Sunday, August 18, 2013

Bulk Drug Units Hoax of Zero Liquid Discharges ( ZLD )?

Back Ground of Ban Order

 

The APPCB, considering the water pollution problems and the need to protect the Drinking and Agriculture Water sources, issued Notification of 14-10-1996. This notification restricts establishment & expansion of water polluting Bulk Drug Industries in industrial estates of Ranga Reddy, Medak, Mahaboobnagar and Nallagonda Districts for two years from 01-01-97. Subsequently, the AP Govt. issued G.O.Ms.No 62 of 28-04-1999 making the APPCB Ban Notification permanent. This was done in compliance with the Hon'ble Supreme Court interim orders dated. 12.05.1998 in W.P.No.1056/90.

 

Forces against Ban Order

 

In spite of the ban order as per Supreme Court directive, the Bulk Drug industries have been indulging in excess production / unconsented products with impunity all these years. The penal action for the violations is being circumvented by approaching the courts and / or influencing the policy & decision makers.

 

The Bulk Drug Manufacturers Association (BDMA) advocated the argument that industries, having Zero Liquid Discharges (ZLD) by adopting the state of the art Pollution Treatment Technologies, be permitted to expand their capacities in spite of the Ban Order. It is also argued that as long as the permitted pollution load does not exceed at the point of discharge, the industry be permitted to undertake the production of new products in the banned areas. 

 

Conceding to the request of BDMA, G.O. Ms. No. 64 dated 25-07-2013 was issued, relaxing the restrictions on expansion of existing Water Polluting Bulk Drug Units in and around Hyderabad. This has confirmed the apprehensions of the public, regarding manipulating capacity of the Bulk Drug Industry .to influence the Policy and Decision makers in their favour.

  

Myth of Zero Liquid Discharges ( ZLD )?

 

The decision process regarding relaxation of the ban, resulting in G.O. No. 64, seems to have been unduly influenced by the representation of BDMA claiming Zero Liquid Discharges (ZLD), ignoring the views of the concerned public on the subject.

 

How is Zero Liquid Discharges going to help the reduction of liquid and solid waste loads generated in the process? How is ZLD going to be evaluated and assessed in the absence of accurate data regarding the material balance of Chemicals, Solvents, Water etc. used in the process, the end product produced & liquid effluents generated?

 

 End of the Pipeline Treatment no Answer

 

While trying to achieve ZLD, by reducing hydraulic load of waste waters generated, through upstream segregation, evaporation, recovery etc. process, it will tend to increase solid waste. The total pollution load generated in the process continues to be the same whether in Liquid or Solid form.

 

The Liquid, Solid & Air pollutants   need to be attacked and minimized / avoided at the very point of their generation in the Production Process that generates them & cannot be eliminated once they are generated.

                                            

There is a need for technological up gradation of the production equipment and the process, to minimize both Inputs of Materials & Energy and Outputs of Waste Products & Pollutants. This is the only way to bring down the total Liquid, Solid and Air Pollution Loads in the process itself. The End of the Pipe treatment solutions, such as ZLD, can never lead to real pollution abatement and only ends up in manipulation and dilution of Pollution & Accountability.

                                   

ZLD will Prove to be a Hoax  

 

Before opting for ZLD, the Consent for Establishment (CFE) of the industry should clearly specify the Type and Quantity of the Product permitted per year, the stipulated energy & water consumption and liquid, solid and air pollution loads permitted per unit of product etc.  Without adequate systems, procedures & manpower in place to monitor regulate & control periodically, the ZLD will prove to be a disaster and a Hoax.

 

 The state of Water Bodies in and around Hyderabad is a testimony to the miserable failure of the present regime of Industrial Pollution Control, by the ill equipped Pollution Control Board (PCB) and its Overbearing Bosses. The Bulk Drug Industry, whose road to profit is paved with environmental crimes, more serious than criminal offences, is willing to take risks, as long as the State does not take stringent penal action against their reprehensible conduct.

 

Quote

 

"The pharmaceutical industry is the most lucrative, the most cynical and the least ethical of all the industries.  It is like an Octopus with tentacles that has infiltrated all the decision-making bodies, world health organizations, governments, parliaments, high administrations in health and hospitals and the medical profession"

 

                                                             - Professor Philippe Evans, Director of Necker Institute, France


 

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