Environmental & Social Report for Vsbk

December 30, 2005 E1394

ENVIRONMENTAL & SOCIAL REPORT FOR

A Guidance document for Entrepreneurs and Project Auditors

Prepared by

Environment Systems Branch Development Alternatives 111/9-Z, Kishan Garh, Vasant Kunj, New Delhi – 110 070, INDIA Ph : 91 11 26134103, 26890380, Fax : 91 11 26130817 Email : [email protected] Website : www.devatl.org December 30, 2005

Content

Sections Title Page number Section I Brick Manufacturing in India – Environment and Social 1 issues Section II The VSBK approach – an effort towards greening the brick 5 industry Section III Managing possible issues in VSBK – that still needs to be 7 considered Section IV The proposed Environmental and Social Management Plans 9 Section V Cash flow structure 12 Section VI Monitoring mechanism and Reporting format 13 Section VII Environment and Social Reporting format 15 Section VIII Laws Applicable to VSBK 18

Annexure I Exhaustive list of environmental and social issues in VSBK Annexure II Issues that needs to be managed in VSBK Annexure III Community Benefit plan Annexure IV Environment and Social Reporting form for VSBK entrepreneur

Development Alternatives December 30, 2005

BRICK MANUFACTURING IN INDIA - Environmental & Social issues

Section I

1.1 INTRODUCTION TO THE PROJECT

Burnt bricks are the most popular building material in India. However the conventional brick making practices in India, including clamps and Bull Trench Kilns are highly energy inefficient and therefore polluting. The search for cleaner brick production technologies has led to the identification of Vertical Shaft Brick Kiln technology. The Vertical Shaft Brick Kiln (VSBK) was originally developed in China and is an energy efficient technology for fired clay brick production economizing on fuel consumption by between 30-50%. The brick industry thus offered a large potential of reduction of Greenhouse Gases through this alternative brick production technology known as VSBK. Realising the potential for accrual of carbon credits, the World Bank Community Development Carbon Fund (CDCF) is supporting Technology and Action for Rural Advancement (TARA) for propagation of this technology on a large scale. In this project, TARA will facilitate the setting up of 126 VSBKs by private entrepreneurs in the states of Chattisgarh, Madhya Pradesh, Rajasthan and Orissa in India. The emission reductions generated therefrom will be purchased by the CDCF as Certified Emission Reductions (VERs) at an agreed price.

The participants in the project will be TARA (as the technology provider), entrepreneurs (as project owners), brick workers (as beneficiaries) and CDCF (as buyer of VERs through TARA). For entrepreneurs to be eligible to earn VER benefits under this project, certain non-negotiable and desirable conditions will have to be complied with. These conditions are elaborated in Section IV.

The various sections in this document provide an overview of the environmental and social benefits in case of VSBK as compared to the traditional brick sector in India. It also identifies the environmental and social issues that may still need to be addressed in VSBK and provides a management plan for priority issues. The document provides the Community Benefit Plan (CBP) besides providing the format for reporting on environment and social performance by the entrepreneurs. The document further elaborates the roles and responsibilities of various participants in the project including the mechanism for flow of funds.

1.2 INTRODUCTION TO BRICK MANUFACTURING IN INDIA The present demand is estimated as 120 billion bricks per year. There are two categories of issues in brick making industry: environmental and social. To see the exhaustive list of issues in brick manufacturing refer to annexure I. The choice of technology for firing of bricks depends generally on factors such as scale of production, soil and fuel availability, availability of skilled manpower and business considerations such as profitability and availability of finance. The popular brick making technologies are clamps, movable chimney and more recently fixed chimney kilns. The small scale brick entrepreneurs are confronted with environmental regulation and face numerous challenges for survival, considering the situation that there are very limited options for them to adopt for their brick business.

Development Alternatives 1 December 30, 2005

The workers in the brick industry are subject to extreme working conditions and poor remuneration. The brick moulder families are contracted through middlemen and usually belong to poor districts of Uttar Pradesh, Bihar, Chattisgarh and Orissa. Both male and female member of the families are engaged in brick making. Children are not employed as such, but usually they accompany their parents to the work place. There is seldom any arrangement for toilets or drinking water facilities. The work force is paid on basis of quantum of work and against completion of certain tasks. Operations are mostly manual and under present conditions 100 to 150 days of employment is available.

1.3 ENVIRONMENTAL ISSUES IN BRICK MAKING Brick making is recognized as a resource intensive and highly polluting industry by Central Pollution Control Board (CPCB). This industry is currently based on decentralized production activity while using energy intensive, resource depleting and highly polluting technologies and production methods. In India, most of the processes deployed in brick making are with low inputs of technology and archaic techniques. 1.3.1 Extensive energy usage Indian brick industry is unorganized with small scale production units, the numbers in the range of more than 100,000 clusters spread across rural and peri-urban areas in the country. With an average consumption of 18 tonnes of coal per lakh bricks, it consumes about 24 million tones of coal per year which is about 8% of the total coal consumption of the country. In addition it also consumes several million tones of biomass fuels. The share of energy in total cost of brick production is 35%-50%. 1.3.2 Inefficient resource utilisation The environmental problems in the brick industry have been exacerbated by cheap access to resources such as soil, water, coal, biomass and labour. This results in irreversible environmental damage in terms of depletion of top soil, water and coal. Soil Soil being the raw material for brick making, is being consumed in huge amount by the brick industry. The kiln itself occupies considerable land which is subjected to high temperature making it unfit for agriculture in future (after the site is abandoned). The fast depletion of arable land thus caused due to brick making is a matter of grave concern to India. Addressing this issue, utilization of fly ash by all kilns within 100 km radius from thermal power plants has been made mandatory. Water Brick industry also consumes considerable amount of water. Most of the brick kilns are therefore sited along the Gangetic belt. However water utilization is generally regulated by local Govt. authorities. In advent of water scarcity, water intensive industries are temporarily closed down by the authorities to preserve water for drinking and other necessary usages. Coal The wasteful utilisation of coal by the brick sector accelerates the depletion of this valuable national resource.

1.3.3 High Air Pollution

With unabated increase in the price of coal and higher costs of transportation, the brick industry is not left with much choice but to opt for poor grade coal. The poor quality of coal (low calorific value) increases the consumption rate. This factor added with the inefficient combustion technologies cause high level of air pollution. While the emission standard for Suspended Particulate Matter (SPM) is 750 mg/Nm3 to 1000 mg/Nm3, the actual emissions from existing technologies range from 600 mg/Nm3 to 1770 mg/Nm3. The high level of suspended particulate matter thrown out by the kilns causes damage to property and crops.

COMPARISON OF VARIOUS TRADITIONAL BRICK MAKING TECHNOLOGIES

Kiln type Typical production Approx Coal consumption Stack capacity no. of (tones per lakh emission kilns bricks) (lakh bricks / year) (mg/Nm3) BTK-fixed 30-100 25000 18 600 chimney BTK-moving 20-80 8000 18 1770 chimney High draft or zig-zag firing 30-50 200 <18 850 or down draft kiln Similar to movable Clamps 0.5-10 >60,000 >18 chimney (not monitored)

High usage of coal as a fuel also leads to considerable amount of Greenhouse Gas (GHG ) emissions. Considering the average specific energy consumption is -6 4.5x10 Tj/ brick, multiplying by 18,44,000 bricks per unit, the CO2 emissions contributed by 100,000 brick kilns is 78 tonnes/annum.

1.3.4 Significant generation of Bottom Ash

As shown in the table above comparing various brick making technologies, large amount of coal is used for firing of bricks. The bottom ash obtained as a residue from combustion of coal causes air pollution. Some part of this bottom ash is used as an insulation material for the firing chamber, while the rest gets dispersed by wind and rain.

1.4 SOCIAL ISSUES IN BRICK KILNS The social issues of brick making are mostly related to workforce. They can be looked as two different categories based on the scale of operation: kiln owned by the brick making community and community engaged as laborers.

Clamps (small production capacity) are owned and operated by brick making communities as a traditional occupation. These communities live in permanent settlements and earn their living through selling bricks. On the other hand, the large producers (BTKs) employ labour on contract. They are paid against completion of specific tasks such as moulding of 1000 bricks, transportation of 1000 green bricks etc. The workers are generally migratory population moving in families. They live in make shift shelters in the vicinity of the kiln. Generally shelter is provided by the entrepreneur.

1.4.1 Occupational hazards Brick making involves crude techniques causing considerable worker drudgery. Brick workers, especially moulders are exposed to the sun for long hours. They are exposed to high concentration of dust while manual breaking of coal. There is also the risk of exposure to dust (from bottom ash spread on the kin) and open fire during manual coal feeding. The workers have to walk on hot surface (top of the furnace) while monitoring and regulating the fire. They are also exposed to high concentrations of respirable suspended particulate matters (RSPM), during monitoring and regulating the fire, as the furnace chamber is covered with ash (ash acts as insulator). After the Government notification making fly ash utilisation mandatory by law, the work force are at the risk of exposure to high concentration of RSPM as the general practice is to mix fly ash and clay manually. Similar exposure also occurs due to open dumping and storage of fly ash. Transportation of green and red bricks is done by head load. Generally 9 to 12 bricks are carried at a time as head load. Carrying head loads on a regular basis causes health problems, especially in women. Even though the brick workers are exposed to these occupational hazards, coverage under any sort of insurance or medical facilities is virtually unheard of.

1.4.2 Living conditions The tight margins in the brick market coupled with rising costs of energy result in poor remuneration for majority of brick workers and deterioration in the quality of life. The firemen and ‘mistries’ receive better remuneration but are forced to work under severe conditions of heat, dust and pollution. There are no avenues for brick workers to acquire new and upgraded skills for running and managing their own brick enterprises. Most of the times, children accompany their parents to the work place instead of attending school. One reason for this being the isolated location of brick kilns from human settlements. In rural India, it is a common practice to defecate in the open, which is a major environmental and health concern. Though the Government of India has been running extensive programmes for provision of free toilets, it is seen that these toilets are largely left unused. The reason for this being that the lack of change in behavioral patterns in favour of using enclosed spaces for defecation. Similar is the case with brick workers. Consequently, there is no provision of toilet facilities at the kiln sites, even though this is mandatory by law.

1.4.3 Periodic (seasonal) employment Due to the seasonal nature of brick industry, the workforce gets employment for a limited period of six months per annum. It closes down in peak summer and monsoons. During this period, the workforce has to look for alternate options of earnings. Generally they move out to agricultural fields and get engaged as agricultural labourers. But on the advent of the next brick making season, there is no guarantee to get employment in the same kiln. Therefore this community has to undergo a job hunt twice every year.

1.4.4 Payment Mechanism In the brick sector, labour is brought in through a contractor (from distant places). Since they are not on the payrolls of the kiln owner, they are not covered under the current labour laws, e.g. Minimum Wages Act. For jobs such as transportation of green bricks which are done by individuals, both males and females are paid separately and at equal rates. Brick making jobs are performed by the husband - wife couple. However, there are no separate wages for women labour for jobs such as brick moulding (which are performed together by several members of a family) and payments are made on piece rate to a family. There is no practice of systematic spending or savings. The male member holds the power of spending at his will thus remaining in the vicious cycle of poverty for ever.

THE VSBK APPROACH – an effort towards greening the brick industry

Section II

2.1 THE VSBK APPROACH The primary problem that will be addressed by VSBK is the environmental degradation caused through unorganized and wide scale brick production activities. The VSBK technology has demonstrated an environment friendly and commercially viable solution, specifically suited for producing 15 to 20 lakh bricks per annum. Salient features of VSBK technology are: energy efficiency, lower GHG emissions, lower dust emissions, reduced worker drudgery and potential to enhance operator skill through training. Mitigation / management of negative environmental and social impacts that are already achieved through the VSBK approach are discussed below (refer annexure I).

2.2 MANAGING ENVIRONMENTAL IMPACTS The Central Pollution Control Board has issued a voluntary endorsement of the VSBK technology. This note has been directed to all the state pollution control boards and regulatory bodies to consider VSBK technology as a viable alternative. 2.2.1 Energy efficiency VSBK is 30% energy efficient when compared to traditional kilns by technological design. Therefore, it requires less fuel. Moreover it allows use of low grade fuels such as lignite and industrial waste with residual calorific value such as sponge iron waste, rice husk, boiler ash etc. 2.2.2 Optimal resource utilisation VSBK takes less space than other kilns, thus preserving land and vegetation. The usage of soil is reduced by utilizing various industrial wastes such as fly ash, stone dust etc. The inherent property of less resource use for VSBK directly contributes to the socio-economic and environmental benefits. 2.2.3 Lower Air Pollution Being an energy efficient kiln, VSBK reduces air pollution by a factor of 3. SPM emission from VSBK is as low as 250 mg/Nm3, lower than any other existing kilns. GHG emission is also reduced by the virtue of increased energy efficiency.

2.3 BRINGING IN POSITIVE SOCIAL CHANGES Several measures are designed to ensure sustainable livelihoods for the brick worker communities. 2.3.1 Minimised occupational hazards

Probability of accident and malfunction is very low in VSBK because of the very design of the kiln. More over skill up gradation trainings are offered to ensure safer and better operation. Occupational hazards during loading-unloading are also lower in VSBK. Green bricks are arranged on the top of the stack manually. There is arrangement for smoke control during loading by using dampers. Unloading is done through trolleys and crow bars. Tongs are used to handle hot bricks. Transportation of burned bricks to the storage area is done by trolleys. The concern of exposure to fly ash and other industrial waste, while manual mixing, is addressed by allowing mechanical mixing.

2.3.2 Improvement in Living conditions Through the trainings (offered by TARA) VSBK offers opportunity for higher number of skill based livelihoods for moulders, fire-masters and supervisors. This is likely to result in higher remuneration for the brick worker community. The VSBK production system closely approaches rural industrial activity which can be used to improve working conditions for the families of the brick workers.

2.3.3 Year long employment By design, the number of days of operation per annum can be extended to 225 days ensuring livelihood security for the brick workers. The kiln can be covered with low cost roof which will allow operations even during monsoons. Therefore the number of days of operations per annum can be therefore extended to 225 days ensuring assured employment.

MANAGING POSSIBLE ISSUES IN VSBK - that still needs to be considered

SECTION III

3.1 ISSUES IN VSBK From the previous chapter it has become very clear that VSBK technology has multiple benefits in addressing issues concerning resource extraction and use, occupational health and safety, pollution problems and compliance to legal requirements and in contributing to providing clean/ healthy/ and dignified employment opportunities. It is also seen that due to decentralised production systems it can contribute to enhancement of the local economy. The purpose of this Environment & Social Report is to provide guidelines in order to enhance the above stated benefits of VSBK. Implementation of these guidelines will lead to: . Improved environmental performance . Improved product quality . Higher profits . Skill development

3.2 CRITERIA FOR SELECTING ENVIRONMENTAL AND SOCIAL ISSUES An exhaustive list of probable issues in brick making has been shown in annexure I. the list shows activity, aspect, impact and action needed to be taken to manage the impact (if any). The impacts are colour coded as follows:

. Red for negative impact that need to be addressed urgently

. Orange for adverse impacts that may not be attended immediately but have to be considered latter

. Green for positive impacts of VSBK

. Blue for issues that has been already managed by VSBK by design The list also contains justification for the actions, if required or not, against each impacts with respect to issues which are already managed in VSBK by design, and those which demand further attention (refer annexure I, column ‘Action required or not with justification’). The selection of the issues, which demand further attention (red category), is based on the extent and severity of impact, regulatory requirements and feasibility of implementation. The impacts which have severe consequences may pose threat to the business. Such as harsh working conditions may reduce worker productivity leading to monetary loss for the business. Coal use is another example which is directly

proportional to GHG emissions. Substituting coal by industrial waste (containing residual calorific value) can reduce both expenditure on fuel and GHG emissions dramatically. Regulatory compliance, such as meeting the lower emission standards of VSBK, can only happen when the kiln operates under optimal conditions. Such a situation will not only lead to environmental conservation but also will ensure operational efficiency. VSBK being a new technology, comes in a package with technical back up support. The package includes training and capacity building, selective mechanisation, operational protocol etc. Therefore it is feasible to do things such as training in VSBK which might not be possible in other types of kilns.

3.3 POSSIBLE ENVIRONMENTAL ISSUES IN VSBK As already discussed brick making is associated with excavation of soil. The top soil containing humus, roots etc. is not used in brick making industry and is rejected. However, this portion of the soil is vital for vegetation growth. In the absence of proper top soil conservation practices, the excavated top soil is lost either by run off or dispersion by wind. Thus, continual loss of this valuable top soil may render the soil infertile. In addition, approximately 20 tonnes of bottom ash is generated annually from each VSBK operations. Majority of this bottom ash is used in brick making wherever soil mixing is done mechanically. It is anonymously used as insulator or as water proof material to cover green bricks. Traditionally, this bottom ash is also used as a padding material for storage of red bricks to avoid breakage while stacking.

3.4 POSSIBLE SOCIAL ISSUES IN VSBK The traditional brick moulding practices are followed in VSBK as well. Manual mixing and preparation of soil is a general practice. The workers are exposed to high level of respirable dust while doing so, especially while handling fine particles such as fly ash. Open transportation and on-site storage of such materials also pose health risk to the workers. Exposure to fine particles lead to pulmonary and skin diseases. In addition, as at other brick kiln sites, there are no toilet facilities in VSBK units as well and worker’s insurance facilities too are unheard of. Moulders spend long hours under the sun in uncomfortable working postures (ergonomics) on a daily basis. This may lead to adverse health impacts deteriorating the productivity of workers. As stated earlier, children often accompany their parents to the workplace. As a result they are exposed to dust, heat and sun. Exposures to these kinds of extremities, in tender age, may lead to severe impairments. It has been seen that it is the women, who are most concerned to feed the family and arrange for other basic requirements. On achieving financial independence, women are able to bring in well being through systematic spending and savings. On the contrary, men of labour communities often end up spending on addiction, gambling etc., leaving little or nothing for the family. Therefore, the prevailing practice of delivering the family income to the male member prohibits the family to break the vicious cycle of poverty.

THE PROPOSED ENVIRONMENTAL AND SOCIAL MANAGEMENT PLANS

SECTION IV

4.1 THE DRIVING FORCE FOR ENVIRONMENT AND SOCIAL MANAGEMENT IN VSBK VSBKs are largely owned by entrepreneurs who are already in brick making business with other types of kilns. As already stated in section 1, in traditional brick making practice the management of environmental and social issues are grossly neglected. Therefore the driving force of the environment and social management plan for VSBK is to influence the behavioural pattern of the entrepreneurs. The focus will be on trust building, improve kiln performance and demonstrate enhanced profitability. The management of environment and social issues will incur additional cost to the entrepreneur. In order to keep parity between the benefit received from CDCF project and the cost incurred to meet the project requirements, the issues that needs to be managed in VSBK are classified into two categories: non-negotiable, and desirable. It should be noted that the cost of land required for setting up VSBK has been included in the profitability ratios and calculation of IRR.

4.2 ENSURING IMPLEMENTATION OF ENVIRONMENT AND SOCIAL MANAGEMENT The responsibility of ensuring the management of issues which are non-negotiable will be taken by TARA. The non-negotiable environmental and legal issues associated with VSBK will be implemented on the condition that if the entrepreneur wishes to avail the CER benefits, the conditions have to be met and only then will the kiln be stabilised by TARA as the Technology provider. For management of desirable issues, capacity building of entrepreneurs will be undertaken. The focus will be to demonstrate the benefits of doing so in terms of financial bottom-line for the entrepreneur, and associated environmental and social benefits to the VSBK entrepreneur. To ensure improvements in the living conditions of worker community, several measures will be undertaken in this project. Toilet facilities for the brick workers will be constructed in consultation with the community with financial contributions from the entrepreneur and CDCF. In addition, insurance schemes covering health and accidental risks will be introduced, the premiums for which will be paid out of community’s share of the carbon revenues. As regards the cultural property, it will be ensured that required care is taken from the crew to not damage the nearby cultural properties like temples/shrines in the first instance. If during excavation, some relics or remains or locally important cultural property like idol are found, the local authority would be notified and work will progress only after the directions issued by such authority have been implemented. This aspects will be taken care of by incorporating it in the sub-project agreement with the entrepreneur. The management of these issues, however, require considerable costs to be incurred. Keeping in view the funds available for carrying out such work, issues to be managed have been prioritised. Besides ensuring mechanisation of unloading of fired bricks and required training for efficient operations, provision of toilet facilities and insurance schemes have been included in the list of non-negotiables.

4.3 MANAGEMENT OF ISSUES: NON-NEGOTIABLE 4.3.1 Environmental . All applicable environmental regulations applicable to VSBK such as: - No objection certificate (NOC) from pollution control board - Height of chimney: pollution control norms (6.5m – 8.5 m from the loading platform)

. Use of internal fuel: increases energy efficiency and reduces emissions . Proper storage of fly ash (only in those kilns which fall within 100 km. radius of thermal power plants). . Analysing calorific value of fuel in 6 kilns, environment monitoring in 6 kilns, monitoring environment practices in14 kilns, and monitoring of drinking water in 14 kilns to be organised by TARA. 4.3.2 Social . Mechanisation of unloading of fired bricks . On site training of fire crew . Training of moulders on material handling and preparation . First aid box available on site . Covering of face with a clean cloth during manual mixing of soil, coal breaking and unloading . Provision of helmets while lowering trolley . Health and Accidental insurance for brick workers at kiln sites . Provision of toilet facilites for brick workers at kiln sites . Compliance with Cultural Property Safeguards Policy (OPN 11.03 of the World Bank - under revision)

4.4 MANAGEMENT OF ISSUES: DESIRABLE 4.4.1 Environmental . Utilisation of industrial waste: to conserve soil . Restoration of top soil . Bottom ash (generated from VSBK) put back in green bricks, wherever possible, especially in mechanised mixing 4.4.2 Social . Adoption of selective mechanisation to overcome drudgery . Posters of Dos’ and Don’ts and safety measures displayed at VSBK site . Training of moulders on mechanised mixing . Use of shaft lid cover for improving work conditions at loading area . Provision of clean drinking water on premises . Provision of clean cooking devices

Table 4.1: Responsibility and cost chart for management of environment and social issues

Catego Issues Responsibility Cost (in Rs.) for Remarks ry TAR Own Worke CDCF Entrepre A er rs neur Non- NOC from pollution control board,  0 Legal Requirement, not negotia regulatory agencies attributable to participation in ble CDCF project Use of internal fuel  0 No additional cost

Height of chimney  0 Part of capital cost already Mechanisation of unloading  0 included in BOM. Therefore no additional cost Provision of First Aid Box 400 Training of fire crew  0 Included in TARA service Training of moulders  0 charges

Proper storage of fly ash  2000 For sheeting, bricks to be provided by entrepreneur (recurrent cost, twice during the project time) Covering of face with clean cloth during  500 20 m*Rs 25/m (recurrent cost, breaking of coal and unloading once a brick season) Provision of shoes to firing crew (12)  5400 Rs 450/pair (recurrent cost, twice during the project time) Provision of helmets to unloaders (4)  1000 Rs 250/helmet Health and accident insurance  0 No additional cost Provision of toilet facilities  25,00 25,000 0 Compliance with Cultural Property  No additional cost Safeguards Policy Total ( One time cost) 26,400 Total (Recurring cost) 18,800 Desira Utilisation of industrial waste  0 No additional cost ble Restoration of top soil   0 No additional cost Selective mechanisation (pug mill and  1,25,000 hoist) Posters of Dos’ and Don’ts  0 No additional cost Training of moulders  0 Included in TARA service charges Use of shaft lid cover  15,000 Provision of clean drinking water  15,000 Provision of clean cooking devices to   6,000 worker community Total (One time cost) 161,000 CASH FLOW STRUCTURE

SECTION V

TARA, on behalf of the project, is the common focal point and organisation that has the responsibility of servicing the VSBK enterprises and the World Bank. This relationship is reflected in the arrangements. TARA has a contractual agreement with VSBK entrepreneurs as a technology provider for delivery of services. Within this agreement, additional clauses for transfer of CARBON RIGHTS to TARA will be in introduced. The project team has worked out “Non–Negotiable” conditions pertaining to Environmental and social performance that will be applicable to VSBK entrepreneurs desirous of availing carbon benefits. On the other hand, TARA will have an agreement with the World Bank to encash the carbon benefits and apportion them between the VSBK entrepreneurs, brick worker communities and TARA itself based on VSBK performance alone. The VSBK entrepreneur will have additional reporting requirements to furnish information to TARA. TARA will compile the information, verify the records and performance and arrive at a figure for “Certified Emission Reduction (CER)” for each VSBK. The cumulative CERs will be reported to the World Bank on an annual basis by October each year. TARA will encash the CERs reported and receive the money; which will be accounted for as a separate TARA – CDCF account. The transfer of carbon benefits to the VSBK entrepreneur will be done through bank drafts or cheques. TARA will also receive its share from the TARA-CDCF account; an annual utilisation certificate will be provided to the World Bank.

World Bank CERs CER Information benefits E&S Reporting

Information TARA Log book Worker E&S Reporting community

VSBK 1 VSBK 1 VSBK 1 VSBK 1

MONITORING MECHANISMS AND REPORTING FORMAT

SECTION VI

This Section provides the background of disclosure and reporting requirements along with formats for Environmental and social performance reporting by the entrepreneurs.

6.1 DISCLOSURE OF ESR IN PUBLIC DOMAIN The Environment and Social Management plan is required to be disclosed and kept in public domain, for 60 days, in order to receive public comments. Accordingly, TARA will display printed information (in local language) in KVICs, District Collectors office and State Pollution Control Board. TARA will also host it in VSBK website.

6.2 OVERALL REPORTING FORMATS FOR ENTREPRENEURS ON ENVIRONMENT & SOCIAL PERFORMANCE

The reporting formats are prepared in a way enabling better understanding and monitoring of implementation of the ESMP (refer Annexure IV for detailed reporting format for entrepreneurs). The reporting format requires the entrepreneur to fill general information about the kiln, various legal obligations relating to environment and social issues in operating the kiln including the siting of the unit, selective mechanisation options adopted, workers skill development measures taken, actions undertaken to provide job security for various categories of workers, measures adopted to enhance the self help capacity of the workers.

6.3 MONITORING MECHANISMS & PROCEDURES

Progress of the set environment and social plans, benefiting the workers and the communities, shall be monitored at two distinct tiers. At the first tier, the entrepreneur accounts for how the environmental and social concerns are addressed at the plant level, using the ESR reporting formats as provided in Annex IV Based on the above reports TARA will arrange for analysis of calorific value in 6 kilns, environment monitoring in 6 kilns, monitoring of environmental practices in 14 kilns and water monitoring in 14 kilns, on an annual basis. The proposed parameters are as follows:

Energy Environment  Calorific value of coal  RSPM at workplace (loading and unloading area)  CO and SPM at stack The information obtained from the entire exercise, from various sites across the state, shall be analysed and complied in the form of a Status Update Report by TARA. This report shall be submitted as a feedback to the district collector, state authorities i.e. Department of Environment and Department of Industries.

At the second tier, intermittent checking is carried out by independent third party verifiers engaged by either the financers or the state pollution control boards.

A schematic diagram below depicts the proposed reporting and monitoring mechanisms.

SPCB, DoI, DoE Obtaining NOC

Status Update Report Operation ESMP al Guidelines Environme ntal & Enhanced Social Performan Worker Sustainabili ce & Benefits Communi ty Visibility ty Benefits

Third Party At Plant Level Verification At Community Entrepreneur Level Reporting

Schematic diagram depicting reporting and monitoring mechanisms

ENVIRONMENT AND SOCIAL REPORTING FORMAT

SECTION VII

The environment and social reporting format for the entrepreneur is given in annexure IV. The purpose is two fold: documentation for TARA, and risk minimizing checklist for entrepreneurs. There are three categories of risk to VSBK entrepreneurs: financial loss by attracting legal penalty, reduced profit due to sub-optimal kiln operations by untrained workers and productivity loss due to absenteeism resulting from unhealthy working conditions. The ESR provides a checklist of all requirements that minimize the above stated risks. It also looks at the issues of worker community benefits such as children education, improvement of standard of living etc. The ESR Format The ESR format has five sections: General details, Risk minimization by averting penalty, Waste utilization, Maximize productivity by Skill development and retention, and Worker health & safety. Following are the explanations for each question with corresponding numbers.

General detail (point 1,2,3,4,5,7,8) is the identity of the kiln. It includes the name of owner, ownership type (entrepreneur/ community based), geographic location of kiln, and size. It also asks for the year of commissioning, to capture the years of successful operation of VSBK. (point 6) In a typical kiln, there are two types of labour who earn their livelihood from the kiln operation. Most of them are full time workers performing the task of moulding, firing, loading, unloading, brick transportation etc., whereas there are others who work part time for loading and unloading operations on truck or tractor. Since the extent of employment generated due to any industrial activity is an important contribution to economic growth of community, these points are also included in the ESR.

Section two  (point 9,10) No Objection Certificate (NOC) from State Pollution Control Board (SPCB) is necessary by law to build a VSBK. If the land falls under village Panchayat, an NOC from it is also required. This is to ensure an environment friendly operation.  (point 11) VSBK is 30% energy efficient to traditional kilns and reduces air pollution by a factor of two. SPM emission from VSBK has been tested and found (by CPCB) to be very low, following which the allowable limit of emission for VSBK was set to 250 mg/m3 by CPCB.  (point 12,13, 14) Brick making involves soil excavation, therefore soil mining lease is necessary. Further, top soil is not suitable for brick making as it contains root stock, humus and coarse matter and other impurities. Also, if a kiln is within 100km of any thermal power plant, it needs to partially substitute soil with fly ash.  (Point 15,16) The owner is required to provide toilet facility and first aid box at the premises for the workforce.

Section three  (Point 17) VSBK allows utilization of various industrial wastes such as fly ash, stone dust, rice husk ash, boiler ash etc. Section three captures the use of industrial waste as a valuable resource. Wastes with high calorific value are used as internal fuel to increase combustion efficiency hence reduces emissions. Others are soil substitutes to conserve topsoil. There is a considerable amount of regulatory pressure for utilization of industrial wastes especially fly ash.

Section four  (Point 18) Selective mechanization has been incorporated in VSBK to enhance productivity and minimize risks resulting from occupational health and safety hazards. Loading hoist/ conveyer belt, unloading screw and trolley also minimize drudgery. The mechanized mixing of industrial waste has a positive effect on occupational health and safety. Very fine particles of wastes such as stone dust and fly ash can be inhaled when handled manually, resulting in respiratory problems. Other wastes such as rice husk ash are coarse substances and may cause skin aberrations on regular manual mixing.  (Point 19) TARA has identified need of training and capacity building of workers for enhancing productivity and maximizing resource efficiency. Course material for construction, commissioning, firing and trouble shooting has been developed in Hindi. On site training for masons, contractors and brick moulders will be conducted. It will include proper handling of auxiliary utilities such as unloading screw, pug mill, lifts and hoist etc. Certification system for fire masters will be established. Audits and third party verification systems will be put in place. Such training will also help avoid malfunctioning and accidents.  (Point 20) Though access to workers’ children education is desirable for social development, most of the times either schools are too far or the parents are indifferent to children education. This point is included to capture the extent of need for an educational institution so that efforts could be made in this direction in future. Section five Worker health and safety is an important factor to operate without hazards, section five deals with these issues. It is aimed to capture the efforts taken to minimize the risk of accidents and work place injury.

 (Point21,22,23) Though probability of accident and malfunction is very low in VSBK, simple measures like loading hoist within safe limits is encouraged. In VSBK head load is typically 12 bricks for men and 9 bricks for women. TARA is however, working towards minimizing the need for workers to carry loads manually through hoists, trolleys and other equipment.

 (Point 24,25) it is desirable that drinking water is available at premises.

 (Point 26) Plantation around VSBK is encouraged for dust suppression, shady workplace etc.

LAWS APPLICABLE TO VSBK

SECTION VIII

7.1 Contract Labour (Regulation and Abolition) Act, 1970

Applicability: It applies to every establishment in which 20 or more workers are employed as contract labour.

Registration: Since the labour employed in brick kilns is generally engaged through the contractors, the brick kiln owners are obliged to comply with the provisions of this Act. The law obliges every principal employer of contract labour to get his establishment registered with the specified authority.

Appropriate Governance: It provides for prohibition of employment of contract labour in certain occupations in consultation with the Tripartite Advisory Board.

Regulation of employment: The various obligations of employers are: 1. Provision of canteens, restrooms, supply of whole some drinking water, washing facilities, public conveniences and first aid facilities. 2. Payment of wages to the contract labour and so as to ensure this payment he is obliged to nominate a representative in whose presence the contractor shall pay to the workers employed. In case the contractor fails to make the payment of wages within the prescribed period or makes short payment, then the principal employer is liable to make the payment of wages in full or unpaid balance due. He is, however, authorised to recover the amount so paid from the contractor’s bill. 3. Contract labour shall be paid equal to the wages paid to a regular employee for the similar work.

7.2 Emission Standards and Stack Height Regulation

S. Kiln Capacity Stack Height in metres Particulate matter No. (from ground level) (mg/Nm3) Less than 15000 bricks per 11.0 (Minimum 6.5 m 1. 250 day (1-3 shafts) from loading platform) 15,000-30,000 bricks per 14.0 (Minimum 7.5 m 2. 250 day (4-6 shafts) from loading platform) More than 30000 bricks per 16.0 (Minimum 8.5 m 3 250 day ( 7shafts or more) from loading platform)

4.3 NOTIFICATION FOR USAGE OF FLY ASH IN BRICKS The original notification S.0.763(E), published in Gazette of India, as required by subrule (3) of rule 5 of the Environment (Protection) Rules, 1986, states that “No person shall within a radius of fifty kilometers from coal or lignite based thermal power plants, manufacture clay bricks or tiles or blocks for use in construction activities without mixing at least 25 per cent of ash (fly ash, bottom ash or pond ash) with soil on weight to weight basis.”

Amendment was done in Notification S.O. 979 (E) published in 27th August, 2005, where in the word "fifty kilometers”, was substituted by the words "one hundred kilometres”.

ANNEXURE I : EXHAUSTIVE LIST OF ENVIRONMNETAL & SOCIAL ISSUES IN VSBK

Action required, if any, with justification Possible Impacts for Environmet Impacts for Social Impacts Process Environmenta Steps/Activities Aspects Category l Social Yes No Yes No As no blasting Soil operations are fast Safety of mining consumption carried out, Excavation of soil Environment consumption of workers needs to be therefore there soil regulated is no risk to Soil Mining workers Semi-skilled Employement of Enhances labourers Social the local development of required for communities local economy operation All water The NOC intensive Unavailibility of Depletion of obtained from the activities are water for the Water withdrawl Water withdrawal Environment water state largely usually banned local resources takes care of this during phases communities issue of water scarcity 1) Fugitive dust emmission due Exposure to Following to vehicular dust emissions rationale traffic Transportation of Vehicular movement in Vehicular implies ill Environment rules will help raw materials movement unmetalled accidents impact on the avoid such road; 2) health of situations Emissions due communities to exhaust fumes Exposure to Exposure to Air pollution Transportation & Exposure to dust respirable respirable due to storage of fly ash, Handling of fine by worker and particles particles Environmnet contamination fuel and other particles non-worker causes both causes both with particulate friable material communities pulmonary and pulmonary and matter skin damages skin damages

Exposure to Exposure of Manual handling Emission of Settling down respirable workers to high of fine particles respirable of fine particles particles Soil Preparation Environmnet concentration of (fly ash, stone particles (i.e. on nearby causes both respirable dust) fly ash) vegetation pulmonary and particles skin damages Uncomfortable Changes in posture of traditional

workers practices are long duration of (ergonomic) often resisted work, usually Comfortable Social directly under the working sun Fatigue of conditions is

workers propotional to Moulding worker productivity Resource effeciency due Use of waste Trained Better control on to less materials workforce Training and green brick rejection of enhances enhances capacity building moulding green bricks; environmental worker practices use of waste sustainability productivity materials Rejection of Guidance is green bricks due provided to Drying of green Wastage of to crack and Environmnet enhace quality bricks soil breakages during and reduces drying wastage Although head loading is a unsafe lifting common operation by practice, loading exceeding safe Social limits are max of load limit in hoist 9-12 bricks are and for head Loading of brick to Manual loading carried by female loaders platform and and arranging of and male arranging in stacks bricks in stacks respectively

exposure to Smoke control Social smoke while is prevalent by loading using dampers

Possible Impacts Action required, if any, with justification for Environmet Impacts for Social Impacts Process Environmenta Steps/Activities Aspects Category l Social Yes No Yes No Exposure to respirable High Exposure to coal particles Social concentration of dust (inhalation) causes both Coal breaking (into SPM in coal pulmonary and small lumps) breaking area skin damages Retarding fast Fuel Depletion of Consumption of rate of consumption is Environmnet non-renewable coal depletion of lower by design resources coal resource in VSBK Risk to worker Exposure to VSBK being an is nullified by Emmission of harmful gases energy efficient use of lid on Burning of GHG and and particulate Environmnet kiln GHG and stack and coal/fuel particulate matter to workers dust emmissions guiding flue matter and nearby are minimal. gas through communities chimney Brick Firing Use of coal is Reduced coal reduced usage will improper drastically in mean lower disposal may exposure to generation of ash Environmnet VSBK therefore, generation of cause air and RSPM amount of ash suspended land pollution generation is particulate insignificant matter Higher local Enhances employment with Training Social development of skilled jobs in local economy brick sector Unloading Unloading of Social likelihood of Tongs and bricks accidents or crow bars are injuries due to already used red hot particles thus maintaining safe distance from the stack mouth reducing chances of accidents

Inhalation of dust causes respiratory exposure to dust problems. Social emission Settling of dust on body and cloths causes irritation Accidents while lowering Chances of Social trolley may mechanical injury cause head injury Likelihood of Broken bricks are Improper Less wastage worker also sold at a disposal of will reduce the Storage of baked rejection of accidents/injury lesser price and Environmnet waste causes chances of bricks broken bricks due to stacked hence not left land accidents/ bricks and dump scattered all degradation worker injury of broken bricks around Hygiene related Absence of Increases health problems toilets in the Social chances of especially in Living conditions premises illness for laboureres women exposure to children harsh at tender Exposure to accompaning age condition Social emissions, sun parent to may cause and fire workplace permanent impairment Overall Such denial Payment of the Denial of may trigger couple handed financial imbalances in Social over to the male independence of the member female workers communities /families

positive Insignificant effect nullified negative Legends Impact Impacts by design impact

Annexure II : Issues that needs to be managed in VSBK

Daily Intermittent Process Checking Aspect Mandatory by Possible Mitigation Operational Checking; if steps/ Aspect Implemented by required: if Category law Impacts Plan Procedure Yes who is Activities yes who is responsible responsible

Utilisation of Yes (refer Fast minimise soil Excavation Environme industrial waste Financers Soil mining section 3.3 for consumption of use by adding Entrepreneur - of soil nt such as fly ash, explanation) soil substitutes /Third Party stone dust etc. Prevent open transport in closed Transportati Exposure to fly storage and containers, cover Improper Social No Entrepreneur Entrepreneur on & storage ash (inhalation) avoid manual with polythine at storage of of fly ash, mixing site raw fuel and Prevent open store in enclosure materials at increased other friable Environme storage and or cover with Third party/ plant level No concentration of Entrepreneur Entrepreneur material ntal avoid manual plastic/ tarpauline SPM in air Financiers mixing sheet adoption of selective Third Party/ Exposure of Replace Entrepreneur - mechanisation, workers to high manulal mixing Financers Soil training of workers Soil mixing Social No concentration of by mechanical preparation respirable operation such In case of manual particles as pugmill mixing provide Third Party/ Entrepreneur Entrepreneur clean cloth to cover Financers face/nose Moulding Harsh Social Yes More incidence Ensure Check for Enterpreneur - Enterpreneur working of workers provisions of availability of space s/ Financers conditions fatigue wash rooms, away from the rest rooms / workplace and sheds for the provide for workers appropriate infrastructure such as clean drinking water, toilet

facilities

High concentratio Provide boots and Coal n of SPM in Exposure to coal clean cloth to cover Enterpreneur Social Enterpreneur Entrepreneur breaking coal dust (inhalation) Prevent worker face/nose while s/ Financers (into small breaking exposure to coal breaking lumps) area No coal dust usage of Depletion of non- industrial use sponge iron Consumptio Environme Financers Firing No renewable waste which waste, boiler ash Enterpreneur - n of coal ntal resources has residual etc. as internal fuel /Third Party calorific value Provision of cover nose and Financers Social No Exposure to dust personal Enterpreneur Entrepreneur mouth with cloth protection gear /Third Party Unloading of Unloading Provide shoes to brick Provision of Chances of firing crew and Financers Social Yes personal Enterpreneur mechanical injury helmets to protection gear /Third Party unloading crew Provision of Hygiene related Hygenic Absence of Living health problems sanitation Build toilets in the Financers toilets in the Social No Enterpreneur - conditions especially in facilities in premises premises /Third Party for women adequate laboureres numbers Overall Children Social No Hindrance to Creation of Schools/Aganwaris/ Enterpreneur & SHGs Financers accompanin education for alternative creshes have to be SHG /Third Party g parent to labour children facilities to set up in to avoid workplace due to distance keep children children intervening from school and away from kiln in the work place migration site

Female workers Mobilisation have Involvement denied financial to be carried out Ensure of women independence as among the workers savings and children traditionally the and communities SHGs/ Social No through SHG & Financer Entrepreneur as part of payment for the living in the vicinity formation of Finamcers the worker couple is made and formation of SHGs community to the male SHGs have to be member promoted;

Annex-III : Community Benefit Plan

CDCF Community Benefits Plan

1. List the community / social benefits the project will provide and include details such as the number of beneficiaries, their location and the time period during which each benefit will be implemented.

Benefit Beneficiaries Locations Time Period (Project Start & Finish Dates) i. Provision of health March 2006 - December insurance and Brick Workers At CDCF supported 2015 accident cover kiln sites

ii. Provision of basic Brick Workers At CDCF supported March 2006-December sanitation facilities; kiln sites 2015 for men and women

iii. Employment for a Cluster/ Villages near January 2005 – longer period (upto Brick Workers the VSBK sites December 2015 220 days/ year). Thus the need for alternative employment is minimized.

iv. Skill upgradation Brick Workers At TARA’s service March 2006 – (brick making (Firemen) center December 2007 techniques with pugged clay and advanced firing Brick Workers At CDCF supported March 2006 onwards techniques and kiln sites management)

2. Please describe how these benefits will be provided. This should include who will do what during the planning, implementation, and operational phases of the project. Please include the roles and responsibilities of all participants in each phase.

Phase Activity Participants Entrepreneur TARA Brick Workers Provision of health insurance and Dialogue and Agreement accident cover Provision of basic Planning sanitation facilities; for men and women Dialogue and Agreement

Provision of health Compilation of 1. Aggregation of insurance and list of workers lists of operational accident cover VSBKs

2. Health and Accident Insurance Policy finalized

Implementation Provision of basic Construction of sanitation facilities; toilets for men and women Skill upgradation To depute Training of Firing Firing crew to get (brick making persons for crew at VSBK Service trained. techniques with training at Centre, Datia pugged clay and VSBK Service advanced firing Centre, Datia techniques and management) Provision of health Responsible for  Payment of insurance and filing of insurance accident cover insurance premium claims  Sensitisation of workers about insurance benefits

Employment for a Operating the Technology support Support to the Operations longer period (upto kiln for longer entrepreneur for 220 days/ year). period longer operations.

Skill upgradation Investing in Technology support (brick making selective techniques with mechanisation pugged clay and advanced firing techniques and management)

3. Please provide a summary budget that indicates the major cost items and amounts for each project phase: planning, implementation, operations. These cost items could include: personnel, labor, materials, equipment. Please identify any other cost items and amounts, and the funding sources.

Budget Responsibilities

Cost Items Amounts (USD) Entrepreneur TARA/CDCF Brick Workers Remarks Provision of Rs. 200 per worker, 40 health insurance workers per site, 10 years for Nil 218,909 Nil and accident 70 kilns and 9 years for 56 cover kilns Provision of Rs. 25,000 share for each basic sanitation per VSBK, 126 kilns 71,591 71,591 Nil facilities; for men and women

Skill upgradation (brick making techniques Nil 44615 Nil with pugged Training on firing clay and techniques by TARA advanced 715909 Nil Nil firing Investment in mechanization (Optional) techniques and @ Rs.250,000 per plant for management) 126 plants. This is not mandatory.

4. For each benefit, please indicate the number of individuals, households or other units that will benefit per year. i. Benefit: Unit: Number: Period:

Employment for a longer Individuals 560 (Jan 2004 – Dec 2005) period (upto220 days). 14 VSBKs Thus the need for alternative employment Individuals 2800 (Jan 2006 – Dec 2006): is minimized. 70 VSBKs (cumulative)

Individuals 5040 (Jan 2007 onwards): 126 VSBKs (cumulative) ii. Benefit: Unit: Number: Period:

Provision of health Individuals 2800 (Jan 2006 – Dec 2006) insurance and accident 70 VSBKs cover (Jan 2007 onwards): Individuals 5040 126 VSBKs (cumulative)

iii. Benefit: Unit: Number: Period: (Jan 2006 – Dec 2006) Provision of basic Individuals 2800 70 VSBKs sanitation facilities; for men and women 5040 (Jan 2007 onwards): 126 VSBKs (cumulative) iv. Benefits: Unit: Number: Period: (Jan 2006 – Dec 2006) Skill upgradation (at the Individuals 840 70 VSBKs end of implementation phase) 1512 (Jan 2007 – Dec 2007): 126 VSBKs (cumulative)

4. Indicate the actual or estimated costs of providing each benefit during the duration of the project. (This should include all phases – preparation, implementation and operations.) Please also indicate in percentages the funding sources. i. Provision of health Planning / Programming & insurance and accident Implementation: cover NIL

Operations: i. Carbon Finance: 100 % US $ 218,909 (Cost of policy) ii. Entrepreneur : 0% US $ 22,849 (50% of TARA recurring costs) ii. Provision of basic Planning / Programming: sanitation facilities; for Nil men and women i. Carbon Finance: 50 % Implementation: ii. Entrepreneur: 50% US $ 143,182

Operations: Nil

iii. Employment for a Planning / Programming:** i. Carbon Finance: 0 % longer period 220 days Nil ii. Entrepreneur: 0% / year). Thus the need for alternative Implementation: employment is Nil minimized. Operations: Nil iv. Skill upgradation Planning / Programming: Nil i. Carbon Finance: 100% Implementation: ii. Entrepreneur: 0% US $ 44615

Operations: i. Carbon Finance 0% 715909 (Optional) ii. Entrepreneur : 100% (optional)

6. Who is responsible for gathering this information and reporting it to the CDCF?

Name: Technology and Action for Rural Advancement India

Address: Village Sultanpur, Ghitorni, Mehrauli - Gurgaon Road New Delhi - 110 030

Phone: 91 11 2680-5826 91 11 2680-1521, 2680-4482

Email: [email protected]

7. When will reports be provided to the CDCF?

The reports will be provided to the CDCF by November 1 each year

8. Who prepared this document?

Name: Dr. K. Vijayalakshmi, Environment Systems Branch, Development Alternatives

Date: December 29, 2005

ANNEXURE IV: Environment and Social Reporting Form for VSBK Entrepreneurs Please refer to the Note (attached with the form) for explanation

Date: D D M M Y Y Y Y

I. General details

1. Type of VSBK: Community owned Entrepreneur owned

2. Name of the owner:

3. Telephone number:

4. Geographical location: Name of the

Place: District:

State:

Type of area:

Urban Peri-urban Rural Remote

5. Year of kiln commissioning 6. Number of workers Full Time Part Time 7. No. of shafts

8. No. of months of operation per year

II. Risk minimization for averting penalty

9. NOC from SPCB received Yes No

10. NOC from gram panchayat * NA Yes No * Applicable on taking loan from KVIC If applicable

11. SPM level within 250mg/m3 Yes No

12. Existence of valid soil mining lease Yes No

13. Utilisation of fly ash % by weight Yes No

14. Is top soil used in brick making? Yes No

15. Proper toilet facility in premises Yes No

16. Provision of rest room Yes No

17. First aid box available on site Yes No

III. Utilisation of Industrial Waste

18. Industrial waste Available Utilised % by weight Type of waste utilised Y N Y N Stone dust Rice husk ash Biomass char Sponge iron waste Fly ash Boiler ash

IV. For full capacity For partial Machine of Kiln capacity of Kiln Pug mill Extruder Lift and hoist Conveyor belt Unloading screw Unloading Trolley Transportation trolley Lifting Tongs Maximise productivity by skill development, worker benefits and retention

19. Any efforts to improve productivity and reduce Yes No drudgery through selective mechanisation

20. Efforts to develop skill and ensure safety through training of workers

Number of Trainings Category Ratio of workers Type of training of workers Suggested Allowed by TARA by owner trained: total Fire masters Munshi Firemen Moulders Loaders

% 21. Worker retention:

22. Common interest saving groups encouraged? Yes No

23. Institutions for workers’ children education accessible? Yes No

V. Worker health and safety

24. Safe loading limit is maintained in hoisting machines Yes No NA

25. Maximum weight carried by adult male is 55 kg Yes No NA As per Factories Act, 1948

26. Maximum weight carried by adult female is 30 kg Yes No NA As per Factories Act, 1948

27. Source of water present near the kiln Yes No Type

28. Clean drinking water facility in premises Yes No

29. Presence of trouble shooting posters Yes No

30. Plantation around VSBK Yes No for dust suppression, shady workplace, and carbon sequestration

Notes on Environment and Social Reporting Format

VSBK and Sustainable Development VSBK has potential for creating sustainable development. Salient features of VSBK are: higher energy efficiency, lower GHG emission, lower dust emission, reduced worker drudgery, and potential to enhance operator skills through training. Unlike other kilns, VSBK can operate 12 months a year. As a result it might encourage migratory worker community to settle down for a longer time period. Environment and Social Review of VSBK VSBK is designed to limit the adverse impacts on environment and society. In order to record the practices to minimize negative effects arising from pollution and to maximize social benefits, the Environment and Social Review (ESR) format has been designed. The purpose is two fold: documentation for TARA, and risk minimizing checklist for entrepreneurs. There are three categories of risk to VSBK entrepreneurs: financial loss by attracting legal penalty, reduced profit due to sub-optimal kiln operations by untrained workers and productivity loss due to absenteeism resulting from unhealthy working conditions. The ESR provides a checklist of all requirements that minimize the above stated risks. It also looks at the issues of worker community benefits such as children education, improvement of standard of living etc. The ESR Format The ESR format has five sections: General details, Risk minimization by averting penalty, waste utilization, Maximize productivity by skill development and retention, and Worker health & safety. Following are the explanation for each question with corresponding numbers. General detail (point 1,2,3,4,5,7,8) is the identity of the kiln. It includes the name of owner, ownership type (entrepreneur/ community based), geographic location of kiln, and size. It also asks for the year of commissioning, to capture the years of successful operation of VSBK. (point 6) In a typical kiln, there are two types of labour who earn their livelihood from the kiln operation. Most of them are full time workers performing the task of moulding, firing, loading, unloading, brick transportation etc. whereas there are others who work part time for loading and unloading operations on truck or tractor. Since the extent of employment generated due to any industrial activity is an important contribution to economic growth of community, these points are also included in the ESR. Section two looks at the legal requirements which can attract penalty and closure resulting in financial losses.  (point 9,10) No Objection Certificate (NOC) from State Pollution Control Board (SPCB) is necessary by law to build a VSBK. If the land falls under village Panchayat, an NOC from it is also required. This is to ensure an environment friendly operation.  (point 11) VSBK is 30% energy efficient to traditional kilns and reduces air pollution by a factor of two. SPM emission from VSBK has been tested and found (by CPCB) to be very low, following which the allowable limit of emission for VSBK was set to 250 mg/m3 by CPCB.  (point 12,13) Brick making involve soil excavation, therefore soil mining lease is necessary. Also, if a kiln is within 100km of any thermal power plant, it needs to partially substitute soil with fly ash.

 (point 14) Soil excavation for brick making needs to conserve top soil. Further, top soil is not suitable for brick making as it contains root stock, humus and coarse matter and other impurities. In VSBK, preservation of top soil is encouraged owing to the fact that it can support vegetation along the periphery of the kiln site.

(Point 15) VSBK allows utilization of various industrial wastes such as fly ash, stone dust, rice husk ash, boiler ash etc. Section three captures the use of industrial waste as a valuable resource. Wastes with high calorific value are used as internal fuel to increase combustion efficiency hence reducing emission. Others are soil substitutes to conserve topsoil. There is a considerable amount of regulatory pressure for utilization of industrial wastes especially fly ash.

As stated earlier, that for maximum productivity VSBK must be operated under optimum conditions. Section four spells out the measures that can enhance productivity. They are as follows:  (Point 16) Selective mechanization has been incorporated in VSBK to enhance productivity and minimize risk resulting from occupational health and safety hazards. Loading hoist/ conveyer belt, unloading screw and trolley also minimize drudgery. The mechanized mixing of industrial waste has a positive effect on occupational health and safety. Very fine particles of wastes such as stone dust and fly ash can be inhaled when handled manually, resulting in respiratory problems. Other wastes such as rice husk ash are coarse substances and may cause skin aberration on regular manual mixing.  (Point 17) TARA has identified need of training and capacity building of workers for enhancing productivity and maximizing resource efficiency. Course material for construction, commissioning, firing and trouble shooting has been developed in Hindi. On site training for masons, contractors and brick moulders will be conducted. It will include proper handling of auxiliary utilities such as unloading screw, pug mill, lifts and hoist etc. Certification system for fire masters will be established. Audits and third party verification systems will be put in place. Such training will also help avoid malfunctioning and accidents.  (Point 18,19) As VSBK needs skilled manpower to maintain optimum conditions, retention of workforce becomes a crucial factor. Generally the workforce of brick kilns is contractual. Payment is task based. It is usually a husband-wife couple who migrates from other places to woks in kilns. Therefore the employment is for the whole family, and not individuals. Wage rate is an indicator of the willingness of the workers to return to the same site year after year. Timely payment and behavior of the entrepreneur is also important. However, money is not the only governing factor to retain workforce. TARA has introduced the concept of “encouraging formation of common interest groups” by the VSBK entrepreneurs. The objective is to improve their living conditions by encouraging savings.  (Point 20) Though access to workers’ children education is desirable for social development, most of the times either schools are too far or the parents are indifferent to children education. This point is included to capture the extent of need for an educational institution so that the money for community development may be utilized for such cause. Worker health and safety is an important factor to operate without hazards, section five deals with these issues. It is aimed to capture the efforts taken to minimize the risk of accidents and work place injury.

 (Point 23,24) In Factories Act, 1948, Section 67, Chapter VII, the maximum allowable carrying loads are 55kgs and 30 kgs respectively for men and women. Therefore these values are given in the form. TARA is however, working towards minimizing the need for workers to carry loads manually through hoists, trolleys and other equipment.

 (Point 25,26,27) Though probability of accident and malfunction is very low in VSBK, simple measures like loading hoist within safe limits, availability of clean drinking water, restrooms etc. is encouraged. These are also required as per Section 18, Drinking water, Chapter III; Section 19, Latrine and Urinals, Chapter III; and Section 28, Hoists and Lifts, Chapter IV of Factories Act, 1948.

 (Point 29) stresses the availability of first aid box within easy reach

 (Point 30) emphasizes the visual documentation of correct operating practices and procedures to avoid mishaps.

Benefits of ESR The ESR is a part of technical back up support provided by TARA along with the VSBK technology. The purpose is to document the risks that can be minimized by complying with several simple measures suggested in the document. The extended part of the support service is the benchmarking system to ensure resource efficiency and optimal operating conditions in the kiln. Training and capacity building sessions for workers, fire masters and masons are been conducted to ensure maintenance of optimum performance of VSBK.

Development Alternatives 38