Larrabee
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ENVIRONMENTAL MANAGEMENT PLAN
FOR
LARRABEE ENTERPRISES LIMITED PLOT 62 SHARADA INDUSTRIAL ESTATE PHASE 111, KANO
Prepared by
PREPRA NIGERIA LIMITED (NESREA Accredited Environmental Management Consultants)
31/32 Bello Road, Kano Email:
[email protected]
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List of figures Figure 1
Location of sharada industrial estate within Kano metropolis
Figure 2
Communication channel & responsibilities in Larrabee
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List of Tables
Table 1
Company profile of Larrabee
Table 2
List of plants and number of Equipments
Table 3
NESREA recommended personnel protective Equipments by hazard type
Table 4
Training Programme - Summary of Training Needs of Larrabee
Table 5
Reporting Plan - Process Summary
Table 6
Emergency Response
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List of Plates
Plate 1 Location of Larrabee factory from Google earth Plate 2 Wet-salted raw skins in the Ware house of Larrabee Plate 3 Soaking in Paddles for un-hairing at Larrabee in Larrabee Plate 4 Beam house in Larrabee(Drums used for liming, tanning and Retanning) Plate 5 Fleshing Operation at Larrabbe Plate 6 Wet blue being Piled in Larrabbe Plate 7 Crust Drying line (dyed black) in Larrabee Plate 8 Diesel Storage tank in Larrabee Plate 9 Waste Water Holding Tanker in Larrabee
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TABLE OF CONTENTS
List of Tables
i
List of Figures
ii
List of Plates
iii
1.0
CHAPTER 1: INTRODUCTION
1-6
1.1
Background
1-3
1.2
Legal and Institutional framework
3-5
1.3
Overview of Environmental legislation in Nigeria
5-6
2.0
CHAPTER 2: COMPANY PROFILE, LOCATION, SITE AND
7-12
ENVIRONMENT 2.1
Company Profile
7
2.2
Plant and Equipment
8
2.3
Location of factory
9-11
2.3.1
Location factors
11
2.3.2
Reasons for the establishment of Larrabee Enterprises Limited
11-12
3.0
CHAPTER 3: DESCRIPTION OF THE ACTIVITIE OF LARRABBE
13-21
ENTERPRISES LIMITED
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3.1
The process technology
13
3.1.1
Raw materials for the tanning Industry
13-14
3.12
The tanning process
14-21
4.0
CHAPTER 4: ENVIRONMENTAL MANAGEMENT SCOPE, OBJECTIVES
22
AND CONTEXT 4.1
What is empirical management plan ?(EMP)
22-23
4.2
Context of this EMP
23
4.3
Objectives of EMP
23-25
4.3
Scope of this EMP
25-26
4.3.1
Environmental policy of Larrabee Enterprises Limited
26-27
4.3.2
Implementation of the EMP
27-32
4.3.3
Environmental Training Plan
32-33
4.3.4
Environmental Reporting Plan
34
4.3.4
Environmental Response
34-37
4.3.5
Checking and Corrective Action Plan
37-38
4.3.6
Contingency Plan
38
4.3.7
Safety Plan
38-40
4.3.8
Management Review Plan
40
4.3.9
Environmental Monitoring Plan
40-43
5.0
CHAPTER 5: CONCLUSION
44
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1.0 CHAPTER 1: INTRODUCTION 1.1
BACKGROUND
The increasing use of the environment and its resources without regulation manifested in among others the discharge of untreated industrial wastes in liquid, solid or gas emission has led to serious harm to humans, living organisms and plants all over the world. This EMP is for Larrabee enterprise limited which is involved in the tanning of Goat and sheep skins. Tanning of skins as seen in Larrabee industrial enterprise limited involves the conversion of animal skins into leather results in considerable quantities of several varieties of waste products and the tanning industry has the unenviable reputation of being one of the evilsmelling industries. With the location of the plant in highly urbanized area of Kano metropolis, the problem is more acute. Generally, tannery wastes can contribute to problems of health hazard by: (i)
causing depleting of oxygen in water where it is discharged, thereby removing the dissolved oxygen required by fish and other aquatic organisms for respiration
(ii)
leading to high concentration of salts and possible formation of metal sulphides which are very harmful to both human beings and animal
(iii)
causing bacteriological pollution by pathogenic organism
(iv)
Emission of foul smelling gas from sodium sulphide and decomposition of fat and other organic matter.
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Large quantity of sludge from fleshing that clog water ways
Despite the enormous environmental hazards, tanning has a long history in Kano that has impacted the economic and social life of a large number of the population. It is also a source of considerable wealth and employment. Consequent upon this realization, the national policy on environment, recognizes not only that cognizance must be taken of the various institutional settings but also the complex historical, economic, social, and cultural considerations in the identification and implementation of measures designed to solve environmental problems associated with operations such as tanning of skins by Larrabee. The provisions of the Policy have been duly adhered to in this study therefore; this environmental management plan (EMP) aims to provide a rational, coherent and comprehensive approach to the pursuit of tanning activity in Larrabee enterprises limited that is of economic and social benefit in a way that minimizes environmental damages. This EMP also, provides strategies, procedures and other concrete actions required for sustainability of the Larrabee tannery through: a. maintenance of quality of environment adequate for good health and wellbeing b. use of the environment and natural resources for the benefit of present and future generations
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c. restore, maintain and enhance the ecosystems and ecological processes essential for the functioning of the biosphere to preserve biological diversity and the principle of optimum sustainability in the use of natural resources and ecosystems d. raise awareness of all staff of Larrabee tannery and promote understanding of the essential linkages between the environment, resources and development e. encourage individual staff and the members of the nearby community to participate in environmental improvement efforts of Larrabee
1.2 LEGAL AND INSTITUTIONAL FRAME WORK The Federal Government of Nigeria established, in 1988, the Federal Environmental Protection Agency vide Decree 58 of 1988 as amended by Decree 59 of 1992 and further amended by Decree 14 of 1999, to protect, restore and preserve the ecosystems of the Federal Republic of Nigeria and establish such environmental criteria, guidelines, specifications of standards as may be necessary to protect the health and welfare of the citizens from environmental degradation. The Federal Ministry of Environment was established in 1999 to take over the responsibilities of the Federal Environmental Protection Agency.
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Some of the other policies and legislative framework that have been put in place to enhance the implementation process for environmental assessment in Nigeria include the following: • Forestry Act 1958 • Antiquities Act 1958 • Territorial Waters Decree 1967 •Oil in Navigable Waters Decree 1968 • Petroleum Decree 1969 • Quarries Decree 1969 • Sea Fisheries Decree 1971 • Land Use Decree 1978 • National Environmental Protection (Management of Solid and Hazardous Waste) Regulations 1991 • Guidelines and Standards for Environmental Pollution Control in Nigeria 1991 • Environmental Impact Assessment Decree 1992 • Water Resources Act 101 of 1993 • Minerals and Mining Act 1999 September, 2014
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At the International level, Nigeria is a signatory to a number of conventions which are related to the environment. Some of these include the following: (i) Convention on Biological Diversity 1992 (ii) Montreal Protocol on Substances that Deplete the Ozone layer. (iii) United National Framework Convention on Climate Change (Climate Change Convention), 1992 (iv)Stockholm Convention on Persistent Organic Pollutants (POPs)
1.3 OVERVIEW OF ENVIRONMENTAL LEGISLATIONS IN NIGERIA Since the return to democracy, there has been a renewed interest in environmental
management
and
protection
which
culminated
in
the
establishment of the Federal Ministry of environment and Ministries of environment at the states level in 1999. The Federal Ministry of environment Nigeria is committed to a national environmental policy that will ensure sustainable development based on proper management of the environment. This demands positive and realistic planning that balances human needs against the carrying capacity of the environment and requires that a number of complementary policies, strategies and management approaches are put in place through the National policy on the environment. The federal ministry of environment is the apex policy organ for all environmental policies in Nigeria. It ensures that all states, federal agencies as well companies September, 2014
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that operate in Nigeria comply with all extant regulations. The regulations that govern the various human activities on the environment are vested in many agencies under the ministry. The main agencies are the National Environmental Standards and Regulations Enforcement Agency (NESREA) and the National Oil Spill Detection and Response Agency (NOSDRA). The National Environmental Standards and Regulations Enforcement Agency (NESREA) was established by Act 25 of 2007. The main responsibility of (NESREA) is to ensure that all projects undertaken in Nigeria comply with all environmental laws and regulations in Nigeria. The management of Larrabee has shown environmental responsiveness and responsibility by commissioning PREPRA NIGERIA LIMITED a NESREA accredited environmental consultants to guide the company in the formulation of its Environmental Management Plan.
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2.0 CHAPTER 2: COMPANY PROFILE, LOCATION, SITE AND ENVIRONMENT 2.1 COMPANY PROFILE Table 1: Profile of Larrabee enterprises limited
The Company
LARRABEE ENTERPRISES LIMITED
RC. NO.
196655
Date of Incorporation
26/5/1992
Registered office Mailing Address
Plot 62, SHARADA INDUSTRIAL ESTATE, PHASE 111, P.O.BOX, 11344 KANO, KANO STATE.
Telephone No
234 (0) 934400 and 978446
Email
[email protected]
Ownership Structure
75% OWNED BY SHOUR FAMILY
Nature of Activity
TANNING
Installed Capacity
10,000 SKINS/DAY (WET BLUE)
Raw Materials
RAW ANIMAL SKINS, CHEMICALS AND WATER DIESEL,PETROL,LUBRICANTS, GREASE etc
Consumables Manpower:
Skilled Semi-skilled
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2.2 PLANT AND EQUIPEMENTS Table 2 Plant and Equipments of Larrabee enterprises limited.
TYPE
UNIT(Nos)
Drums
8
Paddles
9
Fleshing Machines
3
Setting out Machines
3
Shaving Machines
3
Toggle Dryers
3
Hanging lines
2
Buffing Machines
5
Rotary Staking
1
Vibrating Staking
1
Generators – 500kva, 250kva 3 and 50kva Boiler
1
Bore holes
2
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2.3 LOCATION OF FACTORY Larrabee enterprises limited’s tannery is located in Sharada Industrial estate phase 111, Kano, the most important and largest center of manufacturing activity in Northern Nigeria. The location of the Industrial estate within Kano metropolis is shown in Figure 1.
Figure 1 :
Location of Sharada Industrial Estate within Kano metropolis
The factory is sited between latitude 110. 56` 457and longitude 80. 29` 049. Based on the coordinates, the exact position of the factory is shown in Plate 1 as extracted from Google earth. The site of the land in which the factory is located consists of two plots of land covered by C of O No. LKN/1ND/82/36 covering an
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area of 0.735 hectares and C of O No LKN/IND/82/3 covering 0.733 hectares, thus the factory occupies a total area of 1.468 hectares. More 70% of the area of the factory is built up. All structures on the premises have been approved by Kano urban planning development authority (KNUPDA).
Plate 1: Location of Laraabee factory from Google earth The factory site is very firm, relatively level and well drained. Larrabee enterprises limited is bounded by Gongoni Industrial Enterprises, to the east, to the west by Dangote flour mills, to the north by Sani Brothers Wire industries and to the south by Northern plastics. The factory is located about 45 meters off- the main trunk A road that links Kano city with Challawa Industrial estate as seen in Plate1. Across the trunk C road are Angel spinning as well as loquat tannery, thus Larrabee is located in the heart of the industrial landscape of sharada industrial estate. It is September, 2014
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also located a few meters from the main rail line that connects Kano to the south is at the eastern part of the factory making it very accessible.
2.3.1 LOCATION FACTORS Kano enjoys significant advantages required for operating a tanning enterprise. These advantages include: Availability of Raw Materials: The main raw material which is raw skin is highly abundant. Market Prospects: Kano is known for its traditional leather and is famous in the tanning sub-sector with international reputation. The bulk of leathers produced in Kano are exported to Europe and Asia. Also, the artisanal producers convert finished leather for domestic finished leather goods markets. Supply of Labor: Kano state has abundant supply of skilled labor in the Tanning sector. This is obvious as commercial production for leather and leather products existed for many years in Kano.
Infrastructural
Facilities: The factory is located within an Industrial Estate. The site is serviced by mains of electricity, water, telephone services and good network of tarred and un-tarred roads. 2.3.2 REASONS FOR THE ESTABLISHMENT OF LERRABEE Leather and leather products are among the most widely traded and universally used commodities in the world. Already, the total value of annual trade is estimated at 1.5 times the value of the meat trade, more than five times that of coffee and more than eight times that of rice. In Nigeria, according to the Federal Ministry of Industry, Trade and Investment, leather has overtaken September, 2014
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Cocoa as the second biggest foreign exchange earner for the country. A study by Chemonics International Inc. prepared for the United States Agency for International Development (USAID) in 2012 disclosed that Nigeria’s huge leather industry export worth $43.4 billion is begging for investors. According to the Report filed by Business Day, the industry is believed to be worth about $4.4 Billion for raw hides and skins, $14 billion in rough-tanned and finished leathers of all types and $25 billion for footwear with leather uppers. This indicates high exports potentials from the products. However, according to FAO current production in Nigeria is still less than 40% of the potentials that exist in the tanning sector. The aforementioned facts informed the decision of the Shareholders of Larrabee enterprises limited to launch themselves into the leather processing business.
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3.0 CHAPTER 3: DESCRIPTION OF THE ACTIVITIES OF LARRABEE ENTERPRISES 3.1 The Process Technology Tanning is the process of treating animal’s skins to produce leather, which is more durable and less susceptible to decomposition. A tannery is the term for a place where the skins of animals are processed. It can be performed with either vegetable or mineral methods. 3.1.1RAW MATERIALS FOR THE TANNING INDUSTRY
Animal skins
a) Wet – salted Goat skins b) Wet – salted Sheep skins
Chemicals
a) Sodium chloride b) Sodium sulphide c) Chrome d) Sulfuric Acid e) Ammonium sulphate f) Caustic soda g) Soda Ash h) Ammonium liquor i) Dyes
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j) Bactericides k) Fungicides l) Formic Acid m) Enzymes n) Syntans o) Synthetic oils p) Vegetable oils q) Lacquers r) Pigments s) Binders (acrylic and non-acrylic) 3.1.2 The tanning process The first stage of the leather production begins with the collection and sorting of raw skins – normally supplied by designated agents to the companies warehouse. Plate 2 shows sorted raw sheep skins in the company’s warehouse Tanning involves four stages as indicated below: Preparatory Steps Prior to Tanning
Curing
Preparing the skins begins by curing them with salt. Thus the skins form the abattoirs are wet-salted before being transported to the company. Curing is employed to prevent putrefaction of the protein substance [collagen] from September, 2014
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bacterial growth during the time lag that might occur from procuring the skins to when it is processed. Curing removes excess water from the skins using a difference in osmotic pressure. The moisture content of skin is greatly reduced. In wet- salting, skins are heavily salted, then pressed into packs for about 30 days. In brine-curing, the skins are agitated in a salt water bath for about 16 hours. Generally, curing substantially reduces the chance of spoilage by bacteria. Curing can also be done by preserving the skins at a very low temperature. In Nigeria the only form of curing is wet-salting.
Plate 2: Wet – salted raw skins in the ware house of Larrabee
Beam-house operations
The steps in the production of leather between curing and tanning are collectively referred to as beam-house operations. They include: soaking
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liming, removal of extraneous tissues (un-hairing, scudding, and fleshing), deliming, bating, drenching and picking.
Plate 3: Soaking in Paddles for un-hairing at Larrabee
Plate :4 Beam house of Larrabee (Drums used for liming, tanning and Retanning)
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Soaking In the process known as soaking, the hides are soaked in clean water to remove the salt left over from curing and increase the moisture so that the hide or skin can be further treated.
Plate 5: Fleshing operation at Larrabee Liming After soaking, the hides and skins are taken for liming which is a treatment that involves the addition of sharpening agents like sodium sulfide, cyanides, amines etc. The objectives of this operation are mainly to: o Remove the hairs, nails and other keratinous matter. o Remove some of the inter-fibrillary soluble proteins like mucins. o Swell and split up the fibers to the desired extent. o Remove the natural grease and fats to some extent o Bring the collagen in the hide to a proper condition for satisfactory tannage. September, 2014
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The weakening of the hair on the breakdown of the disulfide link of the amino acid is called cystine, which is the characteristic of the ketarin class of protein that gives strength to hair and wools (ketarin makes up 90% of the dry weight hair). The hydrogen atoms supplied by the sharpening agent weaken the cystine. To some extent, sharpening also contributes to unhairing as it tends to break down the hair protein. De-liming and Bating The pH of the collagen is brought down to a lower level so that enzymes may act on it in a process called de-liming. Depending on the end use of the leather, skins may be treated with enzymes to soften them, a process called bating. Pickling Once bating is completed, the hides and skins are treated with a mixture of common table salt and sulfuric acid, in a case a mineral tanning is to be done. This is done to bring down pH of collagen to a very low level so as to facilitate the penetration of mineral tanning agent into the substance. This process is called picking. The common salt penetrates the skins twice as fast as the acid and checks the ill effect of sudden drop of pH. The pH is very acidic when the chromium is introduced to ensure that the chromium complexes are small enough to fit between the fibers and residues of the collagen. Once the desired level of penetration of chrome into substance is
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achieved, the pH of the mineral is raised again to facilitate the process. This step is known as Basification. In the raw state chrome tanned skins are blue in appearance and are therefore referred to as Wet Blue. Chemicals used in tanning include chrome, salts, sulfuric acid, ammonium sulphate and bactericides.
Plate 6: Wet blue being piled in Larrabee Iii Retanning The wet blue is selected and shaved to specified thickness often determined by the final product to be used and subsequently moved back to the drum for re-tanning. Re-tanning is the process of using oils and vegetable extract to convert the skin into leather. September, 2014
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The re-tanned leather is referred to as crust and it is often colored depending on the requirement. The crust is now complete leather and can be finished to various formats by the spray of pigments and lacquers.
Plate 7: Crust drying line (dyed black) in Larrabee Chemicals used in re-tanning includes, dyes, formic and sulfuric acids, fatliqours and Syntans For finishing the main chemicals are binders of different make ie acrylic and non-acrylic, pigments and lacquers The stages can be summarized as follows:Preparation for Tanning => Tanning => Re-tanning => Finishing
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In addition to skins and chemicals other materials that are required in a tannery like Larrabee include water, lubricants, fuel, diesel, packaging materials and auxiliary facilities such as power supply etc.
Plate 8: Diesel storage tank in Larrabee
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CHAPTER 4: ENVIRONMENTAL MANAGEMENT SCOPE, OBJECTIVES AND CONTEXT 4.1 WHAT IS ENVIRONMENTAL MANAGEMENT PLAN (EMP) An environmental management plan (EMP) is a site specific plan developed for a project to ensure that all necessary measures are identified and implemented in order to protect the environment from the potential negative impact of the operation of the project and comply with environmental legislation and regulations. The EMP provides answers to the following question in respect of the operation of Larrabee i) What are the likely environmental issues associated with the operation? ii) What are the likely harmful consequences to the environment from the identified issues? iii) How can the identified issues be managed to minimize harm to the environment? The main components of an EMP are:
summary of the potential impacts of the proposal
description of the recommended mitigation measures
statement of their compliance with relevant standards
allocation of resources and responsibilities for plan implementation
schedule of the actions to be taken
programme for surveillance, monitoring and auditing
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contingency plan when impacts are greater than expected
4.2 CONTEXT OF THIS EMP
This Environmental management plan is in respect of Larrabee enterprises limited which is a manufacturing enterprise involved in the tanning of goat and sheep skins in sharada industrial estate Kano. The factory is sited within an area demarcated for medium to heavy industrial operation. The factory covers an area about 1.468 hectares of land. In Nigeria, Environmental management plan (EMP) must be carried out by all industrial enterprises. The Federal Ministry of Environment of Nigeria has laid down procedures for conducting the environmental management plan and enforces the Decree No. 86 of 1992, through the National Environmental Standards and Regulations Enforcement Agency (NESREA) which sets out the requirements, procedures and methods for conducting such
exercises.
Specifically,
the
National
Environmental
pollution
abatement in industries and facilities generating wastes S.1.9 regulation of 1991 and 2011 is applicable to this project. The EMP is strictly prepared to comply with the regulations. 4.3 OBJECTIVES OF EMP An effective EMP is designed to achieve the following: September, 2014
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Ensure the progressive reduction of the potential impact of the production process on the environment
ii)
Ensure that all mitigation measures prescribed for eliminating or minimizing the impact of production process are fully implemented
iii)
Provide part of the basis and standards needed for overall planning, monitoring, auditing and review of environmental performance throughout the life cycle of Larrabee tannery
iv)
Provide planning tool to promote sustainable development by integrating environmental considerations into the production process
v)
Provide a tool to evaluate the production process
vi)
To mainstream the factory operation to Principle 17 of the Rio Declaration on Environment and Development. The above objectives shall be achieved by taking the following measures:
Ensuring that all stipulated legislations on the protection of the environment are adequately complied with
Ensuring that environmental concerns are adequately incorporated into the operation of the factory
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Justifying existing environmental activities to enhance efficiency and effectiveness
Ensuring that only environmentally approved procedures should be employed at all times
4.3 SCOPE OF THIS EMP Larrabee Enterprises limited is desirous and committed to environmental protection from the potential negative impacts of its operations. In order to comply with guidelines specifically, the National Environmental pollution abatement in industries and facilities generating wastes S.1.9 regulation of 1991 and 2011 and all related extant laws, a preliminary environmental assessment was undertaken in order assess the range and significant environmental hazards of the production processes as well as the staff and other stakeholders directly impacted by the operation. After the assessment, a comprehensive report was made which will be implemented through the following plans: 1) Development of a company environmental policy 2) Environmental Management Implementation plan 3) Environmental Monitoring plan 4) Contingency plan September, 2014
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5) Safety plan 6) Risk assessment and Emergency response plan 7) Environmental management plan review 8) Reporting plan 4.3.1 ENVIRONMENTAL POLICY OF LARRABEE ENTERPRISES LIMITED The realization of the legal requirement to protect the environmental as well as the consciousness of the company to protect the health of its employees as well as the community in its vicinity led the company to initiate a company – community relation in order to come up with an enduring environmental policy. To ensure the actualization, the company engaged a NESREA accredited environmental consultant Messr- PREPRA NIGERIA LIMITED to lead the committee and come up with an environmental policy. In order to arrive at a consensus on the core environmental values of Larrabee, several stakeholder meetings were undertaken with all staff, first, at the unit level and later at the plant level. Focus group discussions were also undertaken in order to create awareness and sensitize all level of the staff to put environment and specifically efficient resource use as part of the day to day production process. The same approach was undertaken at the community level. The result of these consultation resulted in the adoption of an environmental policy by Larrabee enterprise limited with the vision and mission as :
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Vision ------ to be a producer of high quality leather products with an enduring comitement to preserving and protecting the environment ----------Mission -------- protecting and preserving the environment for future generation through commitment to training, creating awareness to staff and community and deploying the best technologies at all times to meet the challenges of a great changing world --------------The main objectives of the environmental policy adopted by Larrabee are: i) To maximize resource utilization and reduce waste ii) Fully comply with all applicable environmental protection regulations iii) Minimize damage to the environments from its operation iv)To use the best technology at all times 4.3.2 IMPLEMENTATION OF THE EMP Due to increasing legal and social pressures, Larrabee is expected to comply with all the principles of environmental protection. Larrabee will ensure that the operation of its plant is integrated harmoniously into the host environment and that its operation will provide an opportunity to actively help in the development of the area.
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Because liquid effluent forms a great proportion of the waste generated and to comply fully with the legal requirement to have a primary treatment plant, Larrabee enterprises established a waste water primary treatment plant with the waste water collection pond shown in Plate 9
Plate 9 Waste water holding tank in Larrabee Larrabee will establish an environmental and social monitoring unit that will ensure implementation of the environmental management plan. The unit shall be led by a project manager and consisting of staff members of Larrabee enterprise limited and a representation of the community. The unit will be September, 2014
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responsible for ensuring that the overall environmental targets are achieved and that the environmental responsibilities and obligation of the EMP is satisfied during operation of the factory. Also the unit will coordinate the day-to-day monitoring of regulatory bodies. There shall be 2- way communications to initiate the flow of environmental information among members of the unit. The communication shall be achieved through meeting, environmental briefing, spot inspection and environmental awareness activities. The community representative will act as a liaison between the unit and all affected communities; they shall carry all affected communities along on the implementation of the factory. As a practical demonstration of compliance to environmental regulation and care to the health and well-being of staff, Larrabee will make it mandatory for all staff to wear protective clothing at all times based on the recommendations of NESREA as specified in Table 3. Bold signs will be put in strategic location of the factory to illustrate the need for proffer clothing and the dangers of not being in appropriate clothing.
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Table 3: NESREA Recommended Personnel Protective Equipments by hazard type Objective
Workplace Hazard
Suggested PPE
Eye and face protection
Flying particles, molten metal, liquid chemicals, gases or vapours, light radiation
Safety glasses with side shields, protective shades, etc.
Head protection
Falling objects, inadequate height clearance and overhead power cords
Plastic helmets with top and side impact protection
Hearing protection
Noise, ultra-sound
Hearing protectors(ear plugs or ear muffs)
Foot protection
Falling or rolling objects, pointed objects. Corrosive or hot liquids
Safety shoes and boots for protective against moving and falling objects, liquids and chemicals
Hand protection
Hazardous materials, cut or laceration, vibrations, extreme temperature
Gloves made of rubber or synthetic materials(Neoprene), leather, steel, insulating material, etc
Respiratory protection
Dust, fogs, fumes, mist, gases, smoke, vapor
Facemasks with appropriate filters for dust removal and air purification (chemicals, masts, vapors and gases). Single or multi-gas personal monitors, if Available
Body/leg protection
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Oxygen deficiency
Portable or supplied air (fixed lines). On site rescue equipment
Extreme temperatures, hazardous materials, biological agents, cutting and laceration
Insulating clothing, body suits, aprons etc of appropriate materials
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The environmental consultant shall monitor the implementation of the Environmental Management plan through regular visit and providing periodic reports to the unit and to regulatory agencies The implementation will be ensured based on the schedule in Figure 2
Figure 2: Communication channels and Responsibilities in Larrabee
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To ensure smooth implementation of the EMP environmental, the following plans are put in place; i)
Environmental Reporting
ii)
Staff training Plan
iii)
Emergency Response Plan
iv)
Checking
v)
Emergency Response plan
vi)
Contingency plan
vii)
Safety plan
viii)
Review
ix)
Environmental monitoring plan
4.3.3 ENVIRONMENTAL TRAINING PLAN The environmental training plan will include General staff awareness induction Familiarization with the EMP Requirement Environmental emergency response training Familiarization with the operation of environmental controls The details of the environmental training are shown in Table 4. September, 2014
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Table 4: Training Programme - Summary of Training Needs of Larrabee Training topic
Summary of training Recipients(staff purpose and content and/or contractor
Targeted date
Induction of EMP
Overview of All EMP including contractor operation information, pollution risk and controls and programme & system
Refresher to EMP
Refresher overview EMP
Detail of activity ETP Staff or area specific risks & control;
Overview air, noise waste water treatment process precautionary measures & maintenance program
Identification of Field officers & c ASAP on-site assistance environmentally hazards that require rapid response
Cleaner method
production
Emergency response training
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All staff
staff/ At the beginning of employment contract
After one year
of From September 2014
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4.3.4 ENVIRONMENTAL REPORTING In order to comply with statutory regulations, statutory reports will be compiled and submitted as at when due to the relevant agencies. Table 5 shows the needed documentation required as well as the areas to submit. Table 5 Reporting Plan - Process Summary Documents EMP
Submitted to
By who
NESREA NWZ NESREA office, NESREA Accredited Headquarters consultant
Kano State Ministry of NESREA Accredited Environment consultant
Date/Frequency September, 2014
September, 2014
4.3.4 EMERGENCY RESPONSE A key requirement in the operation of the EMP is to have an emergency response plan. The procedure in emergency response for Larrabee is set out in table 6
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Table 6: Emergency Response Risk identification
Air quality related risk
Water related
Terrorist Attack
Implementation control required
Monitoring P.M to ensure it is within the acceptable limits.
Excess above limit should be reported
Monitoring P.M to ensure it is within the acceptable limits
Excess should be reported
Be alert and HE keep aware of your surrounding Heed your instincts. If you feel that something isn't right, leave.
September, 2014
Authoriza tion
Contact
Time frame
07032136093
ASAP
08096245530
07032136093
ASAP
08096245530
08133934328
ASAP
08144596237 08085007650
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inform a police officer or security personnel. Blockage Drainage
of
Accident in the plant
Explosion
September, 2014
Main
Use alternative route
HM
08036193736 08051348668 08016129278
Report to PM Karota or Road safety or Police or Fire service
08133934328
Take cover HE away from area as soon as possible.
08036193736
If you are trapped in debris, cover your mouth with a handkerchi ef or clothing to avoid dust inhalation.
Signal to rescue workers to let them know where you are.
Use a flashlight, whistle, or knock on a
ASAP
ASAP
08144596237 08085007650 ASAP
08051348668 08016129278
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pipe or wall.
Other unexpected emergency
Refrain from shouting if possible, as this may result in dust inhalation.
If your surrounding are on fire, keep low to the ground,
cover your mouth and nose with a (preferably) wet cloth, and get out of the area by the safest route possible as quickly as you can.
Discretion and best possible practice.
HE
08036193736
ASAP
08051348668 08016129278
4.3.5 CHECKING AND CORRECTIVE ACTION In order to ensure that this environmental management plan is adhered by all, there will be a verification of the implementation by a committee on environment to include stakeholders. The committee shall meet regularly and
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report to the factory manager and consultant on quarterly basis for evaluation and continuous improvement in meeting the objectives. 4.3.6 CONTINGENCY PLAN The operation of larrabee enterprise limited has considered relevant standards, codes, specification, maintenance doctrines as well as community issues. Nevertheless, notwithstanding these measures, accidents may occur due to equipment failure, negligence, sabotage, and natural catastrophes. Measures are put in place to handle the situation. The essential elements of the contingency plan include early warning, activation of plan, evacuation procedure, provision of first aid facilities and training of first aid officers 4.3.7 SAFETY PLAN Accident prevention is a major responsibility of management. The creation of a safe work environment and initiation of a safety-minded efficient operation are the economic, legal and moral obligation of Larrabbe enterprise limited. Enforcement of the safety rules, procedures and codes is also the responsibility of Larrabbe enterprises limited. The safety procedure that is provided covers the following Management Leadership: The safety programme shall have the support of the management and shall be an integral part of the plant operation. September, 2014
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Responsibility Assignment: Responsibility to provide guidance and direction in the enforcement of compliance of staff with safety codes of larrabee shall be assigned to safety officer. Work Condition: Periodic inspection shall be conducted with detail records being kept to determine top priority hazardous conditions that require management Training programme: A safety training programme that will ensure regular training to keep abreast all staff on environmental issues and work efficiency shall be organized In line with the objectives of safety programme the following training programme shall be implemented a) Basic first aid programme( all staff) b) Advanced first aid programme (selected staff) c) Accident investigation and reporting seminars (supervisory and safety officer) The basic first aid programme shall be extended to all employees and would be geared to ensure that in the event of an accident or injury, someone with first aid knowledge shall always be present to render initial assistance until further medical attention can be available. Qualified personnel shall run seminars to impart the necessary theoretical as well as practical skills required. The advanced first aid programme shall constitute an upgrading course from the September, 2014
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basic first aid in which selected staff including supervisors and safety officer will be exposed to higher knowledge and techniques that will enable them to recognize and assist in the initial management of serious injuries and illnesses e.g spinal injuries, fractures etc. Accident Record: Records of accidents should be kept indicating details of the accident, nature, extent of injury/damage and location within the factory. The point/officer who received the accident report should be indicated as well as the person who made the report. The way the accident is handled should always be indicated. The data on accident is crucial for future plan and redesigning of the processes as well as the work schedule and training. 4.3.8 MANAGEMENT REVIEW Routine management review will be conducted using a checklist to ensure full implementation of the plan. 4.3.9 ENVIRONMENTAL MONITORING PLAN Both international and Nigeria’s environmental guidelines and standards require environmental monitoring for EMP. The primary aim of monitoring is to provide information that will aid impact management, and, secondarily, to achieve a better understanding of cause-effect relationships and to improve prediction and mitigation methods. Monitoring is used to: September, 2014
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establish baseline trends and conditions
measure the impacts that occur during project construction and operation
check their compliance with agreed conditions and standards
facilitate impact management, e.g. by warning of unanticipated impacts
Determine the accuracy of impact predictions and the effectiveness of mitigation measures. A sound baseline is a critical reference point for the conduct of monitoring, as, monitoring establishes the basis for corrective action when actual impacts are unanticipated or worse than predicted. Compliance monitoring, carried out through repetitive or periodic measurement, may suffice as a safety net for the factory. However, compliance monitoring will trigger impact management only if regulatory standards or specified conditions are exceeded. By themselves, compliance and effects monitoring permit only reactive impact management, since they detect violations or adverse changes after the fact. In this context, it is important to tie the results of both types of monitoring to predetermined actions (or emergency responses), which are triggered on a threshold basis. A more proactive, adaptive approach to impact management can be instituted by combining compliance or effects monitoring with supervision or regular inspection. The use of the precautionary principle can facilitate early warning of emerging problems.
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The monitoring data needs to be targeted at the information necessary to manage the impacts that are significant or review the aspects of practice that are of particular importance. These aspects should be identified early to optimize the contribution of monitoring data to EMP implementation and follow up. The following points need to be agreed as part of the EMP monitoring :
major impacts to be monitored
objectives of monitoring and data requirements
arrangements for the conduct of monitoring
use of the information to be collected
response to unanticipated or greater than predicted impacts
measures for public reporting and involvement Monitoring requirements should focus on the significant impacts predicted taking account of:
the environmental values to be safeguarded
the magnitude of each potential impact
the risk or probability of each impact occurring
the pathways and boundaries of each impact
the confidence in the prediction of each impact.
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Monitoring programmes need to be constantly reviewed to make sure that relevant information is being supplied, and to identify the time at which they can be stopped. The environmental monitoring plan shall be an integral part of running the plant and is expected to generate the requisite information dissemination. The plan shall play a pivot in ensuring that trends for specific parameters are traced and also will provide information on compliance with legislations norms, guidelines or desirable operational limits and form the basis for corrective and modifications if necessary. Essentially the main objectives of the monitoring plan includes 1) Ensuring that legal standards for the environmental parameters are not exceeded 2) Checking that mitigation measures are implemented 3) Providing early warning of environmental damage so that actions may be taken and if possible to prevent or reduce the seriousness of the unwanted impact
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CHAPTER 5: CONCLUSION The environmental management plan (EMP) was carried out with strict adherence to the guidelines and regulation of the National Environmental Standards Regulations Enforcement Agency (NESREA). The operation of Larrabee tannery will result in short and long term adverse impact to the environment as well as nuisance to the community. Mitigation measures have been proffered to reduce the adverse effects that might arise from the operation of Larrabee. Communities shall be carried along during the operation and implementation of this EMP.
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