ISO 14001:2004 AND OHSAS 18001:2007 COMPLIANCE STATUS REPORT

OF BATTERY SUPPLIERS AND RECYCLERS OF IDCOL SHS PROGRAM

March, 2014

Prepared by

Infrastructure Development Company Limited

1.

INTRODUCTION

Infrastructure Development Company Limited (IDCOL) is committed to comply with required environmental and social safeguards. It has adopted an Environmental and Social Safeguards Management Framework (ESMF) of for its solar home system (SHS) program. According to this ESMF, all approved battery suppliers in IDCOL SHS program have to be ISO 14001:2004 and OHSAS 18001:2007. ISO 14001:2004 is an internationally recognized standard about environmental management and OHSAS 18001:2007 is worldwide accepted standard for maintaining occupational health and safety aspects. The basic requirements of these two standards are mentioned in Annex –1 of Appendix -A. There are 17 battery suppliers of which 16 are local and the remaining one is Japan Solar Tech, which sells imported batteries. In addition, there are three en-listed expired battery recyclers in IDCOL SHS Program, who also require to be ISO 14001:2004 and OHSAS 18001:2007 compliants. These requirements are in addition of the requirements of the Department of Environment, Bangladesh. To assess the status of implementation of environmental and occupational health safety management system, the respective official of IDCOL half-yearly visits all three recycling plants. In case of battery manufacturing plant, there is a requirement to monthly visit. Based on the primary findings and secondary information as are provided by the battery manufacturers and recyclers, this Compliance Status Report has been prepared.

2.

OBJECTIVES

The objectives of this compliance status Report are as follows: 

To assess the commitment of management of manufacturers and recyclers about environmental and occupational health safety sytem;



To assess the availability of required infrastructure like ETP and ATP;



To assess the status of documentation of required guidelines;



To assess the availability of medical facility;



To assess the gap in respect of the actual scenario and desired level;



To assess the areas where relevant stakeholders can support the recyclers and manufacturers to implement environmental and occupational health safety system in a satisfactory manner.

2

2.

LOCATION AND AREA OF BATTERY MANUFACTURING PLANTS

Among the aforesaid 16 (sixteen) battery suppliers, 13 battery suppliers have their battery manufacturing factories in Dhaka Division, two are in Khulna Division and only one is in Sylhet Division. HAMKO Battery has the largest battery manufacturing and recycling plant in respect of area (an area of about7.5 acres) and scale of production But the smallest manufacturing unit is owned by Z by A Corporation (an area of about 0.05 acre). In the following Table 01, the location and area of the factory of 16 battery suppliers are provided. Table 1: Location and area of battery manufacturing and recycling plants Battery supplier

Location of factory

Area in acre

Rahimafrooz Accumulators Ltd. Panna Batteries Ltd.

West Panisail, Zirani Bazar, Gazipur

4.00

West Rasulpur, Kamrangir Char, Dhaka-1211

6.50

HAMKO Batteries Ltd.

BSCIC I/A Shiromoni, Khulna

7.50

Electro Batteries Co. Ltd. Rimso Batteries Ltd.

Boro Rangamatia, Durgapur, Ashulia, Savar,

5.00

Plot#21, Kadamtoly Road Shyampur I/A, Dhaka-1204

0.20

Euro Battery

0.50

Z by A Corporation

Varardi, Kachkura Bazar, Uttar Khan, Uttara, Dhaka1230 403-404, Tejgaon I/A, Dhaka-1208

White Products Ltd.

Plot 1142-1143, Nowjore, Gazipur

3.30

ECO Batteries Ltd.

Uzilab, Sripur, Gazipur

1.00

JCo. Batteries Ltd.

Plot no. S-6 , BSCIC I/A , Ruhitpur, Keranigonj, Dhaka.

0.25

Navana Batteries Ltd.

3.80

SunTec Batteries Ltd.

CDA Plot No. – 3(P) & 4(P), Fouzderhat I/A, Chittagong BSCIC I/E, Khadimnagor, Sylhet

Gel Tec Batteries Ltd.

Raj Fulbaria, Savar

0.20

Tamim Batteries Ltd.

111, Pobahati Road, Jhenidah-7300

1.20

A&P Batteries Ltd.

Chaparbandh (Adampur), 2nd gate to Sonargaon Museum Road, Sonargaon, Narayanganj

0.75

Confidence Ltd.

Brahmmanbagh, Mohajampur, Narayanganj

3.00

Batteries

0.05

0.25

3

3.

PRODUCTION PROCESS

The production process of lead-acid battery in respect of required materials, basic chemistry and manufacturing steps are briefly described in the following sections. Required materials For manufacturing a lead-acid batteries a number of materials are required including Sulfuric acid, Lead (red, pure, antimonial) Acrylic fiber, Carbon black, Expander, TK Oil and so on. The requirements of these materials varies with the capacity of batteries. In the following Table 02, a list of major materials are presented in respect of various capacity of batteries. Table 02: Location and area of battery manufacturing and recycling plants Sl. No. 01

Materials Red Lead

30 0.5 kg

02

Pure Lead

3.8 kg

03

Antimonial Lead Sulfuric Acid

4.5 kg

04

6.6 L

Capacity of battery in AH 55 80 100 0.90 kg 1.30 kg 1.90 kg 6.2 kg 8.7 kg 11.6 kg 8.0 kg 10 kg 11.5 kg 8.0 L 11 L 13 L

130 2.80 kg 14.0 kg 11.7 kg 15 L

Source: Informal (Engr. Sahhidul Islam, Engineering Complex Limited)

Basic Chemistry The basic chemistry of lead-acid battery is mainly the chemical reaction among lead di-oxide, lead and sulfuric acid as is depicted in Figure 01.

Figure 01: Basic chemistry of lead-acid battery

4

Battery manufacturing process Manufacturing of a lead-acid battery includes a number of steps as are shown in the following Figure 02.

Figure 02: Manufacturing process of al lead-acid battery

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3.

BRIEF DESCRIPTION OF MANUFACTURING PLANTS

A brief description of IDCOL en-listed battery manufacturing plants is provided in the following section in light of some relevant parameters. Number of Workers At present the highest number of workers is operating in Panna Batteries Ltd (585). Thereafter, it is HAMKO and Rahimafrooz having about 500 full time workers. The detail list of workers in terms of gender is provided in the following Table 03. In case of Rahimafrooz, HAMKO and Panna Battery Ltd. the number of workers include both manufacturing plant and recycling plant Table 03: Number of workers based on gender Factory

Number of staff Male Female 500 -

Rahimafrooz Ac. Ltd.

Total 500

Panna Batteries Ltd.

585

550

35

HAMKO Batteries Ltd.

500

470

30

Electro Battery Co. Ltd

230

230

-

RIMSO Battery

150

130

20

Z by A Corporation

30

30

-

Euro Battery Ltd.

54

52

2

White Products Ltd.

202

201

01

ECO Batteries Ltd.

33

33

-

JCo. Batteries Ltd.

33

25

8

Navana Batteries Ltd.

220

220

-

SunTec Batteries Ltd.

177

167

10

Gel Tec Batteries Ltd.

38

37

1

Tamim Batteries Ltd.

45

45

-

A&P Batteries Ltd.

77

72

5

Confidence Batteries Ltd.

330

330

-

6

Capacity of production At present the highest number of battery is manufactured by HAMKO Battery. Their monthly production is about 70,000. But in consideration of manufacturing the solar batteries, it is Panna (30,000). The production of battery and the amount of required lead is depicted in the following Table 04 as is collected informally. Table 04: Average monthly production and required lead Factory

Type of battery production

Rahimafrooz Ac. Ltd.

Electro Battery Co. Ltd

Solar, easy bike and IPS Solar, auto and easy bike, IPS Solar, auto, easy bike, auto, IPS Solar

Production of solar battery/month 15,000

Required lead/month

65,000

30,000

750

70,000

20,000

1000

5,000

5,000

90

RIMSO Battery

Solar, IPS

8,000

6,000

110

Z by A Corporation

Solar

500

500

10

Euro Battery Ltd.

Solar

3,000

300

50

White Products Ltd.

Solar, Auto

6,000

2,000

120

ECO Batteries Ltd.

Solar, IPS

1000

750

25

JCo. Batteries Ltd.

Solar, IPS

2,500

2,000

40

Navana Batteries Ltd.

Solar, IPS, Auto

30,000

4,000

275

SunTec Batteries Ltd.

9,500

500

150

Gel Tec Batteries Ltd.

Solar, IPS, easy bike, rickshaw, auto Solar

1,000

500

20

Tamim Batteries Ltd.

Solar

1,000

1,000

26

A&P Batteries Ltd.

Solar

5,000

5,000

60

Confidence Ltd.

Solar, IPS, easy bike, rickshaw, auto

30,000

10,000

450

Panna Batteries Ltd. HAMKO Batteries Ltd.

Batteries

Average total Production /month 40,000

450

From the above Table 04, it is difficult to correlate with the quantity of required lead and quantity of battery production. Because different suppliers produce battery of varying capacity requiring different capacity of lead as is depicted in Table 02. In addition, the use of automatic technology is another factor to determine the amount of required lead. All of the battery suppliers were found to use manual and semi-automatic process except Rahimafrooz, Panna, Sun Tec, Electro and HAMKO Batteries. Their manufacturing plant seems to be mostly automated. But the most satisfactory automated technology has been observed in Confidence Batteries Ltd. 7

Among the 16 battery suppliers Rahimafrooz, Panna, HAMKO, RIMSO, A&P, White Products, J.Co, Sun Tec and Gel Tec have female staff, of which mostly are engaged in low labour intensive areas like filling, pasting. In addition, in a number of plants , female staff were found to work in kitchen and dining.

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4.

ISO 14001: 2004 AND OHSAS 18001:2007 COMPLIANCES

The ISO 14001:2004/2005 and OHSAS 18001:2007 compliance status in terms of certification agency, date of issuance and expiration of 16 Battery manufacturing plants are mentioned in the following Table 05. Table 05: List of accreditation agency in respect of battery manufacturing plant Battery supplier

Accreditation agency

Accreditation issue date

Accreditation validity date

Parent

Bureau Veritas

ISO 14001:2004 28 Jun 2010

OHSAS 18001:2007 15 Sep 2011

ISO 14001:2004 27 Jun 2013

OHSAS 18001:2007 13 Jun 2014

AJA

6 Jul 2011

1 Nov, 2010

6 Jul 2014

ANAB

SAI Global

18 Jan 2012

22 Dec 2011

31 Oct, 2013 15 Jan 2015

IAF

ISOQAR

5 Mar 2012

5 Mar 2012

5 Mar 2015

5 Mar 2015

AJA

7 Dec 2011

6 Jan 2012

23 Sep 2014

6 Jan 2015

URS

13 Jan 2012

13 Jan 2012

12 Jan 2015

12 Jan 2015

BMQR

22 Dec 2011

22 Dec, 2011

21 Dec 2014

DNV

17 May 2011

17 Dec 2011

URS

17 Sep 2013

17 Sep 2013

21 Dec, 2014 17 May 2014 16 Sep 2016

AJA

1 Feb, 2012

4 Jun, 2012

28 Jan 2015

4 Jun, 2015

Navana Batteries Ltd.

Bureau Veritas

27 Mar 2012

2 Jul 2012

26 Mar 2015

01 Jul 2015

SunTec Batteries Ltd.

AJA

9 Oct 2012

7 Oct 2012

2 Oct 2015

7 Oct 2015

Gel Tec Batteries Ltd.

Care Certification

24 Mar 2012

24 Mar 2012

23 Mar 2015

23 Mar 2015

Rahimafrooz Ac. Ltd. Panna Batteries Ltd. HAMKO Batteries Ltd. Electro Battery Co. Ltd. Rimso Battery Euro Battery Ltd. Z by A Corporation White Products Ltd. ECO Batteries Ltd. JCo. Batteries Ltd.

Subsidiary

IAF

AIAO

22 Dec 2014

16 Dec 2014 16 Sep 2016

Tamim Batteries Ltd.

AIAO

BMQR

18 Jun 2012

19 Jun 2012

18 May 2015

19 May 2015

A&P Batteries Ltd.

IAF

AJA

23 Dec 2012

23 Dec 2012

22 Dec 2015

22 Dec 2015

DAS Certification

15 Jan 2014

15 Jan 2014

14 Jan 2017

14 Jan 2017

Confidence Batteries Ltd.

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5.

MEDICAL FACILITY

It is appreciable that the battery manufacturers and recyclers aware about the medical facility of workers. All battery manufacturers have arranged weekly medical check-up facility except Gel Tec, ECO and Z by A Corporation. Z by A has arranged monthly check-up facility. ECO Batteries and Gel Tec are in the process of engaging doctor. Table 0 6: Arrangement of medical facility Battery supplier Rahimafrooz Ac.Ltd. Panna Batteries Ltd.

Arrangement of Medical Facility Two times per week medical check-up Weekly

Medicine facility All medical facility Basic medicine

HAMKO Batteries Ltd.

Weekly

Basic medicine

Electro Battery Co. Ltd. Rimso Battery Ltd.

Weekly

Basic medicine

Weekly

Basic medicine

Bi-weekly

Basic medicine

Z by A Corporation

Weekly

Basic medicine

White Products Ltd.

Weekly

Basic medicine

ECO Batteries Ltd.

In the process of engagement

Basic medicine

JCo. Batteries Ltd.

Weekly

Basic medicine

Navana Batteries Ltd.

Weekly

Basic medicine

SunTec Batteries Ltd.

Weekly

Basic medicine

Gel Tec Batteries Ltd.

In the process of engagement

Basic medicine

Tamim Batteries Ltd.

Part-time

Basic medicine

A&P Batteries Ltd.

Weekly

Basic medicine

Confidence Batteries Ltd.

Weekly

Basic medicine

Euro Battery

10

6.

RECYCLING FACILITY

At present Rahimafrooz, Panna Battery and HAMKO have independent recycling facility with ISO 14001:2004/2005 and OHSAS 18001:2007 compliant. The list of accreditation agency, date of issuance of compliance certificate and date of expiration are mentioned in the Table 7. Table 7: List of accreditation agency in respect of battery recyclers Battery supplier

Accreditation agency Parent agency

Rahimafrooz

Subsidiary agency

Accreditation issue date ISO 14001:2004

OHSAS 18001:2007

Accreditation validity date ISO 14001:2004

OHSAS 18001:2007

Bureau Veritas

8 Mar 2013

8 Mar 2013

7 Mar 2016

7 Mar 2016

AJA

5 Jan 2013

6 July 2013

7 Jan 2016

6 Jul 2014

SAI Global

18 Jan 2012

18 Sep 2012

15 Jan 2015

2 Aug 2015

IAF Panna Battery Ltd HAMKO Battery Ltd.

ANAB

HAMKO has two rotary furnaces of which one is with capacity of 5 ton and the other one is 8 ton. There are 2 kettles with capacity of 10 ton lead. The monthly capacity is 500 ton, with an assumption car battery 70% and 30% is inverter, solar and others. Batteries are coming without acid, breaking is manually done outdoors and under roof. In Rahimafrooz, there are one rotary furnace with capacity of 10 ton and two kettles with 10 ton capacity. The monthly capacity is 250 ton lead per month. In Panna Battery, there are two rotary furnaces with capacity of 8 ton and two kettles with capacity of 10 ton. The monthly capacity is 500 ton lead per month, 20 ton lead per day and 5 days per week. Breaking of batteries is done without roof, very dusty working condition. For recycling, the other suppliers have made formal agreement with these three recyclers, which conforms that the recyclers will recycle the expired batteries as are submitted by these suppliers.

Figure 03: Basic recycling process

In case of EHS compliance, there was requirement to significantly improve the recycling plant of Panna. Accordingly, they have been found to adopt required mitigation measures as are shown in Appendix-C (Annex-4). 11

The Plastic casing of expired batteries are broken manually by using hammer. Thereafter, the remaining electrolyte is pour in a tank having water to neutralize the acid. After that, the neutralize acid is let out through a drain to the nearby tertiary collector like canal. The lead bar is then taken to the recycling plant for melting and casing is crushed to for plastic chips as are required for manufacturing a new battery casing. The expired battery breaking process is shown as follows through Photographs 01-04.

Photograph manually

01:

Separation

of

cover

Photograph 03: A view of neutralization tank

by

Photograph 02: Pouring the electrolyte to neutralization tank

Photograph 04: Separation of lead bar and separator

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7.

EFFLUENT TREATMENT PLANT

All manufacturing plants have effluent treatment plant (ETP) facility. But there is difference among technology, efficiency and effectiveness. In this regard, there could be an environmental audit to assess these ETP and formulate required improvement initiatives. The arrangement of ETP in terms of capacity and sludge disposal arrangement is shown in Table 08. Table 08: Arrangement of ETP Battery supplier

Sludge management option

Rahimafrooz Ac. Ltd.

40

Use as landfill

Panna Batteries Ltd.

10

Do

HAMKO Batteries Ltd.

40

Do

Electro Battery Co. Ltd.

20

Do

Rimso Battery

5.0

Do

2

Do

Z by A Corporation

0.5

Do

White Products Ltd.

24

Do

ECO Batteries Ltd.

5.0

Do

JCo. Batteries Ltd.

15

Do

Navana Batteries Ltd.

3.5

Do

SunTec Batteries Ltd.

8.0

Do

Gel Tec Batteries Ltd.

2.0

Do

Tamim Batteries Ltd.

10

Do

A&P Batteries Ltd.

2.0

Do

Confidence Batteries Ltd

30

DO

Euro Battery

8.

3

Capacity in m /day

AIR TREATMENT PLANT

All battery supplies and expired battery recyclers of IDCOL SHS have made available of air treatment facility. But there is difference of technology and effectiveness. So, there is necessity of providing training support on this aspect.

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9.

STATUS OF BASIC EMS AND OHS COMPLIANCE Table 9: Compliance of basic EMS and OHS aspects

Battery suppliers and recyclers

Application of PPE

Status of housekeeping

Training on EMS and OHS

Availability of trained professional

Status of documentation

Operation of ETP and ATP

Arrangement of fire fighting

Score

Rahimafrooz Accumulators Ltd. Panna Battery Ltd. HAMKO Battery Ltd. Electro Battery Co. Ltd. Rimso Battery Ltd. Euro Battery

S

S

S

S

S

S

S

21

S

MS

S

S

S

MS

S

19

MS

S

MS

MS

S

S

S

16

MS

S

S

MS

S

S

S

19

NIP

MS

S

MS

S

MS

MS

15

NIP

MS

MS

NIP

S

MS

MS

13

Z by A Corporation White Products Ltd. ECO Batteries Ltd. JCo. Batteries Ltd.

MS

MS

MS

NIP

NIP

MS

MS

12

MS

MS

MS

MS

S

S

S

17

MS

MS

NIP

MS

MS

S

S

15

MS

MS

MS

S

S

MS

MS

16

Navana Batteries Ltd.

S

MS

S

S

MS

MS

MS

17

SunTec Batteries Ltd.

S

MS

S

MS

S

MS

S

18

Gel Tec Batteries Ltd.

MS

MS

NIP

NIP

MS

MS

MS

12

Tamim Batteries Ltd.

MS

MS

NIP

MS

MS

S

MS

14

A&P Batteries Ltd.

MS

S

MS

MS

S

S

S

15

Confidence Batteries Ltd.

S

S

S

MS

S

S

S

19

NIP=Need improvement (1), MS=Moderately satisfactory (2), S=Satisfactory (3)

The status of EMS and OHS compliances by manufacturers and recyclers in respect of some basic parameters are shown in the abovementioned Table 9, where NIP, MS and S stand for Need Improvement, Moderately Satisfactory and Satisfactory respectively with a sample value 1, 2 and 3 respectively. Based on the Table 9, it can be said that Euro Battery, Z by A, Gel Tec and Tamim Batteries Ltd. need significant effort to reach the level of satisfaction.

10.

RECOMMENDATIONS AND CONCLUSIONS

In general, the response of battery manufacturers and recyclers on EMS and OHS have been observed as significantly positive. They have installed ETP, ATP and tried to ensure PPE properly. But it assumes that in general there is inadequacy of trained professional on EHS in Bangladesh. So, to reach a complete level of satisfaction, the relevant stakeholders are requested to think over the following aspects because Figures 01-04, give clear message about the adverse impact of improper management of lead: 

To audit the capacity and effectiveness of ETP and ATP



To train about proper application of PPE



To aware about safe disposal of ETP sludge



To orient them with EHS management practice of developed countries



To monitor the lead content in blood of the workers working in the higher lead exposed area.

Figure 04: Impact of long term exposure to lead

Figure 05: Early symptoms of lead poisoning

Figure 06: Impact of lead poisoning to women

Figure 07: Impact of lead poisoning to children

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Appendix-A

Requirements of ISO 14001:2004 and OHSAS 18001:2007

16

Annex-1: Major requirements of ISO 14001 and OHSAS 18001

Clause Requirement no. 4.1 General Requirements

4.2

4.3

4.4

4.5

4.6

Major issues in brief

This clause requires to clarify whether the EMS system of client is properly adopted, maintained and updated? Environmental Policy This clause requires to clarify whether the EMS system of client is communicated with well structured EMS Policy as is to be adopted and authorized by the top management of client? Planning This clause requires to clarify whether the EMS system of client is based on a systematic planning like written procedures, hierarchy of risk management measures, process to disseminate information and regulations and so on ? Implementation and This clause requires to clarify whether the EMS Operation system of has made adequate arrangement to ensure proper implementation and operation through deployment of adequate number of competent personnel, regular capacity building arrangement, emergency preparedness measures and so on ? Checking and Corrective This clause requires to clarify whether the EMS Action system of has made adequate arrangement for continual improvement through proper regular checking and adopting corrective actions? In this regard, it is expected that there will be arrangement of performance measurement and monitoring mechanism; accidents, incidents, noncompliance and corrective and preventive actions review procedure; arrangement of keeping records and above all internal audits. EMS Management This clause requires to clarify whether the EMS Review system of has made adequate arrangement of keeping regular communication with the top management through regular management review meeting and keeping minutes of the meeting.

NB. The above table provides requirement of ISO 14001: 2004. However, the requirements of OHSAS are almost same but in case of environmental management system it deals with occupational health safety issues.

17

Appendix-B

EHS Compliance of Battery Manufacturing Plants as have been enlisted after July, 2012

18

Annex 1- EHS Compliance of Tamim Batteries Ltd.

Photograph : Checking the first aid facility

Photograph : Monitoring the operation of ETP

Photograph : A view of ETP

Photograph : Aview of fume exhaust arrangement

19

Annex 2- EHS Compliance of A&P Batteries Ltd.

Photographs : Different views of ATP system

Photograph: Application of PPE

Photograph : A view of emergency exit plan

20

Annex 3- EHS Compliance of ECO Batteries Ltd.

Photographs: Different views of ATP system

Photographs: Different views of ETP system

21

Photograph: External fire fighting arrangement

Photograph: Internal fire fighting arrangement

22

Annex 3- EHS Compliance of Confidence Batteries Ltd.

Photographs: Different views of ETP system

23

Photographs: Different views of ATP system

A-S Type

Foam Type

CO2 Type

Photographs: Fire fighting arrangement 24

Photograph: Evacuation Plan during disaster

Photograph: Application of signage 25

Photograph: Disclosure of compliance standard

Photographs: General washing and prayer facility

26

Appendix-C

EHS Compliance of Panna Recycling Plant

27

Annex 4- EHS Compliance of Panna Battery Recycling Plant

Photographs: Different views of Panna Recycling Pant

28