Environmental Aspects of Pharmaceutical Industry in India

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SOURCES OF HAZARDS IN PHARMA
 
Manufacturing and formulation installations.
Handling and storage of hazardous chemicals including warehouses,
godowns, tank forms in ports/fuel depots/docks.
Transportation (road, rail, air, water, pipelines).
Emission of pollutants – the air pollutants include carbon monoxide (CO),
nitrogen dioxide (NO2), particulate matter of 10 microns or less (PM10),
total suspended particulate matter (SPM), sulphur dioxide (SO2), and
volatile organic compounds (VOCs). The most common VOCs include
methanol, dichloromethane, toluene, ethylene glycol,
N,Ndimethylformamide ,and  acetonitrile.
Effluents, especially those that are not easily biodegradable and toxic in
nature. The effluent releases could go directly to streams, rivers, lakes,
oceans, or other bodies of water. The releases due to runoff, including
storm water runoff, could also be a potential hazard.
 
HAZARDOUS WASTE – TYPES
 
these are in the form of liquids, solids, contained
gases or sludge.
This waste, containing spent solvents and other toxic organics in
significant concentrations, requires treatment before it can be
disposed of safely.
The toxic releases from the pharmaceuticals industry includes
on-site     discharge of a toxic chemical to the environment. This
includes emissions to the air, discharges to bodies of water,
releases at the facility to land, as well as contained disposal into
underground injection wells.
Natural calamities like such as flood, cyclone, earthquake,
tsunami.
VARIOUS TYPES OF PHARMACEUTICAL WASTE –CHEMICAL WASTE
Organic chemical residues from manufacturing processes
Heavy metals
 
Dust  during formulation
Gaseous Vapours / emissions during API /Bulk drugs
Chemical Spills
Leakages – water , oils, solvents , chemicals ,
 
 
EXAMPLES OF CHEMICAL WASTE
 
Carcinogenic & other Chemicals used will explore every chances
of gaseous/ fumes for Aromatic Amines , Benzene derivatives
,Solvents like Acetonitrile , Acetic Acid , Toluene, Methanol .
All are very hazardous for Environment & Occupation .
Needs Control measures especially in terms of EMS i.e.
Environment Management System ( ISO 14001)  and OHSAS –
18001 .
 
MOST COMMON ENVIRONMENT HAZARDS BY
PHARMA FIRM
 
The hazards from the pharmaceuticals could be categorized as:
Ecotoxic - damage is caused to the environment.
Carcinogenic - contribute to the causation of cancer.
Persistent - remain dangerous for a long time.
Bio-accumulative – accumulates as it makes its way up the
food chain.
Disastrous due to a catastrophe, mishap, calamity or grave
occurrence in any area.
 
CONTD.
 
Water Pollution – because of spillage , drains and generation of
effluent water , sewage water for uncontrolled pH , and treating
it ineffectively . MOST dangerous for aquatic living organisms or
their livelihood.
Air Pollution – releases of gaseous , fumes , dust , particulates
to atmosphere , poor air quality ,
Land /Soil Pollution – Spillage , chemicals , oils , lubricants
leakages to land /soil – seepage causation of non fertility to soil
/lands , dumping or disposal of incinerated sludge unauthorized
Noise Pollution – persistent vibration in operating machines
    , equipments , use of non acoustic power  generators , air
compressors .
 
CONTD.
 
Odor :- spillage of blood , bio medical waste and culture burning
in autoclave etc  -poor effect on ambient air quality , -leading to
mass air pollution and hazards to neighborhood – plants , trees,
human , animals etc .
GLOBAL WARMING – CO2 Emission , CO , suspended
particulates in atmosphere , NOx , - very sensitive issue globally
now posing great threat of GLACIAL melting
Heat Stress :- Uncontrolled work environment , high temp ,
exothermic reactions , use of solvents , - very dangerous
occupational hazard and also affecting ENVIRONMENT
 
REGULATIONS  AT NATIONAL LEVEL
 
At National Level :-
 FACTORY ACT 1948  Compliance
 MoEF Environmental Clearance
 Environment Protection Act 1986
 Environmental Statements Submission to Pollution Boards – Form
V
 Public Liability Act & Insurance 1991
 MSDS for Hazardous materials and compliance
CCOE ( PESO ) License for  classified solvent storage
Indian Electricity Act 1936 & rules
 
CONTD.
 
Disaster Management Act -2005
Drugs & Cosmetic Act – 1940
Indian Boiler Act 1923
Hazardous Waste Management Act & Rules –
The Petroleum Act – 1934 & Rules -2002
The Explosives Act – 1884 & rules -1983
Central Motor Vehicles Act for HW or Goods carrying -1989
 
REGULATIONS AT STATE LEVEL
 
Enforcement at STATE LEVEL :-
State Level Factory Rules -1963 and further amendments
Pollution Control Board Consent To operate – a) WATER ACT
1974 , b) AIR ACT -1984
Stack Monitoring Reports for emissions to Air
Work Environment monitoring – Ventilation , Illumination ,Dust
& fumes
Noise Monitoring
Formation of SAFETY COMMITTEE as per 73 L
 
CONTD
.
 
Hazardous Waste Disposal Records (manifest)
Petroleum products storage on site – type ,storage , and License
– class A solvents  , Class B chemicals ,  HSD , LPG stock etc
Fire Hydrant system &  FIRE NOC
Trained FIRST AIDERS
EPR & ERT – Emergency Preparedness & Response , Emergency
Response Team
OHC – Occupational Health Centre , with Visiting Doctor & Male
Nurse
 
CONTD.
 
Approved Licensed Contractors
ESI of Employees /Contractors / Sub Contractors
Mock Drills – announced / un announced for Emergency
Evacuation
Safety Committee Meetings & MOM
Safety & Environment Promotional Activities
 
EXISTING GAPS & CONCERN
 
Non compliance too many –
Loose Controls on ETP , Casual Approach for ETP maintenance
and Treatment
Air Pollution – No proper designing of scrubbers , venturies
Storm water and drain water common outlets , effluent load
problems
Unskilled   contract workers
Lack of SOP and training needs
Staff / workforce  in adequate
 
CONTD.
 
Lack of Preventive maintenance activities  - Break downs ,
emissions , leakages –air , water pollution
Over capacity utilization of production schedules – system
failure , leading to Air /Water /Land pollution
 Old  equipments – Poor Efficiency , trouble shooting ,
Poor electrical safety – negligence to earthing ,  fire hazard
Spillages , leakages of chemicals , oils , lubricants – water
pollution , air pollution , ambience pollution
Gaseous emissions to atmosphere  in night time high – Air
Pollution ,  poor ambience , plants
Use of Non Acoustic D G sets  - noise pollution , air pollution
 
GAPS /CONCERNS FOR LEGAL
 
Non adherence to PCB consent norms – diluted standards
Erratic Behavior on SAFETY measures
Spillages , leakages –ignorance and poor maintenance cause for
depletion of natural resources like water , power , forest ,
ozone layer depletion etc.
Non compliance of Annual Environment Returns – forged /
manipulations in statement
Lack of Safety Standards .
 
MANAGING WASTE COMING OUT FORM PHARMA
FIRMS
 
Impact of  Waste – from Pharma Firms
Air Pollution – 50 % of firms hazardous waste is wrongly
handled , not as per MSDS requirements leading to spillage ,
open to evaporation , unclean  dust collectors , inefficient
scrubbers , use of scrubber absorption media for a long period .
Water Pollution :- Adverse functioning of ETP , lack of
monitoring ETP by qualified personnel – leading to profuse
water pollution , discharged to CETP with extra allowance , non
standard use ETP material – in filtration , aeration ,
 
CONTD.-
 
Spillage , Leakage , emissions , fumes , vapors direct impact on
work place monitoring and AIR Quality .
Excessive wastages from R M , storage packing material
consumptions ,resulting in to natural and other source
depletions
 Land fertility problems due to waste dumping
 
           COMMONLY APPLIED SYSTEMS (DO’S & DON’TS )
 
Most of the organization switching to water based / enzyme based
products – API / formulations – improved Environment Controls for
emissions, air quality and water pollution , optimize the process
conditions
Organizations adapting to ISO -14001 – EMS  for continual improvement
Work place environment and ambience improvements with designed
Aspect /Impact controls , Waste minimization by improving material
consumptions.
 
CONTD :-
 
Even establishing OHSAS culture for Behavioral
safety
Internal audits / self inspection  to ensure
conformance
Training to employees / contractors
Lock out /Tag Out Electrical system applied
Work Permit systems
 
GMP system – Process Approach , validation,
compliance
Environment Controls during manufacturing ,
maintenance , storage , transportation , handling .
MSDS for base line requirements
Documentation and records of H W collection and
disposal monitoring
Improve on Technology
Training of employees , contractors
 
Start Up / Shut Down procedures is must for better
environment Controls
Improve on Engineering Controls to mitigate aspect
/impacts also unsafe conditions and unsafe acts
Controls on interfaces of process
Establish EHS policy and communicate to all
employees , contractors , visitors
Provide primary , secondary containments at
spillages /leakages to arrest impact on environment
 
 Haste ,
Overloading of equipments
Small spills , leaks - ignorance
Use of excessive materials – R M , Packing etc .
 short cuts , process bypasses
Critical process – untrained persons
 
GOOD PRACTICES
 
Training to employees / contractors
Documentation
Recording
Self Inspections /Audits
Display of various Environment educative posters
Tool Box Talks at shop floors
 Adoption of GMP
Consider ISO -14001 –EMS for continual
improvement
 
    
 ROLE OF KEY ACTORS IN MANAGING THE
     WASTE COMING OUT PHARMA INDUSTRIES
 
Government (national and state levels)
     
Making Policies & Establish
      Refreshing the changes / amendments in policies , directives
through Web , Media and Updating the MoEF Consents
      Survey  of  Industrial areas though PCB , DISH
      Creation of CETP or Enviro Collection centers in Industrial
outlets
       Air Monitoring at Industries
       Work Place Environment monitoring
 
   CONTD.-
 
Central & State Pollution Control Boards
Independent  , Full Time MEMBER SECRETARY at PCB
Apex level of IAS grade .
Creation of Regional PCB at all District level to ease
out local issues
Public Liability Insurance Act 1991 made mandatory
for off site emergency
Central Hazardous waste collection areas ear marked
by PCB to avoid unauthorized and suspicious
dumping
Provision of CETP
Industrial frequent visits and follow up on critical
env.issues
 
CONTD,-
 
Violation memos to trouble shooter industries
Show cause Notices on major violation of EPA 1986
act
Shut down of major problematic Industries
Mandatory to file /submit quarterly hazardous waste
statement to PCB
In line WEB access to all industries by PCB for ease of
submission and monitoring by them .
 
                DRUG CONTROLLER
             NATIONAL & STATE LEVEL
 
Responsible for  Drug & Cosmetic act enactment in
pharma industries.
Empowered by Ministry of Chemicals for effective
implementation of Drug & Cosmetic act in totality
Sampling of vehicles and industries for controls
taken on hazardous waste generation and it’s
disposal
 
            PHARMACEUTICAL ASSOCIATIONS
            
CHEMIST ASSOCIATIONS
 
Interactions , dialogues with local industrial for their
problem
Arranging work shops / seminars through
associations to diffuse the gravity situations and joint
forums to mitigate issues of hazardous waste
Making presentation to Drug Authorities for facts and
getting their help in disposal of hazardous waste like
creation of authorized dumping outlets,
Creation of CETP or Enviro care centers through
follow up with Regulatory authorities and standardize
practices
Helping to small scale industries through Training
and awareness for acquainting to Pollution
/Environment Controls
 
MEDICAL REPRESENTATIVE ASSOCIATION
CONSUMERS/CITIZENS GROUPS
 
Main role by these group is expected through
campaigning for hazardous waste generation by
consumers through blisters , primary secondary
packing material coming out of drug usage
This group to educate hospitals , nursing staff ,
dispensary staff for impact of packing material in
Environment
Hazards of handling such waste while as an end user
It is expected also by this group to share feedback
from customers- direct/ indirect agencies to pharma
company so that there will be further improvement to
mitigate on issues of hazardous waste by technology
developments and less impact on environment
 
END OF SESSION
 
THANKS
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The pharmaceutical industry in India poses various environmental hazards through manufacturing processes, handling of hazardous chemicals, waste disposal, and natural calamities. Hazardous waste types, sources of hazards, and examples of chemical waste highlight the importance of implementing effective control measures. The industry emits pollutants like VOCs and releases effluents that can be harmful to the environment. Various types of pharmaceutical waste, including chemical residues and heavy metals, further contribute to environmental risks.

  • Pharmaceutical industry
  • Environmental hazards
  • Hazardous waste
  • Chemical waste
  • Pollution

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  1. Introduction to key environmental aspects of pharmaceutical industry in India Faculty :- Mr Shridhar Rajpurohit LA (IMS )/ TUTOR /SAFETY

  2. SOURCES OF HAZARDS IN PHARMA Manufacturing and formulation installations. Handling and storage of hazardous chemicals including warehouses, godowns, tank forms in ports/fuel depots/docks. Transportation (road, rail, air, water, pipelines). Emission of pollutants the air pollutants include carbon monoxide (CO), nitrogen dioxide (NO2), particulate matter of 10 microns or less (PM10), total suspended particulate matter (SPM), sulphur dioxide (SO2), and volatile organic compounds (VOCs). The most common VOCs include methanol, dichloromethane, toluene, ethylene glycol, N,Ndimethylformamide ,and acetonitrile. Effluents, especially those that are not easily biodegradable and toxic in nature. The effluent releases could go directly to streams, rivers, lakes, oceans, or other bodies of water. The releases due to runoff, including storm water runoff, could also be a potential hazard. 2

  3. HAZARDOUS WASTE TYPES these are in the form of liquids, solids, contained gases or sludge. This waste, containing spent solvents and other toxic organics in significant concentrations, requires treatment before it can be disposed of safely. The toxic releases from the pharmaceuticals industry includes on-site discharge of a toxic chemical to the environment. This includes emissions to the air, discharges to bodies of water, releases at the facility to land, as well as contained disposal into underground injection wells. Natural calamities like such as flood, cyclone, earthquake, tsunami. 3

  4. VARIOUS TYPES OF PHARMACEUTICAL WASTE CHEMICAL WASTE Organic chemical residues from manufacturing processes Heavy metals Dust during formulation Gaseous Vapours / emissions during API /Bulk drugs Chemical Spills Leakages water , oils, solvents , chemicals , 4

  5. EXAMPLES OF CHEMICAL WASTE Carcinogenic & other Chemicals used will explore every chances of gaseous/ fumes for Aromatic Amines , Benzene derivatives ,Solvents like Acetonitrile , Acetic Acid , Toluene, Methanol . All are very hazardous for Environment & Occupation . Needs Control measures especially in terms of EMS i.e. Environment Management System ( ISO 14001) and OHSAS 18001 . 5

  6. MOST COMMON ENVIRONMENT HAZARDS BY PHARMA FIRM The hazards from the pharmaceuticals could be categorized as: Ecotoxic - damage is caused to the environment. Carcinogenic - contribute to the causation of cancer. Persistent - remain dangerous for a long time. Bio-accumulative accumulates as it makes its way up the food chain. Disastrous due to a catastrophe, mishap, calamity or grave occurrence in any area. 6

  7. CONTD. Water Pollution because of spillage , drains and generation of effluent water , sewage water for uncontrolled pH , and treating it ineffectively . MOST dangerous for aquatic living organisms or their livelihood. Air Pollution releases of gaseous , fumes , dust , particulates to atmosphere , poor air quality , Land /Soil Pollution Spillage , chemicals , oils , lubricants leakages to land /soil seepage causation of non fertility to soil /lands , dumping or disposal of incinerated sludge unauthorized Noise Pollution persistent vibration in operating machines , equipments , use of non acoustic power generators , air compressors . 7

  8. CONTD. Odor :- spillage of blood , bio medical waste and culture burning in autoclave etc -poor effect on ambient air quality , -leading to mass air pollution and hazards to neighborhood plants , trees, human , animals etc . GLOBAL WARMING CO2 Emission , CO , suspended particulates in atmosphere , NOx , - very sensitive issue globally now posing great threat of GLACIAL melting Heat Stress :- Uncontrolled work environment , high temp , exothermic reactions , use of solvents , - very dangerous occupational hazard and also affecting ENVIRONMENT 8

  9. REGULATIONS AT NATIONAL LEVEL At National Level :- FACTORY ACT 1948 Compliance MoEF Environmental Clearance Environment Protection Act 1986 Environmental Statements Submission to Pollution Boards Form V Public Liability Act & Insurance 1991 MSDS for Hazardous materials and compliance CCOE ( PESO ) License for classified solvent storage Indian Electricity Act 1936 & rules 9

  10. CONTD. Disaster Management Act -2005 Drugs & Cosmetic Act 1940 Indian Boiler Act 1923 Hazardous Waste Management Act & Rules The Petroleum Act 1934 & Rules -2002 The Explosives Act 1884 & rules -1983 Central Motor Vehicles Act for HW or Goods carrying -1989 10

  11. REGULATIONS AT STATE LEVEL Enforcement at STATE LEVEL :- State Level Factory Rules -1963 and further amendments Pollution Control Board Consent To operate a) WATER ACT 1974 , b) AIR ACT -1984 Stack Monitoring Reports for emissions to Air Work Environment monitoring Ventilation , Illumination ,Dust & fumes Noise Monitoring Formation of SAFETY COMMITTEE as per 73 L 11

  12. CONTD. Hazardous Waste Disposal Records (manifest) Petroleum products storage on site type ,storage , and License class A solvents , Class B chemicals , HSD , LPG stock etc Fire Hydrant system & FIRE NOC Trained FIRST AIDERS EPR & ERT Emergency Preparedness & Response , Emergency Response Team OHC Occupational Health Centre , with Visiting Doctor & Male Nurse 12

  13. CONTD. Approved Licensed Contractors ESI of Employees /Contractors / Sub Contractors Mock Drills announced / un announced for Emergency Evacuation Safety Committee Meetings & MOM Safety & Environment Promotional Activities 13

  14. EXISTING GAPS & CONCERN Non compliance too many Loose Controls on ETP , Casual Approach for ETP maintenance and Treatment Air Pollution No proper designing of scrubbers , venturies Storm water and drain water common outlets , effluent load problems Unskilled contract workers Lack of SOP and training needs Staff / workforce in adequate 14

  15. CONTD. Lack of Preventive maintenance activities - Break downs , emissions , leakages air , water pollution Over capacity utilization of production schedules system failure , leading to Air /Water /Land pollution Old equipments Poor Efficiency , trouble shooting , Poor electrical safety negligence to earthing , fire hazard Spillages , leakages of chemicals , oils , lubricants water pollution , air pollution , ambience pollution Gaseous emissions to atmosphere in night time high Air Pollution , poor ambience , plants Use of Non Acoustic D G sets - noise pollution , air pollution 15

  16. GAPS /CONCERNS FOR LEGAL Non adherence to PCB consent norms diluted standards Erratic Behavior on SAFETY measures Spillages , leakages ignorance and poor maintenance cause for depletion of natural resources like water , power , forest , ozone layer depletion etc. Non compliance of Annual Environment Returns forged / manipulations in statement Lack of Safety Standards . 16

  17. MANAGING WASTE COMING OUT FORM PHARMA FIRMS Impact of Waste from Pharma Firms Air Pollution 50 % of firms hazardous waste is wrongly handled , not as per MSDS requirements leading to spillage , open to evaporation , unclean dust collectors , inefficient scrubbers , use of scrubber absorption media for a long period . Water Pollution :- Adverse functioning of ETP , lack of monitoring ETP by qualified personnel leading to profuse water pollution , discharged to CETP with extra allowance , non standard use ETP material in filtration , aeration , 17

  18. CONTD.- Spillage , Leakage , emissions , fumes , vapors direct impact on work place monitoring and AIR Quality . Excessive wastages from R M , storage packing material consumptions ,resulting in to natural and other source depletions Land fertility problems due to waste dumping 18

  19. COMMONLY APPLIED SYSTEMS (DOS & DONTS ) Most of the organization switching to water based / enzyme based products API / formulations improved Environment Controls for emissions, air quality and water pollution , optimize the process conditions Organizations adapting to ISO -14001 EMS for continual improvement Work place environment and ambience improvements with designed Aspect /Impact controls , Waste minimization by improving material consumptions. 19

  20. CONTD :- Even establishing OHSAS culture for Behavioral safety Internal audits / self inspection to ensure conformance Training to employees / contractors Lock out /Tag Out Electrical system applied Work Permit systems 20

  21. Dos Do s GMP system Process Approach , validation, compliance Environment Controls during manufacturing , maintenance , storage , transportation , handling . MSDS for base line requirements Documentation and records of H W collection and disposal monitoring Improve on Technology Training of employees , contractors 21

  22. Dos Do s Start Up / Shut Down procedures is must for better environment Controls Improve on Engineering Controls to mitigate aspect /impacts also unsafe conditions and unsafe acts Controls on interfaces of process Establish EHS policy and communicate to all employees , contractors , visitors Provide primary , secondary containments at spillages /leakages to arrest impact on environment 22

  23. Donts Don ts Haste , Overloading of equipments Small spills , leaks - ignorance Use of excessive materials R M , Packing etc . short cuts , process bypasses Critical process untrained persons 23

  24. GOOD PRACTICES Training to employees / contractors Documentation Recording Self Inspections /Audits Display of various Environment educative posters Tool Box Talks at shop floors Adoption of GMP Consider ISO -14001 EMS for continual improvement 24

  25. ROLE OF KEY ACTORS IN MANAGING THE WASTE COMING OUT PHARMA INDUSTRIES Government (national and state levels) Making Policies & Establish Refreshing the changes / amendments in policies , directives through Web , Media and Updating the MoEF Consents Survey of Industrial areas though PCB , DISH Creation of CETP or Enviro Collection centers in Industrial outlets Air Monitoring at Industries Work Place Environment monitoring 25

  26. CONTD.- Central & State Pollution Control Boards Independent , Full Time MEMBER SECRETARY at PCB Apex level of IAS grade . Creation of Regional PCB at all District level to ease out local issues Public Liability Insurance Act 1991 made mandatory for off site emergency Central Hazardous waste collection areas ear marked by PCB to avoid unauthorized and suspicious dumping Provision of CETP Industrial frequent visits and follow up on critical env.issues 26

  27. CONTD,- Violation memos to trouble shooter industries Show cause Notices on major violation of EPA 1986 act Shut down of major problematic Industries Mandatory to file /submit quarterly hazardous waste statement to PCB In line WEB access to all industries by PCB for ease of submission and monitoring by them . 27

  28. DRUG CONTROLLER NATIONAL & STATE LEVEL Responsible for Drug & Cosmetic act enactment in pharma industries. Empowered by Ministry of Chemicals for effective implementation of Drug & Cosmetic act in totality Sampling of vehicles and industries for controls taken on hazardous waste generation and it s disposal 28

  29. PHARMACEUTICAL ASSOCIATIONS CHEMIST ASSOCIATIONS Interactions , dialogues with local industrial for their problem Arranging work shops / seminars through associations to diffuse the gravity situations and joint forums to mitigate issues of hazardous waste Making presentation to Drug Authorities for facts and getting their help in disposal of hazardous waste like creation of authorized dumping outlets, Creation of CETP or Enviro care centers through follow up with Regulatory authorities and standardize practices Helping to small scale industries through Training and awareness for acquainting to Pollution /Environment Controls 29

  30. MEDICAL REPRESENTATIVE ASSOCIATION CONSUMERS/CITIZENS GROUPS Main role by these group is expected through campaigning for hazardous waste generation by consumers through blisters , primary secondary packing material coming out of drug usage This group to educate hospitals , nursing staff , dispensary staff for impact of packing material in Environment Hazards of handling such waste while as an end user It is expected also by this group to share feedback from customers- direct/ indirect agencies to pharma company so that there will be further improvement to mitigate on issues of hazardous waste by technology developments and less impact on environment 30

  31. END OF SESSION THANKS 31

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