RECOMMENDATIONS

AUTO | CHLOR-ALKALI


allow_dot.jpg (322 bytes) FOR THE CONSUMERS
1.
Automobile pollution is happening in our own backyard and under our very nose and is ffecting one and all. In such a scenario the pro-active involvement of the public in making environment a buying point will go a long-way in improving the air quality of our cities. Therefore, it is recommended that the public:

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Consumers should demand information on the environmental performance of the vehicle
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green_dots.jpg (511 bytes) Use the ratings given by the Green Rating Project and support pro-active companies.

green_dots.jpg (511 bytes) Use the product rating to make its buying decisions.

2. Automobiles pollute maximum when they are in the consumer’s hand and therefore the proper maintenance of the vehicle by the consumer will reduce the emissions substantially. As of today, the quality of information supplied to the consumer is just not sufficient to engage him/her in the maintenance of the vehicle. Just pointing the finger towards the authorised service station by the companies will not solve the problem. It is recommended that the consumers demand information from the automobile companies regarding:

green_dots.jpg (511 bytes) The actual emissions and fuel efficiency of the vehicle

green_dots.jpg (511 bytes) Type of emission control systems installed in the vehicles

green_dots.jpg (511 bytes) Relevant and usable information to know about the conditions in which the pollution control equipment are likely to fail and how will the consumer be able to ascertain that.

green_dots.jpg (511 bytes) Easy to do guidelines which he/she can follow without any assistance of service station to check/maintain the vehicle and its pollution control equipment on day to day basis.

green_dots.jpg (511 bytes) Emission warranty to ensure that the emission from the vehicle is within the norms. The emission warranty must be such that it can be easily executed and not of type in which the companies can blame the consumer for the malfunctioning of the control equipment.

3. To save fuel and money:
green_dots.jpg (511 bytes) Combine errands into one trip. Turn your engine off rather than letting it idle for more than a minute.

green_dots.jpg (511 bytes) Keep tyres inflated to the manufacturer’s recommended maximum pressure and the wheels properly aligned.

green_dots.jpg (511 bytes) Anticipate situations and avoid unnecessary braking.

green_dots.jpg (511 bytes) Use air conditioning sparingly and in recirculation mode whenever possible.

4. Avoid these fuel-wasting habits:
green_dots.jpg (511 bytes) Jackrabbit starts and hard braking and obey posted speed limits. Travelling at 10 km per hour less speed reduces your fuel consumption by over 5 % .


5. Avoid other polluting habits:
green_dots.jpg (511 bytes) Disposing used oils and lubricants on the ground. They directly pollute the groundwater, which is the major source of drinking water in city like Delhi.

green_dots.jpg (511 bytes) Throwing battery, which contains heavy metals

green_dots.jpg (511 bytes) Before the vehicle paint deteriorates, do not get your vehicle painted just for appearance.

6. For proper working of the vehicle and the emission control equipment:
green_dots.jpg (511 bytes) Get your vehicle maintained at the authorised service stations only

green_dots.jpg (511 bytes) Follow the maintenance schedule given by the company in the consumer manual.

7. Today, both company and government blame the consumers lack of interest for the absence of the clean alternate fuelled vehicles on Indian roads. Demand alternate fuelled vehicles from the automobile industry and the infrastructure for the alternate fuel from the government. Alternate fuelled vehicles have same driving performance as that  of any other diesel or petrol fuelled vehicles unless you want to reach 60 km per hour in less than 5 seconds. In the long-run, alternate fuelled vehicles will become cheaper since there is a finite source of conventional fossil fuels and it is depleting fast.

8 . Demand automobile companies to give incentives for properly disposing the used parts and components like battery, tires, used oil and lubricants etc.

9. Demand automobile companies to give more numbers of free servicing. They too have the responsibility for reducing the environmental impact of the vehicle during use.

allow_dot.jpg (322 bytes) FOR THE POLICY MAKERS
1. Government is of the people, by the people and for the people. This means that the people’s interest should be of paramount importance to the government. Therefore, it is recommended that the government policy should not get caught in the so-called scientific debates, which are unscientific.

Consider the poor air quality of urban India and make decisions, which can reduce the air pollution. Safeguard the public health with proper legislations, and then let the market decide the best option.

2. Do not subsidise fuel for the rich of the society. Price fuels as per the cost. Rich should not get the benefits meant for the poor. This also includes government cars running on diesel.

3. Government should take lead in introducing alternate fuelled vehicles. What about converting all diesel cars of gov - ernment to CNG? This will not only reduce particulate pollution, it will also reduce government expenditure, which is increasing year after year.

4. Formulate policy, which rewards less polluting vehicle and penalises polluting ones. This will not only lead to the rejection of polluting vehicles by the public, but will also generate resources which could then be used for undertaking research and development and for establishing effective inspection and control regime for automobile industry.

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Your support to the clean company is going to clean the air you breath. So support the company and the vehicles, which has come at the top in the green rating project
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5. Pushing MNCs to indigenise 70% of their operation within five years of setting up of plant, without any guideline on the broader practise of indigenisation, is leading to transfer of pollution from the automobile companies to the small-scale sector, who neither have the means nor the intent to reduce pollution. Therefore, the policy of the government on indigenisation of new automobile companies needs modification.  The policy should include broader guidlines on indigenisation, which should ensure that the transfer of pollution is not practiced .

6. Pollution norms should match with the kind of pollution being generated by the industrial sector. The pollution norms applicable to the automobile production/assembly plants needs reconsideration especially with respect to the wastewater characteristics. Currently, automobile companies can meet all the norms without any effort.

7. Pollution control boards should not prescribe systems/technologies for pollution control. They should rather set the standards and monitor the pollution effectively. The responsibility of deciding about the type of technology/ systems for pollution control should be left to the automobile companies.

8. Central pollution control board urgently needs to harmonise regulations and monitoring system pertaining to the solid/hazardous wastes management across the states.

9. Pollution control board (P C B) should set regulations for the incinerators being used at the automobile companies for incinerating paint sludge and others.

10. PCB need to upgrade their scientific capability to start monitoring the specific toxins like dioxin and furans.

11. Tri-chloro-ethane should be completely banned since it is a cancer-causing chemical.

12. Supply chain management should become a part of the pollution regulations applicable to the automobile industry. Government needs to formulate a regulation system, which will also look at the performance of the suppliers of the automobile companies before granting clearance to the companies. This will push automobile companies to green their supply chain.

13. Government needs to urgently look at the downstream pollution impact of the automobiles as well. The environmental  status of service stations, workshops etc. need careful consideration since enormous amount of pollution goes unchecked from these sources.

14. Multi-utility vehicles are being used as passenger cars in the cities. Therefore, there is no reason to set standard for MUVs under commercial vehicle segment. The project recommends that the government use the standard of diesel passenger cars for the MUVs as well.

15. Government should promote scrapping of old vehicles by providing incentives to the consumer and the industry.

16. Goverment should introduce legislation for makingthe companies responsible for their product disposal.

allow_dot.jpg (322 bytes) FOR THE AUTOMOBILE INDUSTRY
Corporate environment governance and pro-active initiatives

Environment policy
Less than 50% of the automobile companies have environment policy and out of all the companies who have policies, less than 50% have addressed environmental aspect of the product in the policy. Similarly, the efforts made by the companies towards communicating the environment policy to the various stakeholders are disappointing.

The environmental policy sets the stage for the organisation’s environment management system. It is proof of the company’s intent to translate commitment into actual performance. Automobile companies need to formulate environment policy which reflects the inherent environmental aspects of their business. Environmental policy should be mandated by top management, and verified by them during management review. The policy should include moral, ethical and environmental basis for the organisation’ s actions Communication of environment policy by automobile companies should aim to:

green_dots.jpg (511 bytes) Demonstrate management’ s commitment to the environment

green_dots.jpg (511 bytes) Address concerns about the organisation’ s environmental activities by external parties; and

green_dots.jpg (511 bytes) Announce the organisation’ s strategic environmental management approach.

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The emission norms for MUVs should be same as those of the diesel passenger cars, since MUVs are used for the same purpose as diesel passenger cars
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Environment organisation
Automobile companies need to re-look at the responsibilities assigned to the environment department. A environment department is not just for the production plant but for the entire activity of the company and in this regard Indian automobile companies need to broaden the responsibilities assigned to the environment department and make changes accordingly. Environmental aspects of the product must be included within the responsibility of the environment department.

EMS certification
Considering that the EMS certification should include all the environment impacts in all stages of the life cycle, the certification of production plants means very little in case of the automobile industry, because its major impact happens during the product use and disposal phase. Also without the greening of supply chain, the ISO 14001 certification of the production plant means that the major pollution during production has not been considered in the EMS.

Automobile companies need to rework on the kind of environment management which will be effective and useful in their kind of business. Merely following the existing systems, which has no relevance, will not be useful at all. They need to develop a management system, which is able to include their entire environmental aspects.

Implementation of E M S and environment audit
green_dots.jpg (511 bytes) Decision-making in automobile companies with respect to the environment management needs to be decentralised to make its environment initiatives more effective. To increase the importance of the environment management within their operations, companies need to increase the profile of the environment manager. At the current middle management level, they are just not able to push changes, which will improve the company’s environment performance substantially.

green_dots.jpg (511 bytes) Proper targets should be set for the environment management to ensure continuous improvement.

green_dots.jpg (511 bytes) Environment audit does not only mean mass balance. It goes far beyond it and includes both qualitative and  quantitative aspects of the environment. Indian automobile companies should undertake comprehensive environmental audit to understand the aspects, which they have not yet considered.

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Automobile industry needs to seriously consider the views of the civil society. Because their views reflect the views of the society and reflects the social, environmental and ethical concerns which the society has regarding the automobile industry
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Training and awareness rising
Training and awareness raising initiative of automobile industry needs restructuring. It should not only restrict itself to the issues related to the production plant. Issues related to the supply chain, product’s environment performance and disposal of the product should also be included. Though training is required for all the employees, it should be designed differently for different target groups.

Stakeholders relationship and working with civil society
First and foremost, the automobile industry needs to seriously consider the views of the civil society. Because their views reflect the views of the society and reflects the social, environmental and ethical concerns which the society has regarding the automobile industry.

Automobile companies should come out with their policy on the kind of interaction they wish to have with the civil society as well as with their other stakeholders. A continuous exchange of ideas between the companies and its stakeholders will go a long way in making India more environmentally clean, socially responsible and morally correct.

Consumer awareness raising initiatives and reducing pollution during the usage phase

Consumer awareness raising initiatives and reducing pollution during the usage phase Automobile companies have serious responsibility of increasing the awareness of the consumer regarding the environmental aspects of the product. They should also devise methods to engage the consumers in maintaining the vehicles. Towards this, the automobile companies need to work on the following items:

1. It is important to educate the consumer about the environmental aspect of the vehicle. Automobile companies need to make the consumers aware that " the vehicle is good in terms of providing mobility to the people but bad for the society in terms of public health"and that the customer has to play an important role to reduce this impact.

2. Automobile companies need to develop transparent information system on various negative aspects of the automobile like actual emissions, failure of control equipment, changes in emission characteristics with time, and other aspects and provide this information to the consumer. Similarly, easy to use guidelines for reducing the emissions from the car, which consumers can do on their own should be made available.

3. Promote dealers/distributors to undertake training/orientation programmes for consumers to increase the environment awareness

4. Publish newsletters/advertisements for increasing the environmental awareness of consumers

5. Introduce programmes for providing assistance/ warranties/ incentives etc., to the consumer during the use of the products, which can lead to reduction in the emissions

6. Initiatives like encouraging consumers to go to affiliated service stations where the used items like batteries, oil etc., can be properly collected and properly recycled or disposed. In this regard, automobile companies need to seriously look at the cost of servicing/ maintenance currently charged by there authorised service stations/ workshops. Till the time this cost is very high compared to the not authorised service stations/ workshops, consumers will avoid the authorised ones. So automobile companies need to use the economics of scale and make vehicles maintainace affordable, which can benefit the environment as well their own bottom-line. Annual maintainance contarct could be one of the options.

Corporate fuel performance and alternate fuelled vehicles
green_dots.jpg (511 bytes) Automobile companies should seriously look at the alternate fuel options; rather then pushing for the use of conventional fuel. They should show proactiveness by doing things on their own rather than waiting for the government’s push in form of regulations.

green_dots.jpg (511 bytes) Use of subsidised diesel in passenger car to push sales in unethical, since the benefits instead of reaching the poor reaches the rich. Automobile companies should themselves reject such an option.

Corporate engine performance and introduction of clean technologies
green_dots.jpg (511 bytes) Automobile companies should demand from the government a policy framework, which rewards clean vehicles and penalises polluting vehicles. This in no case will hurt company’s bottom-line; since the reward as well as the penalty will be passed on to the consumer. That is, if a consumer wants to drive a polluting vehicle he/she should be ready to pay more for it.

green_dots.jpg (511 bytes) MNCs should stop the practise of selling obselete vehicles in India; if they are selling advanced vehicle in developed countries. Just by using government norms and poor fuel quality as excuse, they are doing nothing but hurting their own business. They need to develop a long-term strategy rather than going after short-term gains. Monitoring of emissions from vehicles There is an urgent need for the automobile companies to establish their conformity of production in a detailed scientific and statistical manner.

Research and development (R&D)
The environmental R&D in Indian automobile sector is extremely poor and needs urgent upgradation. Studies like impact of poor fuel quality on emissions, ageing of the vehicles on emissions etc. should be undertaken by the companies to synchronise their vehicles to meet the existing ground scenario. MNCs instead of relying of the R&D of their parent companies, should promote R&D in India.

allow_dot.jpg (322 bytes) DURING AUTOMOBILE PRODUCTION
Outsourcing Practices and Supply chain management
To ensure that the entire life cycle chain of the final product is environmentally compatible, the company must bring in a strong greening practice on the part of its suppliers and dealers.

1. The company must clearly define the features of the environment commitment it wants its suppliers and dealers to implement. For example, asking the dealers and suppliers to get ISO 14001 certification etc.

2. The company should then restructure its procurement department to enable itself and the supplier and vendors to adhere to the new procurement guidelines. For example, the procurement department should have a technically qualified person to assess the environment performance of the suppliers and vendors on a continuous basis.

3. The procurement department should be made responsible for making sure that all the new businesses with vendors and suppliers are as per the requirement of the procurement policy. They should also ensure that support and incentives are provided to the existing suppliers and dealers towards this objective.

4. Automobile companies need to vigorously pursue the greening of the supply chain. Like asking its suppliers/ vendors to get ISO 14001 certification.

5. If outsourcing, the company should think in terms of substituting its polluting process with a non-polluting one. In this case, despite outsourcing the process, the transfer of pollution do not figures predominantly in the company’s supply chain.

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The environmental research and development in Indian automobile sector is extremely poor and needs urgent upgradation
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6. Sourcing of polluting processes from one of its own company/joint-ventures. This will give the company the power to influence the environment performance of the vendor, since the company itself is a major stakeholder.

7. Sourcing of polluting processes should be from the competent vendors only.

8. Sourcing of processes like electro-plating should not be undertaken unless the vendor is capable enough to solve the heavy metal pollution.

Production/assembly plant performance
1. Automobile companies need to shift their entire energy requirement to clean gaseous fuels like LPG, CNG, Propane etc. This will reduce their air emissions substantially.

2. Companies need to continue their good work in reducing the specific energy and water consumption at the plant.

3. Automobile companies should evaluate the option of water harvesting seriously. The costs are low and the returns tremendous.

4. Automobile companies should try to use as much recycled metal as possible. Metals are highly versatile material and hence, use of recycled metals will not deteriorate the quality.

5. Majority of the metal working fluids used in the plant are non-biodegradable in nature and urgently needs substitution with the biodegradable ones.Vegetable oils, ester-based oils etc. are options, which can be looked at.

6. Recycling of the metal working fluids and lubricants itself will reduce their consumption substantially and hence companies should promote recycling of the metal working fluids and lubricants.

7. Tri-chloro-ethane should be completely phased out from the Indian automobile sector. Substitution like alkali cleaners etc. should be tried.

8. Use of parts/components that has heavy metal plating, should be minimised and if possible eliminated from the vehicles.

9. Selling of waste oil, solid and hazardous wastes without proper monitoring of the end-use should be stopped.

10. Automobile sector need to undertake extensive R&D to arrive at a suitable reuse/recycling programme for solid and hazardous wastes like paint sludge, grinding sludge, ETP sludge, etc. It should look at the possibility of reusing paint sludge as sealant in the vehicles.

11. Existing paints used in automobile are polluting as well as toxic to human health. Automobile companies should look at the options like heavy-metal free paints and water-based paints.

12. Manual painting should be completely eliminated. There are automatic technologies that give finishing as good as any manual painting operation.

13. Indian companies should monitor VOC emissions from the painting section and toxic emissions from the incinerator.

14. Use of VOCs from the paint section for energy generation should be promoted.

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Use of parts/components that has heavy metal plating, should be minimised and if possible eliminated from the vehicles
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15. Detailed inventories, including those of the part manufacturers, suppliers and vendors need to be developed by the automobile companies. Currently the inventory is very poor and restricts itself to the production/assembly plant only.

16. Pollution prevention has been largely ignored in the automobile plants and therefore, should be given priority over the pollution control.

17. The segregation of wastewater either in terms of the level of pollution (less polluting and more polluting wastewater) or in terms of the characteristics (biological and chemical waste) need to be implemented to reduce the pollution load from the production plant.

18. Companies need to seriously re-look at the design of their ETP’s and should make suitable changes to match the nature of wastes they generate.

19. Suitable air pollution equipment need to installed for incinerator and if required, for the DG sets as well.

Product use and disposal phase
Indian vehicles should be bought to the same level as that of the developed countries or even better than, that since India is facing pollution far in excess of anything that the developed world has ever faced. Towards this:

green_dots.jpg (511 bytes) MNCs should stop the practise of dumping obsolete products in the Indian market.

green_dots.jpg (511 bytes) Indian companies need to upgrade their engine technology and the technologies for the pollution control system.

green_dots.jpg (511 bytes) Pollution control system should match engine design rather than acting as a stand-alone feature.

green_dots.jpg (511 bytes) Promote alternate fuelled vehicles like CNG for 4-wheelers and LPG for 2-wheelers.

green_dots.jpg (511 bytes) R&D should be undertaken on the alternate vehicle technologies like hybrid and fuel cell based vehicles, and then these vehicles should be promoted in India,

green_dots.jpg (511 bytes) Research and development in engine technology is very poor and needs urgent upgradation. Companies need not rely on the developed countries for engine technology.

green_dots.jpg (511 bytes) Companies should take all the initiatives required to move beyond the statues. They should push the standards to become more stringent rather than getting pushed by the standards.

green_dots.jpg (511 bytes) Companies should disclose all information related to the environment performance of the vehicles to the consumer.

green_dots.jpg (511 bytes) Companies need to consider product disposal during the product development stage only. They must label parts based on their recyclability and publish product disposal manuals.

green_dots.jpg (511 bytes) Companies must promote setting up of product disposal facilities in India.

AUTO | CHLOR-ALKALI