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EIA Report

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Environmental Impact Assessment (EIA)

Mondol Intimates Ltd.

Conducted By:

GREENTECH TESTING COMPANY


Environmental Impact Assessment (EIA)

Mondol Intimates Ltd.

Shirir Chala, Bager Bazar, Gazipur, Bangladesh.

Environment Impact Assessment (EIA)


Mondol Intimates Ltd.
Shirir Chala, Bager Bazar, Gazipur, Bangladesh.

Conducted By

GREENTECH TESTING COMPANY LTD.


Lab office: Corporate Office:
Nilu Plaza, 256/A, West Dhanmondi, House: 4 Sobhanbag, Mohammadia Super
Dhaka-1209, Bangladesh Market, Dhanmondi-27, Dhaka-1207
Contact: +8801727-310675, 01795-333332 Contact: +8801727-310675, 01795-333332

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Environmental Impact Assessment (EIA)

Mondol Intimates Ltd.

Shirir Chala, Bager Bazar, Gazipur, Bangladesh.

Environmental Impact Assessment (EIA)


Report
Submitted to

Mondol Intimates Ltd.

Prepared By Approved By

Ms. Sadia Afrin Nitol MD. Habibur Rahman


B.Sc. (Hon’s) & M.Sc. in Environmental B.Sc (Enng.) & M.Sc in Environmental
Sciences Engineering
Jahangirnagar University, Shajalal Science & Technology University,
Savar, Dhaka. Sylhet
Environmental Specialist of Environmental Specialist of
Greentech Testing Company Ltd. Greentech Testing Company Ltd.

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Environmental Impact Assessment (EIA)

Mondol Intimates Ltd.

Shirir Chala, Bager Bazar, Gazipur, Bangladesh.

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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2.3.11 The Acquisition and Requisition of Immovable Property Ordinance (1982)


2.4 Environmental Clearance Procedures in Bangladesh
2.4.1 Screening
2.4.2 Initial Environmental Examination
2.4.3 Scoping
2.4.4 The EIA
2.4.5 Location Clearance & Environmental Clearance Procedure
Description of the Factory:
3.0 Description of the Factory:
3.1 Factory Overview
3.2 Location of the Factory
Chapter 3
3.3 Present Status of the Factory
3.4 Manufacturing Process
3.5 Raw Materials
3.6 Machineries & Utilities
General Consideration
4.0 General Consideration
4.1 Study Area
4.2 Physio-Chemical Environment
4.2.1 Surrounding Land Uses
4.2.2 Land Form & Soil Classification
4.2.3 Water Quality
4.2.3.1 Surface Water Quality
4.2.3.2 Ground Water Quality
4.2.4 Air Quality
Chapter 4
4.2.4.1 Outdoor Air Quality
4.2.4.2 Stack Air Emission data- Generator
4.2.7 Rainfall
4.2.8 Temperature
4.2.9 Humidity
4.2.10 Wind
4.3 Biological Environment
4.3.1 Introduction
4.3.2 Terrestrial Habitat
4.3.3 Wetland Habitat

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Shirir Chala, Bager Bazar, Gazipur, Bangladesh.

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

5.2.1.1 Geology and Soils

5.2.1.2 Topography and landforms

5.2.1.3 Climate and Meteorology

5.2.1.4 Air Emissions

5.2.1.5 Noise

5.2.1.6 Hydrology
5.2.1.7 Water Quality

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5.2.1.8 Solid Waste


5.2.2 Biological
5.2.2.1Flora & Fauna
5.2.2.2Ecosystems
5.2.3Socio Economic Status
5.2.3.1 Demographic
5.2.3.2 Land Use
5.2.4 Occupational Health and Safety
Evaluation of Potential Impacts & Mitigation Measure
6.1 Evaluation of Environmental Aspects, Potential Impacts, Risk assessment
and Mitigation Measure with the factories operational Phase.
6.2 Adverse Impacts and Mitigation and Positive Impact Enhancement
6.2.1 Pollution from solid and Liquid Waste
6.2.2 Impact on Health and Safety, Accident and Emergency
6.2.2.1 Proposed Mitigation Measures
6.2.2.2 Mitigation measures already implemented
Chapter 6 6.2.3 Impact on Air
6.2.4 Impact on Resources
6.2.5 Vibration Management
6.2.6 Noise Management
6.2.7 Odor management
6.2.8 Traffic Congestion
6.3 Anticipated Positive Impacts of the Proposed Project
6.3.1 Opportunity to expand Textile Business and Export Earning
6.3.2 Job Opportunities
7.0 General Considerations
7.1 Mitigation/Benefit Enhancement Measures
7.2 Management Policies
7.2.1 Environmental Management Policy
7.2.2 Occupational Health and Safety Policy
7.2.3 Local Community Policy
7.2.4 Employment Policy
7.3 Tree Planting Program
7.4 Detail Management Plans
7.4.1 Waste Management Plan (WMP)

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7.4.3 Emission Control and Management Plan (ECMP)


7.4.4 Resource Management Plan (RMP)
7.4.5 Occupational Hazards Management Plan
7.5 Environment Monitoring Program
7.5.1 Monitoring Requirement
7.5.2 Monitoring Indicators
7.5.2.1 Active Monitoring
7.5.2.2 Reactive Monitoring
7.5.2.3 Parameters
7.5.3 Environmental Management Records
7.5.4 Environment Audit
7.6 Materials, Supplies and Equipment Monitoring Budget
Risk Analysis and Disaster Management Plan
8.0 Introduction
8.1 Scope of the Study
8.2 Approaches to the Study
8.2.1 Phase I: Hazard Identification
8.2.2 Phase II: Hazard Assessment and Evaluation
8.2.3 Phase III and IV: Disaster Management Plan (DMP) and Emergency
8.3 Hazard Assessment and Evaluation
8.3.1 Introduction
8.3.2 Methodology
8.3.3 Preliminary Hazard Analysis (PHA)
Chapter 8 8.4 Emergency Response and Disaster Management Plan
8.4.1 Six Steps in Emergency Response
8.4.2 Reporting Incidents and Accidents
8.4.3 Approaches to Emergency Response
8.5 Disaster Management Plan
8.5.1 Environment, Health and Safety (EHS)
Stakeholder Participation
9.0 Identification of Stakeholder
9.1 Purpose of Stakeholder Participation
Chapter 9
9.2 Importance of Stakeholder Involvement
9.2.1 Benefits of Stakeholder Involvement in EIA
9.2.2 Limitation of Stakeholder Involvement

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9.3 Method of Stakeholder Involvement


9.4 Key issues Raised during Stakeholder Participation
9.5 Stake holder Participation Meeting
9.5.1 Chemical Supplier
9.5.2 Local People
Conclusion and Recommendation
10.0 Conclusion
Chapter 10 10.1 Recommendation
References
Annexure

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Environmental Impact Assessment (EIA)

Mondol Intimates Ltd.

Shirir Chala, Bager Bazar, Gazipur, Bangladesh.

List of Tables:

Table-1.1: EIA benefits and flaws


Table-2.1: Environmental issues and Relevant laws and regulations in Bangladesh
Table-2.2: ECR Environmental Categories for projects and industries
Table-2.3: Bangladesh Standards for Ambient Air (in microgram per cusec meter)
Table-2.4: Bangladesh standards for wastewater from industrial units
Table-2.5: Bangladesh standard for stack Emission from industrial/projects
Table-2.6: Bangladesh Standard for Ambient Noise
Table-2.7: Bangladesh Standard for Odor
Table-3.1: Factory Profile
Table-4.1: Drinking Water Quality Monitoring Report.
Table-4.2: Indoor Air Quality Monitoring Report.
Table-4.3: Outdoor Air Quality Monitoring Report.
Table-4.4: Stack Air Emission data-Generator
Table-4.5: Noise Level Monitoring Report.
Table-4.6: Monthly Maximum Temperatures at Dhaka in 2012
Table-4.7: Monthly Minimum Temperatures at Dhaka in 2012
Table-4.8: Terrestrial Fauna Planted Flora.
Table-4.9a: Terrestrial Fauna Reptiles.
Table-4.9b: Terrestrial Fauna Mammals
Table-4.9c: Terrestrial Fauna Birds.
Table-4.10: Aquatic Flora of The Project.
Table-4.11: Endangered and threatened species.
Table-5.1: Electricity Consumption (kWh) of the factory.
Table-6.1: Likelihood scoring
Table-6.2: Severity of impact consequence
Table-6.3: Risk Rating Matrix
Environmental Aspects, Impacts, Risk assessment and Controls
Table-6.4:
associated with the factories operational Phase.
Table-7.4: Air Pollution & Dust Management Plan
Table-7.5: Noise & Vibration Management Plan
Table-7.6: Solid Waste Management Plan

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Hazardous Chemicals or other Substances Handling, Storage and


Table-7.7:
Disposal Plan
Table-7.8: Energy Management Plan
Table-7.9: Soil management Plan
Table-7.10: Drainage Management Plan
Table-7.11: Ecological Flora & Fauna Management Plan
Table-7.12: Emergency Response & Disaster Management Plan
Table-7.13: Environmental Monitoring schedule at a glance
Table-7.14: Summary of proposed environmental monitoring schedule
Table-7.5: Environmental Management and Monitoring Budget
Table-8.1: Preliminary Hazard Analysis for process Equipment and Storage Areas

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List of Figures

Fig.1.1: EIA concept and eight guiding principles


Fig.3.1a Location of the project in Bangladesh
Fig.3.1b: Surrounding site picture from Google map.
Fig.3.1c: Google Satellite Map of the factory.
Fig.3.2b: Process Flow Diagram.
Fig.3.2b: Production Flow Diagram.
Fig.4.1: Agro-Ecological zones of Bangladesh
Fig.4.2: Physiographic Map of Bangladesh
Fig.4.3: Elevation Map of Bangladesh.
Fig.4.4: General Soil Map of Bangladesh.
Fig.4.5: Drinking Water Quality Test Report
Fig.4.6: Monthly Average Rainfall of Last Ten years (BMD, 2001 to 2011).
Monthly Average Temperature of Last Ten years (BMD, 2001 to
Fig.4.7:
2011).
Fig.4.8: Average and Minimum Humidity (BMD, 2001 to 2011)
Monthly Average Wind Speed of Last Ten years (DMD, 2001 to
Fig.4.9:
2011).
Fig.4.10: Map of Earth Quake Zones of Bangladesh.
Illustrates an example system approach to plant construction &
Fig.8.1:
operations.

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Environmental Impact Assessment (EIA)

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Shirir Chala, Bager Bazar, Gazipur, Bangladesh.

ABBREVIATION

BOD Bio-Chemical Oxygen Demand


BBS Bangladesh Bureau of Statistics
BMD Bangladesh Meteorological Department
COD Chemical Oxygen Demand
DOE Department of Environment
DAE Department of Agricultural Extension
EIA Environmental Impact Assessment
ECR Environment conservation rules 1997
ECC Environmental clearance certificate
EMP Environmental management plan
EPZ Export processing Zone
EMS Environment Management System
EMF Environmental Management Framework
GOB Government of Bangladesh
GPS Global Positioning System
GIS Geographic Information system
IEE Initial Environmental Examination
ISO International Organization for Standardization
MOEF Ministry of Environment and Forests
NGO Non-Government Organization
NEMAP National Environmental Management Action Plan
REB Rural Electrification Board
WB World Bank

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Glossary

Ambient air: Surrounding air.


Adverse impact: An Impact that is considered undesirable.
Aquatic: Growing or living in or near water.
Accident: It is an unplanned event, which has a probability of causing personal injury or
property damage or both.
Baseline (or existing) conditions: The “baseline” essentially comprises the factual
understanding and interpretation of existing environmental, social and health conditions of
where the business activity is proposed.
Beneficial impacts: Impacts, which are considered to be desirable and useful.
Biological diversity: The variety of life forms, the different plants, animals and
microorganisms, genes they contain and the ecosystems they form. It is usually considered
at three levels: genetic diversity, species diversity and ecological diversity.
Disaster: It is defined as a catastrophic situation that causes damage, economic
disruptions, loss of human life and deterioration of health and health services on a scale
sufficient to warrant an extraordinary response from outside the affected area or
community. Disasters occasioned by man are factory fire explosions and release of toxic
gases or chemical substances etc.
Environmental impact assessment (EIA)/Environmental assessment: The systematic,
reproducible and interdisciplinary identification, prediction and evaluation, mitigation and
management of impacts from a proposed development and its reasonable alternatives,
sometimes known as environmental assessment.
Emission: The total amount of solid, liquid or gaseous pollutant emitted into the
atmosphere from a given source within a given time, as indicated, for e.g., in grams per
cubic meter of gas or by a relative measure, upon discharge from the source.
Ecosystem: A dynamic complex of plant, animal, fungal and microorganism communities
and associated non-living environmental interacting as an ecological unit.
Endangered species: Species in danger of extinction and whose survival is unlikely if the
existing conditions continue to operate included among those are species whose numbers
have been reduced to a critical level or whose habitats have been so drastically educated
that they are deemed to suffer from immediate danger of extinction.

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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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Initial Environmental Assessment/Evaluation: Preliminary analysis undertaken to


ascertain whether there are sufficient likely significant adverse impacts to warrant a “full”
EIA. In some counties, use of initial assessment forms a meaning of “screening” proposed
projects.
Khal: Small Channel, canal.
Land use: Types include agriculture, horticulture, settlement and industries.
Mitigation: An action, which may prevent or minimize adverse impacts and enhance
beneficial impacts.
Mauza: A Bengali word for the smallest government administrative area corresponding to
village revenue unit.
Negative Impact: Negative change from the existing situation due to the project.
Public involvement/Public consultation: A range of techniques that can be used to
inform, consult or interact with stakeholders affected/to be affected by a proposal.
Risk: It is defined as a likelihood of an undesired event (accident, injury or death) occurring
within a specified period or under specified circumstances. This may be either a frequency
or a probability depending on the circumstances.
Reversible impact: An environmental impact that recovers either through natural process
or with human assistance (e.g. cutting off fish migration by an embankment might be
reversible at a later stage if a proper regulator is built).
Stakeholders: Those who may be potentially affected by a proposal, e.g. Local people,
the proponent, government agencies, NGOs, donors and others, all parties who may be
affected by the project or to take an interest in it.
Terrestrial: Living on land.

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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].

This is a post Environmental Impact Assessment (EIA) report prepared as a requirement


of the factory proponent. According to the general procedures required for getting
environmental clearance certificate from DOE, a readymade garment facility as it falls
under Orange-B category according to inclusion list of ECR, 1997; schedule-1 (Clause C)
required conducting EIA. It requires initial Environmental Examination, but as the factory is
already built and the factory proponent is wiling as per the buyers demand thus this EIA
has been conducted.

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.

Bangladesh is earning substantial amount of foreign currency through export of garments


product. The Ready-Made Garments (RMG) industry contributes to the Bangladesh
economy in a distinctive manner. The last 20 years witnessed unparalleled growth in this
sector, which is also the largest exporting industry in Bangladesh. It has attained a high
profile in terms of foreign exchange earnings, exports, industrialization and contribution to
GDP within a short span of time. The industry plays a significant role in terms of
employment generation.

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.

1.1 Purpose of the Environmental Impact Assessment (EIA) Study


EIA is a systematic process to identify, predict and evaluate the environmental effects of
proposed actions and projects. This process is applied prior to major decisions and
commitments being made, a broad definition of environment is adopted.

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The purpose of EIA is to:

Provide information for decision-making on the environmental consequences of proposed


actions; and promote environmentally sound and sustainable development through the
identification of appropriate enhancement and mitigation measures.

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.

1.2 Principle of Environmental Impact Assessment


EIA is applied by countries with different levels of development, types of government and
cultural traditions. The arrangements and practices that are in place in different countries
vary, in some cases substantially, as a result of these factors. A general distinction can be
made between the characteristics of EIA systems of developed and developing countries.
While those of developing countries are less advanced, the EIA process is similar, with
common elements, steps and activities. In addition, the same basic principle for EIA good

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practice is applied internationally to both developed and developing countries (EIA Centre,
1995).

EIA Principles and Process

Figure: 1.1: EIA Concept and Eight guiding principles.

The eight guiding published of EIA:

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.

Credibility: Assessment undertaken with professionally and objectivity.

Accountability: The decision maker are responsible to all parties for their action and
decisions under the assessment process.

1.3 The EIA Process:


Section 12 of the Environmental Conservation Act stipulates “No industrial unit or project
shall be established or undertaken without obtaining environmental clearance from. The
Director General of the DOE in the manner prescribed by the Environmental Conservation
Rules (ECR) 1997. The DOE, which is a statutory body under the Environment
Conservation Act, is responsible for review and evaluation of IEEs and EIAs prepared for
projects in Bangladesh. The whole EIA of this factory has been undertaken following DOE
guideline & complying national & international regulation.

1.3.1 Definition of EIA


Several authors and organizations have put forward several definitions, which provide of
board indication of the objectives of EIA but illustrate defecting concepts of EIA some of
these definitions are given below:
a) To identify, predict and to describe to appropriate terms the penalties and benefits of a
proposed development. To be useful, the assessment needs to be communicated to terms
under stable by the community and decision makers and the pros and cons should be
identified on the basis of criteria relevant to the countries affected”.

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”.

1.3.2 EIA Methodologies


The Process of EIA essentially comprises of three sequential elements impact
identification, prediction and evaluation.

Impact Identification: It is involved in describing the existing environmental system as well


as determining the components of a development project, which shall have effects on the
environment. Identification and be chooses by the following methods.

a) Checklists
b) Matrices
c) Networks
d) Environmental Evaluation System (EES)

Check lists: Checklists methodologies range from listings of environmental factors to


highly structured approached involving importance weightings for factors and the
application of scaling techniques from the impacts of each alternative on each factor. There
are different types of checklists, some of them are as follows:
 Simple Checklist
 Descriptive Checklist
 Scaling Checklist
 Weighting Scaling Checklist.
Matrices: Interaction matrices as mentioned by Canter (1983) were one of the earliest
types of methodologies utilized in the U.S. The simple matrix refers to a display of project
actions or activities along one axis, with appropriate environmental factors listed along the
other axis of the matrix. When a given action or activity is anticipated to cause a change in
an environmental factor, this is noted at the interaction point in the matrix.
Networks: It is capable of identifying and indirect impacts, higher order effects and
interactions between impacts and hence, is able to identify and incorporate mitigation and
management measures into the planning stages of a project. They are suitable for
expressing ecological impacts but of lesser utility in consideration involving social, human
and aesthetic aspects. This is because weightings and rating of impacts are not features
of network analysis.

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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.

To avoid unnecessary expense, the sophistication of the prediction methods to be used


should be kept in proportion to the “scope” of EIA for instance, a complete mathematical
model of atmospheric dispersions should not be used if only a small amount of relatively
harmless pollutant is emitted. Simple models are available and are sufficient for the
purpose.

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 BEES is based on scaling, weighting checklists consisting of a description of


environmental factors related to the project along with the instructions for scaling the values
of each parameter and assigning importance units.

The major feature of BEES is that environmental impact is expressed incommensurate


units providing common units for comparison. The steps involved in the development of
commensurate units include transformation of parameter estimates into an environmental
quality (EQ) scale, assignment of importance units to individual parameters (PIU) and the
multiplication of scale value by importance values to obtain environmental impact units.

1.3.3 Methodology & Process of existing EIA

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.

The environmental baseline, project components, possible environmental impacts,


mitigation measures and environmental management plan are presented in this report
following the DOE guidelines.

1.4 Scope of Study and Limitations

1.4.1 Study scope

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:

 The baseline conditions of the current factory area,


 Description of the factory,
 Relevant legislative, policy and administrative frameworks,
 Views/opinions of the public and other stakeholders.
 Identification of significant adverse impacts to the environment,
 Mitigation measures to adverse impacts, and
 An Environmental Management Plant for the current industry.

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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.

1.4.2 Benefits & Flaws of EIA Study


EIA generates huge benefit sin selection of project location, process, design, development
actions, and decision-making; however, in the current practice of EIA there are a number
of flaws, shortcomings and deficiencies. The table below summarizes apparent benefits
and flaws of the EIA.

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Table 1.1: EIA benefits and flaws.

Benefits Flaws

Provides systematic methods of impact assessment Time-consuming

Estimates the cost/benefit trade-off of alternative


Costly
actions

Facilitates the public participation Little public participation in actual implementation

Provides an effective mechanism for Coordination Unavailability for reliable data (mostly in developing
Environmental integration Negotiations Feed back countries)

To-level decision making Too focused on scientific analysis (sometimes)

Poor presentation of EIA report (bulky volumes, scientific


Triggers an institutional building
explanation, difficult to understand)
Achieve a balance between the impact of
Compliance monitoring after EIA is seldom carried out
developmental and environmental concern

1.5 Study Area


The study area covers the entire area of the factory Mondol Intimates Ltd.

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.

Finally, an Environmental, Safety and Social Management Plan to mitigate negative


impacts has been developed, including a detailed Environmental and Social Management
Plant with feasible and cost-effective measures to prevent or reduce significant negative
impacts to an acceptable level, and containing detailed implementation plans, monitoring
indicators and clear allocation of responsibility among factory personnel, government
agencies, and community-based organization. Also, an Environmental and Safety
Management Plan, focusing on mitigation measures to address the environmental and
safety consequences associated with operational activities of the factory has been
prepared.

1.6.1 Terms of Reference (ToR)


The ToR includes the following condition:
 As per the ToR the EIA need to be conducted within one month of accepting
proposal by client.
 The EIA report will be communicated with factory proponent.
 A multidisciplinary team comprising EIA consultant, Environmental Scientists, Social
Consultant, Chemists and Field Assessors need to be involved for conducting EIA
& preparing & reviewing the report.
 Stakeholder participation needs to be conducted by consulting with the local people
and Workers of the factory due to lack of time.

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1.7 The EIA Team

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.

The Mondol Intimates Ltd. management personnel, compliance & maintenance


personnel helped the EIA team by providing necessary information & supports for the
successful completion of this EIA. Greentech Testing Company Ltd., EIA team are
especially thankful to following personnel for their valuable information and nice
cooperation:
1. Md. Shamsul Haque, Manager-HR and Compliance
2. Shymal Chanra, Engineer
3. Joly, Assistant Manager
4. Nur-e-Jannat, Welfare Officer
5. Liacot, Assistant In charge of Utility.

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Chapter-2
Policy and Legal Consideration

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2.0 Policy and Legal Considerations

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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human settlement highway/railway boundary and high line (Classical regions) or


natural/modified flood repair boundary.

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.

2.2 Bangladesh legal Framework:


The requirements for compliance with environmental regulations are laid down by the
policy, legal & regulatory framework in the country. A large number of laws related to
environmental issues. Some dating based on 19th century exist in Bangladesh. The most
important of these are the Environmental Conservation Act, 1995 (ECA95) and the
Environmental Considerations rules (under the ECA, 1995), 1997 (ECR97).

Table 2.1: Environmental issues and relevant laws and regulations in Bangladesh.
Enforcing
Issues Laws/Regulations Regulated/Enforced items
Agency

Promulgation of standards for


ECA, 1995
MoEF/DOE water quality Promulgation of
ECR 1997
Water “ discharge limits Prosecution of
Environmental Court Act, 2000
pollution “ offenders Control of
The Local Government Ordinance,
UPS Environmental sanitation in
1983.
rural areas
Promulgation of standards for
ECA, 1995
air quality Promulgation of
ECR 1997 (amended 2005) MoEF/DOE
emission standards for Motor
Environmental Court Act, 2000 “
Air pollution vehicles and industries
Brick Burning Control Act, 1989 “
Prosecution of offenders
(Amended 1992) Motor Vehicle Act, BRTA/Police
Prosecution of offending
1983
vehicles
ECA, 1995 MoEF/DOE Promulgation of standards for
Noise pollution
ECR 1997 BAEC noise levels
Toxic of Promulgation of standards and
ECA, 1995
hazardous management rules.
ECR 1997 MoEF/DOE
waste pollution Promulgation of standards and
Nuclear Safety and Radiation
solid waste rules for management of
Protection Ordinance, 2000
pollutions radioactive materials.
Promulgation of standards for
ECA, 1995 water quality Promulgation of
Marine
ECR 1997 MOLF discharge limits
pollution
Environmental Court Act, 2000 Promulgation of regulatory
measures
Pollution of The Protection and Conservation of Promulgation of regulatory
DA
fisheries Fish Act, 1950 measures

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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

2.2.1 Environment Guidelines for Projects in Bangladesh


As pointed out earlier the most important of the laws/rules in table 2.1 are the ECA 95 and
the ECR 97. The ECA 95 is primarily an instrument for the Department of Environment
(DOE) and for controlling industrial pollution. The Act also includes ‘Polluter Pay Principle’
in general terms in that as it states “if any particular activity is causing damage to the eco-
system, the responsible party will have to apply corrective measures”. The ECR 97 was
promulgated under ECA 95 to operationalize the enforcement of the Act. The modifications
to ECR can be brought about by executive orders requiring no new legislation. Thus, the
rules can be moldered from time to time when sound technical reasons exist without going
through the long drawn legislative process.

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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Table: 2.2: ECR Environmental


WB
Sub- Clearance
Category project Comments
projects/Industries Requirements
Category
Only local authority clearance
needed Many BRW SSP sub projects
Non Projects Listed in
point sources and household
Green the ECR (only None C
sanitation units () will in their
industries)
category and should not require any
environmental clearance from DOE.
Although small scale piped water
supply is not listed under this
IEE, Feasibility
Orange A Small-scale industries B category, considering the impacts,
Report
the BRWSSP subprojects are likely
to fall in this category.
BRWSSP subprojects can be
Medium Scale IEE, Feasibility classified in this category also as
Orange-B B
Industries Report water purification plants fall under
this category (le. Sl 28 of the list).

This is a category for large scale


IEE, Feasibility water treatment plant and BRWASSP
Red Water Treatment Plant A/B
Report, EIA subprojects are not expected in this
category

* Full list available in schedule-1 of ECR 1997

2.3 Relevant National Policies and Legislation:


The places of Policy and legislation which apply to such project execution program are
described in the following sections:

2.3.1 National Conservation Strategy (NCS) 1992


National Conservation strategy was drafted in late 1997 and submitted to the government
in early 1992. This was approved in principle; however the final approval of the documents
is yet too made by the cabinet.
For sustainable development in the energy sector, the strategy document forefend various
recommendations but none was there concerning the present specific project execution
process or related matter.

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Major relevant recommendations are:


To use minimum possible of land area in exploration sites;
Rehabilitate site when abandoned;
To take precautionary measures against environmental pollution from liquid effluent,
condensate recovery and dehydration plants; and Technology assessment for selection of
appropriate technology.

2.3.2 National Environmental Management Action Plan (NEMAP), 1995


The National Environmental Management Action Plan (NEMAP) is a wide ranging and
multifaceted plan, which builds on and extends the statements set out in the National
Environmental Policy, ENMAP was developed to address issues and management
requirements for a period between 1995 to 2005 and set out the framework within which
the recommendations of the national conservation strategy are to be implemented.

NEMAP has the broad objectives of:


 Identification of key environmental issues affecting Bangladesh.
 Identification of actions necessary to halt or reduce the rate of environmental
degradation.
 Improvement of the natural and built environmental.
 Conservation of habitats and bio-diversity.
 Promotion of sustainable development; and
 Improvement in the quality of life of the people.
 One of the key issues in NEMAP regarding the energy is that “energy conservation
awareness is generally low throughout the country.
2.3.3 Forest Policy (1994)
The National Forest Policy of 1994 is the amended and revised version of the National
Forest Policy of 1977 in the light of the National Forestry Master Plan. The major target of
the policy is to conserve the existing forest areas and brings about 20% of the country’s
land area under the forestation program and increase the reserve forest land by 10% by
the year 2015 through coordinated efforts of GO-NGOs and active participation of the
people.

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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importance of fulfilling the, responsibilities and commitments under international


conventions, Treaties and protocols (ICTPs).

2.3.4 Industrial Policy (1999)


The National industrial Policy, 1999 aims to ensure a high rate of investment by the public
and private sectors, a strong productive sector, direct foreign investment, development of
labor intensive industries, introduction of new appropriate technology, women’s
participation. Development of small and cottage industries, entrepreneurship development,
high growth of export, infrastructure development and environmentally sound industrial
development. WTO guidelines have been proposed to be followed in the industry Policy.
Following the guidelines may result in conflicts with intellectual property rights. Guidelines
for mitigating such possible conflicts are absent in the policy documents. No specific
guidelines are given for sustainable extraction and utilization for raw materials for different
industries. One of the 17 objectives of the policy (Section 2.12; Chapter II) is “To ensure a
process of industrialization which is environmentally sound and consistent with the
resource endowment of the country”. However, none of the 24 strategies of the policy relate
to the environment.

2.3.5 National Water Policy (1990)


The National Water Policy of 1999 was passed to ensure efficient and equitable
management of water resources, proper harnessing and development of surface and
ground eater, availability of water to all concerned and institutional capacity building for
water resource management. It has also addressed issues like river basin management,
water rights and allocation, public and private investment, water supply and sanitation and
water needs for agriculture, industry, fisheries, wildlife, navigation, recreation,
environmental, preservation of wetlands, etc. The waste policy, however, fails to address
issues like consequences of Transboundary; water disputes and watershed management.

2.3.6 Environmental Policy (1992)


Bangladesh National Environmental Policy of 1992 sets out the basic framework for
environmental action, together with a set of board sector action guidelines. The
Environment policy provides the broader framework of sustainable development in the
country. It also states that all major undertakings, which will have a bearing on the
environment, (including setting up of an industrial establishment) must undertake an IEE
/EIA before they initiate the project.

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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.

2.3.7 Bangladesh Wildlife Preservation Act (1973; Amended in 1974)

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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The main objectives of ECA 95’ are:

 Conservation and improvement of the environment; and


 Control and mitigation of pollution of the environment.
 The main striates of the Act can be summarized as:
 Declaration of ecologically critical areas on the operations and processes, which can
or cannot be carried in the ecologically critical areas.
 Regulations in respect for vehicles emitting smokes harmful for the environment.
 Environmental Clearance
 Regulation of the industries and other development activities discharge permits;
 Promulgation of standards for quality of air, noise, water and soil for different areas
for different purpose; Promulgation of a standard limit for discharging emitting waste;
and
 Formulation and declaration of environmental guidelines.

Bangladesh Environment Conservation Act (Amendment 2000)


The amendment of the Act focuses on: (1) ascertaining of the punitive measures both for
fines and imprisonment and (3) fixing authority on cognizance of offences.

Bangladesh Environment Conservation Act (Amendment 2002)


This amendment of the Act elaborates on: (1) restriction on polluting automobiles, (2)
restriction on the sale and production of environmentally harmful items like polythene bags.
(3) Assistance form law enforcement agencies for environmental actions (4) break up of
punitive measures and (5) authority to try environment cases.

2.3.9 The Environmental Conservation Rules (1997)

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.

2.3.10 The Protection and Conservation of fish rules (1985)


These are a set of rules in line with the overall objectives of the fish Act. Section S of the
rules requires that “No person shall destroy or make any attempt to destroy any fish by
explosives, gun, bow and arrow in inland waters or within coastal waters.” Section 6 of the
rules states, “No person shall destroy or make any attempt to destroy any fish by poisoning
of water, or the depletion of fisheries by pollution, by trade effluents or otherwise in inland
waters”.

2.3.11 The Acquisition and Requisition of immovable property ordinance (1982)


This Ordinance has replaced the land Acquisition Act of 1894 and the East Bengal
(Emergency) Requisition of property Act of 1948.The Ordinance governs acquisition and
requisition by the government of immovable property for any public purpose or in the public
interest. It may be noted that contrary to the previous act (i.e. Act XIII of 1948), this
ordinance deals only with immovable property. The Ordinance has well-defined procedures
regarding payment of compensation for an acquired piece of land. If, for example, the land
is used for rice growing, then and amount equivalent to approximately 1.5 times the market
value of a given variety of rice (e.g. paddy) that is currently being (or could be) produced
annually is fixed as a yearly lease value. In case of outright purchase (carried out on a 99-
year lease), the compensation-value of acquired land varies widely according to the locality,
soil fertility, and access to transportation and related infrastructure factors. The current
compensation and resettlement provisions are however inadequate both in terms of timing
of payments and quantum. The procedures involved are cumbersome and time consuming
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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)

1 Industrial and mixed 120 5000 100

2 Commercial and mixed 100 5000 120

3 Residential and rural 80 2000 80

4 Sensitive 30 1000 30

SPM Density in micrograms per m3 8 hour


According to ECR 97 (amendment 2005) average
Schedule-2
200

Source: Schedule 2 (amendment 2005), Environment Conservation Rules, 1997


Bangladesh

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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Table: 2.4 Bangladesh Standards for wastewater from industrial units.

Source: Schedule 10, Environment Conservation Rules, 1997 Bangladesh

Notes:

Inland surface water means drains/ponds/tanks/water bodies/ditches, canals, rivers,


springs and estuaries.
Public sewerage system means treatment facilities of the first and second stage and also
the combined and complete treatment facilities. Irrigable land means such land Area, which

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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.

Table 2.5: Bangladesh Standard for Stack Emission from Industrial/Projects.


Parameter Standard (mg/Nm3)
Kg/ton acid
Sulfur decided (SO2)
4
H2SO4 acid production (DCDA process)
100
M2SO4 acid production (SCSA process)
Lowest Heights of Stack for H2SO4 dispersion:
Cost based power plant
500 MW and More
275m
200MW-500MW
220m
Less than 200MW
14(Q)*
11m
Boiler
Stream per hour-up to 15 tons
Stream per hour-up to more than 15 tons
14(Q)³
Sides of nitrogen
3kg/per ton acid
Nitric acid production
50 ppm
Gas based power station
50ppm
500MW or more
40ppm
200-500MW
30ppm
Less Than 500MW
200pm
Metaphorical over
Kiln soot and dust
Mg/Nm3
Blast furnace
500
Brick kiln
1000
Coke oven
500
Limekiln
250

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SL No. Parameters Standard (mg/Nm2)


Particulates (Ka)
1 Power station of capacity of 200 MW or more 150
(Kha) power station of capacity less than 200 MW 350
2 Chlorine 150
3 Hydro Chloride acid vapor and mist 350
4 Total fluoride (F) 25
5 H2S04 Sulfuric acid mist 50
6 Lead particulates 50
7 Mercury particulates 02
Source: Schedule 11, Environment Conservation Rules, 1997.

Notes:

“Q” emission of 502 (kg/hour);


DCDA-Double Conversion Double Absorption)
SCSA- Single Conversion Single Absorption.

Table 2.6: Bangladesh Standard for Ambient Noise.

Standard values

SL No. Area Category (all values in dBA)

Day Night

1 Silent Zone 45 30

2 Residential Area 50 40

Mixed Area (basically Residential and together


3 60 50
commercial and industrial purpose)

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.

Table 2.7: Bangladesh Standard for Odor.


Parameters Standard Limit (in ppm)

Acetaldehyde 5.0-0.5

Ammonia 5.0-1.0

Hydrogen Sulfide 0.2-0.02

Methyl disqualified 0.1-0.009

Mercaptan-Methyl 0.20.02

Sulfide Methyl 2.0-0.4

Styrene
0.07-0.005
Amine-methyl-Tri

Sources: Schedule-8, Environment Conservation Rules, 1997, Bangladesh

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.

2.4 The Environmental Clearance Procedures in Bangladesh


The environment clearance process in Bangladesh has three main tiers:
 Screening
 Initial Environmental Examination (IEE)
 Scoping & Detailed EIA
Screening decided whether or not the EIA process should be applied to a development
project. It also helps determine the type that is whether an IEE would sufficient or detailed
EIA should be reported as, The IEE helps understand the potential extent of environmental

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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.

2.4.2 Initial Environmental Examination:


All fabric processing projects are required to conduct and IEE. This involves identification
of the projects key impacts on the environment, evaluation of their important,
recommendation of mitigation measures, and listing of issues that are still unresolved and
warrant further environmental examination, i.e. an EIA.
 The DOE recommends the following steps for undertaking an IEE.
 Collection of baseline information with respect to the project and the environmental
setting of the project site.
 Setting of the boundaries of the IEE by identifying the significant issues.
 Impact assessment, suggesting mitigation measures, environmental management
plan or alternative sites or other project modifications.
 Preparation of an IEE report for submission to DoE.
 Review of the report by DoE.

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.

2.4.4 The ElA


If a project site is cleared by the DG DoE on the basis of the lEE report, and if, while issuing
such a clearance it is stipulated that a detailed ElA should be carried out, the project
proponent must undertake the ElA study. The ElA study should be focused on addressing
the issues that had remained unresolved during the lEE exercise. The steps recommended
by the department for conducting an ElA are:

 Base line studies


 Impact identification
 Impact prediction
 Impact evaluation
 Mitigation measures
 Monitoring program Special studies if needed. The risk analysis, resettlement and
rehabilitation, compensatory forestation, severance study, etc.
 Documentation and communication

2.4.5 Location Clearance and Environmental Clearance Procedure

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).

Once the application for an Environmental for an Environmental Clearance Certificate is


made along with the documents (as mentioned above) for orange or Red category, the
applicant would either be issued a location Clearance Certificate, or the applicant would be
reject with appropriate reasons for rejection within 60 days of the receipt of the application.
After receiving the Location Clearance Certificate, the project proponent.

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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3.0 Description of the Factory


3.1 Factory Overview
Mondol Intimates Ltd. is a 100% export oriented readymade garments manufacturing
factory in Bangladesh. This factory established in January, 2013. Mondol Intimates Ltd.,
is one of the leading knit lingerie garments manufacturer & exporter in Bangladesh. They
design, developed & export all kinds of ladies lingerie product.
Mondol Intimates Ltd., 100% follow and Implement the local labor law, International labor
law & buyer code of conduct (CoC). The Major customer are H&M, MAX, HEMA, LIDL,
WOMEN ‘SECRET etc.

Table 3.1: Overall information of the Factory.

Name of factory Mondol Intimates Ltd.

Address Shirir Chala, Bager Bazar, Gazipur, Bangladesh.

Year of Establishment January, 2013

E-mail momin@mondol.net

Factory Contact Person Abdul Momin Mondol (Managing Director)

Ownership Type Group of Industries

Office Time 8.00AM-5.00PM

Production Capacity 20,00000 (2 Million) pieces per month

Main Products All kinds of ladies lingerie product

Total floor area of the factory 135,000 sq. ft.

Total Manpower 2300

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3.2 Location of the Factory


Mondol Intimates Ltd. located at Shirir Chala, Bager Bazar, Gazipur, Bangladesh. The
site is about 61 km away from Dhaka Zero Point & 36.9 K.M from Hazrat Shahjalal
International Airport without traffic congestion. The latitude of the site is 24°16'44.53" N and
the longitude is 90°42'48.54"E. The location of the site is shown in figure 3.2.1a, 3.21b &
3.2.1c

Figure 3.2.1a: Location of the factory in Bangladesh

Figure 3.2.1b: Surrounding site picture from google map.

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Figure 3.2.1c: Google satellite Map of the factory.

3.3 Present status of the Factory


Mondol Intimates Ltd., has production with all industrial and environmental facilities
available, as this is an industrial zone there are a less quantity of trees within 1 km of the
factory. In the north side of the factory there is an Ice-cream Factory and residential areas.
In the south side there are battery factory & DBL factory, Pepsi factory and residential
areas. In the east side there are Chowdhury Garments & Artisan Ceramic Factory and in
west there are Golden Refit Garments & Merico Industries Ltd. & Bangabondhu Safari Park.

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.

3.4 Manufacturing Process


The process flow diagram supplied by the factory management is shown in below:

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3.5 Raw Materials:

A list of accessories has been given below:


 Fabric
 Label
 Sewing thread
 Hanger loop
 Button poly
 Hang tag
 Tissue paper
 Poly bag
 Carton
 Gum tape etc.

3.6 Machineries and Utilities


A list of machineries has been attached as annexure.

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Chapter 4
Baseline of the Existing Environment

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4.0 General Consideration


Description of existing environment is important to understand existing physical, biological,
cultural, economic and social environmental characteristics. This information forms the
basis to analyze the impacts of the project activities. Mainly there are two principal
objectives in exiting and the existing environment. To identify potential environmental
impacts of the factory and enable mitigation measures to be identified. To provide a base
line against which environmental conditions in the future project may be measured and to
document conditions which were either existing or developing before the introduction of the
factory and not due to the factory.

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.

4.1 Study Area


The study area covers the entire are of the factory which belongs to Mondol Intimates
Ltd., The site is about 61 km away from Dhaka Zero Point & 36.9 K.M. away from Hazrat
Shahjalal International Air Port. For the ease of current post projected EIA study, the study
has been kept limited to surrounding areas, which falls within 1 km radius of the proposed
site. Primary and Secondary data has been generated and collected for conducting the
study.

4.2 Physic-Chemical Environment


4.2.1 Surrounding Land Uses
Mondol Intimates Ltd. is a 100% export oriented readymade knit factory located at Shirir
Chala, Bager Bazar, Gazipur, Bangladesh. The factory is located in mixed Area. The
Industrial zones of Bangladesh are shown in the Figure 4.1.

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Mondol
Intimates Ltd.

Figure 4.1: Industrial zones of Bangladesh.

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4.2.2 Land Form and Soil Classification


The general Physiographic of Bangladesh is shown in Figure 4.2. Most of the area of
Bangladesh is a vast, low-lying alluvial plain, sloping gently to the south and southeast.
According to Bangladesh Agricultural research council’s physiographical map of
Bangladesh, the factory area falls in near the Madhupur Tract.

Mondol Intimates Ltd.

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Mondol Intimates Ltd.

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4.2.3 Water Quality

4.2.3.1 Surface Water Quality


The factory uses ground water for their industrial & domestic purpose. The factory has no
washing facilities thus it has less impact on surface water by discharging hazardous
effluent.

4.2.3.2 Ground Water Quality


Ground water label exists at moderate (Generally below 11.3-15m) depth as shown in
Figure 4.5, which is being recharged mainly by infiltration of rainwater. Ground water is a
stable source of water both for domestic and industrial purposes in this area. There is no
complaint regarding non-availability of ground water in this area.

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.

Table 4.1: Drinking Water Quality Monitoring Report.


Sl. No. Water quality parameter Unit Result
1. pH - 6.62
2. Iron mg/L <0.01
3. Arsenic (As) mg/L <1
4. Total aerobic bacterial count CFU/ml <10
5. Coliform (Total) CFU/100 ml 0
6. Coliform (Fecal) CFU/100 ml 0
7. Total streptococci CFU/100 ml 0
8. Total Hardness (EDTA) as CaCO3 mg/L 15
9. Total Dissolved Solids (TDS) mg/L 27.4
(Source: icddr,b )

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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.

Mondol Intimates Ltd.

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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:

Table 4.2: Indoor Air quality Monitoring Report.


Measured concentration in Sewing
and Cutting Sections OSHA
Air Quality
Sl no. Unit Standard
Parameters
4th floor 3rd floor 2nd floor (Max.limit)

1. CO ppm 0 0 0 50

2. CO2 ppm 700 810 830 5000

3. NO ppm 0 0 0 5

4. SO2 ppm 0.68 0.72 0.76 5

5. Temperature ◦C 31.4 31.9 31.9 ---

6. Relative Humidity % 42.7 44.5 44.6 ---

Source: Department of civil engineering

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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

ECR 97, 35ppm (1hr) 0.053 0.03 ppm


NYS
Schedule 2, 9 ppm (8 hr) (annual) ppm (annual) 0.14 -

Amendment 2005 ppm (24 hr)

35 ppm (1 100 ppb


US EPA hr) NYS (1 hr) 63 ppb 75 ppb (1 hr) -
9 ppm (8 hr) (annual)

OSHA 50 ppm 5000 ppm - - 750 ppb

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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Shirir Chala, Bager Bazar, Gazipur, Bangladesh.

Suspended Particulate Matter (SPM) Standard Limit:


Agency SPM Delaney

According to ECR 97 (amendment 2005), Schedule- 2 200 pg/m3 (24 hr)

PM 2.5-35 pg/m3 (24 hr)


US EPA
PM 10-150 pg/m3 (24 hr)

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:

Table 4.4(a): Stack Air Emission data-Generator (G-1)


Fuel Type: Diesel

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

Flue Temperature 510 °

Differential Flue Pressure 0.13 mbar

P Index 2.25

Excess Air 12.4

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Suspended Particulate Matter (SPM):

Suspended Particulate Matter (µg/m³)


Run
(10 Minutes interval) Total Suspended
PM 0.3 PM 0.5 PM 1.0 PM 2.5 PM 5 PM 10 Particles,
TSP(<10µM)

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

Table 4.4(b): Stack Air Emission data- Generator (G-2)


Fuel Type: Diesel
Measured pollutants
Run
(10 Minutes interval) CO CO2 NO NOx SO2 O2
Mg/Nm3 % Mg/Nm3 Mg/Nm3 Mg/Nm3 %
Run-1 1120 5.2 273 243 245 12.4
Run-2 1106 5.2 250 232 238 12.4
Run-3 1125 5.1 249 243 248 12.4
Run-4 1130 5.1 255 236 263 12.3
Run-5 1086 5.2 264 232 240 12.3
Run-6 1129 5.1 243 238 255 12.4

Flue Temperature 490 °


Differential Flue Pressure 0.13 mbar
P Index 2.25
Excess Air 12.4

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Suspended Particulate Matter (SPM):

Suspended Particulate Matter (µg/m³)


Run
(10 Minutes interval) Total Suspended
PM 0.3 PM 0.5 PM 1.0 PM 2.5 PM 5 PM 10 Particles,
TSP(<10µM)

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

NO = Oxide of Nitrogen [NO+NO2)


US EPA= Environmental Protection Agency SO2= Sulfur dioxide
DOE = Department of Environment (Bangladesh) CO= Carbon monoxide
PM= Particulate Matter

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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4.2.5 Noise Level


The noise level data has been collected from different locations of the factory by sound
level metal and the data is given below:
Measured
Comparative Standard
Name of Section or Area Place of Testing Noise Level
dB
In dB
Dining Room 8th Floor, Main Building 68.6
Sample Section 7th Floor, Main Building 65.8
Training Room 7th Floor, Main Building 70.2

Sample Office Room 7th Floor, Main Building 65.6


Sewing Section 5th Floor, Main Building 73.5
Finishing Section 5th Floor, Main Building 71.7

Cutting Section 5th Floor, Main Building 72.6


Spot Removing Room 5th Floor, Main Building 75
OSHA Standard:
Sewing Section 4th Floor, Main Building 73.4 Maximum Permissible
noise level is 90 dB for 8
Finishing Section 4th Floor, Main Building 70.6
hour exposure.
Cutting Section 4th Floor, Main Building 74.6
Spot Removing Room 4th Floor, Main Building 75
Sewing Section 3rd Floor, Main Building 74.3
According to the ECR 97:
Finishing Section 3rd Floor, Main Building 70.4
In the Industrial zone 75 dB
Cutting Section 3rd Floor, Main Building 74.7 At Day and 70 dB at night
time respectively.
Spot Removing Room 3rd Floor, Main Building 75.7
Sewing Section 2nd Floor, Main Building 74.1
Finishing Section 2nd Floor, Main Building 69.7

Cutting Section 2nd Floor, Main Building 74.1


Spot Removing Room 2nd Floor, Main Building 76.3
Medical Center 1st Floor, Main Building 63.7
Child Care Room 1st Floor, Main Building 68.4

Generator Room Ground Floor, Main Building 94.6

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Permissible Noise Exposures (OSHA Standards)


Si. No Duration per day in hours Maximum Sound Level in dB
1 8 90
2 6 92
3 4 95
4 3 97
5 2 100
6 1.5 102
7 1 105
8 0.5 110
9 0.25 115
Source: www.osha.gov

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:

 Provision of silencers for Generator.


 Planting of trees around the factory site.
 Regular factory maintenance.
 Regular noise monitoring.
 Use of ear-muffs and ear-plugs by factory personal in Generator room.
Light Level
The light level inspection has been done at every section of the factory. Light level is
measured in ‘’Lux’’ by human-eye-response silicon photodiode sensor based instrument.
The instrument is provided with a light sensor connected to the meter through a flexible
coaxial cable, allowing measurements from a distance without any interference from the
operator.

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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

2 Sample Section 7th Floor, Main Building 560


3 Training Room 7th Floor, Main Building 450 Bangladesh National
4 Sample Office Room 7th Floor, Main Building 320 Building
Code Standard
5 Sewing Section 5th Floor, Main Building 320 Cutting & Sewing:
300-700
6 Finishing Section 5th Floor, Main Building 370 Inspection:
450-1500
7 Cutting Section 5th Floor, Main Building 380

8 Spot Removing Room 5th Floor, Main Building 120


OSHA Standard:
9 Sewing Section 4th Floor, Main Building 340 Cutting, Sewing &
Inspection:
10 Finishing Section 4th Floor, Main Building 390 500-600
Warehouse
11 Cutting Section 4th Floor, Main Building 360 &
12 Spot Removing Room 4th Floor, Main Building 130 Office:
200-300
13 Sewing Section 3rd Floor, Main Building 320

14 Finishing Section 3rd Floor, Main Building 380 According to


Labor Rules 2015,
15 Cutting Section 3rd Floor, Main Building 340 Clause no 57,
16 Spot Removing Room 3rd Floor, Main Building 130 Minimum light
level at workplace
17 Sewing Section 2nd Floor, Main Building 340 shall be 350 Lux at 1
meter height from
18 Finishing Section 2nd Floor, Main Building 390 Floor.
19 Cutting Section 2nd Floor, Main Building 360

20 Spot Removing Room 2nd Floor, Main Building 110

21 Medical Center 1st Floor, Main Building 140

22 Child Care Room 1st Floor, Main Building 130

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

2 Sample Section 7th Floor, Main Building 29.5

3 Training Room 7th Floor, Main Building 32.1

4 Sample Office Room 7th Floor, Main Building 29.2

5 Sewing Section 5th Floor, Main Building 32.2

6 Finishing Section 5th Floor, Main Building 32.3

7 Cutting Section 5th Floor, Main Building 32

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

12 Spot Removing Room 4th Floor, Main Building 32.1

13 Sewing Section 3rd Floor, Main Building 32.4


(According to the
14 Finishing Section 3rd Floor, Main Building 32.1 Compliance code
for workplace
15 Cutting Section 3rd Floor, Main Building 32.5 amenities and
work
16 Spot Removing Room 3rd Floor, Main Building 32.6 environment)
17 Sewing Section 2nd Floor, Main Building 32.4

18 Finishing Section 2nd Floor, Main Building 32.3

19 Cutting Section 2nd Floor, Main Building 31.7

20 Spot Removing Room 2nd Floor, Main Building 32.6

21 Medical Center 1st Floor, Main Building 30.9

22 Child Care Room 1st Floor, Main Building 31

23 Generator Room Ground Floor, Main Building 33.8

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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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16 Spot Removing Room 3rd Floor, Main Building 63%


17 Sewing Section 2nd Floor, Main Building 57%
18 Finishing Section 2nd Floor, Main Building 54%
19 Cutting Section 2nd Floor, Main Building 52%
20 Spot Removing Room 2nd Floor, Main Building 64%
21 Medical Center 1st Floor, Main Building 55%
22 Child Care Room 1st Floor, Main Building 53%
23 Generator Room Ground Floor, Main Building 63%

The Humidity Level present in Mondol Intimates Ltd., found within the acceptable limit in
all area.

4.2.6 Climatic Condition


The nearest meteorological rainfall station of the project is Dhaka. So the climate of Dhaka
has been discussed here. The factory area is under the typical monsoon climate prevailing
in the country. It has three main seasons:

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.

Table 4.9: Monthly Maximum Temperatures at Dhaka in 2012.

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

Table 4.10: Monthly Minimum Temperatures at Dhaka in 2012.

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.

Figure 4.8: Average and Minimum Humidity (BMD, 2001 to 2011).

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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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Mondol Intimates Ltd.

Figure 4.10: Map of Earth Quake Zone of Bangladesh.

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4.3 Biological Environment

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.

4.3.2 Terrestrial 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.

II. Terrestrial Fauna


Wildlife that fully depends on the terrestrial ecosystems for life, shelter, food and breeding
is called terrestrial fauna. A number of terrestrial fauna species have been identified during
the brief and rapid assessment in the project area shown in Table 4.12a and 4.12b and
4.13c.

Table 4.11: Terrestrial Planted Flora.


Sl. No Local Name Status
1. NarikelGach Common
2. Devdaru Gash Common
3. Kathal Gach Common
4. Aam Gach Common
5. Peyara Gach Common
6. Mehguni Gach Common
7. Shegun Gach Common

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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

Table 4.12a: Terrestrial Fauna Reptiles.


Sl. No Local Name Status
1 Anjila Common
2 Dlara Shap Common
3 Malasheip Common
4 Tiktiki Common
5 Kari Katta Common
6 DaraishShap Common
7 Gokhra F. Common
8 Kassap F. Common
9 GuiShap Rare
* Source: Field Survey database & secondary Data

Table 4.12b: Terrestrial Fauna Mammals.

Sl. No Local Name Status


1. Badur Common
2. Idur Common
3. Shial Common
4. Metholdur Common
5. Kathbirali Common
6. Benji Common
* Source: Field survey database & secondary Data

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Table 4.12c: Terrestrial Fauna Birds.

Sl. No Local Name Status

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

4.3.3 Wetland habitat

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

ii. Wetland Fauna:


The wildlife that fully or partially depend on water reservoir such as river, canal and pond
etc. for life, shelter, food, nesting, breeding and reproduction inside the water reservoir is
known as wetland fauna. Important aquatic fauna comprises some species of amphibians,
reptiles, birds and mammals. Aquatic fauna may act as sensitive bio indicators of the
altered state of the ecosystem resulting from human influence. In the survey are there are
two major type of wetlands namely permanent wetland (rivers, canals and ponds) and
seasonal wetlands (agricultural lands during flood).

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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4.3.5 Endangered and threatened species


According to the field survey report, five species were in endangered while six species were
in threatened category which has been shown in table 4.14.

Table 4.14: Endangered and threatened species.

Category Endangered Threatened

Amphibian Jhi Jhi Bang Sona Bang

Replies Gokhra Gui Shap, Udh

Mammals Khekshial Khatash

Birds Macharnga, Holud Pakhi Pecha, Kath Thokra

4.4 Socio-economic profile of the project area

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.

4.4.2 Populating and Social Structure

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).

4.4.3 Living and Cultural Standard:


Library 65, club 130, cinema hall 8, playground 1, park 15, pond 2128, river flow 2.

4.4.3.1 Literacy Rate


The literacy rate of Gazipur Sadar is 60.6% where Male 65.2% & Female 55.6%.

4.4.3.2 Religion Status


Muslim 1743994, Hindu 70382, Christian 5108, Buddhist 556.

4.4.3.3 Land use


Total land 402.84 sq. km; forests 54.52 sq. km; Riverine Area 0.31 sq. km.

4.4.4 Other information

Communication facilities: Metaled Road 692 km, Semi Metaled road 284 km,
Unmetalled road 484 km, Railway 16 km, Waterway 52 km.

Manufactories: Pharmaceutical, garments, jute industry, chemical industry, footwear,


steel mill, brick-field.

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 exports: Vegetables, fruits, medicine, cosmetics, cigarettes, aluminum products,


readymade garments, mosquito coil, beverage (soft drinks) etc. are main exports.

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.

NGO activities: 81 NGOs such as BRAC, ASA, CARE, Proshika, Caritas

Health centers: Government health complex 2, Non-government health complex 62


missionary hospitals 3, diagnostic center 30.

* Source- District Statistics 2011, Gazipur.

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Environmental Impact Assessment (EIA)

Mondol Intimates Ltd.

Shirir Chala, Bager Bazar, Gazipur, Bangladesh.

Chapter - 5

Potential Environmental Impact

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Environmental Impact Assessment (EIA)

Mondol Intimates Ltd.

Shirir Chala, Bager Bazar, Gazipur, Bangladesh.

5.0 Potential Environmental Impacts


Environmental impact of Mondol Intimates Ltd., Can be analyzed under two phases-
Construction Phase & Operation Phase. As the factory is already built thus the possible
impacts which might occur at construction phase has cited here based on assumption &
information obtained from the factory. So the environmental impact at operational phase
has been given more importance in this EIA.

5.1 Construction Phase

5.1.1 Physical and Chemical


Physical and chemical impacts of this plan construction includes those on geology, soils,
topography, climate, air and water quality, air and water quality, and noise. Potential
environmental impacts on each of these are presented as the following:

5.1.1.1 Geology and Soils


There might have some soil disturbances and impacts on local geology since the site
preparation activities such as drilling, blasting. There would be major work in the
construction of the site which might causes significant amount of excavation soil,
construction and debris waste, which was handled according to the regulation on
excavation soil, construction and debris waste.

5.1.1.2 Topography and Landforms


Local topography hasn’t altered.

5.1.1.3 Climate and Meteorology


Impacts on the microclimate and meteorology of the local area were negligible.

5.1.1.4 Air Quality


Air quality emission problems resulting from the construction activities might have limited
to fugitive windblown dust, internal combustion engines in heavy equipment and onsite
power generators. These impacts would be low and short-lived. There would be no burning
of vegetation and/or other refuse. During work dust may be generated from solid waste.

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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Environmental Impact Assessment (EIA)

Mondol Intimates Ltd.

Shirir Chala, Bager Bazar, Gazipur, Bangladesh.

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.

5.1.1.7 Water Quality


The potential impacts on water quality during the construction phase of this plant was
minimal as the site drainage was well maintained and good construction practices were
followed to ensure that fuels & solvents were well managed and other construction
materials were stored and handled properly.

5.1.1.8 Solid Waste


Solid wastes during the construction phase were minimal since the system was installed
as a whole unit. Solid wastes such as rejected components and materials, and human
Garbage were disposed properly to sanitary landfills as required by the national Solid
Waste Control Regulation.

5.1.2 Biological
The presence of local flora and fauna were determined and evaluation of construction
impacts was made.

5.1.2.1 Flora and Fauna


There were no significant amount of endangered flora and fauna determined on the project
site; therefore, construction should have no adverse effects on endangered flora and fauna.
The site is in the mixed zone, therefore there is some conches for wild life disturbance.
However there are no endangered species present at the site. There would have been very
minor impacts on fauna due to the construction of the plant.

5.1.2.2 Ecosystems
Impacts of construction on ecosystem were negligible since there was:

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Environmental Impact Assessment (EIA)

Mondol Intimates Ltd.

Shirir Chala, Bager Bazar, Gazipur, Bangladesh.

No removal or interference with prey of predatory animals.


No significant siltation from run-off, altering aquatic and marine flora and fauna populations
and hence population dynamics of dependent organisms;
No noises disrupting breeding behavior or use of breeding grounds, resulting in shifts in
population dynamics; and
No removal of predatory animals resulting in increased prey populations that exceed the
carrying capacity of the local environment.

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.

5.1.3.2 Land Use


The primary changes in land use during the construction were basically at the plant site.
Outside the project site, change in land use was limited to infrastructures that would have
been installed to support the plant such as the road access and storm water collection
system.

5.1.4 Occupational Health and Safety


Health and safety impacts of the project on workers and communities in the area of
influence of the project was reasonably managed according to the national Occupational
Health and Safety Regulation in order to reduce the likelihood of accidents and work-related
illnesses on the job as well as accidents occurring between constructions related
equipment and local vehicles.

5.2 Operation phase


Environmental impacts from the plant operation that is quantified and reported include
those on existing air, water, and soil quality and the disposal of solid wastes. Long and
short-term impacts on flora, fauna, human populations, and the health and safety of
workers in the surrounding community were evaluated.

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Mondol Intimates Ltd.

Shirir Chala, Bager Bazar, Gazipur, Bangladesh.

Table 5.1: Major pollution sources of the industry.

Flue gases emitted from Generator.

Indoor and stack air quality


Air Pollution
Volatile organic compounds emitted from different machineries

Dust in several working sections from machineries operation

Small amount of waste from printing section

Water pollution Sewerage from Human Waste

Mobil or other lubricating oil from any machineries

Sound Pollution Generator or any other vibration creating equipment

Soil Pollution No major source found.

5.2.1 Physical and Soils


Soil impacts consist of negligible effects of windblown fugitive dust. Since the plant use
diesel, thus deposition of sulfates, nitrates and metals from the stack plume, as adsorbed
or incorporated into particles, would cause some adverse effects on environment.

5.2.1.2 Topography and Landforms


Local topography will not be altered and there will be no possible effects on landforms such
as swamps and shorelines.
5.2.3 Climate and Meteorology
There will be some impact on the microclimate and meteorology of the local area caused
by change in surface and aerodynamic disturbances. As liquid fuel is used in the plant thus
there might be particulates in the stack plume.

5.2.1.4 Air Emissions


Air quality impacts during operation of the plant consist primarily of stack gases emitted
following fuel combustion due to generator & boiler operation as well as air polluted by the
operation of different machineries. Emission from stationary combustion source is
comprised of sulfur dioxide (SO2), oxides of nitrogen (NOx), carbon monoxide (CO),
particulate matter (PM), carbon dioxide (CO2), and methane (CH4), trace amounts of

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Environmental Impact Assessment (EIA)

Mondol Intimates Ltd.

Shirir Chala, Bager Bazar, Gazipur, Bangladesh.

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:

= 221.1675139 ton CO2 / Year

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.

ANNUAL GHG EMISSION PERCENTAGE


Electricity
1%

Diesel
99%

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Mondol Intimates Ltd.

Shirir Chala, Bager Bazar, Gazipur, Bangladesh.

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.

5.2.1.7 Water Quality

Mondol Intimates Ltd., have seven reservoir tanks. They use ground water through deep
tube-well for their household (drinking and sanitation) and industrial purpose.

5.2.1.8 Solid Waste


The solid waste generated by the plant is domestic solid. Domestic waste is properly
disposed in sanitary landfills as required by the national waste control regulation. The
factory has agreement with local buyer for waste handover.

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Mondol Intimates Ltd.

Shirir Chala, Bager Bazar, Gazipur, Bangladesh.

5.2.2. Biological

5.2.2.1 Flora and Fauna

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

There is no significant impact of operation of the plant on ecosystem as no hazardous


effluent is discharge to receiving bodies. The factory is situated in industrial zone. The noise
generated from the plant may cause disturbance to several animal. Stack emission also
may pose a danger to local flora & fauna. But the factory has large land area thus there
might be not create any major impacts for noise outside of the factory.

5.2.3 Socio-economic Structure

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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Mondol Intimates Ltd.

Shirir Chala, Bager Bazar, Gazipur, Bangladesh.

5.2.3.2 Land Use

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.

5.2.4 Occupational Health and Safety


Health and safety impacts of the factory on workers and communities in the area of
influence of the factory will be reasonably managed according to the national. Occupational
Health and Safety Regulation in order to reduce the likelihood of accident and work- related
illnesses on the job as well as accidents accruing between projects related equipment and
local vehicles.

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Environmental Impact Assessment (EIA)

Mondol Intimates Ltd.

Shirir Chala, Bager Bazar, Gazipur, Bangladesh.

Chapter -6
Evaluation of Potential Impacts
&
Mitigation Measure

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Environmental Impact Assessment (EIA)

Mondol Intimates Ltd.

Shirir Chala, Bager Bazar, Gazipur, Bangladesh.

6.1 Evaluation of Environmental Aspects, Potential Impacts, Risk assessment and


Mitigation Measure with the factories operational Phase.

Table 6.1: Likelihood scoring


Rare (1) Unlikely (2) Possible (3) Likely (4) Almost certain (5)
Actual Actual Actual Actual
Frequenc Probabilit Probabilit Probabilit Probabilit Probabilit
frequenc frequenc frequenc frequenc
y y y y y y
y y y y
Expecte Expecte Expecte Expecte
Not
d to d to d to d to More
expected
<0.1 % occur at 0.1–1% occur at 1–10 % occur at 10–50 % occur at than
to occur
least least least least 50%
for years
annually monthly weekly daily

Likelihood scoring: Rare=1, Unlikely=2, Possible=3, Likely=4, Almost certain=5

Table 6.2: Severity of impact consequence:


CONSEQUENCE CONDITION SCORING
Loss/interruption of >1 hour
NEGLIGIBLE 1
Minimal or no impact on the environment
Loss/interruption of >8 hours
MINOR 2
Minor impact on environment
Loss/interruption of >1 day
MODERATE 3
Moderate impact on environment
Loss/interruption of >1 week
MAJOR 4
Major impact on environment
Permanent loss of service or facility
CATASTROPHIC Catastrophic impact on 5
environment

Table 6.3: Risk Rating Matrix

ACUTAL RISK OUTCOME


LOW MODERATE HIGH EXTREME
(Green) (Yellow) (Amber) (Red)
1-3 4-6 8-12 15-25
LIKELIHOOD
ALMOST
CONSEQUENCE RARE UNLIKELY POSSIBLE LIKELY
CERTAIN
1 2 3 4
5
CATASTROPHIC 5 10 15 20 25
5 (Yellow) (Amber) (Red) (Red) (Red)
4 MAJOR 4 8 12 16 20
4 (Yellow) (Amber) (Amber) (Red) (Red)
MODERATE 3 6 9 12 15
3 (Green) (Yellow) (Amber) (Amber) (Red)
MINOR 2 4 6 8 10
2 (Green) (Yellow) (Yellow) (Amber) (Amber)
NEGLIGIBLE 1 2 3 4 5
1 (Green) (Green) (Green) (Yellow) (Amber)

Source: National Patient Safety Agency

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Mondol Intimates Ltd.

Shirir Chala, Bager Bazar, Gazipur, Bangladesh.

Table 6.4: Environmental Aspects, Impacts, Risk assessment and Controls


associated with the factories operational Phase.

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

• The factory uses chimney


through which the flue gas
are emitted for reducing
the impact of stack air
emission on environment.
The factory ensures that
the chimney is in proper
functional condition at all
time.
Dust &
other • The factory has planted
exhaust trees in its premises to
atmospheri reduce carbon emission
c emission and thus minimize air
i.e.
MODERATE (Yellow) pollution.
emission
Air of SO2, • Stack gas emission level
pollution NOx, can be controlled by using
Air gas generators with low
& CO,SPM Minor 2 Possible 3 6
Quality NOx technology.
Dust etc. occur
emission due to the
• Provision of spraying water
stack gas
to reduce dust emission on
of
road.
generator
& vehicular • Ensuring vehicles,
movement generators, compressors
in the plant are well maintained.
area.
• Masks are provided to
workers to avoid inhalation
problem of workers due to
dust & Chemical smells.
• The factory ensure that
workers wear masks
during working in dusty
area.

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Mondol Intimates Ltd.

Shirir Chala, Bager Bazar, Gazipur, Bangladesh.

• 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.

•Maintena • The solid waste


nce work generated from the
that operation of plant are
excavate segregated into

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)

especially  Building noise insulated


Noise from the ensure satisfactory
Noise Insignificant 1 Unlikely 2 2
Pollution operation maintenance of relevant
of equipment. However as
generator, the factory already has
compresso lots of trees and around
r or any with natural forest which
other is very useful for reducing
vibrating noise to make buffer
machines. zone.

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Shirir Chala, Bager Bazar, Gazipur, Bangladesh.

 Disposal of solid sewage


waste in own septic
following the waste
Surroundin management plan.
g

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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Shirir Chala, Bager Bazar, Gazipur, Bangladesh.

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:

 Solid waste generation


 Health and Safety, Accidents and emergency
 Air Emissions
 Energy consumption

6.2.1 Pollution from solid and liquid waste

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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Environmental Impact Assessment (EIA)

Mondol Intimates Ltd.

Shirir Chala, Bager Bazar, Gazipur, Bangladesh.

Residual Impact

Provided that the mitigation measure indicated above is fully available, residual impact is
insignificant.

6.2.2 Impact on Health and Safety, Accidents and Emergency

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:

 Fire and explosion risks,


 Electrical-associated risks
 Occupational risks.

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.

6.2.2.2 Mitigation Measures already implemented


The factory proponent has already taken adequate mitigation measures. The factory has
freighting arrangements. Regular health and safety training, fire drill is conducted.
Designated floor level workers are trained and give responsibility for primary health
treatments. Adequate numbers of first aid facilities are available. It has been made
compulsory to use PPEs like ear plug, ear muff etc. in noisy areas like generator area and
hand gloves in printing sections. Work place monitoring is done regularly by third party.

6.2.3 Impacts on Air


Mondol Intimates Ltd., is using generator for electricity supply. However the operation of
this generator & boiler results in emission of exhaust gases. If it is not managed properly it
can create pollution of the surrounding air quality. This could be minimized by providing

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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.

6.2.4 Impact on Resources


The factory consumes insignificant amount of natural resources, so the impact is very
negligible. However the efficient management of energy and resources in a very important
factor for sustainable development.

Mitigation Measures:

Mondol Intimates Ltd., should optimize its resource consumption. It is suggested to


routinely check the resource consumption and takes necessary actions for optimization.
There should be awareness programs and training of floor level workers and the technical
supervisor regarding resource conservation and optimization. The proponent can conduct
cleaner production program at their factory premise by third party which is now available
locally.

6.2.5 Vibration management

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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6.2.6 Noise Management

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.

6.2.7 Odor management


From the production process it is evident that the factory does not generate any kind of
unacceptable or objectionable odor. Therefore, no separate odor management option is
necessary or suggested.

6.2.8 Traffic congestion

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.

6.3 Anticipated positive impacts of the proposed project

Positive impacts identified due to implementation of the proposed project includes:


 Opportunity to Expand Business
 Creation of jobs;
 Beautification of locality;
 Support of local businesses;
 Infrastructure development;
 Revenue to local Municipal Council; and
 Gains to the economy.

6.3.1 Opportunity Expand Business and increased export earnings.

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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6.3.2 Job opportunities

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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Shirir Chala, Bager Bazar, Gazipur, Bangladesh.

7.0 General Considerations

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.

7.1 Mitigation/ Benefit Enhancement measures

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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Table 7.1: The Environmental Management Plan of Mondol Intimates Ltd.


Implementation Mitigation Action Plan
Potential Impact Mitigation measures
Indicators Timeframe Responsibility

Provide all staff with


protective equipment
(helmets, gloves, goggles,
coats, ear muffs and boots
where applicable).

Use adequately these  Number of


Occupational
equipment accidents Throughout  Management of
Hazard/Risk of
on site the factory Mondol Intimates Ltd.
the accidents on
Timely maintenance &  Availability operational  Safety offices &
the personnel of
repair of all equipment of protective cycle Workers
the plant site
equipment
Employee Training
Use appropriate elevator or
other lifting machineries in
conveying building material
to high levels during
construction phase.

Construction of own septic  Management of


tank to mitigate surface of Mondol Intimates
Pollution of Number of
ground water pollution Ltd.
surface and times when All the
caused. Sewerage water  Safety offices
ground water due service is factory life
should be treated in STP if  Workers
to oil from. done
the workers quantity is  District
more than 500. environmental officer
During the  Management of
operation of Mondol Intimates
Regular air monitoring
Amount of the project Ltd.
Air emission Stack emission level can be
dust or other at regular  Safety offices.
During plant controlled by suing low-
pollutant in the interval  Workers
operation NOx technology & adopting
atmosphere generally  District
effluent gas recycle system.
after every 6 Environmental
months. officer

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Increase in the Use of machine with


risk of health minimum noise and select
Noise intensity Entire life of Management of Mondol
hazard because only new machines and
of machines the factory Intimates Ltd.
of the noise from vehicles
the machines
 Management of
Amount of Mondol Intimates
Air pollution from Entire life of
Soil watering dust in the Ltd.
dust the factory
atmosphere  Safety offices
 Workers
To take the rest solid waste  Management of
in the appropriate dumping Contract with Mondol Intimates
Effect of
site Garbage are sorted on the Garbage During Ltd.
generated solid
site and handed over to collector operation  Safety offices
waste
local agent after certain (Local NGO)  NGO
time.  Workers
 Management of
 Firefighting
Firefighting equipment Mondol Intimates
equipment During
Fire safety should be installed with Ltd.
installed operation
more attention paid  Safety offices
 Training
 workers
To the safety & security of the machines the extinguishers should be regularly inspected &
maintained and Provide Training to plant personnel

7.2 Management Policies


Mondol Intimates Ltd., review & enhance environment policies that provides guideline to
the operation of company actives. The policies are vital in that.
 Maintaining sound relations with company employees and the neighboring
community.
 Enable management put in place measures and structure that will care for the safety,
health and welfare of all company employees and customers;
 Ensure that management will plan for, and put in place, monitoring programs that
will ensure dust emissions do not exceed the required maximum limits noise and
aberration to the neighborhood are minimized and controlled, and wastes generated
by the project are properly managed.

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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.

7.2.1 Environmental Management Policy


Mondol Intimates Ltd., already developed an environmental policy for its existing units.
This environmental policy is to be reviewed and enriched. The revised policy should be one
that enables Mondol Intimates Ltd., to carry out its activities with the highest regard to the
natural environmental and sustainable utilization of environmental resources therein. The
policy therefore covers the following; among other issues ensure that all company activities
operate within legal requirements of all relevant national legislation.
 Continuous environmental improvement and performance through monitoring of
company activities;
 Ensure that utilization of natural resources is optimal with measures in place to
ensure resources availability for future generation;
 Awareness creation to the surrounding community regarding sustainable utilization
of natural resources, protection of sensitive ecosystems and bio-diversity
maintenance for communal livelihood; and
 Balancing between natural resource use, environmental conservation and economic
development.

7.2.2 Occupational health and safety 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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 Safety measures for all machines and equipment are used;


 Appropriate safety and rescue equipment is availed ink all work places;
 Emergency procedures and actions;
 Risk minimization of accidental damage to employees community and environment;
 Machine maintenance and machine operator proficiency; and
 Training in safety.

7.2.3. Local community policy


The local community policy developed by Mondol Intimates Ltd., should ensure that the
company develops maintains sound relations with its employees and the local community
on mutual respect and active partnership. The policy highlights on ways the company.
 Work with the local community and relevant government department and agencies
to achieve sustainable community development.
 Ways of enhancing information flow from management to the community and
employees, and vice vise.
 Community capacity building and
 Active engagement of the local community in the factory.

7.2.4 Employment Policy


Mondol Intimates Ltd. has in place an employment policy. This policy will require updating
to reflect the social economic realities that the company is operating in view of the
expansion project and increased number of employees that will be absorbed with the
commissioning of the plant takes into consideration the varying employment needs of the
community. The policy endeavor to protect local community from unfair competition when
it comes to recruitment of workers for the project. The policy covers the following among
other issues:
 Local Community considerations in employment;
 Training needs for employees;
 Employment of people with specialized skills;
 Casual Workers;
 Compensation, allowances and benefits, and
 Terms of payment and scales.

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7.3 Tree planting program


Mondol Intimates Ltd., is situated at near industrial zone. Although the factory should take
green initiative in the factory which include the following:
 Planting trees and grass within the compound;
 Planting trees along the perimeter fence; and
 Donating trees to the neighboring residential estates for planting as part of its CSR
program.

A. Planting trees and grass in the compound


Planting of tree seedlings and grass should begin immediately.

B. Planting trees along perimeter fence


Planting of a band of trees along the perimeter fence will help in greening the site and aid
the development of a microclimate within the factory premises. Once grown, the trees will
trap any fugitive emission from various sources as well as act as a sound barrier. This has
the additional benefit of projecting positive image of the company.

7.4 Detail Management Plans


[

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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7.4.1 Waste Management Plan (WMP);

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.

Sources of Waste and Waste water:

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.
[

7.4.2 Noise Management Plan

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.

7.4.3 Emission Control and Management Plan (ECMP)

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.

Sources of Gaseous Emission

Gaseous Emission is generated mainly from the generator stack. The emission mitigation
action plan is given in table 7.2

Table 7.2 Emission mitigation action plan

Issue Potential Proposed Environmental Responsible actors Time


/concern negative mitigation Monitoring frame
environmental measure
impacts
 Mondol Intimates
 Proper
 released of  Monitoring Ltd. top
stack
het of indoor management
height
 flue gas ambient  Mondol Intimates
 Heat
Air  GHG and stack Ltd. workers
recovery Biannually
pollution emission gases  Occupational
from boiler
 occupational  Monitoring safety and health
&
health of the use officer
generator
impact of PPE  environmental
 Use of PPI
officer

7.4.4 Resource Management Plant (RMP):


[

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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7.4.5 Occupational hazards management plan

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.

High Noise levels

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.

Safety management system:


There are many costs to accidents and unsafe work practices. The greatest costs are
human cost. Protecting employees also protects their friends, families, fellow workers,
management, the public and the environment from the far-reaching effects of serious
accidents. In addition to protecting lives, a safety program contributes to employee morale

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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.

Everyone employed by a company is responsible for maintaining the safety program.


Managers and supervisors are responsible for identifying safety needs, communicating
safety hazards, investigating hazardous conditions and accidents, providing training,
supply or warning appropriate safety and personal protective equipment, and ensuring all
equipment is properly maintained and meets legislated safety standards. Their role is
supported by input from all employees.

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.

a. Company safety Policy

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.

f. Standard Work procedure

The intent of standard work procedures is to ensure consistency in the performance of


hazardous work and it must form the minimum standards by which specific tasks are
performed. Workers must have clear understanding of the procedures they are required for
periodic review of procedures must be developed. The employees are in the work will be
given an opportunity to suggest steps that would provide for continuous improvement to
the procedures. The work procedures ensure that all hazardous are have been accounted
for. Procedures and codes of practice have to be developed for schedule work. To
determine compliance with safety and hazard issues while performing a worker.

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Effects should be made to ensure the following:


 Confirm that employees affected by these tasks participate in the development of
safe work procedures.
 Confirm that the employees are involved in the maintained of safe work procedures,
 Interview workers to determine if they know what tasks have work procedures,
where these procedures are loaded and generally what makes up to content.
 Review records to ensure that employees receive training on hazardous work
procedures and codes and practices.
 Where practical, observe employees performing critical tasks to confirm use of
standard work procedures and codes of standards.

g. Safety Orientation and Training


Initial safety training is one of the most important aspects of any safety program. All
employees and contractors must receive some level of basic training, specific to the facility
and nature of the job. It must be ensured that appropriate orientation is given to:
 Employs
 Contractors
 Sub-contractors
 Visitors
 The orientation shall also include a review of the following:
 Company safety policy and procedures
 Specific job hazards
 Safety precautions
 Job responsibilities
 Regulatory requirements
 company enforcement policy, and
 Worker right-to-know and authority to refuse unsafe work.

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.

i. Maintenance and Training Regarding Personnel Protective Equipment (PPE)


The work site should be assessed to determine what personal protective and safety
equipment is needed and the equipment must be available. A maintenance schedule must
be developed for PPE and records for maintenance retained in life. Employees must be
trained in facing care maintained and use of PPE.

j. Body parts that require protection

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.

Table 7.12: Occupational Noise exposure limits (Without hearing protection).


Sound level (dBA) Maximum Permitted Duration (Hours)
85 8
90 4
95 2
100 1
105 2
110 14
115 1/8
Greater than 115 0

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.

7.5 Environmental monitoring program


7.5.1 Monitoring requirement

Environmental monitoring is an essential tool in relation to environmental management as


it provides the basic information for rational management decisions. The prime objectives
of monitoring are-
 To check on whether mitigation and benefit enhancement measures are actually
being adopted and are providing effective in practice.
 To provide a means whereby impacts which were subject to uncertainty at the time
of preparation of EIA, or which were unforeseen, can be identified, and steps to be
taken to adopt appropriate control measures.
 To provide information on the actual nature and extent of key impacts and the
effectiveness of the mitigation measures which, through a feedback mechanism, can
be taken into account in the planning and execution of similar projects in future.

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There are two basic forms of monitoring.

 Visual observation of checking, coupled with inquires


 Physical measurement of selected parameters.
In the case of industrial projects in general, monitoring is done by physical measurement
of some selected parameters like air, water, noise etc. It should be mentioned here that the
monitoring program should be such so that it can ensure compliance with national
environmental standards. The importance of this monitoring program is also for ensuring
that the plant does not create adverse environmental changes in the area and providing a
database of operations and maintenance, which can be utilized if unwarranted complaints
are made.

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.

7.5.2 Monitoring indicators


Keeping in mind the pollution factors, there will be a need to put in place elaborate and
sound environmental management system and mechanisms of monitoring on a continuo’s
basis the environmental performance of the project. Undertaking monitoring and auditing
of key environmental parameters and putting in place of all approved recommendation of
the environmental management plant and conditions of the license will achieve this.
Monitoring to be undertaken will be both active and reactive.
7.5.2.1 Active monitoring
Active monitoring will include:
 Monitoring of the achievements of specific plans of the Environmental Management
plan, performance criteria and fulfillment of objectives;
 Systematic inspection of work place

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7.5.2.2 Reactive monitoring

This will include:


 Environmental conservation and related activities in the area;
 Work related injuries, ill health (including record keeping and monitoring of
sickness/absence), disease and accidents.
 License such as arrange to property.
 Deficient safety and health performance including DHSMS failures.
 Workers rehabilitation and health restoration programs.

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.

This may include the following:


 Dust levels monitoring
 Surface and ground water quality monitoring in the immediate neighborhood.
 Solid waste disposal monitoring and
 Emission and other effect disposal monitoring.

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.

Environmental Monitoring Schedule at a glance

Environmental Parameter Recommended Monitoring Frequency

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

Energy Monthly monitoring of energy

 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

7.5.3 Environmental Management Records


The industry maintains a well-established system of records to demonstrate compliance
with the environmental management systems and the extent of achievement of the

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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

7.5.4 Environmental Audit

In order sustain a healthy environment in at proposed condominium development and its


environs, the management should undertake to monitor the quality of the environment as
a routine practice. Monitoring well involve measurements, observations, evaluations,
assessment and reporting on the following variables as shown in table below during the
normal condominium.

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

In Table-7.15.Laberatory analysis approximately as per monitoring fees of DoE/ Private


organization.
Table.7.15; Environmental Management and Monitoring Budget.
Monitoring Parameter Yearly cost [in BDT]Including Other Fee
Drinking Water Quality 7000 (LS)
Ambient Air Quality 25000[LS]
Stack Air Emission 20000/Stack
Noise Level 12000[LS]
Note; the test fee could vary depending on different organization quality and their own system.

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Chapter-8

Hazard Analysis and Disaster Management


Plan

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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.

8.1 Scope of the Study


The study aims to analyze the risk associated with the following scenarios in the plant:
 Hazards associated with various processes
 Raw material storages in the plant.

The risk analysis assessment study covers the following:

 Identification of potential hazard areas


 Identification of representative failure cases
 Visualization of the resulting scenarios in terms of fire (thermal radiation) and
explosion.
 Assessment of the overall damage potentials of the identified hazardous event and
the impact zones from the accidental scenarios.

8.2 Approaches to the study


Risk involves the occurrence or potential occurrence of some accident consisting of an
event of sequence of events. The descriptions of the tasks of the various phases involved
in risk analysis are detailed below:

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8.2.1 Phase I: Hazard identification


The technique employed for the hazard identification is MCA analysis. MCA stands for
maximum credible accident or, in other words, an accident with maximum damage
distance, which is believed to be probable. MCA analysis does not include quantification of
the probability of occurrence of an accident. In practice, the selection of accident scenarios
for MCA analysis is carried out on the basis of engineering judgment and expertise in the
field of risk analysis, especially in accident analysis. Process information study and relevant
data would help in the identification of hazard prone section of the plant.

8.2.2 Phase II: Hazard Assessment and Evaluation


Ranking of each unit in hazard prone sections are done based on the fire and explosion
and Toxicity index (FE&T () and inventory analysis, Safety of hazard prone section is
studies using preliminary Hazard analysis. The main purpose of this analysis is to recognize
hazards early, thus saving time and cost which could result from major plant redesigns, if
hazards are discovered at a later stage. Many companies use a similar procedure under a
different name. It’s generally applied during concept or early development phase of a
process plant and can be very useful in site selection. PHA is a precursor to further hazard
analysis and is intended for use only in the preliminary phase of plant development for
cases where past experiences provides little or no insight into any potential safety
problems, e.g. a plant with a new process. The PHA focuses on the hazardous materials
and major plant elements since few details on the plant design are available. The PHA is
sometimes considered to the review where energy can be released in an uncontrolled
manner. The PHA consists of formulating a list of hazard related to:
[

 Plant equipment
 Interface among system components
 Operative environment
 Operations (tests, maintenance, etc.)
 Facility
 Safety equipment

The results include recommendations to reduce or eliminate hazards in the subsequent


plant design phase. The PHA is followed by evaluation of MCA and consequence Analysis.

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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 Hazard Assessment and Evaluation

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.

8.3.3 Preliminary Hazard Analysis (PHA)

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.

Equipment Process Potential Hazard Provision


Mechanical
Converts Layout of
hazards in lube oil
mechanical equipment/machinery is done
Generator system, cable
energy into in accordance to factory and
galleries, short
electrical energy electrical inspectorates.
circuit
All electrical fittings and
Fire and
Power Transformer - cables are provided as per
explosion
the specified standards.
Fire in cable
Switch Yard control
- galleries and As above
room
switch
Diesel & Lubricating Oil Leaks detection system will
Used as fuel Fire & explosion
Storage be provided

8.4 Emergency Response and Disaster Management Plan


The initial response to an incident is a critical step in the overall emergency response. Like
all other industries and installations. Cement-manufacturing facilities must have adequate
measures against accidents or incidents to meet the emergency. The purpose of having an
Emergency Response Plan (ERP) is to:
 Assist personnel in determining the appropriate response to emergencies.
 Provide personnel with established procedures and guidelines.
 Notify the appropriate company emergency response team personnel and
regulatory Govt. agencies.
 Manage public and media relations.
 Notify the next-to-kin of accident victims.
 Promote inter-departmental communications to ensure a “Companywide”
Coordinated emergency response.
 Minimize the effects that disruptive events can have on company operations by
reducing recovery times and costs.

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 Respond to immediate requirements to safeguard the subtending environmental


and community.

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.

III. External factors


 Food poisoning/water poisoning
 Sabotage, and

8.4.1 Six Steps in Emergency response


[

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.

8.4.2 Reporting incidents and accidents


All accidents and near-miss incidents shall be investigated to determine what caused the
problem and what action is required to prevent a recurrence. Employees required to
perform investigations shall be trained in accident investigation techniques. The
incident/accident investigation should be a fact-finding exercise rather than faultfinding. The
investigations will focus on collection of evidence to find out the “root cause” of the incident.
The recommendations of the investigation report are implemented in phases.

8.4.3 Approaches to Emergency Response

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.

8.5 Disaster Management Plan

A disaster is a catastrophic situation in which suddenly people are plunged into


helplessness and suffering and, as a result, need protection clothing shelter, medical and
social care and other necessities of life.

Disasters can be divided into two main groups.

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:

 Effect the rescue and medical treatment of causalities


 Safeguard other people
 Minimize damage to property and the environment
 Initially contain and ultimately bring the incident under control
 Identify and dead.
 Provide for the needs of relatives
 Provide authoritative information to the news media
 Secure the safe rehabilitation of affected area
 Preserve relevant records and equipment for the subsequent inquiry into the cause
and circumstances of the emergency.

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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.

8.5.1 Environment, Health and Safety (EHS)

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:

 Fire extinguisher servicing records.


 EHS meeting schedules and training records
 Electrical installations
 Generator inspection and maintenance records
 Waste disposal records
 Inventory records (fuels, paints, cleaning agent)
 Emergency response procedure.

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Chapter-9

Stakeholder participation

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9.0 Identification of Stakeholder


Stakeholder can be defined as any institution, group or individual with an interest in or a
role to play in a societal decision making process. Stakeholders as these participants (in
the development process) together with any other individuals, groups or organizations
whose actions can influence or be influence or be influenced by the development and use
of the system whether directly or indirectly (Pouloudi, 1997)

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

Project proprietors & beneficiaries:


Not necessarily have to be local

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:

Those who focus on technical aspects of the project, such as


 land use planning
 natural resource management
 Social infrastructure etc.

9.1 Purpose of stakeholders participation


Stakeholder’s participation is a key part of environmental impact assessment of a project.
Stakeholder consultation is the whole process of informing relevant stakeholders about the
project and its impacts and addressing their concerns. A stakeholder consultation process
should provide a forum where relevant information is disseminated to, and asked from, the
stakeholder. It is a forum where social, environmental and other issues that affect
stakeholders can be addressed.
[

The objective of stakeholder’s participation and consultation is to achieve the following:


1. To ensure public and community participation in the definition of environmental
policy objectives and decision making.
2. To improve the project design by using valuable ideas of stakeholders’ raised during
stakeholder consultation.

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9.2 Importance of stakeholder involvement

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.

9.2.1 Benefits of Stakeholder involvement in EIA


 It helps the EIA address relevant issues, including those perceived as being
important by other sectored agencies, public bodies, local communities, affected
groups, and others;
 Helps to harness traditional knowledge which conventional approaches often
overlook;
 Helps to improve information flows between proponents and different stakeholder
groups, improving the understanding and ‘ownership’ of a project;
 Enables project proponents to better respond to different stakeholders needs;
 Helps identify important environmental characteristics or mitigation opportunities
that might be overlooked;
 Helps ensure that the magnitude and significance of impacts has been properly
assessed;
 Improved the acceptability and quality of mitigation and monitoring processes.

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9.2.2 Limitation of stakeholder involvement


 Difficult to identify all affected parties
 Communication difficulty due to linguistic and cultural diversities
 Illiteracy
 Lack of local knowledge on the projects
 Unequal access to consultations (for example, women)
 Time/cost implications

9.3 Method of stakeholder involvement


In participatory decision making, there is no single source of ultimate control or authority.
The participating parties must discuss and reach a decision by means of an agreed
process. There are numerous methods which can be utilized to involve stakeholders,
especially the public, in EIA process.

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.

Advisory Panel: it consist of group of individuals chosen to represent stakeholders.


Advisory panel meet periodically to assess work done/result obtained & advice on further
work.

Public information centers: It facilitates an accessible location for public consultation.


This center contains information about the project& members of the public can visit there
obtain information and express concerns.
Interview: Stakeholder’s involvement can be ensured by open ended interviews with
selected community representatives.
Questionnaires: A written, structured series of questions are issued to local people
assemble concerns/views/ideas.

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Participatory Appraisal Technique: A systematic approach to appraisal based on group


inquiry and analysis with multiple and varied inputs.

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.

9.4 Key issues Raised during Stakeholder Participation

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.

9.5 Stake holder participation at MONDOL INTIMATES LTD.

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.

9.5.2 Local people

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.

2. Local people to be given priority in employment opportunities created by the factory.


3. Pollution mitigation should be given priority in very step and necessary measures
should be taken which is suggested in environmental management lent (chapter 7)
4. DOE recommended ruffs are needed to implement carefully.

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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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Annexure
Mouza Map

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Annexure
Water Testing Report

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Annexure
Site Clearance Certificate from Local
Authority

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Annexure
Factory license

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Annexure
Trade license

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Annexure
Fire license

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Annexure
Permission of BERC

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Annexure
Permission for Boiler

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Annexure
List of Machineries

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Annexure
Medical Agreement

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Annexure
Agreement with Waste Buyer.

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Annexure
Soil Test Report

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