EMP Renewal Jaffer Agro Services PVT, LTD

Environmental Management Plan
March 2019
(Renewal)
JAFFER AGRO SERVICES PVT.

LIMITED
EMC Pakistan
Private Limited
Environmental Management Plan (Renewal)
for
JAFFER AGRO SERVICES

PVT. LIMITED
March 2019
Ref.: EMP/01/11/19
EMC PAKISTAN PVT. LTD.

503, Anum Estate, Opp. Duty Free Shop, Main Shahrah-e-Faisal, Karachi.
Phones: 9221-34311466, 34324680, Fax: 9221-34311467.
E-mail: mail@emc.com.pk, info@emc.com.pk
Website: www.emc.com.pk
Renewal of Jaffer Agro Services (Private) Limited
EMP Renewal
EXECUTIVE SUMMARY
This document encloses a detailed Environmental Management Plan to be implemented by Jaffer
Agro Services (Pvt.) Limited during routine operations at their facility. The EMP shall assist Jaffer
Agro Services (Pvt.) Limited in managing their process being carried out at the facility located F-52,
S.I.T.E, Karachi, Pakistan.
Being responsible corporate citizens, the management and employees at Jaffer Agro Services (Pvt.)
Limited commit themselves to the effective implementation of an objective driven safety, health and
environmental management system, which actively promotes the following;
 The preservation /protection of the environment and workers from unnecessary energy losses that
are detrimental for working environment.
 Responsible and controlled disposal of various wastes in terms of requirements of SEPA, 2014
The Jaffer Family established a trading firm in 1849, in Pune, undivided India. Following the creation
of Pakistan, Jaffer Brothers (Private) Limited (JBL) was incorporated in Karachi on July 2, 1948.
The steady growth and success of JBL, and the position it secured as a leading business house, were
mainly due to the family’s over 150 years of experience, and the trust placed in JBL and associated
companies by its customers, employees and principals - which today include some of the most
renowned names internationally.
Jaffer Agro Services (Pvt.) Limited (JASPL) offers the agricultural sector of Pakistan a wide variety
of crop protection products, nutrients and services with committed stewardship. Having a
repackaging and formulation (granules and dust) plant with a capacity of 6000-8000 bottles per shift,
JASPL has been catering to local and foreign companies’ demand for repackaging of their products.
EMC (Pvt.) during the visit found some minor gaps regarding housekeeping and inappropriate
placement of pallets. Chemical drums and overhead vessel should be provided with secondary
containment. Emergency exits should be provided with illuminated signage. The details of the
observations have been added as an annexure in the report.
The EMP shall assist the Company to achieve the following objectives:
 Outlining measures to be taken during the operations to eliminate or offset adverse environmental
impacts, or if unavoidable, to reduce them to acceptable levels.
 Providing a monitoring Plan to assess the effectiveness of the mitigation measures employed such
as guide through the monitoring mechanism and identifying related parameters that will be
required for confirming the effective implementation of the mitigation measures.
 Ensure that air emissions from process and generator are within the prescribed limits of SEQS by
Sindh Environmental Protection Agency (SEPA) in order to reduce environmental pollution.
This EMP provides all necessary precautions to be taken by the company during the operation at their
facility. Its scope comprises of:
 Applicable legislations and guidelines
 Roles and responsibilities of key players
Executive Summary
Page i of ii
EMC Pakistan Private Limited
EMP Renewal
 Management plan
 Monitoring plan
 Emergency response plan
It is recommended that the EMP will be approved with the assurance that the EMP is followed in
letter and spirit by M/s Jaffer Agro Services (Pvt.) Limited such that its operations do not pose any
adverse impacts on the environment.
Executive Summary
Page ii of ii
EMP Renewal
TABLE OF CONTENTS
1. INTRODUCTION............................................................................................... 1 OF 12
1.1. Profile of the Company .................................................................................................. 1 of 12
1.2. Location of the Production Facility .............................................................................. 2 of 12
1.3. Facility Operations ......................................................................................................... 5 of 12
1.3.1 Unloading and Receiving Cartons and Bags .................................................................... 5 of 12
1.3.2 Filling Lines & Packing ...................................................................................................... 5 of 12
1.3.3 Packing ................................................................................................................ 5 of 12
1.3.4 Storage & Dispatching ...................................................................................................... 7 of 12
1.3.5 Quality Control Laboratory ................................................................................................ 8 of 12
1.4. Products at the Facility................................................................................................ 10 of 12
1.5. Product Handling and Disposal of Waste.................................................................. 11 of 12
1.3.6 Non- contaminated Waste Streams ................................................................................ 11 of 12
1.3.7 Contaminated Waste Streams ........................................................................................ 11 of 12
1.3.8 Local Exhaust Ventilation System (LEV) ......................................................................... 12 of 12
1.6. Utilities ............................................................................................................. 12 of 12
1.6.1 Electricity .............................................................................................................. 12 of 12
1.6.2 Gas .............................................................................................................. 12 of 12
1.6.3 Water .............................................................................................................. 12 of 12
2. STATUTORY OBLIGATIONS ............................................................................. 1 OF 2
3. ENVIRONMENTAL MANAGEMENT PLAN ...................................................... 1 OF 5
3.1. Objectives of Environmental Management Plan ........................................................... 8 of 5
3.2. Scope of Environmental Management Plan .................................................................. 8 of 5
3.3. Significance of Environmental Management Plan ........................................................ 8 of 5
3.4. Management Approach ................................................................................................... 9 of 5
3.5. Organizational Structure of Jaffer Agro Services Private Limited S.I.T.E., Karachi . 9 of 5
3.6. Roles and Responsibilities ............................................................................................. 9 of 5
3.7. Communications & Documentation ............................................................................. 11 of 5
3.8. Trainings ............................................................................................................... 12 of 5
4. IMPLEMENTATION OF ENVIRONMENTAL MANAGEMENT PLAN .............. 1 OF 7
4.1. Potential Environmental Impacts and Mitigation Measures ........................................ 1 of 7
4.2. Mitigation Plan ................................................................................................................. 3 of 7
4.3. Standard Symbols found in MSDS ................................................................................. 3 of 7
3.1 Risk Assessment ............................................................................................................. 4 of 7
5. EMERGENCY RESPONSE PLAN .................................................................... 1 OF 5
5.1 Spill Management Plan .................................................................................................... 4 of 4
6 ENVIRONMENTAL MONITORING PLAN ......................................................... 1 OF 2
6.1 Objectives ................................................................................................................. 1 of 2
6.2 Monitoring Parameters .................................................................................................... 1 of 2
6.3 Non-Conformance & Corrective Action ......................................................................... 1 of 2
7. ENVIRONMENTAL COMPLIANCE ................................................................... 1 OF 1
7.1. Maintenance of EMP ........................................................................................................ 1 of 2
Table of Contents
Page I of II
EMP Renewal
ANNEXURES
ANNEX – I : ISO 9001:2015 certificate
ANNEX – II : Environmental Test Reports
ANNEX – III : Sindh Environmental Protection Act, 2014
ANNEX – IV : SEPA (Review IEE & EIA) Regulation, 2014
ANNEX – V : Sindh Environmental Quality Standards 2016
ANNEX – VI : Hazardous Substance Rules 2014
ANNEX – VII : Waste Disposal Certificates
ANNEX – VIII : Observations at Site
ANNEX – IX : Training Record
Table of Contents
Page II of II
EMP Renewal of Jaffer Agro Services (Private) Limited
1. INTRODUCTION
This Environmental Management Plan (EMP) has been prepared by M/s EMC Pakistan Private
Limited for Jaffer Agro Services (Private) Limited, which is engaged in filling, handling and
packaging of insecticide and pesticides. It is located at F-52, S.I.T.E., Karachi 75700, Pakistan
1.1. Profile of the Company

The Jaffer Family established a trading firm in 1849, in Pune, undivided India. Following the creation
of Pakistan, Jaffer Brothers (Private) Limited (JBL) was incorporated in Karachi on July 2, 1948.
The steady growth and success of JBL, and the position it secured as a leading business house, were
mainly due to the family’s over 150 years of experience, and the trust placed in JBL and associated
companies by its customers, employees and principals - which today include some of the most
renowned names internationally.
The Group actively participates in national growth, and economic and social development. Highly
motivated teams of the business and service divisions, and subsidiary companies, fulfill customers'
needs in accordance with the short and long term objectives set by them.
Since its inception, the goods and services provided by JBL and associated companies have led to
improved productivity in the agro sector, in the information management field and in transportation,
telecommunication, power generation and transmission projects.
JASPL offers the agricultural community of Pakistan a wide variety of crop protection products,
nutrients and services with committed stewardship. Having a repackaging and formulation (granules
and dust) plant with a capacity of 20,000 bottles per day and 7000 packs per day and 8000 sachets per
day. JASPL has been catering to local and foreign companies’ demand for repackaging of their
products.
JASPL represents some of the global giants of the industry. With the nationwide spread of field force
and a committed dealer network, JASPL stands tall among the reputable agrochemical companies in
Pakistan. Taking advantage of the extensive infrastructure of JASPL, JBL has awarded distribution of
its ‘Cheeta’ fertilizer to JASPL.
Vision 2020
A prominent diversified group striving for customer excellence.
Mission
To actively participate in the economic and social development of Pakistan. We will continue to
operate through our national presence and global partners while enhancing the stakeholders’ interests.
Our concern will be mainly in the areas of agriculture, Information & Communication Technology
(ICT), Professional Services (PS), Infrastructure Development, Education, Health, Processing /
Manufacturing, Environmental Engineering and Energy. We will extend our presence at the regional
level.
The image of ISO 9001:2015 certificate is attached in Annex I
Table 1.1: Information of Jaffer Agro Services (Private) Limited

1 Name of the Facility Jaffer Agro Services (Private) Limited
2 Address F-52 Site, Karachi 75700
3 Telephone No. Phones : (021) 32576441, 32570712
Introduction
Page 1 of 12
Table 1.1: Information of Jaffer Agro Services (Private) Limited

4 E-mail Sohail.ahmed@jaffer.com
5 Cell 0345-8280235
5 Factory Manager Muhammad Sohail Ahmed
6 HSE Officer Umair Khan
1.2. Location of the Production Facility

Jaffer Agro Services (Private) Limited is located at F-52, S.I.T.E, Karachi 75700. The company has 86
employees with 20 are permanents and the rest temporary/contract employees. The company operates
one shift from 8:30 a.m. to 4:30 p.m.
Introduction
Page 2 of 12
Fig 1.1: Facility Location Map of Jaffer Agro Services (Pvt.) Limited, Karachi, Pakistan
Introduction
Page 3 of 12
Fig 1.2: Facility Layout Plan of Jaffer Agro Services (Pvt.) Limited
Introduction
Page 4 of 12
1.3. Facility Operations

The central facility produces the crop protection products for domestic market and the main
operations are based on the filling and packing of final products. Details of the processes are given
below.
1.3.1 Unloading and Receiving Cartons and Bags

The process begins from the receipt of cartons and bags. The material gets into filling lines.
1.3.2 Filling Lines & Packing

The process of filling is carried out in the filling line area. Following are the details the filling line
with average output of each products
 Filling Machine with an average capacity of 8000 bottles/day

 Filling Machine with an average capacity of 6000 bottles/day
 Pneumatic Filling Machine with an average capacity of 4000 Packs/day
 Filling Machine with an average capacity of 6000 Bottles/day
 Sachet filling machine for powder & granules with an average capacity of 8000 sachets/day
 Semi-Automatic Powder filling machine with average capacity of 3000 packs/day
Fig 1.3: Process Flow of Liquid Filling and Packing Line
1.3.3 Packing
The filled products area transferred to the packing area. After the packing, the final product moves to
warehouse for the storage and final dispatch.
Introduction
Page 5 of 12
Figure 1.4: Flow Diagram of Production Process
Introduction
Page 6 of 12
The list of equipment used in the filling, packing, capping, sealing and labelling is as under:
Table 1.2: List of Equipment Used at Jaffer Agro Services (Pvt.) Limited
List of Equipment
Production
S.No Item Description Specification Quantity
Capacity/day
1 Liquid Filling Machine 12 Nozzles Rotary Type 8000 Bottles 1
10 Nozzles straight line
2 Liquid Filling Machine filler 6000 Bottles 1
3 Pneumatic Bottle sealer Imported 2
4 Exhaust system 2
5 Fresh Air supply system 1
6 Ink jet Marking Machine Imaje 1
7 Ink jet Marking Machine Domino Model A-200 1
8 Heat Shrink Machine Kalfass Imported 1
9 Heat Shrink Machine Local 1
10 Labelling Machine imported 1
11 Capping Machine Local 3
12 Pneumatic filling Machine 2 Nozzle. I Liter capacity 4000 Packs. 1
13 filling Machine 4 Nozzles 6000 Bottles 1
14 Vacuum pump 2
15 Formulation Tank 1400 Liter Capacity 1
16 Holding Tank 1000 Liter capacity 1
17 Induction Sealer Imported 2
18 Drum Press machine 1
19 Drum Washing machine 1
20 Compressor 7.5 HP 2
21 Duel Filter 1
22 Double Diaphragm Pneumatic pump 2
23 sachet filling machine for powder & Automatic 8000 sachet 1
granules
Semi-Automatic Powder filling Locally Fabricated,( 100
24 machine. gm to 1000 gm) 3000 Packs 1
1.3.4 Storage & Dispatching
The facility has a warehouse having the covered area 100 m2. Spill containment material is provided
at the entrance of the warehouse. There is a capacity of 200 pallets by leaving 30% area for the hand
lifter movement. The warehouse staff, security staff and transport company employees are regularly
trained on emergency response, spillage control and safe handling of chemicals. The packed products
are transported to the field warehouses using a local logistic company.
Introduction
Page 7 of 12
Figure 1.5: Layout of Factory Warehouse
Fig 1.6: Product dispatch area and warehouses
1.3.5 Quality Control Laboratory

The facility has its own quality control laboratory for the analysis of chemical/ products and
packaging material as per JASPL specifications. QC lab is well equipped with all the required
calibrated equipment for the product analysis
The laboratory of Jaffer Agro Services (Pvt.) Limited is equipped with the necessary instrument
which are tabulated as under:
Introduction
Page 8 of 12
Table 1.3: Instrument at Quality Control Department

S. No. Name of Instruments
1 HPLC
2 Spectrophotometer
3 Flame photometer
4 pH Meter-Adwa
5 Conductivity Meter
6 Ultrasonic Bath
7 Water Bath
8 Distillation Unit
9 Shaker
10 Heating mantle
11 Hot Plate Magnetic Stir
12 Oven
13 Electronic Balance
14 Centrifuge Machine
Below is the photographic record taken during the facility visit:
Fig 1.7: Laboratory
Introduction
Page 9 of 12
1.4. Products at the Facility

The products – insecticides and herbicides are stored at the Karachi facility. The List of Product is provided
in Table 1.4.
Table1.4: List of Products

1 AgS.Nohaz 70%WS
2 Buffer 25% WP
3 Capnazole 75% WP
4 Capza 5% G
5 Carbo Gold 3% G
6 Champion 77% wp
7 Clodinafop Propargyl 15% WP
8 Contaf Plus 5.1%^ SC
9 Deltashine 2.5% EC
10 Ematac 1.9% EC
11 Epical 25% SC
12 Fipryte 5% SC
13 Fyfanon 57% EC
14 Gazonner 15% EC
15 Glance 72% WP
16 Glycel 48% SL
17 Jacefex 75% SP
18 Jatara 10%EC
19 Karuz 4% G
20 Kelion 50% WG
21 Kope 36% SC
22 Lamcin 2.5%EC
23 Mera 71% SG
24 Metagold 72% WP
25 Mission Extra 55% SC
26 Miyaling-2 12.5%EC
27 Panida 33%EC
28 Pyrifos 40% EC
29 Quatr 40% EC
30 Simida 25% WP
31 Sulfex Gold 80% WDG
32 Sunpyr 10.8% EC
33 Thru 50% WP
34 Tight 5% EC
35 Titonic 20% SP
36 Trisuper 40%EC
37 Yumei 24% OD
38 Zolfer 25%EC
Introduction
Page 10 of 12
1.5. Product Handling and Disposal of Waste

The products are stored in the facility on arrival and then and filled, packed dispatches to field
warehouses. Standard Operating Procedures for loading and unloading of the products are present and
the facility employees as well as the transportation company personnel are trained in Emergency
Response procedure. The reject/leaked products are stored in a dedicated area and disposed according
to SOP’s.
Non contaminated waste bin Drum washing and pressing
Crushed Empty drum for disposal Contaminated waste chemical pit
1.5.1. Non- contaminated Waste Streams

Non-contaminated Solid Waste containing plastic wraps, rejected empty bottles, scrap etc. is sent to
EPA certified 3rd party waste contractor. The liquid stream of non-contaminated waste includes
sanitary wastewater from canteen and showers which is disposed after complying SEQS.
1.5.2. Contaminated Waste Streams

Contaminated solid waste generated from JASPL Site includes empty drums of active ingredients.
These drums are washed/decontaminated with solvent/water and then crushed and sold to Smelter
Contractor for recycling.
The liquid hazardous waste streams comprising i) out of spec material containing solvents and active
ingredients and ii) equipment & drum wash water.
Introduction
Page 11 of 12
The wash water and waste bags, bottles etc. being hazardous, contaminated with solvents and
pesticides is sent to Enviro green, the SEPA certified contractor for incineration. The Certificates of
waste disposal (hazardous) are attached in Annex VII
1.5.3. Local Exhaust Ventilation System (LEV)

The facility is equipped with LEV which is an engineering system designed to reduce employee
exposure to airborne contaminants (dust, mist, fume, vapor, gas) in the workplace by capturing the
emission at source and transporting it to a safe emission point or to a filter/scrubber.
1.6. Utilities
1.6.1. Electricity
Electricity is supplied by K Electric. Average consumption of electricity per year is 103618 KWH.
One 100KVA stand by diesel generator for electricity supply in case of power failures.
1.6.2. Gas
Gas is used in kitchen and geyser. The average gas consumption per year is 1298 m3.
1.6.3. Water
Water is used in kitchen and washrooms. The source of water is KWSB and annual consumption is
133200 gallons. In case of water shortage, water tanker service is availed.
Introduction
Page 12 of 12
2. STATUTORY OBLIGATIONS
It is expected that the proponent will adhere to all the relevant national legislations, international
conventions as well as other international guidelines. The proponents will also ensure conformance of staff
and contractors to these laws and regulations during its operations. A summary of relevant legislations,
guidelines, conventions and corporate requirements are given in Table 2.1.
Table 2.1: Relevant Statutory Obligations for Jaffer Agro Services (Pvt.) Limited
Sr. No Legislation / Guidelines
National Legislations and Guidelines
1 Sindh Environmental Protection Act (2014)
It is the basic legislative tool empowering the Government of Sindh to frame and enforce
regulations for the protection of the environment. The Sindh Environmental Protection Act
2014 is broadly applicable to air, water, soil, marine and noise pollution and handling of
hazardous wastes. Penalties have been prescribed for those contravening provisions of the Act
under Section 17 of the Act, no project involving construction activities or any change in the
physical environment can be undertaken unless an IEE or EIA is conducted and a report
submitted to SEPA.
2 Sindh Environmental Protection Agency Review of IEE and EIA Regulations, 2014
The Regulation classifies projects on the basis of expected degree of adverse environmental
impacts and lists them in two separate schedules. Schedule I lists projects that may not have
significant environmental impacts and therefore require an IEE. Schedule II lists projects of
potentially significant environmental impacts requiring preparation of an EIA. The regulation
also requires that all projects located in environmentally sensitive areas require preparation of
an EIA.
3 Sindh Environmental Quality Standards 2016
The SEQS specify standards for industrial and municipal effluents, gaseous emissions, ambient
air requirements and emission levels for Sulfur Dioxide and Nitrogen Oxide, vehicular
emissions and noise levels and drinking water quality. The SEPA specifies the imposition of
pollution charge in case of non- compliance with the SEQS.
4 Hazardous Substance Rules, 2014
These Rules were notified to streamline procedures for issuance of licenses to industries /
businesses that generate hazardous waste, safety precautions for workers and devices them
methods for the removal of hazardous wastes in an environmental friendly manner. The rules
also specify procedures to be adopted for import, transport and disposal of hazardous waste;
and identify two hundred and forty-three hazardous substances and synthetic chemicals.
5 Sindh Environmental Quality Standards (Self-Monitoring & Reporting Rules 2014)
The guidelines for Self-Monitoring and Reporting Rules by Industry define Categories of the
industrial units and monitoring and reporting frequencies.
6 National Environmental Policy (2005)
NEP is the primary policy of Government of Pakistan addressing environmental issues. The
broad goal of NEP is “to protect, conserve, and restore Pakistan’s environment in order to
improve the quality of life of the citizens through sustainable development” The NEP identifies
a set of sectoral and cross-sectoral guidelines to achieve its goal of sustainable development. It
also suggests various policy instruments to overcome the environmental problems throughout
the country
7 Pakistan Penal Code (1860)
It authorizes fines, imprisonment or both for voluntary corruption or fouling of public springs
or reservoirs so as to make them less fit for ordinary use
8 Sindh Factories Act (2015)
Chapter-III of the Act has a dedicated section for Occupational Health & Safety which specifies
Statutory Obligations
Page 1 of 2
Table 2.1: Relevant Statutory Obligations for Jaffer Agro Services (Pvt.) Limited
Sr. No Legislation / Guidelines
the requirements of safety and environmental conditions of operating units. These include
measures for ventilation, humidity and temperature control, lighting, sanitation, fire prevention
and emergency response, health issues related to toxic dusts, vapors and fumes, machinery
safety injury and illness reporting etc.
9 Sindh Factories Rules (1975)
This provides directions to implement the Factories Act and provides information and formats
for maintaining records and reporting injury incidents.
10 Guidelines for Use and Manufacture of Oxo-biodegradable Plastic Packaging (2013)
These guidelines provide guidance for import, manufacture and sale of Plastic bags and
packaging material and to prescribe procedures for manufacturing, monitoring and quality of
scheduled plastic products.
National Conservation Strategies
1 National Conservation Strategy
Before the approval of NEP, the National Conservation Strategy (NCS) was considered as the
Government’s primary policy document on national environmental issues. At the moment this
strategy just exists as a national conservation program. The NCS identifies 11 core areas
including conservation of biodiversity, pollution prevention and abatement, soil and water
conservation and preservation of cultural heritage and recommends immediate attention to
these core areas.
2 Biodiversity Action Plan
This plan recognizes EIA as an effective tool for identifying and assessing the effects of a
proposed operation on biodiversity.
Statutory Obligations
Page 2 of 2
3. ENVIRONMENTAL MANAGEMENT PLAN

3.1. Sampling Methodology
After the preliminary visit of the Jaffer Agro (Private) Limited and detailed discussion with the
factory officials, the recent environmental reports have been taken.
3.2. Monitoring Parameters

The testing of drinking water and wastewater was conducted by EPA certified laboratory. and the
results are shown in the following sections.
1.1 Test Results
1.1.1 Drinking Water Quality

Drinking water is available at site. The drinking water test results are in compliance with Sindh
Standard for Drinking Water Quality.
All the parameters like pH, chlorine and TDS were observed within the SSDWQ.
Graphical representation of Drinking Water results is provided below:
pH of Drinking water sample at Jaffer Agro (Pvt) Ltd
pH
7.2 7.4 7.6 7.8 8 8.2 8.4 8.6

pH
SEQS limit 8.5
Result 7.64
SEQS limit Result
Fig.3.1 pH of Drinking Water

Page 1 of 5
TDS of Drinking water Sample at Jaffer Agro (Pvt) Ltd
TDS (mg/L)
0 200 400 600 800 1000 1200
TDS (mg/L)
SEQS limit 1000
Result 510
SEQS limit Result
Fig.3.3 TDS of drinking Water
Total Hardness of Drinking water sample at Jaffer Agro

(Pvt) Ltd
Total Hardness (mg/L)
0 100 200 300 400 500 600
Total Hardness (mg/L)

SEQS limit 500
Result 222
SEQS limit Result
Fig.3.3 Total Hardness of Drinking Water

1.1.2 Waste Water
The liquid stream of non-contaminated waste includes sanitary wastewater from canteen and showers
which is disposed after complying with SEQS. Sample of wastewater was analyzed. The results were
well within the permissible limits.

Page 2 of 5
1.1.2.1 Discussion on Results of Wastewater

The test report is attached in Annexure II. The results are in compliance with SEQS for Liquid
Effluents. Temperature, TDS, pH, and Pesticide level are all in permissible limits. The test results are
presented in graphical form below:
Temperature of Wastewater sample at Jaffer Agro (Pvt)

Ltd
Temperature (Centigrade)
0 5 10 15 20 25 30 35 40 45
Temperature (Centigrade)
SEQS limit 40
Result 31
SEQS limit Result
Fig.3.8 Temperature of Wastewater
pH of Wastewater sample at Jaffer Agro (Pvt) Ltd
pH
0 1 2 3 4 5 6 7 8 9 10
pH
SEQS limit 9
Result 7
SEQS limit Result
Fig.3.9 pH of Wastewater

Page 3 of 5
TDS of Wastewater sample at Jaffer Agro (Pvt) Ltd
TDS (mg/L)
0 500 1000 1500 2000 2500 3000 3500 4000
TDS (mg/L)
SEQS limit 3500
Result 2750
SEQS limit Result
Fig.3.10 TDS of Wastewater

1.1.3 Stack emissions
Source of air pollution at JASPL are Dust collector system and the Diesel generator. Emissions from
the stack of dust collector and diesel generator was monitored.
1.1.3.1 Discussion on Results of Stack Emissions

The parameters monitored for the emissions include the Particulate Matter for Dust Collector system
emissions and Carbon Monoxide, Sulfur Dioxide, Nitrogen Oxides, Particulate Matter and Smoke for
generator emission. All the parameters were found to satisfying the limits of SEQS. Reports of stack
emissions are attached in annexure. Graphical representation of the parameters monitored have been
presented below.
Particulate Matter level in Dust collector system emission

at Jaffer Agro (Pvt) Ltd
Particulate Matter (mg/Nm3)
0 100 200 300 400 500 600

SEQS limit 500
Result 106
SEQS limit Result

Page 4 of 5
Fig.3.11 Particulate Matter in Dust Collector stack emission
CO & NOx level in Generator emission at Jaffer Agro (Pvt)

Ltd
NOx (mg/Nm3)
CO (mg/Nm3)
0 100 200 300 400 500 600 700 800 900
CO (mg/Nm3) NOx (mg/Nm3)

SEQS limit 800 600
Result 423 263
SEQS limit Result
Fig.3.12 CO & NOx in Generator emission
Sulfur Dioxide level in Generator emission at Jaffer Agro

(Pvt) Ltd
SO2 (mg/Nm3)
0 200 400 600 800 1000 1200 1400 1600 1800

SO2 (mg/Nm3)
SEQS limit 1700
Result 111
SEQS limit Result
Fig.3.13 SO2 in Generator emission

Page 5 of 5
Particulate Matter level in Generator emission at Jaffer

Agro (Pvt) Ltd
0 50 100 150 200 250 300 350

SEQS limit 300
Result 183
SEQS limit Result
Fig.3.14 Particulate Matter in Generator emission

1.1.4 Noise Monitoring
Noise generation source at Jaffer Agro Services (Pvt) Ltd. is the generator. Noise level monitoring of
generator and also ambient noise level monitoring of the facility was conducted.
1.1.4.1 Discussion on Results of Noise Level monitoring

The noise level monitoring of the noise emission from the generator revealed that it is higher than
the SEQS limits defined for industrial area. This may be due to the fact that the generator is not
frequently used and may require some engine tuning. Therefore, noise emission from the generator
is not a serious cause of nuisance.
Below is the graphical representation of the noise monitoring and reports have been attached in
annexure.

Page 6 of 5
Noise level from Generator at Jaffer Agro (Pvt) Ltd
Noise (dB(A))
72 73 74 75 76 77 78 79 80 81 82
Noise (dB(A))
SEQS limit 75
Result 81
SEQS limit Result
Fig.3.15 Noise Level of Generator
Ambient Noise level at Jaffer Agro (Pvt) Ltd
Back side Left corner
Back side Right corner
Front side Right corner
Front side Left corner
60 62 64 66 68 70 72 74 76
Front side Left corner Front side Right corner Back side Right corner Back side Left corner
SEQS limit 75 75 75 75
Result 66.6 69 69.3 65.6
SEQS limit Result
Fig.3.16 Ambient Noise Level of JASPL

Page 7 of 5
4. ENVIRONMENTAL MANAGEMENT PLAN

4.1. Objectives of Environmental Management Plan
The specific objectives of the EMP are to:
 Define the applicable legal requirements pertaining to agro-chemical products handling, storage and
disposal;
 Identify and establish a framework for environmental management of concerned operations within the
facility;
 Identify the key environmental issues that are relevant to the operations of the facility;
 Prevent pollution of soil, groundwater and surface water resources during operations;
 Ensure waste minimization and sound waste management practices;
 Define roles and responsibilities of key players;
 Define monitoring and reporting procedures; and
 Identify training requirements at various levels and provide a plan for implementation.
4.2. Scope of Environmental Management Plan

The scope of the Environmental Management Plan has been confined to the management of impacts
arising from agro-chemical products handling, storage and disposal. The scope of this EMP focuses
on the protection of environment and compliance of SEQS. This constitutes the significant endeavor
from fixation of priorities and provision of resources. The scope represents following points:
 Devising sound methods agro-chemical products, handling, storage and disposal;
 Minimizing impacts on physical, biological and social environment of the area;
 Contributing to innovation and definition of best environment practices in industrial units;
 Complying with statutory requirements and other environmental commitments; and
 Ensuring availability of resources for smooth operation and protection of environment.
4.3. Significance of Environmental Management Plan

This EMP signifies an approach for managing and monitoring environment related issues and describes the
institutional framework for environmental management and resource allocations to be carried out at the
above mentioned facility for mitigating the possible negative impacts which may cause degradation of the
environment.
This EMP has been prepared in accordance to environmental management guidelines that will be used as a
document by the company during handling, storage and disposal of agro-chemical products. This EMP is
based on the understanding of the sensitivity and behavior of environmental receptors at the location of the
facility, the legislative controls that apply to the facility and a review of good industrial & commercial
practices while operating in similar environments. This EMP satisfies the requirement of the Sindh
Environmental Protection Act (2014).
The environmental management and monitoring programs are implemented from the very early stages of
planning and execution phases. The monitoring data, observations recorded and test results / analysis are
vital and formulate legal documents to be kept in safe custody and may be provided to competent authority
as and when required in accordance to Sindh Environmental Protection Act, 2014.

Page 8 of 5
4.4. Management Approach

The environmental management will require specific approach in order to handle the issues effectively.
Management will assign the roles and responsibilities to be performed during its entire operations of
product handling. It is expected that a certain degree of redundancy is inevitable across all management’s
level, but will be in that order to ensure the compliance with the environmental management plan.
Jaffer Agro Services (Pvt.) Limited will look after the compliance of EMP during operations with respect to
product filling, handling and storage. It will ensure that all activities executed must comply with all the
environmental regulations as well as cooperation will be associated with concerned regulatory authorities
such as Sindh Environmental Protection Agency (SEPA).
Supervision and monitoring approaches by management during product filling, handling and storage in
accordance with environmental standards are given below:
 Product filling, handling and storage by qualified professionals with trained staff;
 Complying with the relevant legislation and regulations;
 Regularly reviewing of the impacts of various products etc. on the environment;
 Development of appropriate indicators in order to monitor core impacts;
 Recording results and preparing periodical reports; and
 Communicating openly with internal and external stakeholder on environmental issues, if relevant.
4.5. Organizational Structure of Jaffer Agro Services Private Limited

S.I.T.E., Karachi
The organizational structure of Karachi S.I.T.E facility is as Fig.3.1 below.
Figure 3.1: Organogram of JASPL
4.6. Roles and Responsibilities

Formal responsibilities are necessary to be designated in order to ensure that key procedures are executed
and desired functions are carried out effectively. The roles and responsibilities of all personnel with respect
to the implementation of EMP are as given under:”

Page 9 of 5
a) Supply Chain Manager

The EMP will be headed by the Supply Chain Manager. Some of the key role and responsibilities are
described below:
 To monitor the progress, development and implementation of this management plan
 To review EMP every year under the supervision of top management, taking issues and change EMP
accordingly with the solutions and suggestions;
 To provide reports for submission to relevant environmental agency (EPA); and
 To approve any change in decision making and authorities in consultation with Factory Manager, if
appropriate.
b) Factory Manager
Some of the key role and responsibilities are described below:
 To progress the EMP process through development towards implementation.
 To maintain balanced, holistic approach to the solution of concerned issues in accordance with the
compliance to the legislative requirements;
 Monitor and verify that environmental impacts are kept to a minimum, as far as possible;
 To ensure that the point of view of staff are considered and placed in the EMP accordingly;
 To consider and react to issues and solutions proposed by the HSE department;
 To cooperate and consult with Supply Chain Manager for providing reports for submission to relevant
environmental agency (EPA); and
 To approve any change in decision making and authorities in consultation with Supply Chain Manager,
if appropriate.
c) HSE Officer
The role of HSE Officer will be empowered by Factory Manager. Key responsibilities which an HSE
Officer will have to perform include:
 To maintain balanced, holistic approach to the solution of concerned issues in accordance with the
compliance to the legislative requirements;
 Monitor and verify that environmental impacts are kept to a minimum, as far as possible;
 To maintain injury and incident statistics;
 To provide professional guidance on questions relating to the environmental management and issues
raised by contractors/relevant personals; and
 To progress the EMP process through development towards implementation.
d) Individual Employees
Employees must assume a high level of responsibility to work safely and strive for an incident-free
workplace by:
 Considering the consequences of their acts on their safety and that of fellow employees;
 Following all general and job related HSE work procedures and practices;
 Detecting, reporting and correcting unsafe work behaviors or conditions;
 Applying HSE work practices both on and off the job;

Page 10 of 5
 Making or suggesting enhancement to the jobs at hand to reduce or eliminate the risk or stresses
associated with job performance;
 Reinforcing safe behavior; and
 Working safely and with regard for the environment is a condition of employment and no employee
should ever consciously perform an unsafe act.
e) Independent Monitoring Consultant
Independent Monitoring Consultant appointed will be headed by Factory Manager. The Independent
Monitoring Consultant (IMC) will:
 Ensure that all environmental parameters / provisions comply with the applicable standards;
 Ensure that day-to-day activities are carried out in an environmentally sound and sustainable manner;
 Organize periodic environmental training programs and workshops for the workers in consultation with
the administration; and
 Develop “good practice” guidelines to assist the Administrative staff in implementing the EMP.
4.7. Communications & Documentation

For effective monitoring, management and documentation of the environmental performance during the
operation, the Health, Safety and Environment (HSE) matters will be discussed during daily meetings held
on site. Environmental concerns raised during the meetings will be mitigated after discussions between the
Factory Manager and HSE Officer. Any issues that require attention of higher management of Jaffer Agro
Services (Pvt.) Limited will be communicated to them for action. The HSE Officer will also prepare a
monthly environmental report. Duplicates of the report will be provided to the higher management of Jaffer
Agro Services Pakistan Limited.
a) Kick-off Meeting
The aim of organizing the kick-off meeting is to define the environmental responsibilities, awareness to
EMP to the managing staff and to streamline the work plan according to the EMP. This meeting will be
arranged prior to commencement of activities.
b) Monthly HSE Workshop
Monthly HSE Workshop will be held to overview the monthly HSE performance of the site and to
train/refresh workers regarding HSE issues and hazards.
c) Quarterly HSE Meeting
Initially quarterly HSE meetings will be held after monthly HSE workshop. Aim of this meeting is to review
the progress of activities performed, explore ideas and problems, and discuss about the progress in
acquisition and analysis of information. Deadlines are re-evaluated in it and if necessary, the company
program is revised in these meetings.
d) Minutes of Meetings
In the end of quarterly meetings, minutes will be issued which comprises of the discussion made in the
meeting, issues discussed and decisions taken with the time frame for their implementation. Main points of
minutes for employees may be incorporated in the record register. These meeting minutes will also be
provided to the higher authorities of Jaffer Agro Services (Pvt.) Limited for their own record.

Page 11 of 5
4.8. Trainings
All employees are provided general environmental and safety awareness training and training about their
specific responsibilities. Training is also given for firefighting, fire drill and first aid. Training record is
attached in annexure.
The training will ensure that all employees under their obligation to exercise due diligence for
environmental matters. Employees in this instance mean all people working in the project area including
contractors and subcontractors. Training includes:
 Induction course;
 Emergency response program;
 Personnel responsibilities and awareness to emergency services;
 Awareness to hazardous material and MSDS;
 Familiarization with site environmental controls; and
 Other specific environmental trainings for relevant employees e.g., daily checks to maintain controls,
cleaning up spills, waste minimization.
During training, consideration of following areas of knowledge and experience are essential:
 Appreciation of properties of hazardous substances e.g., flammable, reactive etc., as well as, levels at
which they pose a considerable risk requiring protective measures;
 Knowledge of early-warning indicators, hazard/risk identification and ability to recognize potentially
hazardous situations;
 Acquaintance with engineering controls to evade the incidence of hazardous situations;
 Familiarity with capability and restraints of facility to respond the hazardous emergencies, ventilating
systems, shut off systems, containment strategies and emergency response measures;
 Awareness of use, repair/ maintenance of emergency response equipment as well as routine equipment
to health and safety monitoring and protection; and
 Awareness of methods and trials for decontamination personnel, equipment and facility following
potential chemical contaminations.

Page 12 of 5
4. IMPLEMENTATION OF ENVIRONMENTAL
MANAGEMENT PLAN
The success of the management plan will lie with its implementation. It is necessary to establish an HSE
department and organizing a team with direct responsibility for putting the plan into practice. This set-up
needs to be provided with adequate resources and an office base.
In order to implement EMP successfully during operation of the facility, it is required to detect the potential
environmental impacts associated with the project and to follow mitigation measures, monitoring plan,
administrative control and emergency response procedures accordingly. Training will also be required at
each step and stage of company, also if necessary to change management processes, will be documented
and available to the employees.
5.1. Potential Environmental Impacts and Mitigation Measures

a) Filling the Product
Impact Level-High
During filling, dripping or spillage may cause environmental contamination.
Mitigation Measures
 Filling lines should be properly checked regularly to maintain their performance.
 Ensure that any spillage is addressed instantaneously.
 Mask should be worn during the filling operation to avoid any inhalation of fumes/dust.
b) Transport of packed products
Impact Level-Medium
The pesticide products packed at the facility are properly sealed. However, during the transport, there
are chances of spillage of products and environmental contamination.
Mitigation Measures
 Remove all sharp objects from the loading area of the transporting vehicle before loading the
product.
 Ensure that the consignment is secure during transportation.
 Never keep packets of product near the driver’s seat or on the passenger’s seat.
 Do not carry heavy containers on your shoulder or on your head. Use a trolley to carry them.
c) Storage Conditions
Impact Level-High
Inadequate storage conditions can cause leakages and can lead to release of product into atmosphere
in the form of fumes or spills.
Mitigation Measures
 Packed products should always be stored in a cool, dry environment.
 The quantities of packed products should be kept to a minimum, in line with efficient operation,
their usage and shelf life.
 Hazardous chemicals should be clearly marked.
 MSDSs for each packed product should be available.
Implementation of Environmental Management Plan

Page 1 of 7
 Ensure that the product packs are properly sealed and tight.
 Packed products should be stored in such a manner that leaks cannot affect other substances in the
store. Liquids should not be stored above powders and solids.
 Packages are inspected regularly to ensure their integrity.
 Packed products are stored away from any heating and ignition sources.
 Sunlight can affect some plastic containers or the chemical contents. Containers and packed
products must not be stored in a location where they can be exposed to direct sunlight.
 Secondary containment should be available.
d) Waste Management
Impact Level-High
Improper disposal of leaked packets can generate hazardous waste.
Mitigation Measures
 Place hazardous waste in sealable containers prior to disposal. Containers should be filled, leaving
headspace for expansion of the contents. Often the original container is perfectly acceptable.
 Use appropriate container for containing chemical waste.
 Similar wastes may be mixed only if they are compatible.
 Do not discard waste into sink drains, with general waste, liquid wastes or with municipal solid
waste.
 Contact your waste collection contractors when you want to dispose of waste. They should be
notified as to the hazards of that particular chemical. They would then know the appropriate
method and place of disposal.
e) Fire Hazards
Impact Level-High
There is always risk of fire associated with chemicals.
Mitigation Measures
 Implementation of NFPA 30 “Flammable and Combustible Liquid Code” and NFPA 231
“Standard for General Storage of Chemicals” should be considered.
 Fire Alarms should be installed.
 Fire extinguisher arrangements will be ensured.
 Fire extinguisher should be easily accessible.
 Fire Drills should be practiced to ensure the employees are well equipped and trained to deal with
fire emergencies.
f) Spills
Impact Level-High
Spillage of products from container can cause soil and water pollution.
Mitigation Measures
 Packed products will be stored in covered and bounded areas, underlain with impervious lining.
 Regular inspections will be carried out to detect leakage in machines.
 Drums of chemical and overhead chemical tank will be provided with secondary containment
trays. Pallets of product bottles will be placed inside a concrete bunker.
 Contaminated soil will be removed and properly disposed after treatment such as incineration etc.

Page 2 of 7
 In case of hazardous spill, evacuate the area immediately. Isolate the hazard area. Keep out
unnecessary and unprotected personnel. Use personal protective equipment as required. Remove
or isolate incompatible materials as well as other hazardous materials. Contain and soak up spill
with absorbent that does not react with spilled product. Flush spill area. Dike spilled product to
prevent runoff.
g) Environment
Impact Level-Low
Spillage from a damaged containers can deteriorate the air quality.
Mitigation Measures
 Proper ventilation should be available.
 Mask should be worn before storing/handling leaked containers
h) Occupational Health and Safety
Impact Level-High
Transport and storage of products can cause injury and illness.
Mitigation Measures
 Investigation of incidents.
 Adoption of safe working practices.
 Showers and eye washers should be available.
 Use of PPEs (Gloves, Mask, goggles, coverall and etc.) should be ensured.
 Visible, illustrative and easily understood warning signs should be placed in all hazardous areas.
 Regular health and safety trainings should be provided to all workers and all new workers should
be provided training prior to work;
 Packed products will be handled with care and stored properly.
5.2. Mitigation Plan

Pollution prevention and risk management strategies aimed to eliminate, reduce, and minimize emissions
and contaminations that help in safe guarding the ecosystems and promote the health of natural
communities will be selected and implemented during the entire operations. Concerned persons responsible
to work on the mitigation and frequencies as mentioned in Mitigation Matrix (Table 4.1) should be strictly
adhered to.
5.3. Standard Symbols found in MSDS

Page 3 of 7
GHS Pictograms
5.4. Risk Assessment

The success of the management plan will lie with its implementation. It is necessary to establish an HSE
department and organize a team with direct responsibility for putting the plan into practice. This set-up
needs to be provided with adequate resources and an office base.
In order to implement EMP successfully during operation of the facility, it is required to detect the
environmental risks associated with the project and to follow mitigation measures, administrative control
and emergency response procedures accordingly. Training will also be required at each step and stage of
company, also if necessary, change management processes, will be documented and available to the
employees.
Pollution prevention and risk management strategies aimed to eliminate, reduce, and minimize emissions
and contaminations that help in safe guarding the ecosystems and promote the health of natural
communities, that is why preventive measures will be taken during transporting, handling, storing and
disposing Chemicals in various operations.
Concerned persons are responsible to work on the mitigation as mentioned in Mitigation Matrix (Table 4.1).
JASPL will be required to comply with the mitigation measures throughout its operations.
EMP needs to be revised on timely basis to keep up-to-date as per the requirements comes up regularly.
Therefore, outlining the responsibilities and activities associated with the maintenance of the EMP is

Page 4 of 7
essential. EMP revision procedures must include requirements for notification of the appropriate
government and municipal agencies so that their role is also played in the overall management process.

Page 5 of 7
Table 4.1 Mitigation Matrix

Sr. Monitoring
Aspects Impacts Mitigation Measures Responsibility
No. Frequency
 Products that can produce fumes, dusts should always be
handled in a well-ventilated area. Use of containment devices
such as fume hoods, and gas cabinets is particularly
advisable. A fume hood, glove box or other appropriate
Leaks, spills, and exhaust ventilation is necessary when handling particularly
accidental release of hazardous substances.
Filling of  Proper PPE’s (Goggles, Gloves, masks etc.) should be
1. volatile products, HSE Officer Ongoing process
Products available
Incompatible mixing of
products  Ensure the efficacy of ventilation systems.
 Frequently trainings conducts regarding the handling of
Products
 Eye washer must be installed in the area
 Spill kit should available in the area.
 Information specified in sub-rule (1) of rule 21 of Hazardous
Substance Rules, 2014 will be followed.
 Remove all sharp objects from the loading area of the
Spillage of Product and transporting vehicle before loading the Product.
Transport of
2. environmental  Ensure that the consignment is secure when transporting HSE Officer Ongoing process
Products
contamination hazardous product
 Never keep hazardous product near the driver’s seat or on the
passenger’s seat.
 Use a trolley to carry heavy product containers.
 Do not handle product with bare hands, no matter how
harmless they may seem.
 After handling product, hands should be washed prior to
Leaks, spills, and eating or drinking.
Handling of
3. accidental mixing of  Do not eat and drink while working with product. HSE Officer Ongoing process
Product
incompatible product  Do not light a match or smoke tobacco close to inflammable
product
 Keep work surfaces and containers clean.
 Use corrosion-resistant tools and equipment.

Page 5 of 7

Sr. Monitoring
No. Frequency
 Never open the packed material
 Products should always be stored in a cool, dry environment
far from busy work areas.
 The quantities of hazardous products stored should be kept to
a minimum, in line with efficient operation, their usage and
shelf life,
 Hazardous Raw material/products should be clearly marked.
 MSDS for each chemical should be available and displayed at
the areas where chemicals are stored and handled.
 Ensure that the Raw material and product containers and their
seals or stoppers are appropriate for the type and quantity of
product stored. As far as is practicable, product should be
stored in the containers in which they are supplied.
 Incompatible products are segregated from one another (e.g.
Products degradation by fire isolation in a product storage cabinet or segregation in
Storage of Raw
which can become space).
4. material and HSE Officer Ongoing process
more hazardous during  Raw material and finished Products should be stored in such
Product
storage a manner that leaks cannot affect other substances in the
store. Secondary containment should be provided under
drums and vessels of liquid raw material/finished product.
 Liquids should not be stored above powders and solids.
 Packages/containers should be inspected regularly to ensure
their integrity. Leaking or damaged packages/containers
should be removed to a safe area for repacking or disposal
immediately. Labels should be reattached or replaced, as
necessary, to clearly identify the contents of the package.
 Products are stored away from any hot surface and ignition
sources.
 Sunlight can affect some plastic containers or their contents.
Containers and Products must not be stored in a location
where they are not exposed to direct sunlight.

Page 6 of 7

Sr. Monitoring
No. Frequency
 Secondary containment should be available.
 Stockpiling of hazardous Products should be avoided.
 A waste management plan will be developed and includes
information specified in sub-rule (1) of Rule 19 of Hazardous
Substance Rules, 2014.
 Place hazardous waste in sealable containers prior to disposal.
Containers should be filled, leaving headspace for expansion
of the contents. Often the original container is perfectly
acceptable.
 Use appropriate container for disposing waste.
 Similar wastes may be mixed only if they are compatible.
Disposal of Generation of HSE Officer/Factory
5.
Waste hazardous waste  Do not discard waste Raw material/Products into sink drains, Manger Ongoing process
with general waste, liquid wastes or with municipal solid
waste.
 It is the Products user’s responsibility to identify and properly
label all Products wastes.
 Contact your waste collection contractors when you want to
dispose of the waste. The waste contractor should be notified
about the hazardous nature of that material/Products. They
would then know the appropriate method and place of
disposal.

Page 7 of 7
6. EMERGENCY RESPONSE PLAN

Emergency can be defined as a sudden event causing or has the potential to cause serious human injury and
/or environmental degradation of large magnitude. The best “cure’’ for an emergency is, of course,
“prevention”. The probable emergency situation can be:
 Serious fire or explosion
 Major Spillage
 Natural calamity such as heavy rain, flooding, dust storm or cyclone earthquake etc.
 Bomb threat or any sabotage / terrorist activity
 Any other incident involving all or large part of the premises and its workers.
Emergency Response Management is provided by a small team of senior managers (the “Control
Committee”) who in turn will direct all response activities through the Emergency Response Team.
a) Objectives
The main objective of this plan is to establish the general guidelines for the actions to be taken in the event
of fires, explosion, accidents, disasters, sabotage etc. aimed at minimizing their effects and consequences, in
order to protect the lives of own or third-party personnel present in facility as well as neighboring factories
area.
In this regard Jaffer Agro Services (Pvt.) Limited should develop:
 The Emergency Response Plan
 The Material Safety Data Sheets (MSDS) for all chemicals and displayed in local language at the
designated areas on each floor where these chemicals are used.
b) Risk Management
The management of contingencies at facility is based on:
 Early detection (alarms, smoke detectors, setting off of safety elements);
 Confinement of emergency areas;
 Application of the adequate response procedures; and
 Follow-up and monitoring.
c) Evacuation Plan
The following alarm signal(s) will be used to begin evacuation of the facility (check all which applies):
 Bells
 Horns/Sirens
 Verbal (i.e. shouting)
 Other (specify)
 Evacuation map is prominently displayed throughout the facility at each section/floor.
Emergency Response Plan

Page 1 of 5
Table 5.1 : Evacuation Plan

Emergency Contacts Phone No. Address
Fire/Ambulance
Emergency Services
Fire Department
Nearest Hospitals
d) Emergency Equipment
The emergency equipment at the facility will be listed and Emergency Equipment Inventory table will be
completed.
Table 5.2: Emergency Equipment Inventory
Equipment Category Equipment Type Location Description
 Protective Aprons/Coats,
Boots, Gloves and Suits
 Face Shields
 First Aid Kits (describe)
 Portable Eye Wash Kits
Personal Protective Equipment,
 Safety Glasses / Splash
Safety, and First Aid Equipment
Goggles
 Safety Showers
 Self-Contained Breathing
Apparatus
 Other (describe)
 Fire alarm and detection
system
Fire Extinguishing Systems  Fire Extinguisher Systems
(describe)
 Absorbents (describe)
Spill Control Equipment and  Decontamination (describe)
Decontamination Equipment  Sumps (describe)
 Intercoms
Communications and Alarm  Telephones
Systems  Hooters
Additional Equipment
(Use Additional Pages if
Needed)
e) Response Strategy
Upon the occurrence of the emergency, the Plan will be developed under the following conditions:
a. First Stage: Notification
Internal Communication
System will be established for the command post, alternative posts and for the personnel that forms part of
the response Brigade. Furthermore, message forms will be established to record at least the following
information: Name of informant, location and place of the emergency, number of people affected and, if
possible, an estimate of the type of injuries and/or damages, among others.

Page 2 of 5
External Communication
In the event of emergency, the concerned persons must be informed through the fastest means: telephone
and fax; and
 Local Authorities will be advised by telephone.
 The relatives of the injured person, as soon as he is evacuated to a hospital.
 To the extent possible, the press will be notified after the accident has been investigated and by the
person designated by Management.
b. Second Stage: initial assistance / rescue
A joint evaluation of the status of the event will be made, the conditions of the site, the environmental
characteristics that warrant a safe development of rescue actions, provision of first aid and transportation of
the injured to a medical unit.
Trained emergency teams must be prepared to act as required, and a reserve team must be available. All
personnel who are not essential to fight the emergency must be evacuated to a safe place where there must
be communication equipment available to count the number and condition of the personnel. In the event of
fire, the execution or fighting phase will be implemented immediately.
c. Third stage: Response Operations
Response Operations refer to:
 Firefighting using extinguishers or pressure water network or foam;
 Spill control (of chemicals or lubricants) using absorbing material or creating dyke/confinement;
 Medical assistance and evacuation of injured personnel;
 Evacuation of all personnel if their lives are in danger (in the event of earthquakes, tsunamis or other
factors); and
 Application of a monitoring program and a mitigation plan.
d. Fourth Stage: Evaluation of the Plan and of damages
Once response operations have concluded, the development and results of the Plan must be evaluated in
order to suggest recommendations that help addressing the deficiencies for the purpose of improving
response operations. A record of damages will be prepared as part of the final emergency report. The
resources used, lost and recovered will be detailed in said register.

Page 3 of 5
5.1 Spill Management Plan

Chemical spills that are not appropriately managed have the potential to harm the environment. By taking
certain actions, it can be ensured that the likelihood of spills occurring is reduced and that the effect of spill
is minimized. To prevent spills and to help the cleanup process of any spill, the employees should be aware
of spill management procedures. By formalizing these procedures in writing, employees can refer to them
when required thus avoiding undertaking incorrect procedures. A detailed spill management plan should be
prepared for the Chemicals Spills. The plan should contain the following:
 Identification of potential sources of spills and the characterization of spill material and associated
hazards
 Risk assessment (likely magnitude and consequences)
 Steps to be undertaken when a spill occurs (stop, contain, report, clean up and record)
 A map showing the locations of spill kits or other contingency measures.
Avoiding spills
By actively working to prevent spills; money and time can be saved by not letting resources go to waste. In
addition, the environment is protected from contaminants that can potentially cause harm. All chemicals
must be stored in sealed containers that are free of leakage. All containers should be on sealed ground and in
a covered area. Sharp parts must be kept away from liquid containers to avoid damage and leaks.
Spill Kits
Spill kits are purpose built units that contain several items useful for cleaning up spills that could occur.
Typical items are:
 Safety gloves and appropriate protective clothing (depending on the type of chemicals held onsite)
 Absorbent pads, granules and/or pillows
 Booms for larger spills
 Mops, brooms and dustpans
Spill kits are used to contain and clean up spills in an efficient manner. Sufficient number of spill kits should
be provided. Spill kits should be kept in designated areas that are easily accessible to trained staff.
After cleaning up a spill, the materials used to clean up must be disposed of correctly.
Responding to Spills
Following steps will be followed in case of any chemical spill:
 DO NOT attempt to clean up any spill if, it is not safe to do so.
 STOP, GET BACK and ASSESS the following:
 Identify the spilled material (it will be dangerous if material is not identified).
 Ascertain the quantity of spillage.
 Check its Material Safety Data Sheet (MSDS) for hazard identification.
 Care for any risks to life and health.
 Identify as quickly as possible the spilled material. It is important to ensure that correct actions are
taken to treat spilled material.

Page 4 of 5
 Raise a verbal alarm for help if it is a minor spillage. Quite often timely action can avert a major
outbreak.
 Activate the alarm from the nearest source. If there is any doubt about the scale of the spillage, treat it
as major spillage.
 Provide Medical Assistance / First Aid to anyone exposed to chemicals as per instructions provided in
its MSDS.
 Isolate as soon as possible, the source of spill by wearing the appropriate PPE’s. This may mean closing
a valve, up righting a container, etc.
 Any material used in the treatment of the spillage, must be treated as contaminated waste and disposed
of properly. Tools or equipment must be thoroughly decontaminated.
For Solids
 Use vacuum cleaner or collect the spilled material in a suitable container.
For Liquids
 Contain the spilled material in a small area by using spillage containment equipment e.g. absorbents,
sawdust, sand etc. Prevent material flow into drains.
 Transfer the material if possible, to a new container or place the damaged container in oversize
container.
For Gases/Vapors
 Take special precautions in handling and containment of Volatile Solvents, which may form a
hazardous vapor atmosphere.
 Note the wind direction and if necessary, go to the safe enclosed area for self- protection.
 Use appropriate RPE’s for the clean-up.

Page 5 of 5
6 ENVIRONMENTAL MONITORING PLAN

6.1 Objectives
Environmental Monitoring is carried out to evaluate the implementation of the environmental
mitigation measures as suggested in the environmental reports.
The plan of environmental monitoring has the following objectives:
 Monitor the execution of different activities and check their compliance with the approved standards;
 Outline environmental protection measures to be followed;
 Ensure that targets to minimize environmental impacts are met;
 Document environmental concerns and appropriate protection measures;
 Providing awareness and plans to personnel and contractors for environmental protection to minimize
environmental impacts;
 Provide contingency plans to protect against accidents;
 Communicate changes through the review process; and
 Monitor post implementation phase.
An Independent Monitoring Consultant (IMC) shall be appointed to ensure compliance with the EMP,
and to carry out monitoring activities. The IMC must have the appropriate experience and
qualifications to undertake the necessary tasks.
All instruments and devices used for the measurement or monitoring of any aspect of EMP must be
calibrated and appropriately operated and maintained.
6.2 Monitoring Parameters

In order to meet the above objectives, the following parameters need to be monitored:
 Occupational Health and Safety;
 Liquid Effluents;
 Solid waste; and
 Stack Emission Monitoring
A monitoring program for the above areas is given in Table 6.1 with the frequencies to conduct monitoring
and responsible authorities to conduct monitoring. These issues may be eased or nipped at root as much
as possible through environmental control measures and environmental monitoring process.
6.3 Non-Conformance & Corrective Action

The monitoring of the unit may raise non-conformances of the EMP. Non-conformances may also be
identified through incidents, emergencies and complaints. In order to correct those non-conformances,
the sources must be determined and corrective actions must be identified.
Environmental Monitoring Plan

Page 1 of 2
Table 6.1: Environmental Monitoring Plan

Type of
Monitoring
Pollution / Monitoring Areas Parameters to monitor Reason to monitor Responsibility
frequency
Hazard
 Outlet of the wastewater Parameters to monitor:  Monthly during Protection of Water resources
Wastewater Effluent Flow, Pesticides HSE Officer
discharge operations and legal compliance
All time activity  Legal obligations HSE Officer
Collection, handling, storage Type of solid waste, quantity and
Solid Waste and report issued  Soil and ground water
and disposal areas management methodology
every six months contamination
Visual observations HSE Officer
 Fire Accident records of
Monthly inspection  Legal Obligations
Operational  Hazardous spill of  Fire Hazards
and reporting  Occupational and Local
Risk chemicals, used oil in  Safety Protocols
biannually Safety
machines and fuels  Spill on Land
 Spill on Water
Water analysis for following priority HSE Officer
parameters:
 pH, Turbidity, Total Hardness (as
All allocated areas of potable CaCO3) , Nitrites (NO2) , Nitrates Occupational Health and
Drinking Water Every three months
water (NO3), Phenolic Compounds (as Legal Obligations
Phenol) Chloride (as Cl-), Fluoride
(as F-), Residual Chlorine, Total
Coliform, Fecal Coliform, E Coli
Stack All Stacks of main Filling CO, NOx, SOx, SPM, Smoke and Monthly during  Legal Obligations (SEQS) HSE Officer
Emissions equipment and Generator Noise operations  Protection of Ambient air
Environmental Monitoring Plan

Page 2 of 2
8. ENVIRONMENTAL COMPLIANCE
The management will be responsible for the regular audit and review of the environmental management
plan. This will include both on-site auditing and review of performance reports. Additional onsite
inspections and investigations will be undertaken in the event of significant environmental incidents.
The management will participate in the audits and inspections and investigations. The management will also
be responsible for regular review of the environmental performance of the site and site personnel, and for
the reporting on the implementation of commitments made in the EMP.
In particular, there will be:
 Periodic Monitoring reports
 A review and improvement of the EMP
8.1. Maintenance of EMP

The EMP needs to be revised on timely basis to keep it up-to-date as per the requirements that come up
regularly. Therefore, outlining the responsibilities and activities associated with the maintenance of the EMP
is essential. EMP revision procedures must include requirements for notification of the appropriate
government and municipal agencies so that their role is also played in the overall management process.
Environmental Compliance
Page 1 of 1
ANNEXURES
Annexures
ANNEX – I
ISO 9001:2015 Certificate
Annex – I: ISO 9001:2015 Certificate

Annex – I
ANNEX – II
Environmental Monitoring Reports
Annex – II: Environmental Monitoring Reports

Annex – II
ANNEX – III
Sindh Environmental Protection Act, 2014
Annex – III: Sindh Environmental Protection Act, 2014

Annex – III
ANNEX – IV
SEPA (Review IEE & EIA) Regulation, 2014
Annex – IV: SEPA (Review IEE & EIA) Regulation, 2014

Annex – IV
GOVERNMENT OF SINDH
SINDH ENVIRONMENTAL PROTECTION AGENCY
Karachi dated the 16th December, 2014.
NOTIFICATION
NO.EPA/TECH/739/2014:- In exercise of the powers conferred by section 37 of the Sindh
Environmental Protection Act, 2014, the Sindh Environmental Protection Agency, with the
approval of Government, is pleased to make the following regulations, namely:-
1. Short title and commencement
(1) These regulations may be called the Sindh Environmental Protection Agency
(Review of Initial Environmental Examination and Environmental Impact
Assessment) Regulations, 2014.
(2) They shall come into force at once.
2. Definitions.-
(1) In these regulations, unless there is anything repugnant in the subject or

context -
(a) “Act” means the Sindh Environmental Protection Act, 2014 (VIII of
2014);
(b) “Agency” means the Sindh Environmental Protection Agency as

defined under section 2(ii);
(c) “Committee” means the Environmental Assessment Advisory

Committee constituted under regulation 24;
(d) “Director General” means the Director General of the Agency;
(e) “EIA” means an environmental impact assessment as defined in section

2(xv);
(f) “IEE” means an initial environmental examination as defined in section

2(xxx);
(g) “section” means a section of the Act.
(h) "Firm” means the Environmental Consulting Firm certified by the

Agency;
1
(i) “Environmental Sensitive areas” means the area which falls under
sensitive sites like protected areas, or the sites which may have
crucial and growing importance;
(j) “protected area” means any area which safeguards the earths precious
bio-diversity protect outstanding areas of natural beauty and
conservation of cultural significance;
(k) “Schedule” means the Schedule to these regulations;
(l) “urban area” means an area within the limits of a town, municipality or
city and includes any area declared as such by Government by
notification in the official gazette;
(2) All other words and expressions used but not defined in these regulations shall
have the same meaning as are assigned to them in the Act.
3. Projects requiring an IEE
A proponent of a project falling in any category listed in Schedule-I shall file an IEE
with the Agency, and the provisions of section 17 shall apply to such projects.
4. Projects requiring an EIA
A proponent of a project falling in any category listed in Schedule-II shall file an EIA
with the Agency, and the provisions of section 17 shall apply to such projects.
5. Projects requiring checklist
A proponent of a project falling in any category listed in Schedule-III shall file

environmental checklist with the Agency and the provisions of section 17 shall apply
to such projects.
6. Projects not requiring an IEE or EIA
(1) A proponent of a project not falling in any category listed in Schedules-I, II

and III shall not be required to file an IEE or EIA:
Provided that the proponent shall file -
(a) an EIA, if the project is likely to cause an adverse environmental

effects;
(b) an application for projects not listed in Schedules-I, II and III in respect
of which the Agency has issued guidelines for construction and
operation for approval accompanied by an undertaking and an affidavit
that the aforesaid guidelines shall be fully complied with.
2
(2) Notwithstanding anything contained in sub-regulation (1), the Agency may
direct the proponent of a project, whether or not listed in Schedule I or II or III,
to file an IEE or EIA or environmental check list, for reasons to be recorded in
such direction:
Provided that no such direction shall be issued without the recommendations in

writing of the Committee.
(3) The provisions of section 17 shall apply to a project in respect of which an IEE
or EIA or environmental checklist is filed under sub-regulation (1) or (2).
7. Preparation of IEE/EIA and environmental checklist
(1) The Agency may issue guidelines for preparation of an IEE or an EIA or an
environmental checklist, including guidelines of general applicability, and
sectoral guidelines indicating specific assessment requirements for planning,
construction and operation of projects relating to particular sector.
(2) Where guidelines have been issued under sub-regulation (1), an IEE or EIA or
environmental checklist shall be prepared, to the extent practicable, in
accordance therewith and the proponent shall justify in the IEE or EIA or in
environmental checklist any departure therefrom.
8. Review Fees
The proponent shall pay, at the time of submission of an IEE or EIA or environmental
checklist, a non-refundable review fee to the Agency as per rates shown in
Schedule-IV
9. Filing of IEE, EIA and environmental check list.
(1) Ten hard copies and two electronic copies for an IEE and EIA reports shall
be filed with the Agency prepared by Firm.
(2) Every IEE and EIA shall be accompanied by -
(a) an application, in the form prescribed in Schedule-V;
(b) copy of receipt showing payment of the Review Fee.
(c) no objection certificates from the relevant departments in case of EIA

shall be the part of reports;
(d) the environmental check list as per its guidelines.
10. Preliminary scrutiny
(1) Within fifteen working days of filing of the IEE or EIA or environmental check
3
list, the Agency shall –
(a) confirm that the IEE or EIA or environmental check list is

complete for purposes of initiation of the review process; or
(b) require the proponent to submit such additional information as

may be specified; or
(c) return the IEE or EIA or environmental checklist to the

proponent for revision, clearly listing the points requiring
further study and discussion.
(2) Notwithstanding anything contained in sub-regulation (1), the Agency may require
the proponent to submit an additional information at any stage during the review
process.
11. Public participation
(1) In the case of an EIA, the Agency shall simultaneously with issue of confirmation of
completeness under sub-regulation (2) of regulation 9, cause to be published in any English
or Urdu national newspaper and in a local newspaper of general circulation in the area
affected by the project, a public notice mentioning the type of project, its exact location, the
name and address of the proponent and the places at which the EIA of the project can, subject
to the restrictions in sub-section (3) of section 17, be accessed.
(2) The notice issued under sub-regulation (1) shall fix a date, time and place of public
hearing for any comments on the project or its EIA.
(3) The date fixed under sub-regulation (2) shall not be earlier than fifteen days from the
date of publication of the notice.
(4) The Agency shall also ensure the circulation of the EIA to the concerned Government
Agencies and solicit their comments thereon.
(5) All comments received by the Agency from the public or any Government Agency
shall be collated, tabulated and duly considered by it before decision on the EIA.
(6) The Agency may issue guidelines indicating the basic techniques and measures to be
adopted to ensure effective public consultation, involvement and participation in EIA
assessment.
12. Review
(1) The Agency shall make every effort to carry out its review of the
environmental checklist within thirty days, IEE within sixty days, and of the
EIA within four months of issue of confirmation of completeness under
regulation 9.
4
(2) In reviewing the EIA, the Agency shall consult such Committee of Experts be
constituted for the purpose by the Director General, and may also solicit
views of concerned Advisory Committee, if any, constituted by the Agency.
(3) The Director-General may, where he considers it necessary, constitute a

committee to inspect the site of the project and submit its report on such
matters as may be specified.
(4) In reviewing the IEE, the Director General may constitute a committee
of the officers from within the Agency on case to case basis in view of
the jurisdiction and location of the project for the purpose to extend final
recommendation about the approval or rejection of the IEE.
(5) In reviewing of the IEE, the Director General may direct the proponent
and Firm to present the report before the committee as given under sub-
regulation (4) and the Director General may also invite environmental
experts from outside the Agency for the purpose of assistance.
(6) The review of the IEE or EIA by the Agency shall be based on quantitative and
qualitative assessment of the documents and data furnished by the proponent,
comments from the public and Government Agencies received under
regulation 10, and views of the committees mentioned in sub-regulations (2)
and (3) above.
(7) The environmental check list shall be reviewed as per guidelines issued by the
Agency.
13. Decision
(1) Subject to regulation 9 and 11, the documentary evidence in the form of videos
(soft copies) of public hearing shall be submitted by the proponent at the time of
environmental approval or at any stage of review process, to the Agency.
(2) On completion of the review, the decision of the Agency shall be communicated to
the proponent in the form prescribed in Schedule-VI in the case of an IEE and
environmental check list, and in the form prescribed in Schedule-VII in the case of an
EIA and for environmental checklist.
14. Conditions of approval
(1) Every approval of an IEE or EIA or check list shall, in addition to such
conditions as may be imposed by the Agency, be subject to the condition that
the project shall be designed and constructed, and mitigatory and other
measures adopted, strictly in accordance with the IEE or EIA or
environmental check list, unless any variations thereto have been specified in
5
the approval by the Agency.
(2) Where the Agency accords its approval subject to certain conditions, the
proponent shall -
(a) before commencing construction of the project, acknowledge acceptance

of the stipulated conditions by executing an undertaking in the form
prescribed in Schedule-VIII;
(b) before commencing operation of the project, obtain from the Agency
written confirmation that the conditions of approval, and the
requirements in the IEE or EIA or environmental check list relating to
design and construction, adoption of mitigatory and other measures and
other relevant matters, have been duly complied with.
15. Confirmation of compliance
(1) The request for confirmation of compliance under clause (b) of sub-regulation
(2) of Regulation 13 shall be accompanied by an Environmental Management Plan indicating
the measures and procedures proposed to be taken to manage or mitigate the environmental
impacts for the life of the project, including provisions for monitoring, reporting and
auditing.
(2) Where a request for confirmation of compliance is received from a proponent,

the Agency may carry out such inspection of the site and plant and machinery and seek such
additional information from the proponent as it may deem fit:
Provided that every effort shall be made by the Agency to provide the
requisite confirmation or otherwise within twenty days of receipt of the
request, with complete information, from the proponent.
(3) The Agency may, while issuing the requisite confirmation of compliance,
impose such other conditions as the Environmental Management Plan, and the operation,
maintenance and monitoring of the project as it may deem fit, and such conditions shall be
deemed to be included in the conditions to which approval of the project is subject.
16. Deemed approval
The period for communication of decision stipulated in sub-section (4) of section 17

shall commence from the date of filing of an IEE or EIA or environmental check list in
respect of which confirmation of completeness is issued by the Agency under clause
(a) of sub-regulation (1) of regulation 9.
17. Extension in review period
Where the Agency in a particular case extends the period of four months under the
provisions of sub-section (4) of section 17, it may extend the further period as it may
6
deem fit, for the reasons to be recorded in writing thereof.
18. Validity period of approval
(1) The approval accorded by the Agency under section 17 read with regulation
12 shall be valid, for commencement of construction, for a period of three
years from the date of issue.
(2) If construction is commenced during the initial three years validity period, the
validity of the approval shall stand extended for a further period of three years from the date
of issue.
(3) After issue of confirmation of compliance, the approval shall be valid for a
period of three years from the date thereof.
(4) The proponent may apply to the Agency for extension in the validity periods
mentioned in sub-regulations (1), (2) and (3), which may be granted by the Agency in its
discretion for such period not exceeding three years at a time, if the conditions of the approval
do not require significant change:
Provided that the Agency may require the proponent to submit a fresh IEE or
EIA, if in its opinion changes in location, design, construction and operation of
the project so warrant.
19. Entry and inspection
(1) For the purpose of verification of any matter relating to the review or to the
conditions of approval of an IEE or EIA or environmental check list prior to, before or
during and after commencement of construction or operation of a project, duly authorized
staff of the Agency shall be entitled to enter and inspect the project site, factory building and
plant and equipment installed therein.
(2) The proponent shall ensure full cooperation of the project staff at site to
facilitate the inspection, and shall provide such information as may be required by the
Agency for this purpose and pursuant thereto.
20. Monitoring
(1) After issue of approval, the proponent shall submit a report to the Agency on
completion of construction of the project.
(2) After issue of confirmation of compliance, the proponent shall submit an

annual report summarizing operational performance of the project, with
reference to the conditions of approval and maintenance and mitigatory
measures adopted by the project.
7
(3) The proponent shall, in order to enable the Agency to effectively monitor
compliance with the conditions of approval, furnish such additional
information as the Agency may require.
21. Cancellation of approval
(1) Notwithstanding anything contained in these regulations, if, at any time, on the basis
of information or report received or inspection carried out, the Agency is of the
opinion that the conditions of an approval have not been complied with, or that the
information supplied by a proponent in the approved IEE or EIA or environmental
check list is incorrect, it shall issue notice to the proponent for show cause within two
weeks of receipt thereof as to why the approval should not be cancelled.
(2) In case no reply is received or if the reply is considered unsatisfactory, the Agency
may, after giving the proponent an opportunity of being heard -
(i) require the proponent to take such measures and to comply with such
conditions within such period as it may specify, failing which the
approval shall stand cancelled; or
(ii) cancel the approval.
(3) On cancellation of the approval, the proponent shall cease construction or operation of
the project forthwith.
(4) Any action taken under this regulation shall be without prejudice to any other action
that may be taken against the proponent under the Act or rules or regulations or any
other law for the time being in force.
22. Registers of IEE,EIA and Check list projects
Separate Registers to be maintained by the Agency for IEE, EIA and environmental
check list projects under sub-section (6) of section 17 shall be in the form prescribed
in Schedule-IX.
23. Environmentally sensitive areas
(1) The Agency may, by notification in the official Gazette, designate an area to
be an environmentally sensitive area.
(2) Notwithstanding anything contained in regulations 3, 4 and 5, the proponent of

a project situated in an environmentally sensitive area shall be required to file
an EIA with the Agency.
(3) The Agency may from time to time issue guidelines to assist proponents and
other persons involved in the environmental assessment process to plan and
prepare projects located in environmentally sensitive areas.
8
(4) Where guidelines have been issued under sub-regulation (3), the projects shall
be planned and prepared, to the extent practicable, in accordance therewith and
any departure therefrom justified in the EIA pertaining to the project.
24. Environmental Assessment Advisory Committee.- For the purpose of rendering

advice on all aspects of the environmental assessment including guidelines procedure and
categorization of projects, the following Advisory Committee shall be constituted:-
(i) Director Technical, Sindh Environmental Protection Agency Chairman

(EIA/IEE)
(ii) Chief Environment, Planning and Development Department Member
(iii) Four representative on each of industry, non-Governmental Members

organization, legal and other experts
25. Repeal and Savings. (1) The provisions of the Pakistan Environmental Protection
Agency Review of Initial Environmental Examination and Environmental Assessment Impact
Regulations 2000, to the extent of the Province of Sindh are hereby repealed.
(2) All orders made, notification issued, actions taken under the repealed Regulations
shall remain in force until amended, altered or repealed by the provisions of these Rules.
DIRECTOR GENERAL
SINDH ENVIRONMENTAL PROTECTION
AGENCY
9
SCHEDULE I
(See Regulation 3)
A. Agriculture, Livestock and Fisheries
1. Poultry, livestock, stud and fish farms
2. Projects involving packaging, formulation, cold storage and warehouse of

agricultural products.
B. Energy
1. Hydroelectric power generation less than 50 MW
2. Thermal power generation less than 100MW
3. Coal fired power plants with capacity less than 50 MW
4. Transmission lines less than 11 KV, and grid station
5. Waste-to-energy generation projects including bio-mass less than 25 MW
6. Solar project
7. Wind project
C. Oil and Gas projects:
1. Oil and gas 2D/3D Seismic survey and drilling activities
2. Oil and gas extraction projects including exploration and production located
outside the environmentally sensitive areas
3. Construction of LPG storage facilities
4. Construction of LPG,CNG filling station and petrol pumps
D. Manufacturing and processing
1. Ceramics and glass units less than 500 million
2. Food processing industries with total cost less than Rs. 200 millions
3. Pharmaceutical units.
4. Marble units
10
5. Carpet manufacturing units
6. Rice mills, ghee/oil mills ,
7. Brick kilns
8. Stone crushing units
9. Man-made fibers and resin projects with total cost less than Rs. 200
millions
10. Manufacturing of apparel, textile garments unit , including dyeing, bleaching

and printing, with total cost less than Rs.50 million
11. Wood products with total cost more than Rs.100 million
12. Steel re-rolling mills
13. Recycling plants
E. Mining and mineral processing
Commercial extraction of sand, gravel, limestone, clay, sulphur and other

minerals not included in Schedule II with total cost less than Rs.100 million
1. Crushing, grinding and separation processes
2. Smelting plants with total cost less than Rs100 millions
F. Transport
1. Flyovers, underpasses and bridges having total length less than 500 meters
G. Water management, dams, irrigation and flood protection
1. Dams and reservoirs with storage volume less than 25 million cubic meters of
surface area less than 4 square kilometers
2. Small-scale irrigation systems and drainage system with total cost less than
Rs. 100 million
H. Water supply and filtration
Water supply schemes and filtration plants with total cost less than 100 million
(Including projects of maintenance, up gradation, reconstruction of existing projects.)
I. Waste disposal and treatment
11
1. Solid and non-hazardous waste with annual capacity less than 10,000 tons
2. Waste water treatment for sewage treatment facility with total cost less than 200M
3. Industry specific Waste water treatment facility for Industrial effluent (small scale
plant)
J. Urban development
1. Housing schemes less than 10 acres
2. Mutli-story buildings having residential and commercial setup on the total plot
size is less than 2000 sq.yards
3. Hospitals with capacity of 50 beds, health care unit/laboratories with 500

OPD/day.
4. Construction of Educational, Academic institutions on land less than 10 acres.
K. Other projects
Any other project for which filing of an IEE is required by the Agency under sub-
regulation (2) of Regulation 6.
12
SCHEDULE II
(See Regulation 4)
List of projects requiring an EIA
A. Energy
1. Hydroelectric power generation over 50 MW
2. Thermal power generation over 100MW
3. Coal power projects above 50 MW
4. Transmission lines (11 KV and above) and distribution projects.
5. Nuclear power plants
6. Wind energy projects if falls under any sensitive, protected area.
B. Oil and Gas projects
1. Petroleum refineries.
2. LPG and LNG Projects(including LNG Terminals, re-gasification units)

except LPG filling stations
3. Oil and gas transmission systems
4. Oil and gas gathering system, separation and storage.
C. Manufacturing and processing

1. Cement plants
2. Chemical manufacturing industries
3. Fertilizer plants
4. Steel Mills
5. Sugar Mills and Distilleries
6. Food processing industries including beverages, dairy milk and products, slaughter
houses and related activities with total cost more than Rs. 200 Million
7. Industrial estates (including export processing zones)
8. Man-made fibers and resin projects with total cost of Rs 200M and above
9. Pesticides (manufacture or formulation)
10. Petrochemicals complex
11. Synthetic resins, plastics and man-made fibers, paper and paperboard, paper
pulping, plastic products, textiles (except apparel),printing and publishing, paints
and dyes, oils and fats and vegetable ghee projects, with total cost more than Rs.
13
10 million
12. Tanning and leather finishing projects
13. Battery manufacturing plant
D. Mining and mineral processing
1. Mining and processing of coal, gold, copper, sulphur and precious stones
2. Mining and processing of major non-ferrous metals, iron and steel rolling
3. Smelting plants with total cost of Rs. 100 million and above
E. Transport
1. Airports
2. Federal or Provincial highways or major roads (including rehabilitation or

rebuilding or reconstruction of existing roads)
3. Ports and harbor development
4. Railway works
5. Flyovers, underpasses and bridges having total length of more than 500m
F. Water management, dams, irrigation and flood protection
1. Dams and reservoirs with storage volume of 25 million cubic meters and
above having surface area of 4 square kilometers and above
2. Irrigation and drainage projects serving 15,000 hectares and above
3. Flood Protection
G. Water supply and filtration
Large Water supply schemes and filtration plants.
H. Waste Disposal and treatment
1. Handling, storage or disposal of hazardous or toxic wastes or radioactive waste

(including landfill sites, incineration of hospital toxic waste )
2. Waste disposal facilities for municipal or industrial wastes, with total annual
capacity of 10,000 tons and above.
3. Waste water treatment facility for industrial or municipal effluents.
14
I. Urban development and tourism
1. Housing schemes above 10 acres
2. Residential/commercial high rise buildings/apartments from15 stories and

above.
3. Land use studies and urban plans (large cities)
4. Large scale public facilities.
5. Large-scale tourism development projects
J. Environmentally Sensitive Areas
All projects situated in environmentally sensitive areas
K. Other projects
1. Any other project for which filing of an EIA is required by the Agency under
sub-regulation (2) of Regulation 5.
2. Any other project likely to cause an adverse environmental effect
15
SCHEDULE-III
List of projects requiring environmental screening (through check list)
a. Construction of, offices and small commercial buildings (1-6 story),home
industrial units, ware houses, marriage / banquet facilities, large scale motor
vehicles workshops, restaurants / food outlets ,large baking unit subject to the
compliance with existing zoning laws.
b. Reconstruction / rehabilitation of roads ( small roads in urban area and farm to

market roads more than 2 km.
c. On-farm dams and fish farms.
d. Pulses mills.
e. Flour Mills
f. Projects promoting energy efficiency (small scale).
g. Lining of existing minor canals and /or water courses.
h. Canal cleaning
i. Forest harvesting operations
j. Rain harvesting projects
k. Rural schools (Secondary and Higher Secondary) and rural and basic health
units having at least ten beds capacity.
l. BTS Towers
m. Lime Kilns
n. Ice factories and cold storage.
o. Cotton oil mill
p. Warehouses for pesticides and pharmaceuticals
16
Schedule-IV
(See Regulation 7)
Environmental Check
Description IEE EIA
list
Rs.30,000 except BTS

Towers which is
Projects Rs.100,000 Rs.200,000
Rs.15,000
17
SCHEDULE V
[See Regulation 8(2)(a)]
Application Form
1. Name and address of Phone:

Proponent Fax:
Telex:
2. CNIC No. of
proponent
3. Description of project
4. Location of project
6. Objectives of project
7. IEE/EIA attached? IEE/EIA : Yes/No
8. Have alternative sites been considered and Yes/No

reported in IEE/EIA?
9. No Objection Certificate of relevant Name(s)
stakeholders
10. Existing land use Land
requirement
11. Is basic site data (only tick yes if the
available, or has it data is reported in the
been measured? IEE/EIA)
Available Measured
Meterology (including Yes/No Yes/No
rainfall)
Ambient air quality Yes/No Yes/No
Ambient water quality Yes/No Yes/No
Ground water quality Yes/No Yes/No
12. Have estimates of the Estimated Reported
following been Water balance Yes/No Yes/No
reported, especially Solid waste disposal Yes/No Yes/No
Quantitative Analysis? Liquid waste treatment Yes/No Yes/No
13. Source of power Power
requirement
14. Labour force Construction:
(number) Operation:
15. Environmental
Consulting Firm
Verification. I do solemnly affirm and declare that the information given above and
contained in the attached IEE/EIA is true and correct to the best of my knowledge and
belief.
Date Signature, name and ______

designation of proponent
(with official stamp/seal)
18
SCHEDULE VI
[See Regulation 12]
Decision on IEE/Environmental Check List
1. Name and address of proponent
4. Date of filing of IEE
5. After careful review of the IEE, the Agency has decided –
(a) to accord its approval, subject to the following conditions:
or (b) that the proponent should submit an EIA of the project, for the following
reasons –
[Delete (a) or (b), whichever is inapplicable]
Dated
Tracking no.___
Director-General
Sindh Environmental Protection Agency
19
SCHEDULE VII
[See Regulation 12]
Decision on EIA
1. Name and address of proponent
4. Date of filing of EIA
5. After careful review of the EIA, and all comments thereon, the Federation Agency
has decided –
(a) to accord its approval, subject to the following conditions:
or (b) that the proponent should submit an EIA with the following modifications-
or (c) to reject the project, being contrary to environmental objectives, for the
following reasons:
[Delete (a)/(b)/(c), whichever is inapplicable]
Dated
Tracking no.___
Director-General
20
SCHEDULE VIII
[See Regulation 13(2)]
Undertaking
I, (full name and address) as proponent for (name, description and location of project) do
hereby solemnly affirm and declare that I fully understand and accept the conditions
dated , and undertake to design, construct and operate the project strictly in accordance
with the said conditions and the IEE/EIA/Environmental Check List.
Signature, name and

designation of proponent
Witnesses
(full names and addresses)
21
SCHEDULE IX
(See Regulation 21)
Form of Registers for IEE and EIA and Environmental Check List projects
S. No. Description Relevant Provisions

1 2 3
1. Tracking number
2. Category type (as per Schedules I, II & III)
3. Name of proponent
4. Name and designation of contact person
5. Name of consultant
8. Project capital cost
9. Date of receipt of IEE/EIA/Environmental Check List
10. Date of confirmation of completeness
11. Approval granted (Yes/No)
12. Date of approval granted or refused
13. Conditions of approval/reasons for refusal
14. Date of Undertaking
15. Date of extension of approval validity
16. Period of extension
17. Date of commencement of construction
18. Date of issue of confirmation of compliance

19. Date of commencement of operations
20. Dates of filing of monitoring reports
21. Date of cancellation, if applicable
22
ANNEX – V
Sindh Environmental Quality Standards, 2016
Annex – V: Sindh Environmental Quality Standards, 2016

Annex – V
(Review IEE & EIA) Regulation, 2014
EMP Renewal of Jaffer Agro Services (Private) Limited (DRAFT)
ANNEX – VI
Sindh Hazardous Substance Rules, 2014
Annex – VI: Sindh Environmental Quality Standards, 2016

Annex – VI
(Review IEE & EIA) Regulation, 2014
GOVERNMENT OF SINDH
Karachi dated the 16th December, 2014.
NOTIFICATION
NO.EPA/TECH/739/2014 In exercise of the powers conferred by section 36 of the Sindh
Environmental Protection Act, 2014, the Sindh Environmental Protection Agency, with the
approval of the Government is pleased to make the following rules, namely:-
1. Short title and commencement. (1) These rules may be called the Hazardous
Substances Rules, 2014.
(2) They shall come into force at once.
2. Definition. (1) In these rules, unless there is anything repugnant in the subject or context
(i) “Act” means the Sindh Environmental Protection Act, 2014;
(ii) “Director-General” means the Director-General of the Agency;
(iii) “environmental impact assessment” means an environmental impact assessment

as defined in clause (xv) of section 2;
(iv) “major accident” means an occurrence resulting from uncontrolled developments

during industrial activity or from natural events which is likely to cause an
adverse environmental effect, involving substantial loss of life and property;
(v) “section” means a section of the Act;
(vi) “Schedule” means Schedule to these rules; and
(vii) “worker” shall have the same meaning as defined in clause (h) of section 2 of the
Factories Act, 1934 (XXV of 1934).
(2) All other words and expressions used in these rules but not defined shall have the
same meanings as are assigned to them in the Act.
3. Substances prescribed as hazardous substances. As provided in sub-clause (b) of

clause (xxv) of section 2, substances listed in Schedule-I are hereby prescribed as hazardous
substances.
4. Application for licence. An application for grant of licence under section 13 shall be
filed with the Agency in Form-A of Schedule-II:
Provided that an applicant for grant of licence to import or transport a hazardous
substance shall, in addition to information in Form-A, also provide details mentioned in sub-rule
(1) of rules 20 and 21 respectively.
5. EIA of project or industrial activity. (1) An application for grant of licence filed under
rule 4 shall be accompanied by an environmental impact assessment of the project or industrial
activity involving generation, collection, consignment, transport, treatment, disposal, storage,
handling or import of a hazardous substance in respect of which the licence is sought.
(2) The environmental impact assessment submitted by the applicant shall include –
(a) a safety plan, containing information specified in sub-rule (1) of rule 17;
(b) a waste management plan, if hazardous waste shall be generated by the
project or industrial activity, containing information specified in sub-rule
(1) of rule 19.
6. Applicability of Sindh Environmental Protection Agency (Review of Initial
Environmental Examination and Environmental Impact Assessment) Regulations 2014.
The environmental impact assessment accompanying an application for grant of licence shall be
prepared, scrutinized, reviewed and decided in accordance with the provisions of the Sindh
Environmental Protection Agency (Review Initial Environmental Examination and
Environmental Impact Assessment) Regulations 2014.
7. Issue of Licence. (1) Where the Director General approves an application for grant of
licence, the applicant shall be informed accordingly and directed to deposit with the Agency, a
licence fee at the rate specified in Schedule-III.
(2) On receipt of the licence fee, the Agency shall issue a licence in Form-B of Schedule-II.
(3) If a licence is defaced, damaged or lost, duplicate thereof shall be issued on payment of
such fee as specified in Schedule-III.
8. Conditions of licence. (1) A licence granted under section 13 shall be subject to the
conditions of approval of the environmental impact assessment accompanying the application for
licence.
(2) Without prejudice to the provisions of sub-rule(1), a licence granted under section 13
shall also be subject to the following conditions:-
(a) the licensee shall employ qualified technical personnel having necessary
knowledge and experience regarding the use, storage and handling of the
hazardous substance, and safety precautions relating thereto;
(b) the hazardous substance shall be packed and labeled in accordance with rule
9;
(c) the premises of the licensee shall comply with the conditions laid down in
rule 10;
(d) the licensee shall ensure compliance with the provisions of rules 11 and 12
regarding safety precautions;
(e) the licensee shall provide necessary information, and where required
training, to the persons to whom the hazardous substances are sold or
delivered, regarding the use, storage and handling of the hazardous
substances, and safety precautions relating thereto;
(f) the licensee shall maintain a detailed record of the quantity, type, quality
and origin of the hazardous substance and the names and addresses of the
persons to whom the hazardous substances are sold or delivered; and
(g) the licensee shall not extend his operation beyond the scope of the project or
industrial activity in respect of which the environmental impact assessment
has been submitted and approval granted.
(2) The Agency may, in the light of its review of the environmental impact
assessment, require that the licensee maintain adequate insurance cover for any aspect of his
operation.
(3) The licensee shall provide copy of approval from importing country under the
international convention and protocol.
9. Packing and labeling.- (1) A container of a hazardous substance shall be of such size,
material and design as to ensure that –
(a) it can be stored, transported and used without leakage and safely;
(b) the hazardous substance therein does not deteriorate in a manner as to
render it more likely to cause, directly or in combination with other
substances, an adverse environmental effect.
(2) The following information shall be printed conspicuously, legibly and indelibly on every
container of a hazardous substance:-
(a) name of the hazardous substance;
(b) name, address and licence number of the licensee;
(c) net contents (volume or weight);
(d) date of manufacture and date of expiry, if any;
(e) a warning statement comprising –
(i) the word “DANGER!” in red on a contrasting background;
(ii) a picture of a skull and cross-bones;
(iii) pertinent instructions for use, storage and handling and safety precautions
relating thereto.
(f) instructions regarding return or disposal of the empty container:
Provided that if the hazardous substance has an inner container as well as
an outer container, the information shall be printed on both containers:
Provided further that if it is impracticable to print the aforesaid
information on the container itself due to its size, material or design, the same
shall be printed on a label or tag which shall be conspicuously affixed or attached
to the container in such manner as to render it difficult to remove. The empty
chemical containers or drums may not be used for other purposes:
(g) basic instructions mentioning immediate steps to be taken in case of any accident
or emergency, preferably in local language.
10. Conditions for premises. (1) The premises in which a hazardous substance is generated,
collected, consigned, treated, disposed of, stored or handled shall -
(a) comply with the conditions specified in Schedule-IV;
(b) be fitted with a notice on the outer door or gate bearing the following
information:-
(i) the words “DANGER ! HAZARDOUS SUBSTANCE!” in red, on a
contrasting background; and
(ii) a prominent picture of a skull and cross-bones.
(2) In case of import of hazardous substances, proponent shall provide approval from
Climate Change Division (International Convention Wing) Government of Pakistan.
11. General safety precautions. (1) A licensee shall ensure that the following safety
precautions are conveyed to persons to whom the hazardous substances are sold or
delivered:-
(a) carefully read and follow the instructions and safety precautions printed on the
container; (Urdu or local language translation of the same may be preferably
given to the local buyers);
(b) when opening the container, wear protective clothing and equipment including
helmet or cloth cap, safety spectacles or goggles, respirator or mask, rubber or
plastic gloves, and work boots, as may be required;
(c) avoid contact of the hazardous substance with exposed skin or eyes, and if such
contact occurs, wash the exposed area immediately and consult a doctor;
(d) avoid contaminating clothing, gloves and footwear with the hazardous
substance, and if such contamination occurs, remove the clothing, gloves and
footwear immediately and wash the same thoroughly before reuse;
(e) do not eat, drink or smoke in the vicinity of hazardous substances.
(2) The general safety precautions mentioned in sub-rule (1) shall be in addition to such
other specific precautions or measures that may be required to be conveyed by the licensee
for a particular hazardous substance. The licensee will be bound to inform the Agency, the
details of his subsequent consignments as the licence will be issued for a period of one year
under section 13.
12. Safety precautions for workers. A licensee shall ensure that the following safety
precautions are taken in respect of workers employed by him for handling hazardous
substances:-
(a) No worker aged below eighteen years or over sixty years shall be employed for
any job involving physical handling of hazardous substances.
(b) All workers shall be thoroughly trained in safety precautions for handling
hazardous substances and shall be supervised by qualified supervisors.
(c) Protective clothing and equipment comprising helmet or cloth cap, safety
spectacles or goggles, respirators or masks, rubber or plastic gloves and
work-boots shall be available for all workers who may be exposed to any
hazardous substance, and no worker shall be permitted on job unless and until he
is wearing such protective clothing and equipment.
(d) Adequate supply of water shall be made available to the workers for personal
washing as well as for washing their protective clothing and equipment.
(e) Protective clothing and equipment of the workers shall be washed and cleaned as
often as may be required to ensure their efficacy.
(f) No worker shall be permitted to eat, drink or smoke till he has removed his
protective clothing and equipment, washed his hands and face, and left the place
of work.
(g) All fire-fighting, emergency and safety equipment shall be frequently checked and
properly maintained.
(h) First-aid medical facility equipped with required antidotes shall be available in the
premises, supervised by trained staff.
(i) Medical check-up of all workers shall be carried out at the time of employment
and at least once a year thereafter.
(j) A record of every worker shall be maintained containing, amongst other details,
his name and address, his medical check-up history, and the hazardous substances
handled by him.
13. Validity of licence. A licence issued under rule 7 shall be valid for a period of one year
from the date of issue:
Provided that if an application for renewal is made under rule 14, the licence shall
continue to remain valid till the application for renewal is decided.
14. Renewal of licence. An application for renewal of licence shall also be made to the
Federal Agency in Form-A of Schedule II, at least 30 days before the date of its expiry.
(i) An application for renewal shall be accompanied by a brief update of the original
environmental impact assessment, unless changes in circumstances require
submission of a fresh environmental impact assessment.
(ii) the fee for renewal of licence shall be as provided in Schedule-III, and the licence
issued on receipt thereof shall also be in Form-B of Schedule II.
(iii) the fee for duplicate copy of licence shall be as provided in Schedule-III and the
licence issue on the receipt thereof shall also be in Form-B of Schedule-II.
15. Cancellation of the licence. (1) Notwithstanding anything contained in these rules, if at
any time on the basis of information or report received or inspection carried out, the
Agency is of the opinion that the conditions of the licence have not been complied with,
or that the information supplied by the licensee in his application or approved
environmental impact assessment is incorrect, it shall issue notice to the licensee to show
cause, within two weeks of receipt thereof, why the licence should not be cancelled.
(2) If no reply is received or if the reply is considered unsatisfactory, the Agency may, after
giving the licensee an opportunity of being heard -
(i) require the licensee to take such measures and to comply with such
conditions within such period as it may specify, failing which the licence
shall stand cancelled; or
(ii) cancel the licence.
(3) On cancellation of the licence under sub-rule (2), the licensee shall cease his
operations forthwith.
(4) The action taken under this rule shall be without prejudice to any other action that
may be taken against the licensee under the Act or rules or regulations or any other law
for the time being in force.
16. Entry, inspection and monitoring. (1) For the purposes of verification of any matter
relating to the conditions of the licence, duly authorized staff of the Agency shall be
entitled to enter and inspect the premises in which the hazardous substance is being
generated, collected, consigned, treated, disposed of, stored or handled:
Provided that the Agency shall inspect the premises at least once a year.
(2) The licensee shall ensure cooperation of his staff at the premises to facilitate the
inspection mentioned in sub-rule (1).
(3) The licensee shall provide such information as may be required by the Agency for
effective monitoring of compliance by the licensee with the conditions of the licence.
17. Safety plan. (1) The safety plan to be submitted by an applicant under clause (a) of sub-
rule (2) of Rule 5 shall include –
(a) an analysis of major accident hazards relating to the hazardous substance
involved;
(b) an assessment of the nature and scope of the adverse environmental effects
likely to be caused by major accidents;
(c) a description of the safety equipment and systems installed and safety
precautions taken; and
(d) a description of the emergency measures proposed to be taken on and off
the premises of the applicant to control a major accident, and to mitigate
its adverse environmental effect.
(2) Before issue of the licence, the Agency shall, in consultation with other relevant
Government Agencies and Departments including the licensee, review the safety plan to ensure
that it covers all anticipated contingencies and all emergencies likely to result from a major
accident involving the hazardous substance involved, and that the concerned Government
Agencies, Departments and the licensee are aware of their specific responsibilities thereunder.
(3) After issue of the licence, the licensee shall ensure that all persons liable to be
affected by the approved safety plan are informed of the relevant provisions
thereof.
18. Notification of major accident. (1) Where a major accident occurs on the premises of a
licensee, the licensee shall immediately notify the Agency concerned and shall submit
within twenty four hours and weekly thereafter, a report in Schedule-V.
(2) On receipt of the report under sub-rule (1), the Agency shall require the licensee to
carry out a detailed environmental audit of the major accident and initiate necessary action, in
accordance with the approved safety plan or otherwise, to control the major accident, mitigate its
adverse environmental effect and prevent it from recurring.
19. Waste management plan. (1) The waste management plan, if required to be submitted
by an applicant under clause (b) of sub-rule (2) of rule 5, shall -
(a) provide for the generation, collection, transport and disposal of the
hazardous waste in a manner which shall protect against an adverse
environmental effect;
(b) ensure that the hazardous waste is not mixed with non-hazardous waste,
unless the applicant can prove that such mixing will better protect against
an adverse environmental effect.
(2) The waste management plan shall be reviewed every year by the licensee to take
into consideration the development of new technologies and management practices which can
better protect against an adverse environmental effect, and if required revised waste management
plan and fresh environmental impact assessment shall be submitted with the application for
renewal of licence.
(3) If the waste management plan provides for export of the hazardous waste, such
export shall only be allowed if it is in accordance with a bilateral, multilateral or regional
agreement or arrangement that conforms to the requirements of Article 11 of the Convention on
the Control of Transboundary Movements of Hazardous Waste and Their Disposal, Basel, 1989.
(4) The licensee shall inform the Agency on a yearly basis about -
(a) the quantity and characteristics of hazardous waste generated in the
previous year; and
(b) progress regarding implementation of the waste management plan.
20. Import of hazardous substances. (1) The applicant shall, for grant of licence to import a
hazardous substance in addition to the information contained in Form-A of Schedule II,
also provide the following details:-
(i) port of entry into Province of Sindh;

(ii) particulars of transport from exporting country to Pakistan;
(iii) quantity of hazardous substance being imported;
(iv) complete information pertaining to safety precautions to be adopted; and
(v) the purpose for which the hazardous substance is to be utilized, along with
environmental impact assessment in respect thereof, if required under rule 5.
(vi) Licensee shall provide copy of approval from Climate Change Division
(International Convention Wing) Government of Pakistan under the
provisions of International Convention and Protocol.
(2) If the licence applied for is granted, the concerned Federal Agency or Ministry and
the Agency and port authority concerned, shall ensure that proper steps are taken for safe off-
loading, handling and storage of the hazardous substance on arrival at the port.
21. Transport of hazardous substances. (1) The applicant shall, for grant of licence for
transport of a hazardous substance in addition to the information contained in Form-A of
Schedule II, also provide the following details :-
(i) name and address of the person from whom the hazardous substance is to
be collected;
(ii) name and address of the person to whom the hazardous substance is to be
delivered;
(iii) quantity of hazardous substance to be transported;
(iv) mode of transport, including full particulars and specifications of the
motor vehicles or other conveyance;
(v) route to be adopted between the origin and destination;
(vi) date and time of proposed transportation;
(vii) nature of waste which may be liquid or solid and its toxicity along with
Material and Safety Data Sheet (MSDS); and
(viii) contingency or emergency response plan.
(2) If the licence applied for is granted, the Agency shall ensure that the Government
Departments or Agencies concerned are informed of the relevant particulars of the
transportation, for taking necessary safety precautions and other measures.
22. Other approvals. The issuance of a licence under section 13 read with rule 7 shall not
absolve the licensee to obtain any other approval or consent that may be required under
any law for the time being in force.
DIRECTOR GENERAL
SCHEDULE-I
(see Rule 3)
List of Prescribed Hazardous Substances or Any Other Synthetically Chemical
S. NO. NAME OF CHEMICALS CAS. NO

1. Acetaldehyde 75-07-0
2. Acetic acid 64-19-7
3. Acetic anhydride 108-24-7
4. Acetone 67-64-1
5. Acetone cyanohydrins 75-86-5
6. Acetone Thiosemicarbazide
7. Acetylene 74-86-2
8. Acetyl chloride 75-36-5
9. Acrolein 107-02-8
10. Acrylamide 79-06-1
11. Acrylonitrile 107-13-1
12. Adiponitrile 111-69-3
13. Aldicarb 116-06-3
14. Aldrin 309-00-2
15. Allyl alcohol 107-18-6
16. Allyl amine 107-11-9
17. Allyl chloride 107-05-1
18. Amino biphenyl 92-67-1
19. 3-Amino-1, 2,4 triazole 61-82-5
20. Aminopterin
21. Amiton 78-83-5
22. Amiton dialate
23. Ammonia 7664-41-7
24. Ammonium chloride 12125-02-9
25. Ammonium sulphamate 7773-06-0
26. Aniline 62-53-3
27. Aniline 2,4,6-Trimethyl
28. Anthraquinone 84-65-1
29. Antimony & Compounds 7440-36-0
30. Arsenic & Compounds 7440-38-2
31. Arsine 7784-42-1
32. Asbestos 1332-21-4
33. Azinpho-ethyl
34. Azinphos methyl 86-50-0
35. Bacitracin
36. Barium and Compounds 513-77-9
37. Benzal chloride 98-87-3
38. Benzenamine 3-Trifluoromethyl
39. Benzene 71-43-2
40. Benzene sulfonyl chloride 98-09-9
41. Benzene 1- (chloromethyl) –4 Nitro
42. Benzene arsenic acid
43. Benzidine and Salt 92-87-5
44. Benzimidazole, 4,5-dichloro-2 (Trifluoromethyl)
45. Benzyl chloride 100-44-7
46. Beryllium and Compounds 7440-41-7
47. Bis (2-chloroehyl) Sulphide ?
48. Bis (chloroethyl) ketone ?
49. Bis (Tert-butyl peroxy) cyclohexane ?
50. Bis (Tert-butyl peroxy) butane ?
51. Bis (2,4,6-Trinitrophenylamine) ?
52. Bromo chloro methane 74-97-5
53. Bromoform 75-25-2
54. Butyl amine tert 75-64-9
55. Butvl-n-mercaptan 109-79-5
56. Cadmium and Compounds 7440-43-9
57. Calcium arsenate 7778-44-1
58. Calcium Cyanamide 156-62-7
59. Camphechlor Toxaphene) 8001-35-2
60. Cantharidin ?
61. Captan 133-06-2
62. Carbachol chloride ?
63. Carbaryl 63-25-2
64. Carbofuran 1563-66-2
65. Carbon tetrachloride 56-23-5
66. Carbon disulphide 75-15-0
67. Carbon monoxide 630-08-0
68. Cellulose nitrate 9004-70-0 ?
69. Chlordane 12789-03-6
70. Chlorinated benzene 108-90-7
71. Chlorine 7782-50-5
72. Chlorine oxide 10049-04-4
73. Chlorine trifluoride 7790-9102
74. Chloroacetaldehyde 107-20-0
75. Chlorobenzene 108-90-7
76. Chloroform 67-66-3
77. Chloromethyl methylether 107-30-2
78. Chloronitrobenzene 88-73-3
79. Chloroethyle Vinyl ether 110-75-8
80. Chromium and Compounds 7440-47-3
81. Cobalt and Compounds 7440-48-4
82. Copper and compounds 7440-50-8
83. Crotonaldehyde 123-73-9
84. Cumene 98-82-8
85. Cyanides and Compounds 151-50-8
86. Cyclohexane 110-82-7
87. DDT 50-29-3
88. Demeton 298-03-3
89. Dichlorobenzene 95-50-1
90. Dichloroethyl ether 111-44-4
91. Dichlorophenol-2.6 87-65-0
92. Dichlorophenol-2.4 120-83-2
93. Dichloropropene-1,3 142-28-9
94. Dichloroproponic acid 127-20-8
95. Dichlorvos 62-73-7
96. Dieldrin 60-57-1
97. Dimethyl hydrazine 57-14-7
98. Dimethyl phenol 2,4 105-67-9
99. Dimethylamine 109-89-7
100. Dimethylaniline 121-69-7
101. Dinitrophenol 2-4 51-28-5
102. Dinitrotoluenes 121-14-2
103. Dinoseb 88-85-7
104. Dinitrobenzene 528-29-0
105. Dioxane-p 123-91-1
106. Dioxathion 78-34-2
107. Diquat 85-00-7
108. Endosulfan 115-29-7
109. Endrin 72-20-8
110. Epichlorohydrine 106-89-8
111. Ethion 563-12-2
112. Ethyl acetate 141-78-6
113. Ethyl benzene 100-41-4
114. Ethyl amine 75-04-7
115. Ethyl ether 60-29-7
116. Ethyl methacrylate 97-63-2
117. Ethylene dichloride 107-06-2
118. Ethylene dibromide 106-93-4
119. Ethylene diamine 107-15-3
120. Ethylene oxide 75-21-8
121. Ethylenimine 151-56-4
122. Fluorine 7782-41-4
123. Formaldehyde 50-00-0
124. Formic acid 64-18-6
125. Furfural 98-01-1
126. Heptachlor 76-44-8
127. Hexachlorobenzene 118-74-1
128. Hexachlorocyclohexan (Lindane) 608-73-1
129. Hexachlorocyclopentadiene 77-47-4
130. Hydrochloric acid 7647-01-0
131. Hydrogen sulphide 7783-06-4
132. Hydrogen cyanide 74-90-8
133. Hydrogen fluoride 7664-39-3
134. Iridium tetrachloride ?
135. Isobutyl alcohol ?
136. Lead (Inorganic) 7439-92-1
137. Lead arsenate 7784-40-9
138. Lindane 58-89-9
139. Magnesium powder or ribbon 7439-95-4 ?
140. Malathion 121-75-5
141. Maleic anhydride 108-31-6
142. Malononitrile 109-77-3
143. Mercury and Compounds 502-39-6
144. Methoxy chloride
145. Methyl alcohol 67-56-1
146. Methyl amine 74-89-5
147. Methyl bromide (Bromomethane) 74-83-9
148. Methyl chloride 74-87-3
149. M ethyl chloroform (1,1,1-Trichloroethane) 137-5-3
150. Methyl ethyl ketone peroxide 1338-23-4
151. Methyl isocyanate 624-83-9
152. Methyl methacrylate monomer 80-62-6
153. Methyl Parathion 298-00-0
154. Mevinphos 7786-34-7
155. Molybdenum and Compounds 7439-98-7
156. Monocrotophos 6973-22-4
157. Butyl acetate 123-86-4
158. Butyl alcohol 71-36-3
159. Naled 300-76-5
160. Naphthalene 91-20-3
161. Naphthyl amine 91-51-8
162. Nickel salts 7440-02-0
163. Nicotine 54-11-5
164. Nitric acid 7697-37-2
165. Nitric oxide 10102-43-9
166. Nitro benzene 98-95-3
167. Nitrocholorobenzene 100-00-5
168. Nitrocyclohexane
169. Nitrogen dioxide 10102-44-0
170. Nitrogen trifluride 7783-54-2
171. Nitrophenols 88-75-5
172. Nitropropane-2 79-46-9
173. Nitroso dimethyl amine 62-75-9
174. Cresol 1319-77-3
175. Nitroaniline 100-01-6
176. Osmium tetroxide 20816-12-0
177. Oxygen (Liquid) 7727-37-9
178. Oxygen difluoride 7783-41-7
179. Ozone 10028-15-6
180. Paraoxon (diethyl-4 nitrophenyphosphate)
181. Parathion 56-38-2
182. Pentaborane 19624-22-7
183. Pentachlorobenzene 608-93-5
184. Pentachlorophenol 87-86-5
185. Pentabromophenol
186. Phenol 108-95-2
187. Phenol,2,2-thiobis (4,6-dichloro)
188. Phenol,2,2-thiobis (4 chioro 6 methyl phenol)
189. Phenol, 3- (1- methyl-ethyl)- methylcarbamate
190. Phorate 298-02-2
191. Phosgene 75-44-5
192. Phosphoric acid 7664-38-2
193. Phosphorus 7723-14-0
194. Phosphorus oxychloride 10025-87-3
195. Phosphorus pentasulphide 1314-80-3
196. Phosphorus trichloride 7719-12-2
197. Phthalic anhydride 85-44-9
198. Picric acid (2,4,6-trnitrophenol) 88-89-1
199. Polychlorinated biphenyls (PCBs) 1336-36-3
200. Propionic acid 79-09-4
201. Propargyl alcohol 107-19-7
202. Propylene oxide 75-56-9
203. Pyrethrins 8003-34-71
204. Pyridine 110-86-1
205. Quinone 106-51-4
206. Sodium azide 26628-22-8
207. Sodium fluoro-acetate 62-74-8
208. Sodium hydroxide 1310-73-2
209. Strychnine 57-24-9
210. Styrene 100-42-5
211. Sulfuric acid 7664-93-9
212. Tert- Butyl peroxyacetate
213. Tetra ethyl pyrophosphate 107-49-3
214. Tetra nitromethane (Rocket Industry) 509-14-8
215. Tetra-chlorodibenzo-p-dioxin, 1,2,3,7,8 (TCDD) 1746-01-6
216. Tetraethyl lead 78-00-2
217. Thallic oxide
218. Titanium powder 7440-32-6
219. Toluene 108-88-3
220. Toluene 2,4-diisocyanate 584-84-9
221. Toxaphene 8001-35-2
222. Trans-1,4-dichloro-butene
223. Trichloroethylene 79-01-6
224. Trichlorophenols 95-95-4
225. Trichlorophenoxy acetic acid 2,4,5 triethylamine 93-76-5
226. Trichlorophenol 2,3,6 933-75-5
227. Trichlorophenol 2,4,5 95-95-4
228. Triethylamine 121-44-8
229. Triethylene melamine
230. Trinitrobenzene 99-35-4
231. Trinitrotoluene (TNT) 118-96-7
232. Turpentine 8006-64-2
233. Uranium and compounds 7440-61-1
234. Vanadium and compounds 7440-62-2
235. Vinyl acetate 108-05-4
236. Vinyl chloride 75-01-4
237. Vinyledene chloride 75-35-4
238. Warfarin 81-81-2
239. Xylene 1330-20-7
240. Xylidine 1300-73-8
241. Zinc chloride 7646-85-7
242. Zirconium and compounds 7440-67-7
243. Any other substance declared hazardous by Sindh EPA
SCHEDULE-II
FORM A
(see Rule 4)
Application for grant/renewal of licence for hazardous substance
I/we [name(s) _______________] of [address _____________] hereby apply for grant/ renewal
of licence to generate/collect/consign/transport/treat/dispose of/ store/ handle/ import (delete
words inapplicable) the following hazardous substance
__________________________________________________________________
at my/our premises situated at [address _________________________________].
I/we have read, and hereby undertake to comply with, all applicable provisions of the Sindh
Environmental Protection Act, 2014 and rules and regulations made thereunder, including and in
particular the Hazardous Substances Rules, 2014.
I/we submit herewith the following documents:-
(i) Environmental Impact Assessment (EIA) of the project/industrial activity involving the
above-mentioned hazardous substance, including safety plan. Waste management plan
is/is not included. [delete word(s) inapplicable].
(ii) Approved building plan of the premises mentioned above.
(iii) List of machinery and equipment installed/proposed to be installed.
(iv) List of qualified personnel and number of workers employed/proposed to be employed.
Date: __________ ___________

Applicant
SCHEDULE-II
FORM B
(See Rule 7)
Licence for hazardous substance
M/s [name _______________] of [address _____________] is hereby granted licence to

generate / collect / consign / transport / treat / dispose of/ store /handle /import (delete words
inapplicable) the following hazardous substance –
_________________________________________________________________
at its premises situated at [address __________________________] subject to the conditions

specified below –
1) the following conditions of approval of the EIA accompanying the application for
licence –
_____________________________________________________________
2) the conditions specified in Rule 8 of the Hazardous Substances Rules, 2014.
3) The following additional conditions –
_____________________________________________________________
This licence shall be valid for a period of one year from the date given below.
Date: ____________
Director-General
SCHEDULE III
(see Rule 7)
Licence fees
Description Fee
Licence Fee Rs.50,000
Renewal Fee Rs.25,000
Duplicate Fee Rs. 10,000

SCHEDULE IV
(see rule 10)
Conditions for premises
1. Location
The premises shall not be located -

(a) in a congested, residential, commercial or office area;
(b) in small lanes or bye-lanes;
(c) close to drinking water sources; or
(d) in an area liable to flooding.
2. Building
The building shall -

(a) be soundly constructed with good ventilation and protection against direct sunlight;
(b) have well-maintained electrical installations;
(c) have walls protected by non-flammable or slow-burning material;
(d) have fire-resistant doors fitted with self-closing system;
(e) have smooth, crack-fee floors impermeable to liquids;
(f) have drains, if absolutely necessary, which do not connect directly with the sewerage
system;
(g) have signs indicating location of emergency exits, escape routes, and fire-fighting
equipment, prohibition of smoking, and safety precautions; and
(h) have proper washing facilities with adequate supply of water.
SCHEDULE V
(see rule 18)
Notification of major accident
Report no._________
1. Name and address of licensee ____________________________________
2. Licence no. and date ________________________________________ Nature of
industrial activity mentioning Hazardous substance involved.
_____________________________________________________________
3. Description of major accident -
(a) Date and time ____________________________________________
(b) Exact location ____________________________________________
(c) Process/operation during which accident took place ____________________
(d) Type and circumstances of accident and estimated quantity of hazardous
substance involved.
________________________________________________________
4. Known causes of the major accident.
____________________________________________________________
5. Nature and extent of damage –
(a) In the premises; _______________________________________
(b) Outside the premises. __________________________________
6. Description of emergency measures already taken.
_____________________________________________________________
7. Description of further measures proposed to be taken to –
(a) mitigate adverse effects ____________________________________
(b) prevent recurrence ______________________________________
8. Any other relevant information. __________________________________
_____________________________________________________________
Date: _________
Time: _________
Licensee
ANNEX – VII
Waste Disposal Certificates
Annex –VII: Waste Disposal Certificates

Annex – VII
ANNEX – VIII
Observations at Site
Annex –VIII: Waste Disposal Certificates

Annex – VIII
Area/Location Observation Photograph Recommendations
Pesticides & Fertilizer Provide secondary containment to

Filling & Packing Chemical drums and Overhead chemical tanks do not
contain chemicals in case of spillage or
department and rear side have secondary containment.
alley. tank/drum leakage.
Waste water / contaminated water tank was not Cover the underground tank with
Backside alley
properly covered. suitable and sturdy lid.
i. Yellow lines with red direction

i. Exit routes were not marked with yellow lines &
Pesticides & Fertilizer arrows to be provided.
direction arrows.
Filling & Packing ii. Emergency exit signs should be
department ii. Emergency exits do not have illuminated
illuminated and also provided
EMERGENCY EXIT signs.
with backup power source.
Pallets should not be placed in front of

Pesticides & Fertilizer bag Pallets placed in front of fire extinguisher, eye wash, fire extinguisher, eye wash, ESD
storage, Powder filling area shower, ESD switch. switch etc. in any situation. Improve
housekeeping.

Page 1 of 3
Observations noted during last year visit which has been rectified are mentioned below:
Closure of previous observations

Observation Photograph Corrective Action taken Photograph
Use of PPEs has been strictly

4 workers found not wearing proper enforced through inspection and
dust mask at Filling machine area.
guidelines
No emergency light (power back up)

installed at Lab. Emergency exit & Emergency back up light installed
outside Lab. Corridor area without in laboratory
marking in native language.
Area segregated by hazardous and

Housekeeping has been improved.
nonhazardous items.

Page 2 of 3
Closure of previous observations

Observation Photograph Corrective Action taken Photograph
Poor housekeeping observed Proper storage of products. Wall

around the Powder filling constructed between filling hall
department. and storage area.
Emergency Exit leads to outside New gate of appropriate height has

the factory found locked. been installed with key
No Second exit found for using as

emergency exit at first floor of the Emergency exit gate installed in
building. the canteen.

Page 3 of 3
ANNEX – VIII
Training records
Annex –IX: Training Records

Annex – IX

EMP Renewal Jaffer Agro Services PVT, LTD

Uploaded by

Document Information

Original Description:

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

EMP Renewal Jaffer Agro Services PVT, LTD

Uploaded by

Copyright:

Available Formats

Environmental Management Plan

JAFFER AGRO SERVICES PVT.

JAFFER AGRO SERVICES

EMC PAKISTAN PVT. LTD.

1.1. Profile of the Company

Table 1.1: Information of Jaffer Agro Services (Private) Limited

Table 1.1: Information of Jaffer Agro Services (Private) Limited

1.2. Location of the Production Facility

1.3. Facility Operations

1.3.1 Unloading and Receiving Cartons and Bags

1.3.2 Filling Lines & Packing

 Filling Machine with an average capacity of 8000 bottles/day

Fig 1.3: Process Flow of Liquid Filling and Packing Line

Figure 1.4: Flow Diagram of Production Process

1.3.4 Storage & Dispatching

Figure 1.5: Layout of Factory Warehouse

Fig 1.6: Product dispatch area and warehouses

1.3.5 Quality Control Laboratory

Table 1.3: Instrument at Quality Control Department

Below is the photographic record taken during the facility visit:

Fig 1.7: Laboratory

1.4. Products at the Facility

Table1.4: List of Products

1.5. Product Handling and Disposal of Waste

Non contaminated waste bin Drum washing and pressing

Crushed Empty drum for disposal Contaminated waste chemical pit

1.5.1. Non- contaminated Waste Streams

1.5.2. Contaminated Waste Streams

1.5.3. Local Exhaust Ventilation System (LEV)

3. ENVIRONMENTAL MANAGEMENT PLAN

3.2. Monitoring Parameters

1.1.1 Drinking Water Quality

pH of Drinking water sample at Jaffer Agro (Pvt) Ltd

7.2 7.4 7.6 7.8 8 8.2 8.4 8.6

SEQS limit Result

Fig.3.1 pH of Drinking Water

Environmental Management Plan

TDS of Drinking water Sample at Jaffer Agro (Pvt) Ltd

0 200 400 600 800 1000 1200

SEQS limit Result

Fig.3.3 TDS of drinking Water

Total Hardness of Drinking water sample at Jaffer Agro

Total Hardness (mg/L)

0 100 200 300 400 500 600

Total Hardness (mg/L)

SEQS limit Result

Fig.3.3 Total Hardness of Drinking Water

Environmental Management Plan

1.1.2.1 Discussion on Results of Wastewater

Temperature of Wastewater sample at Jaffer Agro (Pvt)

SEQS limit Result

Fig.3.8 Temperature of Wastewater

pH of Wastewater sample at Jaffer Agro (Pvt) Ltd

SEQS limit Result

Environmental Management Plan

TDS of Wastewater sample at Jaffer Agro (Pvt) Ltd

0 500 1000 1500 2000 2500 3000 3500 4000

SEQS limit Result

Fig.3.10 TDS of Wastewater

1.1.3.1 Discussion on Results of Stack Emissions

Particulate Matter level in Dust collector system emission

Particulate Matter (mg/Nm3)