pakistan _ca

Strategic Approach to International Chemical

Management SAICM

National Capacity Assessment

for Implementation of SAICM In Pakistan

Dr. Khalid Mehmood

November, 2009

International Cooperation Wing, Ministry of Environment Government of Pakistan, Islamabad

National Capacity Assessment of Pakistan for Implementation of SAICM

The 2006-2009 pilot project in support of National SAICM implementation to "Strengthen

Governance, Civil Society Participation and Partnerships within an Integrated National Chemicals

and Waste Management Programme" in Pakistan has been supported by the United Nations

Institute for Training and Research (UNITAR) with the financial support of the Swiss Agency for

Development and Cooperation.

International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Page i


Acknowledgements

The National Capacity Assessment was conducted as part of the SAICM project

initiated under the Supervision of Mr. Abid Ali, Joint Secretary, International

Cooperation Wing, Ministry of Environment and Focal Person for SAICM from

Pakistan. I acknowledge with gratitude the support of Mr. Zaheer Ahmed Gillani

National SAICM Coordinator, National Project Manager, Multilateral

Environmental Agreements Secretariat (MEAS) and Syed Hashim Raza, Subject

Specialist SAICM and MEAS, Ministry of Environment, Government of Pakistan,

who provided us guidance and their continued support throughout this project.

This work could not have been accomplished without the generous and gracious

cooperation and contributions of our stakeholders, especially, Federal Ministries of

Environment, Agriculture, Commerce, Health, Labour and Manpower, Production,

Law Justice, Industry, Communication, Science and Technology, Federal Bureau of

Statistics and their departments; provincial departments of Agriculture and

Environment; a large number of R & D organization and Non-Governmental

Organizations (NGOs).

I wish to extend our deep gratitude to United Nations Institute for Training and

Research (UNITAR) for providing guidance and financial support towards the

production of this report and for supporting workshops related to this project.

Special thanks are also extended to my all associates who worked diligently and

provided support during the production of this document. We have endeavored to

ensure our assessment based on situation analysis during preparation of National

Chemical Profile and inputs provided by our stakeholders, however, we would invite

comment on any errors or inaccuracies.

Dr. Khalid Mehmood

Senior Adviser and

Team Leader for

SAICM Project

International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Page ii


Executive Summary

The Capacity Assessment and Priority Setting for the Sound Management of Chemicals and

National SAICM Implementation is a national project of the Government of Pakistan. The

Ministry of environment is responsible for the implementation of the project.

The primary objective of the project is to identify national priorities and needs for capacity

building in the key areas of chemical management throughout their life cycle, with the aim of

catalyzing domestic and / or externally assisted action to meet those needs in a coordinated and

planned manner.

The National Capacity Assessment was undertaken at three levels - individual, institutional, and

systemic capacity. Individual and institutional capacities are well known concepts. Systemic

capacity describes the policy and legislation framework and identifies relationships, collaboration,

and linkages amongst institutions involved in chemical management and use. The national

assessment also investigated cross-cutting issues such as poverty and decentralization, on sectors

including the chemical management.

Challenges to chemical management were identified and prioritized during the first part of

capacity assessment. Although Pakistan has the ability to adequately address some of these

challenges, there is a strong feeling that capacity constraints centre around three themes: Financial

shortfalls; Lack of equipment, tools, physical support, and infrastructure; and Shortage of trained

and skilled personnel. From these, certain priority issues for action were identified:

Lack or limited technical and scientific capacity;

Indicators and monitoring measures for sound chemical management;

Insufficient laboratories, technical research institutions, tools and equipments;

Identification of adaptation measures to chemical management challenges;

Lack of legislation dealing with disposal transportation and storage of chemicals;

Lack or limited data availability related to chemicals during its life cycle; and

Promotion of synergies across the government and other related institutions.

These priority issues need to be approached with a synergistic approach.

During capacity assessment, it was found that awareness levels and knowledge about the chemical

management is very limited in the country. Within the implementing agencies, there is lack of

awareness of existing regulatory framework. The decision-makers have limited knowledge of FAO

and WHO specifications on pesticides. The decision makers and legislators are unaware of the

chemical safety measures. Even the environmental managers have low level of awareness and

knowledge of life cycle management concept. The academia and public are generally unaware of

International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Page iii


the international conventions on chemical management and the concept of chemical management at

all. Individuals and institutions that indicate awareness of the chemical management concept and

conventions are not necessarily familiar with the contents as such. There is some level of

awareness among NGOs and trade associations, and they are playing their role to raise public

awareness to some extent, but they need capacity building exclusively in chemical management.

People involved at various stages of the chemicals life cycle, are unaware of the health and

environmental implications of the chemicals they are exposed to.

Pakistan is striving in the right direction with regard to chemical management and awareness

related activities. There are key ministries, non-governmental organizations, and private

institutions involved in the sound management of chemicals in the country. The mandates of

ministries and departments are clearly defined and there does not exist any overlapping. There is

no need for a separate ministry dealing with chemical management. Trade associations, research

institutions and community groups are playing a vital role in creating awareness among public and

implementation of voluntary initiatives like ISO standards 9000, 14000 and OHSAS 18001. They

are also cooperating in Pak-EPA's SMART programme for self monitoring and reporting. NGOs

especially are playing very important role in raising awareness and educating the public for effective

participation in national environmental management initiatives (e.g. as stated in agenda 21 or the

implementation of Stockholm Convention) as well as access to justice in environmental matters.

The poor chemical management can result in increase in diseases caused by various chemicals such

as cancer, abnormal births, etc; unbelievable damage to environment and chemical accidents

causing financial and life loss as well as damage to environment. Therefore, chemical management

should be given due consideration by the government and funds should be allocated accordingly.

Individual, institutional, and systemic capacity to address the concerns of the SAICM at the

national level is present to some extent. In terms of institutional capacity, despite clearly defined

mandates, relationships, collaboration, and linkages among institutions do not exist. An

environmental advisory committee, NTACC, has been established to complement existing

institutional capacity and enhance coordination among various institutions but the representation

of some ministries, NGOs, industries and academia is lacking. There is also a capacity constraint in

terms of identification of important information that could assist in the implementation of

different activities. Lack of external financing has also been identified a concern for most

government sectors. It has been found that government divisions that have access to additional

funding from international donors have access to relevant information and they have acquired

necessary capacity and facilities. Another major constraint identified is lack of technical human

resource available to the institutions. There is also lack of infrastructure for chemical management.

Capacity must be built in institutions so that they can capture data, negotiate effectively, and

address the legal aspects relating to the chemical management.

International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Page iv


Individual capacity constraints identified are related to lack of knowledge and awareness of the

concept of chemical management, lack of translation of expert knowledge to local communities,

lack of training and work incentives, lack of relevant infrastructure, lack of authority and limited

networking opportunities among technical experts and local environmental managers. Individual

capacity needs to be strengthened as well. There are no specific courses available for chemical

management. The additional modules are required in the curricula of the universities with

reference to the chemical management, waste management, waste treatment etc. There is a need

for the proper awareness and technical training of the workers. Most of the government

institutions are overworked, they should be provided with proper work incentives like promotions,

bonuses, etc.

Systemic capacity is inadequate with regard to policy and legislative framework, because there is

lack of coordination. Legislation related to different aspects of life cycle of chemicals, especially

with reference to import, export, production, use and disposal is very comprehensive, but the

legislation dealing with disposal transportation and storage of chemicals is insufficient. Most of the

existing legislation was not enacted for the specific purpose of chemical life cycle management in

particular. The penalties are not reformatory and stringent enough to deter the crime. The major

drawbacks behind the ineffectiveness and non-enforcement of regulatory framework are with the

inspections, monitoring, vigilance and public awareness. Therefore, no new acts are proposed but

few amendments in existing laws will be sufficient. With regard to international conventions, a

multilateral approach is being adopted for chemical management in the country through

implementation of SAICM. The international conventions have been incorporated in the national

legislation and are being implemented. Beside, GHS is yet to be implemented in the country. The

major loophole to the implementation of international conventions is the poorly managed

national data system related to chemical life cycle. It is therefore suggested that an integrated

approach to the safe use of chemicals should be adopted by establishing effective mechanisms for

following up and updating information on international instruments related to hazardous

substances.

Capacity at the systemic level requires effective implementation and monitoring impacts of laws

and policies.

International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Page v

Acronyms

BAT

BEP

CBOs

CCI

EIA

EPA

FAO

FBR

FBS

GPA

GHS

GSP

HDIP

HEJ

HIES

IAC

ICCM

IC wing

IFCS

IGOs

ILO

ILO-OSH

IMO

INFOCAP

IOMC

ISO

LFS

LPG

MDGs

MEAs

NARC

NIAB

NDMA

NDMC


Best Available Techniques

Best Environmental Practices

Community Board Organizations

Chambers of Commerce and Industry

Environmental Impact Assessment

Environmental Protection Agency

Food and Agriculture Organization

Federal Board of Revenue

Federal Bureau of Statistics

Global Plan of Action

Globally Harmonized System of Classification and Labeling of

Chemicals

Geological Survey of Pakistan

Hydrocarbon development Institute of Pakistan

Husein Ebrahim Jamal Research Institute of Chemistry

Household Integrated Economic Survey

Industrial Analytical Centre

International Conference on Chemicals Management

International Cooperation wing

Intergovernmental Forum on Chemical Safety

Intergovernmental organizations

International Labor Organization

ILO guidelines on occupational safety and health management

System

International Maritime Organization

Inter-Organization Programme for the Sound Management of

Chemicals

International Organization for Standardization

Labour Force Survey

Liquefied petroleum gas

Millennium Development Goals

Multilateral Environmental Agreements

National Agricultural Research Centre

Institute for Agriculture and Biology

National Disaster Management Authority

National Disaster Management Commission

International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Page vi

NGOs

NPRI

NTACC

OECD

OHSA

S

OPS

PAEA

PBTs

PCSIR

PDS

PEPA

PIHS

POPs

PPD

PRTRS

QSP

R&D

SAICM

SMAR

T

SOPs

TDS

TOC

TRI

UNEP

UNITAR

WH O

WSSD


Non-governmental organizations

National Pollutant Release Inventory

National Technical Advisory Committee on Chemicals

Organization for Economic Cooperation and Development

Occupational Health and Safety Assessment Series

Overarching Policy Strategy

Pakistan Atomic Energy Agency

Persistent bio-accumulative and toxic substances

Pakistan Council for Scientific & Industrial Research

Pakistan Demographic Survey

Pakistan Environmental Protection Act

Pakistan Integrated Household Survey

Persistent organic pollutants

Plant Protection Department

Pollutant Release and Transfer Registers

Quick Start Programme

Research and Development

Strategic Approach to International Chemicals Management

Self-Monitoring and Reporting System

Standard Operating Procedures

Total Dissolved Solids Total

Organic Carbon

Toxic Releases Inventory

United Nations Environment Programme

United Nations Institute for Training and Research

World Health Organization

World Summit on Sustainable Development

International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Page vii


Contributors

Muhammad Zafar Iqbal

Mrs. Nuzhat Mahmud

Huma Afzal

Muhammad Umair Sheikh

Aisha Suddle

From Ministry of Environment

Syed Zaheer Ahmed Gillani

Syed Hashim Raza

National SAICM Consultant,

Environmental/Analytical Chemist

Research Assistant

Data Analyst

IT Specialist

Editor/National SAICM Coordinator,

NPM MEAs Secretariat, MoE

Coordinator, MEAs Secretariat, MoE

International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Page viii


Table of Contents

1. 1.1. 1.2. 1.3. 1.4.

2. 2.1. 2.2. 2.3. 2.3.1. 2.4. 2.4.1

3.

3.1 3.2

3. 3.1 3.2.

4.

INTRODUCTION

Context and Overview Background on SAICM Overview of SAICM Outcomes and Decisions Linkages between SAICM and Agenda 21

NATIONAL SAICM CAPACITY ASSESSMENT

Objectives Main Components of SAICM Capacity Assessment Assessment of the Governance Framework

Areas for Governance Assessment

Assessment of Capacities for Important Chemicals Management Issues Areas for Chemical Management Assessment

PRIORITY ISSUES RELATED TO CHEMICAL LIFE CYCLE MANAGEMENT IN PAKISTAN

Priority Issue Related to Governance Priority Issues Related to Capacities for Chemicals Management

RECOMMENDATIONS

Recommendations for Governance Issues Recommendations for Important and Urgent Chemicals Management Issues

CONCLUSION

2 2 2 3 4

5 5 6 6

6

14

14

26 26 27

29 29 30

32

ANNEXURES 38 Annexure 1: Worksheet for Governance Assessment 39 Annexure 2: Worksheet for Identification of Important and Urgent Chemicals Management Issues 69

International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Page 1


1. Introduction

1.1. Context and Overview

The Strategic Approach to International Chemicals Management (SAICM) was adopted by the

International Conference on Chemicals Management (ICCM) at its first session in Dubai in

February 2006. An important objective of SAICM at the national level is to build upon existing

chemicals management initiatives in various sectors and strengthen coordination and

coherence among various government and stakeholder initiatives. A second important

objective is to link these activities to national development planning (e.g. National Sustainable

Development Strategies, UN Development Assistance Frameworks, Poverty Reduction

Strategies, etc). In order to achieve these objectives, the SAICM Overarching Policy Strategy

(OPS) states that: "To sustain an integrated approach to managing chemicals, each

Government should establish arrangements for implementing the Strategic Approach on an

inter-ministerial or inter-institutional basis so that all concerned national departmental and

stakeholder interests are represented and all relevant substantive areas are addressed" (SAICM

OPS, Para. 23).

SAICM provides valuable opportunities to build upon these activities and develop a long-term

strategic approach at the national level towards reaching the WSSD 2020 goal for sound

chemicals management. Such a strategic approach for national management of chemicals

would need, as called for by SAICM, action by government and non-governmental stakeholders

(including the business sector and non-governmental organizations), as well as between two or

more players involved in chemicals management.

1.2. Background on SAICM

The SAICM development process, which started formally through a series of sessions of a

Preparatory Committee ("PrepComs") commencing in 2003, included a number of key

milestones, including:

UNEP Governing Council, February 2002

World Summit on Sustainable Development, Johannesburg, September 2002

World Health Assembly, May 2003

International Labour Conference, June 2003

World Summit, New York, September 2005

SAICM PrepComs 1, 2 & 3

First session of the International Conference on Chemicals Management (ICCM),

February 2006

The development process was multi-sectoral and multi-stakeholder in nature, involving

representatives of governments, non-governmental organizations (NGOs) and

intergovernmental organizations (IGOs) drawn from sectors such as agriculture, environment,

health, industry, and labour. UNEP, the Inter-Organization Programme for the Sound



Management of Chemicals (IOMC), and the Intergovernmental Forum on Chemical Safety

(IFCS) were co-conveners of the process.

Development of SAICM culminated with its adoption by the International Conference on

Chemicals Management (ICCM) at its first session, which was held in Dubai in February 2006.

SAICM consists of three core documents (see below), supplemented by four resolutions

adopted by the ICCM on implementation arrangements, the Quick Start Programme, a tribute

to the Government of the United Arab Emirates and on the IFCS. It is expected that the

second session of the ICCM will be held in 2009 in order to review implementation and take

stock of progress.

1.3. Overview of SAICM Outcomes and Decisions

The overall objective of the Strategic Approach is to support the achievement of the 2020 goal

agreed at the 2002 Johannesburg World Summit on Sustainable Development (WSSD). The

main outcomes of the SAICM process are three key documents:

i. Dubai Declaration on International Chemicals Management

The Dubai Declaration, adopted by Ministers, heads of delegation and representatives of civil

society and the private sector, provides an agreed overview of the political commitments made

for SAICM. It reflects their "firm commitment to the Strategic Approach and its

implementation." In particular, in reinforces the importance of issues such as the linkage of

sound chemicals management to sustainable development and poverty eradication,

contribution of SAICM to the MDGs (Millennium Development Goals), implementation of

international agreements, and the roles of non-governmental stakeholders and importance of

partnerships.

ii. Overarching Policy Strategy (OPS)

The OPS provides information on the scope of SAICM, identifies needs for effective SAICM

implementation, and outlines objectives, principles, and financial and implementation

arrangements. The five categories of SAICM objectives found in the OPS are:

Risk reduction;

Knowledge and information;

Governance;

Capacity-building and technical cooperation; and

Illegal international traffic.

iii. The Global Plan of Action (GPA)

The GPA is a more detailed document that outlines proposed work areas, activities, actors,

timeframes, targets, and indicators of progress related to SAICM implementation. The GPA

contains 36 work areas, and 273 activities, structured in accordance with the five categories of

SAICM objectives set out in the OPS. It is recommended for use and further development as a

working tool and guidance document for stakeholders implementing SAICM. Implementation



of the Strategic Approach at the national level (including the initial "enabling phase") is

suggested to include the development of national implementation plans.

Initial capacity building activities for implementation of Strategic Approach objectives are

supported, inter alia, by a Quick Start Programme (QSP).3 The QSP contains a voluntary, time-

limited trust fund, administered by UNEP, and may include multilateral, bilateral and other

forms of cooperation. The objective of the QSP is to "support initial enabling capacity building

and implementation activities in developing countries, least developed countries, small island

developing States and countries with economies in transition" (ICCM Resolution I/4).

1.4. Linkages between SAICM and Agenda 21

From a national capacity building perspective, SAICM gives more specific guidance to

countries for the implementation relevant provisions of Agenda 21, agreed at the Rio "Earth

Summit" in 1992. When adopting Chapter 19, the Heads of State at the Rio Summit

concluded that elements of sound national chemicals management should include the

following:

a. adequate legislation;

b. information gathering and dissemination;

c. capacity for risk assessment and interpretation;

d. establishment of risk management policy;

e. capacity for implementation and enforcement;

f. capacity for rehabilitation of contaminated sites and poisoned persons;

g. effective education programmes; and h.

Capacity to respond to emergencies.

In developing the approach and methodology for the national SAICM capacity assessment, a

practical approach has been taken by building upon and bringing together the core elements

outlined above.

Pakistan is signatory to the SAICM. The Implementation of SAICM in Pakistan will affect a

large number of stakeholders belonging to public, private sectors and civil society along with

interest groups like labour organizations. The IC Wing Ministry of Environment is the focal

point for implementation of SAICM in Pakistan which is striving to carve out a way forward in

consultation with major stakeholders. First consultation with civil society organizations was

held on 14th November 2008. First meeting for establishment of Inter-Ministerial

Coordination Mechanism was held on 3rd January 2009. International Coordination has been

established through UNITAR (United Nations Institute for Training and Research). A

UNITAR Mission arrived in Pakistan from 19-27 January 2009 which held discussions with the

Federal Minister, Secretary, Additional Secretary and Joint Secretary Ministry of Environment

as well as with some other stakeholders such as Pak EPA and FBR etc. The Mission discussed in

detail the possible course of action and possible pitfalls with the National SAICM

Coordinator /National Project Manager MEAs Secretariat. Meeting of National Technical



Advisory Committee on Chemicals (NTACC) was held on 21st April 2009 which made

decisions on regulating manufacture, import, export and use of various chemicals falling under

international conventions.

The initial consultations built consensus that following actions need to be taken on priority for

the development of an action Plan for integrated chemicals management in Pakistan: 1.

Development of a National Chemicals Profile.

2. Capacity Assessment for Implementation of SAICM

3. Mass Awareness through Civil Society organizations about harmful effects of chemicals on

daily life of citizens with special reference to labour working in industries and agriculture.

National Profile Preparation

Assessing and diagnosing the existing infrastructure for the sound management of chemicals is

an important step towards building national capacity in a systematic way and is also an

important element of preparing for SAICM Implementation. In order to provide baseline

information about existing chemicals management infrastructure and activities, the National

Chemical Profile was prepared through an extensive consultative process with the stakeholders

from across the country. These stakeholders are involved in activities related to chemical life

cycle. The National Chemical Profile has provided us a broader understanding of the current

situation related to chemical life cycle i.e. production, import, export, transport, storage, use

and disposal. It has also provided with the information about ministries/agencies which are

involved in the field of chemicals management, and their respective roles, mandates, existing

legal instruments, technical infrastructure, coordination mechanism and data available related to

chemicals in Pakistan.

Capacity Assessment and Priority Setting

As called for by ICCM in relation to the SAICM QSP, an important enabling activity for

national SAICM implementation is the development of a capacity assessment (including

identification of priorities) as an essential step towards preparing a SAICM implementation

plan.

2. National SAICM Capacity Assessment

2.1. Objectives

Building on the information in a National Profile and other sources, the capacity assessment is

intended to document and evaluate existing national capacities of Pakistan for SAICM

implementation. Specific objectives of the Assessment include the following:

to catalyze a process of collaboration between government and stakeholders towards

understanding and identifying priority needs for SAICM implementation;

to facilitate identification of action in government and within stakeholder groups

which collectively contribute to SAICM implementation;

to identify selected areas where partnership projects between government and

stakeholder groups, or between various stakeholder groups, may be feasible; and



To set the stage for preparation of a SAICM Implementation Plan which is linked to, as

appropriate, an integrated national programme for sound chemicals management.

The Overarching Policy Strategy (OPS, paragraph 2) of SAICM calls for the involvement of

government and all relevant non-governmental stakeholder groups. While developing the

capacity assessment, the involvement of various stakeholder groups has been considered, for

example, industry, labour organizations, environmental and health NGOs, research and

academia, etc. In this regards the guideline developed by UNITAR have been followed.

2.2. Main Components of SAICM Capacity Assessment

National Capacity Assessment for sound management of chemicals involves two main

components:

i) An assessment of the national governance frame work

ii) An assessment of capacities for selected chemical issues and priorities

2.3. Assessment of the Governance Framework

Development of a governance framework for SAICM implementation is very significant for

sound management of chemicals. Sound governance can provide an important enabling

platform which can help to ensure that chemical management activities are effectively planned

and co-ordinated, that working relationships for government and stakeholders in SAICM

implementation are in place, and that chemical management issues are "mainstreamed" in

national development planning. An assessment of governance issues and taking action where

needed can assist in ensuring that there is high-level support to implement SAICM and provide a

basis for developing a coordinated national programme for SAICM implementation.

2.3.1.

i.

ii.

iii.

iv.

v.

Areas for Governance Assessment

Integrating chemicals management into national development priorities

Sound institutional and programmatic national framework

Effective project planning, implementation, monitoring, and evaluation

Legislation and enforcement

Participation of private sector and civil society in chemical management

For each of the five issues during the assessment information was collected on the following;

i. Strength of existing capacities (high, medium, low)

ii. Existing gaps or problems iii.

Possible action

iv. Level of Priority

The worksheet in Annex 1 has been developed to assist in compiling and analyzing the above

information. Activities related Global Plan of Action (GPA) has been considered while making

the assessment.



2.3.1.1. Mechanisms for Integrating Chemicals Management into Development

Priorities

Strengths:

The backbone of Pakistan's environmental protection system is Pakistan Environmental

Protection Act (PEPA) 1997, which provides a comprehensive legislative authority to address

the range of environmental issues with its jurisdiction over all environmental mediums and

grant of broad powers to regulatory bodies to implement any rules developed under the act.

Under the provisions of PEPA various rules have been made and implemented for national

environmental quality standards, pollution charge for industry, environmental sampling,

sustainable development fund, environmental impact assessment of development projects and

establishment of environmental tribunals.

Under the PEPA the federal government has the authority to delegate any of its environmental

management functions and powers to provincial governments, government agencies, or local

authorities. Provincial governments in turn may delegate powers to any lower-tiered

government agency. This provision establishes a framework for environmental federalism

within which environmental management responsibilities are shared among federal, provincial

and local governments.

The ministerial setup required for sound chemical management is well established with clearly

defined mandates. No new ministry is required exclusively for chemicals management. Beside,

due attention has been given to the pests and pesticide management in national and provincial

sustainable development strategies and poverty reduction paper of Pakistan. SAICM is being

implemented and the National Chemical Profile has been prepared and capacity assessment is

being carried out which will be followed by National Action Plan.

Socio-economic data which is essential for chemical life cycle management is primarily collected

and analyze by Federal Bureau of Statistics FBS. These data are collected from primary and

Secondary Sources. The primary data are collected through different surveys such as Labour

Force Survey (LFS), Household Integrated Economic Survey (HIES), Pakistan Integrated

Household Survey (PIHS), and Pakistan Demographic Survey (PDS) etc. Secondary data such

as Foreign Trade Statistics, Industrial Statistics, Transport and Communication Statistics,

Social Statistics, Agriculture Statistics, Environment statistics etc. are collected from the records

of concerned Ministries/Departments.

Gaps:

According to the Principle 16 of the Rio Declaration there is a need to promote the

internalization of the environmental costs and the use of economic instruments. Adaptation of

such approaches is required that polluter should bear the cost of pollution, with due regard to

the public interest and without distorting international trade and investment.



There is a lack of harmonized national chemical information system in Pakistan. Usually the

information is collected for various other purposes on different parameters and synthesis of

such data is difficult for chemical management. There is no inventory system related to

chemical accidents, chemical poisoning cases, drinking water contamination, food

contamination, hot spots of chemical pollution, stocks and storage sites of obsolete chemicals,

transportation and storage of chemicals, required for chemical management.

Although pest and pesticide management have been included in the national poverty reduction

strategy paper but the capacity building for sound management of chemicals in general is not

included. There is a limited coordination between policy makers industry and in policy making

process. The capacity to undertake social and economic impact assessment of chemical

production and use is also low in the country.

There is a dire need of integrating capacity building policies for sound management of

chemicals within ministries involved in chemical life cycle. Generally the capacities of

government institutions in terms of technical human resource, financial resource and

infrastructure are limited. The capacity building for sound management of chemicals in general is

not included in the national poverty reduction and strategy paper and country assistance

strategies.

2.3.1.2. A Sound Institutional and Programmatic National Framework

Strengths:

A multilateral approach is being adopted for chemical management in the country through

implementation of SAICM. For the implementation, the focal points are well defined, their

duties are laid down and implementations are at various stages. NTACC has a cross sectoral

representation and will be playing a vital role in technical guidance and decision making

process in future. At present some resources have been provided for implementation of various

Chemical Conventions under National Development Framework.

Chemical management in Pakistan is done through a well defined governmental structure

where responsibilities and mandates of various ministries, agencies, and attached departments

related to different aspects or categories of chemicals are defined through these legal

instruments. By acts enacted by the parliament, specific institutions have been created and

their authorities and powers have been defined to manage chemicals.

Officials of ministries and government agencies often attend training courses, seminars,

workshops on policy issues, legal framework and environmental management in general. Trade

organizations/ chambers of commerce also participate in activities organized by ministries and

other government institutions. A multi-stakeholder approach was adopted while preparing

National Chemical Profile and Action Plan. This involved stakeholders from all relevant

ministries, government departments, NGOs, CSOs, and industry.



Trade organizations are playing an important role in implementation of international voluntary

initiatives like ISO etc. Few NGOs and trade organizations are also involved in information

dissemination and policy analysis. Industries are cooperating to some extent in Pak-EPA's

SMART programme and playing some role in raising public awareness. Integrated pest

management strategies have been developed and implemented in the country. E-government

has been established for the fast pace communication system within the government, for public to

government as well as with other countries.

Gaps:

Globally Harmonized System of Classification and Labelling of Chemicals (GHS) are yet to be

implemented in Pakistan. National information system related to chemical life cycle and global

information network at national level for delivery of chemical safety information are not

present.

Government departments have low capacities to implement integrated pest management

strategies at grass root level due to lack of financial and technical capacities. The cooperation

and coordination among ministries is also lacking. There is a very limited interaction of trade

organizations with inter-governmental institutions. Despite considerable role in awareness

raising and implementation of voluntary programmes, there are no initiatives taken by trade

unions and NGOs for capacity building and development of expertise for sampling, testing and

research on environmental pollution caused by industrial processes. There is a need to create

some mechanism of standardizing NGOs so that they can play some vital role in monitoring

and inspections.

The role of women is limited in chemical management especially in agriculture sector due to

lack of awareness. Moreover, there is no harmonized data collection system, inventory and

reporting system. Information network for early warning systems, for cross-boundary movement

of hazardous substances and chemical waste is lacking. Preliminary hazard analysis and

guidelines for hazard identification for government institutions, industry, importers and

exporters are also absent. Storage facilities are devoid of any health and safety measures.

Clearing House Mechanism is not present in the country. Access to updated information in

government departments and industry is difficult for academia and common public.

There is no global information network established for early warning systems regarding cross-

boundary movement of hazardous chemicals in Pakistan. Such system may be developed with

help of UNEP, ILO, WHO, and FAO etc.

2.3.1.3. Effective Project Planning, Implementation, Monitoring and Evaluation

Strengths:

To give due attention to environmental issues and sustainable development projects in the

country funds are allocated in annual, Medium Term and Long Term Development

Framework.



Gaps:

The capacities of Planning Commission and provincial departments to plan projects relevant to

management of chemicals are generally very low. The main constraints to project

implementation are the lack of capacities of government departments due to lack of technical

knowledge, poor infrastructure, and limited experienced human resource. Beside these, the

funds are often diverted to cater other urgent needs due to financial crunches.

The targeted chemical risk assessment approach is seldom seen in major development projects.

The capacity and technical knowledge regarding the monitoring of priority contaminants is

generally low. There is a lack of evaluation of socioeconomic and chronic impacts of chemicals

used in different sectors. The disaster management, development planning and environmental

management institutions operate in isolation. There is dearth of knowledge and limited

capacity of hazard identification, risk assessment & management, and linkages between

livelihoods and disaster preparedness related to chemical accidents, within disaster

management bodies.

2.3.1.4. Legislation and Enforcement

Strengths:

Pollution prevention concept is present in various legislations and environmental policies e.g.

Pakistan Environmental Protection Act. Stockholm Convention, Rotterdam Convention, Basel

Convention, ILO conventions and IMO conventions related to chemicals have been ratified

and are being implemented in the country. The implementation plans have been made,

whereas focal points are established and working for implementation of multilateral

environmental agreements related to chemicals.

Pollution prevention concept is present in various legislations and environmental policies.

Pakistan Environmental Act clearly defines pollution prevention and need to implement

programmes and activities to control chemical pollution. There exists sufficient legislation

related to different aspects of life cycle of chemicals, especially with reference to import, export

and production. No new laws are required but certain amendments are urgently required to

address the priority issues identified for chemical management in the country.

For promoting private-public partnerships in the sound management of chemicals and wastes,

National Technical Advisory Committee on Chemicals is established consisting of members

from public as well private sector.

The relevant international instruments on chemicals and hazardous waste e.g. Stockholm

Convention, Rotterdam Convention, Basel Convention, ILO conventions and IMO

conventions have been ratified and are being implemented in the country. Their

implementation plans have been made in most cases.



Gaps:

Most of the existing legislation was not enacted for the specific purpose of chemical life cycle

management in particular e.g. Carriage of Goods by Sea Act, The Motor Vehicle Act, The

Railways Act, Explosive Substances Act, Mines Act, fatal Accidents Act, does not cover all

aspects of chemical management. Therefore their environmental content is ancillary.

There does not exist any law directly related to transport and storage, use and disposal of

chemicals. Explosive act is present but that too does not cover all aspect of chemical handling

and safety. Legislation related to consumer chemicals including food product is very poor. This is

causing serious health hazards due to uncheck use of chemicals in consumer and food

products.

Penalties for environmental offences are generally punitive rather than reformatory. The

approach is counterproductive since punishment may induce future restraint but it does not

rectify the damage committed. For any law to be successfully implemented the penalty must be

stringent enough to deter the felon. A fine of Rs. 500 on an industrialist for discharging his

units' industrial waste in the nearby stream may provide no deterrence.

The cases of adulterations in chemicals, if any are dealt with under the pure food rules.

Similarly, no specialized legislation exists to control the import, production, storage,

transportation, distribution, use/handling of any kind of chemicals except that the

disposal/handling of toxic and hazardous substances are dealt with under the Pakistan Penal

Code and the Explosives Act, 1884 and Hazardous Substances Rules, 2006.

The effectiveness and enforcement of regulatory framework is very poor. The major drawbacks

are with the inspections, monitoring, vigilance and public awareness. There is a serious lack of

trained technical human resource in every related department. This can be enhanced with the

properly accredited NGOs for such purpose.

Pakistan, at present, like many developing countries of the world, does not have comprehensive

occupational health and safety laws. The incidence of injuries and illnesses is probably very

high in Pakistan because thousands of workers are routinely exposed to hazardous chemicals in

many industries and agriculture. However, there is no reliable data on occupational safety and

health injuries and illnesses because a majority of accidents are not reported to the regulatory

agencies. The regulatory agencies do not have an effective enforcement policy or strict

requirements for reporting injuries and illness at workplaces.

An overview of current laws/regulations related to occupational safety and health shows that

there are several laws on the book, such as Factories Act, 1934; Provincial Factories Rules;

Hazardous Occupations Rules, 1963; Mines Act, 1923; West Pakistan Shops and

Establishments Ordinance, 1969; Provincial Employees Social Security Ordinance, 1965;

Workmen's Compensation Act, 1923 and Dock Labourers Act, 1934. The current regulations

are, however, fragmented and there is no single comprehensive piece of legislation dealing with

occupational safety and health.



There is no formal legislative process for setting up new standards, codes of practice and

occupational exposure limits. Whatever exists on the book is frequently hampered with

repeated martial laws. The current outdated Factories Act, established in 1934, requires only a

very basic level of safety and health measures. There are no guidelines for minimum

qualifications or employment of health and safety professionals in the industry. Several

important sectors, such as agriculture, construction and informal/self-employed are not even

covered under any law.

Although, several occupational diseases, such as anthrax, Byssinosis, compressed air illness,

poisoning by lead tetraethyl, poisoning by nitrous fumes, lead poisoning, phosphorus

poisoning, mercury poisoning, poisoning by benzene & homologues, chrome ulceration,

arsenic poisoning, pathological disorders due to X-rays, radium or radioactive materials,

primary epithliomatous cancer of skin, silicosis, etc., are covered under the Social Security

Ordinance and Workmen's Compensation Act but the reporting mechanism is so poor that

very few get the benefits.

The implementation of existing environmental laws, policies, international conventions,

programmes and activities is low due to low level of technical and financial capacities of law

enforcing institutions, lack of proper infrastructures, limited knowledge of FAO and WHO

specifications on pesticides among decision makers and low level of awareness and knowledge of

life cycle management concept among environmental managers.

There is a need to develop national strategies for prevention, detection and control of illegal

traffic, including the strengthening of laws, judicial mechanisms and the capacity of customs

administrations and other national authorities to control and prevent illegal shipments of toxic

and hazardous chemical.

The Representation of ministry for Petroleum & Natural Resources, Labour, Railway,

Communication, Ports & Shipping, National Disaster Management Cell, and Rescue 115

Service is lacking in NTACC. The participation of academia, heads of departments of chemical

technology, chemistry and environmental sciences of the major universities of the country may

also be included in the committee.

A sustainable financial mechanism for capacity building of institutions is lacking consisting of

incentive measures for skilled human resource. The same is also required for introduction of

new technologies. We need also to consider approaches to facilitate and strengthen synergies

and coordination between chemicals and waste conventions, including by developing common

structures. In this regard pilot projects to pursue implementation of coordination between the

national focal points of chemicals-related multilateral environmental agreements (Rotterdam,

Stockholm and Basel Conventions and Montreal Protocol) may be developed to achieve

synergies in their implementation. At present Pakistan has limited technical as well as financial

capacities to implement these conventions.



There is a low capacity of agencies responsible for compliance and accountability and effective

enforcement and monitoring programmes. There is a little development and application of

economic instruments for pollution control. The economic incentives should be given to

industries to reduce their waste emission and proper disposal of wastes.

The measures taken to encourage sustainable and cleaner production technologies, in

particular best available techniques and best environmental practices (BAT/BEP) are

ineffective so far and their impact is very little. These technologies are very expensive therefore

need special incentive measures to promote these technologies in the industry.

2.3.1.5. Participation of the Private Sector and Civil Society in Chemical

Management

Strengths:

There are a large number of non-governmental organizations and community based

organizations working in the country in areas like consumer protection, environment, natural

resource management, pollution control, labour welfare, health and gender issues etc. These

organizations are working in isolation.

Participation of private sector and civil society in policy making and policy implementation is

very important for chemical management in the country. Although in Pakistan these

stakeholders are playing their role in policy making and implementation process but there

participation is limited.

The private sector and civil society fully participate in meetings, seminars, conferences and

workshops. Some of the important NGOs, CSOs and trade associations are part of

committees made for chemical management. These organizations are playing a vital role in

implementation of international voluntary initiatives like ISO standards 9000, 14000 and

OHSAS 18001. They are also cooperating in Pak-EPA's SMART programme for self

monitoring and reporting.

NGOs have direct linkage with local communities hence their role in dissemination of

information and creating awareness among workers and local population is very effective. They

arrange seminars, workshops, focal groups meetings and interact with common man. NGOs

have right to access to environmental tribunals, labour courts and other similar institutions for

any complaint related communities benefit.

NGOs have the capacities for policy analysis, legislation, and research on alternatives, trainings,

education, data collection/dissemination and raising awareness. Only few NGOs have these

capabilities collectively. The cross cutting capacities are very important to deal with the

chemical management in the country.

Gaps:



A good number of NGOs and CSOs are working for environmental issues but there is no

NGO, CBO, working exclusively for chemical management in Pakistan. There role is indirect.

NGOs and CSOs require capacity building in chemical management exclusively. There is very

little coordination among these organizations and government agencies. There is need to

develop a framework to promote the active involvement of these non-governmental

organizations, CSOs, managers, workers and trade unions in all enterprises - private, public

and civil service (formal and informal sector) - in the sound management of chemicals and

wastes.

There is a need to create some mechanism of standardizing these organizations so that they can

play some vital role in monitoring and inspections. Once some mechanism for accredit non-

governmental organization is brought in they can play better role in dealing with

environmental issues.

Through an innovative consultation processes, such as mediated discussions, with the help of

private sector, NGOs and CSOs, efforts should be made to find common ground and

agreement among affected sectors of society on critical issues that impede efforts to achieve the

sound management of chemicals.

There should be a broader representation of civil society and private sector in National

Technical advisory Committee on Chemicals (NTACC), carrying out and monitoring SAICM

implementation plans.

Private sector should be encouraged for use of voluntary initiatives (e.g., Responsible Care and

FAO Code of Conduct) to promote corporate social responsibility for the safe production and

use of all products, including through the development of approaches that reduce human and

environmental risks.

2.4. Assessment of Capacities for Important Chemicals Management Issues

The assessment of chemicals management capacities includes specific chemical management

issues such as chemicals information generation and dissemination, risk reduction, import

control, etc.

2.4.1

i.

ii.

iii.

iv.

v.

Areas for Chemical Management Assessment

Information Generation and dissemination

Risk reduction

Education and Awareness raising

Accident Prevention and Control

Analytical and Laboratory Capacity

While doing assessment of chemical management issues, classification and labelling, safe

handling and use of pesticides, training and chemical accidents have been considered



important areas. For each of the five issues during the assessment information was collected on

the following;

i. Strength of existing capacities (high, medium, low)

ii. Existing gaps or problems iii.

Possible action

iv. Level of Priority

The worksheet in Annex 2 has been developed to assist in identifying the priorities of the

various issues. The activities included in SAICM GPA have been considered while doing

Chemical Management Assessment.

2.4.1.1. Information generation and dissemination

Strengths:

Pakistan has implemented "Harmonized System" (HS) of nomenclature to assign specific HS

codes to individual chemicals or group of chemicals listed in Annex III to the Rotterdam

convention, adopted by World Customs Organization in June 2004. The HS Code system is a

system of progressively more specific identifiers for a commodity.

EPA has setup emission inventory system in major cities. Pesticides residue research centers

have been established in various cities in the country. Eco-toxicology centre has been

established at NARC. A programme is being implemented through it to monitor pesticide

residues in food and the environment.

At present few toxicology centers are working in Karachi, Faisalabad Multan and Islamabad.

Other facilities associated with many hospitals are just treating the poisoning cases

Gaps:

Chemicals, through their life cycle, i.e. production, import, export, transport, use, storage and

disposal pose a real danger to human health and environment. People of any ages, from

children to elderly, using many different languages and alphabets, belonging to various social

conditions, including illiterates, are daily confronted to dangers of chemicals and pesticides. To

face this danger and keeping in mind the extensive global trade in chemicals and need for safe

handling of these chemicals through their life cycle, a new system "Globally Harmonized

System for Classification and Labelling of Chemicals" (GHS) has been introduce. This system

addresses classification of chemicals by types of hazards, and proposes harmonized

communication elements including labels and safety data sheets. GHS aims at ensuring that

information on physical hazards and toxicity from chemicals is available in order to enhance

the protection of human health and environment during chemical life cycle. The third revised

edition has been published on GHS has been published in July 2009.

GHS is not implemented in Pakistan and the present capacities for its implementation in

Pakistan are very low. In fact there is a very little knowledge about GHS in Pakistan. In this



regard, GHS awareness-raising, training and capacity-building, GHS action plan development,

national situation analysis and implementation plan should be developed on priority basis.

A key component of the sound management of chemicals, and one required in many

international agreements, is the capacity to gather information. This is also a priority area in

many developing countries. Information gathering and systemization may take the form of

chemical inventories or lists, supplemented by a means for disseminating the gathered

information (information exchange). This can be done by developing separate inventories of

chemicals or emissions, or consolidate the efforts within more integrated approaches such as

the development of Pollutant Release and Transfer Registers (PRTRS). Pakistan has to yet

initiate its toxic releases inventory (TRI) or National Pollutant Release Inventory (NPRI). Such

inventories should include industries, residential, transportation, incineration, roads, forest

fires and more. Pollutants from mobile sources such as trucks and cars, households, facilities

that release pollutant on smaller scale by certain sectors such as agriculture, education, and

mining activities may also be included.

Pakistan has low capacities for assessment of exposure to different chemicals. There is a need

for setting priorities for action for determining the impact of chemicals on human health. A

mechanism has to be established to share and disseminate information that can be used to

reduce uncertainty in risk assessment. Health surveillance programmes should be established

with more poisoning information and control centers and systems for data collection and

analysis and enhance the capacity of present facilities. The pesticide monitoring facilities are

present in the country in some regions but their technical capacities should be enhanced.

At present few toxicology centers are working in Karachi, Faisalabad Multan and Islamabad.

Other facilities associated with many hospitals are just treating the poisoning cases. Eco-

toxicology centre has been established at NARC. These facilities are often facing shortage of

trained human resource and technical facilities. Collection of data is very poor on the use

patterns of chemicals to support risk assessment characterization and communication. There is a

need to develop objective indicators for evaluating the influence of chemicals on human

health and the environment.

Institutional as well as individual capacities in Pakistan for risk assessment of chemical use and

exposures are poor. Very few studies have been made by individual efforts but without

developing indicators. There is a need to develop training and guidance programmes to assist

in the preparation of initial national assessments of groups of chemicals posing risk for human

health and the environment, including, persistent bio-accumulative and toxic substances,

(PBTs); very persistent and very bio-accumulative substances; chemicals that are carcinogens or

mutagens or that adversely affect, inter alia, the reproductive, endocrine, immune or nervous

system; and persistent organic pollutants (POPs), children's environmental health, and the

identification of priority concerns.



Infrastructure for research that may reduce uncertainty in risk assessment is required in related

organizations. There is a big gap in scientific knowledge for risk assessment among concerned

people. Public organizations as well as NGOs should develop a general framework for capacity

building in risk assessment in order to improve understanding of the impact of natural

disasters on releases of harmful chemicals and resulting human and wildlife exposures, as well

as possible measures to mitigate them.

2.4.1.2. Risk Reduction

Strengths:

Programme for integrated pest management is being implemented. EIA has been made

mandatory for all development projects. Chemicals listed in Rotterdam Convention have been

banned in Pakistan. Lead has been eliminated from gasoline where as mercury programme is

being implemented in the country. Pesticide registration and control system has been

established which controls risks from the initial point of production and formulation.

Few studies have been conducted to identify obsolete Pesticides contaminated sites under the

implementation of Stockholm Convention. Very limited facilities for remediation of

contaminated sites and disposal of obsolete chemicals exist in some major cities in Pakistan.

Gaps:

There is lack of preventive strategies for chemical safety and targeted risk assessment approach

in the country. FAO International Code of Conduct on Distribution and Use of Pesticides is

not being fully implemented. Pesticide registration and control system does not control the

disposal of obsolete products or containers. Few studies have been conducted to identify

obsolete Pesticides contaminated sites under the implementation of Stockholm Convention.

There are limited facilities, know-how and technical expertise available for remediation of

contaminated sites and disposal of obsolete chemicals. Integrated pest management programme is

being implemented but there is no integrated vector management programme.

Present legislation related to health and safety of workers at their workplace is insufficient.

There is a lack of health impact assessment system in development activities. Occupational

health & safety policies are also not present in the country; therefore, there is lack of training

and sensitization on chemical safety for those exposed to chemicals at various work places. The

existing legislation does not cover the entire spectrum of work situations in which chemicals are

handled, including such sectors as agriculture and health, to protect the health of workers and

the public.

Existing system of health and environmental impact assessment in chemicals handling is poorly

managed such assessments should be incorporated in occupational safety and health

programmes. ILO safe work standards, ILO guidelines on occupational safety and health

management system (ILO-OSH 2001) are poorly implemented in industry in Pakistan. The

chemical life cycle management approach is lacking in national occupational safety and health

policies. Integrated health and safety programmes for public health and safety practitioners and



professionals with an emphasis on identification, assessment and control of occupational

chemical risk factors at workplaces in industry as well as agriculture are established only in few

enterprises.

Workers are exposed to chemicals in most of the small and medium enterprises. They are not

provided with appropriate protective equipment. There does not exist national inspection

systems for the protection of employees from the adverse effects of chemicals and to encourage

dialogue between employers and employees to maximize chemical safety and minimize

workplace hazards. The role of Public media is limited in chemical-safety-related information

dissemination among general public.

The know-how and technical expertise are not available for remediation of contaminated sites

and disposal of obsolete chemicals. There are few incinerations facilities present in some

hospitals operated by private sector. The Waste disposal plans have been prepared and in some

cases under implementation in few major cities of Pakistan.

The monitoring mechanism for chemical impacts of dumps and landfills and waste facilities on

human health and national strategies for prevention, detection and control of illegal trans-

boundary movements of waste are also lacking.

2.4.1.3. Education and Awareness Raising

Strengths:

The education related to chemistry, biochemistry, chemical engineering and chemical

technology is well established in nearly all universities in Pakistan in public as well as private

sector. Chemistry is taught as a compulsory subject in schools and as elective in colleges.

Workshops, seminars and lectures are arranged on chemical issues and pollution in public

organizations as well as by NGOs. Health and safety awareness raising measures are taken in

large enterprises especially in multinational organizations. Ministry of Environment celebrate

Environment Days and walks are arranged for awareness of common public on environmental

issues.

Gaps:

With reference Chapter 19, Agenda 21, a national Chemical Information system is required by

standardization of chemical information on electronic data interchange formats according to

UN EDIFACT procedures. Pakistan is lacking such harmonized chemical information and

dissemination system. There is no Toxic Releases Inventory (TRI) or National Pollutant

Release Inventory (NPRI) system developed with free access to general public in the country.

There is also no national inventory system for chemical use, transport, storage and disposal.

Chemical risk assessment and chemical hazard assessment studies and chemical life cycle

management issues and requirements are not included in university curricula. At present, there

are no degree programs in the environmental health and safety (EHS) discipline in the country.



Few institutions, such as the Institute of Public Health, Lahore, and the University of Lahore,

however, offer some basic courses. Also, there are no guidelines on EHS core curriculum at

national level.

Several limitations have prevented the development of occupational health and safety (OHS)

culture in the country. The lack of formal education, absence of a national focal institution for

providing training and advisory services, lack of strict requirements by the enforcement

agencies for authentic data collection and reporting, lenient enforcement of the law, lack of

technically qualified personnel for inspection services that can recognize and evaluate

occupational hazards, lack of Inter-agency coordination at the government level, inadequate

funding for OSH programs and limited expertise at the policy making level, as well as illiteracy of

the workforce are some of the handicaps which have inhibited growth of safety culture.

These issues need to be addressed before OSH culture can establish its roots in Pakistan.

There are limited opportunities for trainings of people at risk to chemical exposure on safe

handling of chemicals, policy makers and planners. In small industries workers are

uninformed of the hazards posed by the chemicals they are using at their workplace. Illiteracy

and poverty are the main causes among others for it besides the lake of capacities and

knowledge of law enforcing agencies. There are no measures taken for awareness raising of

waste handlers and small-scale recyclers from the hazards of handling and recycling chemical

waste across the country.

Training opportunities needed to develop capacity in legislative approaches, policy

formulation, analysis and management, to detect and prevent illegal traffic in toxic and

dangerous goods and hazardous wastes, cleaner production techniques and to create linkage

between trade and environment, including needed negotiating skills are required.

R & D organizations have very few training programmes for necessary testing of chemicals for

their management across their life cycle. The know-how of technical manpower engaged in

these organizations is limited for safe handling and chemical management issues. The

capacities and know-how of emergency response agencies is poor in dealing chemical disasters.

Moreover, the knowledge for cleaner production technologies is low.

Awareness of consumers, in particular on best practices for chemical use, about the risks that

the chemicals they use pose to themselves and their environment and the pathways by which

exposures occur is low. Consumers are always at risk of chemical hazards posed by preservatives

and other chemicals used in food items.

2.4.1.4. Accident prevention and control

Strengths:

National Disaster Management Commission (NDMC) headed by the Prime Minister and the

National Disaster Management Authority (NDMA) has included Industrial/Chemical

Accidents Contingency Plan in its major initiatives. NDMA has been mandated to established



technical committees to assist local, provincial or national authorities in identifying issues and

problems and devising solutions in areas like, Industrial and mines accidents, Major

transportation accidents, Marine disasters, including oil spills, Nuclear, chemical, biological

and radiological accidents, Urban and forest fires, etc.

Roles and responsibilities described in this part refer to functions that are expected to be

performed by concerned stakeholders with relation to disaster risk reduction, preparedness,

response and recovery after disasters. The Ministry of Environment is responsible for following;

Develop disaster risk management plan for risk reduction and response with relation to

Ministry's mandate;

Incorporate Natural Disaster Risk Assessment in the Environmental Impact Assessment

guidelines;

Develop technical capacities of the staff of ministry to undertake disaster risk

assessment and disaster risk reduction activities in the environment sector;

Undertake assessment of vulnerability of natural resources (forest, lakes, streams,

mangroves, coral reefs, protected areas, coastal areas) to natural and human induced

hazards;

Implement programmes for conservation and rehabilitation of natural resources in

order to reduce risks of natural hazards; e.g. reforestation, mangrove plantation,

combating desertification, conservation of special natural resources; e.g. wetlands, lakes,

reefs, mangroves, and coastal areas;

Allocate resources for implementation of programmes to conserve and rehabilitate the

natural resource base, particularly in up-stream areas of the Indus River basin;

Develop mechanisms for assessment of environmental losses and damages in the

aftermath of disasters and their rehabilitation;

Ministry of Industries, Production and Special Initiatives is responsible for following;

Develop disaster risk management plan with regards to the mandate of the Ministry;

Develop guidelines for industrial sector to ensure safety of industry and its production

processes in hazard-prone areas;

Establish systems to monitor implementation of guidelines by industrial sector;

Develop system of incentives and disincentives for industry to promote application of

disaster safety;

Implement awareness raising programmes for industrial sector including Chambers of

Commerce and Industry (CCI) on integrating disaster risk assessment and vulnerability

reduction in project planning and implementation stages;

Prepare inventories of industries based upon the type of chemicals and raw materials

used in their products and the dangers posed by various types of industries;

Initiate demonstration programmes on industrial disaster preparedness;



Develop safety codes for all industries to reduce risks of industrial and chemical hazards

and to ensure vulnerability reduction from natural hazards;

Develop SOPs for emergency response to industrial disasters;

Develop physical capability to manage all types of likely industrial disasters including

chemical disasters;

Monitor and encourage implementation of safety codes in industry;

And Ministry of Petroleum and Natural Resources is required to;

Develop disaster risk management plan with regards to the mandate of the Ministry;

Develop guidelines for safety in oil/gas, fire and mining sectors;

Integrate risk assessment and risk reduction in planning and implementation of

projects in the above sectors;

Implement awareness raising programmes for staff in the oil, gas, fire and mining

sectors;

Develop SOPs for emergency response to disasters in the above sectors;

Through the Geological Survey of Pakistan (GSP) conduct research on hazard mapping

and produce user friendly maps;

Gaps:

There is no formal or informal mechanism in place to investigate a chemical incident and its

outcome in the country, a standardized format for collecting the information about the

incident should be developed by the Pak-EPA. Investigations leading to a formal enquiry about

the causes and responsibilities of various parties involved are often made these investigations

never lead to a follow-up activity, in general. The record for chemicals incidents and disasters

is never kept in organized manners at any agency. The do not exist any follow-up surveillance

and rehabilitation mechanism in the health service for exposed persons who may suffer long

term disabilities and sequelae and Government level. Generally some NGOs are involved in

such surveys and rehabilitation activities.

Disaster management in Pakistan basically revolves around flood disasters with a primary focus

on rescue and relief. After each disaster episode the government incurs considerable

expenditure directed at rescue, relief and rehabilitation. The Disaster management related to

chemical accidents though part of framework but still not implemented.

Disaster management, development planning and environmental management institutions

operate in isolation and integrated planning between these sectors is almost lacking. Within

disaster management bodies in Pakistan, there is a dearth of knowledge and information about

hazard identification, risk assessment & management, and linkages between livelihoods and

disaster preparedness. Disaster management policy responses are not generally influenced by

methods and tools for cost effective and sustainable interventions.



There does not exist any mechanism for inventories of installations and transport routes at risk

of chemical incidents. Fire, police and other emergency services does not have specific

equipment, including protective clothing, to deal with chemical incidents and staffs are not

specifically trained for such incidents. There are no chemical hazard identification systems both

in the transport and industrial/commercial sectors except in very few large enterprises.

There are no dedicated chemical emergency services in the country. Only few hospitals have

proper patient decontamination facilities and stocks of antidotes, medicines, and appropriate

equipment for chemical emergencies. But in small towns and agricultural rural areas there are

no such facilities to meet the emergency situation like pesticides poisoning. Health or

emergency services are not properly trained and equipped for transportation of chemically

exposed persons.

There is no special training programme to prepare the emergency services (e.g. fire, police, and

civil defence) personnel in dealing with a chemical incident, as well as medical and paramedical

staff in handling and treating chemically exposed persons. Only in major cities veterinarians

are available and not all of them have enough knowledge/trainings concerning treatment of

exposed animals to toxic substances.

The capacities for remediation of contaminated sites caused by chemical accidents are limited.

The National Disaster Management Plan does not include strategies for chemical

accidents/industrial accidents. In Karachi, Faisalabad, Multan and Islamabad, few poison

treatment and control centers have been established with reasonable technical and monitoring

facilities.

2.4.1.5. Analytical and Laboratory Capacity

Strengths:

For support of national legal instruments, policies and plans related to chemical management,

numerous R & D organizations, institutes and laboratories have been established throughout

the country over the last decades. The main objectives of these facilities are quality control of

chemicals including petroleum products, residue analysis, and research on unknown substances

and monitoring of harmful effects of chemicals. Among them a number of laboratories have

been accredited through National Accreditation Council of Pakistan, where the laboratory

quality standards are being maintained. But still there are other laboratories which still require

certification.

Laboratories established under Pakistan Council for Scientific & Industrial Research (PCSIR)

in Karachi, Quetta, Peshawar, Lahore and Islamabad have capacities for investigation and

R&D on organic, inorganic and microbiological contamination in water, wastewater, foodstuff,

industrial emission, automobile emission and particulate matters analysis, ambient air

monitoring, pharmaceutical chemicals/ products, Plastic and Polymers, marine products, food

products, fuels, leather industry chemicals and for chemical characterization and analysis of



ores and minerals. PCSIR laboratories are also conducting research on industrial wastes

treatment and designing of treatment plants, preparation of environmental impact assessment,

carrying out environmental impact assessment, evaluation / characterization of materials and

wastes, carrying out environment related surveys.

Hydrocarbon development Institute of Pakistan (HDIP) is the sole R & D Institution in energy

sector of Pakistan. HDIP has established state of the art Petroleum Testing Labs for checking of

quality, standards and specifications of hydrocarbons including crude petroleum, petroleum

products, liquefied petroleum gas and natural gas in downstream petroleum sector and

geochemical labs in upstream petroleum sector.

The Geochemical labs in HDIP have facilities for Bitumen Classification, Source Rock Typing,

Gas Analysis by Chromatography, TOC and Rock Eval (S1, S2, S3 and Tmax), Gas

Chromatography of Saturated Hydrocarbons, Biological Marker Analysis by Gas

Chromatography/Mass Spectrometry, Natural Gas Analysis by Gas Analyser, Calorific Value

and Gravity Estimation of Gas by Calculation Method, Compositional Analysis of LPG,

Density Estimation by Calculation Method, Light Hydrocarbon Analysis by Head Space Gas

Analyser.

The Combustion Engineering Labs of HDIP have facilities for study of environmental

pollution for the CO2, CO, Soots, Nitrogen and Sulphur, in ppm level, Exhaust Emission

Study, Energy Conservation Study for the Industries, Study for the Substitute Fuel

Performance in I.C. Engine, Efficiency Monitoring of Domestic Heating Appliances. HDIP has

also expertise in Environmental analysis for Water Portability (Dissolved), Alkalinity,

Conductivity, pH, Chloride, Iron, Bicarbonate, Nitrate, Sulphate, Carbonate, Sodium,

Hydrocarbons, TDS Hardness, Calcium and Magnesium, Water Salinity (Dissolved), Calcium,

Chloride, Magnesium, pH, Potassium, Sulphate, Sodium and Conductivity. Studies for Trace

Elements in Salt/Sediments/Water, Trace Metal Analysis by Atomic Absorption (15 Elements)

are also done.

Industrial Analytical Centre, IAC, (HEJ), Karachi is involved in wide range of chemical

analysis, microbiological testing, food science, biotechnology, pharmacology, and material

testing.

Surveillance of pesticide poisoning is done through National Poisoning Control Center

Karachi at Jinnah Post Graduate Medical Centre Karachi. This centre is acting as a registry,

information investigation, treatment and research centre at Federal level. The provincial

centers at different hospitals are only acting as treatment centers for pesticides cases. The

Nutrition Division of NIH, Islamabad is running programme for quality testing of food and

feed. The pesticide residue study programme was started in 1981 and a project on food

contamination study and control in Asia and Far East was completed.



The Plant Protection Department (PPD) has a network of laboratories throughout the country.

PPD labs are dealing with pesticides formulations being marketed in the country. Pesticide

Chemistry Lab, nuclear Institute for Agriculture and Biology (NIAB), Faisalabad under

administrative control of Pakistan Atomic Energy Agency (PAEA) is conducting pesticides

residue analysis by employing radio labelled techniques for elucidating fate of pesticides in

different agro-ecological conditions.

In addition to these there are some analytical facilities established by private sector which have

capacities to conduct various chemical analysis.

Gaps:

Although education in chemistry, chemical engineering, environmental management and

environmental studies is available in the country but there are no specific course available

related to life cycle chemical management. The additional modules are required in the

curricula of the universities with reference to the chemical management, risk assessment and

risk reduction, waste management, waste treatment etc. Due to lack of qualified and well

trained human resource in related R & D organizations their capacity in above mentioned

areas of chemical management is poor.

Institutional capacities are needed to be strengthened in terms of improved availability of

information, filling gaps in the understanding of chemicals related health issues, risk

assessment methods, protection of vulnerable groups including children, workers and

population in general, promotion of safe alternatives and needs for prevention.

There is a dire need for development of emergency response infrastructures in the country fro

chemical disaster management. The National Disaster Management Plan does not include

chemical accidents response and management plan in it.

The capacities of analytical laboratories are low to medium. Monitoring and analytical

capacities of chemical and social data are low as well. Most of the institutions lack proper funds

to acquire and maintain equipment.

Surveillance of pesticide poisoning is through National Poisoning Control Center Karachi at

Jinnah Post Graduate Medical Centre Karachi. This centre is acting as a registry, information

investigation, treatment and research centre at Federal level. The provincial centers at different

hospitals are only acting as treatment centres for pesticides cases. The existing poison control

centers are insufficient for catering the needs of the large population. There is an urgent need

to increase such facilities with required technical human resource and infrastructure. The

capacity building of existing poison control centers in terms of trained persons and technical

support is also required.



The inter-linkage of National Poison Control Center and Provincial Centers is also very

important. There is a need for coordination mechanism between these centers, registration

authority at Plant Protection Department, and Ministries of Health and Environment.

There is a need for strong National Public Health Pesticides Resistance Monitoring System.

Public health authorities need to be involved in the licensing process of public health

pesticides.

Ministry of Health should be involved in the national information exchange system and strong

public health pesticide management awareness should be done, in collaboration of ministry of

health. To address the poisoning due to different agents, whether acute or chronic, the

integrated and collaborative approach of government, nongovernmental organizations along

with industries and private sector representatives is required.

Most of the Pesticides monitoring laboratories/ institutes conduct research on the efficacy

trials of pesticides and developing pest management packages. Very little attention is paid to

ecological studies. Whereas all the provincial institutes are mainly concerned with the quality

of the pesticides, the institute of Ecotoxicology has gone beyond and is looking into the

residues in crops and food products.

Although some federal and provincial institutes conduct research on fertilizer production, use

and formulating recommendations for improving crop productivity through balanced fertilizer

application, there is no independent institute and /or non-governmental body/entity in

existence to carry out research on detrimental effects of overuse of fertilizers.

The Standard Reference chemicals are very expensive and there availability in the country is

insufficient. The laboratory grade chemicals required for lab analysis are although available in

the country on demand but their quality standards are required to be monitored as the

practices of adulteration is common.



3. Priority Issues Related to Chemical Life Cycle Management in Pakistan

3.1 Priority Issue Related to Governance

i)

ii)

iii) iv)

v)

vi) vii)

viii)

ix)

x)

Insufficient legislation dealing with transportation, storage, use of chemicals and

disposal obsolete chemicals/pesticides as well as protection of health of workers in

their working environment. There is no provision about remediation of

contaminated sites in the laws.

There are certain gaps in implementation of existing environmental laws, policies,

project planning, implementation, monitoring and evaluation due to various factors,

i.e., low capacities of implementing government agencies, lake of proper

infrastructures, lake of funds, lake of trainings, low salary structure, corruption, social

values, socio-economic issues etc.

Poor capacities of government institutions for sound management of chemicals in

terms of technical human resource, awareness, technical know-how, financial

resources and infrastructure.

Penalties for environmental offences are not generally reformatory and stringent

enough to deter the felon.

Pesticide related laws do not control the storage, use and disposal of obsolete

pesticides. Complete FAO and WHO codes for use and disposal of pesticides is not

fully implemented in the country. There is a low level of awareness and knowledge of

life cycle management concept among environmental managers including limited

knowledge of FAO and WHO specifications on pesticides.

Lack of Occupational Health & Safety (OHS) and Environmental Health and Safety

(EHS) policies and laws and protective measures from chemical exposures for workers

at their workplaces.

Disaster management, development planning and environmental management

institutions operate in isolation. There is a lake of preventive strategies for chemical

safety. National Disaster Management Plan does not include strategies for chemical

accidents/industrial accidents and remediation mechanism. The capacities and

technical knowledge for remediation of contaminated sites is poor.

The capacity building for sound management of chemicals in general is not included

in the national poverty reduction and strategy paper and country assistance strategies

Lack of cooperation and coordination among ministries and other related

institutions. Limited coordination between policy makers and industry in policy

making process. Stakeholders from some ministries related NGOs, academia, labour

unions and civil society neither are nor present in NATCC.

Lack of initiatives by trade unions/private sector for capacity building and

development of expertise for sampling, testing and research on environmental

pollution caused by industrial processes. There is a very limited interaction of trade

organizations with inter-governmental institutions


xi)

xii)

xiii)

xiv)

xv)

xvi)

xvii) xviii)


There is a need to create some mechanism of standardizing NGOs so that they can

play some vital role in monitoring and inspections.

The role of women is limited in chemical management especially in agriculture sector

due to lack of awareness and education.

Role of electronic media in dissemination of information about chemical hazards is

very limited especially for consumer products/house hold products containing

hazardous chemicals. In this regards lack of consumer societies for awareness of such

harmful products is another bottleneck.

Limited evaluation of socioeconomic impacts and chronic impacts of chemicals used

in different sectors.

Lack of preliminary hazard analysis system and guidelines for hazard identification for

government institutions, industry, importers and exporters. Hazard information on

chemicals used in industry is seldom displayed. Targeted chemical risk assessment

approach is seldom seen in major development projects.

Globally Harmonized System of Classification and Labelling of Chemicals (GHS) are

yet to be implemented in Pakistan.

Absence of continuous monitoring system for trans-boundary movement of

hazardous waste. Lack of critical infrastructure, trained human resource and financial

resources required for monitoring.

The information management and dissemination system for chemicals is absent in

the country which play a critical role in life cycle management of chemicals. Non

availability of relevant and harmonized data, absence of inventory system and records

by industry as well as related institutions, related to chemical accidents, chemical

poisoning cases, drinking water contamination, food contamination, transportation

and storage of chemicals is the key obstacle to sound management of chemicals

Information regarding unknown chemicals imported which are used in numerous

micro-level units is also lacking.

3.2 Priority Issues Related to Capacities for Chemicals Management

i) Poor technical infrastructure for recycling, recovery and disposal of obsolete

pesticides as well as lack of sustainable monitoring mechanism for obsolete storage

sites of obsolete pesticides

ii) iii)

Inadequate patient poison control/decontamination facilities and stocks of antidotes,

medicines, and appropriate equipment in hospitals for chemical emergencies like

pesticides poisoning. Lack of poison analysis, research and information centres.

Majority of farmers are uneducated and unaware of health and environmental

implications of use of agricultural chemicals like pesticides and fertilizers. Due to

illiteracy farmers do not have access to information about integrated pest

management and proper pesticide/fertilizer use.


iv) v)

vi)

vii)

viii)

ix)


Dearth of knowledge and limited capacity of hazard identification, risk assessment &

management, and linkages between livelihoods and disaster preparedness related to

chemical accidents, within disaster management bodies. The industries do not have

any chemical disaster management plans and training programme developed for

workers. Fire fighting departments do not have necessary facilities/ equipment know-

how to cope with chemical fires.

Lack of degree programmes in universities about chemical management, risk

assessment/prevention, occupational health and safety, environmental health and

safety issues, waste management, waste treatment technologies, cleaner production

technologies and international environmental Conventions and Protocols.

Cleaner production technologies were introduced by the private sector with the

technical assistance of Cleaner Production Center Sialkot few years back especially in

leather tanneries. In order to bring about environmental and economic improvement a

program to promote cleaner production technologies in every industrial sector in Pakistan is

needed. These technologies are very expensive and the there is a limited know-how about

these technologies, therefore incentive should be given and capacity building programmes for

SMEs may be initiated.

Absence of integrated vector control programme and pest management programme.

There are very few poison control and information centers working in the country.

These centers are not fully equipped with necessary technical infrastructure according

to guidelines of IPCS. There is an urgent need of establishment of new poison

control and information centers especially in industrial and agricultural hubs of

Pakistan.

The capacities of analytical laboratories are low to medium. Generally there is a lack

of sustainable financial mechanism required for R & D in environmental sector.

There are no special allocations for chemical management/research in Pakistan. The

other bottle neck is lack of technical human resource. During the last two decades

due to economical crises in the country there was a brain drain from the institutions.

This has become a critical issue. The relevant institutions lack critical monitoring

infrastructure.



3. Recommendations

3.1 Recommendations for Governance Issues

Establish a centralized chemical information management and dissemination system for

including chemical hazard data sheets and inventory system of chemicals use, storage,

transport and disposal system.

Build capacity of industries and EPA to establish Pollutant release and Transfer

Registers (PRTRs)

The Globally Harmonized System of Classification and Labelling of Chemicals (GHS)

should be implemented in the country.

Develop the recycling and recovery facilities for disposal of obsolete pesticides.

Additional poison control centers should be established near agricultural hubs, with

technical human resource and medical facilities required for treatment of

pesticides/other poisoning cases according to the IPCS guidelines.

Capacity building for sound management of chemicals should be given priority in

national development plans and poverty reduction strategies. Sufficient financial

resources should be allocated for capacity building of ministries and related institutions

for life cycle management strategies including economic impact assessment of chemical

use.

Stakeholders from trade and industry should be involved in policy making process and

a coordination mechanism should be evolved.

Addition of Representatives of Ministries for Petroleum & Natural Resources, Labour,

Railway, Communication, Ports & Shipping, National Disaster Management Cell,

Emergency Services, is required. Academia, industries and NGOs should also be given

representation. A broader representation should be ensured in NTACC to bring

synergies from related initiatives on chemical management.

A mechanism should be evolved to enhance cooperation between trade organizations

with inter government issues through participation in their initiatives for global

chemical management.

Mechanism to accredit NGOs should be brought in so that they can play better role in

monitoring the chemical management issues.

Training and awareness programme is required exclusive for women workers including

agriculture workforce.

Need for improvement in advertisement laws with reference to include safety concerns

of chemicals used in agriculture and consumer products for public awareness. Enhance

the capacity and role of electronic media for information dissemination on chemical

hazards.

Develop a Clearing House Mechanism for information on chemical safety for optimum

use of resources



A sustainable monitoring system should be established for trans-boundary movement of

hazardous waste and illegal chemicals and law enforcing agencies should be provided

necessary equipment and training.

There is a need to further enhance public private partnership for exchange of

information, technology and expertise required for chemical management

Explore cooperation with other countries and IOMC organizations in the field of

education, science and technology.

Global information network may be developed with help of ILO, WHO, UNEP and

FAO etc.

Enhance integration planning between disaster management, development planning

and environmental management institutions.

University curricula should be revised to include courses related to chemical life cycle

management and integrated waste management.

Implement/introduce voluntary initiatives like environmental management system to

prevent pollution in industry and R & D institutions.

Give incentives for introduction of pollution prevention technologies like cleaner

production technologies and enhance corporate responsibility of environmental

management in corporate sector.

Penalties to be made reformatory and stringent by increasing the amount of fine so that

they deter the offence and beside penalties economic incentives should be given to

industries to reduce their waste emission and proper disposal of wastes.

3.2.

Recommendations for Important and Urgent Chemicals Management Issues

Develop harmonized data elements on occupational health and safety for recording

relevant workplace data in company specific databases. Set time frames for industry, in

cooperation and coordination with other stakeholders, to generate hazard information

for high-production volume chemicals not addressed under existing commitments

Promote training in risk/hazard assessment, classification and preparation of safety data

sheets and implement GHS in the country.

Establish more poisoning information and control centers and systems for data

collection and analysis and enhance the capacity of present facilities.

Develop PRTRs tailored to variable national conditions as a source of valuable

environmental information for industry, so that risks are communicated in a timely and

accurate fashion without unduly alarming the public.

Fill gender specific gaps in scientific knowledge (e.g., gaps in understanding of

endocrine disruptors and special women concerns related to chemical exposures)

Develop and establish targeted risk assessment approaches to evaluating exposure and

impacts, including socio-economic impacts and chronic and synergistic effects of

chemicals on human health and the environment Harmonize chemical safety norms)

Encourage full implementation of the FAO International Code of Conduct on the

Distribution and Use of Pesticides.



Promote integrated pest and integrated vector management in Pakistan.

Develop national occupational health and safety and environmental health and safety

policies containing specific text on chemicals management.

Develop a system of health and environmental impact assessment in chemicals

handling, and incorporate it in occupational safety and health programmes

Develop, enhance, update and implement ILO safe work standards, ILO guidelines on

occupational safety and health management system (ILO-OSH 2001)

Promote the establishment of national inspection systems for the protection of

employees from the adverse effects of chemicals and encourage dialogue between

employers and employees to maximize chemical safety and minimize workplace hazards

Provide appropriate training and sensitization on chemical safety for those exposed to

chemicals at each stage from manufacture to disposal to protect them from diseases and

occupational cancers, caused by chemicals.

Identify contaminated sites and hotspots, and establish infrastructure for analyzing and

remediation of contaminated sites to reduce risks to the public and to the environment.

Apply life-cycle management approaches to ensure that chemicals management

decisions are consistent with the goals of sustainable development.

Develop and implement life cycle based integrated solid waste management plan for

waste minimizing, recycling and reuse.

Develop national and local capacities to monitor, assess and mitigate chemical impacts

of dumps, landfills and other waste facilities on human health and the environment

Promote research for use of safe and effective alternatives, including non-chemical

alternatives to organic chemicals that are highly toxic, persistent and bio-accumulative.

Undertake awareness-raising for consumers, in particular by educating them on best

practices for chemical use, about the risks that the chemicals they use pose to

themselves and their environment and the pathways by which exposures occur

Develop national training/awareness raising programme on hazards and management

of solid waste, health sector waste and hazardous waste produced by industry.

Provide training to emergency response services personnel for chemical disaster

management.

Develop national capacity building programme to government agencies to

monitor/prevent illegal traffic in toxic and dangerous goods and hazardous wastes, g in

cleaner production technologies to industries and relevant institutions, negotiating

skills at international level, project development and monitoring etc.

Establish national or regional laboratory facilities, complete with modern instruments

and equipment, including those necessary for testing/monitoring emissions and

industrial effluents and wastes according to national/international standards. Build

capacity of existing research and monitoring facilities.



4. Conclusion

Chemical management is an important issue; it needs to be addressed urgently. There is low

awareness to and understanding of poor chemical management, there are inadequate facilities

and unclear responsibilities. At present chemical use, production and import are on the

increase and if appropriate capacities are not built in the country as a matter of urgency,

resultant negative impacts on health, environment, society and economy are going to escalate.

In Pakistan, an approach to address chemical management issues took a head start with the

efforts to implement SAICM. As a result of it, National Chemical Profile was formed in 2000.

Now the National profile is being again formulated along with capacity assessment and plan of

action. Therefore, this capacity document is a part of this project. This document serves to

develop a baseline assessment of Pakistan's capacity to respond to chemical management issues

throughout the life cycle of chemicals. Moreover, it serves to highlight a number of priority

issue areas that should be considered by the Ministry of Environment and other related

institutions in future.

The main, overarching problem that was identified from the capacity assessment is that the

government institutions lack capacity for the sound management of chemicals due to financial

shortfalls, shortages of tools, equipment, physical support and infrastructure, and lack of

trained and skilled human resource. This should be a first step, before tackling any of the more

specific issues identified in the document.

The data required for the sound chemical management is compiled by the government

institutions such as EPA, Federal bureau of Statistics, Ministry of Environment, etc. This data is

non-reliable and non-harmonized as well as data related to disposal, storage, chemical

accidents and transportation is missing. These gaps in data are due to absence of inventory

system and centralized database. GHS is not yet implemented in the country and no efforts vis-

a-vis its implementation being made. Steps should be taken to implement GHS in the country

on priority basis. Information management systems for hazard information according to GHS

guidelines should be established and training in hazard classification should be promoted.

Although EPA has setup emission inventory system in major cities, but the present capacities

for assessment of exposure to different chemicals are very low. PRTRs tailored to variable

national conditions should be used as a source of valuable environmental information for

industry, so that risks are communicated in a timely and accurate fashion without unduly

alarming the public.

Risk reduction is another major area being continuously ignored by the government. The

present capacities for assessment of exposure to different chemicals are very low in the country.

There is lack of preventive strategies for chemical safety and targeted risk assessment approach.

FAO International Code of Conduct on Distribution and Use of Pesticides is not being fully

implemented. Integrated pest management programme is being implemented but there is no



integrated vector management programme. Present legislation related to health and safety of

workers at their workplace is insufficient. There is a lack of health impact assessment system in

development activities. Occupational health & safety policies are also not present in the

country, therefore, lack of training and sensitization on chemical safety for those exposed to

chemicals at various work places. The targeted risk assessment approaches to evaluating

exposure and impacts, including socio-economic impacts and chronic and synergistic effects of

chemicals on human health and the environment should be developed and established. Beside,

there is a need to develop, enhance, update and implement ILO safe work standards, ILO

guidelines on occupational safety and health management system (ILO-OSH 2001)

Chemical risk assessment studies and chemical life cycle management issues are not included

in university curricula. There is also lack of information dissemination system. There are

limited opportunities for trainings of people at risk to chemical exposure on safe handling of

chemicals, policy makers and planners. The capacities and know-how of emergency response

agencies are usually limited. There is a need to include a range of preventive strategies,

education and awareness-raising and capacity-building in risk communication. Training in

cleaner production techniques should be provided to industries and relevant institutions. The

training on links between trade and environment, including needed negotiating skills; and in

the concept of protected areas should also be promoted. Moreover, there is a need to establish

and implement national action plans with respect to waste minimization and waste disposal.

The capacities for remediation of contaminated sites caused by chemical accidents are limited.

The National Disaster Management Plan does not include strategies for chemical

accidents/industrial accidents. The national infrastructure needs to be established or

strengthened, including for information management, poison control centers and emergency

response capabilities for chemical incidents. In Karachi, Faisalabad, Multan and Islamabad, few

poison treatment and control centers have been established with reasonable technical and

monitoring facilities. The capacities of analytical laboratories are low to medium. National or

regional laboratory facilities should be established with complete modern instruments and

equipment, including those necessary for testing emissions and operating according to national

standards.

In short, Pakistan is faced with the challenge of slow pace of developing national capacity to

assess, devise, and implement related chemical management activities. The development of a

national capacity on the whole nevertheless remains uneven, with key institutions, especially in

administration, academia and the private sector, largely uninitiated in terms of technical

knowledge, relevant activities and awareness of possible benefits. There are a number of

ongoing initiatives in the country to strengthen the required capacities for the sound chemical

management; but they are insufficient. There is a capacity in the country to manage chemicals

but they needed to be strengthened. There exists a tremendous scope in Pakistan for the

transfer of suitable technical and technological expertise in the area of chemical management

as well as the development of infrastructure and financial support. There is already a



substantial capacity in the country to provide the momentum for SAICM implementation for

developing chemical management mechanisms, which should be fully taken advantage of.



Annexure

Annexure 1: Worksheet for Governance Assessment 39

Annexure 2: Worksheet for Identification of Important and Urgent Chemicals Management Issues 71



Annexure 1: Worksheet for Governance Assessment

A.1 Integrating Chemicals Management into National Development Priorities

Category Level of Summary of Strengths and Gaps Possible action Urgency and

(and related GPA activities) existing importance

capacities: of taking

High/ action:

Medium/ High/

Low Medium/

Low

1.1 Mechanisms for Integrating Chemicals Management into Development Priorities

Develop national profiles and Medium Strength: Develop a centralized chemical High

implement action plans for The National chemical Profile management information

sound management of has been Prepared. Capacity system.

chemicals assessment is being carried out

which will be followed by

National Action Plan.

Gaps:

Non availability of relevant

and harmonized data, absence of

inventory system related to chemical

accidents, chemical

poisoning cases, drinking

water contamination, food

contamination, transportation

and storage of chemicals

required for preparation of

chemical profile.

Give appropriate priority to Low Strengths: • Capacity building of law High

pest and pesticide Pests and Pesticide enforcing agencies to increase



management in national Management has been given their technical know-how and

sustainable development due attention in national and provide infrastructure/

strategies and poverty provincial sustainable equipment for monitoring

of

reduction papers to enable development strategies and illegal traffic of banned and

access to relevant technical poverty reduction paper of obsolete pesticide across

and financial assistance, Pakistan. borders.

including appropriate Gaps: • Develop Laws dealing with

technology • There are low capacities to disposal, transportation and

monitor illegal trafficking of storage of pesticides

pesticides • Develop recycling and recovery

• Poor technical infrastructure facilities for disposal of

for recycling and recovery as obsolete pesticides

well as for disposal of obsolete • Capacity building of NGOs for

pesticides monitoring of pesticides use

• Lack of sustainable monitoring and disposal

mechanism for obsolete • Establish additional poison

storage sites of obsolete control centers near

pesticides agricultural hubs with

• Insufficient legislation dealing technical human resource and

with transportation, storage medical facilities required for

and disposal of pesticides treatment of pesticides

• Poor capacities of law poisoning cases

enforcing agencies

• Inadequate patient poison

control/decontamination

facilities and stocks of

antidotes, medicines, and

appropriate equipment in

hospitals for chemical

emergencies like pesticides

poisoning



Establish the capacity to Medium Strengths: • Develop harmonized chemical High

collect and analyze social and • Socio-economic data is management information

economic data primarily collected and analyze system

by Federal Bureau of Statistics FBS.

• These data are collected from

primary and Secondary

Sources.

• The primary data are collected

through different surveys such as

Labour Force Survey (LFS),

Household Integrated

Economic Survey (HIES),

Pakistan Integrated Household

Survey (PIHS), and Pakistan

Demographic Survey (PDS) etc.

• Secondary data such as

Foreign Trade Statistics,

Industrial Statistics, Transport and

Communication Statistics,

Social Statistics, Agriculture

Statistics, Environment

statistics etc. are collected from

the records of concerned

Ministries/Departments.

Gaps:

• There is no harmonized system

for collection of data. Usually

the information is collected for

various other purposes on



different parameters and

synthesis of such data is

difficult for chemical

management.

Consider and apply Low Gaps: • Penalties for environmental Medium

approaches to the • Penalties for environmental offences should be made

internalization of the costs to offences are not generally reformatory i.e. punishment

human health, society and reformatory may not only induce future

the environment of the • Penalties are not stringent restraint but also rectifies the

production and use of enough to deter the felon damage committed.

chemicals, consistent with • Penalties to be made stringent

Principle 16 of the Rio by increasing the amount of

Declaration. fine so that they deter the

offence.

• Beside penalties economic

incentives should be given to

industries to reduce their waste

emission and proper disposal of

wastes.

Include capacity-building for Low Strengths: • Give priority in national High

the sound management of • Pest and pesticide development and poverty

chemicals as one of the management have been reduction strategies of capacity

priorities in national poverty included in the national building for sound

reduction poverty reduction strategy management of chemicals

strategies and country paper.

assistance strategies Gaps:

• The capacity building for

sound management of

chemicals in general is not

included in the national

poverty reduction and strategy



paper and country assistance

strategies

Ensure mutual Low Gaps: • Stakeholders from trade and Medium

supportiveness between trade • Limited coordination between industry should be involved in

and environment policies policy makers and industry in policy making process. Some

policy making process coordination mechanism

should be evolved.

Integrate the sound Low Strengths: • Allocate sufficient financial High

management of chemicals • Ministerial setup required for resources for capacity building

capacity within ministries sound chemical management of ministries like induction

involved in supporting is well established with clearly training of technical human

chemicals production, use defined mandates. resource and establish

and management Gaps: infrastructure required for

• Poor capacities of government sound management of

institutions for sound chemicals.

management of chemicals in

terms of technical human

resource and infrastructure

• Lack of awareness of existing

regulatory framework within

implementing agencies

• Meagre funds available

• Most of the staff ministries

and related departments are

overworked

• Few financial/career incentives

available to technical human

resource

• Lack of critical infrastructure

required for monitoring

Establish the capacity to Gaps: • Establish sustainable Medium



undertake social and • Lack of critical infrastructure mechanism for economic

economic impact assessment required for monitoring impact assessment

• Non-availability of relevant

data

A.2 A Sound Institutional and Programmatic National Framework

Category Level of Summary of Strengths and Possible action Urgency and

(and related GPA activities) existing Gaps importance


High/Medium action:

/Low High/

Medium/

Low

2.1 Establishing an Inter-ministerial Coordination Mechanism

Articulate an integrated Low Strengths: • Implementation of Globally High

approach to chemicals • Multilateral environmental Harmonized System of

management taking into agreements have been Classification and Labelling of

account multilateral integrated into environmental Chemicals (GHS)

environmental agreements laws of Pakistan.

and strategies that target a • SAICM pilot project is under

broad spectrum of chemicals implementation

• For the implementation of

International Chemical

Management Programme the focal

points are well defined,

their duties laid down and

implementations are at

various stages

• A multilateral approach is

being adopted for chemical


management in the country

through implementation of

SAICM

Gaps:

• Globally Harmonized System

of Classification and

Labelling of Chemicals (GHS)

is yet to be implemented in

Pakistan


With regard to the implementation of national programmes:

• Develop comprehensive High National chemical Profile has - High

national profiles; been prepared

• Formalize inter-ministerial

and multi-stakeholder

coordinating mechanisms on

chemicals management

issues, including

coordination of national

Government and multi-

stakeholder positions in

international meetings;

High Strength:

National Technical Advisory

Committee on Chemicals

(NTACC) including member

from all related ministries has

been formed which is

working effectively.

Gaps:

Representation of ministry

for Petroleum & Natural

Resources, Labour, Railway,

Communication, Ports &

Shipping, National Disaster

Management Cell, Rescue

115 Service is not there in

NTACC

Addition of Representatives of High

ministry for Petroleum &

Natural Resources, Labour,

Railway, Communication, Ports

& Shipping, National Disaster

Management Cell, Rescue 115

Service, is required.

• Develop national chemical High Strength: National Action Plan will High

safety policies outlining National Action Plan for include all necessary actions

strategic goals and milestones SAICM is under process needed to achieve targets of



towards reaching the Johannesburg 2020 goals

Johannesburg Summit 2020

goal;

• Develop national chemicals Low Gaps: Efforts should be made to High

safety information exchange At present there is no establish a sustainable

systems; national chemical mechanism for a National

information exchange system Chemical Information System

present in the country. A to assist sound chemical

proposal is underway to management in the country

establish a chemical

information system in

Ministry of Environment

• Develop national strategies Low Strengths: A sustainable mechanism for High

to mobilize national and At present some resources resource allocation should be

external resources and to have been provided for developed.

raise the importance placed implementation of various

on chemicals management Chemical Conventions under

within national sustainable National Development

development frameworks; Framework

Gaps:

Available resources are

insufficient for sound

chemical management in the

country

• Develop policies of High Strengths: A broader representation Medium

systematic stakeholder Stakeholder involvement is should be ensured in NTACC

involvement, bringing already ensured in NTACC to bring synergies from related

synergies from related Gaps: initiatives on chemical

initiatives on chemicals Stakeholders from some management.

management ministries, related NGOs,



academia, labour unions and

civil society are nor present

in NATCC

Establish national multi- High Strength:

stakeholder coordination National Technical Advisory

bodies on chemicals to Committee on Chemicals is

provide information and already functioning. increase awareness of

their risks

Incorporate capacity-building Low Strengths: A proactive approach should be High

strategies and promote Officials of ministries and adopted to enhance the

activities to enhance government agencies often capacities of government

country's legal and attend training courses, functionaries to ensure

institutional framework seminars, workshops on chemical safety across the

for implementing chemical policy issues, legal framework country through implementing

safety across all relevant and environmental policies and legal framework.

ministries and Government management in general.

agencies Gaps:

Activities for capacity

building of government

institutions to enhance

countries legal and

institutional framework for safe

chemical handling are

very limited

Encourage cooperation Low Strengths: • A mechanism should be Medium

between secretariats of • Trade organizations/ evolved to enhance cooperation

multilateral trade and chambers of commerce between trade organizations of

multilateral environmental participate in activities Pakistan with inter government

agreements in development organized by ministries other issues through participation in

of programmes and materials government institutions their initiatives for global


to enhance mutual

understanding of the rules

and disciplines in the two

areas among Governments,

intergovernmental

institutions and other

stakeholders

2.2 Setting National Priorities

• Trade organizations are also

member of NTACC where

they actively participate and

coordinate with various

government institutions

Gaps:

• There is a very limited

interaction of trade

organizations with inter-

governmental institutions


chemical management

Work to ensure broad and

meaningful participation of

stakeholders, including

women, at all levels in

devising responses to


challenges and in regulatory

and decision-making

processes that relate to

chemical safety

Strengths:

• NTACC has a cross sectoral

representation and is playing

a vital role in technical

guidance and decision

making process

• Trade organizations are

playing an important role in

implementation of

international voluntary

initiatives like ISO etc.

• Industries are cooperating in

Pak-EPA's SMART

programme

• Important role in raising

member/public awareness

• Trade unions are moderately

active in information

dissemination and policy

• Improve the understanding of

communicators and the media

concerning chemical safety

issues for better

communication of these issues

to the public in order and to

improve understanding and

promote chemical safety

actions by the public and civil

society in general

• Mechanism to accredit NGOs

should be brought in so that

they can play better role in

monitoring the chemical

management issues.

• Training and awareness

programme is required

exclusive for women workers

including agriculture

High


analysis

• Some of the NGOs are

involved in dissemination of

information and creating

awareness

Gaps

• Lack of initiatives by trade

unions for capacity building

and development of expertise

for sampling, testing and

research on environmental

pollution caused by industrial

processes

• Need to create some

mechanism of standardizing

NGOs so that they can play

some vital role in monitoring

and inspections.

• The role of women is limited

in chemical management

especially in agriculture sector

due to lack of awareness


workforce

Have in place multi-sectoral High Strengths: - -

and multi-stakeholder • A multi-stakeholder approach

mechanisms to develop was adopted while preparing

national profiles and priority National Chemical Profile

actions and Action Plan. This

involved stakeholders from all

relevant ministries,

government departments,

NGOs, CSOs, and industry



Strengthen mechanisms for Low Gaps: • Develop chemical information High

reporting and consolidating • Absence of harmonized data management system at national

information necessary to collection system on as well as provincial level

produce baseline overviews production, storage, • Develop sustainable financial

that will help transport, use and waste mechanism required for data

determine domestic disposal of chemicals collection

management priorities and • Lack of inventory and • Develop capacity of trade

gaps (e.g., PRTRs and reporting system for chemical unions, industry, and NGOs

inventories), taking into storage, transport and for self reporting initiatives

account industry reporting industrial accidents

initiatives) • Absence of records of

occupational accidents,

chemical accidents, chemical

poisoning, chemical injuries,

drinking water

contamination, food

contamination, and deaths

caused due to chemical

accidents, by industry as well

as related institutions

2.3 Information Exchange Mechanisms

Develop mechanisms to share Low

and disseminate information

that can be used to reduce

uncertainty in risk assessment

Provide extension and

advisory services to farmer

organizations with

information on integrated

Gaps:

Absence of national

information system related to

chemical life cycle

Strengths:

• Integrated pest management

strategies have been

developed and implemented

Develop chemical information

system with proper

dissemination mechanism

• Capacity building of

government departments and

NGOs is required to provide

advisory services and

High

Medium


pest management strategies

and methods

in the country

• Agriculture extension and

advisory services are available

with the government

departments

• NGOs are involved in

awareness raising on

integrated pest management

Gaps:

• Majority of farmers are

uneducated and unaware of

health and environmental

implications of use of

agricultural chemicals

• Government departments

have low capacities to

implement integrated pest

management strategies at

grass root level

• Due to illiteracy farmers do

not have access to

information about pest

management and proper

pesticide use.


information on integrated pest

management to the farmers o

field;

Generate and share

information detailing the

inherent hazards of all

chemicals in commerce,

giving priority to hazard

information for those

chemicals that have the

Gaps:

• Lack of preliminary hazard

analysis

• Absence of Globally

Harmonized System for

Labelling of chemicals

• Hazard information on

• Need for improvement in

advertisement laws with

reference to chemicals used in

agriculture and consumer

products

• Capacity building of related

stakeholders for hazards

High


greatest potential for

substantial or significant

exposures

Establish national priorities

for information generation

for chemicals that are not

produced in high volumes

Low

chemicals used in industry are

seldom displayed

• Majority of farmers are

uneducated and unaware of

health hazards of agricultural

pesticides

• Poor capacities of monitoring

and law enforcing agencies

• Lack of information

regarding unknown chemicals

imported which are used in

numerous micro-level units

• Storage facilities are devoid of

any health and safety

measurements.

Gaps:

Absence of information on

chemicals imported and used

in small quantities


identification

• Dissemination of information

regarding chemicals hazards

and safety manuals required

• Requirement of Statutory

bodies /funds/technical

support

• Implementation of GHS for

labelling of chemicals

Introduce inventory system Medium

on chemicals imported,

produced and used in

small quantities

Promote the establishment of Low Gaps: • Capacity building for hazard Medium

generally applicable Absence of guidelines for identification and risk

guidelines on the respective hazard identification for assessment is required for

roles, responsibilities and government institutions, Government institutions and

accountabilities of industry, importers and industry;

Governments, producing and exporters; • Integrate planning between importing enterprises and disaster management,

suppliers of chemicals development planning and

concerning the generation environmental management

and assessment of institutions;

hazard information

Establish arrangements for Low Strengths: • Develop an easily accessible High


the timely exchange of

information on chemicals,

including what is necessary to

overcome barriers to

information exchange (e.g.,

providing information in

local languages)

• Electronic Data Management

System has been introduced

to interlink all government

offices through internet for

information exchange

Gaps

• Website of each ministry is

present but not regularly

updated

• Not all information uploaded

on websites

• Time consuming and lengthy

procedures for getting

information from ministries

• All people do not have easy

access to information • Lack of financial and

technical capacities

• Information are usually not

available in local languages


chemical information system;

Consider establishing a Gaps: • Develop a Clearing House High

clearing-house for • Absence of Clearing House Mechanism for information on

information on chemical Mechanism chemical safety for optimum

safety to optimize the use of use of resources

resources

Ensure that all Government High Strengths: - -

officials from developing • Officers and staff of all

countries and countries with Ministries and attached

economies in transition departments have been

responsible for provided with personal

chemicals management have computers with Microsoft

Page 53

access to the Internet and

training in its use

window operating system, MS

Office tool, email, high speed

internet, system management

and security clients,

departmental servers for print

sharing, local area

networking, directory services

and networking between the

Divisions

• Training programmes also

being arranged for

government officers and staff

in this regard


Strengthen the exchange of Low Strengths: • Develop a fast track and High

technical information among • E-government has been updated technical information

the academic, industrial, established for the fast pace system required for analysis and

governmental and communication system within academic purposes on chemical

intergovernmental the government as well as for management

sectors public to government

• Exchange of information with

other countries is possible

through internet

Gaps:

• Access to updated

information in government

departments and industry is

difficult for academia and

common public

• Lengthy and time consuming

procedures of obtaining

information from ministries



and related departments • Lack of cooperation and

coordination among

ministries

Improve the information Low • Lack of awareness among • Awareness raising campaigns High

base, including via electronic people about their right to are required for common

media such as the Internet information on chemicals public

and CD ROMs, in particular used in their daily life • Enhance the capacity and role

in developing countries, • Absence of information in of electronic media for

ensuring that information local languages information dissemination on

reaches appropriate target • Role of electronic media in chemical hazards.

groups to enable their dissemination of information

empowerment and ensure about chemical hazards is very

their right to limited

know

Establish information- Low Gaps: • A permanent monitoring High

exchange mechanisms on • Absence of continuous system may be established for

contamination in border monitoring system for trans- trans-boundary movement of

areas boundary movement of hazardous waste;

hazardous waste

Encourage and facilitate Strengths: • There is a need to further

exchange of information, • In most of the institutions in enhance public private

technology and expertise public as well as private sector partnership for exchange of

within and among countries regular trainings/visits are information, technology and

by both the public arranged for exchange of expertise required for chemical

and private sectors for risk information on new management

reduction and mitigation technologies using expertise • Explore cooperation with other

from other countries; countries in the field of

• Public private partnership education, science and

also exist for exchange of technology

information on new


technologies

Gaps:

• The existing opportunities do

not fulfil the requirement of

capacity building for chemical

management in the country;


Facilitate access to research Low • Most of the farmers are • Improve coordination between Medium

results related to alternative uneducated and research R & D institutions and farmers

pest control (both chemical results on integrated pest

and non-chemical) and crop management, crop protection

protection measures by methods and health hazards

pesticide users, those exposed seldom reach to them

to pesticides and extension • Unawareness among people

services at risk to pesticides

contamination

Strengthen global Low • Absence of any global • Global information network Medium

information networks in the information network at may be developed including

sharing, exchange and national level for delivery of ILO, WHO, INFOCAP and

delivery of chemical safety chemical safety information FAO etc

information (e.g. ILO,

WHO, INFOCAP)

Promote the development of Low • National Chemical • Develop Chemical high

databases based on scientific Management Information Management Information

assessment and the System is absent in Pakistan System at national as well as

establishment of centers for provincial level

the collection and

exchange of information at the national,

regional and

international levels

Develop and enhance the Low • Poor system to acquire, • Development capacities of High

capacity to acquire, generate, generate, store, disseminate concerned department s



store, disseminate and access and access to information involved in chemical data

information, including regarding chemical management

INFOCAP management

Create a global information Low Absence of information Create a global information Medium

network, including early network for early warning network for early warning

warning systems, across systems for cross-boundary systems regarding cross-

international borders, movement of hazardous boundary movement of

especially at the regional substances and chemical hazardous chemicals

level) waste in Pakistan



A.3 Effective Project Planning, Implementation, Monitoring and Evaluation

Category Level of Summary of Strengths and Gaps Possible action Urgency and

(and related GPA activities) existing importance


High/ action:

Medium/Low High/

Medium/

Low

3.1 Project Planning

Develop competencies and Low Low level of capacities of • Capacity building of planning Medium

capacities for the national Planning Commission and commission and provincial

planning of projects relevant provincial departments to departments and institutions

to the management of plan projects relevant to • Provide training, technical and

chemicals management of chemicals financial support to the relevant institutions

Develop resources for Medium Strengths: • Develop sustainable High

national implementation Funds are allocated in mechanism to mobilize

plans and projects annual, Medium Term and resources required for

Long Term Development implementation of projects by

Framework to cope with exploring opportunities of

environmental issues and foreign findings;

sustainable development • Develop Capacities in terms of

project s technical know-how, human

Gaps: resource, infrastructure

• Poor capacities of government required for implementation

departments to implement of projects;

projects are the main

constraints due to lake of

technical know-how, poor

infrastructure, limited



experienced human resource; • Due

to financial crunches the

funds are often diverted to

cater other urgent needs

3.2 Monitoring and Evaluation

Develop and establish • Targeted chemical risk • Capacity building of project

targeted risk assessment assessment approach is implementers and

approaches to evaluating seldom seen in major administrators is required for

exposure and impacts, development projects; risk assessment and

including socio-economic • Limited evaluation of socioeconomic of

impacts and chronic and socioeconomic impacts and • Requirement of integrated

synergistic effects of chemicals chronic impacts of chemicals planning between disaster on

human health and the used in different sectors management, development

environment • Disaster management, planning and environmental

development planning and management institutions

environmental management

institutions operate in

isolation

• Dearth of knowledge and

limited capacity of hazard

identification, risk assessment &

management, and linkages

between livelihoods and

disaster preparedness related to

chemical accidents, within disaster

management bodies

Evaluate whether different Low • No such data is available • Conduct studies on different Medium

segments of the population • Only few studies have been segments of population having

(e.g., children, women) have made on pesticides effect on different susceptibility or

different susceptibility and/or working women in agriculture exposure on chemicals to



exposure on a chemical-by- sector chemical basis

chemical basis in order of

priority

Develop, validate and share Low • Low level of capacity and • Capacity building is required of High

reliable, affordable and technical knowledge institutions involved in

practical analytical techniques regarding the monitoring of monitoring of chemical

for monitoring substances for priority contaminants contamination across the

which there is significant country.

concern in environmental • Allocate sufficient funds for

media and biological samples. Technical human resource

Develop a targeted process to development , trainings,

assess and monitor infrastructure and equipment

levels of a discrete number of required to develop processes

priority contaminants in the for monitoring of priority

environment contaminants;

Develop scientific knowledge Low • Low capacities of academia • Capacity building of High

to strengthen and accelerate for innovative research departments of chemistry,

innovation, research, related to chemical chemical engineering and

development, training and management chemical technology with

education that • Absence of courses related to specific reference of chemical

promote sustainability chemical management waste life cycle management

management, waste treatment • Revise curricula to include

etc chemical management issues

Develop common principles Low • Lack of reporting system and • Develop harmonized reporting Medium

for harmonized approaches capacities for health and mechanism and capacities for for

performing and reporting environmental risk health and environmental risk

health and environmental assessments assessments in EPAs and health

risk Assessments departments;

Undertake capacity-building Low • Present capacities of related • Build capacity for identifying Medium

in identifying and monitoring institutions are very low and monitoring biological

biological indicators indicators



A.4 Legislation and Enforcement




High/Medium action:

/Low High/

Medium/

Low

4.1 Legislation, Regulations and Policies -General

Consider legislation to Medium • Existing legislation is • Improve labour laws, factories High

protect the health of workers insufficient regarding Act, pesticide rules to include

and the public, covering the protection of health of issues related to protection of

entire spectrum of work workers in their working industrial and agricultural

situations in which chemicals environment including workers

are handled, including such pesticides use in agriculture

sectors as agriculture and

health

Incorporate the concept of Low Strengths: • Implement/introduce Medium

pollution prevention in • Pollution prevention concept environmental management

policies, programmes and is present in various system in to prevent pollution

activities on chemicals legislations and in industry and R & D

management environmental policies. institutions

Pakistan Environmental Act • Give incentives for

clearly defines pollution introduction of pollution

prevention and need to prevention technologies

implement programmes and

activities to control chemical

pollution.

Gaps:

• Poor implementation of



policies, programmes and

activities due to low level of

capacity

Support the further Low • Limited knowledge of FAO • Develop training programmes Medium

development and adoption of and WHO specifications on to improve knowledge of

FAO and WHO pesticides among decision decision makers and

specifications on pesticides makers environmental mangers on

international initiatives on

pesticides management

Utilize the life-cycle Low • Low level of awareness and • Develop capacity of High

management concept to knowledge of life cycle environmental mangers and

identify priority gaps in management concept among policy makers to design actions

chemicals management environmental managers for safe lifecycle management of

regimes and practices and to chemicals

design actions to address gaps

in order to identify

opportunities to manage

hazardous products,

unintentional toxic emissions

and hazardous wastes at the most

advantageous point in

the chemical life cycle

Promote ratification and Strength: • Develop capacity to upgrade High

implementation of all Stockholm Convention, national institutions related to

relevant international Rotterdam Convention, Basel chemical management and

instruments on chemicals and Convention, ILO conventions responsible for implementation

hazardous waste, encouraging and IMO conventions related to of international Conventions;

and improving partnerships chemicals have been ratified and • Explore for availability of funds

and coordination (e.g., are being implemented in the within the financial framework


Stockholm Convention,

Rotterdam Convention, Basel

Convention, ILO

conventions and IMO

conventions related to

chemicals such as the TBT

Convention) and ensuring

that necessary procedures are

put into place

country. The implementation

plans have been made;

Gaps:

• Pakistan has limited technical

as well as financial capacities

to implement these

conventions;

• The institutional strengths are

weak with limited trained

human resources, equipment

and technologies

• Limited financial resources


of these Conventions;

Consider approaches to Low • At present no such • Follow synergistic approach to Medium

facilitate and strengthen approaches have been plan activities to achieve

synergies and coordination developed to establish common goals

between chemicals and waste synergies to chalk out

conventions, including by common strategies

developing common

structures

Consider evaluating the low • Limited awareness and • Capacity building for improved High

possibilities and potential potential exist in the understanding of these

benefits of using the Basel institutions for such conventions is urgently

and/or Stockholm evaluations required

Convention ways and means

for waste management and

disposal of wastes of

reclaimed ozone-depleting substances

regulated under

the Montreal Protocol

Develop pilot projects to • Focal points are established • Develop pilot projects for Medium

pursue implementation of and working for creation of synergies among


coordination between the

national focal points of

chemicals-related

multilateral environmental

agreements (Rotterdam,

Stockholm and Basel

Conventions and Montreal

Protocol) to achieve

synergies in their

implementation

implementation of

multilateral environmental

agreements related to

chemicals;

• To create synergies a better

coordination mechanism is

required


Conventions related to

chemicals to achieve common

goals of chemical lifecycle

management

Address gaps at the domestic Medium • There are certain gaps in • Develop sustainable financial High

level in implementation of implementation of existing mechanism for capacity

existing laws and policy environmental laws, policies building of institutions,

instruments promulgated in due to various factors, i.e., introduce incentive measures

the context of low capacities of for skilled human resource,

national environmental implementing government introduction of new

management regimes, agencies, lake of proper technologies etc

including with respect to infrastructures, lake of funds,

meeting obligations under lake of trainings, low salary

international legally structure, corruption, social

binding instruments values etc.

Develop frameworks for Low • NTACC is established • The composition of NTACC Medium

promoting private-public consisting of members from may be revised to increase

partnerships in the sound public as well private sector participation of NGOs, trade

management of chemicals which can play an important unions, research institutions

and wastes role in sound management of and community groups

chemicals; • Representation of ministry for

Petroleum & Natural

Resources, Labour, Railway,

Communication, Ports &

Shipping, National Disaster



Management Cell, Rescue 115

Service in NTACC

• Enhance participation of

academia; heads of departments

of chemical technology,

chemistry and environmental

sciences of the major

universities of the country may

also be included in the

committee

Promote a culture of Low • Penalties for environmental • Penalties for environmental High

compliance and offences are not generally offences should be made

accountability and effective reformatory reformatory i.e. punishment

enforcement and monitoring • Penalties are not stringent may not only induce future

programmes, including enough to deter the felon restraint but also rectifies the

through the development and damage committed.

application of economic • Penalties to be made stringent

instruments by increasing the amount of

fine so that they deter the

offence.

• Beside penalties economic

incentives should be given to

industries to reduce their

waste emission and proper

disposal of wastes.

Establish effective Low • Poor capacities of monitoring • Enhance capacities of Medium

implementation and and law enforcing agencies government monitoring

monitoring arrangements like EPAs agencies with effective incentive

measures

Develop national strategies Low • Insufficient regulatory • Introduce improved legislation Medium

for prevention, detection and framework f or control of and judicial reforms for quick


control of illegal traffic,

including the strengthening

of laws, judicial mechanisms

and the capacity of customs

administrations and other

national authorities to

control and prevent illegal

shipments of toxic and

hazardous chemical

4.2 Pesticides Legislation and Policies

illegal traffic of hazardous

chemicals

• Judicial process is very slow • Poor capacities and lake of

knowledge of officials of

custom department and other

agencies


justice system

• Improve knowledge through

regular trainings of officials of

law enforcing agencies, custom

department and ports.

Improve access to and use of Moderate • Information dissemination • Develop awareness raising and Medium

information on pesticides, system for highly toxic information development

particularly highly toxic pesticides is weak in the mechanism on highly toxic

pesticides, and promote country pesticides

alternative safer pest control • Integrated pest management • Improve coordination of

measures through networks programme is being academia and research

such as academia implemented in NARC organization on pest control

• There is some involvement research for introduction of

of academia in promotion of alternate safer measures

safer alternate pest control

measures;

Evaluate the efficacy of Low • Low level of implementation • Capacity building is required High

pesticide risk reduction of pesticides risk reduction

programmes and alternative programmes due to limited

pest control methods capacities

currently implemented

and planned by international

organizations, Governments, the

pesticide, agriculture and

trade sectors and other

International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad

Page 66


stakeholders

Develop broad strategies Low • Only few individual studies • Develop strategies to address Medium

specifically directed to the have been made so far on health of children and young

health of children and young health issues related to use of people

families pesticides, in this regard

strategies are required to be

developed;

4.3 Policies for Pollution Prevention and Cleaner Production

Encourage sustainable Low • Cleaner production strategy • Develop an aggressive High

production and use and has been adopted in Pakistan programme to introduce

promote the transfer, but still it requires further cleaner production

implementation and promotion technologies in the country

adoption of pollution

prevention

policies and cleaner

production technologies, in

particular best available

techniques and best

environmental practices

(BAT/BEP)

Encourage management Low • Very little measures have • Environmental management Medium

practices that take into been taken so far; system should be implemented

account the full life-cycle in the industry

approach to sustainable

chemicals management,

emphasizing front-end

pollution prevention

approaches

Enhance efforts to Low • Corporate sector is partially • Take proper measures to Medium

implement values of involved in environmental enhance environmental

corporate social and and social responsibility responsibility of corporate



environmental responsibility sector

242. Promote the transfer of Low • Cleaner production • Incentive mechanism along Medium

technology and knowledge technologies are very with promotion of cleaner

for cleaner production and expensive which need technologies

manufacture of alternatives incentives for their

promotion in the industry



Annexure 2: Worksheet for Identification of Important and Urgent Chemicals Management Issues

B. 1 Information generation and dissemination

Stakeholder Input Level of Summary of Strengths and Gaps Possible action Urgency and

Category existing importance

(and related GPA activities) capacities: of taking

High/ action:

Medium/ High/

Low Medium/

Low

Hazard Identification, Low • GHS is not implemented in • Develop harmonized data High

Classification and Labelling Pakistan elements on occupational

(GHS) health and safety for recording

relevant workplace data in

company specific databases

• Establish roles and

responsibilities of employers,

employees, chemical suppliers

and Governments in the

implementation of GHS

• Encourage the use of IPCS

health and safety cards

(international chemical safety

cards, or ICSCs)

• Set time frames for industry, in

cooperation and coordination

with other stakeholders, to

generate hazard information for

high-production volume



chemicals not addressed under

existing commitments

• Ensure that each pesticide is

tested by recognized

procedures and test methods to

enable a full evaluation of

its efficacy, behaviour, fate,

hazard and risk, with respect to

anticipated conditions in

regions or countries where it is

used

• Establish information

management systems for

hazard information

• Prepare safety data sheets and

labels

• Complete GHS awareness-

raising and capacity-building

guidance and training

materials (including GHS

action plan development

guidance, national situation

analysis guidance and other

training tools) and make them

available to the stakeholders.

• Establish procedures to ensure

that any hazardous material

put into circulation is

accompanied, at a minimum,

by appropriate and reliable

safety data sheets which



provide information that is

easy to access, read and

understand, taking into

account GHS

• Articles and products

containing hazardous

substances should all be

accompanied by relevant

information for users,

workplaces and at disposal

sites

• Review national legislation

and align it with GHS

requirements

• Promote training in hazard

classification

• Make available sufficient

financial and technical

resources to support national

and regional GHS capacity-

building projects in developing

countries and countries with

economies in transition)

Exposure Assessment Low • Present capacities for • Fill gaps in abilities to access, High

assessment of exposure to interpret and apply knowledge

different chemicals are very • Develop better methods and

low criteria for determining the

impact of chemicals on human

health for setting priorities for

action, for the detection of

chemicals and for monitoring



the progress of SAICM

• Develop mechanisms to share

and disseminate information

that can be used to reduce


• Establish health surveillance

programmes

• Establish more poisoning

information and control

centers and systems for data

collection and analysis and

enhance the capacity of

present facilities.

• Establish programmes for

monitoring chemicals and

pesticides to assess exposure

1.3 Toxicology Low • At present few toxicology • Harmonize principles and High

centers are working in Karachi, methods for risk assessment,

Faisalabad Multan and e.g., methods for vulnerable

Islamabad. Other facilities groups, for specific

associated with many hospitals toxicological endpoints such as

are just treating the poisoning carcinogenicity, immuno-

cases toxicity, endocrine disruption

• Eco-toxicology center has been and eco-toxicology, for new

established at NARC tools

Epidemiology and

Monitoring

Low • Pesticides residue research

centers has been established in

various cities in the country

• There is very little coordination

among these institutions

• A programme is being

• Collect data on the use patterns High

of chemicals for which there is

a reasonable basis of concern

where necessary to support risk

assessment characterization and

communication


implemented to monitor

pesticide residues in food and

the environment at NARC

Ecotoxicology Center


• Promote the use of comparable

indicators of children's

environmental health as part of

a national assessment and

prioritization process for

managing unacceptable risks to

children's health

• Develop criteria related to

chemicals considering potential

exposures and vulnerabilities of

children

• Develop objective indicators for

evaluating the influence of

chemicals on human health

and the environment)

PRTRs Low • Emission inventory system has • Use PRTRs tailored to variable High

been setup by EPA in major national conditions as a source

cities of valuable environmental

information for industry,

Governments and the public

and as mechanisms to stimulate

reductions in emissions;

• Develop manuals and

implementation guides to

explain in a simple form the

benefits provided by a registry

and the steps necessary to

develop one

• Establish the required

framework for creating national

PRTRs



• Promote a political consensus

in favour of public access to

national environmental

information

• Manage information

dissemination from PRTRs so

that risks are communicated in

Risk reduction of Chemicals

• timely and accurate fashion

without unduly alarming the

public

• Promote harmonization of

environmental performance

requirements in the context of

international trade

• Promote within the industrial

sector the adoption of PRTRs

and cleaner production

methods)

1.6 Risk Assessment Low • Limited existing capacity for • Develop and use new and High

risk assessment harmonized methods for risk

assessment

• Develop guidance materials to

assist in the preparation of

initial national assessments of

children's environmental health

and the identification of

priority concerns;

• develop and implement action

plans to address those priority

concerns



• Establish needed infrastructure

for research that will reduce


• Prioritize for assessment and

related studies groups of

chemicals posing risk for

human health and the

environment, including,

persistent bio-accumulative and

toxic substances, (PBTs); very

persistent and very bio-

accumulative substances;

chemicals that are carcinogens or

mutagens or that adversely

affect, inter alia, the

reproductive, endocrine,

immune or nervous system; and

persistent organic pollutants

(POPs)

• Establish knowledge on risk

assessment procedures, building

on existing products such as

those generated by OECD;

• Fill gaps in scientific knowledge

(e.g., gaps in understanding of

endocrine disruptors)

• Responsible public authorities

should establish general

frameworks for risk assessment

procedures and controls

• Improve understanding of the



impact of natural disasters on

releases of harmful chemicals

and resulting human and

wildlife exposures, as well as

possible measures to mitigate

them

• Ensure that pesticides and

chemicals issues are considered

within environmental impact

assessments covering protected

areas

• Evaluate the dispersion of

pollutant releases (air, water

and ground) in protected areas

B. 2 Risk Reduction




High/ action:

Medium/ High/

Low Medium/

Low

Chemical Safety - General Low • Lake of preventive strategies for • Build capacities for abilities to High

chemical safety access, interpret and apply

• Lake of targeted risk assessment knowledge

approach • Include a range of preventive

• Programme for integrated pest strategies


management is being

implemented


• Develop and establish targeted

risk assessment approaches to

evaluating exposure and

impacts, including socio-

economic impacts and chronic

and synergistic effects of

chemicals on human health

and the environment

• Harmonize chemical safety

norms)

Safe Handling and Use of Low • FAO International Code of • Encourage full implementation High

Pesticides Conduct on Distribution and of the FAO International Code

Use of Pesticides is not fully of Conduct on the Distribution

implemented and Use of Pesticides

• Pesticide registration and • Base national decisions on

control system has been highly toxic pesticides on an

established which controls risks evaluation of their intrinsic

from the initial point of hazards and anticipated local

production and formulation. exposure to them

This mechanism does not • Promote development and use

control the disposal of obsolete of reduced-risk pesticides and

products or containers substitution for highly toxic

• Integrated pest management pesticides as well as effective

programme is being and non-chemical alternative

implemented but there is no means of pest control.

integrated vector management • Promote integrated pest and

programme; integrated vector management

• Introduce incentive measures

for industry to extend product

stewardship and to withdraw

voluntarily highly toxic



pesticides which are hazardous

• Establish pesticide management

programmes to regulate the

availability, distribution and use

of pesticides and considering

the FAO Code of Conduct on

the Distribution and Use of

Pesticides;

• Ensure proper storage

conditions for pesticides at the

point of sale, in warehouses and

on farms

• License and sell pesticide

products in containers that are

ready to use, unattractive for re-

use, inaccessible to children

and labelled with clear,

unambiguous directions that

are understandable for local

users

2.3 Chemical Safety in the Medium • Present legislation related to • Revise legislation to protect the High

Workplace health and safety of workers at health of workers and the

their workplace is insufficient; public, covering the entire

• EIA is mandatory of all spectrum of work situations in

development projects; which chemicals are handled,

• Lack of health impact including such sectors as

assessment system of agriculture and health

development activities; • Develop a system of health and

• Lack of training and environmental impact

sensitization on chemical safety assessment in chemicals

for those exposed to chemicals handling and incorporate it in



at various work places occupational safety and health

• Lack of occupational health & programmes

safety policies • Develop, enhance, update and

• Poor protection measure from implement ILO safe work

chemical exposures at standards, ILO guidelines on

workplaces i.e. use of protective occupational safety and health

equipment management system (ILO-OSH

2001)

• Develop national occupational

safety and health policies

containing specific text on


• Establish integrated

programmes for all public

health and safety practitioners

and professionals, with an

emphasis on identification,

assessment and control of

occupational chemical risk

factors in all workplaces (such

as industrial, rural, business

and services)

• Avoid worker exposure through

technical measures where

possible; provide appropriate

protective equipment; improve

the acceptance of wearing

protective equipment and

stimulate further research on

protective equipment to be

used under hot and humid



conditions

• Promote research on the

development of appropriate

protective equipment

• Promote the establishment of

national inspection systems for

the protection of employees

from the adverse effects of

chemicals and encourage

dialogue between employers

and employees to maximize

chemical safety and minimize

workplace hazards

• Strengthen chemical-safety-

related information

dissemination among social

partners and through public

media at the national and

international levels

• Provide appropriate training

and sensitization on chemical

safety for those exposed to

chemicals at each stage from

manufacture to disposal (crop

growers, industries,

enforcement agents, etc.

• Support efforts to implement

an integrated approach to the

safe use of chemicals at the

workplace by establishing

effective mechanisms for



following up and updating

information on international

instruments related to

hazardous substances

Chemical-Specific Risk Low • Lead has been eliminated from • Protect workers from diseases High

Reduction gasoline in Pakistan and occupational cancers,

• Mercury programme is being caused by chemicals included in

implemented in the country; Rotterdam Convention

• Chemicals listed in Rotterdam • Promote reduction of the risks

Convention have been banned posed to human health and the

in Pakistan; environment, especially by lead,

mercury and cadmium, by

sound environmental

management

• Consider the need for further

action on mercury, considering

a full range of options,

including the possibility of a

legally binding instrument,

partnerships and other actions;

• Take immediate action to

reduce the risk to human

health and the environment

posed on a global scale by

mercury in products and

production processes (based on

UNEP Governing Council

decision 23/9)

Industry-sector Specific Low • Lack of proper protective • Avoid worker exposure through

Risk Reduction measures at work places which technical measures where

pose health hazards through possible; provide appropriate



exposure to chemicals protective equipment;

• Encourage industry to extend

product stewardship and to

withdraw voluntarily highly

toxic pesticides which are

hazardous and cannot be used

safely under prevalent

conditions

• Eliminate workplace hazards

posed by chemicals through

simple, practical methods, in

particular chemical control

banding)

Obsolete Pesticides and Low • Few studies have been • Identify contaminated sites

Wastes conducted to identify obsolete and hotspots and develop and

Pesticides contaminated sites implement contaminated site

under the implementation of remediation plans to reduce

Stockholm Convention risks to the public and to the

• There are limited facilities, environment

know-how and technical • Ensure the remediation of

expertise available for contaminated sites, including

remediation of contaminated those caused by accidents sites

and disposal of obsolete • Establish infrastructure for

chemicals analyzing and remediating

contaminated sites. Provide

training in rehabilitation

approaches.

• Develop capacity to

rehabilitate contaminated

sites. Develop remediation

techniques. Increase



international cooperation in

the provision of technical and

financial assistance to remedy

environmental and human

health effects of chemicals

caused by chemical accidents,

mismanagement, military

practices and wars)

Prevention and Control of Low • Basal convention has been • Apply life-cycle management

Chemical Pollution and ratified and is being approaches to ensure that

Waste implemented in Pakistan chemicals management

• Little research on waste decisions are consistent with

management the goals of sustainable

• Lack of monitoring mechanism development

for chemical impacts of dumps • Establish and implement

and landfills and waste facilities national action plans with on

human health respect to waste minimization

• Lack of national strategies for and waste disposal

prevention, detection and • Support research on best

control of illegal trans-boundary practices in waste management

movements of waste • Implement capacity-building

programmes on waste

minimization and increased

resource efficiency

• Develop national and local

capacities to monitor, assess

and mitigate chemical impacts of

dumps, landfills and other

waste facilities on human

health and the environment

• Undertake training



programmes for preventing the

exposure of waste handlers and

recyclers, particularly waste

scavengers, to hazardous

chemicals and waste.

• Strengthen national strategies

for prevention, detection and

control of illegal trans-boundary

movements of waste

• Promote efforts to prevent

illegal traffic of waste

Promote Safer Alternatives Low • Very little research is conducted • Undertake development of pest-

on safer alternatives of and disease-resistant crop

chemicals and technologies that varieties

are less resource intensive and • Promote the use of safe and

less polluting; effective alternatives, including

non-chemical alternatives to

organic chemicals that are

highly toxic, persistent and bio-

accumulative

• Promote waste prevention and

minimization by encouraging

production of

reusable/recyclable consumer

goods and bio-degradable

products and developing the

infrastructure required

• Promote research into

technologies and alternatives

that are less resource intensive

and less polluting



• Establish ecologically sound

and integrated strategies for the

management of pests and,

where appropriate, vectors for

communicable diseases

• Promote information exchange

on alternative and ecological

agricultural practices, including

on non-chemical alternatives

B. 3 Education and Awareness Raising




High/ action:

Medium/ High/

Low Medium/

Low

Education Low • Chemical risk assessment • Include a range of preventive High

studies are and chemical life

cycle management issues are

not included in university

curricula


strategies, education and

awareness-raising and capacity-

building in risk communication

• Incorporate life-cycle issues in

university curricula

• Promote education and training

on children's chemical safety

• Incorporate chemical safety and

especially understanding of the

Page 85


labelling system of GHS into

school and university curricula)

Information Low • Workshops, seminars and • Promote exchange of High

Dissemination lectures are arranged on information on chemical

chemical issues and pollution occupational safety and health

in public organizations as well • Develop and disseminate as

by NGOs. chemical safety data sheets to

• Health and safety awareness assist enterprises in protecting

raising measures are taken in their workers

large enterprises especially in • Provide extension and advisory

multinational organizations. services and farmer

• Environmental days and walks organizations with information

are arranged for awareness of on integrated pest management

common public. strategies and methods

• No national inventory system • Implement warning systems

exists chemical use, transport, with regard to the risks posed

storage and disposal by the production, use or

• Lack of harmonized chemical disposal of chemicals

information and dissemination • For all chemicals in commerce,

system appropriate information

detailing their inherent hazards

should be made available to the

public at no charge and

generated where needed with

essential health, safety and

environmental information

made available.

• Undertake awareness-raising for

consumers, in particular by

educating them on best

practices for chemical use,



about the risks that the

chemicals they use pose to

themselves and their

environment and the pathways

by which exposures occur

• Strengthen chemical-safety-

related information

dissemination through public

media

• Undertake awareness-raising

and preventive measures

campaigns in order to promote

safe use of chemicals)

Training Medium • Limited opportunities for • Ensure training of agricultural

trainings of agricultural workers in safe application

farmers, waste handlers, methods to allow the safe use of

recyclers, scientific research products

staff, custom staff and health • Provide training in alternative

personnel on safe handling of and ecological agricultural

chemicals; practices, including non-

• Lack of trainings required for chemical alternatives

necessary testing of chemicals • Carry out measures that will

for their management across inform, educate and protect

their life cycle; waste handlers and small-scale

• Limited training opportunities recyclers from the hazards of

for policy makers and planners; handling and recycling

• Limited capacities and know- chemical waste

how of emergency response • Establish programmes for

agencies scientific and technical training

• Limited knowledge for cleaner of personnel, including customs

production technologies; personnel.



• Establish the necessary training

and infrastructure for

undertaking the necessary

testing of chemicals for their

management across their life

cycle

• Develop training programmes

in risk assessment and

management-related health

techniques and communication

• Address training needed to

develop capacity in legislative

approaches, policy formulation,

analysis and management

• Provide training in emergency

response

• Provide the necessary technical

training and financial resources

for national Governments to

detect and prevent illegal traffic

in toxic and dangerous goods

and hazardous wastes

• Provide training in cleaner

production techniques

• Provide training on links

between trade and

environment, including needed

negotiating skills

• Provide training in the concept

of protected areas



B-4 Accident prevention and control




High/Medium action:

/Low High/

Medium/

Low

Chemical Accidents Low • Low capacities for • Build capacities of institutions

remediation of contaminated

sites caused by chemical

accidents

• National Disaster

Management Plan does not

include strategies for

chemical accidents/industrial

accidents


responsible for remediation of

contaminated sites, including

those caused by accidents

• Develop integrated national

and international systems to

prevent major industrial

accidents and for emergency

preparedness and response to

all accidents and natural

disasters involving chemicals

• Develop an international

mechanism for responding to

requests from countries

affected by chemical accidents

• Address gaps in the application

of safety procedures relevant to

the operation of chemical-

intensive facilities, including

the environmentally sound

management of hazardous

Page 89

Poisoning Prevention,

Treatment and Control

Medium

• A few poison treatment and

control centers have been

established in Karachi,

Faisalabad, Multan and

Islamabad with reasonable

technical and monitoring

facilities.


substances and products

• Build capacities of country to

deal with poisonings and

chemical incidents to minimize

the occurrence of poisonings

and diseases caused by

chemicals

• Establish or strengthen

national infrastructure,

including for information

management, poison control

centers and emergency

response capabilities for

chemical incidents

• Establish and strengthen

poison control centers to

provide toxicological

information and advice;

develop relevant clinical and

analytical toxicological facilities

according to the needs

identified and resources

available in each country)

B.5 Analytical and Laboratory Capacity


(and related GPA activities) existing Gaps importance of

capacities: taking action:

High/Medium High/

/Low Medium/

Low



Analytical and Laboratory Low-Medium • The capacities of analytical • Apply science-based high

Capacities laboratories are low to approaches, as described by

medium. IOMC organizations on, inter

• Most of the institutions lack alia, test guidelines, good

proper funds to acquire laboratory practices, mutual

/maintain equipment acceptance of data, new

• Monitoring and analytical chemicals, existing chemicals,

capacities of chemical and tools and strategies for testing

social data are low and assessment

• Develop, validate and share

reliable, affordable and

practical analytical techniques for

monitoring substances for

which there is significant

concern in environmental

media and biological samples

• Establish the capacity to collect

and analyze social and

economic data

• Establish national or regional

laboratory facilities, complete

with modern instruments and

equipment, including those

necessary for testing emissions

and operating according to

national standards

• Establish needed infrastructure

for research into the impact of

exposure to chemicals on

children and women

• Establish accredited testing



facilities for chemicals.

• Establish accredited testing

facilities to undertake testing

of hazard characteristics of

chemicals for classification and

verification of label

information
