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ENVIRONMENTAL & SOCIAL REPORT FOR VSBK A Guidance document for Entrepreneurs and Project Auditors Prepared by Environment Systems Branch E1394

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Page 1: ENVIRONMENTAL & SOCIAL REPORT FOR VSBK€¦  · Web view4.1 The Driving Force for Environment and Social Management in VSBK. VSBKs are largely owned by entrepreneurs who are already

December 30, 2005

ENVIRONMENTAL & SOCIAL REPORT FOR

VSBK

A Guidance document for Entrepreneurs and Project Auditors

Prepared by

Environment Systems BranchDevelopment 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

E1394

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Content

Sections Title Page number

Section I Brick Manufacturing in India – Environment and Social issues

1

Section II The VSBK approach – an effort towards greening the brick industry

5

Section III Managing possible issues in VSBK – that still needs to be considered

7

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

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BBRICKRICK M MANUFACTURINGANUFACTURING ININ I INDIANDIA- 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.

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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

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Kiln type Typical production capacity(lakh bricks / year)

Approx no. of kilns

Coal consumption (tones per lakh bricks)

Stack emission(mg/Nm3)

BTK-fixed chimney 30-100 25000 18 600

BTK-moving chimney 20-80 8000 18 1770

High draft or zig-zag firing or down draft

kiln

30-50 200 <18 850

Clamps 0.5-10 >60,000 >18

Similar to movable

chimney (not monitored)

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

High usage of coal as a fuel also leads to considerable amount of Greenhouse Gas (GHG ) emissions. Considering the average specific energy consumption is 4.5x10-6 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.

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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 hazardsBrick 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 conditionsThe 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.

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1.4.3 Periodic (seasonal) employmentDue 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 MechanismIn 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.

Development Alternatives 5

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TTHEHE VSBK A VSBK APPROACHPPROACH–– an effort towards greening the brick industryan 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

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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 conditionsThrough 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 employmentBy 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.

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MMANAGINGANAGING P POSSIBLEOSSIBLE I ISSUESSSUES ININ VSBK 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:

for negative impact that need to be addressed urgently

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

for positive impacts of VSBK

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

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Red

Orange

Green

Blue

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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 VSBKAs 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 VSBKThe 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.

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TTHEHE P PROPOSEDROPOSED E ENVIRONMENTALNVIRONMENTAL ANDAND SSOCIALOCIAL M MANAGEMENTANAGEMENT P PLANSLANS

SECTION IV

4.1 THE DRIVING FORCE FOR ENVIRONMENT AND SOCIAL MANAGEMENT IN VSBKVSBKs 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 liketemples/shrines in the first instance. If during excavation, some relics orremains or locally important cultural property like idol are found, the localauthority would be notified and work will progress only after the directionsissued 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

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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

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Table 4.1: Responsibility and cost chart for management of environment and social issuesCategory Issues Responsibility Cost (in Rs.) for Remarks

TARA Owner Workers CDCF EntrepreneurNon-negotiable

NOC from pollution control board, regulatory agencies 0 Legal Requirement, not attributable to participation in CDCF project

Use of internal fuel 0 No additional cost

Height of chimney 0 Part of capital cost already included in BOM. Therefore no additional costMechanisation of unloading 0

Provision of First Aid Box 400Training of fire crew 0 Included in TARA service chargesTraining of moulders 0Proper 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 breaking of coal and unloading

500 20 m*Rs 25/m (recurrent cost, 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/helmetHealth and accident insurance 0 No additional costProvision of toilet facilities 25,000 25,000Compliance with Cultural Property Safeguards Policy No additional cost

Total ( One time cost) 26,400Total (Recurring cost) 18,800Desirable Utilisation of industrial waste 0 No additional cost

Restoration of top soil 0 No additional costSelective mechanisation (pug mill and hoist) 1,25,000Posters of Dos’ and Don’ts 0 No additional costTraining of moulders 0 Included in TARA service chargesUse of shaft lid cover 15,000Provision of clean drinking water 15,000

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Provision of clean cooking devices to worker community 6,000Total (One time cost) 161,000

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CCASHASH F FLOWLOW S STRUCTURETRUCTURE

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.

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World Bank

TARA

VSBK 1 VSBK 1 VSBK 1 VSBK 1

InformationLog bookE&S Reporting

CERsInformationE&S Reporting

CER benefits

Worker community

14

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MMONITORINGONITORING M MECHANISMSECHANISMS ANDAND

RREPORTINGEPORTING F FORMATORMAT

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:

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.

Development Alternatives

Energy Environment Calorific value of coal RSPM at workplace

(loading and unloading area) CO and SPM at stack

15

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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.

Schematic diagram depicting reporting and monitoring mechanisms

Development Alternatives

Environmental & Social

Sustainability

Status Update Report

SPCB, DoI, DoEObtaining NOC

Operational

Guidelines

EntrepreneurReporting

Third PartyVerification

Community

Benefits

ESMP

Worker Benefits

Enhanced Performan

ce & Visibility

At Plant LevelAt Plant Level

At Community At Community LevelLevel

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EENVIRONMENTNVIRONMENT ANDAND S SOCIALOCIAL R REPORTINGEPORTING FFORMATORMAT

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 FormatThe 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.

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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 fiveWorker 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.

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LLAWSAWS A APPLICABLEPPLICABLE TOTO VSBK 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. No.

Kiln Capacity Stack Height in metres (from ground level)

Particulate matter (mg/Nm3)

1. Less than 15000 bricks per day (1-3 shafts)

11.0 (Minimum 6.5 m from loading platform) 250

2. 15,000-30,000 bricks per day (4-6 shafts)

14.0 (Minimum 7.5 m from loading platform) 250

3 More than 30000 bricks per day ( 7shafts or more)

16.0 (Minimum 8.5 m from loading platform) 250

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7.3 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”.

Development Alternatives 20

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

Process Steps/Activities Aspects Category

Possible Impacts Action required, if any, with justification

Environmental Social

for Environmet Impacts for Social Impacts

Yes No Yes No

Soil Mining

Excavation of soil Environmentfast consumption of soil

Safety of mining workers

Soil consumption needs to be regulated

   

As no blasting operations are carried out, therefore there is no risk to workers

Semi-skilled labourers required for operation

Social  Employement of the local communities

     

Enhances development of local economy

Water withdrawl Water withdrawal EnvironmentDepletion of water resources

Unavailibility of water for the local communities

 

The NOC obtained from the state largely takes care of this issue

 

All water intensive activities are usually banned during phases of water scarcity

Transportation of raw materials

Vehicular movement Environment

1) Fugitive dust emmission due to vehicular movement in unmetalled road; 2) Emissions due to exhaust fumes

Vehicular accidents

Exposure to dust emissions implies ill impact on the health of communities

   

Following rationale traffic rules will help avoid such situations

Transportation & storage of fly ash, fuel and other friable material

Handling of fine particles Environmnet

Air pollution due to contamination with particulate matter

Exposure to dust by worker and non-worker communities

Exposure to respirable particles causes both pulmonary and skin damages

 

Exposure to respirable particles causes both pulmonary and skin damages

 

Soil PreparationManual handling of fine particles (fly ash, stone

EnvironmnetEmission of respirable particles (i.e.

Exposure of workers to high concentration of

Settling down of fine particles on nearby

 Exposure to respirable particles

 

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dust) fly ash) respirable particles vegetation

causes both pulmonary and skin damages

Moulding

long duration of work, usually directly under the sun

Social  

Uncomfortable posture of workers (ergonomic)

     

Changes in traditional practices are often resisted

Fatigue of workers    

Comfortable working conditions is propotional to worker productivity

 

Training and capacity building  

Resource effeciency due to less rejection of green bricks; use of waste materials

Better control on green brick moulding practices

 

Use of waste materials enhances environmental sustainability

 

Trained workforce enhances worker productivity

Drying of green bricks

Rejection of green bricks due to crack and breakages during drying

Environmnet Wastage of soil    

Guidance is provided to enhace quality and reduces wastage

   

Loading of brick to platform and arranging in stacks

Manual loading and arranging of bricks in stacks

Social  

unsafe lifting operation by exceeding safe load limit in hoist and for head loaders

 

Although head loading is a common practice, loading limits are max of 9-12 bricks are carried by female and male respectively

   

Social  exposure to smoke while loading

     Smoke control is prevalent by using dampers

Process Steps/Activities Aspects Category

Possible Impacts Action required, if any, with justification

Environmenta Social for Environmet Impacts for Social Impacts

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l Yes No Yes No

Coal breaking (into small lumps)

High concentration of SPM in coal breaking area

Social

 

Exposure to coal dust (inhalation)

   

Exposure to respirable particles causes both pulmonary and skin damages  

Brick Firing

Consumption of coal Environmnet

Depletion of non-renewable resources

 

Retarding fast rate of depletion of coal resource

Fuel consumption is lower by design in VSBK

   

Burning of coal/fuel Environmnet

Emmission of GHG and particulate matter

Exposure to harmful gases and particulate matter to workers and nearby communities

 

VSBK being an energy efficient kiln GHG and dust emmissions are minimal.

 

Risk to worker is nullified by use of lid on stack and guiding flue gas through chimney

generation of ash Environmnet

improper disposal may cause air and land pollution

exposure to RSPM  

Use of coal is reduced drastically in VSBK therefore, amount of ash generation is insignificant

 

Reduced coal usage will mean lower generation of suspended particulate matter

Training Social  

Higher local employment with skilled jobs in brick sector

     

Enhances development of local economy

Unloading Unloading of bricks

Social  

likelihood of accidents or injuries due to red hot particles

     

Tongs and crow bars are already used thus maintaining safe distance from the stack mouth reducing chances of accidents

Social   exposure to dust emission    

Inhalation of dust causes respiratory

 

Development Alternatives 23

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problems. Settling of dust on body and cloths causes irritation

Social   Chances of mechanical injury    

Accidents while lowering trolley may cause head injury

 

Storage of baked bricks

rejection of broken bricks Environmnet

Improper disposal of waste causes land degradation

Likelihood of worker accidents/injury due to stacked bricks and dump of broken bricks

 

Broken bricks are also sold at a lesser price and hence not left scattered all around

 

Less wastage will reduce the chances of accidents/ worker injury

Living conditions for laboureres

Absence of toilets in the premises

Social  

Hygiene related health problems especially in women

   Increases chances of illness

 

Overall

children accompaning parent to workplace

Social  Exposure to emissions, sun and fire

   

exposure to harsh at tender age condition may cause permanent impairment

 

Payment of the couple handed over to the male member

Social  

Denial of financial independence of female workers

   

Such denial may trigger imbalances in the communities /families

 

Legendspositive Impact

Insignificant Impacts

effect nullified by design

negative impact

Development Alternatives 24

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Annexure II : Issues that needs to be managed in VSBK

Process steps/ Activities

Aspect Aspect Category

Mandatory by law

Possible Impacts

Mitigation Plan

Operational Procedure Implemented by

Daily Checking required: if yes who is responsible

Intermittent Checking; if Yes who is responsible

Soil mining Excavation of soil

Environment

Yes (refer section 3.3 for explanation)

Fast consumption of soil

minimise soil use by adding substitutes

Utilisation of industrial waste such as fly ash, stone dust etc.

Entrepreneur - Financers /Third Party

Transportation & storage of fly ash, fuel and other friable material

Improper storage of raw materials at plant level

Social No Exposure to fly ash (inhalation)

Prevent open storage and avoid manual mixing

transport in closed containers, cover with polythine at site

Entrepreneur Entrepreneur  

Environmental No

increased concentration of SPM in air

Prevent open storage and avoid manual mixing

store in enclosure or cover with plastic/ tarpauline sheet

Entrepreneur Entrepreneur Third party/ Financiers

Soil mixing Soil preparation Social No

Exposure of workers to high concentration of respirable particles

Replace manulal mixing by mechanical operation such as pugmill

adoption of selective mechanisation, training of workers

Entrepreneur - Third Party/ Financers

In case of manual mixing provide clean cloth to cover face/nose

Entrepreneur Entrepreneur Third Party/ Financers

Moulding Harsh working conditions

Social Yes More incidence of workers fatigue

Ensure provisions of wash rooms, rest rooms / sheds for the workers

Check for availability of space away from the workplace and provide for appropriate infrastructure such as clean drinking water, toilet

Enterpreneur - Enterpreneurs/ Financers

Development Alternatives 25

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facilities

Coal breaking (into small lumps)

High concentration of SPM in coal breaking area

Social

No

Exposure to coal dust (inhalation) Prevent worker

exposure to coal dust

Provide boots and clean cloth to cover face/nose while coal breaking

Enterpreneur Entrepreneur Enterpreneurs/ Financers

Firing Consumption of coal

Environmental No

Depletion of non-renewable resources

usage of industrial waste which has residual calorific value

use sponge iron waste, boiler ash etc. as internal fuel

Enterpreneur - Financers /Third Party

Unloading Unloading of brick

Social No Exposure to dustProvision of personal protection gear

cover nose and mouth with cloth Enterpreneur Entrepreneur Financers

/Third Party

Social Yes Chances of mechanical injury

Provision of personal protection gear

Provide shoes to firing crew and helmets to unloading crew

Enterpreneur   Financers /Third Party

Living conditions for laboureres

Absence of toilets in the premises

Social No

Hygiene related health problems especially in women

Provision of Hygenic sanitation facilities in adequate numbers

Build toilets in the premises Enterpreneur - Financers

/Third Party

Overall

Children accompaning parent to workplace

Social No

Hindrance to education for labour children due to distance from school and migration

Creation of alternative facilities to keep children away from kiln site

Schools/Aganwaris/creshes have to be set up in to avoid children intervening in the work place

Enterpreneur & SHG SHGs Financers

/Third Party

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Involvement of women and children as part of the worker community

Social No

Female workers denied financial independence as traditionally the payment for the couple is made to the male member

Ensure savings through formation of SHGs

Mobilisation have to be carried out among the workers and communities living in the vicinity and formation of SHGs have to be promoted;

SHG & Financer Entrepreneur SHGs/ Finamcers

Development Alternatives 27

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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 insurance and accident cover

Brick Workers At CDCF supported kiln sites

March 2006 - December 2015

ii. Provision of basic sanitation facilities; for men and women

Brick Workers At CDCF supported kiln sites

March 2006-December 2015

iii. Employment for a longer period (upto 220 days/ year). Thus the need for alternative employment is minimized.

Brick Workers

Cluster/ Villages near the VSBK sites

January 2005 – December 2015

iv. Skill upgradation (brick making techniques with pugged clay and advanced firing techniques and management)

Brick Workers (Firemen)

Brick Workers

At TARA’s service center

At CDCF supported kiln sites

March 2006 – December 2007

March 2006 onwards

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 ParticipantsEntrepreneur TARA Brick Workers

Planning

Provision of health insurance and accident cover

Dialogue and Agreement

Provision of basic sanitation facilities; for men and women Dialogue and Agreement

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Implementation

Provision of health insurance and accident cover

Compilation of list of workers

1. Aggregation of lists of operational VSBKs

2. Health and Accident Insurance Policy finalized

Provision of basic sanitation facilities; for men and women

Construction of toilets

Skill upgradation (brick making techniques with pugged clay and advanced firing techniques and management)

To depute persons for training at VSBK Service Centre, Datia

Training of Firing crew at VSBK Service

Centre, Datia

Firing crew to get trained.

Operations

Provision of health insurance and accident cover

Responsible for filing of insurance claims

Payment of insurance premium

Sensitisation of workers about insurance benefits

Employment for a longer period (upto 220 days/ year).

Operating the kiln for longer period

Technology support Support to the entrepreneur for

longer operations.

Skill upgradation (brick making techniques with pugged clay and advanced firing techniques and management)

Investing in selective mechanisation

Technology support

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 health insurance and accident cover

Nil 218,909 Nil

Rs. 200 per worker, 40 workers per site, 10 years for 70 kilns and 9 years for 56 kilns

Provision of basic sanitation facilities; for men and women

71,591 71,591 Nil

Rs. 25,000 share for each per VSBK, 126 kilns

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Skill upgradation (brick making techniques with pugged clay and advanced firing techniques and management)

Nil

715909 (Optional)

44615

Nil

Nil

Nil

Training on firing techniques by TARA

Investment in mechanization @ Rs.250,000 per plant for 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:

Employment for a longer period (upto220 days). Thus the need for alternative employment is minimized.

Unit: Number: Period:

Individuals 560 (Jan 2004 – Dec 2005) 14 VSBKs

Individuals 2800 (Jan 2006 – Dec 2006):70 VSBKs (cumulative)

Individuals 5040 (Jan 2007 onwards):126 VSBKs (cumulative)

ii. Benefit:

Provision of health insurance and accident cover

Unit: Number: Period:

Individuals 2800 (Jan 2006 – Dec 2006) 70 VSBKs

Individuals 5040(Jan 2007 onwards):126 VSBKs (cumulative)

iii. Benefit:

Provision of basic sanitation facilities; for men and women

Unit:

Individuals

Number:

2800

5040

Period:(Jan 2006 – Dec 2006) 70 VSBKs

(Jan 2007 onwards):126 VSBKs (cumulative)

iv. Benefits:

Skill upgradation (at the end of implementation phase)

Unit:

Individuals

Number:

840

1512

Period:(Jan 2006 – Dec 2006) 70 VSBKs

(Jan 2007 – Dec 2007):126 VSBKs (cumulative)

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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 insurance and accident cover

Planning / Programming & Implementation:NIL

Operations:US $ 218,909 (Cost of policy)US $ 22,849 (50% of TARA recurring costs)

i. Carbon Finance: 100 %ii. Entrepreneur : 0%

ii. Provision of basic sanitation facilities; for men and women

Planning / Programming:Nil

Implementation:US $ 143,182

Operations:Nil

i. Carbon Finance: 50 %ii. Entrepreneur: 50%

iii. Employment for a longer period 220 days / year). Thus the need for alternative employment is minimized.

Planning / Programming:**Nil

Implementation:Nil

Operations:Nil

i. Carbon Finance: 0 %ii. Entrepreneur: 0%

iv. Skill upgradation Planning / Programming:Nil

Implementation:US $ 44615

Operations:715909 (Optional)

i. Carbon Finance: 100%ii. Entrepreneur: 0%

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

Development Alternatives 31

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

Name: Technology and Action for Rural AdvancementIndia

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

Phone: 91 11 2680-582691 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

Development Alternatives 32

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ANNEXURE IV: Environment and Social Reporting Form for VSBK Entrepreneurs

Please refer to the Note (attached with the form) for explanation

Date:

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

Development Alternatives

D D M M Y Y Y Y

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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. Type of waste utilised

IV.

Maximise productivity by skill development, worker benefits and retention

19. Any efforts to improve productivity and reduce Yes Nodrudgery through selective mechanisation

Development Alternatives

Industrial waste Available Utilised % by weight

Y N Y N

Stone dustRice husk ashBiomass charSponge iron wasteFly ashBoiler ash

Machine For full capacity of Kiln

For partial capacity of Kiln

Pug mill

Extruder

Lift and hoist

Conveyor belt

Unloading screw

Unloading Trolley

Transportation trolley

Lifting Tongs

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

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

Development Alternatives

Category of workers

Number of Trainings Ratio of workers trained: total

Type of trainingSuggested by TARA

Allowed by owner

Fire masters

Munshi

Firemen

Moulders

Loaders

%

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Notes on Environment and Social Reporting Format

VSBK and Sustainable DevelopmentVSBK 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 VSBKVSBK 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 FormatThe 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.

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December 30, 2005

(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.

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(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 ESRThe 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.

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