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pubs.acs.org/acschas Research Article

Framework for Sound Management of Chemicals: Toward a

Sustainable Chemicals Industry in Bangladesh
Published as part of ACS Chemical Health & Safety virtual special issue “Safety Policy, Regulations, and Codes
from around the World”.
Sultana Razia Syeda*

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ABSTRACT: Bangladesh entered the group of middle-income countries in 2015. The ever-
Downloaded via 83.142.53.26 on September 8, 2020 at 03:59:37 (UTC).

increasing manufacturing sector is the key player behind its GDP growth, which led to a
substantial rise in chemical demand in the past decade. As 2020 approached, scrutiny intensified
over the global performance toward achieving the Sustainable Development Goals (SDG) target
of 12.4 (i.e., achieving environmentally sound management of chemicals and wastes throughout
their life-cycle by 2020). This study aims to shed light on the status of Bangladesh in this regard.
The study includes a review of the existing rules and regulations regarding chemical management
followed by an analysis of a major chemical incident that took place in Old Dhaka in February
2019 aiming to identify the gaps and challenges on the ground for attaining sound chemicals
management in Bangladesh. Additionally, a framework for sound chemicals management
including options for regulatory authority is proposed based on international guidelines and local
needs.
KEYWORDS: SDG target 12, chemical life-cycle management, sustainability, national framework, Old Dhaka fire, Bangladesh

1. INTRODUCTION
Bangladesh is one of the fastest growing economies in South
Asia. The country is strategically located beside two giant
economies, India and China, and poised to hold one of the
highest GDP growth rates in the region.1 Along with expanding
the ready-made garments (RMG) sector, the key driver of
Bangladesh’s GDP rise, the country is observing rapid growth in
textile, pharmaceutical, and process industries, leading to
increased chemical demand. Figure 1 shows a significant hike
in importing national chemicals and chemical-related products
in the past ten years.2 Expert speculation is that importing
accounts for 70% of the chemical demand, 3.5% of the total
import value of Bangladesh in 2017−2018.
Sound management of chemicals and waste is one of the key
contributors for achieving the Sustainable Development Goals
(SDGs). The objectives of sound management of chemicals are Figure 1. Chemicals and chemical-related products import by
to protect human health and the environment from harmful Bangladesh. Source: Bangladesh Bank2 (1USD = 84.5TK (BDT), 1
effects of hazardous chemicals through the improvement of the crore = 10 million).
legal framework, monitoring, evaluation, and prevention, and to
avoid negative effects to the national economy through
restrictions on the import and export of certain chemicals.3 It Received: April 12, 2020
requires integrated activities that cover and link all aspects of the
chemical lifecycle, including production, import, export, storage,
transport, distribution, use, and disposal of chemicals.
The country’s infrastructure and legal framework develop-
ment for chemical management have not kept pace with market

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A ACS Chem. Health Saf. XXXX, XXX, XXX−XXX
ACS Chemical Health & Safety pubs.acs.org/acschas Research Article

Table 1. Major Chemical Incidents in Bangladesh

chemicals
date, incident involved consequences short description
11 September, 1974 UFFL, NG 2 killed, 17 injured ammonia control room explosion
Ghorashal
20 June 1991, UFFL, Ghorashal CO2/NH3 11 fatalities, 50 injured, estimated property loss: explosion of high-pressure CO2 stripper during the startup,
US$ 60 M releasing CO2 and NH3
3 June 2010, Nimtoli fire, Old Dhaka Combustible 124 fatalities, 200 injured, property damage fire at chemical storage in residential building.
Residential Area chemicals
16 October 2011 Global Heavy Cl2 100 seriously exposed to toxic gas pipe failure due to rust and Cl2 gas leaks to surrounding area
Chemicals, Narayongonj
9 December 2014, Shela River in furnace oil spill affected the protected mangrove area and threatened oil tanker carrying 350 000 L of furnace oil collided with cargo
Sundarbans, a UNESCO World trees, plankton, and vast populations of small fish vessel and sank in the river, causing oil spread over 350 km2
Heritage site. and dolphins area in 1 week
24 January 2016, Smart Metal and boiler and 7 fatalities fire erupted in tire recycling factory after boiler exploded
Chemical Industries Ltd., Gazipur furnace oil
22 August 2016, DAP-1, Anawara, NH3 50 hospitalized, environmental damage 325 ton ammonia release due to drastic explosion of 500 MT
Chittagong ammonia tank
10 September 2016, Tampaco Foils NG and 35 fatalities, 100 hospitalized fire erupted triggered by two explosions in chemical storage
Ltd. Fire, Gazipur chemicals facilities
20 September 2017, Ideal Textile fire at the 6 fatalities from chemical suffocation sparks from welding work caused fire at the nearby chemical
Mill Charmuktarpur, Mushiganj chemical warehouse, which spread to other parts
warehouse
21 February 2019, Chawkbazar, Old combustible 70 fatalities, property damage explosion and fire at chemical storage in residential building
Dhaka Residential Area chemicals

growth as reflected by the fact that Bangladesh held the 162nd
position among 180 countries in the 2020 Environmental
Performance Index despite entering the group of middle-income
countries in 2015. Environmental issues of hazardous chemicals
have been a national concern for the past two decades. Existing
environmental policies are mostly sector-based (i.e., addressing
hazardous chemicals one at a time) and media-based (i.e.,
addressing air, water, and land separately).4,5 The policies have
failed to consider the possible linkages and opportunities for an
integrated approach and, hence, have remained largely
unsuccessful. Chemical safety issues have never been a priority
at the policy level. For more than a decade, accidents in garment
factories remained prevalent in Bangladesh. After the Rana Plaza
(2013) incident, the concerted efforts of the government,
buyers, and factory owners have made it possible to prevent
further incidents of a similar scale in this sector. On the other
hand, deadly incidents like the Nimtoli fire (2010), Tampaco
fire (2016), DAP ammonia release (2016), and very recently the
Old Dhaka fire (2019) in Chawkbazar involved chemicals and
have yet to receive the attention needed. Table 1 presents the list
of major chemical accidents in Bangladesh since its independ-
ence. The high number of fatalities, particularly in the Old
Dhaka incident, highlights the lack of proper policy
implementation, the technical and financial vulnerabilities of
affected people, and the growing need for an improved safety
management system and safety practices in this sector.6
Since the Old Dhaka fire, public concern regarding chemical
safety has heightened, and government agencies and industry are
showing interest for a better chemical safety and management
system at the national and organizational levels to keep
employees, communities, and the environment safe. Bangladesh
has signed a number of international treaties dealing with
chemical management. A number of acts and regulations aligned
with these treaties have been introduced by the pertinent
ministries. One treaty of particular importance is the Strategic
Approach to International Chemicals Management (SAICM)
convention. The implementation report of Bangladesh on
SAICM7 reveals that the overall chemical safety situation in
Bangladesh has not improved significantly since the signing of
the declaration in 2006, mainly because of insignificant
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government intervention for chemical management, an absence
of a dedicated budget and platform for active interaction, and
insufficient involvement of stakeholders in SAICM processes.
Most of the international treaties signed by Bangladesh
address environmental and long-term human exposure issues
and do not address workers’ safety. Although Bangladesh has
signed 35 ILO conventions including fundamental, governance,
and technical conventions, the country has not signed the
Chemicals Convention 1990 (No. 170) providing the basis for
the sound management of all types of chemicals at the workplace
and Prevention of Major Industrial Accidents Convention, 1993
(No. 174). Table 2 presents a summary of the international
conventions signed by Bangladesh along with national focal
points and relevant national acts. It is not clear, however, how far
the country has gone in implementing these treaties and in
acting to achieve sustainable chemical management.
This paper presents the big picture of national chemical
management of Bangladesh and suggests the way forward at the
policy level. It prescribes a framework for a national chemical
management system in light of international guidelines and best
practices along with priority areas that need immediate
government attention and long-term commitment. This paper
is one of the pioneering attempts discussing the national
chemical management situation of Bangladesh.
Through its Strategic Approach to International Chemicals
Management (SAICM), UNEP set 2020 as the initial deadline
to achieve sound management of chemicals throughout their
lifecycle around the world. The EU has already completed a
review of its chemicals policy.8 Reviews on US policies are being
reported for further improvements.9,10 Developing countries, on
the other hand, are lagging far behind the EU, US, and other
developed countries. The present study can serve as a starting
point for the policy makers of Bangladesh as well as for those in
other developing economies facing increasing chemical demand
and seeking to establish an appropriate infrastructure and legal
framework for sustainable chemical management.
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ACS Chemical Health & Safety pubs.acs.org/acschas Research Article

2. LEGISLATION AND MAIN REGULATORY AGENCIES

Hazardous and Toxic materials in 1996

Bangladesh Environment Conservation

Chemical Weapons (Prohibition) Act,

FOR CHEMICAL LIFE-CYCLE MANAGEMENT

Regulatory Framework on Import of

relevant national law/act Bangladesh has enacted environmental legislation, as well as

National Ozone Unit (NOU)

legislation and regulations that govern some aspects of chemical
management. The most important legislations in this regard are

established in 1996
the Environmental Conservation Act (ECA) of 1995 and the
Environmental Conservation Rules (ECR) of 1997. ECA, 1995,
is the central framework for the environment in Bangladesh. The
Act, 1997

Act provides for environmental conservation and improvement

2006
of environmental standards and for controlling and mitigating
environmental pollution. The regulatory body for this legislation
is the Department of Environment under the Ministry of

Communicable Disease Control Unit (CDC) of Directorate General of

Environment, Forest and Climate Change. The government also
Ministry of Environment, Forest and Climate Change (MoEFCC)

Bangladesh National Authority for CWC, Armed Forces Division

Health Services (DGHS), Ministry of Health & Family Welfare

declared the National 3-R Strategy, 2010,11 to provide guidance
to local government bodies, industries, NGOs, and trade bodies
to develop individual action plans for achieving National 3R
goals in their respective areas. Bangladesh Standards and
Guidelines for Sludge Management, 2015, provides guidelines
Department of Environment (DoE), MoEFCC

for the safe disposal of various kinds of sludge. ECR, 1997, is

national focal point

undergoing revision with a target to achieve zero discharge from

industrial facilities. There are rules to regulate generation and
disposal of specific hazardous wastes. Biomedical Waste
Management Rules, 2008, and Lead Acid Battery Recycling
and Management Rules, 2006, are specific to collecting and
treating hospital and medical waste, and lead acid battery waste,
respectively. The Bangladesh Ship Building and Ship Recycling
DoE, MoEFCC

Rules, 2011, is additional critical guidance specific to ship

recycling facilities. Bangladesh derives 80−90% of its steel by
MoEFCC

MoEFCC

MoEFCC

ship breaking. The rules require ship recycling facilities to

undertake risk management for occupational safety and health of
workers as well as to protect the environment from harmful
substances, such as persistent organic pollutants (POPs),
commitment
Bangladesh’s

not ratified

not ratified

not ratified
reduce hazardous wastes and provide environmentally sound management signed and

institute prior informed consent (PIC) procedure for certain hazardous signed and

signed and

ban the development production, possession or use of chemical weapons signed and

signed and
signed but

signed but

signed but

asbestos, and heavy metals, released from ship breaking. A

ratified

ratified

ratified

ratified

ratified

separate authorized body, the Ship Building and Ship Recycling

Board (SBSRB), involves a number of ministries to inspect and
Table 2. International Conventions and Respective National Focal Points

certify ship breaking and recycling facilities.

prevent, prepare for and respond to public-health events and emergencies

Additionally, there are a few regulations of toxic chemicals

protect ozone layer by phasing out chemicals that deplete ozone layer
protect humans and environment from persistent organic pollutants

covering import, export, transportation, storage, production,

of potential international concern, including chemical events.

handling, and the use of such chemicals. The Imports and

Exports (Control) Act, 1950, and the Import Policy Order and
Export Policy, 2015−2018, provide general and specific
guidelines to control the import and export of chemicals. The
chemicals and pesticides in international trade

Dangerous Cargoes Act, 1953, prescribes provisions for safety of

ports regarding the transit, working, and storage of dangerous
manage chemicals throughout their lifecycle

cargoes, including calcium carbide, sulfur, refrigerant gas, fish

objectives

meal, tetrafluoroethane, liquefied gas, isobutane, and chlorodi-

fluoromethane. The Bangladesh Navy inspects and issues
clearances for dangerous cargoes. The Chemical Weapons
(Prohibition) Act, 2006, yet another act for specific chemicals,
phase out use of mercury

was introduced to enact Chemical Weapons Convention

(CWC). The convention prohibits the development, produc-
tion, acquisition, stockpiling, retention, use, or transfer of
schedule chemicals and discrete organic chemicals (DOCs)
(POPs)

except for permitted purposes under the CWC. Enrollment

Rules, 2010, published in The Bangladesh Gazette in 2010, states
the criteria, procedure, and submission requirements of various
Basel Convention

documents for enlistment with the national authority. The

convention

Convention

Convention

Convention

Convention

Convention
International

Gazette includes the list of schedule chemicals with the

Regulation
Weapons
Mina Mata
Rotterdam

Stockholm

Protocol

Chemical
Montreal

Harmonized System (HS) Code. The CW Act entrusts the

Health
SAICM

Armed Forces Division with the duties of the National Authority

of CWC. The Drugs Act, 1940, and the Drugs (control)
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ACS Chem. Health Saf. XXXX, XXX, XXX−XXX
ACS Chemical Health & Safety
Ordinance, 1982 (amended 2006), regulate the import, export,
manufacture, distribution, and sale of drugs.
There are also century-old acts, such as the Explosive Act,
1884, Explosive Substance Act, 1908 (modified up to 1983), and
Explosive Rules, 2004, to regulate the manufacture, possession,
use, sale, transport, and importation of explosives. Ammonium
Nitrate Rules, 2018, was introduced to regulate the manufacture,
modification, possession, packaging, use, sale, transport, loading,
unloading and importation of ammonium nitrate. Petroleum
Act, 2016, which is the updated version of Petroleum Act, 1934,
deals with licensing requirements and procedures for individuals
dealing with import, storage, transportation, and distribution of
petroleum products under the authority of Department of
Explosives. Petroleum Rules, 2018, describes the safety of
storage; road, waterway, and pipeline transportation; hazardous
area classification; and accident investigation. All the above
mentioned acts and rules concerning explosives and petroleum
products are under the authority of Department of Explosives,
Ministry of Power, Energy and Mineral Resource.
For industrial and hazardous indoor facilities, Bangladesh
National Building Code, 2015, provides guidelines for building
construction, layout, fire escape, and firefighting provisions. The
Building Regulatory Authority, mandated in the Bangladesh
National Building Code (BNBC) to ensure building safety in the
country, has yet to be formed by the government.
The Bangladesh Energy Regulatory Commission’s LPG
Storage, Bottling, Transportation and Dispensing Codes and
Standards, 2016, provide minimum requirements to ensure
quality, safety, and environmental protection for LPG storage,
bottling, transportation, and dispensing including container,
piping, and associated equipment and appurtenances. A few laws
deal with workers’ safety from chemical exposure. The Factories
Act, 1965, and the Factory Rules, 1979, prescribe for the health,
hygiene, and safety of workers, including safety from dust and
fumes, and proper disposal of wastes and effluents. The
Bangladesh Labor Law includes sections concerning emergency
exits, mandatory use of personal safety equipment, and access to
gangways and stairs, and other safety procedures for workers.
The 2013 amendment of this law requires the formation of a
safety committee and notification to a competent authority in
case of incidents. The amendment also provides for a chemical
safety manual for the safety committee’s use. The National
Occupational Health and Safety (OSH) Policy, 2013, comple-
ments the labor law to ensure workplace safety and health
protection, to set up national standards on OSH, and to include
OSH issues in the policies and programs of all related ministries
and agencies. The Department of Disaster Management
(DDM), under the Ministry of Disaster Management and
Relief, has recently added chemical disaster management to the
Standing Orders on Disaster (SOD). The Fire Service and Civil
Defense (FSCD) and National Authority for Chemical
Weapons Convention (BNACWC) have important roles in
chemical disaster management.
At the user end, the Bangladesh Pure Food Ordinance, 1959,
and Amended Act, 2005, prohibit the use of harmful chemicals
in manufacture/processing of food and sale of food stuff. The
Formalin Control Act, 2015, protects against formalin, widely
used in foodstuff. The act establishes a licensing system for
importing, producing, shipping, stocking, and selling of formalin
as well as its use as a preservative. Among toxic chemicals,
pesticides have the most potential to come in contact with
humans and the environment. The Pesticide Ordinance, 1971,
and Pesticide Rules, 1985, govern the registration, import,
D https://dx.doi.org/10.1021/acs.chas.0c00039
pubs.acs.org/acschas Research Article
packaging and labeling, and use of pesticides in agriculture. The
rules also prescribe measures for safeguarding the safety and
health of workers engaged in manufacturing and formulation
processes. The Bangladesh Standards and Testing Institution
(BSTI), under the Ministry of Industries, is entrusted with the
responsibility of formulating national standards for industrial,
food, and chemical products in view of regional and interna-
tional standards. The relevant legislations are the Bangladesh
Standards and Testing Institution (Amendment) Ordinance,
1988, and the Bangladesh Standards and Testing Institution
Rules, 1989. Sound management of chemicals requires a legal
framework and integrated activities that cover and link all
aspects of the chemical lifecycle, including production, import,
export, storage, transport, distribution, use, and disposal of
chemicals, otherwise known as “lifecycle” management. Table 3
lists Bangladeshi legislation along with the implementing
authorities under different stages of chemical lifecycles.
3. OLD DHAKA FIRE 2019
3.1. Background and Incident Description. Old Dhaka,
with its old buildings, informal and unplanned constructions,
narrow streets, entangled electrical wires, and chemical
factories/warehouses in residential buildings, has remained a
vulnerable area for both natural and man-made hazards.
According to an estimate by Bangladesh Poribesh Andolan
(Bangladesh Environmental Movement), more than 25 000
chemical warehouses are in Old Dhaka, of which some 15 000
are in residential buildings. It is reported that only 2500 of these
warehouses have a license.12 The warehouses store chemicals
and dyes, used largely in ready-made garment (RMG) and
textile factories. In some buildings are shoe factories and rubber
and plastic processing facilities. Old Dhaka also has numerous
warehouses and filling/refilling facilities for counterfeit perfume
products.
On the night of 20 February, 2019, a massive fire razed the
Chawkbazar’s Churihatta area of Old Dhaka causing over 71
deaths and numerous injuries. 37 fire-fighting units worked
incessantly for 15 h to control the flames. This is the second
biggest fire in Old Dhaka after the 2010 Nimtoli fire that claimed
124 lives.
Immediately after the incident, different ministries and
authorities, including the Ministry of Industries, Ministry of
Home Affairs, Ministry of Labour and Employment (MoLE),
FSCD, and Dhaka South City Corporation (DSCC), formed a
number of probe committees. Within 5 days, the probe
committee of Ministry of Industries submitted a report claiming
the fire was sparked by a gas cylinder blast on the road and that
the explosion of a roadside transformer contributed to it.13
Contrarily, the probe committee of Ministry of Home Affairs
reported that the fire originated from a chemical explosion on
the first floor of Wahed Mansion, the worst affected building,
where hundreds of damaged cans of body spray and canisters to
refill gas lighters were found. The latter view was supported by
most other probe committees.
After the incident, a team of firefighters discovered several
hundred barrels and sacks of combustible and flammable
substances stored in the basement of the four-story Wahed
Mansion. Most of the barrels and sacks did not have proper
labeling or safety signs.13
3.2. Observation. Prima facie, the Churihatta incident is an
unfortunate case of negligence by regulatory authorities and
contraventions of the statutory requirements of safety and
environmental safeguard by the warehouse owners. The key
ACS Chem. Health Saf. XXXX, XXX, XXX−XXX
 Table 3. Legislations and Implementing Authorities Relevant to Chemical Life-cycles Management
act/rule
The Environmental Conservation Act (ECA), 1995; Environmental
Conservation Rules (ECR), 1997
National 3-R Strategy, 2010
Bangladesh Standards and Guidelines for Sludge Management, 2015
Lead Acid Battery Recycling and Management Rules, 2006
Biomedical Waste Management Rules, 2008
The Bangladesh Ship Building and Ship Recycling Rules, 2011
The Bangladesh Standards and Testing Institution (Amendment) Ordinance,
1988; The Bangladesh Standards and Testing Institution Rules, 1989
Bangladesh Pure Food Ordinance 1959; Amended Act, 2005
Formalin Control Act, 2015
The Pesticide Ordinance, 1971; Pesticide Rules, 1985
The Imports and Exports (Control) Act, 1950; The Import Policy Order,
E
2015−2018; Export Policy, 2015−2018
Chemical Weapons (Prohibition) Act, 2006; Enrollment Rules, 2010
Dangerous Cargoes Act, 1953
The Drugs Act, 1940; The Drugs (control) Ordinance 1982 (amended up to
2006)
The Explosive Act 1884; The Explosive substance Act, 1908 (modified up to
1983)
Ammonium Nitrate Rules, 2018
Petroleum Act, 2016
Bangladesh National Building Code (BNBC), 2015
LPG Storage, Bottling, Transportation and Dispensing Codes and Standards,
2016
Petroleum Rules, 2018
Factories Act, 1965; The Factory Rules, 1979
Bangladesh Labor Law, 2006 (Amended in 2013)
National Occupational Health and Safety Policy, 2013
ACS Chem. Health Saf. XXXX, XXX, XXX−XXX
https://dx.doi.org/10.1021/acs.chas.0c00039
objective
Waste Management/Disposal/Recycle
to provide standards for industrial pollutants
to provide strategy for 3 Rs: Reduce, Reuse, Recycle
to provide guidelines for safe sludge disposal
to provide rules for collecting and recycling lead acid batteries
to provide rules for managing hospital waste
to provide rules for safe and environmentally sound ship recycling
Use
to provide national standards of industrial, food and chemical products
to prohibit use of harmful chemicals in manufacturing or processing food and
selling food stuff
to control using formalin
to control importing and using pesticides in agriculture
Import/Export/Transport
to control importing and exporting goods including chemicals
to prohibit development, production, acquisition, stockpiling, retention, use, or
transfer of chemicals relevant to Chemical Weapons Convention (CWC)
to provide for safety of the port for handling dangerous goods
to control manufacturing, importing, distributing and selling drugs
to regulate the manufacture, possession, use, sale, transport and importation of
explosives
To regulate the manufacture, modification, possession, packaging, use, sale,
transport, loading, unloading and importation of ammonium nitrate
to regulate the manufacture, possession, use, sale, transport and importation of
petroleum products
Storage/Industrial Facilities
to provide building guidelines including for industrial and hazardous indoor
facilities
to establish minimum requirements for storing, bottling, transporting, and
dispensing LPG
Petroleum product storage design layout, transportation, hazardous area
classification
Safety/Disaster Management
to provide rules for health and hygiene and safety of workers
to ensure Occupational safety through safety committee (provides chemical safety
manual)
to ensure workplace safety and occupational health
implementing authority
Department of Environment (DoE), Ministry of
Environment Forest and Climate Change (MoEFCC)
Department of Environment (DoE), Ministry of
Environment Forest and Climate Change (MoEFCC)
Department of Environment (DoE), Ministry of
Environment Forest and Climate Change (MoEFCC)
Department of Environment (DoE), Ministry of
Environment Forest and Climate Change (MoEFCC)
Department of Environment (DoE), Ministry of
ACS Chemical Health & Safety
Environment Forest and Climate Change (MoEFCC)
The Ship Building and Ship Recycling Board (SBSRB)
Bangladesh Standards and Testing Institution (BSTI),
Ministry of Industry
Local Government Authority
Deputy Commissioner/District Magistrate
Plant Protection Wing, Department of Agricultural
Extension, Ministry of Agriculture
Office of the Chief Controller of Imports & Exports,
Ministry of Commerce
Bangladesh National Authority for CWC, Armed Forces
Division
Bangladesh Navy; Port Authority
Department of Drug Administration, Ministry of Health
and Family Welfare.
Department of Explosives, Ministry of Power, Energy
pubs.acs.org/acschas
and Mineral Resource
Department of Explosives, Ministry of Power, Energy
and Mineral Resource
Department of Explosives, Ministry of Power, Energy
and Mineral Resource
Ministry of Housing and Public Works
Bangladesh Energy Regulatory Commission (BERC)
Department of Explosives, Ministry of Power, Energy
and Mineral Resource
Department of Inspection for Factories and
Establishments, Ministry of Labour and Employment
Department of Inspection for Factories and
Establishments, Ministry of Labour and Employment
Department of Inspection for Factories and
Research Article
Establishments, Ministry of Labour and Employment
ACS Chemical Health & Safety pubs.acs.org/acschas Research Article

contributing factor of the incident was the storage of highly

Department of Disaster Management (DDM), Ministry

flammable and toxic chemicals in a residential building without
even minimal fire prevention/emergency management provi-
sions. This was a violation of the Environment (Protection) Act,
1986, prohibiting industrial facilities in residential areas, as well
implementing authority

as the Building Construction Act, 1952, prohibiting the use of

of Disaster Management and Relief

residential buildings for commercial purposes.

3.3. Role of Regulatory Authorities. All chemical
businesses of Old Dhaka must get their trade license from
Dhaka South City Corporation (DSCC), which approves the
quantity and type of chemicals as well as their designs and
drawings of storage/factories and their locations. A business
owner can import any amount of chemical and store it at the
address for which the city corporation issues a trade license. The
commerce ministry gives an import registration certificate, and
the National Board of Revenue (NBR) gives a tax identification
number for this address.
Also mandatory is a fire certificate from the FSCD upon
showing a satisfactory fire prevention and mitigation plan. All
factories must get factory plans approved by the Department of
Inspection for Factories and Establishments (DIFE) for a
certificate of registration. The factories also need an Environ-
mental Clearance Certificate from the Department of Environ-
ment. Chemical facilities involved with commercial explosives,
compressed gases, and flammable liquids such as petroleum,
combustible solids, and oxidizing substances need approval from
to enforce the standing order for chemical disaster

the Department of Explosives for their site layout and

objective

construction plans for manufacturing factories/storage. Addi-

Safety/Disaster Management

tionally, RAJUK, the capital development authority, must

approve new building construction. All of these regulatory
bodies have partial mandate to safeguard chemical establish-
ments. There is no single authority to oversee the import,
transportation, and storage of hazardous chemicals as a whole.
3.4. Recommendations and Aftermath. The probe
committees have not released their reports and recommenda-
tions. Media reports, however, indicated that all probe
committees emphasized the immediate implementation of the
home ministry’s 17-point recommendations made after the 2010
Nimtoli fire, which include relocating warehouses to nonres-
idential areas, enforcing Fire Prevention and Extinguishing
Rules, 2003, and Bangladesh National Building Code, installing
separate hydrant points in the city’s different areas, forming a
cross-functional license issuing body, and updating school and
college textbooks to raise awareness from an early age.14
The only recommendations released to the press are those of
DIFE’s probe committee.14 The key points of the recom-
mendations are as follows:
• relocating chemical factories to a special zone, and
creating a regulatory authority to monitor transportation,
storage, and marketing of flammable items;
act/rule

• preparing a database of the factories in Old Dhaka,

including the number of factories, nature of their work,
and raw materials they use;
Standing orders for Disaster, 2018

• identify the level of risks involved in the plastic and

chemical factories in Old Dhaka, and recommend ways to
Table 3. continued

mitigate the risks;

• form a Chemical Cell under DIFE that follows the
Material Safety Data Sheet to eliminate risks involved in
storing, transporting, and using chemicals;
• ensure effective implementation of legal measures by
incorporating jail terms in the labor law to motivate the

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ACS Chem. Health Saf. XXXX, XXX, XXX−XXX
ACS Chemical Health & Safety
owners of chemical factories and warehouses to comply
with the safety-related provisions.
After the incident, Dhaka South City Corporation (DSCC)
formed a two-tier task force to remove warehouses containing
the 35 most flammable chemicals suggested by the Department
of Explosives from 15 wards in Old Dhaka in a 1 month drive.
The drive failed mainly due to the following reasons: (i) a lack of
inventory of the chemicals in the area, (ii) no designated
destinations for immediate transfer of the chemicals, and (ii) the
reluctance of business owners to relocate.
The government has approved two temporary chemical
warehousing projects in Shyampur and Tongi for relocating Old
Dhaka chemicals under Bangladesh Chemical Industries
Corporation (BCIC) and Bangladesh Steel and Engineering
Corporation (BSEC), respectively. While the fate of the
Shyampur project became uncertain due to siting issues, the
Tongi project will take an estimated 1 year to complete if all
steps are carried out on time. The project to permanently shift
the chemical businesses to Chemical Industrial Park in the
Munshiganj area under Bangladesh Small and Cottage
Industries Corporation (BSCIC) will not come into operation
before June 2022.15
4. GAPS AND CHALLENGES
4.1. Legal Framework and Regulatory Agencies. The
incident at Old Dhaka calls attention to the fact that existing
regulations provide chemical management on a sectorial basis.
Each regulatory body has its own legislation covering part of
chemical management or focuses on control of particular
chemicals with specific objectives. Lack of integration among
different government organizations became evident as six
different probe committees were formed by six government
agencies after the incident, some of which issued contradictory
reports. Besides, frequent overlapping and gaps in regulations
can be observed. For example, the dangerous cargoes act and
explosive substance act overlap in some areas, whereas there is
no regulation to adequately address safe transportation of
chemicals.
4.2. Chemical Inventory and Hazard Communication.
After the Old Dhaka incident, it became apparent that no
organization or authority has the complete chemical inventory
of Old Dhaka residential area or for chemical facilities
countrywide. The only public data source relevant to the
chemical industry is the Bangladesh Bureau of Statistics, which is
not verified for its completeness and inaccessible to the public.
The Bangladesh Bank publishes monthly statistics of total
export/import monetary values for different merchandise
categories including chemicals. Information on chemicals,
however, is not adequately collected and compiled to allow for
its use in the management of chemicals for risk assessment or
risk reduction. More significantly, the government does not
enforce a uniform and mandatory hazard labeling system. Thus,
unlabeled or inadequately labeled chemical containers are
frequently found in storage facilities, such as those in the Wahed
Mansion, and in transports.
4.3. Enforcement and Monitoring. Shortages of a skilled
workforce and testing facilities are two major barriers for
effective monitoring and enforcement. The probe committee
formed by DIFE after the Old Dhaka incident reported that
DIFE inspected a total of 2959 factories and establishments in
Old Dhaka from the beginning of 2013 to February 2019, which
is less than 1% of the estimated number of chemical warehouse
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residing in the area. This shortfall is representative of the overall
scenario of regulatory agencies pertinent to chemical life-cycle
management.
4.4. Chemical Safety. Occupational safety for industrial
facilities is addressed in the amended Labor Act, 2013. A manual
of chemical safety is also prescribed for industry to follow. Safety
in the use of chemicals and safety of major hazard installations,
known as process safety, have not been addressed in any of the
existing regulations. Risk assessment and risk management of
different chemicals with respect to their effects on the
employees, consumers, and the environment have yet to be
introduced. The process of lessons learned from incident
investigations is also absent at the national or organization level.
Investigations seek to find the person responsible, not the root
cause, and most of the investigation reports do not see daylight,
as in the case of the probe committees’ reports formed after the
Old Dhaka incident.
4.5. Involvement of Stakeholders. One of the main
reasons that the drive for chemical warehouse relocation from
Old Dhaka failed is the reluctance of the business owners. In the
whole legal framework, there is no platform for active interaction
and involvement of the stakeholders in the chemical manage-
ment process; chemical importers, chemical producers, and
distributors have little or no say in the policy making. This has
led to the formulation of policies and regulations that are
difficult to implement. Conversely, due to noninvolvement of
industry, the regulatory body fails to collect necessary
information regarding hazardous chemical storage in certain
facilities or hazardous properties of the chemicals contained in
certain products.
4.6. Awareness and Training. There is lack of awareness
regarding sound chemical management among stakeholders,
particularly among the small- and medium-scale enterprises, and
a serious dearth of technical personnel in chemical safety
management in both regulatory bodies and industries. For
example, none of the probe committees of the Old Dhaka
incident included any expert with a chemical safety background.
This shows a lack of appropriate personnel in the regulatory
authorities as well as a lack of appreciation of distinguishing
between chemical safety, with the unique concerns it brings to
bear, and general fire safety. Furthermore, no institution of the
country offers degrees, certification courses, or diplomas for this
purpose. The OSH institute of DIFE, BNACWC, and Training
Institute of Chemical Industries (TICI) under BCIC and the
Chemical Engineering Department of Bangladesh University of
Engineering and Technology (BUET) offer limited courses of
short duration, but they are far from adequate.
5. PRIORITY AREAS
A number of chemical management issues, beyond those of Old
Dhaka, requiring government initiatives at the national level
arose in the gap analysis described above. Some of the issues can
be addressed immediately, whereas others need a long-term
commitment. Suggestions for government action to achieve
sound chemicals management based on priority and ease of
implementation are listed as follows.
Short-term activities (6 months):
• Introducing an Act for Mandatory Hazard labeling all
chemicals being imported, transported, and stored.
• Activating the One-stop Service Act, 2018, (OSSA) for
effective chemical registration and database maintenance
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under which some 15 government agencies provide all
relevant services to investors from one point.
Medium-term activities (1−2 years):
• Setting up of a National Chemical Coordination
Committee.
• Initiating a three-way partnership with academia, industry
stakeholders, and regulatory authorities to address
chemical safety issues.
• Establishing a national center for chemical safety to train
personnel from regulatory authorities and industry.
Long-term activities (3−5 five years):
• Creating a national regulatory authority (i.e., a full-fledged
department for chemical management and safety).
• Developing chemical safety management policy/regula-
tions and guidelines for storing, transporting, using, and
auditing hazardous/dangerous chemicals.
• Establishing judicial capabilities in support of enforce-
ment activities.
• Establishing a national chemical database accessible to the
public.
• Forming a national chemical safety/investigation board to
conduct incident investigation and provide recommen-
dations and guidelines to prevent accidents.
• Integrating chemical and fire safety courses in the
curriculum of chemistry/chemical engineering and allied
fields of study.
6. FRAMEWORK FOR CHEMICAL MANAGEMENT
The 17-point recommendations made after the 2010 Nimtoli
fire emphasized the formation of a cross-functional license
issuing body. The probe committee of DIFE for the Old Dhaka
fire 2019 recommended establishing an authority to monitor
transportation, storage, and marketing of flammable items.
These recommendations implied the need of an appropriate
regulatory body to oversee the national chemical activities.
Key features of a national chemical management system16
may be categorized in the six elements as shown in Figure 2. The
Figure 2. Elements of National Chemical Management System
central three elements, national chemical inventory, hazard
communicating system, and funding and support, require
management by the government; the other three, waste
management, risk assessment and management, and data access
and use, require close collaboration between government
agencies and industry. To run a chemical management system
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efficiently, a country needs three essentials: a legal framework, a
regulatory authority, and a chemical database. The precondition
for a strong chemical management system is national
prioritization. The government needs to provide directives for
sound chemical management in a holistic and integrated manner
taking into account existing laws and international regulations.
US Toxic Substances Control Act and REACHEuropean
Union Regulation (EC) are two major examples of hazardous
chemical control regulations, which are the bases of chemical-
related regulations adopted by many other countries.
Furthermore, a national coordination body with a chemical
management mandate needs to be formed. This body would
have multifarious tasks, integrating interministerial activities and
maintaining contact with its funding agency and international
bodies. Among its tasks would be enforcing the chemical registry
to create a national database and monitoring the environmental
and health impact of chemicals. This body would also support its
stakeholders by maintaining the database and contributing
toward capacity building.
The structure of such national bodies has taken different
forms with diverse modes of operation in different countries. In
most countries, the national body or regulatory authority is
under the environment- or labor-related ministry. For example,
Occupational Safety and Health Administration (OSHA) and
U.S. Environmental Protection Agency (EPA) are two
regulatory authorities responsible for making rules and oversee-
ing compliance of chemical-related activities in the US. In the
UK, the Health and Safety Executive is the key authority for
national chemical management and works closely with the
Environment Agency.
Countries where a chemical management system is still
developing follow a similar system. Examples of Malaysia and
India are noteworthy.17,18 In Malaysia, an independent National
Chemical Management Board/Commission is in planning to be
formed under the five-year plan 2015−2020. The work of
creating the database, however, has already been started by the
Department of Environment through the voluntary Environ-
mentally Hazardous Substances Notification and Registration
(EHSNR) to build a foundation for the database of environ-
mentally hazardous chemicals. The Department of Occupa-
tional Safety and Health (DOSH) also maintains a database
through its Chemical Information Management System
(CIMS). A complete database is expected to be created by
combining these two.
India has numerous rules and acts that apply to chemical life-
cycle management, but it does not have a coordinated chemical
management system. In April 2017, the Ministry of Environ-
ment, Forest and Climate Change formed the National
Coordination Committee (NCC) to form a National Action
Plan for Chemicals (NAPC). The NCC comprises experts in
chemical processes, ecology, and toxicology as well as senior
officials from the central Pollution Control Board (PCB). In
December 2019, NCC published a draft National Action Plan
for chemicals, which includes recommendations such as
compilation of a national chemicals inventory with risk
assessment, implementation of GHS, and development of risk
mitigation strategies, policies, and regulations.19
In some countries, such as Italy and Slovenia, the regulatory
authority is under the ministry of health.20,21 The DG Health
Prevention, Ministry of Health, is the regulatory authority of
chemical management in Italy working with the Ministry of
Environment and Ministry of Economic Development to
enforce regulatory requirements. In Slovenia, the National
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ACS Chemical Health & Safety
Figure 3. Proposed framework for national chemical management.
Chemicals Bureau was established in the Ministry of Health in
1999 to provide acceptable risks for chemical exposure in the use
and production of chemicals to its country’s population. The
National Chemicals Bureau was changed to the Chemicals
Office of the Republic of Slovenia (CORS) in 2008. CORS has
six internal organizational units for planning, coordination and
development, monitoring, risk assessment, quality assurance,
and data access and chemicals inspection.
Which governmental agency should be given the mandate of
chemical management in Bangladesh? This is a major dilemma
and one of the key factors that slowed any progress in this sector.
The focal point of most of the international treaties pertinent to
chemical management is the Ministry of Environment, Forest
and Climate Change (MoEFCC) and its regulatory body the
Department of Environment (DoE). The other relevant
regulatory bodies include the Department of Explosives, which
controls the export/import of explosives as well as petroleum
products; Department of Inspection for Factories and Establish-
ments, responsible for inspection of factories and facilities for
occupational safety; and Fire Service and Civil Defense, which
gives clearance for firefighting provisions of the facility. All of
these organizations have their own mandates and separate
inventories of registered facilities. The chemical incident in Old
Dhaka exposed the fact that none of these departments has the
mandate, capacity, or preparedness to deal single-handedly with
the multifaceted issues of chemical management.
pubs.acs.org/acschas Research Article
Considering the gravity of this shortfall, the government
needs to form an independent national coordination body of
chemical management, preferably under the cabinet division on
a priority basis. The national body would consist of
representatives from government agencies, industry, academia,
experts, and public interest groups.
A suggested framework for chemical life-cycle management in
Bangladesh in light of international guidelines and local needs
appears in Figure 3. Initially, the framework can be applied for
regulated chemicals and adopted or extended to achieve a
sustainable chemical management system. Apart from integrat-
ing interministerial activities and communicating with interna-
tional agencies, the national coordination body needs to work
closely with industry, academia, and research/testing organ-
izations, particularly for enforcement and capacity building. This
body in due course may take the form of a permanent
department dedicated to sound chemical management.
Funding for establishing a national chemical management
system is vital. National prioritization would necessitate the
government to make budgetary allocations. Funding sources can
include international agencies (e.g., UNITAR’s funding for
Zambia) or donor countries (e.g., Swedish chemical agency
Kemi’s funding for Vietnam). Notable among available
international funding opportunities is the Global Environment
Facility (GEF) Project on Global Best Practices on Emerging
Policy Issues of Concern under SAICM.22 Bangladesh is in the
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right position to explore these funding opportunities. The
growing local chemical industry can be enlisted to subscribe to
facilitate different activities of chemical life-cycle management,
which in turn would be beneficial for them in capacity building
and regulatory compliance. The International Council of
Chemical Associations (ICCA), while sharing its experience
regarding establishing a chemical management system, recently
said “In our experience of working with emerging markets, it is
often not the amount of funding that makes a difference but
whether we can equip the right people developing chemical
management programmes with the right skills.”23 Thus, the
effort of fund generation should go hand in hand with
appropriate workforce development.
7. CONCLUSIONS
The review of local policy and regulations concerning chemical
management and the analysis of the Old Dhaka fire 2019
incident reveal that Bangladesh is lacking in several areas
including a legal framework, chemical inventory and hazard
communication, involvement of stakeholders, skilled workforce
and analytical facilities toward achieving sound chemical
management. This paper proposes a national framework and a
national coordination body under the cabinet ministry. The
priority areas identified for government initiatives are GHS
implementation, chemical registry enforcement and database
formation, allocation of funds, and capacity building.
Chemical management is best implemented in countries with
strong financial and regulatory capacities, that is, countries with
a developed infrastructure and skilled workforce.24 Although
Bangladesh joined the lower-middle-income country category in
2015, it is yet to graduate from the Less-Developed Countries
(LDC) status.25,26 Thus, implementing sound chemical
management would be challenging here. On a positive note, as
the regulatory framework is not comprehensive, the legal
framework to be formulated for this purpose is unlikely to
overlap or conflict with the existing laws. Strengthening
chemical management is of highest importance in countries
with the lowest capacity, and Bangladesh will benefit from LDC-
specific special support measures from the international
community, which is also applicable for the chemical manage-
ment sector. As UNEP is looking beyond 2020 to establish
sustainable chemical management globally, the government
needs to initiate the process of sound chemical management in
the country while aiming to graduate from LDC in 2024.
■
AUTHOR INFORMATION
Corresponding Author
Sultana Razia Syeda − Department of Chemical Engineering,
Bangladesh University of Engineering and Technology, Dhaka
1000, Bangladesh; orcid.org/0000-0002-8523-592X;
Phone: +880 1817550666; Email: syedasrazia@
che.buet.ac.bd
Complete contact information is available at:
https://pubs.acs.org/10.1021/acs.chas.0c00039
Notes
The author declares no competing financial interest.
■
ACKNOWLEDGMENTS
The author would like to thank Bangladesh National Authority
of Chemical Weapons Convention (BNACWC) and Bangla-
desh Bank for making data and information available.
J https://dx.doi.org/10.1021/acs.chas.0c00039
■
Research Article
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