Performance and progress analysis

of
Environmental Management System(EMS) practices
with respect to
Workplace Safety Standard and Management in Bangladesh

This report is submitted for the partial fulfillment of the degree of Masters in
Environmental Sciences and Management under Weekend program in the
Department of Environmental Sciences

Jishan Mahmud Rumi

Std. ID 170109, Reg. No. WMES 00009
Admission Semester: September 2017

J an ua ry 20 19
Department of Environmental Sciences
Jahangirnagar University
 Performance and progress analysis
of
Environmental Management System(EMS) practices
with respect to
Workplace Safety Standard and Management in Bangladesh

This report is submitted for the partial fulfillment of the degree of Masters in
Environmental Sciences and Management under Weekend program in the
Department of Environmental Sciences

Jishan Mahmud Rumi

Std. ID 170109, Reg. No. WMES 00009
Admission Semester: September 2017

J an ua ry 20 19
Department of Environmental Sciences
Jahangirnagar University
The Thesis Report titled “Performance and progress analysis of Environmental Management
System(EMS) practices with respect to Workplace Safety Standard and Management in
Bangladesh” submitted by Jishan Mahmud Rumi, Roll No: 170109, Registration No: WMES
00009, Session September 2017, under supervision of Dr. A H M Saadat (Professor, Dept. of
Environmental Science, JU) in partial fulfillment of the requirement for the degree of Master of
Science in Environmental Science and Management.

i
 Certificate

This thesis/report has been compiled according to the regulation of the Masters in
Environmental Sciences and Management under Weekend Program in the Department of
Environmental Sciences, Jahangirnagar University and approved in its style and content.

Professor Dr. A H M Saadat Jishan Mahmud Rumi

Supervisor Student ID: 170109

Professor Dr. A H M Saadat

Coordinator
WMES Program

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 ACKNOWLEDGEMENT

The author wishes to express his deepest gratitude to Dr. A H M Saadat, Professor, Department of
Environmental Science, Jahangirnagar University for his continuous support and guidance during
the course of this thesis work starting from development of the thesis proposal to writing this thesis.
His careful reading of the draft thesis, valuable comments, criticism and constructive suggestions
greatly contributed to the improvement of the thesis.

The author expresses his profound gratitude to Prof. Dr. Mohammad Amir Hossain Bhuiyan, for
his valuable advice and kind cooperation. The author is also grateful to the professional students
of WMES program for helping in a great way to conduct the survey.

The author wishes to thank all the officers of relevant industries in Bangladesh who had provided
with the valuable data of their industries and spared their valuable time during the interview. The
author also expresses his thanks to the management of the industries who had let their officers to
provide with the data needed for this research work.

The author also expresses his sincere thanks and indebtedness to Md. Zahanggir Alam, Zakir
Hossain, Abdullah Al Mahmud & Najmul Huda Mohd. Sharif Uddin for their valuable interview
and for sharing their experiences about EM practices & auditing scenario in Bangladesh.

The author is grateful to his family members, colleagues and friends for their cooperation and
companionship extended to him during this study.

The author also conveys his sincere thanks to all support staffs of Environmental Science
Department, JU for their services and support during the course of this thesis work.

iii
 ABSTRACT

The main objective of the study was to analyze performance analysis of environmental
management system practices in different industries of Bangladesh. The study also investigated
the current environmental management initiatives taken by different industries in Bangladesh and
their motivation for adopting the system as well as their level of compliance with the local
environmental legislation. To achieve these objectives a questionnaire survey was carried out.

Secondly the study also conducted a comparative analysis with Environmental Management &
Occupational Health & Safety management considering significant improvement of workplace
safety in RMG sector; after the miserable incident of RANA Plaza & Tazrin Fashion.

Conceptual framework was developed by the common perception of the implementation of EMS
in Bangladesh at the outset of the research to frame the study and find suitable literature as well as
to design the questionnaire. The questionnaire was primarily developed from the conceptual
framework and from the review of the relevant literature. A convenient purposive sampling
method was employed to collect data from industries located mainly in industrially populated areas
like Dhaka, Chittagong, Gazipur, Savar, Cumilla, Mymensing and Narayanganj and popular in
their respective field. From the study it was found that major drivers of implementing EMS &
several environmental initiatives, in the industries of Bangladesh were international acceptance,
compliance to local environmental legislation, international trading, pressure from the customers,
production cost reduction and company’s policy for environmental safeguard. But the performance
is not adequate and still remained in awareness level at maximum industries. The major barriers
identified from the study were top management’s commitment, complexity in the process of EMS,
lack of government incentives and awareness, lack of education and training, high investment and
maintenance cost, ignorance of government regulations and socio-economic culture. Results also
shows that most of the manufacturing industries have significantly improved the workplace safety
& social compliance standards compared to EMS due to international & national pressure. Though
the developed some form of EMS like waste management, pollution control and energy
conservation in their operations. From this study it was realized that manufacturers are still
reluctant to implement EMS in the industries.

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Dedicated to my Wife
&
Beloved Son Aunnoy

v
 Table of Contents

Certificate ii
Acknowledgement iii
Abstract iv
Table of Contents vi

Chapter 01: 1
1.1 Introduction 2
1.2 Background of Studies 4
1.3 Environmental Management 7
1.4 Occupational Health & Safety 9

Chapter 02: Literature Review 15

2.1 Introduction 16
2.2 Laws, Rules and Regulations: Bangladesh Perspectives 16
2.3 The Environmental Clearance Procedures in Bangladesh 20
2.4 Bangladesh Environment Quality Standard (BEQS) 21
2.5 Environmental Management System 26
2.6 The ISO 14000 Series 37
2.7 EMAS 44
2.8 British Standard BS 8555 45
2.9 Criteria of suitable EMS 46
2.10 Occupational Health & Safety 48
2.11 Workplace safety in RMG industries: Aftermath of Rana Plaza 56

Chapter 03: Methodology 64

3.1 Introduction 65

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Chapter 04: Result & Discussion 71
4.1 Introduction 72
4.2 Performance analysis of EMS 74
4.3 Findings & Comments: 79

Chapter 05: Conclusion 80

5.1 Conclusion 81
5.2 Suggestions for Future Studies 81

List of Reference: 82
Annexure 84

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Chapter 1

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1.1 Introduction:

The market-based economy of Bangladesh is the 42nd largest in the world in nominal terms, and
31st largest by purchasing power parity; it is classified among the Next Eleven emerging market
middle income economies and a Frontier market. According to the IMF, Bangladesh's economy is
the second fastest growing major economy of 2016, with a rate of 7.1%.

In the decade since 2004, Bangladesh averaged a GDP growth of 6.5%, that has been largely driven
by its exports of readymade garments, remittances and the domestic agricultural sector. The
country has pursued export-oriented industrialization, with its key export sectors include textiles,
shipbuilding, fish and seafood, jute and leather goods. It has also developed self-sufficient
industries in pharmaceuticals, steel and food processing. Bangladesh's telecommunication industry
has witnessed rapid growth over the years, receiving high investment from foreign companies.
Bangladesh also has substantial reserves of natural gas and is Asia's seventh largest gas producer.
Offshore exploration activities are increasing in its maritime territory in the Bay of Bengal. It also
has large deposits of limestone. The government promotes the Digital Bangladesh scheme as part
of its efforts to develop the country's growing information technology sector.

With the rapid growth of economy sequentially environmental performance of the industries are
no longer ignorable rather became one of the greatest concern for present and future days.
According to World bank only urban pollution costs around $6.5 billion a year which is about
3.4% of the GDP of 2015.

1.1.1 Objectives of the Study

The main objective of the study is to investigate performance of implementing EMS in industries
of Bangladesh. This study also investigates the current environmental management initiatives
taken by industries in Bangladesh and their motivation for adopting the system. The specific
objectives of the study are to find out:

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 i) Performance of EMS practices in different industry

ii) Progress analysis of EMS CAP’s compared to workplace safety initiatives.

iii) to find the drivers & barriers of implementing EMS.

1.1.2 Scope of the Study

This study focuses on the industries all over Bangladesh. A Convenient sampling method was
employed to collect data from industries for this purpose and industries, irrespective of location,
interviewed were medium to large industries as defined in industrial policy of Bangladesh.

1.1.3 Outline of the Study

The study is divided into five chapters. The first chapter is the introductory chapter and describes
the background of the studies which includes overview of major industries, background for
adopting EM, OHSM, & workplace safety practices in industrial operations, impact of industrial
environmental problems in Bangladesh; the objectives and scope of the study.

Second chapter illustrates about study related laws, rules and regulations of Bangladesh; reviews
literature on environmental management system (EMS) and the ISO 1400 series; history and
development of ISO 14001; benefits and problems of ISO 14001; ISO 14001 and other EM
practices in Bangladesh. It also includes workplace safety initiatives.

Chapter three develops methodology, conceptual framework of EMS implementation in

Bangladesh to construct questionnaire; includes sampling method, justification and limitation of
the study.

Chapter four discusses about the results and findings of the study as well as compares the results
with existing literature and practices.

Last chapter of this study concludes about the results and suggests some recommendations for
further study.

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1.2 Background of Studies

1.2.1 Overview of Major industries in Bangladesh

Bangladesh is a developing country in the world. The economic development is largely dependent
on the industrial advancement of a country. Industrializations have a great contribution to
minimize the unemployment problem in this country and can raise social productivity by
producing goods on a mass scale. The gross economy of is increasing with the industrialization in
Bangladesh. It proves that industries have a great contribution on the country economy. No country
in the world is self-sufficient in the production of all types of goods and services. Every country
has to import to meet the demand of its own. Bangladesh is no exception to that. Bangladesh has
production deficit in necessary equipment’s, medicine, vehicles and imported these from foreign
countries. At the same time, Bangladesh is producing garments, pharmaceuticals, cements and
many other goods excessively after meeting her demand. So it is understood that Bangladesh can
meet its deficit by importing goods and can export her excess produced goods after meeting up
own demand. Poor countries like Bangladesh can earn valuable foreign exchange by exporting
manufactured products and the foreign exchange can be used to invest in newer machines and
technologies so that a rapid growth of industry becomes possible. Bangladesh is the 54th largest
importer and 55th largest export economy in the world as reported in 2015. During the last five
years the imports and exports of Bangladesh have increased at an annualized rate of 8.7% and
11.9% respectively.

Instead of being a developing country, almost one third of her population is under extreme poverty.
Bangladesh has one of the largest populations in the world with over 162 million inhabitants (as
of 2016). Due to Bangladesh’s relatively small land mass, its population density is also one of the
highest in the world; with more than 1,200 inhabitants per square km. There is different type of
industries in Bangladesh, although the productivity growth that comes from industrialization
depends on the growth of high-value-adding modern industries, most of the firms in the industrial
sector in Bangladesh are small-scale or traditional cottage industries. They are often firms in the
informal sector, which means that these firms are too small to come under the regulatory structures
of the state. Because of the development in RMG sector and microcredit, GDP growth rated are

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above 5 percent in the last decade. Bangladesh has a growing economy, having maintained a steady
GDP growth averaging above 6 percent since 2010. As in most growing economies, contribution
of the Agriculture sector to GDP has been on a steady decline, with Services making up most of
GDP, followed by the Industries sector. Bangladesh operates a thriving textile and clothing export
industry and is one of the world’s largest garment exporters. Garments account for almost 80
percent of its total exports. Large-scale industries are also likely to enjoy faster productivity growth
compared to small-scale and cottage industries. Productivity is a measure of the output produced
in that industry and productivity growth measures the rate of growth chemicals import and use.
There are various types of industries in Bangladesh. The average growth rate of industries is on
average 610%. Chemical and pharmaceutical, power, food and allied industries have major share
in numbers as shown in Fig.1.

Figure 1.1: Percentage of Sector Wise Industries in Bangladesh

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1.2.2 Status of Industrial Growth

Since its independence in 1971, Bangladesh has achieved a tremendous growth rate in its
industrial production. The economy comprises of a number of Small and Medium Enterprises that
make up for 25% of the nation’s Gross Domestic Product (GDP). Three products like garments,
pharmaceuticals and textiles constitute 65% of manufacturing growth. In the 1960s and 1970s, it
was widely believed by international economists that the state had to play a direct role in industrial
development. The reconstruction and rehabilitation cost of the damaged industrial units after
liberation war was estimated at Taka 291 million, of which Tk. 223 million was estimated for the
public-sector industries. The journey of the nationalized industrial sector began in 1972 with 72
jute mills, 44 textile mills, 15 sugar mills, 1 still mill, a diesel engine unit and a shipbuilding
industry. However, all these industries turned into loosing concerns very soon due to mainly
mismanagement and secret removal of wealth and capital. The development of new industries like
sulfuric acid, chemicals, paper, caustic soda, glass, fertilizer, ceramic utensils, cement, still and
engineering was slow before 1985.New industrial ventures set up in the 1980s in Bangladesh have
been playing a significant role in the country’s economy. These include, shipbuilding industry,
motor vehicle assembling plant, oil refinery, insulator and medical equipment manufacturing
factories, telephone and telecom accessories making units, televisions assembling factories,
cigarette factory and vegetable oil industries. Readymade garment sector achieved a remarkable
progress in the country during the period. Policy comprising national development plan and open
market economy have been followed by the government, resulting in significant industrial growth
in the 1990s. Since then the industrial growth is remarkable except some obstacle in few years.
The clear picture of the industrial growth form financial year 1998 to 2016 is shown in Fig. 1.2

Figure 1.2: Industrial growth rate of Bangladesh

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Major Industrial Sector in Bangladesh

 Garments Industry
 Chemical Industry
 Pharmaceutical Industry
 Tannery Industry
 Cement Industry
 Food industry
 Fertilizer industry

One of major concern of the growth of industrialization is environmental pollution load from each
industrial sector which greatly affects the environment as well as public health. For example, only
tannery sectors produce approximately 20,000 m3 of liquid waste per day and 780000 ton of solid
waste. With the growth of the industries, the total pollution load is also increased. Therefore, it is
high time to introduce regulatory standard and the proper waste management & control technology
for each sector. Department of Environment should play the central role to monitor and control
pollution index of each sector. There are deficiencies in regulation and standard formulation and
its implementation.

1.3 Environmental Management

Environmental issues can no longer be ignored by the manufacturing industries. Companies are
facing increasingly stringent legislative controls and rising utility and raw material costs. Efficient
and effective use of raw materials and improved process operations are vital if companies are to
survive in competitive market. Pressure is also being exerted by suppliers and customers for
companies to reduce their negative environmental impact. All these factors mean that
environmental issues should be an essential part of business plan.
Setting up an environmental management system (EMS) will provide a company with a framework
through which its environmental performance can be controlled and improved. One can either
develop its own EMS or follow the guidelines laid down in an international standard or local
standard set up by the government. An EMS can help one to identify opportunities to reduce
operating costs through reduced waste generation and reduced use of water and other utilities.

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According to Khanna and Anton (2002) EMS represents an organizational change within firms
and a self-motivated effort at internalizing environmental externalities by adopting management
practices that integrate environment and production decisions, which identify opportunities for
pollution reduction and enable the firm to make continuous improvements in production methods
and environmental performance.
Standards for environmental management systems have been developed and evolving for several
years (Brorson and Larsson, 1999). The British Standards Institution (BSI) introduced the first
standard for environmental management in 1992 (BS 7750). The International Organization for
Standardization (ISO) introduced the ISO 14000 series in September 1996 and it specifies the
requirements for an EMS (Clements, 1996, Brorson and Larsson, 1999). Clement (1996) notes
that, the standard applies to those environmental aspects over which the firm either has control or
could be expected to have an influence on. Aboulnaga (1998) pointed out that, the adoption and
use of an EMS can be a source of competitive advantage to industries and organizations wishing
to compete on the international stage. Roy and Vezina (2001) also show that environmental
initiatives can be used to enhance a firm’s innovative capability. Sheldon (1997) also shows that
ISO 14001 has been heartily welcomed by people in government, business and academia. It is
believed globally that the standard is useful and one that augurs well for the future of
environmental management (Moxen and Strachan, 2000). Other proponents of ISO 14001 like
Stapleton et al (2001) argued that the standard could act as a framework for
significantly improving organizational performance. By adopting and being certified, a company
can improve its market share and reduce expenses related to environmental taxes, energy, waste,
water usage, emissions and fines. After its independence in 1971 from Pakistan, Bangladesh
embarked on massive industrialization. Establishment of Industries is being encouraged for rapid
economic development of the country. Most of these factories are located in the urban areas like
Dhaka, Narayanganj, Narshingdi and Chittagong (BBS, 2010). At present a number of
environmental problems have been reported and attributed to industrial establishments in
Bangladesh. According to a World Bank study, the four major rivers near Dhaka- Shitalakhya,
Balu, Turag and the Burignanga – receive more than1.5 million cubic metres
of wastewater every day, from the surrounding industrial units. The report suggests that the
improper treatment of the wastewaters by a number of factories, result in the discharge of highly
toxic wastes that cause serious damage to the ecology and aquatic life. More than 30 to 40 lacs

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people suffer from the consequences of poor water quality in the river system caused by untreated
industrial waste. In January 2011, the concentration of dissolved oxygen (DO) of Buriganga was
found almost 0 mg/L which is much less than the minimum acceptable standard value (5 mg/L)
for the river (Banani Biswas and Takeshi Hamada 2013). Textiles, dyeing, tannery, printing,
washing and pharmaceuticals industries are main polluters. People are suffering from different
health problems. A qualitative assessment found that about 20 types of diseases appeared to be
highly correlated with industrial water pollution. It affirmed that these types of illness have been
increasing in the last ten years (Ahmed, 2012). Industrial environmental management has now
become a very important issue for the country. This concern has prompted manufacturing
industries of Bangladesh for using some form of EMS as an option to environmental management.

1.4 Occupational Health & Safety:

In many rapidly developing countries, industrialization bring a radical alteration with it in the lives
of the countries. But if industries are not well designed and appropriate safety measures are not
adequately adopted, serious adverse health consequences can ensue. For example, in country like
Bangladesh, agricultural profession as well as fishing or forestry can make people face substantial
risks due to their occupational and geographical setting. According to the ILO, it is estimated that
11.7 thousand workers suffer fatal accidents and a further 24.5 thousand die from work related
diseases across all sectors each year in Bangladesh whereas work related diseases result in
approximately over 2 million fatalities from over the 2.3 million fatalities that are caused
throughout the whole world annually. It was also observed that a further 8 million workers suffer
injuries at work–many of which will result in permanent disability. Although little research has
taken place in Bangladesh, it is internationally recognized that most of the occupational deaths and
injuries are entirely preventable, and could also be avoided if organization provide proper
environment with all kinds of safety facilities and employers and workers took simple initiatives
to reduce hazards and risks at the workplace.

Considering the statistical scenario, latest labor force survey of Bangladesh published in 2009
(Table 1), about 51 million people are in the occupational sector in Bangladesh, of whom 22.2
million are involved in agriculture, forestry and fisheries sector, 7.8 million in trade, hotel and

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restaurant service occupations, about 7 million in manufacturing, 2 million in construction sector,
and about 4.2 million people are involved in transport, storage and communication sector (Figures
1.3) But the alarming news is most of these employees operate under poor working conditions and
also quite terrifyingly, in absence of occupational health and safety standards.

Table 1.1: Bangladesh labor force characteristics, 2009.

Figure 1.3: Employment distribution in Bangladesh by major industries (Bangladesh Labor

Force Characteristics, 2009).

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Figure 1.4: Status of employment in Bangladesh (Bangladesh Labor Force Characteristics,
2009).

A study conducted in Bangladesh revealed that about 79.52% of the injured (by occupational
injuries) workers were in between 40–59 age group and about 73.26% of the accidents that caused
injury to hands, feet, torso, arms and eyes result in different forms of disability. It was also
observed from a study conducted by Mohammad Muhsin Aziz Khan, Zaheed Ibne Halim and
Mohammad Iqbal which was published in the International Journal of Occupational Safety and
Ergonomics (JOSE) that of all the respondents suffered from occupational hazards, 75.24% of total
injured workers faced hand, feet, arm, eye, face and head injury, among which 27.72, 18.81, 7.92
and 5.94% of the total injury occurred in hands, feet, eyes and head respectively and the rest
(24.76%) of the injured workers suffered injury in other parts of the body. However, that type of
injury pattern was seen due to the ignorance of workers for not using precautionary measures such
as gloves, helmets, eye shields, etc., during their working hours. The illustrates the number and
percentages of the risk susceptibility of the different organs of the workers obtained from the below
mentioned study (Figure 1.5).

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 Figure 1.5: Susceptibility of various body parts to occupational injuries

The real scenario of occupational health hazard in Bangladesh can be inferred if the regular media
reports concerning workplace accidents and injuries are taken into account. A media scan report
of 2007 showed that almost half of all worker deaths took place in the construction sector, with
164 separate incidents which ultimately results in a combined total of 222 deaths, whereas in
Thailand which is another developing country there were 189,621 cases of occupational injuries
in 2001. It is also observed that in spite of being one of the most developed countries, a preliminary
total of 4,405 fatal work injuries was also recorded in the United States in 2013 [16]. Therefore,
Bangladesh is not only the hazardous prey of occupational health injuries but it has been estimated
that at least, in the developed world, they have taken drastic measures to discard the fatalities
caused lower than the revised count of 4,628 fatal work injuries in 2012. On the contrary statistics
from the Bangladesh Occupational Safety, Health and Environment Foundation (OSHE) revealed
that 1,310 workers were killed and 899 others were injured during the first six months of 2010 and
some 622 workers were killed and 395 others injured in various work related incidents across the
country in the first six months of 2011 which are much higher than the number of fatalities caused
in the previous year’s. List of casualties caused from occupational incidents in the year 2012 and
2013 in Bangladesh is mentioned in the (Table 1.2).

Since 1985, expert committee, clinical and epidemiological research teams have provided a great
deal of new evidences on the relationship of work to diseases. The attribution by work varies
widely depending on diseases and type of work, as well as on local working conditions and health
conditions of the community. A substantial part of work-related morbidity has been associated
with common non-communicable and communicable diseases prevalent among populations, such

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as cardiovascular disorders, respiratory disorders and musculoskeletal disorders. It is observed that
adults as well as children working in hazardous jobs are subjected more to acute or chronic physical
illness, and this number of population is not at all insignificant. The National Child Labour Survey
(NCLS) 2002-2003 conducted in Bangladesh found that about 7.9 million children who are
working are between the ages of 5 and 17 and 8 percent of these children are hurt or become sick
due to work. These child workers were often found to work long hours in a variety of hazardous
occupations and sectors that have the potential to seriously damage their health (e.g., in bidi
factories, manufacturing, construction, tanneries, and the seafood and garments industries). Even
in the developed countries like USA it has been found that younger workers who are in between
15 to 24 age group represent 14% labor force. This labor force face high risk for injury when on
the job during the period 1998- 2007 but there is a moderate decline in the number of fatalities by
year unlike Bangladesh. The following illustrates the percentages of various illness related to
different employment sectors (Table 1.3)

24th November,2012: A fire at Tazreen Fashions at Ashulia kills 112 workers

26th January 2013: Fire at Smart Exports Garments killed 7 worker
24th April,2013:Rana Plaza Collapse, Death of 1135 victims who used to work at RMG factory
on the building
6th October,2013: Fire at Aswad Composite Mills, death of 7 worker

Table 1.2: List of incidents and casualties in Bangladesh in the year 2012 and 2013

Table 1.3: Percentages of health conditions by sectors of employment (NCLS data

2002).

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Workplace safety in RMG industries: Aftermath of Rana Plaza:

After the collapse of Rana Plaza which claimed the lives of 1,138 mostly garment workers and left
thousands more injured, the global outcry for improved worker safety in the ready-made garment
(RMG) industry of Bangladesh caused by global public interest, media attention and harrowing
stories of workers has led to the emergence of various international and national initiatives to
address the issue. Three of these initiatives are the Accord on Fire and Building Safety in
Bangladesh (the Accord), the Alliance for Bangladesh Worker Safety (the Alliance) and the
National Tripartite Plan of Action on Fire Safety and Structural Integrity in the Garment Sector of
Bangladesh (the National Initiative).

Although on the surface, these initiatives appear to be quite similar and have the primary objective
of improving worker safety in the RMG sector of Bangladesh through inspections and
identification of fire, structural and electrical remediation’s for garment factories, they show
considerable differences when looked more carefully. These differences influence the outcomes
of the three initiatives on factory remediation for fire, structural and electrical safety in the RMG
sector in Bangladesh. In this blog, after a brief description of each initiative (for a broader
description, see here), I will discuss the effectiveness of the remediation processes introduced by
the Accord, the Alliance and the National Tripartite Plan.

The remediation initiatives in the Bangladeshi RMG sector

 The Bangladesh Accord on Fire and Building Safety in Bangladesh

 Alliance for Bangladesh Worker Safety
 The National Initiative

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Chapter 2

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Literature Review

2.1 Introduction

A very important element in understanding environmental management is to understand what the

environment is (Hewitt and Gary, 1998). ISO defined the environment as “the surroundings in
which an organization operates, including air, water, land, natural resources, flora, fauna, humans
and their interrelation” (ISO, 1996). Environmental Management (EM) can be said to mean
different thing to different people, however Hewitt and Gary (1998) defined it as “management of
an organization’s or company’s impact on the environment”. Therefore, EM is ‘the process of
reducing the environmental impact of an organization or people’s activities through the control of
all aspects of their operation that can cause or lead to an impact on the environment.

Industrial environmental management has now become a very important issue for the country.
This concern has prompted manufacturing industries for using some form of Environmental
Management System (EMS) as an option to environmental management. The present trend in
industrial environmental management is towards prevention rather than the control of pollution.
Bangladesh has put in place some comprehensive legislation and regulations on environmental
protection as well as some form of supporting institutional infrastructure. The next section of this
chapter illustrates about study related laws, rules and regulations of Bangladesh and the following
deals with EMS in general and ISO 14001 particular.

2.2 Laws, Rules and Regulations: Bangladesh Perspectives

Bangladesh has established certain policies, acts and rules for the betterment of its industrial
development, environmental safeguard and best utilization of resources and worker’s occupational
safety as well as to increase productivities of the industries. Among these some important policies,
rules and regulations are discussed in the following sections.

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2.2.1 Environmental Policy (1992)

Bangladesh National Environmental Policy of 1992 sets out the basic framework for
environmental action, together with a set of broad sectoral action guidelines. The Environmental
Policy provides the broader framework of sustainable development in the country. It also states
that all major establishments including setting up of an industrial establishment, which will have
a bearing on the environment, must undertake an IEE / EIA before they initiate the project. The
Environmental Policy delineates the Department of Environment (DoE), as the approving agency
for all such IEE / EIA's to be undertaken in the country. Policies of fifteen sectors are described in
the Policy.

2.2.2 Industrial Policy (1999)

The National Industrial Policy, 1999 aims to ensure a high rate of investment by the public and
private sectors, a strong productive sector, direct foreign investment, development of labour
intensive industries, introduction of new appropriate technology, women's participation,
development of small and cottage industries, entrepreneurship development, high growth of
export, infrastructure development and environmentally sound industrial development.

WTO guidelines have been proposed to be followed in the Industrial Policy. Following the
guidelines may result in conflicts with intellectual property rights. Guidelines for mitigating such
possible conflicts are absent in the policy document. No specific guidelines are given for
sustainable extraction and utilization of raw materials for different industries.

2.2.3 Industrial policy (2010)

This new policy seeks to make the industrial sector environment-friendly since environmental
pollution control remains still a challenge in manufacturing industries particularly for effluent
treatment and its effects on public health. It lays strong emphasis on the protection of the
environment and directs manufacturing enterprises to control environmental pollution by setting
up effluent treatment plants (ETPs) and strictly comply with environment-related laws and
regulations. Government will take necessary measures for effective enforcement for proper
running of ETP in the industries and ensure that the industrialization process is environment-
friendly and conforms to specific WTO agreements and standards.

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2.2.4 National Conservation Strategy (NCS), 1992

National Conservation Strategy (NCS) was drafted in late 1991 and submitted to the Government
in early 1992. This was approved in principle. Major relevant recommendations are:

• To use minimum possible area of land in exploration sites:

• Rehabilitate site when abandoned;

• Technology assessment for selection of appropriate technology; and

• To take precautionary measures against environmental pollution from liquid effluent,

condensate recovery and dehydration plants.

2.2.5 National Environmental Management Action Plan (NEMAP), 1995

The National Environmental Management Action Plan (NEMAP) is a wide ranging and
multifaceted plan which builds on and extends the statements set out in the National Environmental
Policy (1992). NEMAP was developed to address environmental issues and management
requirements for a period from 1995 to 2005 and set out the framework within which the
recommendations of the National Conservation Strategy (NCS) are to be implemented. NEMAP
has the broad objectives of:

• Identification of key environmental issues affecting Bangladesh.

• Identification of actions necessary to halt or reduce the rate of environmental degradation.

• Improvement of the natural and built environment.

• Conservation of habitats and bio-diversity.

• Promotion of sustainable development; and

• Improvement in the quality of life of the people.

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2.2.6 The Bangladesh Environmental Conservation Act (ECA), 1995 (Amended in
2000, 2002 & 2010)

The Bangladesh Environment Conservation Act of 1995 (ECA '95) is currently the main legislation
in relation to environment protection in Bangladesh. This Act is promulgated for environmental
conservation, environmental standards development and environmental pollution control and
abatement. It has repealed the Environmental Pollution Control Ordinance of 1977. The main
objectives of Environmental Conservation Act of 1995 are:

 Conservation and improvement of the environment; and

 Control and mitigation of pollution of the environment.

The main strategies of Environmental Conservation Act of 1995 can be summarized as:

 Declaration of ecologically critical areas and restriction on the operations and processes,
which can or cannot be carried/initiated in the ecologically critical areas;
 Regulations in respect of vehicles emitting smoke harmful for the environment;
 Regulation of the industries and other development activities' discharge permits;
 Promulgation of standards for quality of air, water and soil for different areas;
 Promulgation of a standard limit for discharging and emitting waste;
 Formulation and declaration of environmental guidelines; and
 Environmental Clearance.

Bangladesh Environmental Conservation Act (Amendment 2000)

This amendment of the Act focuses on:

 Ascertaining responsibility for compensation in cases of damage to ecosystems,

 Increased provision of punitive measures both for fines and imprisonment and
 Fixing authority on cognizance of offences.

Bangladesh Environmental Conservation Act (Amendment 2002)

This amendment of the Act elaborates on:

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  Restriction on polluting automobiles,
 Restriction on the sale and production of items harmful to environment,
 Assistance from law enforcement agencies for environmental actions,
 Break up of punitive measures; and
 Authority to try environmental cases.

Bangladesh Environmental Conservation Act (Amendment 2010)

This amendment of the Act focuses on:

 Demarcation of wetlands and water bodies,

 Restriction on hazardous waste import, transportation, storage etc.,
 Prevention of cutting of hills, mountains; and
 Declaration of Ecologically Critical Areas.

2.2.7 The Environmental Conservation Rules (ECR), 1997

These are the first set of rules, promulgated under the Environmental Conservation Act of 1995
(so far there have been four amendments to this set of rules - February and August 2002, April
2003 and 2010). The Environmental Conservation Rules of 1997 has provided categorization of
industries and projects and identified types of environmental assessments needed against
respective categories of industries or projects.

Among other things, these rules set (i) the National Environmental Quality Standards for ambient
air, various types of water, industrial effluent, emission, noise, vehicular exhaust etc., (ii) the
requirement for and procedures to obtain environmental clearance, and (iii) the requirement for
IEE / EIA's according to categories of industrial and other development interventions.

2.3 The Environmental Clearance Procedures in Bangladesh

The environmental clearance process in Bangladesh has three main tiers:

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  Screening: Screening decides whether the EIA process should be applied to a development
project. It also helps to determine the type for which whether an IEE would be sufficient
or a detailed EIA should be resorted to.
 Initial Environmental Examination (IEE): The IEE helps to understand the potential extent
of environmental changes and the ways to mitigate them, as well as past experiences or
standard operating practices.
 Detailed EIA: The EIA procedure carries out a detailed examination of impacts by
conducting relevant surveys and monitoring studies, applying impact prediction tools and
ensuring the effectiveness of mitigation and enhancement measures.

2.4 Bangladesh Environment Quality Standard (BEQS)

The ECR’97 determines the environmental standards for air and effluents to which an industry has
to adhere. The standards for ambient air, wastewater, stack emissions, ambient noise and odour
are illustrated in table 2.1, table 2.2, table 2.3, table 2.4 and table 2.5 respectively. These standards
are applicable for all types of industrial or development activities.

Table 2.1: Bangladesh Standards for Ambient Air

Source: Schedule 2, Environment Conservation Rules, 1997 Bangladesh (amended, July 2005)

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Notes:

 Not to be exceeded more than once per year (a)

 The objective is attained when the annual arithmetic mean is less than or equal to 50 μg/m3
(b).
 The objective is attained when the expected number of days per calendar year with a 24-
hour average of 150 μg/m3 is equal to or less than 1 (c)
 The objective is attained when the expected number of days per calendar year with the
maximum hourly average of 0.12 ppm is equal to or less than 1 (d).
 PM10=Particulate matter with a diameter of not more than 10 microns.
 PM2.5= Particulate matter with a diameter of not more than 2.5 microns.
 μg/m3 =Micrograms per cubic meter. ppm= Parts per million.

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Table 2.2: Bangladesh Standards for Wastewater from Industrial Units or Project Wastes

Source: Schedule 10, Environment Conservation Rules, 1997 Bangladesh

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Notes:

 Inland surface water means drains/ponds/tanks/water bodies/ ditches, canals, rivers,

springs and estuaries.
 Public sewerage system means treatment facilities of the first and second stage and also
the combined and complete treatment facilities.
 Irrigable land means such land area, which is sufficiently irrigated by wastewater taking
into consideration the quantity and quality of such water for cultivation of selected crops
on that land.
 Inland surface water standards shall apply to any discharge into a public sewerage system
or to a land, if the discharge does not meet the requirements.

Table 2.3: Bangladesh Standards for Stack Emission from Industrial Projects

Source: Schedule 11, Environment Conservation Rules, 1997

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Notes:
*Q = emission of SO2 (kg/hour);
DCDA - Double Conversion Double Absorption;
SCSA - Single Conversion Single Absorption

Table 2.4: Bangladesh Standard for Ambient Noise

Source: Schedule 4, Environmental Conservation Rules, 1997, Bangladesh
Notes:

 The time from 6 AM to 9 PM is counted as daytime.

 The time from 9 PM to 6 AM is counted as night-time.
 Area up to a radius of 100 meters around hospitals or educational institutions or special
institutions/establishments identified/to be identified by the government is designated as a
'silent zone', where the use of horns of vehicles or other audio signals and loudspeakers are
prohibited.

Table 2.5: Bangladesh Standard for Odour

Source: Schedule 8, Environmental Conservation Rules, 1997, Bangladesh

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Notes:

 The following regulatory limits shall be generally applicable to emission/exhaust outlet

pipes with a height of above 5 meters:
 Q = 0.108 x Het Cm (where Q = gas emission rate in Nm3/hr.)
 Het = Height of exhaust outlet pipe in meter
 Cm = above mentioned limit in ppm

In cases where a special parameter has been mentioned, the lower limit shall be applicable for
warning purposes and the upper limit shall be applicable for prosecution purposes or punitive
measures.

2.5 Environmental Management System

An Environmental Management System (EMS) is a set of processes and practices that enable an
organization to reduce its environmental impacts and increase its operating efficiency. It is a
framework that helps a company to achieve its environmental goals through consistent control of
its operations. The assumption is that this increased control will improve the environmental
performance of the company. The EMS itself does not dictate a level of environmental
performance that must be achieved. Each company's EMS is customized to the company's business
and goals.

The ISO 14001 standard defines EMS as “that part of the overall management system which
includes the organizational structure, planning activities, responsibilities, practices, procedures,
processes and resources for developing, implementing, achieving, reviewing and maintaining the
environmental policy” (ISO, 1996). It can be said that EMS is derived from the environmental
policy of an organization. A policy is a set of rules orprinciples that an individual or organization
adopts for a chosen course of action (Hewitt and Gary, 1998). It can be formal and documented.
Environmental policy, to these authors, is the “formal and documented set of principles and
intentions of an enterprise with respect to the environment”. It serves as the guiding document for
environmental improvement and adherence to it is very important to the integrity and success of
the EMS.

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An EMS helps a company to address its regulatory demands in a systematic and cost-effective
manner. This proactive approach can help to reduce the risk of noncompliance and improve health
and safety practices for employees and the public. It can also help to address non-regulated issues
such as energy conservation and can promote stronger operational control and employee
stewardship (US EPA). Basic elements of an EMS are:

 Reviewing the company's environmental goals.

 Analyzing its environmental impacts and legal requirements.
 Setting environmental objectives and targets to reduce environmental impacts and comply
with legal requirements.
 Establishing programs to meet these objectives and targets.
 Monitoring and measuring progress in achieving the objectives.
 Ensuring employees' environmental awareness and competence.
 Reviewing progress of the EMS and making improvements.

An EMS encourages a company to continuously improve its environmental performance. The

system follows a repeating cycle. The cycle can be represented by a simple diagram as shown in
Figure 2.1. The company first commits to an environmental policy, then uses its policy as a basis
for establishing a plan, which sets objectives and targets for improving environmental
performance. The next step is implementation. After that, the company evaluates its environmental
performance to see whether the objectives and targets are being met. If targets are not being met,
corrective action is taken. The results of this evaluation are then reviewed by top management to
see if the EMS is working. Management revisits the environmental policy and sets new targets in
a revised plan. The company then implements the revised plan. The cycle repeats and continuous
improvement occurs.

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 Figure 2.1: The continuous improvement cycle according to US EPA

2.5.1 Components of an EMS

EMS, according to ISO 14001 has four components. It is like a cycle of plan, do, check, and act.
If the cycle is adhered to constantly it leads to continuous improvement of the system. Figure 2.2
shows the EMS cycle according to ISO 14001 standard that gives an abstract description of the
different components. The design and implementation of an EMS requires a considerable time and
effort therefore requiring the commitment of management of the organization. Management needs
to communicate their support to the system and emphasize that “they aim to improve their
environmental performance”.

An inventory is then needed to access how the organization currently deals with environmental
issues. This is the initial review and it focuses on all elements of which an EMS consists in order
to see the activities that have been undertaken and the results. Some of the topics to be treated here
according to ISO 14001 include environmental impact, use of resources like raw materials, water
and energy, relevant regulations, organizational structures and culture, products and marketing,

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training and communications, instructions and handling of incidents. Deficiencies will emerge as
the system is used and the gaps that need to be filled will become clear.

The ‘Plan’ Phase

This stage is helpful in the formulation of an environmental policy. It serves the direction for future
action and communication of the organization’s environmental commitment and targets.
According to ISO (1996) environmental policy deals with: the nature, scale and environmental
impacts of the organization’s activities, products or services; a commitment to continual
improvement and pollution prevention; a commitment to comply with relevant environmental
legislation and regulations and other requirements to which the organization subscribes; provides
framework for setting and reviewing environmental objectives and targets; it is documented,
implemented and maintained; it is communicated to all employees and; it is available to the general
public

Environmental policy and planning starts with the assessment of the environmental aspects and
impacts of the organization’s activities, products and services (Kuhre, 1995). Aspects can be said
to be the ‘potential effects’, which can be good or bad. They become impacts when they manifest
themselves and lead to changes on the landscape. Aspects can be direct or indirect resulting
respectively from the firm’s activities or from those of supplies. The organization’s environmental
programme specifies how the objectives and targets will be met by stipulating the actions,
methods, responsibilities, time frames and resources. These should be fully integrated in and
coordinated with other areas of management and new structures can be identified if possible to
enable total environmental management.

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 Figure 2.2: EMS Cycle According to ISO 14001

The ‘Do’ Phase

An organizational chart is defined and laid down at this stage in order to embed the environmental
management in the organization. Individual roles and responsibilities are outlined in addition to
the allocation of resources like finance, personnel, skills and technology. The next step is the
identification of training needs to build environmental awareness and competence. This can be
done from current staff or new employees recruited. Communication, both internally and
externally is relevant for an EMS implementation since it helps keep people informed.
Communication is best if it is topdown and bottom-up. It directs attention to the fact that
environmental management involves more than a system with procedures, instructions,

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performance indicators, requirements and checks laid down in manuals, plans, schemes and reports
(ISO, 1996). Documentation is very important in any EMS since it points to implementation and
operation. Document control entails designation of someone to be responsible for revision and
change. Operations and activities must be controlled to ensure that policy addressing the most
significant environmental aspects is carried out.

The ‘Check’ Phase

This stage aims at checking how the firm performs in terms of environmental management and if
necessary, identify possibilities for improvement and take subsequent action to realize these
changes (ISO, 1996). Organizations' operations and activities with respect to significant
environmental impacts are to be monitored, their performances are measured and compared with
the objectives and targets and compliance with regulations is assessed.

The ‘Act’ Phase

Management review here aims at making sure that the EMS continues to produce the desired
effects as outlined in the policy. Apart from the information derived from audits, other internal
reports on performance and incidents, external reports on regulatory and environmental changes
and suggestions for improvement received from internal and external sources can play a role for
the organization to act upon. The process is then repeated again. The drivers or motivations to use
EMS are internal and external involving different forces.

2.5.2 Drivers of EMS

Globalization coupled with industrialization with increasing environmental degradation has

compelled a number of firms and organizations to adopt new strategies for sustainability. Business
has also come to realize the enormity of their actions on the environment. A number of pressures
are now being put on organizations from all corners of the globe. The drivers of EMS
implementation in industries and organizations can be grouped into five different actors. They
include; the organizations themselves, market, social forces including the public and community,
financial organizations and regulatory authorities.

Organizations

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Environmental issues have become increasingly important in organization’s activities since it acts
as insurance for its stakeholders both within and outside (Chan,1998). Surveys carried out by
Banerjee (1998) showed that most managers are in favour of nvironmental management albeit at
different levels. These rising awareness can be traced back to the 1972 Stockholm conference and
further by the Rio conference where environmental issues were brought to the forefront of the
world. Environmental issues and concerns have thus become very important issues in organization
dealings today. Organizations have come to realize the advantages they start to gain by adopting
EMS therefore initiating it within themselves. Some of the drivers within organizations include

management, staff, parent company and shareholders.

Market

The market these days, especially in developed countries is leading environmental stewardship
among firms as most consumers now demand environmental loyalty of the factory before they
purchase its products. Environmental friendly goods are being sought and they are willing to pay
more for that product. Industries that fail to heed such a call become uncompetitive, therefore
prompting them to adopt new strategies towards the environment. This case does not apply to
Bangladesh as the market is more preoccupied with cheaper goods than environment friendly ones.

Social forces/community

A community can demand the existence of a good EMS in an organization that they feel is a threat
to the environment and their existence. With increasing awareness on the environment these days,
society is a force to be reckoned with as far as the environment is a concern especially in the DCs.
The activities of environmental non-governmental organizations (ENGOs) are also becoming very
vocal and serve as a driver of EMS. In Bangladesh, local communities may demand environmental
stewardship but without appropriate ENGO or institutional backing, this will be a mirage. For
Example: In 1989, there was a major effort by certain quarters to get the government of Bangladesh
allow the import of waste from the USA under the guise of raw material for producing cheap
energy. When the process advanced considerably, a section of journalists, academics and NGOs
began to voice their concern about the possibility of allowing hazardous wastes to be imported.
This led to considerable agitation and media reporting backed by NGOs which eventually caused
the government to reconsider the matter. Permission was eventually not

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granted. This exercise is a useful example of NGOs, academics and media working together to
raise concerns about an environmental issue and having an impact. NGOs are working with the
government of Bangladesh in environmental management to ensure a safe and better environment
for the country. The Bangladesh government has devised policies to ensure the NGOs
accountability for environmental management (Ahmed, Z. 2011).

Financial

Financial institutions and insurance companies these days demand the existence of an effective
management system like EMS in order to acquire and get insurance. The existence of such a system
gives advantages to the company for being granted loan or insurance. Some international financial
institutions like the International Monetary Fund (IMF) and the World Bank (WB) are some of
such organizations. Green financing contributes to the transition to resource-efficient and low
carbon industries i.e., green industry and green economy in general. The banking sector can play
a significant role in protecting the environment by financing to high impact environmentally
sensitive sectors. Broad objective of green banking is to use resources with responsibility and
giving priority to environment and society. It is not just another Corporate Social Responsibility
(CSR) activity rather all out effort to keep this world liveable without much damage. To foster
green banking practices in the country, Bangladesh Bank (BB) formulated the Green Banking
Policy and strategy framework and Environmental Risk Management Guidelines in a consultative
manner. Many banks are now financing environmental friendly projects. BB has introduced a
refinance scheme worth about BDT 2 billion to refinance loans to effluent treatment plants (ETPs),
solar panels, bio-gas plants and in brick making industries (BB, 2012). People as well demand the
existence of such a system before they invest in such an enterprise. Financial law suits can also
compel them to adopt EMS in their operations.

Regulatory Institutions

Research has shown that environmental initiative by organizations is driven primarily by external
forces, such as regulatory pressures. Porter and van der Linde (1995b) argued that “government
regulations may serve in practice as a stimulus to both economic growth and cleaner production,
if they are used as a business asset to gain market advantages over competitors”. It has been
reviewed in other literature however that “neither positive nor negative effects of environmental
regulation on competitiveness were easily detectable” (Jaffe et al. 1995). Porter and van der Linde

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(1995b) concluded that firms seek to maximize ‘resource productivity’ in response to both
regulatory and market pressures. Environmental regulation has been a major factor leading firms
putting into effect EM (Kolk, 2000). According to him, some firms with less environmental risks
used to focus on compliance to regulations but as EM developed, firms started to move beyond
mere compliance.

2.5.3 Barriers of EMS

Motivations are important in promoting EMSs, but the barriers to implementation must be
acknowledged and addressed in order to minimise them. The adoption of an environmental
management system is a complicated procedure where difficulties can appear in the different
stages, acting as barriers for its implementation (Biondi et al.,2000). These can vary depending on
the characteristics of the organization, such as, size, business sector, and even country (Biondi et
al., 2000; Gerstenfeld and Roberts, 2000). The findings of the analysis carried out by Hillary
(1999), of the thirty-three separate studies that examined the implementation of formal EMSs in
industries showed that these barriers could be differentiated between internal and external as
follows:

Internal barriers

 Lack of resources: including, among others, lack of time, cost constraints and lack of
knowledge and specialists in environmental issues.
 Negative attitudes and company culture: for instance, inconsistent top management support
for EMS, or, a general resistance to change.
 Inadequate understanding and perception: such as, low awareness of EMSs, and, lack of
knowledge of certifiers’ systems, confusion between ISO 14001 and EMAS and their
interrelationship.
 Implementation problems: including, difficulty in dealing with environmental aspects such
as the evaluation and determination of impact significance, and, uncertainty about how to
maintain continual improvement. (Hillary, 1999)

External barriers

 Certifiers’ difficulties: such as, the degree of difficulty in obtaining the certification, and
the associated costs, or, the amount of documentation and bureaucracy required.
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  Economic aspects: including, for example, uncertainty of the value of an EMS in markets,
or insufficient benefits and drivers.
 Lack of support and guidance: for instance, lack of specific implementation tools and
examples, taking into account the different business sectors.
 Institutional weakness: for example, lack of promotion of EMSs, of financial support or of
a legislative framework. (Hillary, 1999)

Hillary (1999) found that internal barriers were more significant in impeding easy implementation
of EMSs in SMEs than the external ones. Among these internal difficulties, lack of human
resources and negative company culture were the most cited in the studies. Lack of human
resources rather than financial ones was the major barrier found, not only in the implementation
of an environmental management system, also in its maintenance, and it increased in importance
as the size of the company decreased (Hillary,1999). The second biggest internal difficulty was an
unfavorable company culture. It was the case that organizations that had had negative experiences
with one of the ISO 9000 standards showed a negative attitude to ISO 14001 (Hillary, 1999).

However, in the case of large companies, where more resources are available, external barriers
seem to be more important than the internal ones. Issues, such as, economic aspects, and, the
complexity of the procedure of obtaining the certification, due to the amount of paperwork
required, can play a significant role in the implementation of an environmental management
system, and also in the choice of its certifier (Sunderland,1996).

Another external barrier indicated by Hillary (1999), that can play an important role in the
implementation, is institutional weakness, for instance, lack of a legislative framework. Similar
conclusions to the ones achieved by Hillary (1999) were also found in the research programme
carried out by Biondi et al. (2000).

The main barrier found was, confirming Hillary’s (1999) findings, the indirect costs, such as, the
amount of time, or, the lack of human and technical resources. In general, the smaller the enterprise
was, the higher the probability that the organization could not implement the EMS by depending
only on internal expertise. In addition to this, the stages of the implementation where the SMEs
met the most significant problems were the initial environmental review and the definition of
objectives and programmes, in part, due to the difficulty of understanding, interpreting and

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applying the EMS standards, requiring sometimes a technical knowledge of environmental issues.
Difficulties were also found in defining the environmental policy and the programmes due to a
lack of environmental culture in the organization (Biondi et al., 2000), which was also pointed out
by Hillary (1999) as the second biggest barrier encountered by SMEs

The fact, which has been cited before, that the importance of the barriers increases as the size of
the company decreases has been indicated by other authors. For example, a review of studies
concerning UK SME’s that was carried out by Gerstenfeld and Roberts (2000) showed how the
lack of awareness of EMSs increased the smaller the organization was, with micro-sized
companies being the least aware. Furthermore, they pointed out lack of knowledge and expertise
as important constraints in the implementation of an EMS, as Hillary (1999) and Biondi et al.
(2000) previously concluded.

The difficulties of the maintenance of an environmental management system were indicated in the
analysis of a large aluminum smelting plant certified to ISO 14001 in South Carolina, USA, by
Rondinelli and Vastag (2000), who addressed the impacts of the standard three years after its
implementation. The main negative impact of maintaining the EMS was the increase of
administrative bureaucracy, followed by a lack of customer approval and recognition of the
standard (which had been some of the key motivations behind implementing it), and resulted in an
imperceptible competitive advantage. Furthermore, another complexity for the company was that
ISO 14001 did not ensure compliance as they had expected (Rondinelli and Vastag, 2000).

This imperceptible competitive advantage and therefore minimal market opportunities was also
indicated by Steger (2000), in his review of empirical studies on EMS, based on evidence from
European organizations that had implemented an environmental management system.

2.5.4 Approaches to Environmental Management System

Environmental policies/instruments currently in existence include; regulations, incentives,

disincentives, marketable permits, liabilities, training, information for firms, information for
customers, voluntary agreements and plans. These policies are mainly used in advanced countries.
These instruments proved effective in controlling pollution in developed countries but only few
policies such as direct regulation and economic measures are being used in Bangladesh.

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2.5.5 The Gap between EMS Theory and Practice

1. Though much has been written on EMS theory, there is inadequacy of documentation and
analysis of specific cases of EMS implementation (Kirkland and Thompson, 1998) for
adoption. This has placed developing countries at a disadvantage.
2. The practitioners of EMS just introduced the concept with no adequate dissemination of
those ideas to the general public.
3. The lack of communication of the ideas in EMS has a number of roots. One, the concept is
new; second, the lack of communication can also be attributed to competition between its
practitioners especially those in the developed countries, and lastly, the lack of leadership
on the issue (Kirkland and Thompson, 1998).
4. According to the Kirkland and Thompson (1998), the gap between EMS theory and
practice has been exacerbated by the dominance of a structural approach to EMS. EMS
work has focused on the identification and description of components and frameworks but
has not addressed how to put EMS elements together.
5. ISO 14000 provides a list of resources needed in an EMS including general directions for
the blending of these resources but fails to describe techniques that may be used to blend
the ingredients into a successful whole.
6. The provided information can be said to be good but further information is needed to
develop an effective EMS especially in Less Developed Countries (LDCs) like Bangladesh
where the practice is not known.
7. Commitment by organizations is a vital component of the system but this has not been
catered for in the ISO 14000 series (Kirkland and Thompson, 1998).
8. Some books attempted to guide readers through the process of developing EMS but these
are all done in line with developed countries standards and examples with little attention
being paid to that of the LDCs.

2.6 The ISO 14000 Series

ISO 14000 is a series of international standards for environmental management. It is the first such
series of standards that allows organizations all over the world to pursue environmental efforts and
measure performance according to internationally accepted criteria (Hewitt and Gary, 1998). It

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lays out tools and systems for the management of various environmental obligations and the
conduct of product evaluations, without prescribing the goals an organization must achieve (Cascio
et al, 1996). Table 2.6 shows the various elements in the series.

Table 2.6: The ISO 14000 Series

Source: Hewitt and Gary, 1998

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The series aims at providing guidance for developing a comprehensive approach to EM and for
standardizing key environmental tools of analysis such as labelling and life cycle analysis. ISO
14001 is the first in the 14000 series as shown in table 2.6. It is aimed at supplementing
environmental protection and the prevention of pollution in accordance with socio-economic
needs.

2.6.1 History and Development of ISO 14001

According to ISO (1996), the main purpose of the standard is to provide a systematic, documented,
consistent procedure that provides clear evidence of the relationship between organizations'
publicly stated environmental policy and the implementation of this policy in practice. The
standard specifies a continuous cyclical process consisting of five elements as shown in Figure
2.2.

A major antecedent that led ISO to develop standards can be traced to the British Standards
Institute (BSI) publication of the three part quality series-BS 5750. The success of this standard
led to the adoption of BS 7750, the first formal systematic and standardized approach to
environmental management (Hewitt and Gary, 1998). The BS 7750 was published in 1992 and it
was a voluntary management standard. Countries started to produce their own EMS. An initiative
began regionally within the EU and the EMAS was negotiated with industry, environmental groups
and other interested stakeholders within the environmental field. It was created for businesses
interested in voluntary certification to an EMS within the EU. The increase in national standards
on the environment compelled ISO to initiate moves on EM standards. ISO embarked on creating
standards that are not essentially technical or scientifically based neither limited to a specific
region. The success of ISO 9000 led to the development of other standards. It is generally believed
however that the ISO 14000 series emerged as a result of both the Uruguay round of the General
Agreement on Trade and Tariff (GATT) negotiations and the UN Rio Summit on the environment
held in 1992 (Hewitt and Gary, 1998).

2.6.2 ISO 14001 Developments throughout the World

There is mixed results with respect to ISO 14001 development throughout the world. ISO 14001
achieved success in Europe as a result of the development of other EMS like BS 7750 and EMAS.
These standards laid strong foundation for the take off of ISO 14001. In addition, government

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institutions through the EU promoted the diffusion of EMS in Europe, a phenomena lacking in
most developing countries of Africa and Latin America. The size of firms is the major contributor
to the development of an effective EMS here. Asia has large MNCs as compared to Africa and
Latin America. These large companies are pushing ISO 14001 down their supply chain. China is
the leading developing country with large certification to ISO 14001. Due to its large population
many

companies established here. These companies are subsidiaries with their parent companies in
Europe. To do business with these companies, one has to be certified to the standard. Brazil is also
following the same step as China in getting certified, however, this is not the case in other LDCs
as they are doing business on a small scale and are mainly import substitution industries.

Table 2.7: Top 10 countries for ISO 14001 certificates – 2010

Table 2.8: Top 10 countries for ISO 14001 growth – 2010

Source: The ISO Survey of ISO 9000 and ISO 14001 Certificates, 2011

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Bangladesh had only 2 Companies certified to ISO 14001 in 2001 and 3 ISO 14001Certified
Companies in 2003. Reliable source shows (BSTI, interview) that ISO certification in Bangladesh
has an increasing trend. As per ISO Survey presently number of ISO certified company is 354

2.6.3 Benefits of ISO 14001Certification

EMS certification is of the management system itself, not the environmental performance (Hewitt
and Gary, 1998). ISO 14001 EMS has been heartily welcomed by people in government, business
and academia (Sheldon, 1997). A company can develop EMS but may not certify it, however most
companies that develop EMS indeed certify it. Certification does not generate instant results
(Hewitt and Gary, 1998). Certification of ISO 14001 EMS has the following benefits:

1. ISO 14001certification gives an external ‘stamp’ of approval of the environmental

management system (EMS) of the organization and proves that the organization’s
commitment to improve environmental performance is valid. It also proves that industries'
activities have been evaluated and accepted by an accredited, independent third party.
2. After ISO 14001certification the greatest positive impact to the environment will be the
reduction of hazardous waste. This would lead to reduction, reuse or recycling, all of which
maximize natural resources. There is thus conservation of other natural resources in the
process. Hence, the level of compliance with the local environmental regulations would
improve.
3. The inspection agency will know that the certified organization cares for the environment
and has systems in place even before visiting the operation. This positive relation is
extremely valuable and would help foster a better working relationship
4. By adopting and being certified, organization can reduce expenses related to environmental
taxes, energy, waste, water usage, emissions and fines. It leads to long-term cost savings,
especially in the area of environmental control and cleanup of incidents. According to
Kuhre (1995) certification will not eliminate all cleanup cost. However, it would minimize
the number and size of future cleanups.
5. It leads to prevention of suffering and possible death of workers due to mishaps. The costs
associated with injuries will also be reduced.
6. It increases public awareness in case of protection of the environment. If an organization
improves its EM program, it would surely improve its community relations as well.

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 7. ISO14000 EMS procedures are proactive environmental actions. It could be communicated
to the public, since it is a positive venture. Thus their confidence in the organization will
be increased. It creates customer trust and satisfaction.
8. Organizations that obtain the certificate would be able to increase the market share of their
products since most customers especially of advanced industrialized countries are
environmentally conscious and would be in competitive position in the market because the
customers feel more secure that the environment is being catered for.
9. Companies certified to ISO 14001 have market access all over the world. It levels the
playing field of international trade bringing more competitors to the scene.
10. Investors these days also try to invest in environment friendly companies. Employment
would be created in the home country thereby reducing unemployment thus poverty.
11. Insurance companies these days find it easier transacting business with companies that
have effective EMS like ISO 14001 EMS as they view such a company as having limited
liability.
12. The standard also provides an effective means of technological development as well as its
transfer to other sectors of the industry or the organization.

2.6.4 Problems with ISO 14001 Certification

1. Adopting ISO 14001 might bring benefits and loss to any business activity. The standard
has been criticized by a number of companies (Yiridoe et al, 2003).
2. One of the major barriers to certification and development of an effective EMS is that,
companies become vulnerable to legal claims as they develop EMS.
3. The development of an EMS creates documentation on environmental performance and
these documents can become a basis for court action against an organization that does not
go according to its targets (Kolk, 2000). These litigation problems can create caution on
the development of an EMS. The good side however is that, the standard does not mention
reporting of environmental performance by companies.
4. Auditors may have access to information on performance and can leak such information
out.
5. Some MNCs claim that they have much more sophisticated system in place other than the
weak ISO 14001 as such there is no need to certify to ISO 14001 (Kolk, 2000).

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 6. The system has also been criticized for not focusing on internal control. It has been said
that it is deficient in giving guidelines on information needed for internal and external
purposes, the organization of the information system and how the system and its
information should be verified.
7. The criticism goes further that certification itself does not give guarantee that the
management system meets all requirements. For example, it fails to specify limits to energy
or resource consumption, emission levels and performance levels other than those of
national levels, which in LDCs like Bangladesh are low and not complied with due to weak
enforcement mechanisms.
8. The system, it is said does not aim at protecting the environment (Welford, 1998).
Certification therefore does not necessarily make a company environmentally perfect or
ensure company's constantly improving performance but rather depends on the people who
drive it.
9. Another criticism of the system is the high cost required to get certified. Not only the cost
but the attendant bureaucracy involved in its preparation and implementation is another
cause for a company not to get certification.
10. The yearly auditing of records also adds to the cost. A number of man hours are therefore
spent on the certificate.
11. These problems do not help the small and medium scale enterprises in developing countries
to get the certificate.

2.6.5 ISO 14001 and Environmental Management in Bangladesh

After its independence in 1971 from Pakistan, Bangladesh embarked on massive industrialization.
There was heavy tariff protection of local industries. Some measures such as trade policy reforms,
improvement in the tax system and reformation and incentives on foreign investment taken led to
an increase in the industrial performance of some industries. New enterprises were formed and
government has created some industrial zone and export processing zones to establish industries.
Establishment of Industries is being encouraged for rapid economic development of the country.
At present a number of environmental problems have been reported and attributed to industrial
establishment in the country. It is expected that the current environmental problems would increase

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unless due attention is given to industrial environmental management. Industrial environmental
management has now become a very important issue for the country. This concern has prompted
manufacturing industries for using some form of EMS as an option to environmental management
and getting it certified. The use of ISO 14001, a voluntary environmental management option is
being offered as a way for environmental management in the country based on its ingrain
properties of waste management, emission control, energy conservation and water management,
prevention of industrial disasters. Bangladesh needs not follow the path of the industrialized
countries of pollute first then develop later as put forward in the Environmental Kuznet’s Curve
(EKC). The theory implies that during the initial stage of development, some form of
environmental degradation occurs but increasing income produces incentives to improve
environmental quality (Munasinghe, 1999). The aim is to encourage restructuring of development
policy programmes to move on the path of sustainability by flattening the EKC curve for the
environmental indicators that are being dealt with. This process is aimed at avoiding the degree of
environmental damage in Bangladesh as experienced by industrialized countries during their early
periods of development without hindering development (Munasinghe, 1999).

2.7 EMAS

Background information of EMAS

EMAS - the Eco-Management and Audit Scheme, is a voluntary initiative designed for companies
and other organizations to evaluate, report, and improve their environmental performance. It
should be highlight that EMAS is a European Union Regulation, which applied within the
European Union and the European Economic Area (EEA) — Iceland, Liechtenstein, and Norway.
An increasing number of candidate countries are also implementing the scheme in preparation for
their accession to the EU (EMAS, 2004). The scheme has been available for participation by
companies since 1995 (Council Regulation (EEC) No 1836/93 of 29 June 1993) and was originally
restricted to companies in industrial sectors.

The aim of EMAS is to recognize and reward those organizations that go beyond minimum legal
compliance and continuously improve their environmental performance (EMAS-UK, 2004). In
addition, it is a requirement of the scheme that participating organizations regularly produce a

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public environmental statement that reports on their environmental performance. It is this
voluntary publication of environmental information, whose accuracy and reliability has been
independently checked by an environmental verifier, that gives EMAS and those organizations
that participate enhanced credibility and recognition.

In June 1997 The Commission undertook a 5-year review of EMAS, taking into account
experience gained during its operation. The final revised Regulation (Regulation (EC) No
761/2001 of the European Parliament and of the Council of 19 March 2001) published in April
2001, is often referred to as EMAS II. This new Regulation has been open to all economic sectors
including public and private services. In addition, EMAS was strengthened by the integration of
EN/ISO 14001 as the environmental management system required by EMAS; by adopting an
attractive EMAS logo to signal EMAS registration to the outside world; and by considering more
strongly indirect effects such as those related to financial services or administrative and planning
decisions.

2.8 British Standard BS 8555

Background information of BS 8555

BS 8555 (Environmental management systems - Guide to the phased implementation of an

environmental management system including the use of environmental performance evaluation) is
a new British standard published by the British Standard Institute (BSI) in April 2003. The aim of
BS 8555 is to provide guidance to all type of companies but particularly small and medium-sized
enterprises (SMEs) to achieve externally certified environmental management systems using a
phased rather than all-or-nothing approach to implementation (ENDS 340, 2003). This new
standard is drafted based on a three-years’ project- the Acorn Trust's supply chain project.

Project Acorn was a UK based nation-wide project to help SMEs to grow and develop their own
environmental performance controls, built around the specific needs of their own business. The
project ran between 2001 - 2003 and spent the time producing and refining a six-stage model that
could ultimately take a company towards ISO 14001 certification or EMAS if they wished (The
Acorn Trust, 2004).

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Acorn relies on larger "mentor" companies to introduce their suppliers to the scheme. The project's
website identifies 14 organisations which are now pursuing the Acorn approach in their supply
chains. They range across sectors including finance, utilities, manufacturing, retail and telecoms.
The scheme offers a five-level approach to implementing an environmental management system
compatible with the international standard ISO14001, and a sixth level compatible with European
standard EMAS (ENDS 337,2003).

An important outcome of the project - a new standard, BS 8555 - is released by the British
Standards Institution in April 2003. The standard takes the form of guidance towards achieving
ISO14001 or EMAS. It is not a certifiable specification in itself. However, the accreditation service
UKAS is understood to be considering some form of recognition (ENDS 337,2003).

2.9 Criteria of suitable EMS

1. Easy to start implementation

For those who are planning to implement an EMS, they all facing a problem: how to start it? It is
especially stubborn for SMEs who usually has less experience of environmental management
system. An easy start can eliminate hesitate and increase involvement.

2. Costs are relatively low

Pursuit of profit is the ultimate aim of business. Therefore, decision on whether implement an EMS
largely depend on how much it costs. The cost here means not only money but also time and human
resource which are all very limited for SMEs. Therefore, lower cost can definitely attract more
potential participants.

3. Benefits are relatively high

One of the reasons for EMS implementation is the benefits EMS can provide to its users. Hilary
1999 categorized the benefits of EMS implementation for SMEs as organizational benefits,
financial benefits, people benefits, Commercial Benefits, Environmental Benefits, and

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Communication Benefits. Different EMS can provide different benefits and the more benefits the
more participants.

4. Environmental performance are continuously improved

The ultimate aim of EMS is to control the participant’s environmental impacts (Welford, 1998).
Therefore, implementation an EMS is not just establishing an EMS and maintenance it but through
the EMS to improve the company’s environmental performance continuously. The one who meets
this criterion better can be seen as more suitable for businesses.

5. Legal compliance

Make sure the legal compliance is one of the basic functions of a successful EMS. Businesses
through EMS implementation should reduce the chance of conflict with environmental legislation
and regulation and thus make the company work more efficiency.

6. Implementation process is easy to be control

EMS implementation is easy to be interrupted due to some more important factors such as
economic profits. Therefore, flexibility is very important for a successful EMS. A clear structure
of each stage of EMS implementation process and sufficient control to each stage is preferable to
participants.

7. Easy to get assistance

Most of the companies find it is difficult to solve all the problems during the EMS implementation
by themselves. It is necessary to get some kind of assistance from outside. Hence, a good EMS
needs a good mechanism to guide its user and easy to get help from outside.

8. Mature accreditation system

Mature accreditation system is necessary in order to make sure the creditability of EMS
implementation. Creditability is receiving more and more concerns form EMS participant,
stakeholders as well as the competitors (ENDS Report 353, 2004). Whit the support and guidance
form accreditation body, EMS implementation can be carried out under a proper way and be
accepted by more and more companies.

9. Compatible with other systems

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In additional to EMS, there are several other management systems such quality management
systems and health and safe management systems. Study shows that compatible with other systems
can cause more involvement (Best Report, 2004). Besides, compatible with other EMSs also need
to be considered because a better compatible system has more opportunities.

10. Easy to diffuse

Diffuse here means whether an EMS is easy to be used in certain industry sector. Studies have
already focused on the implementation of EMS in certain industry sectors on the assumption that
such approach is better for the involvement of EMS implementation, especially for SMEs.

2.10 Occupational Health & Safety

At the present scenario occupational hazard lies as the hazardous genesis of almost all fatalities in
this digital and industrialized generation. The reason behind this statement came from the statistics
estimated by the International Labor Organization (ILO) according to which, from over the 2.3
million fatalities that take place annually, over 2 million fatalities are caused by work related
diseases. This burning issue has made a huge impact in different sectors (Human, Social and
Economic) because of their contribution to significant losses both on the national and international
arena, but especially on the Asian arena. The fatalities of occupational hazards (occupational
accidents, injuries, diseases and major industrial disasters) which had caused human, social and
economic costs have raised concern in all levels of people starting from the working individuals,
employers, to the national and international skeleton, mostly in Asian region. However, to keep
pace with technological and economic changes, measures and strategies are designed, developed
and applied to prevent, control, reduce or eliminate these occupational hazards and risks over the
years, particularly, when it is compared with the ancestral period. But despite these consistent slow
improvements, considering the human suffering and economic burden, occupational accidents and
diseases are still too frequent and still continuing to be significantly disastrous in Asia. Asia is the
largest and most populous continent of the Earth. The vast demographic, cultural, political and
economic differences among the countries of Asia have often been the basis for a lively
engagement of this continent with the world. While diversity is a universal feature, Asia represents
an extreme form of it comprising some of the highly performing sub groups of economics. It

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contains some of the developed countries as well as those that have performed relatively poorly,
commonly characterized as developing countries. Therefore, this article will provide a brief
overview of health risk due to occupational hazard and will also provide recommendations for
Asian region with a close comparison with other developed and developing countries of the world.

2.10.1 Occupational Health & workplace Safety in Bangladesh

The occupational health and safety service in Bangladesh is still in the developmental stage. Here
the occupational health & safety refers mainly to needs of workers of industries or some
manufacturing processes but does not completely cover all occupations of the country. The main
laws related to occupational health & safety in this country is the Factory Act 1965 and the Factory
Rule of 1979. There are a number of other laws and regulations that are also have some provisions
related to occupational health and safety. These laws have provisions on occupational hygiene,
occupational diseases, industrial accidents, protection of women and young persons in dangerous
occupations and also cover conditions of work, working hours, welfare facilities, holidays, leave
etc. But most of the laws are lacking in standard values and not specific rather general in nature.

For certain work environment factors, manufacturing process, machineries and toxic substances,
certain levels or concentrations of substances in the air have been recommended by various
international organization and agencies, which are considered to be safe, are implemented in the
respective countries. In USA Occupational Safety and Health Administration (OSHA) are referred
for the permissible levels or various standard limits for working environment. In Bangladesh no
such organization or agencies have been developed which could be a referral center for different
standard or occupational permissible limits. As such the prevalent rules and regulations in
Bangladesh are insufficient or inadequate in terms of standards and permissible limits. Moreover,
the enforcement department, the department of inspection, which is poor in quantity as well quality
could not effectively enforce to improve the occupational safety and health in Bangladesh.

In Bangladesh, as in most countries in the west the responsibility for health and safety at work is
placed on the employer, although the government has some kind of occupational health care
services and safety standards. Occupational health services are provided as benefits by employers
and generally are separate from other community health services. In the developing countries,

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many of which are undergoing rapid industrialization, the importance of occupational health is
increasingly realized. It is of concern that in Bangladesh like other developing countries pre-
existing malnutrition and a high incidence of infectious disease, however, frequently compound
the problems of exposure to occupational hazards.

The labor laws in Bangladesh have been framed which requires employers to undertake corrective
measures on occupational safety and health. Lack of awareness, training, non-compliances of the
OSH standards by the employers, the negative involvement of the workers could not achieve the
goal of providing safety and health to the workers as intended by the laws.

In Bangladesh, as in other developing nations the major considerations in industries are higher
production and greater economic returns. The main economics centered on the employer’s benefit.
Little importance is focused on the social costs in terms of impacts on workers, society, and the
environment. The impacts are compounded by inappropriate value of life considerations, pain and
suffering, opportunity costs and questions of equity. The estimates of direct economic costs and
benefits are usually made keeping aside the ethical liabilities to the society as a whole.
Entrepreneurs often consider the regulatory compliances related administrative costs deterrent to
productivity. As such occupational health & safety considerations remains ignored.

Time has come to consider the Occupational Health in its true spirit in a holistic way. The policy
makers, legislators, employers, and all other members of the society require to understand the
relationship of true social development with economic development through a system of good
practices of occupational safety and health in work places so that the fruit of industrial
development actuates the social goals. There should be awareness about consequences of not
addressing and non-implementations of occupational health & workplace safety standards.

2.10.2 National Policy Framework

The constitution of Bangladesh adapted on the November 4th 1972 recognizes productivity as a
basic need for economic development and covers the right to work and reasonable wages,
Medicare and, disease and disablement. And thus it is assumed the health and safety of industrial
workers has been taken care of.

The Occupational Health and Safety Services in Bangladesh, is still in the developmental stage. In
Bangladesh Occupational Health and Safety generally refers mainly to needs of workers of

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industries or some manufacturing process but does not completely cover all recognized
occupations of the country.

In the Fifth Five Year Plan (1997-2002) for the labour and manpower sector the objectives
relatable to OSH are:

 "To ensure fair wages, welfare and social protection of workers under the structural
adjustment programmes adopted by the government."
 "To initiate steps to protect children from economic exploitation. "

To achieve the objectives of the Fifth Five Year Plan (1997-2002) for the labour and manpower
sector the strategies relatable to OSH that were to be pursued are:

 "Review of existing labour related laws, rules, regulations and directives and adoption of
necessary modifications."
 "Stress on gradual elimination of child labour and protection of children from economic
exploitation and hazardous work."

In the labour sector the OSH relatable programmes that were to be undertaken under the Fifth Five
Year Plan included- Strengthening of Inspectorate of Factories and Establishments in terms of
manpower and resources so as to enable them to "enforce various labour laws/rules concerning
working hours, working condition, safety, and maternity benefits in different mills, shops and
factories, etc. "

In the Fifth Five Year Plan (1997-2002) for the health population and family welfare sector some
scope for further development in the sector against the background that 'with increased
urbanization and industrialization, the number of burn and trauma cases due to traffic and industrial
accidents, unsafe use of chemicals, fire, etc., has been increasing every year'. The following needs
has been identified:

 Need to establish hospitals near major highways, traffic blackspots and industrial areas
with trauma and burn units to treat burn and trauma cases in time.
 Promote industrial and occupational health through IEC activities so as to raise awareness
of industrial workers and protect them from industrial hazards.

2.10.3 Labour Policy:

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  Undertake effective new labour policy on the basis of tripartite negotiation
 Link wages with productivity
 Quick disposal of Industrial dispute
 Stop child labour and provide workers with education, healthcare, and better working
facilities,

2.10.4 Legislations Relating to Occupational Health and Safety

The Department of Inspection for Factories and Establishments under the Ministry of Labour and
Employment administers and enforces 42 labour laws. The following legislations have provisions
relating to occupational health, hygiene of workers, occupational diseases, industrial accidents,
protection of women and young persons in dangerous occupations, and also cover conditions of
work, working hours, welfare facilities, holidays, leave, etc.

Table 2.9

It is obvious from the above table that almost all the labour legislation are enforced by Department
of Inspection for Factories and Establishments. Therefore, there is little scope of overlapping
responsibilities.

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2.10.5 ILO Convention Regarding OSH:

Until now 31 ILO conventions have been ratified by Bangladesh. The ILO convention C 155 and
C161 are concerned with the Occupational Safety and Health and the Occupational Health Services
respectively. The aim of the policy of the convention C155 is to prevent occupational accidents
and injury to health, and illnesses by identification and minimizing the causes of hazards in the
working environment. The aim of the convention C161 is to establish and maintain a safe and
healthy working environment which will facilitate optimal physical and mental health in relation
to work. Although these conventions are not yet ratified in Bangladesh but many of the
recommendations of these conventions have been practiced to some extent through the
implementations of existing various laws and regulations. In the Factory Act 1965 and Factory
Rules 1979 and in some other laws and regulations there are various chapters that are relatable to
OSH. But by the existing laws and regulations qualitative inspections regarding safety and health
in the working is possible but could not be monitored in terms of quantitative standard values and
permissible limits.

For ratification of ILO convention No. C 155 and C161 the motivation of all the parties-
policymakers, employers and employees is required.

2.10.6 National Statistics for Occupational Injuries and Occupational Diseases

All accidents and occupational diseases are legally reportable as per provisions of The Factory Act
1965 and Rules made there under and there are standardized national reporting form. But all
accidents are not generally reported to the Department of Inspection so, under reporting is usual.
On the other hand, no occupational diseases and poisoning out of the processes of manufacturing
has ever been reported which is thought to be due lack of knowledge and awareness on the part of
the medical personnel and management.

Occupational Injuries: In the Factories Rules, 1979, the Fatal, Serious and Minor accidents are
described as follows:

Fatal and Serious accidents- When there occurs in any factory an accident to any person which
results in death or such injury that there is no reasonable prospect that he will be able to resume

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his employment in the factory within 20 days, such accidents shall be called as Fatal or Serious as
the case may be.

Minor Accidents- When there occurs in any factory an accident to any person less serious than
those described as above but which prevents or is likely to prevent him from resuming the
employment in the factory within 48 hours after the accident occurred, such accidents shall be
called as Minor Accidents.

If any Fatal or Serious accident occurs the manager of the factory shall give notice of the
occurrence forthwith by telephone, telegram, or special messenger to a) the Chief Inspector b) the
Deputy Commissioner c) Inspector d) the Commissioner for Workmen’s Compensation and e) and
in the case of fatal accident only, the Officer-in-Charge of the police station. If any Minor accidents
occurs the manager of the factory within 7 days of occurrence shall report to authorities mentioned
in a), b) and c).

Following tables shows the report regarding occupational accidents and injuries as reported to the
chief Inspector of Factories:

Table 2.10: Number of industrial accidents/injuries by severity in Bangladesh during the period
1990 to 1999.

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Table 2.11: Number of accidents/ injuries & their severity in major industry categories in the
year 1999.

Table 2.12: Number of death & in major industry categories of last 10 years

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2.11 Workplace safety in RMG industries: Aftermath of Rana Plaza:

After the collapse of Rana Plaza which claimed the lives of 1,138 mostly garment workers and left
thousands more injured, the global outcry for improved worker safety in the ready-made garment
(RMG) industry of Bangladesh caused by global public interest, media attention and harrowing
stories of workers has led to the emergence of various international and national initiatives to
address the issue. Three of these initiatives are the Accord on Fire and Building Safety in
Bangladesh (the Accord), the Alliance for Bangladesh Worker Safety (the Alliance) and the
National Tripartite Plan of Action on Fire Safety and Structural Integrity in the Garment Sector of
Bangladesh (the National Initiative).

Although on the surface, these initiatives appear to be quite similar and have the primary objective
of improving worker safety in the RMG sector of Bangladesh through inspections and
identification of fire, structural and electrical remediation’s for garment factories, they show
considerable differences when looked more carefully. These differences influence the outcomes
of the three initiatives on factory remediation for fire, structural and electrical safety in the RMG
sector in Bangladesh. In this blog, after a brief description of each initiative (for a broader
description, see here), I will discuss the effectiveness of the remediation processes introduced by
the Accord, the Alliance and the National Tripartite Plan.

The remediation initiatives in the Bangladeshi RMG sector are mentioned below

2.11.1 The Bangladesh Accord on Fire and Building Safety in Bangladesh

On 15 May 2013 the Accord, which covers more than 2 million garment workers, was adopted for
a period of five years to stop business-as-usual in Bangladesh’s RMG sector. To date, more than
200 apparel brands, retailers and importers from more than 20 countries in Asia, Australia, Europe
and North America, along with two global unions and 14 Bangladeshi trade union federations have
signed the Accord. Additionally, four international labour rights NGOs have signed the Accord as
international witnesses. A unique feature of the Accord is that its signatories have made binding
commitments – that is, they can be brought before arbitral courts for disputes arising from the
Accord. It stipulates independent inspections, disclosures of these inspection reports and corrective
action plans (CAPs) and commitments by the signatory brands to assist the financing of RMG
factory remediation. Under the Accord, as of 2018, more than 2,000 factories have been inspected

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for fire, electrical and structural issues and more than 130,000 issues have been identified in the
factory inspections, 83% of which have been verified as fixed. Although the Accord will expire in
May 2018. After this date, the Transition Accord, which is signed by 145 brands already (as of 17
April 2018), will replace it for an extendable period of three years.

Figure 2.3: Factories Inspected Or Scheduled For Inspection Under Accord Program

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Figure 2.4: Total Reported Findings of RMG industries

Figure 2.5: DEA Status

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Table: 2.13 Status of Total Original Findings (In Published Caps)

Table 2.14: Status of Total New Findings (In Published Caps)

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Figure 2.6: Status of Total Original and New Fire, Electrical And

Structural Findings Combined

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2.11.2 Alliance for Bangladesh Worker Safety

Many North American companies refused to sign the Accord due to liability concerns and instead
they (currently 29 companies, with all but one from North America) formed the Alliance in July
2013 to be active for a period of five years. The members do not have legally binding commitments
under the Alliance and are just obliged to pay the annual membership fee. The Alliance also
provides for independent inspections and the disclosure of inspection reports, the preparation of
CAPs and the suspension of factories if they fail to meet the safety standards of the Alliance. Under
the Alliance, inspections have been carried out in more than 900 factories and 85% of all
remediation proposed in the CAPs has been completed. It does not seem that the Alliance will be
extended after 2018, but there have been efforts to create a local organization that could build on
the legacy of the Alliance and would be tasked with monitoring new and existing factories
according to the standards of the Alliance concerning fire, electrical and building safety.

Figure 2.7

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Figure 2.8

Figure 2.9

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2.11.3 The National Initiative: REMEDIATION COORDINATION CELL (RCC)

After the Tazreen fire, the Bangladeshi Government, in collaboration with employers and workers
organizations started to develop an action plan aimed at ensuring fire safety in garment factories.
Although the plan was formally adopted on 24 March 2013, it was reassessed after the collapse of
Rana Plaza and the structural component was included in the plan. On 25 July 2013 the revised
version was adopted. The plan consists of legislative, administrative and practical activities to
promote fire safety and structural integrity in Bangladesh’s RMG sector. This government
initiative, supported and coordinated by the ILO, inspected approximately 1,500 factories not
covered by the Accord or the Alliance. However, the reports of these inspections are not publicly
available.

Importance of RCC

 The operation of the RCC marks a major step towards improving workplace safety in the
RMG sector.
 It is a concrete manifestation of efforts to institutionalize safety reforms which will
ultimately benefit all sectors.
 The RCC will further contribute to building the national capacity of regulators as well as
collaboration between them.
 Ultimately, the entity which the RCC evolves into will take responsibility for relevant
workplace safety issues once the Accord, Alliance and development partner support ends.

RCC Stakeholders:

The RCC has been established through the collaboration of the

 Government of Bangladesh
 Bangladesh Garment Manufacturers and Exporters Association (BGMEA)
 Bangladesh Knitwear Manufacturers and Exporters Association (BKMEA).

Trade unions and international buyers have been consulted on its development while technical
support is provided by ILO with funding from Canada, the Netherlands and the United Kingdom.

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Chapter 3

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Methodology

3.1 Introduction

The main objective of the study is to investigate performance of implementing EMS in industries
of Bangladesh. This study also investigates the current environmental management initiatives
taken by industries in Bangladesh and their motivation for adopting the system. The specific
objectives of the study are to find out:

i) Performance of EMS practices in different industry

ii) Progress analysis of EMS CAP’s compared to workplace safety initiatives.

iii) to find the drivers & barriers of implementing EMS.

To achieve first and third objective a questionnaire survey and few interview was carried out. A
conceptual framework was developed at the outset of the research to frame the study as well as to
design the questionnaire. Field survey was accomplished to collect the primary data from the
questionnaire. Then the data was analyzed to obtain the results. Primary data was the main source
of information for the study.

To achieve second both secondary and primary data was derived and compared. Secondary data
derived from the annual report of several workplace safety initiatives annual report and primary
data was carried out by conducting interview with different factory personnel. This interview
mainly focused on realizing real scenario of industry by conducting an in-house EMS audit.
Industries were selected from both “satisfactory” and “behind the schedule” labeled in workplace
safety initiatives. Thus general information of those industries kept confidential.

3.1.1 Conceptual Framework

A theoretical conceptual framework is used in research to outline possible courses of action or to

present a preferred approach to an idea or thought. Theoretical conceptual frameworks are a type
of intermediate theory that attempt to connect all aspects of an inquiry e.g., problem definition,
purpose, literature review, methodology, data collection and analysis. Conceptual frameworks can
act like maps that give coherence to empirical inquiry. Because conceptual frameworks are

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potentially so close to empirical inquiry, they take different forms depending upon the research
question or problem. In this research, a descriptive conceptual framework was developed to link
with the descriptive study. Figure 3.1 shows the conceptual framework developed for the study.
This conceptual framework was designed by the common perception of the implementation of
EMS in Bangladesh. The box shows indicators and arrow shows the relationship between
indicators. The larger box shows common indicators which influence the other indicator. Also the
arrow depicts the positive relationship among indicators.

As this is a descriptive conceptual framework there are some limitations of this model. Other
variables which might influence in implementing the EMS would not be revealed and there might
some other factors which are interlinking with other or interactive to other might be missing in this
model. Barriers of implementing EMS are not shown in the model and how the barriers would
influence the model is also absent.

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3.1.2 Instruments

For the acquisition of primary data, a questionnaire was administered to several (manufacturing,
RMG, FMCG, Telecom, MNC) industries in the study area. The questionnaire was primarily
developed from the conceptual framework that was designed earlier by the common perception of
the implementation of EMS in Bangladesh and from the review of the literature that has identified
performance analysis, different motivations and barriers of implementing an environmental
management system.

Draft survey was pre tested by asking over 10 corporate environmental managers and
environmental management consultants to complete the draft survey, and then discussing their
experience to ensure they interpreted the questions the same way we had intended. In addition, it
was also verified by the thesis coordinator. Finalized survey was prepared by clarifying several
questions and responses.

The first section provided general information of the organization, such as, the location of the
industries, the number of employees, the industrial sector that it belonged to, and the type of
certification that it had. This information concerning characteristics of the organization was
required because a classification of the organizations by business sector and by size was needed in
order to establish relationships with data about EMS implementation experience. Based on the
responses to the third question, where the organizations indicated their industrial sector, a
categorization of the main sectors that the companies surveyed belonged to was done. The second
classification by size was based on the answers to the question on the number of employees
whether the company was a SME or a large enterprise (MOI, 2010).

The second section focused on motivations, communication method & driving force of EMS. This
part was intended to investigate the key drivers that motivated the organizations to implement an
EMS. Different options were given to the respondents, who selected the appropriate ones. The
third section was based on EMS Staffing, certification approaches & to realize organization main
motivation toward achieving EMS.

Final portion was to identify external & internal influence and to identify barriers toward EMS.

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3.1.3 Questionnaire Survey

In order to carry out the survey most effectively the structured questionnaires were administered
personally to human resources responsible to the environment in the respective industries with a
covering letter, explaining the reasons of the survey. Some questionnaires were left with those
industries in which the questionnaire could not be administered personally. Some interviewees
were contacted through e-mail and telephonic call. Telephonic interviews were also conducted
after receiving the filled up questionnaires.

3.1.4 Population and Sampling

A convenient purposive sampling method was employed to collect data from industries located
mainly in industrially populated areas like like Dhaka, Chittagong, Gazipur, Savar, Cumilla,
Mymensing and Narayanganj and popular in their respective manufacturing field. Major sectors
of industries included food production and processing, cotton and textile, plastic production,
pharmaceuticals and iron and steel manufactures. Industries were selected on the basis of their
availability and accessibility to the author and their willingness to take part in the survey. Contact
with most of the industries was facilitated through personal relationship.

3.1.5 Data Analysis and Presentation

As the number of industries interviewed was small, the study was considered to be exploratory
and the data were not analyzed statistically. All the results were collated into a spreadsheet format.
Answers to open questions were categorized in the main responses. Common responses to each
question were expressed as a percentage of the total number of replies received, which allowed
direct comparability. In addition to this, questions left in blank by the respondents were counted
into the total number of replies received. In most cases, the results for each question did not add
up to one-hundred percent, due to the fact that most organizations selected more than one option
for the same question, or because of a consequence of rounding up figures. The results were then
presented in tables, graphs and charts for displaying responses to questions in different formats as
appropriate. Frequencies of the various responses are worked out. It is then interpreted and
explained in terms of the general trends that emerged from the analysis. Relationships between
variables are shown. Inductive reasoning is employed to arrive at conclusions in the final analysis.
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3.1.6 Rationale for the Study

1. The rationales for the study are varied but interlinked.

2. The study will help to ascertain the level of compliance with the local environmental
legislation (DoE standard) or ISO standard.
3. It will also help policy makers and organizations to realize the performance status of EMS
compared to other standards.
4. Results from the study would be very informative in increasing compliance with the
standards, to cut cost, to improve the environment by way of reduction of emission and
waste production for sustainable development.
5. Industries and establishments in Bangladesh do not have much reference information that
they would find relevant for adopting EM practices in their operations as best as to
international standards to make sustainable development and about benefits they would
derive from it. The study would therefore serve as a reference point to industries and policy
makers trying to make sustainable development a priority in their activities and help
industries of Bangladesh to get EM practice in their operations and relate it to the current
state of environmental problems.

3.1.7 Limitations to the Study

1. Data for the study was collected arbitrarily from few industries of different sectors of the
country therefore making it difficult to draw a clear-cut generalization to all industries in
Bangladesh.
2. The selection of companies was done purposively. Some of the companies declined to
participate in the study and some, due to bureaucracy could not allow for the administration
of the questionnaire directly to individuals responsible to the environment. The
questionnaire was therefore left with Personnel Manager (PM) or Human Resource
Manager (HRM). These might lead to bias in responses which ultimately could affect the
study.
3. The study data are also limited by the knowledge and personal judgment of the participants
as they were obtained through personal interviews and written responses. They thus had to
rely on their memories on why and how some events occurred at their establishments. The
anonymity of the companies was assured but some would as much as possible try to protect

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 the image and reputation of their companies making it difficult to say whether the responses
are what is actually happening in the establishments.
4. To determine links among motivations, methods and outcomes is beyond the scope of this
study. Aggregate environmental performance was expected to be measured at a point in
time. However, the respondents were not able to link specific management practice to
comparative advantage enjoyed as a result of that practice. Despite this problem, the results
provide a basis for understating corporate EMS and factors influencing companies in
Bangladesh to adopt EM standards and advantages they are enjoying from it.

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Chapter 4

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Result & Discussion

4.1 Introduction

The main objective of the study is to investigate performance of implementing EMS in industries
of Bangladesh. This study also investigates the current environmental management initiatives
taken by industries in Bangladesh and their motivation for adopting the system. The specific
objectives of the study are to find out:

i) Performance of EMS practices in different industry

ii) Progress analysis of EMS CAP’s compared to workplace safety initiatives.

iii) to find the drivers & barriers of implementing EMS.

4.1.1 Background and Location of the Industries

The study was carried out on different industries of Bangladesh. Table 4.1 shows the distribution
of the sectors. From the table it is seen that 30% of the sample was taken from Gazipur district and
21.6% from Dhaka district. These figures do not indicate the proportional distribution of industries
in Bangladesh as the sample was taken conveniently. But it is obvious from Statistical Pocket Book
(BBS, 2005) that major industrial development took place in larger urban areas like Dhaka,
Chittagong, Gazipur etc. Fig: 4.2 shows the ratio of different sector who responded on survey.

Location Frequency
Dhaka 13
Savar 9
Gazipur 18
Chittagong 3
Mymensing 4
Narayangonj 12
Cumilla 1

Table 4.1: Location vs Frequency of Survey

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 Fig 4.1 Percentage of Respondents
Dhaka

1% Savar
20% 22%
Gazipur
7% Chittagong
5% 15%
Mymensing
30% Narayangonj
Cumilla

Fig 4.2 Number of Respondent(Sector-wise)

30

25

20

15

10

We tried addressed our survey to Environmental Managers/Specialists or Environment, Health and

Safety (EHS) Managers/Specialists because we thought these individuals would possess the most
comprehensive and accurate knowledge about the questions in our survey. Indeed, as depicted in
Figure 4.3 above 50% the respondents held one of the positions we were targeting.

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 Fig 4.3: “Which of the following most closely reflects your
position?”

Other
EHS Manager
15%
Environmental
HR & 28%
Compliance
Manager/Speciali
18%
st
Plant Manager
17% 22%

EHS Manager Environmental Manager/Specialist

Plant Manager HR & Compliance
Other

4.2 Performance analysis of EMS

EHS Staffing

The average number of full time equivalent (FTE) employees in a facility’s EHS department
ranged across the different industries from 0-10, with an overall average of 3.79 (see Figure 4.3).
The highest average is in the refining industry with over 10 employees. On average, facilities’ EHS
departments include less than 1% of a facility’s total employees.

Fig 4.4: EHS Staffing

12
10
8
6
4
2
0

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Environmental Policy

95% of the respondents indicated they have adopted an environmental policy at their facility.
Respondents were asked to indicate the methods used to communicate their environmental policy.
Figure 4 summarizes these results. The majority of the respondents post hardcopies of their policy
at the facility while nearly half of them post the policy on the Internet and distribute it to their
employees.

Fig 4.5: Communication of Environment

policy
Posted at Facility

23% Posted on internet

48% 5%
Distributed to employee
24%
Through interactive
trainning program

Environmental Audits

On average, facilities have 1.7 internal audits plus 1.4 external audit per year. Only a few industry
averages differed from these overall averages. Specifically, facilities in the refining sector
averaged less than 2 audits per year.

Fig 4.6: How many times(yearly) has your facility had an

internal/external environmental audit conducted by third parties such
as consultants, not including regulators or corporate staff?
3.5
3
2.5
2
1.5
1
0.5
0

Internal External

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Employee Training

Figures 6, 7, and 8 present the percentage of facilities providing environmental training for more
than 60% of their employees. The graphs below illustrate how departmental training varies within
each industry. Maintenance and operations & engdineering employees usually receive the most
training, while sales department employees receive the least.

Fig 4.7: Employee Training(%)

All over
Operation
Maintainanace
Eng-Design
Management
Sales
Purchasing

0 10 20 30 40 50 60 70

Status of ISO 14001 certification:

As depicted in Figure 9, just over a third of the respondents indicated that they had already
successfully implemented the ISO 14001 Environmental Management System Standard. In
addition, 13% of the facilities noted that they are planning to implement or are currently
implementing ISO 14001. A fifth is considering implementing ISO 14001 in the future.

Fig 4.8: ISO 14001 Certification

50
40
30
20
10
0
Not being Future Planning to Currently Successfully
Considered Consideration implement Implemented Implemented

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Setting Objectives and Targets

Figure depicts the percentage of facilities that have objectives and targets for various
environmental issues. Overall, most facilities have performance targets for air, water, and waste.
Less than a fifth of the respondents have targets for noise reduction. No significant differences
were found between industries.

Fig 4.9: For which of these environmental issues

do you have objectives and targets?”
80%
70%
60%
50%
40%
30%
20%
10%
0%
Air Water Silod Waste Hazardous Noise
Waste

Percentage(%)

Influence of External Stake-holder:

Respondents indicated that a variety of stakeholders exerted a strong influence on their

environmental performance improvement. As noted in Figure 16, the three stakeholders most often
cited as exerting a strong influence were government (58% of the facilities), customers (41%), and
local communities (34%)

Fig 4.10: To what extent have each of the following groups influenced
your facility to improve its environmental
performance?” "%"

Customers

Shareholder

Environmental Organization

Media

Supplier
0 10 20 30 40 50 60 70

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EMS Adopted by Industries:

Fig 4.11: EMS Adopted

35
30
25
20
15
10
5
0
ISO 14001 Energy Eco-Labelling Waste Green No Answer
Management Management Industry

Progress of EMS CAP’s Compared to Workplace safety initiative capes:

Primary data from five different industries EMS checklist shows that both are maintaining proper
documentation & conducting testing, maintaining govt. requirements. But mitigation of impacts is
not satisfactory compared to the progress that we have seen in workplace safety by ACCORD &
Alliance. In literature review it is clearly shown how CAP’s of structural, Fire & electrical safety
has been resolved almost by 70%. Compared to those in real scenario performance of EMS &
mitigating initiatives to minimize impacts are very poor and insufficient.

Fig 4.12: EMS CAP status

Case 5

Case 4

Case 3

Case 2

Case 1

0 0.2 0.4 0.6 0.8 1

Satisfactory Behind Schedule Not Done

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4.3 Findings & Comments:

According to annual data of workplace safety initiatives (%) of CAP removal is almost 92% of all
over RMG industries. Compared to this during EMS removal of CAPS’s is really very low in
progress. Which indicates industries doing the minimum required initiatives toward EMS. Due to
pressure from external stakeholder and govt.

4.3.1 Motivation to develop EMS

 International acceptance
 Compliance to regulation
 Social commitment
 Customer satisfaction
 Increase of overall performance
 Increase of worker’s competence

4.3.2 Barriers of Achieving EMS

 High Investment and Maintenance Cost

 Lack of Government Incentives
 Management Ignorance of Regulations, its Existences and Other Impediments

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Chapter 5

80 | P a g e
5.1 Conclusion

The main objective of the study is to investigate performance of implementing EMS in industries
of Bangladesh. This study also investigates the current environmental management initiatives
taken by industries in Bangladesh and their motivation for adopting the system. The specific
objectives of the study are to find out:

i) Performance of EMS practices in different industry

ii) Progress analysis of EMS CAP’s compared to workplace safety initiatives.

iii) to find the drivers & barriers of implementing EMS.

It is observed that mostly the manufacturing industry, RMG & Food industries are more compliant
and have better performance of EMS. It is due to top-management commitment, immense pressure
& competition from external market, certification incentives.

On the other hand, overall EMS performance is not satisfactory due to less pressure from
government and local stakeholders toward industries to maintain quality of Environment. Also
testing & EIA procedures are poor and can be easily manipulated. Thus by documentation the
industries are very resilient on maintaining environment, but in reality condition is more poor.

Many industries are taking several green banking initiatives which are mutually beneficiary for
industry & environment. Thus government incentive and strengthen of policy; implementation of
law will drive the industries to be more careful and enthusiastic towards EMS.

5.2 Suggestions for Future Studies

1. In the current study the questionnaire designed were mostly of nominal type. For future study,
questionnaire can be designed with dichotomous variables or scoring system can be employed to
find out the dependencies among/ between variables.

2. In the current study, samples were not homogeneous or categorized. For future study, to make
the results statistically more justifiable samples can be categorically framed and homogeneity can
be maintained.

3. Quantitative performance analysis of industry will provide suggestions to resolve impacts.

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List of Reference:

“Bangladesh Garment Manufacturers and Exports Association (BGMEA)” [Online]. (Accessed: November 30,
2018)

“Bangladesh: Share of industry” [Online].

Available:http://www.theglobaleconomy.com/Bangladesh/Share_of_industry/ (Accessed: November 28, 2018)

“Bangladesh: Share of manufacturing” [Online].

Available:http://www.theglobaleconomy.com/Bangladesh/Share_of_manufacturing/

“The world Economy” [Online]. Available from:

http://www.ereport.ru/en/stat.php?razdel=country&count=bangladesh&table=ipecia&time=2 (Accessed:
November 30, 2018)

14: 27-76.

Alliance for Bangladesh Worker Safety Fifth Annual Report ,(November 2018) An Industry Transformed: Leaving a
Legacy of Safety in Bangladesh’s Garment Sector, Bangladesh

Alliance for Bangladesh Worker Safety Annual Report, (November 2017) Dawn of a New Era in Safety:
Accelerating Progress in the Alliance’s Final Year, Bangladesh

Ahaduzzaman, Prottasha Sarkar, Aniqa Anjum and Easir A Khan (2017) Overview of Major Industries in
Bangladesh, Journal of Chemical Engineering, IEB

Ahmed HO, Newson-Smith MS (2010) "Knowledge And Practices Related To Occupational Hazards Among
Cement Workers In United Arab Emirates," Journal Egypt Public Health Association 85: 3-4.

Akram O (2014) "Occupational Health and Safety in Urban and Peri-Urban Bangladesh: An Important Cause and
Consequence of Extreme Poverty," Governemnt of the People's Republic Bangladesh, UKaid, Swiss Agency for
Development and Cooperation SDC, eprg, Centre for Development Studies, ADD International.

Alasaari JS, Lagus M, Ollila HM, Toivola A, Kivimäki M, et al. (2012) Environmental stress affects DNA
methylation of a CpG rich promoter region of serotonin transporter gene in a nurse cohort. PLoS One 7: e45813.

Alli BO (2008) "Fundamental Principles of Occupational Health and Safety,"

Available: http://www.bgmea.com.bd/home/ pages/tradeinformation. (Accessed: November 30, 2018)

Bangadesh Bureau of Statistics (BBS) "Household Income and Expenditure Survey (2011)," Bangadesh Bureau of
Statistics (BBS).

Bangladesh National Accounts Blue Book 2016

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Bureau of Labor Statistics (2013) "Census of Fatal Occupational Injuries Summary," United States Department of
Labor, USA.

Gupta D (2005) "Economic Diversity in Asia," in Asian Economy and Finance

ILO (2014) "Creating Safe and Heathy Workplaces for All," International Labour

International Labour Office Geneva pp: 1-227.

International Labour Organization (2013) "Chronology of recent events in the Bangladesh Ready Made Garment
(RMG) sector.

Islam MM, Chuenpagdee R (2013) "Negotiating risk and poverty in mangrove fishing communities of the
Bangladesh Sundarbans," Martime Studies a Springer Open Journal 12: 7.

Khan MM, Halim ZI, Iqbal M (2006) Attributes of occupational injury among workers in the chemical industry and
safety issues. Int J Occup Saf Ergon 12: 327-341.

M. A. Rashid Sarker (November 2005),“Prospects and Challenges of Industrialization in Bangladesh”, Bangladesh

Organization pp: 1-18.

Pham VH, Lan Tran TN, Le GV, Movahed M, Jiang Y, et al. (2013) Asbestos and Asbestos-related Diseases in
Vietnam: In reference to the International Labor Organization/World Health Organization National Asbestos
Profile. Saf Health Work 4: 117-121.

Qarterly Aggregate Report (April, 2018) Accord on Fire andbuilding Safety in Bangladesh.

Rod NH, Vahtera J, Westerlund H, Kivimaki M, Zins M, et al. (2011) Sleep disturbances and cause-specific
mortality: Results from the GAZEL cohort study. Am J Epidemiol 173: 300-309.

Safety and Rights (2008) "High number of construction wo rkers dieing at the workplace: Survey."

Siriruttanapruk S, Anantagulnathi P (2004) Occupational health and safety situation and research priority in
Thailand. Ind Health 42: 135-140.

Stickgold R (2007) "Sleep, Performance, and Public Safety," Harvard Medical School.

Uehli K, Mehta AJ, Miedinger D, Hug K, Schindler C, et al. (2014) Sleep problems and work injuries: a systematic
review and meta-analysis. Sleep Med Rev 18: 61-73.

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Annexure:

Sample of Survey questionnaires:

A Survey Questionnaire on Environmental management practice in the

industries/organizations of Bangladesh

Name of Respondent :
Designation :
Organization Name/Type :

1. Which of the following most closely reflects your position?

a. EHS Manager/Specialist
b. Environment Manager & Specialist
c. Plant Manager
d. HR & Compliance
e. Others
2. Approximately how many full-time equivalent employees (FTEs) are working on
environment, health and safety issues for your facility?

……………………………………………………………………………. person
3. If your facility or company has an environmental policy, how is it communicated?
a. Posted at facility
b. Posted on internet
c. Distributed to employees
d. Through interactive training program

4. Does your organization promote following initiatives? (Tick)

a. In house Environmental policy
b. Product life cycle assessment
c. Eco Mapping
d. Process mapping
e. Environmental Management System
f. Ethical purchasing

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5. What is the driving force of your organization to maintain EMS (Environmental
Management System)? (Rate within 1-5)

Corporate influence 1 2 3 4 5
1. Law Enforcement
2. Buyers Demand
3. Self-Motivation
4. Incentives for EMS
5. Environmental Awareness
6. Commitment to compliance

6. How many times has your facility had an external environmental audit conducted by third
parties such as consultants, not including regulators or corporate staff?

……………………………………………………………………………………… times.

7. How many times has your facility had an internal environmental audit conducted by your
facility staff and/or corporate staff?

………………………………………………………………………………………… times.

8. Approximately, what proportion of your employees at your facility has received

environmental training over the past 12 months in the following departments?
All over ------------------------------------------------------------------------------------------- %
-
Operations Department----------------------------------------------------------------------- %
-
Maintenance Department-------------------------------------------------------------------- %
-
Engineering - Design Department---------------------------------------------------------- %
-
Management------------------------------------------------------------------------------------ %
-
Purchasing Department----------------------------------------------------------------------- %
-
Sales Department------------------------------------------------------------------------------- %
-

9. What is the status of ISO 14001 certification at your facility?

a. Not being Considered

b. Future Consideration
c. Planning to implement

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 d. Currently Implemented
e. Successfully Implemented

10. Does your purchasing department use a green purchasing policy?

a. Yes
b. No
11. What is the status of your participation in voluntary programs such as Energy Star,LEED,
Green Globe?

a. Yes
b. No

12. Does your organization promote uses of renewable energy?

a. Yes
b. No
If Yes, then how?
a. Investing on renewable energy set-up.
b. CSR (Corporate social responsibilities)
c. Other (…………………………..)

13. Does your organization/industry participate on Green Banking initiatives?

a. Yes
b. No
If yes, then which initiative are/is initiated
- Solar Home system
- Solar irrigation pumping station
- Solar PV module assembly plant
- Solar Mini grid
- Bio-gas plant
- Effluent Treatment Plant (ETP)
- Hybrid Hoffman Kiln/equivalent technology Brick Field
- Vermicompost
- Safety Working Environment
- Green Industry
- Paper waste recycling
- Organic Manure
14. Does your company has own industry-led environmental programs?
a. Yes
b. No

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 If yes, please rate the program
1 2 3 4 5

15. How often does your facility solicit opinions from environmental non-profit organizations,
such as involving them in site planning or in identifying environmental impacts?

a. Regularly
b. Before undergoing new project
c. During awareness program

16. For which of these environmental issues do you have objectives and targets?
a. Air
b. Water
c. Solid waste
d. Hazardous waste
e. Noise

17. To what extent have each of the following groups influenced your facility to improve its
environmental performance? (Rate within 1-5)

External Stakeholders 1 2 3 4 5
1. Suppliers
2. Fund Providers
3. Media
4. Trade Association
5. Environmental Organizations
6. Competitors
7. Shareholders
8. Local Community
9. Customers
10. Regulator

18. To what extent have the following corporate departments influenced your facility to
improve its environmental performance?

Corporate influence 1 2 3 4 5
7. Corporate product design
8. Corporate Marketing
9. Corporate Public Relation
10. Corporate Strategy
11. Corporate legal & regulatory affairs

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 12. Corporate Environmental Management

19. In addition to improving environmental performance, how important are the factors listed
below in motivating your facility to implement environmental management practices?

Factors 1 2 3 4 5
1. Improve environmental NGO relation
2. Generate new product/service
3. Improve customer loyalty
4. Reach new customer
5. Influence of pending legislation/registration
6. Improve community relations
7. Improve regular compliance

Comments:
Please describe briefly the internal & external factors that are barriers to achieve
environmental goals/sustainability
………………………………………………………………………………………………………………………………………………
………………………………………………………………………………………………………………………………………………
………………………………………………………………………………………………………………………………………………
………………………………………………………………………………………………………………………………………………
………………………………....................................................................................................................
........................................................................................................................

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