Industrial waste flowing into the river Buriganga in Dhaka city without any treatment. © Sony Ramany, WIN photo competition 2017

Wastewater management in the garment industry

Stronger implementation mechanisms are needed

In 2013, the eight-story Rana Plaza building, which houses many garment manufacturing units in Dhaka, collapsed, leading to the death of more than a thousand workers. The primary reason for the collapse is structural fault, which itself is due to non-adherence to prescribed standards for buildings.

This incident brought international attention to the garment industry in Bangladesh, where clothing is manufactured for some of the world’s most famous brands. This led to numerous efforts to raise concerns and address challenges that exist within the garment and textile manufacturing sector in Bangladesh: human rights violation, poor work environment, flouting of laws, corruption, and public and environmental health damage.

The violation of pollution control laws with the discharge of untreated wastewater into Dhaka’s rivers and lakes is one such key challenge. In early 2017, Transparency International Bangladesh (TI-B) and the Bangladesh Water Integrity Network (BAWIN) with support from WIN, undertook a study to understand the integrity concerns around the implementation of laws to protect water bodies from garment industry pollution. The study Use and Effectiveness of Effluent Treatment Plants (ETPs) in the Garments’ Industry of Bangladesh: a Water Sector Integrity Perspective was published in June 2017.

What does the study reveal?

This report points towards poor implementation of laws, inadequate monitoring from government agencies, and factories’ underuse of ETPs. These wastewater treatment plants are the basic treatment facilities that are required to treat effluents at a factory before discharge. They help in reducing the biological oxygen demand (BOD) and keeping waters bodies healthy. In case of use of dyes and colours, the ETP with additional features functions to reduce the chemical oxygen demand (COD) too.

The rivers around Dhaka city are already polluted by textile effluent. While production increases day by day, ETP performance has not. Buyers push to drive down prices so factory owners look for ways to cut costs. Improving ETP performance becomes less of a priority, especially as space is limited in garment factories, an additional constraint.

 

The other side of the garment industry growth engine

The textile and garment industry is a major driver of the Bangladesh economy, accounting for nearly 80% of export earnings and contributing more than 12% of national GDP. ‘Made-in-Bangladesh’ is an internationally recognized badge of quality and has bolstered the country’s image worldwide. Annual turnover of nearly 23 billion USD is predicted to more than double to 50 billion USD by 2021.

The textile firms contribute to wealth and prosperity of the country but in the process, they are destroying the surrounding environment on which farmers and others depend for their livelihoods. According to the Ministry of Environment and Forests, the water of the rivers surrounding Dhaka city where wastewater is discharged without adequate treatment is highly polluted. The rivers have been characterized as ecologically critical areas. Few textile factories in Bangladesh maintain wastewater treatment processes at the necessary level to meet discharge standards.

BA_ETP_Study-enrac (2)
Discharge of wastewater from garment factories in Bangladesh

(c) enrac

 

Legal provisions for ‘Red industries’ and their implementation

Under Bangladeshi law, the garment industry falls under ‘Red industries’. These pose the highest environmental threats. Environmental law mandates that all Red category wastewater producing industries, including textile dyeing plants, must use Effluent Treatment Plants (ETP) to treat wastewater before discharge.

Factories must also obtain an Environmental Clearance Certificate (ECC) by conducting an Environmental Impact Assessment (EIA) and having it approved by the Department of Environment (DoE). Prior approval is also required from the DoE before designing and starting a high polluting industry, including textile factories.

But going by the new BAWIN and TI-B study, there is no effective EIA system and the DoE only published non-statutory guidelines for industrial projects. This weakens the compliance mechanism to ensure proper implementation of environmental laws.

The report further states that the Environment Management Plan is not followed in the day to day operations of a textile factory. There is only a low chance that a factory will in fact be penalized for failing to meet environmental standards. More than 70% of respondents in the study said that environmental laws are not implemented properly.

 

Regulatory weaknesses

Why are environmental laws not implemented properly? According to the Dhaka Watershed Report of the World Bank (2011) the DoE, like the national regulatory agency, is acutely short of manpower and logistical resources. Polluting factories are seldom inspected.

Communities living around industrial clusters informed the report authors that inadequate monitoring and inconsistent enforcement are the main reasons for the fact that factories dispose of untreated effluent into wetlands or rivers. It was reported that agencies often do take mild actions but appeals by industries lead to withdrawal or reduction of punishment. In community and stakeholder consultations, it was suggested that ambiguity and corruption may cause these irregularities. As a result, farmers, fishermen, and others who rely on water bodies have seen a reduction in their livelihoods and an increase in the prevalence of diseases.

On the positive side, there have been efforts to address some of these issues. For example, since 2010, the DoE has deployed mobile magistrates, which help sanction more polluting companies.

There are still big gaps however. A review of the National Water Act 2013 for Bangladesh conducted by the global apparel brand H&M identified a number of issues and made recommendations that may offer useful ways to improve water sector integrity through improved effectiveness of ETPs in the textile industry. The report claims that that it is less expensive to pay penalties, than to invest in ETPs. Legal weakness put the entire enforcement system at risk of inefficiency and corruption. As long as weaknesses and loopholes exist, polluters will bypass wastewater treatment to gain higher profits.

 

Underperforming ETPs

The BAWIN and TI-B report estimates that the proportion of factories with ETPs between 40 and 80%. It has been reported that the volume of wastewater generated by factories is within the capacity of the ETPs used by the textile industry.

However, it is widely acknowledged that many of the installed plants are not designed according to standards or are not operated in an appropriate and responsible manner.

Main factors causing this poor performance of ETPs are a lack of knowledge and technical capability, a lack of monitoring, and poor record keeping. Owners are also often reluctant to run ETPs effectively full-time to minimize the costs of the expensive chemicals consumed in the treatment process. There are no accountability mechanisms.

Factory managers and regulators consulted for the study expressed different views regarding the problems in inspection processes.

Factory managers indicated that the frequency of inspections varies between factories, as does the quality of the inspections. In some cases, water samples are not collected and no action is taken if a factory is non-compliant. Sometimes, additional unofficial payments are required for environmental certificates. It is also reported that there are cases where officials seem to have put pressure on company owners by creating false test reports.

DoE officials report that inspection officers do not always get adequate support from factory managers. Sometimes inspectors are barred from entering factory premises or managers delay their entry so that ETPs can be turned on. Some factories conceal drains through which they dispose of untreated waste.

Punitive measures are difficult to implement because of weak political willingness to impose punishments or appropriate actions for environmental violations. When the violators are politically active they can bring strong pressures to bear on the regulatory bodies.

Water quality testing of polluted water sample for ETP evaluation study

(c) enrac

 

Integrity in the garments industry: everyone needs to do more

The rich set of policies and laws that Bangladesh has should provide should be a strong backing for better wastewater management for the garment industry.

Enforcement is too weak however. The report shows a clear lack of transparency and accountability in environmental decision-making processes in Bangladesh. Weak governance has resulted in undue influence on state institutions to achieve growth rather than sustainable environment management practices.

For the country to reach its ambitious SDG goals, it will be crucial to address these challenges.

The government must enforce its rules and make sure industries comply.

There is space for an advisory and regulatory watchdog in this sector to oversee activities and make suggestions for improvements, undertake advocacy campaigns, and enforce action against violations.

Factories have corporate social and environmental responsibilities and they should comply with rules that can be rewarding and sustainable for them.

The international agencies that are investing in the improvement of governance in the garment sector and reputed global brands that source their garments from the country need to take this issue up urgently to ensure that public health, workers’ rights, and healthy ecosystems are protected and need to contribute to strengthening integrity within the garment industry.

Political commitment, skilled human resources, and institutional capacity are all required to ensure proper enforcement of rules and regulations for pollution control and protection of the environment.

 

Report recommendations

Transparency: Greater transparency requires strengthening rights to information and researching the extent of social and economic damage.

  • Greater clarity and definitions are needed on the responsibilities, and licensing and enforcement powers such as those currently divided between the Departments of Textiles and the Department of the Environment.
  • Adequate enforcement of water regulations requires full-time monitoring of effluents and ETP functions.
  • Awareness needs to be raised among textile owners and their Apex Organizations about pollution and their legal and social responsibility to prevent it.
  • The DoE should make Local Government Institutions aware of how to use their powers to minimize pollution and support Upazila Fisheries Committees in ensuring acceptable water quality in wetlands and fishery areas.
  • The DoE should accredit and appoint competent third-party organizations to monitor textile companies regularly on its behalf in addition to conducting its own monitoring.

 

Accountability: Greater accountability requires clearer lines of responsibility and stronger sector capacity.

  • Greater integration of responsibilities by the Ministry of the Environment and Forests with related ministries will help to identify common goals and start a dialogue on strengthening institutional ownership.
  • A review of the ECA 1995, the ECR 1997 and the Water Act 2013 is needed to establish a consistent approach to conduct EIA and issue project approval for water related project.
  • The DoE needs the skills, staffing levels and resources required to perform its watchdog and enforcement roles, especially in monitoring Environmental Impact Assessments.
  • The country should incorporate a market-based ‘polluters pay principle’ system with appropriate economic incentives, rewards, disincentive and penalties.
  • The Water Resources Planning Organization (WARPO) requires a clearer mandate and the resources to operate a project approval system with integrity.

 

Participation: Participation must ensure places at the table for civil society, private sector and excluded groups to balance stakeholder interests.

  • An appropriate system is required for public consultation to ensure informed decision-making and grievance redress, especially for local people affected by water pollution.
  • National and community-level bodies should be established and validated to monitor water quality of khals, beels and rivers, and the results used to determine anti-pollution measures, operating permits, and actions (including legal actions) against offending industries.

 

Anti-corruption: Corruption can be tackled by ensuring a stronger role for regulators and making participation and transparency mandatory.

  • A licensing system for industrial withdrawal from groundwater sources is required with a strong monitoring system by the DoE and the Water Resources Planning Organization (WARPO).
  • The DoE regulatory bodies should be decentralized and strengthened to monitor effluent treatment plants and systems.
  • The DoE and WARPO should create a more effective mechanism for penalties, such as fines, loss of tax and duty concessions, blacklisting or even removal of operating licenses.
  • Environmental courts should be strengthened to ensure punishment of polluters.
  • Administrative interference should be minimized to decrease corruptions and increase transparency.
  • The legal process should be simpler and quicker when action is taken against alleged improper extraction of water or pollution.

 

Download full report

Use and Effectiveness of Effluent Treatment Plants (ETPs) in the Garments Industry of Bangladesh: a Water Sector Integrity Perspective

 

Thank you

We would like to thank all contributors to the study on the Use and Effectiveness of Effluent Treatment Plants (ETPs) in the Garments’ Industry of Bangladesh: a Water Sector Integrity Perspective, in particular the authors—ENRAC, Transparency International Bangladesh, BAWIN— and Peter McIntyre, for his editing and review.

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