Although buyer pressure remains one of the key motivators for RMG industry greening -- the government’s role in promoting cleaner production remains significant -- especially in regard to RMG companies where buyer pressure for greening is comparatively less.
Bangladesh has a rich and diverse mixture of policies and regulations covering water pollution management. The strengthening of regulatory provisions for groundwater monitoring, licensing, and charging as part of the rules supporting the 2013 Bangladesh Water Act by the Ministry of Water Resources (MOWR) would be a step towards promoting smarter water use by industries.
Buyer codes and Leadership in Energy and Environmental Design (LEED) certification prioritizes water efficiency. Water conservation and rainwater harvesting could be promoted more -- which can be used in certain washing dyeing or toilet facilities within the RMG factories.
It could be made compulsory in factories above a certain size, or a utility bill discount could be given to companies using a certain amount of rainwater. On the punitive side, banning the drilling of uncontrolled deep tube wells by private companies, groundwater pricing, fee structure (for different types of water use), strict licensing, and use fees for RMG companies could also be explored for sustainable management of the groundwater aquifers in Dhaka.
A Zero Discharge policy by the Department of Environment (DoE) is under process and will go towards relieving some of the groundwater pressure. Dhaka and Chittagong water municipalities (DWASA and CWASA) could review groundwater licensing arrangements for the larger RMG companies, including a revision of water jurisdiction in the growing industrial clusters around Dhaka and Chittagong.
Regulating and pricing groundwater use is likely to be a politically sensitive issue as it will increase the production costs of factories initially before it encourages them to adopt water-saving measures. A groundwater pricing scheme must be combined with technical advisory (and financial assistance in the case of smaller companies) on water-efficient apparel production.
Revising the DoE’s volumetric tariffs to reflect environmental externalities, and developing effective environmental compliance systems are all high priority actions for the DoE. RMG factories are either classified as Red category (if they have a dyeing unit) or Orange B category (if they have a washing unit) -- depending on their production process and potential pollution load -- determining the extent of environmental evaluation the company must undertake, and the kind of ETP and pollution management system they must design before the DoE grants them environmental clearances.
Previously, RMG factories that were “cut and sew only” were classified as Green category -- requiring minimal environmental assessments for certification. In 2008, the ministry amended its rules so that “cut and sew” factories no longer needed any form of DoE clearance. However, cutting and sewing sections use high amounts of artificial lights and generate a fair amount of heat transfer.
These factories usually produce air pollution and solid waste that is disposed of without regulation. The DoE can only penalize them upon receiving written complaints from locals -- about solid wastes incorrectly disposed of in local waterways -- causing a blockage. For greening to occur in all segments of the RMG industry, attention must be paid to the “cutting and sewing only” segment as well.
Red and Orange A category factories must submit various waste and environmental management plans as part of their certification. Every four months, the DoE laboratory officials visit the factories to take samples of air and ETP effluents to be tested at the DoE laboratories. The factories pay the DoE for the laboratory testing and use the results to submit reports to the DoE on their environmental management performance.
During yearly certification renewal, these factory reports help the DoE track performance. While this is an important source of revenue for DoE, it is also important to ensure transparency to prevent agency capture.
It may be noted that RMG companies are now used to compliance scrutiny of an international standard. As of July 1, 2018, building safety audits have been completed in 3,780 factories under the work plan formulated by a tripartite body comprising International Labour Organization, Ministry of Labour and Manpower and factory owners (as mentioned in the Budget Speech 2018). In addition, a Public Accessibility Database has been prepared to contain information of 3,743 export-oriented RMG factories; another database with information of another 27,000 factories is underway. The government and the industry believe this has given a strong signal to the international market.
In the same spirit, a revision in the Environment Conservation Rules 1997 (which is underway) could also consider expanding requirements for companies to publicly disclose their EIAs and their environmental management plans through an online database. A more sophisticated and transparent system would involve the public disclosure of pollution data from the companies.
A pollution database such as this can be useful to design and implement a control system for total emissions of certain pollutants and create requirements for emergency control plans. While the full database will be for use by regulators only, the public should be able to see pollution compliance status for each company.
The DoE could selectively share positive results achieved by companies among their peers, buyers in Bangladesh, and on the DoE website for international audiences. A voluntary benchmarking program could be started in collaboration with interested RMG factories -- possibly from the RMG high achievers -- and their buyers.
This could be done with GCF funding since this involves climate adaptation. The DoE could also start publishing details of court cases brought to the environmental courts, and statistics on environmental fines charged and collected.
Water quality emissions standards are set out in the ECR, Schedule 12. The schedule sets out the maximum amounts of a pollutant (volumetric concentrations) that may be discharged by a factory (or other sources), based on available abatement technology or the impacts of the emissions on the ambient environment.
While such standards are important to ensure the wastewater generated in industrial processes is adequately treated -- such traditional “concentration based” environmental standards do not provide textile factories with incentives to conserve water and to reduce the number of chemicals used in the production process.
Indeed, given the practice of “free and unmetered” water use (via private deep tube wells), volumetric standards such as these, set perverse incentives for factories to dilute the effluent with clean water so that the volumetric standard is met but no effort is made to reduce cumulative effects of pollution (given the population density and economic growth in the Dhaka watershed, this situation can be alarming).
It is mandatory under the ECR 1997 for Orange B and Red category factories to have ETPs. Several reports and government documents note that many RMG owners do not run their ETPs regularly, and often run them prior to DoE visits. The government might consider clarifying the Public Interest Litigation laws to make it easier for citizens living near factory outfalls to bring cases against companies that do not run ETPs.
Currently, the fines for violation are too small and irregularly imposed, allowing noncompliant companies to pay the fine as a cost of doing business rather than purchase and run ETPs. The DoE’s mandate as it stands is not designed to encourage greening outside of the environmental clearances. Recently, they have been drafting guidelines to encourage factories to go for a Zero Discharge model for their air and water emissions.
Once the guidelines are finalized, the DoE will request the factories to submit a Zero Discharge plan on a voluntary basis. According to DoE officials, the institutional challenge lies in monitoring cleaner production (beyond the national requirements), given their current staffing levels.
The Ministry of Environment, Forests and Climate Change is in the process of finalizing an update to the ECR 1997 (Draft Environmental Protection Rules 2017). The update will replace the ECR 1997. The update contains revised emissions standards. The categorization of factories will also be changed to reflect the size of the plant.
The certification process will also be amended. Once the draft is adopted, a technical advisory project could address the staffing gap to increase their capacity to monitor cleaner production targets. A new partnership with the DoE and the most proactive buyers could open new opportunities for scaling up cleaner production in the RMG industry.
The papers in this series are a part of a paper for the DFID supported Economic Dialogue on Green Growth (EDGG) project, implemented by Adam Smith International.
Dr Shahpar Selim has a doctorate on environmental policy, compliance and regulations from the London School of Economics. She also specializes in climate change and disaster management. She is currently working as the Programme Coordinator of the National Resilience Programme, at the UNDP
