly
I. Wetland flora:
Wetland flora plays a vital role in nature. It grows mainly in aquatic habitats viz. beel, ponds,
canals, ditches or low lying cultivated lands. From a rapid survey in different wetland and
aquatic habitat, a number of species have been identified as shown in Table 4.13.
Table 4.13: Aquatic Flora of the Project.
Sl. No Local Name Status
1. Dholkalmi Common
2. Muthagas Common
3. Kachuripana Common
4. Hoggal Common
5. Sheola Common
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6. Shapla F. Common
7. Ghagra F. Common
8. KhudiKachuripana F. Common
9. Padmaphul F. Common
10. Kalmi F. Common
11. Shalook F. Common
12. JalPdma Common
13. Bishkathali Common
14. Hizal Common
15. Kharjar Common
16. Keorali Common
4.3.4 Fisheries
Two hundred and fifty species of fresh water fish have been identified in Bangladesh. The
most important species is Hilsha followed by Carps, Catfish, Jeol and Prawns. Bangladesh
has the highest rate of fish production unit area (4047kg/sq. km) and fish accounts for 71%
of animal protein intake. It is estimated that 73% of rural household undertake some sort of
fishing in the course of a year (Rahman et al 1990). Small fish ponds in the vicinity of the
pipeline routes and the project area neighborhood contribute significantly to the protein
intake of the village family. Fish is usually produced in the rivers and wetlands and in
cultured in fish farms. It has been reported by Bangladesh Center of Advanced Studies that
fresh water fish production has declined significantly due to over fishing, pollution and
construction of hydraulic structure. Natural reproduction of fish is tightly bared and linked
to cycle of annual flooding.
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4.4.1 General
This section is intended to highlight the socio-economic scenario of the project are and its
vicinity. It covers demographic and socio-economic characteristics of the project
inhabitants. It is prepared on the basis of primary and secondary sources of data.
Environment specialist and sociologist of the EIA team visited the project area. They have
collected data on some selected characteristics of the inhabitants of affected union’s
villages on population density; household size and other available utility services. The
concerned specialist has conducted focus group discussion at different places near the
project. The study revealed the following salient features of the project area.
The factory is situated at Shirir Chala, Bager Bazar, Gazipur, Bangladesh. located at just
north of capital city of Dhaka, Bangladesh. It lies within the jurisdiction Gazipur District
which is a part of the Dhaka Division. It is bounded on the north by Mymensingh and
Kishoreganj Districts, on the east by Narsingdi District, on the south by Naranyanganj and
Dhaka Districts and on the west by the Tangail District.
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Geologically, the at Shirir Chala, Bager Bazar, Gazipur area comprises the southern
extension of the Madhupur tract, a long narrow tract of tectonically elevated area of older
sediments only a few meters above the surrounding rivers the Turag. Locally, the Tract is
subdivided into the Bhawal Garh. According to the Bangladesh census 2011, Gazipur
Sadar Upazilla has population of 18, 20,374 Males constitute are 9, 76,683 and females 8,
43,691 Various establishments such as Bangladesh Rice Research Institute (BRRI),
Bangladesh Agricultural Research Institute (BARI), CERDI, Seed Certifying Agency,
Security printing Machine Tools Factory, Bangladesh Ordinance Factory, Diesel Factory,
Bangladesh Institute of Technology (BIT), BRAC Dairy Farm, Local Government
Engineering Department (LGED).
Communication facilities: Metaled Road 692 km, Semi Metaled road 284 km,
Unmetalled road 484 km, Railway 16 km, Waterway 52 km.
Cottage Industries: Husking craft mill 10, Goor Processing 12, Salt Processing 3, Dry Fish
Processing 43, and Pottery 125.
[
Hats and bzars: Daily bazars are 42 and weekly hats are 16. Most noted of which are
Tongi, Publi, Mirzapur, Kasimpur, Joydebpur.
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Main crops: Paddy, jute, sugarcane, pulse, potato, oil seed, pepper, onion, garlic, turmeric,
ginger etc.
Main fruits: Mango, jackfruit, banana, papaya litchi, blackberry, pineapple, guava.
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Chapter - 5
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5.1.1.5 Noise
Noise impacts may occur as a result of operation of heavy equipment and onsite power
generation.
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5.1.1.6 Hydrology
Groundwater
Fresh water required by the personnel was supplied from the deep tube well at and/or
around the site with necessary permissions of the appropriate authority. The daily
discharges from the well will not have any adverse effect on the local hydrology.
Surface Water
The wastewater generated at the site was discharged in the municipal sewerage line. The
factory didn’t the waste water in nearby pond/river. Thus there was less negative impact on
surface water.
5.1.2 Biological
The presence of local flora and fauna were determined and evaluation of construction
impacts was made.
5.1.2.2 Ecosystems
Impacts of construction on ecosystem were negligible since there was:
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5.1.3 Socio-economic
5.1.3.1 Demographic
The construction of plant had limited effects on the demographic conditions. There was no
permanent living quarters associated with this plant. The factory didn’t cause any
displacement of individuals whose livelihood depends on the land that will be occupied by
the factory.
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various metals and trace amounts of organic & inorganic compounds. The proportions and
amounts of pollutants emitted depend on the fuel quality and combustion strategy. In this
particular case, the factory uses diesel in generator for electricity generation & natural Gas
in boiler. It also uses purchased electricity for backup which causes GHG emission and
pollute the environment.
Greenhouse Gas (GHG) Emission of Mondol Intimates Ltd.: It cause GHG emission
from 2 sources-direct source i.e. fuel burning as well as from indirect source i.e. purchased
electricity.
The annual fuel (Diesel) consumption of the factory is approximately 81,145.38 Liter & the
Purchase Electricity consumption is 1,037.49 KWH.
The CO2e Emission from direct emission (Diesel) is 219.0925 ton CO2/year.
The CO2e Emission from indirect emission (electricity) is 2.07498 ton CO2/year.
So, the TOTAL GHG Emission of Mondol Intimates Ltd. is:
For estimating the annual GHG emission the last one year natural gas & electricity
consumption data has been used and this GHG estimation has done in accordance with
“2006 IPCC Guidelines for National Greenhouse Gas Inventories for Stationary
Combustion (Volume2_Energy_Chapter 2)”. The emission of Greenhouse gases is
calculated by applying Tier 1 approach following IPCC 2006 guideline.
Diesel
99%
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From the above pie chart it is observed that about 99% CO2 e is emitted from diesel.
Emission from indirect source i.e. electricity in negligible.
5.2.1.5 Noise
Noise generated from the plant during energy production i.e. the operation of generators
and other vibration creating equipment. It is suggested to introduce canopy system to
generator or insulate the generator room to reduce noise level. It is also recommended to
provide ear muff/plug to the workers during working in any noisy area. The factory is located
maintaining a distance from the nearest residential area although it is situated in mixed
zone and it has large area with lots of trees which create buffer zone, thus it does not impart
any significant impact to the local community as well as physic-chemical & biological
environment. Thus the noise generated by the operation generator does not create any
major impacts on environment.
5.2.1.6 Hydrology
Ground water
During the operation phase the factory use ground water for its drinking & sanitation
purpose. The water consumption rates does not affect the local hydrology significantly.
Surface Water
As the factory totally uses water from deep tube well. Factory does not discharge any
harmful liquid waste into the surface water thus there is no significant adverse impact on
surface water due to wastewater discharge.
Mondol Intimates Ltd., have seven reservoir tanks. They use ground water through deep
tube-well for their household (drinking and sanitation) and industrial purpose.
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5.2.2. Biological
It is assumed that the air emissions majority affect the land biota, whereas the fauna
species can move away from the discomforting sources, plants will have to respond
physiologically. Pollution damaged their tissues and may even kill them. In the operation
phase, the effects on flora will be basically from NOx emissions. NOx emissions were found
to be causing discoloration in plant in plant leaves and then to lesions (Brown or dark Brown
spots). The loss of carotene and reduction of chlorophyll are the major responses from
plant vary depending on both internal and external factors. Environmental Conditions,
presence of other pollutants and the existing plant condition affect the responses of the
plant to NOx exposure. Operation of the plant will supply reliable electrical energy to the
users in the region which will limit the use of operation of diesel type machineries which
have adverse effects on the environment. Hence the current pollution load that arises from
the use of other fossil fuels will be reduced. However there are no endangered flora and
fauna on the project site to be affected from air emissions.
5.2.2.2. Ecosystems
5.2.3.1 Demographic
The operation of plant has limited effects on the demographic conditions since there is no
permanent living quarters associated with this plant. Hence there will be no increased
demand on local infrastructure, such as utilities, housing medical facilities, schools, water,
and food. The factory doesn’t causes any displacement of individuals whose livelihood
depends on the land that will be occupied by the Project. The labor force for the operation
of the plant is supplied also from local area, which will result in increased disposable income
of plant employees. The plant contributes in the GDP of the country which is a positive
impact of the plant.
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Additional changes in land use may occur as a result of development of new industries in
the area. Due to establishment of industries the local land value will be increased.
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Chapter -6
Evaluation of Potential Impacts
&
Mitigation Measure
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Risk
Risk Evaluation
rating
LIKELIHOO
Level of Risk
SEVERITY
Potential Identified D Operational Mitigation /
Environment
Score
Impacts risk Control Measures
al Aspects
Score
Score
Conditio Conditio
n n
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• Machine is stored in a
certain place within a
• Disposal container and the container
MODERATE (Yellow)
of oil used need to handover to all
for supplier or waste buyer for
maintenan recycling or proper disposal
Water Water ce of according to local laws and
Minor 2 Unlikely 2 4 regulation. Verification of
Quality contaminat machines
ion oil disposal by supplier
• sewerage might be done by the
discharge factory which would be a
good practice.
• Flow Meter need to be
installed at overhead tank.
LOW (Green)
soil biodegradable &
Soil recyclable waste and
Soil erosion & • leakage handed over to NGOs or
Minor 2 Rare 1 2
Quality sedimentat of oil from local registered waste
ion vehicle buyer for proper
can cause management.
soil • Contamination of soil is
contaminat reduced by suitable
ion. management of oil & fuel.
Noise can Use of personal
generate protective equipment
from (PPE) like ear plug/ ear
vehicle muffs in the noisy
movement workplace like generator
& area.
LOW (Green)
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MODERATE (Yellow)
environme Solid waste need to
Waste Incorrect
ntal collect in storage and
Management/ disposal of Minor 2 Possible 3 6
pollution & handed over to
Disposal waste
soil registered local waste
contaminat buyer.
ion
Medical waste generated
by the factory is handed
over to local hospital.
Loss of
Maintain maximum
LOW (Green)
habitat of
Ecological some flora vegetation
Inappropri
Environment & fauna Negligible
1 Rare 1 1 Implementation of agro
ate control
(Flora and forestry techniques well
of weeds
& Fauna) biodiversity adapted to the site.
reduction
Accidental
spillage
Contamina
from fuel Proper inspection and
LOW (Green)
Dangerous tion of soil,
and Maintenance / storage of
Goods / surface,
chemical hazardous materials such
Hazardous water, Unlikely 2 Rare 1 2
storage as needle , fudge electric
Material ground
due to blubs, empty oil/ medicals
Handling water &
unconscio waste etc.
accident
us
handling
Increase of
vehicular
traffic as
LOW (Green)
well as
Vehicle Vehicular movement would
gaseous
Traffic increase at Negligible 1 Possible 3 3 be restricted at day time
emission &
Pattern plant area and adequate parking
Risk of
facilities might be provided
increasing
road
accidents
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6.2 Adverse Impacts Assessment & Mitigation and positive impacts enhancement
As an existing facility environmental impacts that generally arise from the operation phase
of any garment manufacturing facilities and the possible mitigation measure is discussed
here. This section will also describe the mitigation measure that is important to reduce
operation impacts to reduce it to allowable limit. It is highly believed the proponent has
adopted some that was necessary to reduce impacts at the pre-construction and
construction stages of the project, hence impacts during construction phase and mitigation
measures are not discussed here.
It is evident from the production process Mondol Intimates Ltd., that the factory is a cut to
pack factory. The following issues can be considered during the operational phase of this
factory:
Impact Origin
Significant amount of solid waste would be generated form the factory, which included
broken machineries part, packing box, chemical container, medical waste, etc. from the
overall operation system. However air filter, oil filter, scrap metals, empty container can be
generated from utility sections and mechanical workshops. Liquid waste that may be
generated from the plant is used lubricant from the generator section. These need proper
handling, storage, transportation and disposal. These need proper handling, storage,
transportation and disposal.
Mitigation Measures:
In the case of garment washing industries the amount of solid waste that is generated is
very small. The waste fabrics, chemical containers and waste lubricants have resale value,
which the proponent would sale to the authorized small traders. All other solid waste is
collected in a well-managed system; a solid waste inventory should be prepared. The
factory has storage facilities for solid waste.
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Residual Impact
Provided that the mitigation measure indicated above is fully available, residual impact is
insignificant.
Impact Origin
There might be hazards to the plant workers, employees and technical personnel from
working at the floor level, at the utility sections, storerooms. The garment raw materials
products are very prone to cause fire hazards, from the few years of Bangladeshi garments
history this kind of fire hazards are very common. The risk probability in garment
manufacturing units can be broadly categorized as:
One of these, the risks of principal concern are fire, explosion, sound hazard from the futility
areas etc. To combat unforeseen events ensuring a safe environment, an emergency
management plan is essential for al garments manufacturing units. Bases on the magnitude
of the impact and the area that can be potentially affected, the emergency management
plant may either be an onsite management plan or an offsite management plan.
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proper stack height for the well dispersion of exhaust gasses. For evaluating the impact on
air the are several emission estimating techniques (EETs) like sampling or direct
measurement, fuel analysis or other engineering calculation, emission factor etc. In case
of evaluating the impacts on air caused by Mondol Intimates Ltd., we have adopted direct
measurement techniques for measuring the concentration of different pollutant like CO,
CO2, SOx, NOx, O2, and Formaldehyde & No in flue gas emitted from generator and boiler.
However, it is evident from the indoor and stack gas analysis data presented in chapter 4
that the factory does not creating any major pollution to ambient air.
Mitigation Measures:
The factory need to plant a lot of trees in its premise which help to reduce carbon emission
by absorbing CO2. Trees remove carbon dioxide from the atmosphere through the natural
process of photosynthesis and store the carbon (C) in their leaves, branches, stems, bark
and roots. Approximately half of the dry weight of a tree’s biomass is carbon.
Mitigation Measures:
The vibration levels of the equipment/machinery are expected to be within tolerable and
acceptable limit. No significant management action is suggested. In case of any vibration
hazard, working program should be according to the local situation.
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The work place noise level of Mondol Intimates Ltd., has been found satisfactory in most
of the sections in comparison to the Ambient Noise quality. However, as the measured
noise level of Generator Room Area (Ground Floor, Main Building) & Boiler Room Area has
been exceed both the Noise level Standard of OSHA ECR and 97. However it is
recommended to provide ear plug/ear muff should be used to the workers and silencers for
Generator.
The Mondol Intimates Ltd., and the area inside the factory is big enough to accommodate
traffics during peak period. The factory premise is large which could accommodate
transport during loading & unloading of materials. Therefore no traffic congestion is
anticipated and no mitigation measures are suggested.
Mondol Intimates Ltd., is contributing to Bangladesh export incomes. This is a good step
towards expanding business and the country is earning significant foreign currency each
year.
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The factory has created employment opportunities for local youths. Mondol Intimates Ltd.,
has 2300 employees. Additional jobs have also been created indirectly from the support of
raw materials to the factory.
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Chapter-7
Environmental Management Plan Outline
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In the context of a project, Environmental Management Plan (EMP) is concerned with the
implantation of the measures necessary to minimize or offset adverse impacts and to
enhance beneficial impacts. All the measured are said to be successful when they comply
with the Environmental Quality Standard (EQS) of Bangladesh. Thus the objectives of EMP
for the present project would be
Mitigation measures to reduce or eliminate negative impacts
Enhancement measures to maximize positive impacts
Monitoring requirement and
Monitoring indicators
The following surveys have identified the potential positive and negative impacts and in
enabling development of the Environmental Management Plan (EMP).
Existing Environmental Survey
Socio-economic survey
Biological resource survey
In preparation of the EMP, the above studies were carefully reviewed. Environmental
components and sub-components were identified and their magnitude and duration of
impacts were examined.
During the life span of the factory Mondol Intimates Ltd., will need to integrate to its
existing environmental management plan (EMP) with the one proposed in this section so
as to harmonize and mitigate all significant impacts from the proposed development. To
achieve this Mondol Intimates Ltd., will need to put in place and document policies that
will govern their operations to this end. This will also ensure that management will be
committed to avail necessary finances to be used in implementation of the EMP,
management of air quality, noise, traffic management, solid waste, occupational health and
safety and solid wastes and also for decommissioning of the unit.
The goal of the EMP development is to address the key potential negative impacts identified
in the preceding chapter as well as setting the relevant policies and actions plans needed
to achieve an environmentally sound and sustainable project venture. This EMP for the
current factory will therefore also consist of the following:
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Management policies;
Tree planting program;
Management Plans.; and
Safety Management system
The detail EMP of the factory is given is separate report. The functional components of the
EMP for the project are briefly described in the following sections. The detail EMP of the
factory is given in a separate report.
For effective and environment friendly operation of an industry, a set for guiding tools and
suggestions are necessary which need to be followed at various stages of plant installation,
operation and maintenance. This plan generally has various components of management
depending on the type of industry or plant activity and types of discharge and their pollution
potential. This environmental Management Plan (EMP) once prepared forms the basis of
environment management actions from the part of the plant authority may need
modification or up-gradation because of charges in the plant operation or accurate pollution
load/environmental problems detected afterwards. The plant authority may also be needed
to expand the suggested outline of the EMP proposed in this report.
This section described the modalities provided in the project for the implementation of the
proposed mitigation measures to its potential negative impacts. It proposes the institutional
responsibilities for the implementation of the mitigation measures, the implementation
indicators, the time frame for monitoring and follow-up and also the estimated cost for the
implementation activities. The Environmental Management Plan of the plant is summarized
here
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Ensure that management assumes it corporate responsible for its activities with
regard to conservation of the environment as well as for the well-being of the
neighboring community.
The following policies need to be enhanced with respect to the new finishing unit:
a) Environmental management policy;
b) Occupational Health and safety Policy;
c) Local community policy; and
d) Employment policy.
Mondol Intimates Ltd. has already developed an Occupational health and safety policy.
This policy should be reviewed and revised to incorporation the proposed garment unit.
This enables the company put in place appropriate measures that will ensure that the health
safety and welfare of all employees is cared for; together with the health requirements of
the local community in which the company is conducting business. The policy highlight on
the following, among others:
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To address the potential impacts of solid wastes, health and safety impacts, noise and
vibration the following management plans are in force:
Waste management plan (WMP);
Noise Management Plan (NMP);
Emission Control and Management Plan (ECMP)
Resource Management Plan (RMP);
Occupational Hazards Management Plan
The environmental management plan developed for Mondol Intimates Ltd., identifies
potential negative environmental impacts and proposes mitigation measures and outlines
action plant for implementation. As major issues here only WMP, NMP, ECMP, RMP given
in separate report.
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Objective:
The objective of the WMP is to ensure that operations in the plant at all stages do not result
in releasing significant amount of waste to the environment. The WMP takes into critical
account all possible production process and waste treatment activities that can result in
generation of waste and waste water to pollute surrounding air, water and solid
environment.
Enforcement:
The WMP guiding principle ensures good housekeeping practices, proper and continuous
effective operation of waste management facilities, safety and environmental performance,
supported by regular feedback from the community through consultative meetings,
management reviews and evaluations.
Waste generated at Mondol Intimates Ltd., is in the form of dirt, kitchen/canteen wastes
and liquid waste generated mainly from sanitation process. Mondol Intimates Ltd., has
waste disposal policy for handling solid wastes.
[
Objective:
The objective of the noise management plan (NMP) is to ensure that cooperation of Mondol
Intimates Ltd., does not generate and result in noise pollution to the employees and local
community. The NMP is to be achieved by continuous monitoring of noise levels on site,
implementation of recommendations and mitigation measures made in this report in respect
to noise pollution and ensuring the conditions subjected to license approval with respect to
noise management are adhered to.
Sources of noise:
Likely sources of noise at Mondol Intimates Ltd., are Generator and other process
sections are potential source of noise.
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Noise minimization:
Noise at Mondol Intimates Ltd,. can be minimized by assessing the noise risks, protecting
employees against noise; proper maintaining and equipment use; training and sensitizing
of workers; health surveillance; and work reviews. Assessing of noise risks involves
identification of nose hazards at the work place and developing the appropriate action
plans. Employee protection involves elimination or controlling noise risks to acceptable
legal limits by use of good practice, appropriate engineering controls and employee
protection. Equipment use and maintenance involves appropriate use of all nose control
equipment and appropriate use of hearing protection. Training and sensitization of workers
involves employee accessing information and training on noise risks, control measures and
hearing protection. Health surveillance involves hearing checks for exposed workers and
using result to improve on protection of the workers. The noise generated from Mondol
Intimates Ltd. does not create any major problem to the local community but it is a problem
for workers.
Enforcement
[
The NMP guiding principle will be carrying out all site activities in a coordinated and
acceptable way continuous and sustained improvement in the construction and
implantation of the process operations, safety and environmental performance, supported
by regular feedback from the community through consultative meetings, management
reviews and evaluations. To ensure adherence to the set conditions, all the local and
national regulatory authorities will be enjoined in actions taken. This will include giving them
access to the facility to assess working conditions as far as noise is concerned and give
government directives as provided for in the law.
Objective
The objective of the ECMP is to ensure that operations in the plant at all stages do not
release significant amount of gaseous emission to the air environment beyond acceptable
limit. The ECMP takes into critical account all steam and electricity production process and
waste treatment activities that can result in generation of gaseous emission to pollute
surrounding air. This is to be achieved by regular monitoring of air on site, implementation
of recommendations and mitigation measures made in this report in respect to air pollution
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and ensuring that the conditions subjected to license approval with respect to pollution
control are adhered to.
Enforcement
The ECMP guiding principle will be proper storage and handling of chemical and use of
PPE, proper and optimum operation of generator, providing sufficient stack height and
regular monitoring of stack exhaust gases.
To ensure adherence to the set conditions, the all regulatory authority will be enjoined in
actions taken. This will include giving them access to the facility to assess working
conditions as far as air quality is concerned and give government directives as may be
required by law.
Gaseous Emission is generated mainly from the generator stack. The emission mitigation
action plan is given in table 7.2
The RMP, which Mondol Intimates Ltd., should have, is benchmarking of all resources
and try to optimize resource effectively. However Mondol Intimates Ltd., could easily set
up a resource management team to track, audit and report resource utilization and try to
optimize. The steams working principle could be easily done by following PDCA (Plan, Do,
Check and Act) cycle.
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Objective
The objective of the Occupational Hazards Management Plan (OHMP) is to ensure that
building and operation of the garments unit does not result in occupational hazards. The
OHMP covers possible occupational hazards such as fails, dust inhalation, high noise
levels and collapse of structures under construction. The plan is to be achieved by
continuous monitoring of work standards at site, implementation of recommendation and
mitigation measures made in this report in respect to occupational hazards and ensuring
the conditions subjected to license approval with respect to occupational hazards are
adhered to.
Enforcement
The OHMP guiding principle will be continuous and sustained improvement of site working
conditions and activities, environmental performance, supported by regular feedback from
employees, site engineers, neighbors and general public through consultative meetings,
management reviews and evaluation. To ensure adherence to the set conditions, all the
concerned local and National regulatory authority will be enjoined in actions taken. This will
include giving them unlimited access to construction site to assess working conditions of
employees, implementations of proposed mitigation measures and adherence to set
standards and give government directives as provided for in the law.
Background
Occupational hazards at garments industries include cuts and bruises when one come into
contact with moving parts of plant and equipment, falling from eighth, exposure to high
noise levels, among others. Occupational hazards in the workplace can be occasioned by
a number of factors including, poor housekeeping practices, poor plant and equipment
working condition that exposes workers to for example moving parts, dust and high noise
levels; lack of appropriate training on plant and equipment operation. Lack of and
inappropriate use of personal protective equipment by workers and visitors to the plant;
lack of appropriate warning at the workplace; poor enforcement on the use of provided
personal protective equipment and lack of engineering controls for example to reduce noise
are also some reason. Employees working at constructionists are more often than not
exposed to occupational hazards. These include but not limited to the following:-
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Falls;
Inhalation of dust and toxic gaseous emission;
High noise levels; and
Collapse of structures
Falls:
Occupational hazards resulting from working from height can be reduces by completely
sealing off the working site from access of general public and use of appropriate protective
gear like belts and elevators when appropriate.
Subjecting employees to high noise levels can result in an occupation hazards. High noise
level can potentially affect normal functioning and hearing mechanism. Noise sources at
construction site include noise resulting from machine activity, noise resulting from loading
and offloading of building materials, construction work and human activity. At operational
phase, noise is significantly generated in generator room. Employees can be protected
from high noise levels by ensuring that machines likely to produce high noise are filtered
with silencers and by providing employees with ear protectors.
Collapse of structure:
Sometimes building being constructed can be an occupational hazard to constructors and
the general public. In the recent past, sections of building under construction have been
reported caving in a collapsing killing employees on site and members of the general public.
Collapse of structure is associated with poor workmanship and not observing and
maintaining required standards and specification. Such collapses can be avoid by ensuring
that work standards are observed and that there is not compromise, site specifications are
observed strictly, design specifications are observed and length of time for curing and other
engineering requirements are observed.
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and pride because employees participate in identifying safety needs and developing safe
work procures.
Visitors to the worksite may also face legal action if they knowingly disobey safety rules in
addition, the company may face legal action and fines for violations of regulatory
requirements. Those individuals who do not fulfill their safety responsibilities will become
accountable for any problems their negligence creates and may be liable under the law.
All company employees are responsible for obeying all safety rules, following
recommended safe work procedures, weaning and using personal protective equipment
when required, participating in safety training programs and informing supervisors of any
unsafe work conditions. Everyone has the right and responsibility to reuse to do work when
unsafe conditions exist. By fulfilling safety responsibilities, workers will share the benefits
of a safety place. The company must have its own safety management and mitigation plan
Mondol Intimates Ltd., already has health & safety policy. Listed below are some
important features that need proper attention of company management.
The company must have its own safety policy. The safety policy should be updated from
time to time. The policy should be signed and dated by the chief safety officer. The policy
should be discussed with all personnel. The chief safety officer should periodically review
the policy and re-issue the policy.
b. Safety responsibilities
All personnel should have safety responsibilities assigned to them. The documented
responsibility should be included in the program manual. Compliance with the
responsibilities.
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c. Management Communication
The management should decide how it communicates periodically with the personnel
regarding safety. A site schedule for conducting site task should be development, this
should be included the safety program manual. Documentation of site tours should be
retained for verification.
d. Inspections
A list of all work sheets, equipment, vehicles and work practices requiring inspection should
be developed. Checklists and schedules should be developed as part of the inspection
program. A system for correcting deficiencies noted during the inspection process must be
developed. The system should prioritize deficiencies noted so that serious hazards are
dealt with immediately.
e. Safety Rules
Detailed rules and procedures identifying company and legislative requirements and
expectations must be communicated to all employees and contractors. They serve as a
reference and describe the minimum standard by which business is conducted. Most
important rules and procedures ensure consistency in the performances of tasks by all
employees. The current rules should be reviewed and assess as to whether they are
appropriate for the operation/facility /employees. The formulated rules must be
communicated to the works effectively, and workers must ensure that they understand the
rules and have no difficulty to comply with the rules.
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h. Protective Equipment
The main reason for protecting workers is to eliminate or reduce the possibility of injury.
The Occupational Health and Safety Act (USA) require that every worker shall wear or sue
such personal protective clothing, equipment or devices and is necessary for his or her
protection from the particular hazards to which he or she is exposed.
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There are some people who resist wearing protective clothing or devices, and will only wear
protective own safety. The consequences of an accident to his quality of life can be major.
He can also lose his life. Personal protective equipment provides the worker with a measure
of protection, but for it to be really effective; it must be accompanied by the right attitude
towards during his job the right way. The wearing of personal protective equipment does
not guarantee that he won’t get injured. However, when coupled with a good safety attitude
it with reduce the likelihood and severity of accidents.
The body and its internal organs can be seriously injured by any violent impact with an
object. A on below to any part of a worker’s body, even with protection, can easily result in
some injury either major or minor. The following eight areas or parts of the body require
protections.
Head
Arms
Eyes
Chest
Hearing
Legs
Hands
Feet
The worker’s head controls all the motor and sensory fictions of the body. Any blow to his
head, on matter how slight, can be very dangerous and result in injuries ranging from
dizziness to total disability and even death. One of our most valuable services is light. One
must protect his eyes from the dangers of flying objects, bright light and chemicals without
eyes one would live a life in total darkness. Hearing damage is not often a result of an
accident, unless someone has had a head injury. A more common problem is hearing loss
which can occur one exposed to noise levels above the exposure limits, as outlined in the
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noise regulation. In table 7.3 Occupational exposure limits are described with a maximum
permitted duration in the following page. Without hearing protection in a sound level of 100
dBA maximum permitted duration is 1 hour/day.
The longer one is expected to high Nosie levels, the greater the potential hearing loss.
Hearing loss associated with exposure to noise tends to be gradual, it may take several
years before one can realize that for some reason he has difficulty hearing normal
conversation. Hearing is a valuable asset that should be preserved, so the worker can have
a full and productive life.
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The Mondol Intimates Ltd., requires the regular monitoring of possible change in
environmental parameters to be undertaken during the construction and operational life of
the plant.
Moderate quantities of domestic wastewater are likely to be generated from the proposed
project during its operational life. These concerns become more concrete with the
increasing urbanization around the project site. The monitoring program to be developed
must take into account possible impacts of wastewater treatment and discharge. All wastes
and emissions emanating from the project and the method of disposal must be monitored
to ensure no environmental degradation arises.
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7.3.2.3 Parameters
Environmental monitoring request a set of indictors that could be converted resources
assess and evaluated periodically to establish trends of impacts. The indicators may by
indignant be may be functionally related. The monitoring program, in view of the possible
impacts as assessed lighter, should consider the indicators for the impact assessment
related to following issues is presented in table 7.6 in the following page. Monitoring will
encode measuring, observing recording and evaluation of physical, socio-economic and
ecological amiable within the project area and the neighborhood.
It is important for the facility management to set up regular monitoring programs to assess
parameters of the environment as stipulated in ECR 1997. This monitoring program will
help to identify changes in the environmental situations giving opportunities for adopting
appropriate control measures. A comprehensive checklist must be developed for
operational usage. The basic actives for a sound monitoring program should at least
include:
Collection and analysis of relevant environmental data of the project area;
Operation of process effect monitoring program and
Principal risk assessment programs should be introduces.
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This would be active the responsibility of the environmental health and safety officer and
occupation with the tats group appropriate as indication above.
Biannually (Recommended)
Note: According to Bangladesh Labor rules
Water-Quality Water quality test by third party
2015, Drinking water from any source
should be tasted at least annually.
Noise Noise measured in decibel (dB) Biannually
Waste Management
Daily
Solid Waste
Firemen
switch Testing
Servicing Fire Daily
extinguishers Monthly
Fire hazards Review Records of Quarterly
accidents which is Quarterly
recorded on & around the Biannual
entire facility,
DHS training
Site inspection of storage and
distribution facilities
Emergency preparedness and
Daily
personnel competence
Hazardous Material Biannual
Contamination investigation
As-needed basis
following any release of
hazardous materials to the
surrounding environment
All water taps shut when not in
use
Resource Usage
Power to unused equipment
shut at distribution panel
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environmental objectives and targets. In addition to the other records (legislative, audit and
review reports), management records shall address the following:
Details of failure in compliance and corrective action
Details of incidents and corrective action
Details of complaints and follow -up action
Appropriate contractor and supplier information
Inspection and maintenance reports
product identification and composition data
Monitoring data
Environmental training records
7.6 Materials, Supplies and Equipment [In house monitoring Capability]/ Monitoring
Budget
To be an environmentally acceptable industrial unit, the present factory should have its own
environment monitoring unit/cell with trained manpower with necessary equipment and
other logistics along with required budget. Mondol Intimates Ltd., should develop a
working relationship with the Department of Environment [DOE] by undertaking a joint
monitoring program to monitor the parameters given below in table or they may exchange
data and information or submit periodic report on self-monitoring to the DoE or as the
situation may require. The materials, supplies, equipment and personnel requirements are
largely guided by technical aspects of monitoring and such requirements thus, largely
control the budget of the monitoring program too. Mondol Intimates Ltd., should have
capability of conducting all kinds of monitoring which could be made successful by
arranging all kinds of equipment, laboratory, laboratory instrument, chemicals and
engaging technically efficient personnel. In case of lack of in house monitoring facility, the
company may engage any government approved 3rd party organization or apply to DoE to
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conduct monitoring. However, for conduction the monitoring program by third party a
proposed budget has been tabulated
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Chapter-8
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8.0 Introduction
Hazard analysis involves the identification and quantification of the various hazards (unsafe
conditions) that exist in the plant. On the other hand, risk analysis deals with the
identification and quantification of risks the plant equipment and personnel are exposed to,
due to accidents resulting from the hazards present in the plant. Hazard and risk analysis
involves very extensive studies, and requires a very detailed design and engineering
information. The various hazards analysis techniques that may be applied are hazard and
operability studies, fault-tree analysis, event-tree analysis and failure and effects mode
analysis. Risk analysis follows an extensive hazard analysis. It involves the identification
and assessment of risks the neighboring populations are exposed to as a result of hazards
present. This requires a thorough knowledge of failure probability, credible accident
scenario, vulnerability of populations etc. Much of this information is difficult to get or
generate.
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Plant equipment
Interface among system components
Operative environment
Operations (tests, maintenance, etc.)
Facility
Safety equipment
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8.2.3 Phase III and IV: Disaster Management Plan (DMP) and Emergency Response
Plan Preparedness Plan (EPP)
Safety review of especially vulnerable process units is covered in these phases. This helps
in reducing the risk qualitatively, while the outcome of phase I and phase II would reduce
risk in quantitative terms. Emergency preparedness Plan (EPP) based on the earlier
studies is covered in this activity. Customarily, major industries do have their EPPS and,
therefore, there is a need to look into those in detail and recommend a realistic EPP based
on the above studies.
8.3.1 Introduction
Preliminary Hazards Analysis (PHA) is based on the philosophy “Better than Cure”. Safety
is relative and implies freedom from danger or injury. But there is always some element of
danger or risk in anything we don or build. This calls for identification of hazards and
quantification of risk, and further suggests hazard -mitigating measures, if necessary.
The purpose of the preliminary hazards analysis (PHA) is to identify early in the design
process the potential hazard points at the design stage itself. Hence, preliminary hazards
analysis is more relevant when a plant is at design/construction stage. This technique,
applied early in the project lifecycle, helps to eliminate hazards and, thus to avoid costly
design modifications later. This analysis fortifies the proposed process design by
incorporating additional safety factors into the design criteria.
8.3.2. Methodology
An assessment of the conceptual design is conducted for the purpose of identifying and
examining hazards related to feed stock materials, major process component, utility and
support system, environmental factors, proposed operations, facilities, and safeguards.
A preliminary hazard analysis is carried out initially to identify the major hazards associated
with storages and the processes of the plant. This is followed by consequence analysis to
quantify these hazards. Finally, the vulnerable zones are plotted for which risk reducing
measures are deduced and implemented. The various process activities involved in the
plant operations are:
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Cutting
Sewing
Finishing
All the processes involve purely mechanical operations that are not complex or hazardous.
The other hazards related to the process equipment and storages area are given below:
Table 8.1 Preliminary Hazard Analysis for process Equipment and Storage areas.
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Generally, the initial response is guided by three priorities Ranked in importance these
priorities are:
1. People
2. Property
3. Environment
Emergency response procedures will identify who does what and when in the event of an
emergency. Responsibility for who is in charge and their coordination of emergency actions
shall be identified. Nature of emergency& Hazardous situations may be of any or all of the
following categories:
I. Emergency
Fire,
Explosion
Medical emergency,
II. Natural Disasters
Flood,
Earthquake/cyclone,
Storm/typhoon/tornados, and
Cloud burst lighting.
First Step:
This step determine the potential hazards associated with the incident, substance or
circumstances and take appropriate action identify the type and qualities of dangerous
goods involved and any known associated hazards.
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It also determine potential hazards stemming from local conditions such as inclement
weather water bodies etc. and ensure that the initial response team is aware of these
conditions.
Second Step:
Determine the source/cause of the event resulting to the emergency and prevent further
losses.
[
Third Step:
Conduct an assessment of the incident site for any further information on hazards or
remedies.
[
Fourth Step:
Initiate redress procedures.
Fifth Step:
Report the incidence its nature cause impact applied redress procedures and any further
assistance required etc. to the appropriate company, government and/or land owner.
Sixth Step:
Take appropriate steps with respect to hazards to wildlife, other resources and addressing
public and media concerns and issues, as applicable. Response priorities are to protect
human lives, property and the environment.
For this factory, emergency response systems should be in place to deal with dangerous
goods uncontrolled releases of dust and gaseous emission, natural calamities fires burns
and injuries. There are to be trained emergency response teams, specific contingency
plans and incidence specific equipment packages in place to cope with these types
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emergency. The factory already have emergency response plan taken necessary initiatives
to implement that plan.
In case of an emergency incident occur, immediate action must be taken to mitigate the
impacts. In order to minimize the possibility of injury to the responders and others it is
important that emergency responders follow a specific sequence of actions as stepped out
in the preceding paragraphs.
In the first, are disaster resulting from natural phenomena like earthquake volcanic
eruptions, storm surges, and cyclones tropical storms, flood &forest fires.
The second group includes disaster events associated by man or by man’s impact upon
the environment. Examples are named conflict, industrial accidents, factory fires,
explosions and entopic of low gases or substances river pollution, mining or other structural
collapses.
The objective of the industrial Disaster Management Plan is to make use of the combined
resources of the plant and the outside services to achieve the following:
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In normal operation of the plant, when all environmental protection equipment works
according to design specification, then there would be no environmental problems for the
present plant.
Disaster (to certain degree) may occur if the environmental protection equipment fails to
work at normal condition. This situation may arise for any of the following causes
When plant runs at abnormal situation e.g. if emission level increases than its normal
level or if the engines give unwanted noise than normal level
If liquid waste over flows and pollutes the surroundings therefore, appropriate
management plan should have to be taken by the project proponent to prevent any
unwanted disaster in the plant. In this regard, there should be a provision to stop the
production immediately during any process failure as discussed above. The disaster
management plan should consist of preventive measures including, among others,
the following.
Formulation and strict implementation of safety codes and measures;
Periodic inspection of safety relief valves provided with pressure vessels and
equipment; Preventive maintenance; Aware the workers about electric shock.
Declaring the factory a “no smoking fine”
Mack drifts by the firefighting cells groups
Prevision and inspection of firefighting equipment and fire hydrant system in all the
sections;
Prophet training of the employees about the importance of codes;
Training the employees and the residents of the surrounding villages about the
actions to be taken during an accident, disaster etc.
It is imperative to develop entire facility environment policy and display necessary
documentation for case in accessing information. Some of these documents include.
Emergency contacts;
Emergency response procedures for fires.
The facilities operations and monitoring are carried out under the management and help
from both the employees and relevant government lead agencies. In order to take care of
any hazards the following control should be adopted:
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All safety precautions and provision covering the general cleanliness of the entire facility
down to ventilation, lighting, sanitary, was collection, first aid box provision, adequate fire
extinguishers and site security by fencing.
Health and safety aspects of the entire facility should be given due attention. Protective
devices as provided should continuously be used within the unit’s operations to ensure the
safety of the natural resources and boat owners is guaranteed.
The maintenance of material safety Data sheets (MSDS) will be followed to ensure safety
all section of the facility that chemicals are utilized.
An Environment, Health and Safety register is essential for monitoring of performance of
the entire facility community to relation to the environment. The management with use this
as a self -auditing tool. This register should include:
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Chapter-9
Stakeholder participation
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Holett and Nagu (1997) define stakeholders as ‘all those people and institutions who have
an interest in the successful design, implementation and sustainability of the project. This
includes those positively and negatively affected by the project. Stakeholder participation
involves processes whereby all those with a stake in the outcome of a project can actively
participate in decisions on planning and management. They share information and
knowledge, and may contribute to the project, so as to enhance the success of the project
and hence ultimately their own interest. The possible stakeholders can be:
Directly involved:
Workers
Staffs
Local people:
Individuals
Communities/villages
traditional authorities e.g. village leaders
NGOs:
those which are active in local area or have interest on natural resources/social
welfare
interested parties in the country of any external financing agency
Voluntary organizations:
local community
development or users groups
kinship societies
recreational groups
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neighborhood associations
labor unions
gender groups
ethnic organizations
Cooperatives etc.
Private sector:
business interest groups
trade associations
Professional societies etc.
National/Local governments:
Those with responsibilities for management of natural resources along with people well and
those likely to be affected by the development project.
Scientist/experts:
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Stakeholders will be individuals or organizations who are most likely to be affected by, or
concerned with the imitative and are likely to include the public, statutory, local and national
interest groups, local communities and NGOs. Care must be taken to ensure that the weight
given to stakeholder views is representative to the level of support conveyed by an
organization or group. For example, the most coeval stakeholder group with the most
effective lobbying techniques may not necessarily be the most representative of the
community likely to be affected. Care should also be taken to ensure that all groups
concerned, including black, ethnic and minority groups are involved. Stakeholder
involvement brings in clarifications on points which were not previously grasped by the
stakeholders and elaborates on the roles of the various stakeholders while fine tuning their
expectations. False hopes are decried and stakeholders are edified on their rights, powers
and limitations. A common vision on project design in encouraged for example in the
development of Emergency response plans involving community members and leadership
structures, while the local capacities, knowledge and know-how which could be useful to
the project’s implementation could be identified.
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Public meeting: Public meetings offer an opportunity for anyone with an interest in the
subject of the consultation to express concerns and gain a broader perspective of concerns
in a short period of time. Sometimes it is expected that a decision will be made at a public
meeting, and there will be some level of consultation occurring. In controversial situations.
It may be best for the public meeting to be facilities by an independent body. Public
meetings often begin with a technical overview of the situation and process, and then
provide opportunity for members of the public to speak from the floor regarding their
concerns or to ask questions of expert panelists. Public meeting is open to all without any
restriction.
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In case of Mondol Intimates Ltd., the stakeholder participation has been conducted by
taking interview of different selected group of stakeholders and asking them some
questions.
The stakeholder consultation process is a good opportunity to know the social &
environmental impact of the factory in the current location. The Stakeholder participation of
Mondol Intimates Ltd., . has been conducted by asking interview of factory workers &
discussing with management personnel. Some questions has asked to total people to
collect their view about the factory. It has been explained during the field visit and the
meeting with the stakeholders that the public hearing is very crucial for the development
and planning of the project as it will help in forecasting the possible mitigation measures
for having better impacts on both the environmental and social life.
The key discussion issues are included but not limited to social impacts, health effect &
environmental impact. Workers are satisfied to their work environmental in the factory local
people including shopkeepers, dwellers of that area also expressed positive view about the
factory as the factory creates employment opportunity for them.
In case of Mondol Intimates Ltd., The stakeholder participation has been conducted by
taking interview of different selected group of stakeholders following some questionaries’
Different stakeholders was called in the factory to meet with EIA team and they share some
information regarding their involvement with the factory. Factory management presume
were also present in stakeholder participation and share their view.
The group of stakeholder presented in the meeting is:
Workers
Local people
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9.5.1 Workers
Worker interview has taken during factory visit. The workers view about the factory is found
satisfactory. The stated that the working environment is good, they get salary on time if
they faced any problem they inform their management and management take necessary
action immediately.
Other EIA team members have taken interview of local people the Local people
participations was limited to some shopkeepers residential peoples. During interview, they
raised no objection against the factory. Most of them are happy due to the factory
establishment as they get opportunity to exam their livelihood from the factory. The
shopkeepers outside the factory have also expressed satisfactory comment as they could
sell goods to the worker working in the factory.
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Chapter-10
Conclusion and Recommendations
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10.0 Conclusion
The EIA report has been prepared through identifying the potential impacts, assessing
them and recommending possible mitigating and enhancing measure for negative and
positive impacts, respectively.
Mondol Intimates Ltd., is a 100% Export oriented knit garment factory located at Shirir
Chala, Bager Bazar, Gazipur, Bangladesh. An EIA has been carried out for the whole
factory according to the requirement of the factory proponent although this factory requires
EMP as it falls under orange B category according to ECR 97 and it require EMP. However
this post EIA has been conducted as per the buyer’s demand.
Health and safety issues and impacts due to solid wastes are the major impacts associated
during the operation phase of Mondol Intimates Ltd., This may create long term and
irreversibly effect to a limited degree on the receiving environment if no mitigation measures
are adopted.
However, in the case of Mondol Intimates Ltd., all necessary implementation measures
to mitigate adverse environmental, health and safety impacts have already been taken to
meet national Environmental Quality Standards. On the other hand, the factory has a
positive impact in terms of employment in the operation phase, further, this will indirectly
help in boosting up the national economic condition through foreign investment. An outline
of EMP has been given in the present report to mitigate/enhance the impacts, which
generally occurs during operation phase of the factory.
Although the factory is situated in Industrial zone, there is no major environmental issue of
sensitive nature, which might have any potential of serious effects due to the factory in this
area. Since it is understood that the factory proponent is committed to take necessary steps
to address and environmental problems, the selected location of Mondol Intimates Ltd.,
is environmentally acceptable.
However, adequate and effective pollution prevention, abatement and control measure
proper and careful operation and maintenance, regular and effective environmental
monitoring with adequate staff and budgetary provision, and reporting to DOE should
ensure. It is expected that Mondol Intimates Ltd., will follow all environmental compatible
steps during by which it sets a positive example as an environmental friendly industrial unit,
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very much within the environmentally acceptable limits all the time. It is also expected that
DOE will do surveillance monitoring of the factory performance.
The findings of this Environmental impact Assessment (EIA) suggests that the factory
involves potential but limited environmental impacts to which further careful attention
should be given to minimize and offset the adverse effects. The possible negative impacts
are not severe, and the adverse impacts if duly addressed could be minimized without
much effort, though they would require attention and positive commitment from the factory
management.
10.1 Recommendations
Several environmental and social considerations need to be comprehensively addressed
to improve the sustainability of the factory some of these improvement proposals are
summarized below:
1. Workers to be given appropriate personal protective equipment. It need to ensure
that workers are using PPE. During the operation of generator and some machines
ear muff and in printing section hand gloves need to wear by the relevant workers.
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References:
1. De, A. K. 1989 Environmental Chemistry, Wiley Eastern Ltd. New Delhi, India.
2. AECL,l 2000, Environmental Impact Assessment of Mymun Textiles Ltd. At
nayapara, Kashimpur, Gazipur.
3. AECL 2005 Environmental Impact Assessment of Hamza Textiles at Nayapara,
Kashimpur, Gazipur.
4. Archival, 1994, Wastewater Treatment for pollution Control, Tata MCgrow-Hill
Publishing Co, Ltd, New Delhi, India.
5. “2006 IPCC Guidelines for National Greenhouse Gas inventories for Stationary
Combustion (Volume 2 Energy Chapter 2)
6. BBS, 1998, the statistical Yearbook of Bangladesh. Bangladesh Bureau of Statistics
Dhaka, Bangladesh.
7. Canter, G.T. 1983. Environmental Impact Assessment Handbook. McGraw Hill.
8. DOE, 1995 the Bangladesh Environment Conservation Act, Department of
Environment.
9. DOE, 1997, The Environmental Conservation Rules, Department of environment.
10. Eckenfelder, 1989, Industrial Water Pollution Control”. MC gRawHill inc, Singapore
England Environment, Govt. Of Bangladesh.
11. GOB 1992 Bangladesh Environmental Policy.
12. GOB 1995 National Environmental Management Action Plant (NEMAP).
13. Kudesia, 1996 industrial pollution Pragati parakashani, Meerut, India.
14. Metcalf & Eddy, 1997Wastewater Engineering, McGraw Hill Inc, Singapore.
15. Munn, R.E. 1979. Environmental Impact Assessment: Principal and Procedures.
16. Peavy& Rowe. 1989 Environmental Engineering. Mc Graw Hill Inc. Singapore.
17. Pouloudi, A 1997, Stakeholders Analysis as a Front End to Knowledge Elicitations.
Al &Society, 11, 122, 137.
18. Dara, S.S. 1995, Environmental Chemistry and Pollution Control S. Chand &
Company Ltd,. New Delli. India.
19. Sawyer & M carty. 1994. Chemistry for Environmental Engineers. Mc Graw-Hill Inc.
Singapore.
20. Sincero & Sincereo1999 Environmental Engineering, Prentic Hall of India Private
Ltd. New Delhi.
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Annexure
Factory Layout Picture
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Mouza Map
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Water Testing Report
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Annexure
Site Clearance Certificate from Local
Authority
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Factory license
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Trade license
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Fire license
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Permission of BERC
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Permission for Boiler
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List of Machineries
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Medical Agreement
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Agreement with Waste Buyer.
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Soil Test Report
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