Effective Policy Intervention to ensure Health, Safety, Security & Environment

(HSSE) in the MSME

Dr. Rashmi NaiduDirector, Technical Services

NS Support Services Pvt. Ltd

(Technical Support Centre to SSS (Europe) AB, Sweden)

25 March’ 2015 – National Workshop on Health, Safety, Security & Environment – Transforming MSME’s, Creating Value www.ssseurope.org

Issues addressed in the presentation

Essentials of an effective chemical policy How does NCP compare with global chemical policies Expectations from the draft NCP Effective policy interventions to ensure HSS&E in MSME’s Important HSE issues concerning industrial use of chemicals What the MSME’s can do to ensure HSSE within their units What does India stand to gain through an effective NCP Take Home Messages

Essentials – Effective Chemical Policy

Protection of human health and environment Enhancing competitiveness and innovation of the chemical

industry Non-discriminatory Compliance procedures for chemical manufacturers, importers

and traders to be spelt out clearly Effective implementation Encourage “gradual” substitution of highly hazardous chemicals Should not be burdensome for the industry: Procedures as well

as cost

(Achieve objectives of SAICM and WSSD)

How does NCP compare with global chemical policies

Aims and Objectives of the NCP (Final Draft 2014)

To create an enabling framework for the following:•Fostering innovation•Catalyze manufacturing•Addressing environmental concerns•Adopting green technologies•Encourage R&D through industry-academia interactions•Rationalize the statutory regulations and controls•Setting up a “National Chemical Centre”•Enhancing the image of the Indian chemical industry

Expectations from the draft NCP

Protection of human health and environment Address the issue of PBT chemicals (Environmental aspect) Focus on CMR chemicals deleterious to human health (Human health

aspect) Clearly spelt out compliance procedure to comply to the NCP

Possible compliance procedure suggested (A simple 2 Tier approach)

Tier 1 chemicals: Chemicals of high concern to require a full registration & safety assessment

Tier 2 chemicals: Low concern chemicals to have toned down information requirement relating to identity, volumes, use details & classification

Possible Compliance Procedure (Contd..)

If concerns arise relating to safety of Tier 2 chemicals then a “chemical safety report shall be required

Advantages of the above system Simple (companies understand their chemical and can identify

which tier they belong to and prepare accordingly) Effective (Compliance procedures for the 2 tiers can be spelt out

clearly) Cost efficient (cost should be proportional to the hazard posed by

the chemical)These suggestions was provided to the Ministry of Chemicals by SSS and CII in a

series of documents submitted during past couple of years – we sincerely hope that the suggestions shall be duly considered in finalizing the NCP

Effective policy interventions to ensure HSS&E in MSME’s

MSME’s – Vital for National Development Bulk of the SME’s in unorganized and cottage sectors MSME’s to become competitive – need to adopt changes Change shall have to be driven by policy requirements Change could as simple as involving use of PPE by workers,

adopting clean manufacturing techniques, simple recycle Discharge of waste into central ETP Ensure effective functioning of boilers, condensers, etc. Industry audits to be systematic and “realistic” Annual audit reports should be reviewed by industry organization

Important HSE issues concerning industrial production & use of chemicals (Environment)

Use of renewable and clean energy sources, wherever possible (try to substitute coal and diesel with bio-waste pellets and biofuels

No discharge of untreated liquid waste into surface water & ground

Divert liquid waste to central ETP’s where facility exists Minimize air pollution – proper positioning of chimneys Explore options to recycle solid waste Location of noisy operations away from other unit operations

Important HSE issues concerning industrial production & use of chemicals (Health)

Health is a neglected issue not only in MSME’s but also in bigger industries

Measures to prevent deleterious effects on health could often be simpleIndustrial workers to be provided with PPE’s and oriented to use them regularlyFacility for health check-up once a year by the companyDiscussion on issue of medical compensation with workers to explain importance

25 March’ 2015 – National Workshop on Health, Safety, Security & Environment – Transforming MSME’s, Creating Value www.ssseurope.org

Important HSE issues concerning industrial production & use of chemicals (Safety)

Safety aspects are closely related to Environment & Health

Safety issues mostly concern SME workers working in high risk environment like near high temperature furnaces, shifting of heavy loads, handling haz chemicals, etc.

Use of Quality & sturdy PPE’s to be made mandatory List of Do’s and Dont’s to be prominently displayed in all units at entrance of factoryStrong deterrents to be put in place by management for workers avoiding the use of the PPE’s

Important Stakeholders

Chemical Companies (Major role)

Supportive role Chemical Industry Associations/Councils Ministries associated with various chemicals (Policy makers) Academia (cost effective R&D to ensure HSSE in MSME’s)

Possible roles the stakeholders can play

Chemical Companies (Responsible Manufacturing)

Chemical Industry Associations/Councils (support role in dissemination of best practices for the chemical industry, greater hand-holding of the MSME’s)

Ministries associated with various chemicals (Ensuring “a robust and effective NCP” with focus on MSME’s)

Academia (cost effective R&D)

Proactive initiative & support of SSS to NCP

Robust Chemical Inventory being put in place – close to finalization

•Such an inventory can be the cornerstone of an effective chemical policy •Wealth of information relating to over 300,000 chemicals•Will be of immense benefit to the chemical industry and its workforce•Shall help to distinguish Haz chemicals from the non-HazSome of the important policy papers that SSS has provided to the GoI apart from other inputs include:Trade Impacts of REACH – A Non-EU Manufacturer’s / Exporter’s Perspective: 2008 (Two updated versions in 2012 and 2013)Need for an Indian Chemical Policy in response to EU’s REACH Regulation - 2010Draft Paper on the Proposed Indian Chemical Policy (ICP) - 2011REACH Status Paper (Prepared for the Ministry of Chemicals and Fertilizers, Government of India, New Delhi) – 2012Proposal for Indian chemicals management framework / policy – 2013

What does India stand to gain

A robust, safe and secure Indian chemical industry (More so MSME’s)

Reduction in accidents Less polluting “chemical clusters” Marked improvement in the country’s pollution index Gainful employment for the youth of the country “Brand India”: Intent of the government to have an effective, non-

discriminatory chemical policy Image makeover for the Indian chemical MSME’s

Healthy individuals, clean environment & safe factories: could be the pillars of “Swacch Bharat”

Take Home Messages

“Transforming MSME’s – Creating Value”: Immense potential – challenges need to be overcome & many can be overcome

MSME’s: to look beyond production, should show intent to participate in “transforming into responsible manufacturers”

Effective policy measures to improve the HSSE status in MSME’s

The whole world is waiting in anticipation for a Final Chemical Policy – Needed soon

All stakeholders have a collective responsibility & should work in synergy

About SSS (Europe) AB

SSS is a much sought after organization offering regulatory compliance services

Clientele spread across Asia, Europe, Latin America and growing rapidly to other continents

Caters to over 1000 companies presently Entire basket of REACH compliance services offered Capacity to offer services for other regulations such as CLP,

BPR, China REACH, K-REACH and actively involved with the NCP of India

Contact Us

SSS (Europe) AB, Sweden

www.ssseurope.org

www.sustainability-support.ssseurope.org E-mail: info@reach-onlyrep.eu

NS Support Services Pvt Ltd (Brand name “REACH Support”)

www.helpdesk.reach-support.org E-mail: advisor@or-reach.com