Recommendations

To the Government of Bangladesh

• Order all Hazaribagh tanneries to immediately begin relocating outside Dhaka city.
• In accordance with Bangladesh’s Environmental Conservation Act (1995) and Environment Conservation Rules (1997), ensure that all tanneries (including relocated ones) have an environmental clearance certificate for industrial units categorized as “red” (i.e. heavily polluting) from the Department of Environment, or close them down.
• Immediately fill all vacancies for inspectors and assistant inspectors in the Ministry of Labour’s Inspection Department. Within two years, significantly increase the number of staff positions and resources (including for salaries) available to the department to enable it to conduct more regular in-field assessments, including unannounced inspections.
• Revise the Labour Act to strengthen penalties for the following offences:
  • Causing death, grievous bodily harm, or any “injury or danger to workers”,
  • Employing a child or adolescent in hazardous labor,
  • The “catch-all” offence of violating the terms of the act.
• Ratify the International Labour Organization’s Convention 138 On The Minimum Age For Admission To Employment And Work.

To the Ministry of Environment and Forests

• Regardless of the status of the relocation plan, implement the provisions of Bangladesh’s Environmental Conservation Act (1995) and Environment Conservation Rules (1997) that allow for monitoring of all tanneries in Hazaribagh for pollution levels that surpass national standards. Prioritize tanneries that discharge a comparatively large amount of effluent, or discharge effluent with high concentrations of comparatively hazardous chemicals.
• Regardless of the status of the relocation plan, implement the provisions of Bangladesh’s Environmental Conservation Act (1995) and Environment Conservation Rules (1997) that allow for fines on all tanneries in Hazaribagh found to have pollution levels that surpass national standards.
• In accordance with Bangladesh’s Environmental Conservation Act (1995) and Environment Conservation Rules (1997), ensure all tanneries in Bangladesh have an environmental clearance certificate for industrial units categorized as “red” (i.e. heavily polluting). Close tanneries operating without an environmental clearance certificate, if necessary seeking the cooperation of law enforcement agencies and/or utility service providers.
• Design a comprehensive environmental strategy for the Savar relocation site to prevent replicating the environmental damage and hazards to health present in Hazaribagh. 
• Devise a comprehensive environmental clean-up strategy for Hazaribagh, prioritizing surface ponds, large dumps of tannery waste, and the main drainage canals. Remove topsoil polluted beyond the risk-based threshold values and replace it with clean soil.
• Actively monitor for Hazaribagh groundwater contamination on an ongoing basis.
• Ensure that residents of Hazaribagh are informed about the extent of environmental contamination in Hazaribagh and possible health consequences of contamination.
• Increase children’s knowledge of environmental health issues by introducing environmental health programs in schools in Hazaribagh.

To the Ministry of Labour and Employment

• Take immediate and sustained action to enforce compliance by all tanneries in Hazaribagh (and, following relocation, in Savar) with the Labour Act (2006), including the provisions on:
  • Worker health and safety,
  • All paid leave including sick leave,
  • Compensation for injuries (including occupational diseases),
  • Effective disposal of waste and effluent.
• Revise the practice whereby labor inspectors set up advance appointments with factory management. Train and instruct labor inspectors to undertake unannounced inspections.
• Immediately implement an effective removal program for child laborers in tanneries that provides: access to education, including non-formal education and skills development training; alternative income generation opportunities where appropriate; and socio-economic empowerment programs for their families. Prioritize those children performing hazardous labor, including work with chemicals, tannery machinery, and blades for cutting leather. Ensure that the program includes children not reached by previous programs, such as those working full-time, those working with employers who did not want to cooperate with the projects, and those living in tanneries.
• Rigorously enforce existing laws prohibiting hazardous child labor in tanneries, including through proactive monitoring and unannounced on-site inspections, and by imposing effective penalties against employers who violate the law.
• Provide labor inspectors with all the necessary support, including child labor expertise, to enable them to effectively monitor the implementation of labor law standards regarding children in Hazaribagh tanneries.
• Require employers to have, and produce on demand, proof of age of all children working on their premises.

To the Ministry of Health and Family Welfare

• Devise a comprehensive public health strategy to tackle the health problems of residents in Hazaribagh (and, following relocation, to prevent such health problems for residents in Savar).
• Ensure the cancer registry maintained by National Institute of Cancer Research and Hospital collects and makes available data disaggregated by profession and current address at the level of thana/upazila (i.e. sub-district).

To Foreign Companies Sourcing Leather or Leather Goods from Hazaribagh

• Ensure that all leather and/or leather goods originate from tanneries in compliance with international standards and Bangladeshi environmental and labor law, through the following mechanisms:
  • A social and environmental review of source tanneries (including tanneries that process all or part of the leather from supplier tanneries on a “job work” basis) performed by a credible third party,
  • Site visits of source tanneries (including tanneries that process all or part of the leather from supplier tanneries on a “job work” basis).
• Cease all commercial relationships with tanneries that do not operate in compliance with international standards and Bangladeshi environmental and labor law.

To Bangladesh’s Bilateral and Multilateral Donors

• Support a comprehensive environmental clean-up strategy for Hazaribagh, prioritizing surface ponds, large dumps of tannery waste, and the main drainage canals, and the removal and replacement of polluted topsoil.