Ref: GCI/EMP/00302052016

Environmental Management Program

Of
RUSSEL GARMENTS Ltd.
UNIT-01
At

Osman Tower, 56/1, S.M. Maleh Road, Narayanganj,

Bangladesh

Prepared By
Global Compliance Initiative
Chittagong Office: Middle Halishahar, West Nimtala, Bandar, Chittagong.
Dhaka Office: House 40, Road 18, Sector 11, Uttara Model Town, Uttara, Dhaka-1230,
Bangladesh.
May, 2016

1
Table of Contents
Description Page
1.0 Company Profile 3
1.1 Background Information 3
1.2 Legal, Administrative Framework and Environmental Policy 5
1.3 EMS Policy 5
1.4 Environmental Aspects & Its Impact 6
1.5 EMS Objectives, Targets & Management Program 7-24
1.6 Specific objectives of the EMP 25
1.7 Methodology 25
1.8 The EMP Team 26
2.1 Type of the Project 26
2.2 Location & Status of the Project 26
2.3 Manufacturing Processes 26
2.4 Number of Machines 27-28
2.5 Raw Materials 28
3.0 Existing Environmental Conditions 28
3.1 Land Use 28
3.2 Water Quality 29
3.3 Air Quality 29
4.0 Identification of Potential Impacts 30
5.0 Evaluation and Mitigation/Enhancement of Impacts 30
5.1 General considerations 30
5.2 Adverse Impacts and Mitigation 31
5.2.1 Impact due to project location 31
5.2.2 Impacts During Operation Stage 31
5.2.3 Pollution from Solid Waste 32
5.2.4 Air Pollution 32
5.2.5 Light, Humidity, Temperature 33
5.2.6 Noise Pollution 34
5.2.7 Occupational Health 35
6.0 ODS & Environmental Impact 36
7.0 Other Mitigation Measures 37
7.1 Disaster Management Plan 37
7.2 Other Safety Provisions 37
8.0 Beneficial Impacts and Enhancement 37
9.0 Outline of Environmental Management Plan 37
10. Monitoring Requirement 38
11. Conclusions 38
List of Tables
Table-1: Basic data on Russel Garments Ltd. 27
2.4 Number of Machines 27
Table-2.4: List of basic raw materials 28
Table-2: Drinking Water quality (limited parameters) 29
Table 3: Checklists 30
Table 4: Results of Analysis 32
Table 5: Floor wise Light, Humidity & Temperature 33
Table: 6 Test result of noise level 35

2
1.0 Company Profile
About Us:

Russel Garments is one of the models of clean & systematic woven garments manufacturers
& exporters in Bangladesh. Situated 14km far from capital city of Dhaka. With the motto to
deliver readymade garments within the schedule time to our valued client with good quality
and competitive price.

Russel Garments Ltd is sister concern of Osman Group, are designed and installed a state of
the art equipment with skilled & experienced manpower in all sectors with most updated
machineries for its stitching unit. So we are confident that we would be able to meet the
high expectation of our esteemed buyers.

Russel Garments is dedicated to deliver products and services of the highest quality
possible. Our goal is not only to deliver the final product on time, but also to install and
nurture trust, dedication, and support for the clients who are our partners in every steps of
the process.

Above all, we achieve this by recognizing the human capital, which is our most precious
asset and by conducting our business with courtesy to our staff at every level.

Our vision is to ensure customer satisfaction by providing quality product on time as per
requirements of the buyer and also provide the satisfaction to our clients through
unwavering commitment to International Quality Standards in every aspect of our business.
We achieve our vision on the strength of our highly motivated employees in a caring and
safe work environment.

Our clients are introduced to new fashion and experimental design with a view to providing
them with craftsmanship that is both striking and innovative. Our team of garments
professionals keeps an eye on the A to Z process in order to meet the quality and on time
shipment schedule along with sourcing material from the right skilled concern in all aspects
of production. Skilled workers backed by chain of highly professional management to help
them maintaining AQL standard and the perfect planning is the most important part in
executing any order smoothly and other requirement.

1.1 Background Information

Company’s viewpoint

It is a moment of rejoice to introduce ourselves to our clients and patrons. We believe

whatever we have achieved; its credits should be directed toward our clients.

We initiated journey in 1984 with a vision of becoming the most recognized woven
manufacturer of the country as well as to take the widely known reputation of
BANGLADESH as a global Clothing leader to a new high by offering the best blend of quality
and efficiency.

3
 Our painstaking efforts to reengineer each steps of Russel Garments value chain—
procurement, production process & IE & planning, workforce productivity & efficiency,
technologies—and turned them into core competencies have paid off.

Focusing solely in apparel lines, we have adopted a Structure by reengineering its value
chain to deliver high quality Products in shorter lead time with flexibility in order size.
Moreover, having endless efforts to ensure internationally accepted Employment practice,
our clients recognize us as a Partner to protect their value system and images among final
Consumers.

Work place environment

As a responsible apparel producer, we provide employees a Standard work environment as

per law-required level. We installed and have updated lighting, ventilation and ergonomics
of its plants using latest technologies like bus bar for electrical fitting, installing LED bulb,
forced duct ventilation and so on. The goal is to exceed requirements of local legislation and
reach the global environmental standards, and thereby support clients’ images and sourcing
principles. Clearly demarcated emergency routes & exits, smoke & fire detectors,
consciously designed working lay-outs ensure a safe workplace for workers. Instructions
and warning signs are posted in highly visible places, inside the factory and in local
language (Bangla).

Besides being safe, Russel’s Garments workplace offers a congenial & supporting
environment for all managerial staffs and workers work in mutual co-operation and
respect. We consciously put effort to empower woman not only by just recruiting more
women in workforce, rather by undertaking some assertive programs to train & promote
women in the higher levels.

PROCESS FLOWCHART

Receiving Fabrics & Storage of Fabrics & Receiving of

Fabric & Accessories Cutting
Accessories Accessories Inspection Packaging Materials

Button Holing Stitching

Labeling Ironing Trimming
/Buttoning

Storage of Packaging
Final Inspection Packing Final Product
Materials
Checking

Dispatch

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1.2 Environmental Policy, Legal and Administrative Framework
Regulatory requirements toward protection and conservation of environment have been
enunciated by the Govt. of Bangladesh as well as international financial corporation (IFC)
and pertinent policies and regulations among these requirements are summarized as under:

 GoB Environmental Policy, Regulations, and Guidelines;

 IFC Performance Standards and EHS Guidelines;
 National Environmental Policy, 1992;
 National Environment Management Action Plan, 1995;
 Environment Conservation Act, 1995;
 Environment Conservation Rules, 1997;
 Relevant Other National Polices;
 Bangladesh Labor Law, 2006 and
 Bangladesh Labour Rules 2015
 International Labour Organization (ILO)

Applicable documents and records

Record of Legal Compliance (RGLF-LAW-001)

1.3 EMS Policy

Russel Garments Ltd EMS Policy covers the activities of factory, including environmental
compliance. The policy includes a commitment to continual improvement and prevention of
pollution, as well as a commitment to meet or exceed relevant environmental legislation,
regulations, customers’ and other requirements. It will be reviewed annually by the top
management, be communicated to all employees and be made available to the public.

Russel Garments Ltd has developed an environmental policy. The policy statements have
expressed organization’s vision and mission towards customer, safety and environment.

Objectives and targets are formulated to support policy commitments and will be
periodically reviewed to ensure ongoing support of the policy.

ENVIRONMENTAL POLICY

Ruseel Garments Ltd has established the following policies in accordance with its basic
environmental principle.

We give utmost consideration to environmental preservation in all aspects of operations,

products and services.

We strictly respect environmental laws and regulations, and also pursue environmental
improvements as it deems necessary.

Based on these policies, we established, implemented and reviews environmental objectives

and targets; works to prevent pollution; and seeks continuous improvement of its
environmental management.

5
In order to achieve these goals, Russel Garments provides education and conducts
environmental awareness-raising activities for all employees and promotes
environmentally friendly business operations. These environmental policies are
communicated to all employees and also announced to the public.

The EMS Policy ensures that it:

a) Is appropriate to the purpose of the organization, to the nature, scale and
environmental impacts of its activities and services.
b) Includes a commitment to comply with the EMS requirements & continual
improvement.
c) Includes a commitment to comply with applicable legal requirements and with
other requirements to which the organization subscribes,
d) Provides a framework for establishing and reviewing EMS objectives and
targets,
e) Is documented, implemented and maintained,
f) Is understood within the organization and communicated to all persons
working for or on behalf of the organization,
g) Is regularly reviewed for continuing suitability at appropriate level of the
organization,
h) Is available to the public.

1.4 Environmental Aspects & Its Impact

The Manager HR, Admin & Compliance appointed by Russel Garments Ltd identifies the
environmental aspects that the controls and over which it may be expected to have
influence, and determines which of those aspects are considered significant. Procedure of
Aspect Identification and Impact Evaluation (Annex-01) are Identifying the most significant
environmental impact variables, estimating the parameter & respective impact values are
considered for evaluation and sets of target are fixed to mitigate the negative impacts &
enhancement of positive impacts. The method and process to determine significance are
recorded by the Manager HR, Admin & Compliance & his team or departmental head. These
aspects are reviewed at least annually by the half yearly meeting or when there is a new or
changed process or activity at the offices. The Manager HR, Admin & Compliance and other
departmental heads maintain half yearly presentation records.

The identification of the environmental aspects associated with the activities of Russel
Garments Ltd and subsequent evaluation of their impacts and assessment of risks are
undertaken using the following methodologies:

 Collection and review of pertinent reports and other references on EMS

 Thorough study of the office activities and its process, aspects and the surrounding
environment
 Collecting information from Govt. and other agencies about environmental parameters
 Surveying the neighborhood
 Studying the noise level in the factory

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 Studying the water quality
 Studying the air quality by collection of air samples at different locations of the offices.
The processes will be continually developed to mitigate and minimize impact of
environmental aspects associated with the activities of the company, where relevant,
considering the following:

a. Releases to water; emission to air

b. Waste management;
c. Contamination of land;
d. Use of raw materials and natural resources;
e. Other local environmental and community issues,
f. Quality of noise level etc.
Significance of the aspects has been identified through the process of screening the various
activities by the members of the emergency committee, which is shown in the list of
environmental hazards.

Applicable documents and records

Procedure of Aspect Identification and Impact Evaluation (Annex-01)
Record of Aspect Identification and Impact Evaluation (RGLF-AIM-001)

1.5 EMS Objectives & Targets:

The Head of HR, Admin & Compliance is responsible for determining annual operational
objectives and targets. Objectives and targets are developed for all aspects of operations.
EMS objectives take into consideration customer requirements, environmental aspects,
legal compliance as well as views of interested parties. One list of annual EMS objectives
and targets has been documented, and the programs and methods for achieving the targets
and objectives are detailed in the applicable management programs.

At the initial meetings of the emergency team, Russel Garments Ltd sets objectives relating
to improvement of the environmental performance of its offices. All objectives within the
requirements are set giving consideration to the following issues:

 Identified significant aspects and determined significant impacts;

 Legal and other applicable requirements (existing and anticipated);
 Views of customers and interested parties, both external to the company and staff;
 Other relevant issues.
The objectives will be set on annual basis. For each objective, target will be set and will be
reviewed against each objective at the first Management Review Meeting of the year.

7
 Environmental Aspects, Objectives, Targets and Programmes
Responsible Monitoring
Aspect Objectives Targets Programmes
person Measurement
Section/Location: Office Management

1. Review all floors

under LAN/ Wi-Fi
Network to use the
common folders.
Manager-HR,
2. Collect Printing
Admin &
Reduction records and
We will reduce Compliance, IT
of paper communicate the
minimum responsible, Asst.
Paper usage to status with the
Three or Four Manager HR, Internal Audit
waste create a employees.
Rim Paper by Admin &
paperless 3. Creating awareness on
Dec, 2016 Compliance and
office. limited use of paper as
Photocopy
well as encourage
Operator
people to use
electronic media as
much as possible.
4. Verify the use of Paper.

Reduce number of Manager-HR,

individual printers and set Admin &
Reduction Reduce up network printer to Compliance, IT
Toner, of use & number of ink control unnecessary or responsible, Asst.
wastage misuse cartridges use personal documents Manager HR, Internal Audit
tissue ink/cartrid 2% by Dec, printing. Admin &
ge & tissue 2016. Reduce the misuse of Compliance and
tissue paper by Photocopy
awareness. Operator

Regular monitoring water Section Head,

Reduce Reduce usage pipeline, taps, joints etc. Respective
Use of usage of of domestic Conduct awareness Welfare Officer
Internal Audit
Water domestic water 5% by session among employee and Responsible
water Dec, 2016. regarding efficient use of Maintenance
domestic water. personnel.

Monitoring electrical
Reduction of
wiring, equipment etc on
the
Reduction regular interval. Section Head,
Consumpt consumption of
of the Posting awareness sticker Respective
ion of electricity by
consumptio in required locations. Welfare Officer, Internal Audit
electricity 5% within Dec,
n of Conduct awareness Responsible
. 2016 (based on
electricity. session among employee Electrician
current
regarding efficient use of
consumption)
electricity.

8
 Responsible Monitoring
Aspect Objectives Targets Programmes
person Measurement
Manager-HR,
By arranging the monthly
Reduce the Admin &
awareness training and
degradatio Compliance,
5% GHG & CO2 get the feedback from
n of Ozone Section Head,
GHG, CO2 will be reduced trainee. Internal Audit
layer by Respective
by Dec, 2016 Monitoring efficient use of
reducing Welfare Officer &
AC, Refrigerator and
Gas & Responsible
reduce smoke.
electricity Electrician

Section/Location: Store

Regular monitoring water Section Head,

Reduce Reduce usage pipeline, taps, joints etc. Respective
Use of usage of of domestic Conduct awareness Welfare Officer
Internal Audit
Water domestic water 5% by session among employee and Responsible
water Dec, 2016. regarding efficient use of Maintenance
domestic water. personnel.

Monitoring electrical
Reduction of
wiring, equipment etc on
the
Reduction regular interval. Section Head,
Consumpt consumption of
of the Posting awareness sticker Respective
ion of electricity by
consumptio in required locations. Welfare Officer, Internal Audit
electricity 5% within Dec,
n of Conduct awareness Responsible
. 2016 (based on
electricity. session among employee Electrician
current
regarding efficient use of
consumption)
electricity.

Reduction Reduction of Follow waste Manager, Store,

of waste waste 5% by management procedure. Asst. Manager,
Dec, 2016. Store and Waste Records
Waste
Keep records of all types Manager-HR, and Internal
handling
of waste. Admin & Audit
Compliance
Waste disposal records.

Manager, Store,
Ensure 100% Follow chemical purchase Asst. Manager,
Ensure safe procedure.
Chemical safe chemical Store and
chemical Internal Audit
Handling handling and Follow chemical Manager-HR,
handling
storage. compatible chart. Admin &
Compliance

9
 Responsible Monitoring
Aspect Objectives Targets Programmes
person Measurement
Section/Location: Cutting

Regular monitoring water Section Head,

Reduce Reduce usage pipeline, taps, joints etc. Respective
Use of usage of of domestic Conduct awareness Welfare Officer
Internal Audit
Water domestic water 5% by session among employee and Responsible
water Dec, 2016. regarding efficient use of Maintenance
domestic water. personnel.

Monitoring electrical
Reduction of
wiring, equipment etc on
the
Reduction regular interval. Section Head,
Consumpt consumption of
of the Posting awareness sticker Respective
ion of electricity by
consumptio in required locations. Welfare Officer, Internal Audit
electricity 5% within Dec,
n of Conduct awareness Responsible
. 2016 (based on
electricity. session among employee Electrician
current
regarding efficient use of
consumption)
electricity.

Cutting To minimize Maintained To Supply exhaust Fan Cutting In-charge,

waste, cutting 100% waste and growing awareness Cutting
Dust, waste, dust management on waste management supervisor,
Marking and policy. procedure and also about Respective
Paper, increasing effective negative impact Welfare Officer
Using awareness among responsible Person
Internal Audit
Knife, among
roll- Worker
which about
found Pollution
inside the
fabric

10
 Responsible Monitoring
Aspect Objectives Targets Programmes
person Measurement
Section/Location: Sewing

Regular monitoring
water pipeline, taps, Section Head,
Reduce usage joints etc. Respective
Reduce usage
of domestic Welfare Officer
Use of Water of domestic Conduct awareness Internal Audit
water 5% by and Responsible
water session among employee
Dec, 2016. Maintenance
regarding efficient use of personnel.
domestic water.

Monitoring electrical
Reduction of wiring, equipment etc on
the regular interval.
Section Head,
Reduction of consumption of Posting awareness
Respective
Consumption the electricity by sticker in required
Welfare Officer, Internal Audit
of electricity. consumption 5% within Dec, locations.
Responsible
of electricity. 2016 (based on Conduct awareness
Electrician
current session among employee
consumption) regarding efficient use of
electricity.

Reduce the 5% GHG & CO2 By arranging the Manager-HR,

degradation will be reduced monthly awareness Admin &
of Ozone by Dec, 2016 training and get the Compliance,
layer by feedback from trainee. Section Head,
GHG, CO2 Internal Audit
reducing Gas Monitoring efficient use Respective
& electricity of AC, Refrigerator and Welfare Officer &
reduce smoke. Responsible
Electrician

Maintained Keep record of wastage.

Reduction Manager-HR,
100% waste Conduct awareness
and misuse Admin &
management program on waste
Using broken of needle & Compliance,
policy. reduction. To Supply
needle, Plastic, wastage and Section Head,
available needle box Internal Audit
Jhut, Thread to grow Waste
paper and to grow
cone awareness management
awareness negative
among the team &
impact on the
worker. Respective
Environment among
Welfare Officer
user.

11
 Monitoring
Responsible
Aspect Objectives Targets Programmes and
person
Measurement
Section/Location: Finishing

Regular monitoring water Section Head,

Reduce Reduce usage pipeline, taps, joints etc. Respective
usage of of domestic Conduct awareness session Welfare Officer
Use of Water Internal Audit
domestic water 5% by among employee regarding and Responsible
water Dec, 2016. efficient use of domestic Maintenance
water. personnel.

Reduction of
Monitoring electrical wiring,
the
equipment etc on regular
consumption Section Head,
Reduction of interval.
Consumptio of electricity Respective
the Posting awareness sticker in
n of by 5% within Welfare Officer, Internal Audit
consumption required locations.
electricity. Dec, 2016 Responsible
of electricity. Conduct awareness session
(based on Electrician
among employee regarding
current
efficient use of electricity.
consumption)

Reduce the 5% GHG & By arranging the monthly Manager-HR,

degradation CO2 will be awareness training and get Admin &
of Ozone reduced by the feedback from trainee. Compliance,
layer by Dec, 2016 Monitoring efficient use of Section Head,
Internal Audit
GHG, CO2 reducing Gas AC, Refrigerator and reduce Respective
& electricity smoke. Welfare Officer &
Responsible
Electrician

Reduction of Reduction of Follow waste management Manager, Store,

waste waste 5% by procedure. Asst. Manager,
Dec, 2016. Store and Waste Records
Keep records of all types of Manager-HR, and Internal
Wastage
waste. Admin & Audit
Compliance
Waste disposal records.

Manager, Store,
Ensure 100% Asst. Manager,
Ensure safe Conduct awareness training.
Use of safe chemical Store and
chemical Internal Audit
Chemical handling by Continuous monitoring Manager-HR,
handling
Dec, 2016 Admin &
Compliance

12
 Aspect Objectives Targets Programmes Responsible Monitoring
person Measurement
Section/Location: Packing

Regular monitoring water Section Head,

Reduce usage pipeline, taps, joints etc. Respective
Reduce usage
of domestic Conduct awareness session Welfare Officer
Use of Water of domestic Internal Audit
water 5% by among employee regarding and Responsible
water
Dec, 2016. efficient use of domestic Maintenance
water. personnel.

Reduction of
Monitoring electrical
the
wiring, equipment etc on
consumption Section Head,
Reduction of regular interval.
Consumptio of electricity Respective
the Posting awareness sticker
n of by 5% within Welfare Officer, Internal Audit
consumption in required locations.
electricity. Dec, 2016 Responsible
of electricity. Conduct awareness session
(based on Electrician
among employee regarding
current
efficient use of electricity.
consumption)

Reduce the 5% GHG & By arranging the monthly Manager-HR,

degradation CO2 will be awareness training and get Admin &
of Ozone reduced by the feedback from trainee. Compliance,
layer by Dec, 2016 Monitoring efficient use of Section Head,
GHG, CO2 Internal Audit
reducing Gas AC, Refrigerator and reduce Respective
& electricity smoke. Welfare Officer &
Responsible
Electrician

To decrease To follow Manager-HR,

wastage and 100% waste Admin &
Wastage To supply dust box and
increasing management Compliance,
Carton, Poly, properly management and Internal Audit
proper waste Procedure Section Head,
Paper segregate waste
management Respective
Policy Welfare Officer

13
 Aspect Objectives Targets Programmes Responsible Monitoring &
person Measurement
Section/Location: Mechanical & Boiler

To grow
consciousness
to the
Manager-
Responsible
Electrical & Monthly meter
Person and Use 80% CNG instead
To supply available 80% Mechanical reading,
Using Diesel find the of Diesel by Dec,
CNG instead of Diesel and Monthly bill
another 2016
Generator Internal Audit
renewable
Operator
energy source
like solar
energy

Reduce steam Improved guidance on

Manager-
generation or operation of boiler and Monthly meter
Electrical &
increase steam checking all steam line reading,
Generation of Reduce steam Mechanical
utilization 2% insulation. Monthly
steam generation. and
consuming same electric bill
Generator
amount of diesel by Champaign awareness on Internal Audit
Operator
Dec, 2016. consumption of stem.

Aspect Objectives Targets Programmes Responsible Monitoring &

person Measurement
Section/Location: Electrical & Power

Reduction of Reduction of the Electricity consumption

the consumption of monitoring through Manager-
Monthly meter
consumption of electricity by 5% quarterly utility bill Electrical &
reading,
Consumption electricity. within Dec, 2016 review and meter Mechanical
monthly gas
of electricity. (based on current reading. and
bill
consumption) Aware employees Generator
Internal Audit
regarding efficient Operator
electricity use.

Reduction of
using fuel and
find the Manager-
Monthly meter
another Electrical &
Use 80% CNG instead reading,
Using renewable To supply available 80% Mechanical
of Diesel by Dec, Monthly
Generator energy source CNG instead of Diesel and
2016 electric bill
like solar Generator
Internal Audit
energy/ Using Operator
Carbon filter in
the stake

14
Management Program

RUSSEL GARMENTS LTD Document No. RGL-OBJ-003

Unit-01 Date Effective 01.06.2016

(Risk/Env. Management Program)

Prepared by : Manager-HR, Admin & Compliance Approved By: Managing Director

Brief Description: Objective & Target:
Objective :
Department Central Section
Reduction of paper usage to create a paperless office.
Completion Target :
Start Date Jan’16 Dec’16
Date We will reduce minimum Three or Four Rim Paper by
SL # 01 0f 2016 Dec, 2016.
Resources:
Budgeted expenditure Expertise Equipment
N/A IS/IT LAN Network for all
Key Characteristic(s) to monitor:
SL# Characteristic Frequency Responsibility
Concern
01 Paper Consumption Report Once in a Year
Department
Action Plan:
Actual
Curre Date of
SL Respon Proposed Date
Action plan nt completio
# sibility
n
Start End Status
In
Review all departments under LAN/ WiFi
01 IS/IT Jan’16 Dec’16 proces Dec’2016
Network to use the common folders.
s
In
Collect Printing records and communicate Continual
02 HR Jan’16 Dec’16 proces
the status with the employees. Process
s
Creating awareness on limited use of paper In
Continual
03 as well as encourage people to use HR Jan’16 Dec’16 proces
Process
electronic media as much as possible. s
In
04 Verify use of paper Admin Jan’16 Dec’16 proces Dec’2016
s

15
 RUSSEL GARMENTS LTD Document No. RGL-OBJ-003
Unit-01
Date Effective 01.06.2016
(Risk/Env. Management Program)

Prepared by : Manager-HR, Admin & Compliance Approved By: Managing Director

Brief Description: Objective & Target:
Objective :
Department Central Section
Reduction of use & misuse ink/cartridge & tissue
Completion Target :
Start Date Jan’16 Dec’16
Date Reduce number of ink cartridges use 2% by Dec,
SL # 02 0f 2016 2016.
Resources:
Budgeted expenditure Expertise Equipment
N/A HR & IS/IT Use online database, auxiliary use of
printers/copiers
Key Characteristic(s) to monitor:
SL# Characteristic Frequency Responsibility
Inventory Report of
02 Once in a Year Concern Department
Ink/Cartridges & Tissue
Action Plan:
Respon Proposed Date Current Actual Date of
SL# Action plan completion
sibility Start End Status
Reduce number of individual printers and
set up network printer to control
01 unnecessary or personal documents IS/IT Jun’15 Dec’16 DONE Jun’16
printing.

Reduce the misuse of tissue paper by

Continual
02 awareness. HR Jan’16 Dec’16 In process
Process

16
 RUSSEL GARMENTS LTD Document No. RGL-OBJ-003
Unit-01
(Risk/Env. Management Program) Date Effective 01.06.2016

Prepared by : Manager-HR, Admin & Compliance Approved By: Managing Director

Brief Description: Objective & Target:
Objective :
Department All Section
Reduction of domestic water uses
Completion
Start Date Jan’16 Dec’16 Target :
Date
Reduce usage of domestic water 5% by Dec, 2016.
SL # 03 0f 2016
Resources:
Budgeted expenditure Expertise Equipment
N/A Environmental Officer Use proper management of equipment’s like
pumps, valves, tanks, fittings
Key Characteristic(s) to monitor:
SL# Characteristic Frequency Responsibility
Section Head, Respective
Welfare Officer and
03 Report of Domestic Water Use Once in a Year Responsible Maintenance
personnel.
Action Plan:
Responsi Proposed Date Current Actual Date of
SL# Action plan completion
bility Start End Status
Regular monitoring water pipeline, taps,
Operation Continual
01 joints etc. Jan’16 Dec’16 In process
In-charge Process
Manager-
HR, Admin
Installation of water sensitive
02 & Jan’16 Dec’16 In process Dec, 2016
technologies
Complianc
e
Manager-
Conduct awareness session among HR, Admin
Continual
03 employee regarding efficient use of & Jan’16 Dec’16 In process
Process
domestic water. Complianc
e
Training on awareness development in Admin/ Continual
04 Jan’16 Dec’16 In process
using domestic water HR Process

17
 RUSSEL GARMENTS LTD Document No. RGL-OBJ-003
Unit-01
(Risk/Env. Management Program) Date Effective 01.06.2016

Prepared by : Manager-HR, Admin & Compliance Approved By: Managing Director

Brief Description: Objective & Target:
Objective :
Department All department Section Reduction of the consumption of
electricity
Completion Target :
Start Date Jan’16 Dec’16 Reduction of the consumption of
Date
electricity by 5% within Dec, 2016
SL # 04 0f 2016 (based on current consumption)

Resources:
Budgeted expenditure Expertise Equipment
N/A Technical Officer, Electrician Use of low energy consumption
equipment’s
Key Characteristic(s) to monitor:
SL# Characteristic Frequency Responsibility
Section Head, Respective
Report of Electricity Consumption &
04 Once in a Year Welfare Officer,
invoices of electric bill
Responsible Electrician
Action Plan:

Responsibil Proposed Date Current Actual Date

SL# Action plan of
ity Start End Status completion
Monitoring electrical wiring, Operation Continual
01 Jan’16 Dec’16 In process
equipment etc on regular interval. In-charge Process
Respective
Posting awareness sticker in required Continual
02 locations.
Welfare Jan’16 Dec’16 In process
Process
Officer
Conduct awareness session among Respective
Continual
03 employee regarding efficient use of Welfare Jan’16 Dec’16 In process
Process
electricity. Officer

18
 RUSSEL GARMENTS LTD Document No. RGL-OBJ-003
Unit-01
(Risk/Env. Management Program) Date Effective 01.06.2016

Prepared by : Manager-HR, Admin & Compliance Approved By: Managing Director

Brief Description: Objective & Target:
Objective :
Department All Sites Section Reduce the degradation of Ozone layer
by reducing Gas & electricity
Completion Target :
Start Date Jan’16 Dec’16
Date 5% GHG & CO2 will be reduced by Dec,
SL # 05 0f 2016 2016
Resources:
Budgeted expenditure Expertise Equipment
N/A Environmental Officer Use of low carbon emission
equipment’s
Key Characteristic(s) to monitor:
SL# Characteristic Frequency Responsibility
Manager-HR, Admin &
Compliance, Section Head,
05 Report of GHG inventory Once in a Year Respective Welfare Officer &
Responsible Electrician
Action Plan:

Responsibili Proposed Date Current Actual Date

SL# Action plan of
ty Start End Status completion
By arranging the monthly awareness
GM/Operatio Continual
01 training and get the feedback from Jan’16 Dec’16 In process
n In-charge Process
trainee.
Monitoring efficient use of AC, Operation In- Dec’16
02 Refrigerator and reduce smoke.
Jan’16 Dec’16 In process
charge
Initiate & implement tree plantation GM/HR/Admi Dec’16
03 Jan’16 Dec’16 In process
program annually n

19
 RUSSEL GARMENTS LTD Document No. RGL-OBJ-003
Unit-01
(Risk/Env. Management Program) Date Effective 01.06.2016

Prepared by : Manager-HR, Admin & Compliance Approved By: Managing Director

Brief Description: Objective & Target:
Objective :
Department All Sites Section
Reduction of waste
Completion
Start Date Jan’16 Dec’16 Target :
Date
Reduction of waste 5% by Dec, 2016.
SL # 06 0f 2016
Resources:
Budgeted expenditure Expertise Equipment
N/A Manager, Store, Asst. Manager,
Store and Manager-HR, Admin N/A
& Compliance
Key Characteristic(s) to monitor:
SL# Characteristic Frequency Responsibility
Section Head, responsible
06 Waste records Once in a Year
Officers & Staffs
Action Plan:
Proposed Date Current Actual Date
SL# Action plan Responsibility of
Start End Status completion
Manager, Store,
Asst. Manager,
Follow waste management Store and Continual
01 Jan’16 Dec’16 In process
procedure Manager-HR, Process
Admin &
Compliance
Operation In-
02 Keep records of all types of waste. Jan’16 Dec’16 In process Dec’16
charge
Continual
03 Waste disposal records. HR/Admin Jan’16 Dec’16 In process
Process

20
 RUSSEL GARMENTS LTD Document No. RGL-OBJ-003

Unit-01 Date Effective 01.06.2016

(Risk/Env. Management Program)

Prepared by : Manager-HR, Admin & Compliance Approved By: Managing Director

Brief Description: Objective & Target:
Objective :
Mechanical To grow consciousness to the
Department Section Responsible Person and find the another
& Boiler renewable energy source like solar
energy
Start Date Jan’16 Completion Date Dec’16 Target :
Use 80% CNG instead of Diesel by Dec,
SL # 07 0f 2016 2016
Resources:
Budgeted expenditure Expertise Equipment
N/A Manager- Electrical &
Up-gradation of equipment’s to reduce
Mechanical and Manager-HR,
consumption & steam generation
Admin & Compliance
Key Characteristic(s) to monitor:
SL# Characteristic Frequency Responsibility
Manager- Electrical &
09 Report of energy inventory Once in a Year Mechanical and Manager-
HR, Admin & Compliance
Action Plan:
Proposed Date Current Actual Date
SL# Action plan Responsibility of
Start End Status completion
To supply available 80% CNG GM/Operation Continual
01 Jan’16 Dec’16 In process
instead of Diesel In-charge Process
Improvement of energy efficiency
GM/Operation/ Continual
02 like leakage management, heat Jan’16 Dec’16 In process
Admin Process
transfer equipment’s
Continuous training on effective Continual
03 HR/Admin Jan’16 Dec’16 In process
awareness build up Process

21
 RUSSEL GARMENTS LTD Document No. RGL-OBJ-003
Unit-01
(Risk/Env. Management Program) Date Effective 01.06.2016

Prepared by : Manager-HR, Admin & Compliance Approved By: Managing Director

Brief Description: Objective & Target:
Mechanical Objective :
Department Section
& Boiler Reduce steam generation.
Start Date Jan’16 Completion Date Dec’16 Target :
Reduce steam generation or increase
steam utilization 2% consuming same
SL # 08 0f 2016
amount of diesel by Dec, 2016.
Resources:
Budgeted expenditure Expertise Equipment
N/A Manager- Electrical &
Up-gradation of equipment’s to reduce gas
Mechanical and Generator
consumption & steam generation
Operator
Key Characteristic(s) to monitor:
SL# Characteristic Frequency Responsibility
Report of energy inventory & invoices of Section Head, responsible
09 Once in a Year
gas & electric bills Officers & Staffs
Action Plan:
Proposed Date Current Actual Date
SL# Action plan Responsibility of
Start End Status completion
Improved guidance on operation of
Manager- Continual
01 boiler and checking all steam line Jan’16 Dec’16 In process
Maintenance Process
insulation.
Manager-HR,
Champaign awareness on Admin & Continual
02 consumption of stem.
Jan’16 Dec’16 In process
ComplianceAd Process
min
Continuous training on effective Continual
03 GM/HR/Admin Jan’16 Dec’16 In process
awareness build up Process

22
 RUSSEL GARMENTS LTD Document No. RGL-OBJ-003

Unit-01 Date Effective 01.06.2016

(Risk/Env. Management Program)

Prepared by : Manager-HR, Admin & Compliance Approved By: Managing Director

Brief Description: Objective & Target:
Objective :
Reduction and misuse of needle &
Department Production Section Sewing
wastage and to grow awareness among
the worker.
Start Date Jan’16 Completion Date Dec’16 Target :
Maintained 100% waste management
SL # 09 0f 2016 policy.
Resources:
Budgeted expenditure Expertise Equipment
N/A Production Manager, Broken needle keeping box and waste
Supervisor & Operator collection box
Key Characteristic(s) to monitor:
SL# Characteristic Frequency Responsibility
10 Broken needle & waste records Once in a Year Production Manager
Action Plan:
Proposed Date Current Actual Date
SL# Action plan Responsibility of
Start End Status completion
Floor Continual
01 Keep record of wastage. Jan’16 Dec’16 In process
Supervisor Process
Conduct awareness program on
waste reduction. To Supply Manager-HR,
Continual
02 available needle box paper and to Admin & Jan’16 Dec’16 In process
Process
grow awareness negative impact on Compliance
the Environment among user.

23
 RUSSEL GARMENTS LTD Document No. RGL-OBJ-003

Unit-01 Date Effective 01.06.2016

(Risk/Env. Management Program)

Prepared by : Manager-HR, Admin & Compliance Approved By: Managing Director

Brief Description: Objective & Target:
Finishin Objective :
Department Production Section
g Ensure safe chemical handling
Start Date Jan’16 Completion Date Dec’16 Target :
Ensure 100% safe chemical handling by
SL # 10 0f 2016 Dec, 2016
Resources:
Budgeted expenditure Expertise Equipment
N/A Production Manager,
Spillage kits
Supervisor & Operator
Key Characteristic(s) to monitor:
SL# Characteristic Frequency Responsibility
Production Manager,
Manager Store, Asst.
Chemical list, MSDS & Chemical handling
10 Once in a Year Manager-Store and
procedure. Manager-HR, Admin &
Compliance
Action Plan:
Proposed Date Current Actual Date
SL# Action plan Responsibility of
Start End Status completion
Manager-HR,
Conduct awareness training. Continual
01 Admin & Jan’16 Dec’16 In process
Process
Compliance
Manager-HR,
Continual
02 Continuous monitoring Admin & Jan’16 Dec’16 In process
Process
Compliance

24
1.6 Specific objectives of the EMP

The objective of the EMP study is to provide an examination and assessment of the principal
environmental impacts & action plans of the industry. The outline of an environmental management
plan also suggested with an indication of the extent of work to be done to keep the development and
environment compatible. In this context, it should be noted that the term “environment” and its
derivatives have been used in a wide sense, which covers not only physical and chemical aspect, but
also the human measurement.

The specific aims of this EMP are to:

Present a brief discussion on the process and its role in the planning and implementation of
development projects; Present a general description of the project and the process and existing
environment; Delineate the significant environmental issues found and believed to be involved;
Identify the environmental impacts of the project, quantify them & implement the set targets through
proper action plans to the extent possible and suggest the appropriate strategy & plan for the
management of the environment for further improvement in the facility.

1.7 Methodology
National Environmental Policy of Bangladesh sets out the basic framework for environmental action,
together with a set of broad sector action guidelines. The Environment Policy provides the broader
framework of sustainable development in the country. Environment Conservation Act 1995 (ECA’95)
is currently the main legislative document relating to environmental protection in Bangladesh. Under
this act, ‘ No industrial unit or project shall be established or adopted without obtaining environmental
clearance, in the manner prescribed by the rules, from Director General’. Compliance with the
provision of this Act is the responsibility of Department of Environment (DOE). A set of the relevant
rules to implement the ECA, 95 has recently been promulgated (August, 1997). These rules mainly
consist of:
 Categorized list (green, orange and red) of the projects
 Application format to take environmental clearance
 Ambient standards in relation to water pollution, air pollution and noise, as well as permitted
discharge/emission levels of water and air pollutants and noise by industries.
The Rules incorporate “inclusion lists” of projects requiring varying degrees of environmental
investigation e.g. all the existing projects under Orange category (part-B) generally will require an
Environmental Management Plan (EMP) for necessary environmental clearance. The construction of
garments falls under Orange-B category.
This report is based on the secondary data, and information form field visits and project proponent.
Two field visits were undertaken to the project location with a view to reconnaissance survey of the
surrounding areas and to get an idea about operation of the plant. This is follower by evolution of the
information to delineate the major environmental issues relating to the industry. During this process,
the following steps are followed.
 Understanding the process involved in the plan
 Identification of potential impacts and evaluation of their consequences. Identification of
impacts was done using Checklist methods.

25
1.8 The EMP Team
This report has been prepared by Russel Garments Ltd under the guidance & supervision of
S.M. Nurul Huda (CEO-Global Compliance Initiative)- Lead Auditor (ISO 9001 and ISO 14001) and
Kabirul Alam (MSc. In Environmental Science & Lead Auditor (ISO 9001, ISO 14001 & OHSAS
18001)

2.0 The Project

2.1 Type of the Project

Russel Garments Ltd. is a sister concern of Osman Group, specialized in Trouser / Shorts, Skirt / Dress,
Swimwear / Sleepwear. It is designed & installed state of the art equipment with skilled & experienced
manpower in all sectors with most updated machineries for its processes. Company is dedicated to
deliver products & services of the highest quality possible. It is a nationally recognized responsible
business organization; who engaged in manufacturing & export business with the vision to provide
satisfaction to clients through commitment to International Quality Standards in every aspect of the
project. This is done by strengthening the motivation behind employees & safe work environment.

Osman group achieved its quick success through continuous improvement of the processes in the
project site. It is a garment product manufacturing plant with a capacity of 20000 pcs/day. This is
producing different size items as per requirement & specification to be provided by the overseas
buyers.

2.2 Location & Status of the Project

The existing plant has been set up at Osman Tower, 56/1, S.M Maleh Road, Unit-01 Narayanganj,
Bangladesh. The site is about 14 km away from Dhaka city. The production of the project has been
started in the site for a number of years. The plant location is shown in the location map (Anexure-1).

2.3 Manufacturing Processes

Best quality raw materials are collected locally or imported from foreign countries. These are then
passed through cutting, sewing, washing & finishing sections systematically. Then, the finished
products goes for quality check & packing.

26
 Table-1: Basic data on Russel Garments Ltd.

Factory Profile of Russel Garments Ltd-Unit-01

Name of Factory Russel Garments Ltd-Unit-01

Osman Tower, 56/1, S.M Maleh Road, Unit-01

Address
Narayanganj, Bangladesh.

Postal Code 1400

Telephone Number 88-02-7632671

Fax Number 88-02-7630683

E-mail info.rg@osmangroupbd.com

Contact person Bikash Chandra Saha (General Manager)

Ownership Type Private Limited Company.

Plant Capacity 20,000 pcs/day

Major Product All sorts of woven Garments e.g.: Trouser /

Shorts, Skirt / Dress, Swimwear / Sleepwear.
H & M, TEMA, NEXT, HEMA, LIDL, CIA HERING,
Major Customer
O’STIN.

Factory Space 1,62,000 sft

Number of Employees 2300

2.4 Number of Machines

Section Type of Machines Quantity

Cutting Section 1. Cutting Table 5 Sets
2. Cutting Machine 12 Sets
3. Fabric Inspection Machine 01 Set
4. Fusing Machine 04 Sets
5. Band Knife Machine 01 Set
Sewing Section 1. Single Needle Plain Machine 1059 Sets
2. Two Needle Lock Stich Machine 130 Sets
3. Over lock Machine (5 Thread) 119 Sets
4. Over lock Machine (3 & 4 Thread) 48 Sets
5. Flat lock Machine 12 Sets
6. Feed of the Arm 34 Sets

27
 7. Kansai Special 34 Sets
8. Loop Kansai 04 Sets
9. Bar tack Machine 58 Sets
10. Vertical Trimmer 11 Sets
11. Two Needle Chain Stich Machine 25 Sets
12. Eye Button Hole 04Sets
13. Button Hole 29 Sets
14. Button Stich Machine 21 Sets
15. ZIG ZAG Machine 04 Sets
16. Blind Stich 02 Sets
17. Velcro Cutter 02 Sets
18. Velcro Attach 04 Sets
Finishing Section 1. Snap Attaching 34 Sets
2. Folding Table 06 Sets
3. Steam Iron 30 Sets
4. Steam Boiler 05 Sets
Embroidery 1. Shen Shilet 15 Head Becs 328c 01 set
Machine 2. Auto Win 20 Head Fh 920 02 sets
3. Auto Win 06 Head Fh 906 01 set
Others 1. Needle Detector 04 Sets
2. CAD System (LECTRA) 02 Sets
3. SAFQ Machine (Pull Test) 02 Sets
4. Electric Generator 03 Sets
5. Head Press Machine 01 Sets
6. Auto Spreading Machine 01 Sets
7. Compressor Machine 04 Sets
8. Dosting Machine 01 Sets
9. Spot Removing Machine 03 Sets
10. Thread Sucking Machine 05 Sets

2.5 Raw Materials

The main raw materials are fabric & accessories. The quantity of raw materials is given in Table-2.4

Table-2.4: List of basic raw materials

SL No Name of Items Quantity per day Source

01 Fabric 20,000 yds Imported
02 Accessories Local Agent

3.0 Existing Environmental Conditions

3.1 Land Use

Russel Garments Limited is a garment’s manufacturing factory situated at Osman Tower, 56/1, S.M
Maleh Road, Unit-01 Narayanganj, Bangladesh. The project site is about 14 km from the Dhaka city.
The road communication, electricity and gas facilities are available in the project area. From the
surrounding land usage of the project, it can be considered as an area with mix industrial and
residential facilities. For the ease of current post project EMP study, the study has been kept limited to
surrounding areas, which falls within 2 Km radius of the proposed site. Primary and Secondary data
has been generated and collected for conducting the Study.

28
3.2 Water Quality

3.2.1 Ground Water Quality

Ground water label exists at moderate (Generally below 10 m) depth as shown in Anexure-2, which is
being recharged mainly by infiltration of rainwater. Ground water is a stable source of water both for
domestic and industrial purposes in this area. There is no complaint regarding non-availability of
ground water in this area.

Russel Garments Limited is using water from underground source which is assumed to be available. To
determine quality of ground water, water sample was collected from deep tube well. Results show that
all the parameters remain within allowable limit of drinking water value as per Environmental Quality
Standards for Bangladesh. The physical, chemical & bacteriological analysis of drinking water is done
by Department of public health engineering, Bangladesh. The test report is attached in the annexure
of this report.

It is found that local ground water represents a stable source of water for various activities including
irrigation (both shallow and deep tube wells), domestic purposes (hand pumps) and industrial
applications (deep tube wells).

The local groundwater level is lowered to approximately 9m below ground level during the dry
seasons, with levels returning to their normal position before the end of the monsoon.

Table-2: Drinking Water quality (limited parameters)

Sl Water Quality Parameters UNIT Concentration Bangladesh Standards
No Present for Drinking Water
1 pH - 7.6 6.5-8.5
2 Total coliforms CFU/100mL 0 0
3 Faecal coliforms CFU/100ml 0 0
4 Total Hardness as CaCO3 mg/L 258 200-500
5 Chloride mg/l 18 150-600
6 Total Dissolved Solids (TDS) mg/l 188 1000
7 Iron (Fe) mg/l 0.64 0.3-1.0
8 Arsenic (As) mg/l 0.001 0.05
Source: Department of public health engineering, Bangladesh

3.3 Air Quality

Air quality depends on substances, which are present in atmosphere in such concentrations that they
produce undesirable effects on human beings, animal and as well as plant life. These substances
include gases (SOx, NOx, CO, CO2 etc.), Suspended Particulate Matter (smoke, dust, fumes, etc.), and
many others. Concentration of different pollutants above allowable level can have adverse impacts on
plant, animal and human life. In order to establish baseline air quality, monitoring program was
undertaken at the area. Air quality is monitored using continuous ambient air analyzer. According to
the result of analysis, it has been observed that the air quality inside the factory area is under the
national & international guidelines.

4.0 Identification of Potential Impacts

Overall environmental impact of Russel Garments Ltd. plant can be analyzed under two phases-
Construction Phase & Operation Phase. Those are identified in the Table-4.
29
Table 3: Checklists

Project Action Affecting SFIs without mitigation measures Type

Phase Environmental None Minor Medium Major Adverse Beneficial
Resources & Values
Plant Land value depreciation ×
Location Loss of & displacement ×
from homestead land
Loss of & displacement × ×
from agricultural land
Damage to nearby ×
operation
Disruption to drainage × ×
pattern
Inadequacy of buffer × ×
zone
Encroachment into ×
precious ecological
Operation Pollution from liquid × ×
Stage discharge
Pollution from solid × ×
Air quality × ×
Occupational health × ×
hazard
Odor hazard × ×
Traffic congestion ×
Noise hazard × ×
Employment × ×

In this check lists, actions which may affect at the various stages of the project activities are listed and
the degrees of Significant Environmental Impacts (SEIs) are shown. The terms none, minor moderate
and major are used in checklists to classify the magnitude of SEIs. In the checklists, both the plant
location and operational phases of the proposed development are considered separately in order to
distinguish the short term and long term impacts. It is clear from the check lists, liquid waste due to
toilet & canteen washing & occupational health hazard having the slight negative impacts in the
activity, which has the potentiality of creating minor negative SEIs. However, the plants have positive
impacts in terms of employment for numbers of skilled, semiskilled and unskilled people in operation
stage of the plant. It should be noted that identification indicated in the Checklists relates to the
significant level of impact, assuming that nonnegative impacts mitigation measures on benefit
enhancements are adopted.

5.0 Evaluation and Mitigation/Enhancement of Impacts

5.1 General considerations
The impacts which are likely to be occurred in the different phases of the projects are identified in
section 4.0. In this section, evaluation of these impacts was done mentioning their origin and
characteristics along with their possible mitigation/enhancing measures. At the end of each sub
section, status of residual impact is also mentioned.

30
5.2 Adverse Impacts and Mitigation
5.2.1 Impact due to project location

Change in Landscape
Impact Origin
A landscape is a subjective concept that cannot be precisely quantified. However, in general, industrial
building when not designed in considering the local landscape, and then it creates visual intrusion to
the people. The present plant, changes the local landscape of the area to some extent by converting a
green area into a built-up area. This will modify the natural and visual equilibrium for the local people.

Mitigating Measure
Any built up part of the plant should be designed considering key criteria of landscape like coherence,
readability, hierarchy, harmony, and stability. It is understood that the project have a modern
architectural view which does not provide any significant visual intrusion. One simple way by which
the altered green area can be turned into its original visual quality is the plantation of trees around the
build area. This plantation also creates buffer zones. Buffer Zones are spaces which provide natural
environmental protection from damage by external events. These spaces, in between any development
projects, are usually remaining vegetated which can provide windbreaks, erosion control, sediment
traps, sound insulation and visual screening.
A green belt should be developed by planting trees of various species in all possible open spaces
within factory premises. Trees take carbon-di-oxide and discharge oxygen for their photosynthesis,
which helps to clean the air. Some trees also able to absorb toxic pollutant in the air. It also maintains
the ecological balance and improves scenic beauty.

Residual Impact
Provided that the mitigation measure indicated above is fully implemented, residual impact to be very
insignificant.

5.2.2 Impacts During Operation Stage

Impact Due To Liquid Discharge

Impact Origin
The domestic waste water is directly going to nearby area. However, the quantity of waste from this is
limited. Characteristics of effluent from as monitored for limited parameters during the study for
existing plant. Characteristics of effluent from as monitored for limited parameters during the study
for existing plant. From the drinking water quality test report, it is found that all the basic parameters
are lies below the permissible limits of Bangladesh standards (according to ECR 1997). So, when
waters are discharging to environment permits the level of acceptance.

Mitigation Measures
Considering this real fact, the reservoir capacity needs to be upgraded to mitigate the minor impact. It
will be better for the environmental condition & also the factory. Russel Garments ltd. has already
taken initiatives to decrease the water consumption inside their factory premises & solve the recent
issues.

Residual Impact
Provided that the mitigation measure indicated above is fully implemented, residual impact to be very
insignificant.
31
5.2.3 Pollution from Solid Waste
Impact origin
Substantial amount solid wastes are generated from the factory. The solid wastes mainly include
cutting of fabrics, discarded packing materials etc. Total amount of solid waste would be around 400-
500 kg/day. These solid wastes may pollute the surrounding environment if not properly disposed of.

Mitigation Measures
The solid waste (particularly cutting fabric & packing materials) have a secondary use and are sold to
the small traders in the country. These cutting fabrics are secondarily used in making insulated
materials for other systems. Factory has already taken some initiatives to reduce the solid waste & also
use less solid materials for their purposes.

Residual Impact
Provided that the mitigation measure indicated above is fully implemented, residual impact to be very
insignificant.

5.2.4 Air Pollution

In order to establish base line air quality, monitoring program was undertaken at the project area. An
eight hourly air sample was collected through high volume air sampler inside Russel Garments Ltd
boundary. Monitoring was done for SO², CO, CO², O², Flue temperature, Flue pressure, SOX, and NOX and
monitoring results are given in Table 4. From the analysis result it has been demonstrated that all result
are within the permissible limit.

Table 4: Results of Analysis

Parameters
Observations CO CO2 SO2 NO NOx O2
mg/m3 % mg/m3 mg/m3 mg/m3 %
Run-01
01 185 2.3 39 155 166 17.8
02 128 2.3 17 148 159 17.9
03 128 2.3 17 155 166 17.9
Run-02
01 130 2.2 14 156 167 18.0
02 140 2.3 11 155 166 17.9
03 130 2.2 11 172 185 18.0
Run-03
01 130 2.2 11 163 175 18.0
02 111 2.2 5 168 180 18.1
03 118 2.2 5 167 179 18.0

Recommendation
The Air Emission from the stack point of the GENERATOR has been analyzed for the parameter of
NOx, SO2, CO, O2 and CO2 to evaluate the effect of the plant’s emission while running on 100% Diesel
(Heavy Oil) on the air environment. From the analysis, it has been observed that the factory emission
NOx, SO2, CO, O2 and CO2 are within the standard limit of IFC/World Bank.

32
5.2.5 Light, Humidity, Temperature
Light, humidity and Temperature have been measure as the same procedure.

Table 5: Floor wise Light, Humidity and Temperature of the Russel Garments Ltd
Lighting Assessment Result
Avg. Light Level
Building / Floor Section
(Lux)
Main Building Finishing & Inspection
1063
1st Floor Section
2nd Floor Cutting Section 759
3rd Floor Sewing Section 713
Finishing & Inspection
4th Floor 1029
Section
4th Floor Sewing Section 583
5 Floor
th Sewing Section 893
5th Floor Finishing & Inspection
1055
Section
5th Floor Sample Section 808
6 Floor
th Lab Room 518
6th Floor Training Center 514
7 Floor
th Sewing Section 816
7th Floor Finishing & Inspection
1218
Section

Recommendation
It has been observed that the workplace light level of the factory is satisfactory according to the BNBC &
OSHA standards.

Humidity Assessment Result

Avg. Humidity Level
Building / Floor Section
(% RH)
Main Building
Generator Room 51.98
Basement
Basement General Store 59.73
Basement Warehouse 59.65
Ground Floor Generator Room 50.25
Ground Floor Carton godown 50.25
Ground Floor Childcare Room 52.95
1st Floor Boiler Room 47.10
1st Floor Finishing Section 47.25
2nd Floor Cutting Section 48.88
2nd Floor Finished goods Area 49.70
2nd Floor Doctor Room 48.40
3rd Floor Sewing Section 48.70
4th Floor Finishing Section 49.85
4th Floor Sewing Section 49.60
4th Floor Boiler Room 45.60
5th Floor Sewing Section 51.35
5th Floor Finishing Section 50.00
5th Floor Boiler Room 47.13
5th Floor Sample Section 54.65
6th Floor Lab Room 38.28
33
 6th Floor Training Center 52.98
6th Floor Dining Room 52.65
7th Floor Finishing Section 53.20
7th Floor Sewing Section 56.75
7th Floor Boiler Room 47.62

Recommendation
It has been observed that the workplace humidity level of the factory is satisfactory according to the
standard humidity reference limit.

Temperature Assessment Result

Avg. Temperature
Building / Floor Section
Level (ºC)
Main Building
Generator Room 32.15
Basement
Basement General Store 29.25
Basement Warehouse 29.68
Ground Floor Generator Room 32.05
Ground Floor Carton godown 31.68
Ground Floor Childcare Room 28.53
1st Floor Boiler Room 32.02
1st Floor Finishing Section 29.95
2nd Floor Cutting Section 29.63
2nd Floor Finished goods Area 31.32
2nd Floor Doctor Room 28.50
3rd Floor Sewing Section 29.32
4th Floor Finishing Section 29.73
4th Floor Sewing Section 28.80
4th Floor Boiler Room 31.95
5th Floor Sewing Section 29.43
5th Floor Finishing Section 29.22
5th Floor Boiler Room 32.12
5th Floor Sample Section 28.30
6th Floor Training Center 29.43
6th Floor Dining Room 32.22
7th Floor Finishing Section 29.50
7th Floor Sewing Section 29.60
7th Floor Boiler Room 32.20

Recommendation
It has been observed that the workplace temperature Level of the factory is satisfactory according to the
OSHA & ACGIH standards temperature reference limit.

5.2.6 Noise Pollution

Different types of machine and boiler are using for production in the floor and deferent floor, which
are not producing any significant noise, which is harm to working people of factory. 3R consulting firm
has conducted a laboratory analysis for identification of noise level different section of the factory.

34
Table: 6 Test result of noise level
Avg. Noise Level Recommended
Floor/Level Section
(dB) Value
Main building
Generator Room 93.93
Basement
Basement General Store 61.65

Basement Warehouse 60.40

Ground Floor Generator Room 92.38

Ground Floor Carton godown 63.50 Bangladesh

National
Ground Floor Childcare Room 61.10 Building Code
(BNBC) Standard
1st Floor Boiler Room 79.42 90 dB for 8 hours
exposure
1st Floor Finishing Section 75.70
2nd Floor Cutting Section 82.08
OSHA standard:
2nd Floor Finished Goods Area 72.20 90 dB for 8 hours
exposure
2nd Floor Doctor Room 68.92

3rd Floor Sewing Section 80.32

NIOSH Standard:
4th Floor Finishing Section 71.28

4th Floor Sewing Section 79.33 85 dBA TWA for 8

hours
4th Floor Boiler Room 77.88

5th Floor Sewing Section 80.60

5th Floor Finishing Section 71.20

5th Floor Boiler Room 79.38

5th Floor Sample Section 70.30

6th Floor Lab Room 66.83

6th Floor Training Center 69.83

6th Floor Dining Room 69.63

7th Floor Finishing Section 74.10

7th Floor Sewing Section 81.48

7th Floor Boiler Room 79.10

Recommendation
It has been observed that the workplace Noise Level of the factory is satisfactory according to the BNBC,
OSHA and NIOSH standards. As the noise level of Generator Room has been exceeded the reference
value, it is recommended that air plug should be provided to the related workers to avoid occupational
health hazards.

35
5.2.7 Occupational Health
Impact Original
The workers who work inside the factory face occupation health status of the employees and workers
are important for not only the persons working in the plant, but also for the better plant operation and
maintenance.

Mitigation Measures
Regular medical check-up is to be done to ensure the soundness of health of the employees and
workers. Pollution control measures are to be duly adopted if necessary, including noise and odor
control, so that there would not be any negative occupational health impact.
Insurance for all employees should be taken out. A senior Medical officer with sufficient background
and experience in occupational health problems is coordinating this issue and would be responsible
for implementing a detailed and regular program for ensuring health safety for all the workers in the
industrial unit. This program should have adequate training arrangements for workers in occupational
health.

Residual Impact
Provided that the mitigation measure indicated above is fully implemented, residual impact to be very
low.

6.0 ODS & Environmental Impact

Ozone-depleting substances (ODS) generally contain chlorine, fluorine, bromine, carbon, and hydrogen
in varying proportions and are often described by the general term halocarbons. Chlorofluorocarbons
(CFCs), carbon tetrachloride, and methyl chloroform are important human-produced ozone-depleting
gases that have been used in many applications including refrigeration, air conditioning, and as
solvents.

These substances are effective ozone-depletes for two reasons. The first is that they do not break
down in the lower atmosphere - they can remain in the atmosphere from 20 to 120 years or more.
Unlike most chemicals released into the atmosphere at the Earth's surface, ozone-depleting substances
are not washed back to Earth by rain or destroyed by other chemicals, which means they drift up into
the stratosphere. The second is that they contain either/both chlorine and/or bromine and thus help
the natural reactions that destroy ozone.

Once they reach the stratosphere, ultraviolet (UV) radiation breaks up these molecules into chlorine
(for example, from CFCs, methyl chloroform, or carbon tetrachloride) or bromine (for example, from
halons or methyl bromide) which, in turn, break up ozone (O3).

Mitigation Measures
To reduce the ODS generation, factory should have to use CFC free refrigerator, air conditioning and
mitigate the use of solvents.

Residual Impact
Provided that the mitigation measure indicated above is fully implemented, residual impact to be very
low.

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7.0 Other Mitigation Measures
7.1 Disaster Management Plan
Recently, fire is the major disaster has taken place in the numbers of such factory. Fire not only guts
but some time workers of the factory are burned or even died from fire. The man source of fire is the
electric short-circuit within the factory to project the properties and working people. In this regard,
following suggestions are made:
 All electrical works should be concealed/PVC piped with double
insulation/protecting covering.
 There should be sufficient fire/ heat detecting system in each floor.
 There should be sufficient number of fire extinguishers/firefighting items in each
floor which should be checked by Fire Service officials twice in a year.
 There should be a reserve of gas masks (at least 10 nos. In each floor), a drum of
water, bucket, hand-gloves etc. in the factory to put of the fire.
 No smoking and cooking should be allowed in the factory during working hours.

7.2 Other Safety Provisions

Beyond the above measures, the project should also have provision for first aid medical services after
any accident. The project has provision in its recurring annual expenditure for purchasing safety items
such as firefighting items, hand gloves etc.

8.0 Beneficial Impacts and Enhancement

During Operation Phase
Impact Origin
The most significant positive impact of the plant would be the production of garments which earn
foreign currency through export. The other important positive impact of the plant is the employment
of personnel for the operation of the plant. The project envisages employing substantial numbers of
skilled and unskilled personnel during its operational phase. A part from these above positive impacts
other beneficial impacts include benefit to local transport business, local economy because of
employment, community development etc.

Benefit Enhancement Measures

Although employment is a matter of company who has the right to determine whom he shall and shall
not employ, but still, the project should take initiative to employ local people wherever possible and to
give preference to employment of the jobless people.

9.0 Outline of Environmental Management Plan

General Consideration
In the context of a project, Environmental Management Plan (EMP) is concerned with the
implementation of the measures necessary to minimize or offset adverse impacts and to enhance
beneficial impacts. Unless the mitigation and benefit enhancement measures, identified in EIA, are
fully implemented the prime function of EIA cannot be achieved. All the measures are said to be
successful when they comply with the Environmental Quality Standard (EQS) of Bangladesh. Thus the
objectives of EMP for the present project would be:
 Mitigation measures to reduce or eliminate negative impacts
 Enhancement measures to maximize positive impacts
 Monitoring requirement and indicators.

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Mitigation/Beneficial Enhancement Measures
For effective and environment friendly operation of an industry, a set of guideline tools and suggestion
are necessary which need to be followed at various stages of plant installation, operation and
maintenance . This plan generally has various components of management depending on the type of
industry or plan activity and types of discharge and their pollution potential. The EMP once prepared
forms the basis of environmental management actions from the part of the plan authority and often
may need modification or up-gradation because of changes in the plant operation or factory or factual
pollution load/environmental problems detected afterwards. The plant authority may also need
fleshing out the suggested outline of the EMP laid down in this report. Some aspects of mitigation and
benefit enhancement measures have also been discussed concurrently with impact evaluation. In view
of the earlier discussion, summary of all possible mitigation and benefit enhancement measures due to
plant location and plant operation are presented in Table-7.

Table-7: Possible Mitigation/Enhancement Measures

Project Phase Potential Impacts Mitigation/Benefit Enhancement Measures

Plant Location Disruption of earth surface *Cutting & filling of earth should be kept
minimum at the site
Inadequacy of buffer zone *Plantation of trees should be done in all
Air pollution adequate open space
* Provide proper stack height
Operation Phase Water Pollution *Improvement in all water management
Solid Waste *Collect all type of solid wastes & solid it
whichever is possible.
Employment *Employ local jobless labors.

10. Monitoring Requirement

Monitoring of the performance of a plant is very important and sometimes vital. An industrial unit in
Bangladesh generally monitors the quality of its raw materials and product, but not the related
environmental parameters, thereby neglecting the environment. For surveillance of the performance
of the equipment and the quality of the environment, monitoring of the environment of the work zone
and the general environment should be performed on a regular basis.

It should be maintained here that the monitoring program should be such so that it can ensure
compliance with national environmental standards. The importance of this monitoring program is also
for ensuring that the plant does not create adverse environmental changes which can be utilized if
unwarranted complaints are made.

Monitoring Indication:
Environmental monitoring requires set of indicators that could be conveniently measured, assessed
and evaluated periodically to observe the trends of change in basic line environmental quality.

11. Conclusions
The present study reveals that liquid waste, domestic waste water from general activities are the main
adverse impact to be associated during operation phase of the plant. An analysis of the waste water
has been shown, which would create harm to the natural water body. So, there has given a Reuse
suggestion of the liquid waste for this plant, which will reduce the water consumption. Substantial
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amount of solid waste are generator from very nature of the project. These solid wastes, after
collection disposed of in safe place. The other adverse impact is the disaster management. On the other
hand, the plant has a positive impact in terms of employment during its operation phase. So, the
selected location is acceptable for the factory. On the other hand, the plant has a positive impact in
terms of employment and earning of foreign currencies in the operation phase.
However, any beneficial impacts on the nation as well as human beings would only be meaningful and
sustainable development would only be possible if the adverse effects are minimized through strict
maintenance and control measures as mentioned for this project. All this would need vigilant care and
cost money, and the project authority should take these into consideration.
Finally, it can be concluding that no Follow up Study would be required for the project.

Annexure-1

Russel Garments Ltd –U-01

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Annexure-2

Russel Garments Ltd.-U-01

40