October 9, 2012

I. Background

Hazaribagh’s Tanneries

The neighborhood of Hazaribagh lies to the west of Dhaka’s city center, absorbed into the city as Dhaka has expanded. It is surrounded by residential neighborhoods, except to the west where it is bordered by an embankment built in the late 1980s to protect the area from flooding. Beyond the western embankment is a flood plain of the Buriganga, one of Dhaka’s main rivers that lies just one kilometer away.

Like much of Dhaka, Hazaribagh is dense with medium-rise apartment buildings, as well as shops, schools, and mosques. Small businesses like fruit sellers, hairdressers, and tea stalls line the streets. On either side of the western embankment—but mostly on the floodplain—are slums of single-room houses made from concrete, wood, and tin sheets.

Tanneries, some on main streets and others tucked down side alleys, are packed into 50 acres of Hazaribagh. They are often brick-walled factories, with small windows of grills or broken glass. Running beside the factories are open gutters full of opaque blue-grey water, bubbling and swirling. Drains spouting from tannery walls add brown, red or black effluent to the mix. Scraps of discarded leather—thin ribbons or sharp triangles—are everywhere in the streets. There is a strong smell in the air, like rotten eggs.

In between the tanneries are shop fronts stocked with white sacks and plastic blue drums filled with tanning chemicals. Pushcarts with drums lashed to them are constantly on the move through the narrow streets and lanes, as are men pushing bamboo carts piled high with folded leather. Other workers ferry between tanneries balancing a bamboo pole over one shoulder, two square metal tins full of tannery wastewater bouncing on each end: they are recycling wastewater from one tannery for use in another.

Many tanneries in Hazaribagh are multi-story buildings. Raw hides are often processed into “wet blue” leather in large wooden drums and pits on the ground floor, before they are taken upstairs for drying and further processing with heavy machinery.[1] Conditions in these factories are often hot and cramped, with loud noise from machines and poor ventilation of chemical fumes.

How Tanneries Operate

There is considerable variety in how tanneries in Hazaribagh operate. Some tanneries will perform all stages of leather processing, converting raw hides to “wet blue” leather, then to “crust leather,” and finally finished leather. All these stages might be performed under the same roof, or the tannery might have a number of different factory units specialized in each stage scattered throughout Hazaribagh.

In other cases, a single hide will pass through two or three different tanneries before the tanning process is complete. Some tanneries only process raw hides to the “wet blue” stage, or to the “crust leather” stage, before selling on these hides to other tanneries which then complete the process.

Other tanneries rent their factory to leather businessmen who process a batch of hides using that tannery’s premises and heavy machinery, but supplying their own workers, hides and chemicals. The leather businessmen pay the tannery a pre-determined fee based on the number of hides and the stages of processing performed. This way of working, known as “job work,” is common in Hazaribagh. A “job work” tannery might have a dozen or so leather businessmen whose workers all process batches of hides under the same roof at any one time. Those leather businessmen will describe themselves as an independent tannery, even though they rent out the production facilities from another tannery (that may or may not have its own production).

Regular tanneries might process some hides in “job work” tanneries, for instance during peak production periods, or in order to fulfill a large order.

Because of such variety in how tanneries operate, the number of tanneries in Hazaribagh is sometimes given as low as 50 or as high as 350, depending in large part on what is counted as a tannery. Human Rights Watch estimates there are about 150 tanneries in Hazaribagh, considering a tannery as an independent factory unit.[2] A relatively large tannery will employ a few hundred workers, while a medium-sized tannery will employ around a hundred workers, and small tanneries might have just a dozen or so workers.

There are some 8,000 to 12,000 tannery workers, rising to about 15,000 for two or three months following the festival of Eid-al-Adha, the peak season for raw hide processing.[3]

The Hazaribagh tanneries make up between 90 and 95 percent of all tanneries in Bangladesh.[4] There are a handful of tanneries in Bangladesh outside Hazaribagh, located in other areas of Dhaka, as well as Jessore and Chittagong. This report does not address those tanneries.

Around 80 percent of Bangladesh’s total leather production is for export.[5]

Leather (as crust or finished leather), leather footwear, and leather goods (such as suitcases, handbags, and belts) are major export earners for Bangladesh. According to official trade statistics, from June 2011 to July 2012 Bangladesh exported around $663 million worth of leather and leather goods (including leather footwear). This leather was exported to some 70 countries throughout in the world, but principally China, South Korea, Japan, Italy, Germany, Spain, and the United States.[6] In the ten years since 2001-2002, the value of leather exports has grown by an average of $41 million per year.[7]

Bangladesh’s exporters of leather and leather goods enjoy economic incentives from the government, including cash subsidies as a percentage of the value of exports. For example, in 2010-2011, the government reportedly disbursed $22 million to exporters of leather goods.[8] In mid-2012, the government raised the rate of cash subsidy for the export of leather goods to 15 percent (up from 12.50 percent for 2011-2012).[9]

Water, Soil, and Air Pollution

The effluent that pours off tannery floors and into Hazaribagh’s open gutters contains animal flesh, dissolved hair, and fats. It is thick with lime, hydrogen sulfide, chromium sulfate, sulfuric acid, formic acid, bleach, dyes, oils, and numerous heavy metals used in the processing of hides.[10] This effluent flows from the open gutters into a stream that runs through some of Hazaribagh’s slums, and into Dhaka’s main river, the Buriganga.

The tanneries generate a lot of solid and liquid waste.[11] Each day, the tanneries in Hazaribagh create an estimated 75 metric tons of solid waste (mostly salts, bones, as well as leather shavings and trimmings), an amount which may rise to 200 metric tons of solid waste per day in peak production periods.[12] In terms of liquid waste, the government and the two main tannery associations stated in 2003:

About 21,600 cubic meters of environmentally hazardous liquid waste is emitted every day from the tanneries located in Hazaribagh which include hazardous chemicals such as chromium, sulphur, ammonium, salt and other chemicals.….[13] The lives of the people of Hazaribagh are greatly endangered through the damage of the environmental balance in this way, and it is taking a very frightening turn.[14]

Concentrations of chemicals and other contaminants in tannery effluent depend on the location of the wastewater sample, as well as the type of tanning process employed in the tannery, and whether monsoon rains have diluted the wastewater.

Regardless of such variables, previous studies by academic researchers, international projects, and even government investigations have found that the pollution content in Hazaribagh’s wastewater surpasses the limits for tannery effluent established in Bangladesh’s environmental regulations, in some cases by many thousands of times the permitted concentrations.[15]

One detailed study published in 1999 analyzed wastewater samples taken directly from 47 tanneries. The results showed extremely elevated levels of chromium, chloride, lead, sulfates, sulfides, nitrates, and zinc in the effluent. For example, wastewater from one particular tannery had a biochemical oxygen demand (BOD) reading of 3,600 mg/L (against Bangladesh’s quality standard for tannery effluent of 100 mg/L) and a chemical oxygen demand (COD) reading of 9,300 mg/L (against a standard of 200 mg/L). High BOD and COD readings mean there is less oxygen in the water, which causes aquatic life to suffocate and die.[16] This tannery’s wastewater contained concentrations vastly in excess of permitted standards: chromium (4,043 mg/L, against a standard of 2 mg/L), chloride (45,000 mg/L, against a standard of 600 mg/L), lead (1.944 mg/L, against a standard of 0.1 mg/L), and sulfide (145 mg/L, against a standard of 1 mg/L).[17]

Other studies have sampled the water in gutters and streams around Hazaribagh. They also found that the wastewater is thick with chemicals common to the tanning process, far in excess of permitted levels.[18]

One of the rare government studies to measure water quality in Hazaribagh was a 2008 Department of Environment survey on industrial pollution. BOD and COD concentrations found in the Hazaribagh samples were notably higher than those from seven other industrial zones near Dhaka, and revealed that Hazaribagh wastewater vastly exceeds Bangladesh’s permitted standards for tannery effluent.

Tannery effluent also threatens the groundwater under Hazaribagh, although there is no research showing negative effects on human health from this potential route of exposure. However, the issue is particularly significant given that an estimated 95 percent of Dhaka city’s water supply (used for bathing, cooking, and cleaning by an estimated 14 to 15 million people) is derived from various groundwater supplies.[19]

Table: The Department of Environment’s Chemical Analysis of Wastewater[20]

Parameter

Unit

Bangladeshi Standard for Tannery Industry Effluent [21]

Hazaribagh Sample 1

Hazaribagh Sample 2

pH [22]

 

6-9

5.017

4.987

Biochemical Oxygen Demand [23]

mg/L

100

846.7

730.0

Total Suspended Solids [24]

mg/L

150

17,467

15,068

Total Dissolved Solids [25]

mg/L

2,100

4,490

2,867

Chromium

mg/L

2

3,324

2,558

Most studies of Hazaribagh’s groundwater have focused on the presence of elevated levels of chromium.[26] One widely-cited 2001 study showed an average chromium concentration in Hazaribagh groundwater of 0.036 mg/L, about 10 times higher than the average chromium concentration of water samples from other areas in Dhaka. Samples from two deep tube wells in Hazaribagh surpassed the limit for chromium in drinking water permitted by Bangladeshi environmental regulations (i.e. 0.05 mg/L). The study concluded:

In the absence of any natural source for chromium and the presence of a large number of tanneries in the Hazaribagh area, it appears that chromium from tannery wastewater is contaminating the groundwater in and around Hazaribagh area.[27]

Although the vast majority of chromium detected in the 2001 study on Hazaribagh groundwater was in trivalent form, trace amounts of chromium were detected in hexavalent form.[28] Hexavalent chromium is much more toxic than trivalent chromium: inhaled hexavalent chromium increases risk of lung cancer, while touching certain forms of hexavalent chromium can cause dermatitis and skin ulcers.[29] There is recent data from China associating higher levels of hexavalent chromium in well water with significantly higher rates of death from stomach cancer in humans.[30]

A study in 2006 reported lower concentrations of chromium in Hazaribagh groundwater than the 2001 study.[31] However, it did find that groundwater samples from Hazaribagh were higher in sodium, magnesium, ammonium, chlorine, sulfate, and calcium as well as chromium, copper, lead, aluminum, and sulfur than adjacent areas. It warned that “there is the possibility of contamination of the deeper groundwater in the future if protection of the soil and groundwater environment from untreated tannery wastes is not considered.”[32]

Foul-smelling and noxious gases pollute the air in Hazaribagh. Gas analysis of air samples taken in 2007 found levels of nitric oxide above the permitted Bangladeshi limit for ambient air quality. The study also found alarmingly high levels of benzene gas and hydrogen sulfide, a colorless, poisonous, and flammable gas commonly described as smelling like rotten eggs.[33] A 2000 study of air quality at a Hazaribagh tannery found the air surpassed the standard for suspended particulate matter (such as dust and fumes).[34]

Studies have also shown that tannery waste contaminates Hazaribagh’s topsoil. A 1999 study found contamination by various metals, including lead and cadmium. It concluded:

As a whole, the tannery area soils had the highest concentration of… cadmium, manganese, nickel, lead and zinc which might be due to discharging liquid wastes, flocculated sludge and other solids with excessive heavy metals coming from different tanning processes. The highest level of lead … may constitute direct health hazards too.[35]

Along with many other contaminants, the topsoil in Hazaribagh is heavily polluted with chromium, with some studies measuring the concentration in a range from 15,000 to 33,500 mg/kg dm.[36] Although the vast majority of chromium in the soil in Hazaribagh is trivalent, a small amount of the total chromium in the topsoil is in hexavalent form.[37]

Long-Term Problems

In addition to unregulated industrial pollution, studies from as early as the 1990s identified other issues covered by this report. They include:

Illnesses among Residents

A 1997 study compared the self-reported health problems in 112 households in Hazaribagh with those from 100 households in a nearby Dhaka neighborhood (with similar socio-economic characteristics but located further from the tanneries). Respondents in Hazaribagh reported 31 percent more cases of skin diseases, 21 percent more cases of jaundice, 17 percent more cases of kidney-related disease, 15 percent more cases of diarrhea, and 10 percent more cases of fever than the residents in the other neighborhood. [38]

A Worker Health and Safety Crisis

A study on the health of tannery workers undertaken in 1999 found high morbidity among tannery workers. The report found that 58 percent of the tannery workers suffer from gastrointestinal disease (versus 24 percent for the country as a whole), 31 percent from skin diseases (versus 9 percent), 12 percent from hypertension (versus 0.9 percent), and 19 percent from jaundice (versus 0.07 percent). Thirty-seven percent of workers reported experiencing workplace accidents . [39]

Hazardous Child Labor

A UNICEF-commissioned survey of child labor published in 1997 documented the hazardous work performed by children in the Hazaribagh tanneries. The report found that “Under-aged children are not supposed to work with dangerous machinery, yet… fairly young individuals do.” The report recommended that tanneries reduce or eliminate child labor . [40]

A study in 2008 funded by the European Union found the top three meters of soil in Hazaribagh severely contaminated. It noted:

Through percolation of the wastewater, the soil of Hazaribagh has been contaminated with chromium (up to 37000 mg/kg dm), mineral oil, phenols and extractable organohalogen compounds (up to 1200 mg/kg dm). Sulfur concentrations are high as well.[41]

The study found that exposure to chromium via skin contact with the soil and water (while bathing) represented unacceptably high risks to the health of adults and children living in Hazaribagh. It recommended the immediate elimination of direct waste discharges, the removal of surface ponds, large dumps of tannery waste, and the main drainage canals, as well as remedial action to remove and cover the contaminated soil.[42] As of this writing, no such remediation had taken place.

 

[1]“Wet blue” leather is hide after the first stage of leather processing, which can include chrome tanning. Chromium colors the hides blue and the hides contain a lot of moisture, hence the name. “Crust leather” is hide after the second stage of leather processing, when it has been re-tanned, dyed, and dried. The third stage of leather processing— known as finishing— involves buffing the leather and adding various dyes and agents to give it the desired appearance. For a more detailed explanation of leather processing, see Annex 2.

[2] Human Rights Watch interview with anonymous researcher, May 30, 2012.

[3]Asociación Cluster de Industrias de Medio Ambiente de Euskadi (ACLIMA), “Application of Innovative Technologies for the Reclamation and Environmental Improvement of Derelict Urban Areas in Dhaka City (Bangladesh),” December 2008, p. 5. Copy on file with Human Rights Watch. Eid-al-Adha, or the Muslim festival of sacrifice, occurs around 70 days after the end of the month of Ramadan. It involves the sacrifice of animals such as cows, and the donation of part of the meat to the poor.

[4] The figure of 90 percent is from the report by Society for Environment and Human Development, “Leather Industry: Environmental Pollution and Mitigation Measures,” 1998, citing a 1993 World Bank study. The figure of 95 percent is from a 2004 report, Uniconsult International Limited, “A Draft Report on Census Study on Leather Sector in Bangladesh,” August 19, 2004, p. 19. Copy on file with Human Rights Watch. Local media has claimed that the Hazaribagh tanneries are responsible for processing some 84 percent of Bangladesh’s hide and skin supply: Shahiduzzaman Khan, “Clean technology a must for the Savar tannery complex,” Financial Express, December 3, 2006. Copy on file with Human Rights Watch.

[5] Uniconsult International Limited, “A Draft Report on Census Study on Leather Sector in Bangladesh,” August 19, 2004, p. 51. Copy on file with Human Rights Watch. The study found that about 76 percent of tanneries in Bangladesh are export-oriented, 20 percent are both export and domestic- oriented, while only 4 percent of tanneries in Bangladesh sell their product domestically.

[6] From June 2011 to July 2012 Bangladesh exported $330 million of leather (as crust or finished leather): the main importing countries of this leather were China (mostly via Hong Kong) ($139 million), South Korea ($74 million), Italy ($45 million), Japan ($20 million), and Spain ($15 million). During the same period it exported $234 million worth of leather footwear: Japan ($66 million), Germany ($39 million), Italy ($25 million), and the United States ($20 million). Bangladesh earned a further $99 million exporting leather goods: most were exported to China (mostly via Hong Kong) ($61 million), Italy ($11 million) and Germany ($10 million). Bangladesh Export Promotion Bureau, “Product Wise Export Report, July 2011 to June 2012,” http://www.epb.gov.bd/productexportdatadetails.php?year=2011-2012 (accessed July 27, 2012).

[7] Bangladesh Export Promotion Bureau, “Export Performance Bangladesh Leather Sector 2011,” copy on file with Human Rights Watch.

[8] Cited in Pranav Kumar Gupta et al., “Close Eye or Closed Eye: The Case of Export Misinvoicing in Bangladesh,” International Food and Policy Research Institute, January 2012, p. 12. Copy on file with Human Rights Watch.

[9] At the same time, the government announced it was ending export rebates of 4 percent for finished leather and 3 percent for “crust leather.” Rezaul Karim, “Cash incentives for some export items to go,” Financial Express, July 7, 2012, http://www.thefinancialexpress-bd.com/more.php?news_id=135726&date=2012-07-07 (accessed July 28, 2012).

[10] See, for example, S.M. Imamul Huq, “Critical Environmental Issues Relating to Tanning Industries in Bangladesh,” In Naidu et al. (eds), Towards Better Management Of Soils Contaminated With Tannery waste: Proceedings Of A Workshop Held At The Tamil Nadu Agricultural University, Coimbatore, India, January 31 to February 4, 1998, p. 23.

[11]One study calculated that processing one metric ton of raw hide generates approximately 200 kg of final leather product (containing 3 kg of chromium), 250 kg of non-tanned solid waste, 200 kg of tanned waste (containing 3 kg of chromium), and 50,000 kg of wastewater (containing 5 kg of chromium): S. Hüffer and T. Taeger, “Sustainable leather manufacturing a topic with growing importance,” Journal of the American Leather Chemists Association, 99 (10) 2004, pp. 423–428.

[12]Asociación Cluster de Industrias de Medio Ambiente de Euskadi (ACLIMA), “Application of Innovative Technologies for the Reclamation and Environmental Improvement of Derelict Urban Areas in Dhaka City (Bangladesh),” December 2008, p. 11.

[13] The figure of 21, 600 cubic meters of untreated effluent is derived from an assessment by the United Nations Industrial Development Organization undertaken in the late 1990s: BETS Consulting Services, “Environmental Impact Assessment (EIA) of Central Effluent Treatment Plant (CETP) And Other Industrial Installations in The Proposed Tannery Estate, Dhaka, Final Report,” 2005. Copy on file with Human Rights Watch. The amount of untreated effluent currently discharged by the Hazaribagh tanneries could be lower because some tanneries have closed, or higher because tanneries are producing more intensively.

[14] In 2003, the government and tanning associations signed a memorandum of understanding regarding relocation of the tanneries to a site in Savar, lying some 20 km to the west of Hazaribagh. That memorandum is one of the few official documents to mention the amount of liquid waste generated by the tanneries. Bangladesh Small and Cottage Industries Corporation, the Bangladesh Finished Leather, Leather Goods and Footwear Exporters Association, and Bangladesh Tanners Association, “Memorandum of Understanding,” October 23, 2003. Copy on file with Human Rights Watch.

[15] Bangladesh’s tannery effluent standards are found in The Environment Conservation Rules, 1997, August 27, 1997, schedule 12(I).

[16] Biochemical oxygen demand (or BOD) measures the amount of pollution that can be oxidized biologically, while chemical oxygen demand (or COD) measures the amount of pollution in water that cannot be oxidized biologically. They are both standard measurements of water pollution.

[17] Md. Ashiqur Rahman, “Characteristics of Major Industrial Liquid Pollutants in Bangladesh,” M. Eng. thesis, Department of Civil Engineering, Bangladesh University of Engineering and Technology, 1997, appendix A-2. Copy on file with Human Rights Watch.

[18] For example, a study published in 2000 analyzed the water at the Hazaribagh sluice gate outlet: it had a biochemical oxygen demand reading of 2,450 mg/L (against an effluent quality standard of 100 mg/L) and a chemical oxygen demand reading of 3,575 mg/L (against a standard of 200 mg/L). The concentration of chromium at the Hazaribagh sluice gate outlet was 16.41 mg/L (against an effluent quality standard of 2 mg/L): Bangladesh Engineering and Technological Services, “Environmental Impact Assessment on the Industrial Activities at Hazaribagh Area, Dhaka: Final Report,” November 2000, chapter 6, p. 12. Another study, published in 2001, found excessively high concentrations of chromium, lead, sulfide, chloride, ammonia nitrogen, and iron in Hazaribagh effluent and groundwater samples: Ganesh Chandra Saha and Md. Ashraf Ali, “Groundwater Contamination in Dhaka City From Tannery Waste,” Journal of Civil Engineering, 29(2), 2001, pp. 151- 166.

[19] Asiatic Society of Bangladesh, Banglapedia: the National Encyclopedia of Bangladesh, “Groundwater,” 2006 http://www.banglapedia.org/httpdocs/HT/G_0209.HTM (accessed August 9, 2012.) For one dire prognosis of the interplay between population growth and environmental contamination, see “Dhaka City faces collapse in a decade, say experts,” The Independent (Bangladesh), January 2, 2011, http://www.theindependentbd.com/paper-edition/backpage/132-backpage/26939-dhaka-city-faces-collapse-in-a-decade-say-experts.html (accessed August 22, 2012).

[20] Department of Environment, “Survey and Mapping of Environmental Pollution From Industries In Greater Dhaka And Preparation Of Strategies For Its Mitigation,” September 2008, p. 62. Copy on file with Human Rights Watch.

[21] The Environment Conservation Rules, 1997, August 27, 1997, schedule 12(I).

[22] pH is a measure of hydrogen ion concentrations in a solution. Solutions with a pH less than 7 are said to be acidic and solutions with a pH greater than 7 are alkaline. pH is a logarithmic scale, so a difference of one pH unit indicates a ten-fold difference in hydrogen ion concentration.

[23] As noted above, biochemical oxygen demand measures the amount of pollution that can be oxidized biologically, and a high BOD reading means there is less oxygen in the water, which causes aquatic life to suffocate and die.

[24] Total suspended solids are those solid materials (organic or inorganic) suspended in water that can be trapped by a filter.

[25] Total dissolved solids are the inorganic salts and small amounts of organic matter present in solution in water.

[26] In a 2009 study, Khaled Mahmud Shams et al. consider that high chloride and lead concentrations also pose a risk for the city’s groundwater: Khaled Mahmud Shams et al., “Soil Contamination from Tannery Wastes with Emphasis on the Fate and Distribution of Tri- and Hexavalent Chromium,” Water, Air, Soil Pollution, vol. 199, 2009, pp. 123-137.

[27] Ganesh Chandra Saha and Md. Ashraf Ali, “Groundwater Contamination in Dhaka City From Tannery Waste,” Journal of Civil Engineering, 29(2), 2001, pp. 151- 166. Note also that a study published in 1998 detected chromium in shallow tube wells in Hazaribagh, although not in deep tube wells: Md. Hasan Ali et al., “Chromium Contamination And Its Effect on Human Health,” Journal of Dhaka Medical College, 1998 vol. 7(1), pp. 14-19.

[28] Hexavalent chromium (also referred to as chromium VI or hexchrome) is a chemical compound containing chromium in the +6 oxidation state. For the findings on hexavalent chromium in Hazaribagh groundwater, see Ganesh Chandra Saha and Md. Ashraf Ali, “Groundwater Contamination in Dhaka City From Tannery Waste,” Journal of Civil Engineering, 29(2), 2001, pp. 155.

[29] U.S. Department of Health and Human Services, Agency for Toxic Substances and Disease Registry, “Chromium,” September 2008, http://www.atsdr.cdc.gov/toxfaqs/TF.asp?id=61&tid=17 (accessed August 8, 2012).

[30]See J.J. Beaumont et al., “Cancer mortality in a Chinese population exposed to hexavalent chromium in drinking water,” Epidemiology 2008, vol. 19(1), pp. 12-23.As of 2012, the US Environmental Protection Agency is reviewing its guidance to US state drinking water agencies on hexavalent chromium, given recent studies that indicate a greater health risk to hexavalent chromium than previously thought. See US Environmental Protection Agency, “Guidance for Public Water Systems on Enhanced Monitoring for Chromium-6 (Hexavalent Chromium) in Drinking Water,” January 2011, 2011 http://water.epa.gov/drink/info/chromium/upload/memorandum_2011_petesilva_pws_chromium6guidance.pdf (accessed August 22, 2012).

[31] Anwar Zahid et al, “Evaluation of Aquifer Environment Under Hazaribagh Leather Processing Zone of Dhaka City,” Environmental Geology, vol. 50 2006, pp. 495-504. Also note that Md. Rezaul Karim et al., in a study published in 2012, concluded “The results of the present study indicate that groundwater resources at Hazaribagh area are not polluted by any of the toxic heavy metals accumulated into the Hazaribagh subsoil… Since the soil pollution has already percolated to great depth in certain locations, and continues to percolate as the wastewater is still discharged, there is a potential risk of groundwater contamination in the future, especially of shallow groundwater.” Md. Rezaul Karim et al., “Assessment Of An Urban Contaminated Site From Tannery Industries in Dhaka City, Bangladesh,” Journal of Hazardous, Toxic and Radioactive Waste, 2012, manuscript accepted for publication.

[32] Anwar Zahid et al, “Evaluation of Aquifer Environment Under Hazaribagh Leather Processing Zone of Dhaka City,” Environmental Geology, vol. 50 2006, p. 504.

[33]Asociación Cluster de Industrias de Medio Ambiente de Euskadi (ACLIMA), “Application of Innovative Technologies for the Reclamation and Environmental Improvement of Derelict Urban Areas in Dhaka City (Bangladesh),” December 2008, p. 55. Copy on file with Human Rights Watch.

[34] Bangladesh Engineering and Technological Services, “Environmental Impact Assessment on the Industrial Activities at Hazaribagh Area, Dhaka: Final Report,” November 2000, chapter 6, p. 16.

[35] Md Abdul Kashem and Bal Ram Singh, “Heavy Metal Contamination of Soil and Vegetation in the Vicinity of Industries in Bangladesh,” Air, Water and Soil Pollution, vol. 115 1999, pp. 347-361. A study in 2006 found: “From the composition of heavy metals in top soils, it is obvious that tannery industries were responsible for not only the increase of chromium content in soil which is inherent to the tanning process but also an increase in significant amounts of iron, aluminum, zinc, magnesium, copper, sulfur and lead.” See Anwar Zahid et al, “Evaluation of Aquifer Environment Under Hazaribagh Leather Processing Zone of Dhaka City,” Environmental Geology, vol. 50 2006, pp. 495-504.

[36] See, for example, Shaikh Abdul Latif et al., “Determination of Toxic trace Elements in Foodstuffs, Soils and Sediments of Bangladesh Using Instrumental Neutron Activation Analysis Technique,” Bulletin of Environmental Contamination and Toxicology, vol. 82 2009, pp. 384-388; Bangladesh Engineering and Technological Services, “Environmental Impact Assessment on the Industrial Activities at Hazaribagh Area, Dhaka: Final Report,” November 2000, chapter 8, p. 7; Khaled Mahmud Shams et al., “Soil Contamination from Tannery Wastes with Emphasis on the Fate and Distribution of Tri- and Hexavalent Chromium,” Water, Air, Soil Pollution, vol. 199 2009, pp. 123-137; Ganesh Chandra Saha and Md. Ashraf Ali, “Groundwater Contamination in Dhaka City From Tannery Waste,” Journal of Civil Engineering, 29(2), 2001, pp. 151- 166; Anwar Zahid et al, “Evaluation of Aquifer Environment Under Hazaribagh Leather Processing Zone of Dhaka City,” Environmental Geology, vol. 50 2006, pp. 495-504.

[37] Khaled Mahmud Shams et al., “Soil Contamination from Tannery Wastes with Emphasis on the Fate and Distribution of Tri- and Hexavalent Chromium,” Water, Air, Soil Pollution, vol. 199 2009, pp. 123-137.

[38]A.K.E. Haque et al., “Welfare costs of environmental pollution from the tanning industry in Dhaka: An EIA study,” Paper Presented at the mid-term Review Workshop in Yogyakarta, Indonesia, September 3-8 1997. Copy on file with Human Rights Watch. Subsequent studies have documented high rates of fever, skin diseases, stomach and respiratory illnesses, and eye irritation among residents: Bangladesh Engineering and Technological Services, “Environmental Impact Assessment on the Industrial Activities at Hazaribagh Area, Dhaka: Final Report,” November 2000, chapter 7; A.T.N. Asaduzzaman et al., “Water and soil contamination from tannery waste: potential impact on public health in Hazaribagh and surroundings, Dhaka, Bangladesh,” Atlas of Urban Geology, vol. 14 2002, pp. 415-443.

[39]Philip Gain et al., “Health of the Tannery Workers,” Earth Touch: Journal of the Society for Environment and Human Development, vol. 6 2001, pp. 1-7. Copy on file with Human Rights Watch. Subsequent studies have documented high rates of skin diseases and respiratory illnesses among Hazaribagh tannery workers: Md. Sifuddin Chowdhury, “Knowledge About Self-Protection Among Workers in Selected Tanneries,” dissertation for Masters of Public Health at the National Institute of Preventative and Social Medicine, 2007. Copy on file with Human Rights Watch; Ahmed Hasan, “Occupational Health Risks Among The workers Employed in Tanneries At Hazaribag,” dissertation for Masters of Public Health at the National Institute of Preventative and Social Medicine, 2010. Copy on file with Human Rights Watch; Suraiya Begum, “Skin Problems Among the Workers Employed in Leather Tanneries,” dissertation for Masters of Public Health at the National Institute of Preventative and Social Medicine, 2011. Copy on file with Human Rights Watch.

[40]Bert Pelto, “Daily Lives of Working Children: Case Studies from Bangladesh,” 1997, p. 66. Copy on file with Human Rights Watch. Subsequent studies have documented hazardous child labor in Bangladesh tanneries: Zehadul Karim, “Child Labour Situation in Leather Tannery Industry in Dhaka District,” International Labour Organization, 2005. Copy on file with Human Rights Watch; Bangladesh Bureau of Statistics, “Baseline Survey for Determining Hazardous child Labour Sectors in Bangladesh 2005,” July 2006. Copy on file with Human Rights Watch; Anna Ensing, “Hazardous Child Labour in the Leather Sector of Dhaka, Bangladesh,” Foundation for International Research on Working Children, January 2009 http://www.childlabour.net/documents/worstformsAsiaproject/Ensing_Leather_Bangladesh_2009.pdf (accessed September 29, 2012).

[41] Organohalogens are a group of compounds that contain a halogen atom (fluorine, chlorine, bromine, or iodine) bonded to a carbon atom. Extractable organohalogen compounds (EOX) are a fraction of the total organically bound halogen compounds, and some (particularly the organochlorines) have known toxic effects. They include polychlorinated biphenyls (PCBs), chlorobenzenes and DDT (dichlorodiphenyitrichloroethane).

[42]Asociación Cluster de Industrias de Medio Ambiente de Euskadi (ACLIMA), “Application of Innovative Technologies for the Reclamation and Environmental Improvement of Derelict Urban Areas in Dhaka City (Bangladesh),” December 2008. Copy on file with Human Rights Watch.