Environmental compliance

Issues and opportunities

Who we are

•  Result oriented Indian organisation focusing on Resource

Efficiency and Sustainability Strategy at enterprises across
sectors in South Asia
•  Proven track record of delivering high savings with quick
payback period, through a team of energy and environment
professionals, with international cooperation partners
Outline

•  The context for Sustainable

Development
•  Indian environmental compliance
scenario
•  Opportunities for businesses
Sustainability

…..is an
Economic system
which fulfils the needs of
the present generation
without compromising
the needs of future
generations
Sustainable development
through the 3P concept

§  Planet
to have environmental considerations

§  Profit
to have economic success

§  People
to have fairness to all persons involved
§  in the process

Economy
Projected need for 2 planet by 2050

1900 2002 2050 2100

Reference: Wuppertal Institute

Indian environmental scenario

•  Industrial growth and urbanisation

•  Constitution and national policy
•  Key institutions
–  MoEFCC
–  CPCB
–  SPCB
–  Judiciary, NGT
Pollution Index of Industry
sectors

Pollution Index Category Sectors

Above 60 Red 60 (oil, dyes, paint
thinner..)
41 to 59 Orange 83 (ice cream, vegetable
oil…)
21 to 40 Green 63 (tea processing, cement
products …)
Below 20 White 36 (paper clips, fountain
pen…)
Environment related legislations
in India

•  The National Green Tribunal Act, 2010

•  The Air (Prevention and Control of
Pollution) Act, 1981
•  The Water (Prevention and Control of
Pollution) Act, 1974
•  The Environment Protection Act, 1986
•  The Hazardous Waste Management
Regulations, etc.
The Hazardous Waste
Management Regulations, etc.

•  Hazardous Wastes (Management, Handling and

Transboundary) Rules, 2008
–  guide for manufacture, storage and import of
hazardous chemicals and for management of
hazardous wastes.
•  Biomedical Waste (Management and Handling)
Rules, 2015
–  proper disposal, segregation, transport, etc. of
infectious wastes
•  Municipal Solid Wastes (Management and
Handling) Rules, 2016
–  aim at enabling municipalities to dispose municipal
solid waste in a scientific manner
Environment related legislations
in India - others

•  E - Waste (Management and Handling)

Rules, 2011
•  Batteries (Management & Handling)
Rules, 2001
•  The Wildlife Protection Act, 1972
•  Coastal Regulation Zone Notification
Common Environmental
Compliance Gaps Observed

•  Lack of Valid Environmental Permits

–  Environmental Clearance (EC), Consent to
Establish (CTE), or Consent to Operate (CTO)
–  Hazardous Wastes Authorisation and Bio-medical
Wastes Authorisation
•  Omission of Details of Site Operations in
Applications, Statutory Records & Returns
–  Record of Hazardous Wastes (Form-3),
Hazardous Waste Labels (Form-12), Hazardous
Wastes Manifests (Form-13), Returns under
Batteries Rules, 2001 (Form-I)
Common Environmental
Compliance Gaps Observed

•  Lack of proper Waste Management

–  Inadequate segregation of wastes
–  Lack of documented records of waste
characterisation and inventory
–  Lack of prescribed labels on containers of
hazardous chemicals and hazardous wastes
•  Lack of Spill Response Plans and Equipment
•  Lack of appropriate training, equipment, and
information to workers and neighbouring
communities
•  Effluent discharge without treatment
Why is compliance poor

•  Lack of management commitment

•  Lack of adequate knowledge of the
applicable regulations
•  Lack of understanding of actions required
to demonstrate compliance
•  A culture of ‘casual compliance’
•  Lack of adequate resources
•  Lack of adequate resources for regulators
Approach to compliance
HIGH
Have decided Use full force
not to comply of the law

Do not want to Deter by

SHIFT
comply detection

Try but do not

Assist to
succeed
comply
Willing to do
the right thing LOW Make it
easy

ATTITUDE TO COMPLIANCE
COMPLIANCE STRATEGY
Ref: John Braithwaite “AN EVOLVING COMPLIANCE MODEL FOR TAX ENFORCEMENT”
Levels of compliance and
response

18
16
14
12
10
8
6
4
2
0
Industry A Industry B
Pollution load Acceptable
How companies respond to pollution

1. Passive 2. Reactive

3. Constructive 4. Proactive
Understanding the pollution prevention or
Resource Efficiency (RE) approach

Waste is generated
What is to be done with it ? Costs
money
End of Pipe thinking:
Waste Treatment approach

Waste is generated
Where does it come from ?
What can be done to avoid it ?
Saves
What can be done to reduce it ? money!
Can it be used by someone else?

RE approach
Resource saving rationale
Resource saving rationale
Global trends – Integrated
Systems
Parallelism of the main standards
ISO 9000, ISO 14001, OHSAS

Employees
Society
Customers

continuous improvement
Global trends – Integrated
Systems
Management systems – common principles?

A management system is a business practice

that enables an organization to strategically
address its goals.

This practice is applicable to Quality,

Environmental, Responsible Care
Health and safety matters and others.

To implement this system the management The Helix of
circle “Plan, Do, Check, Act” is used. Continual Improvement

Global trends – Integrated
Management Systems
Global trends

Protect our
planet’s
resources and
leave no one
behind
SDGs offer a huge opportunity for the private sector
SDGs and private sector in India

•  At least US$ 1 trillion opportunities by 2030

•  Over 72 million new jobs by 2030 opportunity
(e.g. 11 million new jobs in low-income food
markets alone in India)
•  Indian business leaders are using innovative
technologies and business models to enter the
SDGs related markets
 Major market opportunities for Indian
business

100
90
80
US$ Billion

70
60
50
40
30
20
10
0
Forward looking companies are operating
on strategic levels

Horizon 3
Horizon 2 Preparing for
Horizon 1 Optimising and
within today’s influencing the
Greening today’s next business
products and business model,
e.g. upgrading model
supply chain
product
•  Reducing •  Changing •  Moving to a
emissions products service model
along value through •  Changing
chains innovation consumer
•  Reducing •  Collaborating behavior
resource with industry
consumption
What pollution prevention
means for industry

Emissions and wastes are raw and auxiliary

materials – which have mostly been purchased by
paying money – and have not been transformed into
saleable products.

Resource Efficiency is high when nearly all raw and

auxiliary materials are transformed to saleable
products – minimised waste
How RE is implemented in industry

•  Not about specific areas or topics

•  About company as a whole “Gate to Gate”
•  First step; improving resource use with its
actual equipment and facilities
–  Low and no cost options preferred to mid- and
high-cost options
•  Low and no cost options have a short “return
on investment”
•  Second step; Consider investments in more
costly RECP options and expand the scope
to suppliers
Specific balance:
Water use – before intervention
 Interventions

•  Training of management and staff

•  Monitoring of bath conditions

•  Reduced leakages

•  Change to efficient / new technology

Water use –– after
Water use before
intervention
intervention
 Case study: Change in air compressor
technology

Situation: Six reciprocating compressors (7.5 kW each) were operated for 24

hrs/day to supply compressed air at lighting factory in Mohali

ECO Impact: Electricity savings

Solution: Single screw compressor (of
equivalent to Rs. 7.52 lakhs per year
30 kW capacity) has been installed
Payback: 9 months
Case study: Reduced waste – auto
parts SME in Gurgaon

Situation: Losses of brass chips in turning process

Solution: Guard provided on machine ECO Impact: Brass metal

to avoid coolant & chips on floor. This recovery worth Rs 27,600/yr
results in proper brass chips collection Payback: 12 months
Case study: Optimised air conditioning
load

Situation: The industry used 30 nos. of individual window AC units.

Compressor and condenser unit are kept outside are in direct sunlight as
they are on south side of building

Solution: Shade provided over AC

outdoor unit. This reduced the
temperature of the condenser.

ECO Impact: Electricity saving of

Rs. 4,584 per month (573 kWh per
month)
Payback: 3 months
Case study: Energy saving at hot baths

Situation: Auto parts company in India, uses baths at elevated temperatures

for blackening, degreasing. Tanks not insulated from top

Solution: Improve insulation on sides of ECO Impact:

tanks and insulate top of tank Saved 43,200 kWh/yr
Payback: 3 Months
Case Study: Reduced
energy- auto parts SME

After

Situation: 36 pieces of mirror are placed

on a standard brick for convex process in
an oven
Solution: Number of pieces increased
from 36 to 39 per lot thus saving energy on
one hand and enhancing productivity on ECO Impact:
the other. Savings/a: Rs. 207,000
Payback: 2 months
Case Study: Reduced water consumption
– electroplating SME in Gurgaon

Situation: The SME had randomly

set water flow rate in rinse water
tank
Solution:
•  Conductivity profile of rinse
tanks monitored over 3 months
•  Based on this, optimum water
flow rate implemented
•  Operators trained to measure
conductivity as a basis for flow
rate

ECO Impact:
Payback: Immediate
RE example

Paharpur Business Centre

•  Indoor Air is washed, filtered and further purified

using selected natural plants – higher comfort and
productivity for occupants
•  Energy consumed for air conditioning is 20% of
conventional building
Results from a project

Indian metal finishing MSMEs

Electricity 1,607,361 kWh

Diesel 2,479,605 MJ
LPG + PNG 14,406,911 MJ
Coal + wood 4,587,246 MJ

25% 2,289

with low cost or no cost interventions by the MSMEs

themselves. Most interventions payback period
less than 9 months
 Ahmedabad 13%
21%
CHAPTER 5
KEY RESULTS OF THE DIRECT COMPANY SUPPORT 35%
20
25
Vadodara Distribution of Company Savings

Project results II
18
Showing the impact of the ACIDLOOP approach was very At the end of the project period – after the RECP measures 25% 16
14
important from the beginning of the project. During the identified had been implemented by the companies – the 12

No. Companies
first assessment of companies, the ACIDLOOP consultants consultants again measured the consumption of input materials 10
therefore collected data on what amount of resources the per output produced (specific consumption). The ACIDLOOP team 35% 8
company was using, and how much energy and water it is very proud to have achieved significant savings in specific 6
4
consumed. This consumption data was correlated with consumption of input resources across all Aurangabad 24%
regions. As can be 2
the production output. seen in the figure below material, energy and water consumption 0
decreased on an average by more than 20% in all regions. 40% 0% -10% 10% - 20% 20% - 30% 30% - 40% 40% - 50% > 50 %

24%
15% SUCCESSFUL RECP MEASURES
Chandigarh-Mohali 25%

West
20 30%
Puneand 28%
Material, water
18 11%
Distribution of Company
energy savings of
Savings
A wide variety of RECP improvement measures was
suggested to the companies over the course of the direct
On the following three pages, we would li
some of the measures that we have implem
16 Gurgaon 19% ACIDLOOP companies16% engagement phase. Many measures were then implemented ACIDLOOP project. Many more good and b
23% by the companies in close consultation and cooperation be found in the Good and Best Practice
14 with the local counterpart. Measures in the Metal Finishing Sector.
13%
12
North
No. Companies

Faridabad 14%
10 45% Material
8 Replacement of Wires with Jigs in Plating Baths
48% Location: Faridabad | Process: Electroplating
6 18%
Energy

South
4 Ahmedabad 13%
Chennai 32% Before: Steel wires were used for hanging the metal parts to be plated in
2 21% the electroplating bath. Problems associated with this approach included:

0 Vadodara
35% 43% ― Steel wire was consumed during plating. Water
0% -10% 25%
10% - 20% 20% - 30% 30% - 40% 40% - 50% ― > 50 %of parts to be plated was time consuming.
Loading
35%
― The orientation of the parts could not be controlled.
Aurangabad 24%
40%

15%
27% After: The ACIDLOOP team suggested the replacement of all steel wires
SUCCESSFUL RECP MEASURES
Total

with reusable jigs. Benefits from this approach included:

West

Pune 28%
All locations 23%
16% ― The time required for loading was reduced which
increased the productivity.
33%
A wide variety of RECP 48% improvement measures was ― The orientation of parts could now be controlled which
On the following three pages, we would like to present you
improved the quality of the plating process.
South

suggested to the companies over the course of the direct

Chennai 32%
some of the measures that we have implemented during the
43%
Material Energy Water
engagement phase. Many measures were then implemented ACIDLOOP project. ManyRs.more good and
1,00,000 for hangers
best practices
Rs 84,000 from can
reduced costs for
wires and less product losses 14 m
by the companies in close 27% consultation and cooperation be found in the Good and Best Practice Module for RECP
Total

with the local counterpart.

All locations 23%
Measures in the Metal Finishing Sector.
Cost and benefits:
33%

Material Energy Water Costs of interventions Annual savings Payback time

Replacement of Wires with Jigs in Plating Baths

Location: Faridabad | Process: Electroplating
RECP project at hotels

₹ 25,00,000

₹ 20,00,000

₹ 15,00,000

₹ 10,00,000

₹ 5,00,000

₹0
Total investment (one time) Savings achieved (recurring,
per annum)
RECP project at industries cluster

₹ 70,00,000

₹ 60,00,000

₹ 50,00,000

₹ 40,00,000

₹ 30,00,000

₹ 20,00,000

₹ 10,00,000

₹ 0
Total investment (one time) Savings achieved (recurring, per
annum)
Life cycle thinking - example textile and
apparel industry

Reference: Euratex
Life-cycle thinking is key for a
circular economy

Reference: Circular Flanders

Life cycle thinking and circularity

Reference: Ellen McArthur Foundation

New business models for
circularity: Products as a service
Consumer engagement for
circularity
Current Indian trends - Raymond
Current Indian trends – H&M
India
Current Indian trends -
Upcycling
•  Traditional Indian practices – old is new again
with some improvements
•  Several start-ups are offering platforms (apps) to
exchange clothing and to recover fabrics for
other products
What lies ahead for the circular
economy industry?

• Design for circularity

• Scaleable innovations in materials and processes
• Breakthrough in recycling technologies
• Industry-wide end-of-use garment collection
• Rise of supporting frameworks, standards and
agreements for circularity
• Achieving the Sustainable Development Goals
with the circular economy
 Environmental consideration in
the supply chain - examples
•  Danone; sustainable packaging:
–  Moved from polystyrene to Ingeo PLA
–  Joint effort of Danone, WWF Germany and
Nature Works

•  Coca Cola; water use reduction

–  In plant improvements from 2.7 to 2.08 l of
water per l of beverage
–  80% of water use in agriculture supply
chains
Resource efficiency example
from Walmart

Ref: Tom Blanck, CSCP, CPP Principal CHAINalytics; 2011 APIC Intl. Conf., Pitsburgh, USA
Resource efficiency example
from Walmart
Resource efficiency example
from Walmart
Thank you for your attention
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