The water law framework in our country is attributed by the coexistence of a number of different principles, rules and acts adopted over several decades extending from common law principles and irrigation acts from the colonial acts to the recent regulation of water quality and pollution. The basic underlying reasons for water law reforms are both physical and institutional. Over the past few decades water has gradually become sparse in many parts of the country. This can be attributed to increased pollution of finite water resources and also increased use of water by all categories of water users as a consequence of economic and population growth.
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The Water Act of 1974 was India’s first attempt towards dealing comprehensively with the environment related issues. Water is a subject in the State List under the Constitution. Consequently, the Water Act which is a central law came into being under Article 252(I) of the Constitution which empowers the Union Government to make laws in a field reserved for states. All the states have approved the implementation of Water Act 1974. In spite of this there is a lack of umbrella legislation at the national level because of which different state and central legal interventions do not coincide often.
Water Prevention And Control Of Pollution Act, 1974 Salient Features
The Water Act establishes a Central and State pollution control boards. The Central Board may advise the Central Govt. on water pollution issues, coordinate the activities of state pollution control boards and devise a comprehensive plan for the control and prevention of water pollution. In case of any conflicts between the Central and the State boards, central board prevails.
This act is applicable to streams, inland waters, subterranean waters, and sea or tidal waters. Standards for the discharge of effluent or the quality of the used water being released into the water sources are to be prescribed by the state boards.
Any person or any industry for that matter has to take the consent of the state board before proceeding towards establishing any industry, operation or process or any treatment or waste disposal system.
The Act specifies other important functions of the state boards as follows:
Devising a comprehensive programme for prevention, control and abatement of water pollution in respective states
Encouraging, conducting, and participating in investigations and research of water pollution problems
Inspecting facilities for sewage and developing economical and reliable methods of its treatment
State board in its capacity may take emergency measures if it foresees accidents or events that might pollute the water bodies. These measures include activities like removing the pollutants, alleviating the damage and issuing orders to the polluter prohibiting effluent discharges.
Under section 33A state boards can issue directions to any person, office or authority, including orders to close, prohibit or regulate any industry, operation or process and to stop or regulate the supply of water, electricity or any other service.
Not complying with a court order under section 33 or a direction from the board under section 33A is punishable by fines and imprisonment as per section 41.
In order to assist the Water Act, the Water Pollution Board constituted under the Pollution Act, has been empowered under the Cess Act to levy a cess/tax for meeting the financial requirements for its working. This cess is for the purposes and utilization under the Water Act. The Cess Act grants a rebate in the cess payable to those who install a plant for the treatment of sewage or effluents. This is one of the steps to encourage establishments to set up effluent treatment plants and process the effluents before releasing them. However it is to be noted that Cess Act cannot be deciphered individually and should be taken into consideration only in relation with the Water Act.
While it is quite evident that water laws are the need of the hour but these water law reforms can only contribute to solving water management issues but fail to solve issues related to human rights, social, environmental and health aspects of water.
The textile industry in India mainly depends upon exports and manufacturing. Export income from textiles account for around 30% of India’s export revenues and 3% of India’s Gross domestic product. This industry has grown a lot over the past few years especially after the economic liberalization in 1991 where the country was opened to free trade under the auspices of Dr Manmohan Singh.
The table below gives the major strength and weaknesses of the textile industry in the country
Increased global competition
Efficient production facilities
Huge Decentralized sector
Large domestic markets
High production costs
Large Export Potential
Poor Supply chain management
Flexible manufacturing Systems
To grow at a rate of around 15% in the coming years the sector needs to keep in mind the following points which shall go a long way in ensuring that growth is maintained at healthy rate and is also sustainable.
Threat of competition in Domestic Market
Ecological and Social Awareness
Ecological and social awareness are going to play a huge role in determining who is going to reap profits in a sustainable manner keeping in view the sensitivity of the stakeholders who are most of the times the losers when large scale development takes place.
The industry is likely to face pressure from the media, the Government and the common people to follow international norms and regulations which shall prohibit it from using natural resources like Water which is a key ingredient in producing textiles. The way this industry uses water and how much it pollutes the various sources shall be determined by external factors.
Developed markets have extremely high standards of consumer consciousness on issues such as polluting Dyes, Usage of Child Labor, Unhealthy working conditions of the mill workers etc. Standards like SA 8000 have now been started to get implemented in the industry at a large scale. This has also led to pressure on companies to limit sourcing from countries which violate the practices mandated under the norms of SA 8000. The Indian industry needs to improve its working practices and the fallout of the new international developments in this particular area. In such a scenario large players can take advantage of this and indulge in practices which promote sustainability. Proper water Use by textile mills and recycling and purifying water and then reusing it for industrial purposes can also serve the purpose in the long run.
Textile Industry and water Pollution
Textile Industry is one of the most polluting industries in the country and in terms of consumption of water it constitutes around 3.2% of total consumption of water for various processes like scouring, sizing, and bleaching, dying and other associated processes. It is one of the most growing sectors in the Indian economy in terms of its contribution to the total GDP of the country.
Water pollution is done by each and every process in the whole manufacturing of textiles, The table below gives an exhaustive list of the various processes and the nature of effluents and pollutants which are released as a result of the above.
Nature of Effluents
Starch, Glucose, Resins, Fats and Waxes
High Biochemical oxygen demand
Caustic Soda, Wax, Grease, Soda Ash, Sodium Sillicate
Strongly Alkaline, High Biochemical oxygen Demand
Hypochlorite, Caustic soda, Hydrogen peroxide and acids
Low biochemical oxygen demand and strongly alkaline
Strongly alkaline, low biochemical oxygen demand
Reducing agents like sulphides, acetic acids and soaps
Fairly high biochemical oxygen demand ,strongly colored
Dyes, starch, gums oil, china clay, mordants, acids and salts
Faily high biochemical oxygen demand, Oily appearance
Special finishes, starch, salts, tallow
Low Biochemical oxygen demand, less alkaline
The polluted water is very harmful for human beings living in and around the area where the pollution takes place as the turbidity of the water is very high and toxic elements present in the water which have a detrimental effect on humans and animals make such water unfit for consumption. The stakeholders which reside alongside areas which are affected by this menace face severe health hazards and face decrease and productivity and life span as a result of the above.
Effects on Aquatic Life and Other living creatures
High PH levels in water makes it alkaline, alkaline water is not fit for aquatic creatures like fishes and it also causes incrustation in sewers and may also damage crops by hampering their natural growth rate.
Spoiling the natural color of water hampers the passage of sunlight and thus prevents photosynthesis in the aquatic plants and other marine life existing inside water.
The effluents and oils present in the pollutants which are passed into water increase the turbidity of water and gives it a bad appearance and foul smell. Oily scum interferes with the oxygen transfer and colloidal matter clog the pores of soil.
High levels of dissolved solids are detrimental to sewers as it causes incrustation in sewers. High level of sodium is also harmful to crops.
Dissolved oxygen in water is an essential element in marine life and therefore the amount of oxygen required to correct the effluent is expressed in the form of biochemical oxygen demand or BOD.
Steps to curb Water Pollution
To curb pollution due to these textile mills in the areas around them the following measures can be taken in order to increase measures leading to long term sustainability as a corporate strategy which is wholly aligned to the business goals of being profitable in the long run and acquire market share in the future.
Reduction in waste water volume: The water used in processing of textiles is reduced to a considerable extent such that the effluent concentration is limited to a specified small volume of water and it does not start impacting larger volume of water.
Counter flow processing
Water re-use technique which uses the same water before discharging it into the water body so that effluent concentration is limited to a small volume and more water is saved in the process.
Reduction of process chemicals: The process chemicals create more than 90% of the pollution in textile industries. This also brings down the production cost in terms of the chemicals used. It can be achieved through reusing various chemicals when processes are completed. For Example: Caustic soda is recovered from the mercerizing and sourcing and is consequently filtered and dialyzed so that it can be reused.
Process modification would involve slight modifications in the various processes used during manufacturing in order to create lesser pollution and reduces unnecessary wastage of water. Certain alternate chemicals can also be used during manufacturing so that recovering those chemicals become easy and it thus can be used in further manufacturing processes.
Pre-Release Stage Water Treatment
Before water is released into the nearest water body it is essential that it is treated properly in order to ensure that there is significant reduction in the level of pollutants in water before it gets released into the water body.
The following steps are necessary in order to ensure proper water condition before release into the nearest river or stream or lake.
Primary Treatment: It involves concepts of removal of suspended solids by sedimentation, floatation or coagulation techniques using alum and electrolyte.
Secondary Treatment: This involves oxidation of organic matter by aeration either by chemical of biological methods or by both. This is done in presence of micro organisms in presence of chemicals such as Urea. Pollutants resistant to biodegradation such as detergents and petrochemicals are removed by non biological means and are again treated with bleaching powder before releasing them into the water body.
Tertiary Treatments: Tertiary treatment contains of three main methods like
Chemical Coagulation which involves a mixing tank with the effluent and the coagulant mixed and its PH adjusted to an optimum level. The resultant coagulated material is separated by sedimentation or flocculation.
Carbon absorption Technique which is effective in removing pigments and dyes using carbon which is activated and has large surface area.
Reverse osmosis where cellulose acetate is used to create a semi permeable membrane and subjected to pressure which is usually greater than the osmotic pressure of the effluent. This process can remove 95% of the dissolved solid content as the solution passes from area of higher concentration to lower concentration.
Now to discuss the applicability of these methods to curb water pollution in Textile industry and also to do the cost benefit analysis of the same we shall discuss a relevant case of Tiruppur Textile Industry.
Case discussion: Tiruppur Textile Industry
South Asia lately has become the hub of Industrialisation and the unchecked growth is leading to severe environmental problems. Industries have sprung up as clusters which is why the issue of environmental pollution becomes even more relevant in highly water polluting industries like textile dyeing, leather tanning, paper and pulp processing, sugar manufacturing, etc. The runoff released by these industries leads to contamination of surface and ground water sources and eventually impacts the livelihood of the poor. In a usual scenario, the above mentioned industrial units function at a small or medium scale, are a huge employment opportunity for the locals and have the potential to generate foreign exchange because all these industries are export oriented and more than half of their produce is shipped abroad. Given the vast coverage of these industries, the pollution control mechanisms have been awfully weak in these units. The pollution control authorities have been lenient in implementing the law and ensuring prevention of water pollution caused due to these industries mainly considering the socio economic benefits that they provide and also the low financial capacity of the small scale units. It is a huge capital investment for the relatively smaller industrial units to set up effluent treatment plants and the return on investment is very low. Since they provide employment, therefore these agencies have not tightened the noose on them. This stance of the Pollution Control Boards further discouraged the polluting industries to formulate and implement pollution management and reduction strategies either by efficient effluent treatment or process changes by adopting newer and cleaner technologies. In this report we have attempted to analyse the environmental impact of the production process followed in a textile unit with reference to Tiruppur, a major textile cluster in South India. A cost benefit analysis of the implementation of cleaner production processes and setting up of treatment plants has also been done to depict the return on investment for these textile units.
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Textile Industry And Its Benefits
Tiruppur, located in Tamil Nadu, is a leading cotton knitwear industrial hub in South India. The industrial activities have experienced a rapid growth during the last two decades due to decentralization and flexibility. At this point of time more than 9000 small-scale textile related units are operating with a volume of investment more than US $ 200 million. The city of Tiruppur contributes 56% of the total cotton knitwear exports from India. The industry provides socio-economic benefits to the local community and to the nation in the form of employment, income, and foreign exchange. More than 2 lakh people are directly employed by this industry. The export value from Tiruppur during the year 2002 was about US $ 957.5 million. An equal amount is sold in the domestic market. The economic opulence of Tiruppur on this industry and the local community is employed either directly or indirectly in this industry in one way or the other.
Textile Process And Pollution
The textile manufacturing process on the whole is a polluting activity with the major contributors being the bleaching and dyeing (textile processing).During 1981, in Tiruppur , only around 70 textile units were operating. This number drastically rose to 450 ten years later and further to 866 in 1997. With due credit to efforts of the Tamil Nadu Pollution Control Board (TNPCB) against the release of untreated effluents some units had to be shut down because of non-conformity to the pollution prevention standards in the state. In 2004 there were a total of 702 textile processing units functioning in Tiruppur. These units together used around 85 million litres per day (mld) of water and discharged a similar quantity (83 mld) as effluents, which are laced with a significant volume of chemicals used at the “wet processing stage”. The point worth noting here is that the amount of water used as input is almost same as the amount of water that is released in the water bodies which actually means that if there is a possibility to treat the effluents, the resultant residual water can be used as a recycled input and thus costs can be decreased. These units collectively produced a quantity of 15,000 tonnes of cloth per month. The incessant release of untreated effluents for more than 10 years has resulted in accumulation of harmful suspended and dissolved solids in the soil, ground water, etc. at Tiruppur and surroundings. During 1980 to 2000, the cumulative pollution load discharged by the Tiruppur units is as follows:
Total Dissolved Solids(TDS) : 2.35 million tonnes
Sulphate: 0.13 mt
Total Suspended Solids: 0.098 mt
Chemical Oxygen Demand: 0.09mt
Biological Oxygen Demand: 0.03 mt
Oil and Grease: 0.001mt
Impact of Textile Effluents On The Environment
From the research conducted on water pollution in Tiruppur area, it is clearly evident that the accumulation of chemicals had added to the woes. All ground water studies showed that open wells and bore wells in and around Tiruppur exhibited high levels of TDS (ranging from 3000mg/l to 11,000 mg/l) and Chloride (ranging from 2000 mg/l to 5000 mg/l) due to industrial pollution and these values were much higher than the background level for this region. The available groundwater in this region was rendered unsuitable for domestic, industrial or irrigation consumption. The surface water studies indicated that the Noyyal river (the river passes through Tiruppur and receives the major share of untreated effluents), reservoir, downstream of Noyyam, (Orthapalayam) and irrigation tanks have been adversely affected by industrial pollution and the surface water is unfit for consumption purposes. A study to measure the quality of soil also indicated the pollution concentration and most of the area the soil is alkaline (pH >8.5) or tending to alkalinity (pH 8-8.5).
The Damage Cost Imposed By Pollution
Due to high water pollution many adverse effects in the ecology of the Tiruppur area are observed. Agricultural water, drinking water and various fisheries in Tiruppur area and downstream villages have been affected. The water which has been polluted by the textile industry is injurious (EC>3mmhos/cm) to agriculture in an area of 146.3 square km and critical (EC 1.1 to 3 mmhos/cm) in 218.3 square km. Because of this, crop productivity in these villages has declined substantially which has affected the welfare of farmers. Recently farmers took action and filed a case against the industry. The total cost to agriculture was estimated at US $50 million. Drinking water in these villages has also been affected and the municipality has to bring additional water from neighboring villages. In affected villages, special water supply schemes have been issued by the Water Board. Also, a lot of the short fall is being met by bringing water from distant sources of water which leads to the wastage of a lot of time and effort. Considerin all of this, the total damage cost due to pollution of drinking water comes down to US$23.8 million. The fisheries activities in various downstream regions like the Noyyalriver, tanks and reservoirs have been affected as well. Fish mortality rate has increased which has led to a stoppage of fish culture. US $.15 miilion comes out to be the loss in value of fish and besides that, the possibility of the toxicity of existing fish is also high, consumption of which can lead to serious health problems.
This high level of pollution has had an adverse effect on the operations of the industry itself. Since most of the industrial wells in this area have only coloured, or very highly polluted water, major water supply is brought in through tankers from peripheral areas. The cost incurred by the industry to maintain this additional source of water supply is US $165 million. Besdies this, the continued buying of water leads to the development of a water market, which causes the water levels in the peripheral villages to go down, affecting the livelihood of villagers. On many occasions, protests have been done by villagers against the water transfer. A mega water supply project is being undertaken by the Tiruppur Area Development Corporation. The total cost of this project is estimated to be US $269 millions and will have to be financed by government agencies and the consortium.
Under this scheme, it has been planned that 185 mld of water, which would be both industrial and domestic, would be transferred to Tiruppur from River Cauvery, which is an interstate and a very controversial river in India. If this project would succeed, the industry will need to pay more than what they are currently paying for water, which could result in a huge cost increase for textile processing.
Besides these quantifiable terms, human health and aquatic eco-system of river, tanks and reservoir, livestock etc. also get affected by water pollution, but their cost has not been taken into account as it is not easy to express in monetary terms.
Status of Effluent Treatment
On seeing various adverse effects and hence assessing the seriousness of pollution from textile affluents, the Courts finally gave an order against the continued functioning of various polluting units without being accompanied by effluent treatment plants in 1997. After this order, the state pollution control agency has increased the amount of pressure on all the textile manufacturing units towards effluent treatment. The units which were too small to comply with these regulations and survive were closed. Presently out of the existing 702 units, 278 units are treating upto 38 mld of water effluents through Common Effluent Treatment Plants (CEPTs) which are 8 in number and 424 units are treating upto 45 mldof chemical effluents using Individual Effluent Treatment Plants (IETPs). For effective effluent treatment, US $ 10 million has been spent for various fixed costs, which the Government subsidizes heavily. Besides these, an additional US $ 6.7 million has already been incurred as annual running costs. The cost analysis has shown that the variable cost per unit of effluent treatment is much higher than the capital cost both in the IETPs (which is 86% of total cost) and CETPs (which is 73%). Unfortunately the current treatment system is not sufficient for reducing the large amounts of TDS, particularly the acids like Chloride and Sulphates. The average concentration of TDS in the treated effluents is 300 of the TNPCB standard of 2100 mg/l. The same is true of Chloride, which averages more than 300% of the CETP existent standard.
Learnings from the case
Thus we can see that the management of environment at the Tiruppur textile industry has been difficult and the various difficulties faced by the various actors (State Pollution Control Board, Water Resources Organisations, Local Government , Industrial Organisations, NGOs etc.) or interested parties in this regard or in finding a solution for this problem. If these difficulties had been effectively dealt with, the environmental impacts could not have continued at this level. The above analysis on various RO plants and CPT for the textile units has clearly shown the long run advantage to the industries apart from reducing the various social costs. These technologies can be implemented by all large-scale units who possess the capacity for investment and have long-term vision about the business. But the affordability of affluent treatments among existing large number of small and medium units remains a big challenge. The textile manufacturing industry is predominantly an export oriented business which faces high competition. So any investment done on RO or CPT here impacts the cost of production by increasing it in the short run which is especially true for the smaller units. Also being able to find such big investment, which is approximately more than 10-20 times the overall capital investment, is almost impossible. But the introduction of a much cleaner production for textiles and the availability of advanced treatment technology is the viable long term solution towards further improvement of environmental standards. Realizing the same facts, (i.e. the existing economic benefits of the Tiruppur industry, social costs of pollution, various constraints in effective management of pollution among small scale units, and the need for a having a critical solution for the pollution problem), an integrated process of pollution management can be attempted at by different actors who are related to Tiruppur textile business. In such circumstances the role of various foreign buyers and the consumers of Tiruppur garments are greatly significant. If a very strong demand for garments which are “pollution free” or come with a “green label” is observed from them along with a willingness to pay more, definitely it would provide pressure to introduce cleaner technology by the various industries operating in this domain. A few very small units will have no other option but to close down, since making such an investment may not be viable for them. Other units however can think of various steps like unit modification individually or even have joint units. Most critical are proper technical guidelines for these units and financial support is needed for the units from various domestic and foreign research institutions and other donor agencies. In parallel, sincere collaborative efforts from joint industrial associations, pollution law enforcement agencies, industrial consultants and experts, etc. are also required. Only than the textile industry in Tiruppur would be able to achieve the ideal objective of sustainable development.
Recommended Strategy for companies in textile industry
The companies in Textile industries can be divided into two: Major players with financial strength to invest in greener technologies and small player which need assistance even to maintain regulatory standards. Hence the strategy will also differ based on the type of company.
Strategy for small players
A broad categorization has been done based on the revenue. Below Rs. 10 million the company can be said a small company. It is imperative for a small company to follow regulatory standards at least. While government is finding difficult to close all such factory due to labor intensive nature of such industry it is always a long term risk hence the standards should always be maintained. Hence their strategy is to achieve the minimum standards by increasing the cost as less as possible. The immediate high investment in green technology may throw them out of market. Following strategy must be followed by the company. To have least impact on increment in costs the company might seek financial assistance from government subsidy or jointly making investments. To get knowledge assistance it could collaborate with various stakeholders.
Small Players (Under Rs. 10 million)
Maintain Pollution control board standards with least impact of costs
Maintain PCB Standards (Avoid risk of closure)
Annual maintenance and up gradation as per standards
Collaboration with the foreign buyer
Setting up Joint Effluent Treatment Plants (JETP)
Identify subsidies given by government and avail them
Join with other small players to invest in ETP
Collaboration with pollution enforcement agencies, NGOs, industrial consultants, Industrial associations,
Least impact on costs (Remain competitive)
Strategy for big players:
A major player could afford a significant investment for the long term overall benefit. The strategy should be to gain competitive advantage by achieving Cleaner process technology and establishing efficient effluent treatment plants. These will have high investments in short term but will give major cost advantage and high value of intangibles, other important aspect is to have a differentiation based on greener features. This way a high premium could be charged against the product and much higher overall profitability could be achieved.
Big Players (Above Rs. 10 million)
Differentiate product based on Green features
Process improvement (Raw material efficiency, Waste reduction)
Application of Cleaner Process Technology (CPT) e.g. soft flow machines, dye bath segregation etc.
Collaborate with foreign buyers to create demand for green products
Establish Individual Effluent Treatment Plant (IETP) Recycle major percentage of used water using RO etc. technology
Get green label and accreditations from ISO etc.
Recycling of critical resources (Water)
Promotions as a Clean and Green Product
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