Annex 1: Correspondence with the Bangladeshi Government
July 23, 2012
Hon. Hasan Mahmud,
Minister of Environment and Forest,
Government of the People’s Republic of Bangladesh
Building #6, Level # 13,
Bangladesh Secretariat, Dhaka, Bangladesh.
Via fax: +88-02-7160166
Via email: minister@moef.gov.bd
Dear Minister,
Human Rights Watch is an international nongovernmental organization that monitors violations of human rights by states and non-state actors in more than 90 countries around the world.
I am writing to you in reference to research Human Rights Watch is conducting on health and human rights conditions related to the tanneries in Hazaribagh in Dhaka. Our research to date has documented a number of serious concerns related to the tanneries in Dhaka, including:
- None of the tanneries in Hazaribagh have an effluent treatment plant. Studies of tannery effluent in Hazaribagh have found that effluent from tanneries in Hazaribagh contains contaminants in concentrations that exceed the permitted limits for effluent discharged into surface water.
- Residents in Hazaribagh complain of various health problems such as fevers, skins diseases, respiratory problems and diarrhoea that they fear are related to tannery pollution.
- Tannery workers suffer from various health problems, such as skin diseases caused by direct exposure to chemicals used in the tanning process as well as serious accidents caused by dangerous heavy machinery.
- Some tanneries employ children as young as 11 in hazardous labour with chemicals and heavy machinery.
On June 6, 2012 Richard Pearshouse, a senior researcher with the health and human rights division of Human Rights Watch, requested to meet you while in Dhaka. In an email dated June 11, your personal secretary Mr. Rafique Ahammed responded to this request by stating that “that the Ministry of Industry is dealing with the tannery industry in Bangladesh” and suggested that Human Rights Watch seek a meeting with the Minister of Industries instead.
Human Rights Watch is committed to producing material that is well-informed and objective. As many of our findings relate to laws and regulations that the Ministry of Environment and Forests is statutorily required to uphold, Human Rights Watch is writing to you now to ensure that our report properly reflects the views, policies and practices of the Ministry of Environment and Forests and the Government of Bangladesh regarding the tanneries in Hazaribagh. Human Rights Watch is also writing at this time to seek information from the Minister of Industries and the Minister of Labour and Employment.
We hope you or your staff will respond to the attached questions so that your views are accurately reflected in our reporting, In order for us to take your answers into account in our forthcoming report, we would appreciate a written response by August 17, 2012.
In addition to the information below, please include any other materials, statistics, and government actions regarding the Hazaribagh tanneries that you consider would be important to understand the issue.
Thank you in advance for your time in addressing these urgent matters.
Yours sincerely,
Richard Pearshouse
Senior Researcher
Health and Human Rights Division
Human Rights Watch
Background and statistical information
1. Does the Ministry of Environment and Forest maintain a list of tanneries operating in Hazaribagh? If so, please provide us with that list.
2. Does the Ministry of Environment and Forest maintain a list of tanneries operating in Hazaribagh without effluent treatment plants? If so, please provide us with that list.
3. I understand that on August 7, 1986 the Department of the Environment published in the Bangladesh Gazette a determination that 903 industries and factories (including 176 tanneries) were polluters. Did that list contain any Hazaribagh tanneries? If so, please provide the names and addresses of those tanneries.
Monitoring
1. The Ministry of Environment and Forest decision on August 7, 1986 (mentioned above) ordered 903 polluting industries and factories (including 176 tanneries) to adopt measures to control their pollution within three years. Did the Ministry of Environment and Forest take any further steps to monitor whether these polluting factories and industries complied with this order? If so, please detail the steps taken. If not, please detail why no steps were taken.
2. Does the Ministry of Environment and Forest have any data estimating the total volume of liquid and/or solid waste produced by the Hazaribagh tanneries over a specified period of time (e.g. day, week, month, year)? If so, please provide us with the most recent data.
3. Human Rights Watch has a copy of a Department of Environment report titled Survey and Mapping of Environmental Pollution from Industries in Greater Dhaka and Preparation of Strategies for its Mitigation (September 2008). That report includes some information on water quality samples taken from two locations in Hazaribagh. Other than that publication, from 2000-2012 has the Ministry of Environment and Forest undertaken any monitoring of water, air and soil quality in Hazaribagh? If so, specify:
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Date of sample |
Nature of sample (e.g. water, air, soil) |
Location of sample |
Parameters tested |
Result of test for each parameter |
Relevant Bangladesh standard limit for each parameter |
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4. If, from 2000-2012, the Ministry of Environment and Forest has not undertaken monitoring of water, air or soil quality in Hazaribagh, please explain why not.
Enforcement
1. Human Rights Watch understands that no tannery in Hazaribagh has a full effluent treatment plant. From 2000-2012, has the Ministry of the Environment and Forests undertaken any legal actions against any Hazaribagh tanneries for infringing environmental laws or regulations (including for the discharge of effluent in excess of the permitted limits). If so, please specify:
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Date |
Name and address of tannery |
Type of infringement |
Type of legal action |
Result of the legal action |
Whether infringement is ongoing |
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2. A Department of Environment report titled Survey and Mapping of Environmental Pollution from Industries in Greater Dhaka and Preparation of Strategies for its Mitigation (September 2008) shows that water quality samples taken from two locations in Hazaribagh were far in excess of permitted levels. Did the Ministry of Environment and Forests take any further action on the basis of this data, including any enforcement action against any Hazaribagh tanneries?
3. Does the Government of Bangladesh have, in law or in fact, a policy to not enforce environmental laws or regulations against any Hazaribagh tannery until the tannery relocation site in Savar is prepared? If so, please explain the date this policy was adopted, the precise terms of this policy, and the rationale for this policy. Please also explain the legal grounds that permit the Government of Bangladesh to adopt such a policy.
4. According to Bangladesh media reports in June 2011, you informed parliament on June 1, 2011 that relocation of the Hazaribagh tanneries to Savar would be completed by the end of 2012. Did you in fact inform parliament that relocation of the Hazaribagh tanneries to Savar would be completed by the end of 2012? If so, please explain why such relocation has not happened yet.
***
July 23, 2012
Hon. Khandker Mosharraf Hossain,
Minister for Labour and Employment,
Government of the People’s Republic of Bangladesh
Via fax: +88(02)7168660
Via email: info@mole.gov.bd
Dear Minister,
Human Rights Watch is an international nongovernmental organization that monitors violations of human rights by states and non-state actors in more than 90 countries around the world.
I am writing to you in reference to research Human Rights Watch is conducting on health and human rights conditions related to the tanneries in Hazaribagh in Dhaka. Our research to date has documented a number of serious concerns related to the tanneries in Dhaka, including:
- None of the tanneries in Hazaribagh have an effluent treatment plant. Studies of tannery effluent in Hazaribagh have found that effluent from tanneries in Hazaribagh contains contaminants in concentrations that exceed the permitted limits for effluent discharged into surface water.
- Residents in Hazaribagh complain of various health problems such as fevers, skins diseases, respiratory problems and diarrhoea that they fear are related to tannery pollution.
- Tannery workers suffer from various health problems, such as skin diseases caused by direct exposure to chemicals used in the tanning process as well as serious accidents caused by dangerous heavy machinery.
- Some tanneries employ children as young as 11 in hazardous labour with chemicals and heavy machinery.
Human Rights Watch is committed to producing material that is well-informed and objective. Human rights Watch is writing to you now to ensure that our report properly reflects the views, policies and practices of the Ministry of Labour and Employment and the Government of Bangladesh regarding the tanneries in Hazaribagh. Human Rights Watch is also writing at this time to seek information from the Minister of Environment and Forest and the Minister of Industries.
We hope you or your staff will respond to the attached questions so that your views are accurately reflected in our reporting, In order for us to take your answers into account in our forthcoming report, we would appreciate a written response by August 17, 2012.
In addition to the information below, please include any other materials, statistics, and government actions regarding the Hazaribagh tanneries that you consider would be important to understand the issue.
Thank you in advance for your time in addressing these urgent matters.
Yours sincerely,
Richard Pearshouse
Senior Researcher
Health and Human Rights Division
Human Rights Watch
Background information
- Does the Ministry of Labour and Employment maintain a list of registered tanneries operating in Hazaribagh? If so, please provide us with that list.
- Does the Ministry of Labour and Employment maintain a list of unregistered tanneries operating in Hazaribagh? If so, please provide us with that list.
- Please specify the current minimum wage for workers in tanneries in Bangladesh.
Monitoring and Enforcement
Please provide details (for 2006-2011 and separately for 2012 – to the present) on:
Questions 2-4 could be answered in the following table:
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Date |
Name and address of tannery |
Type of infringement |
Type of legal action |
Result of the legal action |
Whether infringement is ongoing |
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***;
July 23, 2012
Hon. Dilip Barua,
Minister of Industries,
Government of the People’s Republic of Bangladesh
Ministry of Industries 91, Motijheel C/A, Dhaka- 1000
Via fax: +88(02)9563564
Via email: dsict@moind.gov.bd / industry@moind.gov.bd
Dear Minister,
Human Rights Watch is an international nongovernmental organization that monitors violations of human rights by states and non-state actors in more than 90 countries around the world.
I am writing to you in reference to research Human Rights Watch is conducting on health and human rights conditions related to the tanneries in Hazaribagh in Dhaka. Our research to date has documented a number of serious concerns related to the tanneries in Dhaka, including:
- None of the tanneries in Hazaribagh have an effluent treatment plant. Studies of tannery effluent in Hazaribagh have found that effluent from tanneries in Hazaribagh contains contaminants in concentrations that exceed the permitted limits for effluent discharged into surface water.
- Residents in Hazaribagh complain of various health problems such as fevers, skins diseases, respiratory problems and diarrhoea that they fear are related to tannery pollution.
- Tannery workers suffer from various health problems, such as skin diseases caused by direct exposure to chemicals used in the tanning process as well as serious accidents caused by dangerous heavy machinery.
- Some tanneries employ children as young as 11 in hazardous labour with chemicals and heavy machinery.
On June 6, 2012 Richard Pearshouse, a senior researcher with the health and human rights division of Human Rights Watch, requested to meet you while in Dhaka. In an email dated June 7, your personal secretary Mr. Md. Ashraf Shammem responded to this request by stating that you were traveling overseas at that time.
Human Rights Watch is committed to producing material that is well-informed and objective. Human Rights Watch is writing to you now to ensure that our report properly reflects the views, policies and practices of the Ministry of Industries and the Government of Bangladesh regarding the tanneries in Hazaribagh. Human Rights Watch is also writing at this time to seek information from the Minister of Environment and Forest and the Minister of Labour and Employment.
We hope you or your staff will respond to the attached questions so that your views are accurately reflected in our reporting, In order for us to take your answers into account in our forthcoming report, we would appreciate a written response by August 17, 2012.
In addition to the information below, please include any other materials, statistics, and government actions regarding the Hazaribagh tanneries that you consider would be important to understand the issue.
Thank you in advance for your time in addressing these urgent matters.
Yours sincerely,
Richard Pearshouse
Senior Researcher
Health and Human Rights Division
Human Rights Watch
Background and statistical information
1. Does the Ministry of Industries maintain a list of tanneries operating in Hazaribagh? If so, please provide us with that list.
Dhaka Tannery Estate Project delays
2. In 2003, the Bangladesh Small and Cottage Industries Corporation (BSCIC)’s Dhaka Tannery Estate Project (to develop a suitable relocation area in Savar) was initially scheduled to be completed by December 2005. I understand that the project was initially extended until December 2006. What was the reason for this extension?
3. I understand that the Dhaka Tannery Estate Project was then extended until June 2010, then again to June 2012. What were the reasons for these extensions?
4. I understand that in December 2011, BSCIC sought to extend the Dhaka Tannery Estate Project for 3 years beyond the June 2012 deadline. Was this request granted? What were the reasons for these extensions?
5. What is the current deadline for completing the Dhaka Tannery Estate Project?
Enforcement
6. Does the Government of Bangladesh have, in law or in fact, a policy to not enforce environmental laws or regulations against any Hazaribagh tannery until the tannery relocation site in Savar is prepared? If so, please explain the date this policy was adopted, the precise terms of this policy, and the rationale for this policy. Please also explain the legal grounds that permit the Government of Bangladesh to adopt such a policy.
Annex 2: Leather Processing
Leather tanning is essentially the conversion of raw animal hides (cows, sheep, goats, buffalo) into leather by a series of chemical reactions that alters the protein structure to preserve the hide. It involves three main stages: the first to produce “wet blue” leather, the second to produce “crust leather,” and the third to produce finished leather.
1. “Wet blue” stage
Hides are first soaked for one or two days in water, wetting agents and bactericides, to remove the salt. They are then treated in pits or drums with lime and sodium sulfide to remove hair and excess flesh, in processes called liming and unhairing. These two stages are particularly polluting, causing the release of hydrogen sulfide and sulfur dioxide gases (which can cause sulfuric acid in the atmosphere) while the effluent contains calcium hydroxide as well as toxic sulfides and large amounts of suspended solids.
After liming, the hides undergo fleshing, either manually or in a fleshing machine, a process which strips the remaining flesh and fat from the hide. De-liming then removes the lime from the hides, often by ammonium sulfate or ammonium chloride as well as sodium metabisulfite. Bating, to soften the leather, uses a protein-digesting enzyme. Pickling then prepares the hide for tanning, often using salt, sulfuric acid, and formic acid.
Tanning can involve chrome tanning, synthetic tanning or vegetable tanning. Vegetable tanning uses tannins that occur naturally in the leaves and bark of certain plants. Chrome tanning, which is common in Hazaribagh, involves treating the hides with chromium sulfate then sodium carbonate or sodium bicarbonate. Some 60 percent of the chromium is normally discharged as solid or liquid waste.[274]
The hide then undergoes pre-crusting operations. Sammying, pressing the hides through heavy rollers, removes water from the hide. The hide may be split horizontally to adjust the thickness of the leather, the upper part being the most valued leather. In shaving, rotating blades of a machine smooth the rough part of the leather, generating a fine dust of leather particles.
Some tanneries will sell the resulting “wet blue” hides to other tanneries, while others continue further processing (crusting, then finishing) themselves.
2. “Crust leather”
The leather can be rechromed in order to increase its density and quality. Chromium sulfate is again used along with sodium carbonate or sodium bicarbonate. Re-tanning spreads tanning agents evenly through the leather. This can involve tanning agents, resin, vegetable tannins and other chemicals. The hide is then ready for dying with acid dyes, alkaline dyes, or various others. Ammonium hydroxide, ammonium chloride, labeling agents, synthetic tanning agents, vegetable extracts, formic acid, and acetic acid are also used.
The hides then undergo fat liquoring, which treats the hides with natural or synthetic oils. The hides then go through a setting machine to remove the wrinkles in the hide, and then drying (by hanging, in a vacuum machine, or toggling in the sun) before being trimmed and plated (or smoothed out under high pressure and heat).
Some tanneries will sell the resulting “crust leather” to other tanneries, while others continue the finishing process themselves.
3. Finishing
Leather can be finished in a variety of ways. In general, the finishing process gives a decorative and protective surface coating to the leather. Buffing in a machine smoothes the leather, often creating a fine dust. A finishing solution is applied by a spray machine or by padding. Dyes, binders, adhesives, fillers, waxes, resins, polymers, modifiers, fixatives, thinners, oils and preservative may be used in this part of the process.
[274]K. Kolomaznick et al., “Leather Waste- Potential Threat To Human Health, And A New Technology Of Its Treatment,” Journal of Hazardous Materials, vol. 160 2008, pp. 514.
