pakistan _ca
TRANSCRIPT
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
National Capacity Assessment of Pakistan for Implementation of SAICM
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
National Capacity Assessment of Pakistan for Implementation of SAICM
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
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National Capacity Assessment of Pakistan for Implementation of SAICM
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.
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National Capacity Assessment of Pakistan for Implementation of SAICM
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
National Capacity Assessment of Pakistan for Implementation of SAICM
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
National Capacity Assessment of Pakistan for Implementation of SAICM
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
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National Capacity Assessment of Pakistan for Implementation of SAICM
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
National Capacity Assessment of Pakistan for Implementation of SAICM
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
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National Capacity Assessment of Pakistan for Implementation of SAICM
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
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National Capacity Assessment of Pakistan for Implementation of SAICM
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
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National Capacity Assessment of Pakistan for Implementation of SAICM
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
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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
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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.
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National Capacity Assessment of Pakistan for Implementation of SAICM
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.
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National Capacity Assessment of Pakistan for Implementation of SAICM
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.
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National Capacity Assessment of Pakistan for Implementation of SAICM
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.
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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.
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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.
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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.
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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:
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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
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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
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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.
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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
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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.
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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
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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;
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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.
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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
International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Page 22
National Capacity Assessment of Pakistan for Implementation of SAICM
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.
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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.
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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.
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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
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xi)
xii)
xiii)
xiv)
xv)
xvi)
xvii) xviii)
National Capacity Assessment of Pakistan for Implementation of SAICM
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.
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iv) v)
vi)
vii)
viii)
ix)
National Capacity Assessment of Pakistan for Implementation of SAICM
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.
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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
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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.
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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.
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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
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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
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substantial capacity in the country to provide the momentum for SAICM implementation for
developing chemical management mechanisms, which should be fully taken advantage of.
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Annexure
Annexure 1: Worksheet for Governance Assessment 39
Annexure 2: Worksheet for Identification of Important and Urgent Chemicals Management Issues 71
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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
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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
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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
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National Capacity Assessment of Pakistan for Implementation of SAICM
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
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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
International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Page 43
National Capacity Assessment of Pakistan for Implementation of SAICM
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
capacities: of taking
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
International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Page 44
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
National Capacity Assessment of Pakistan for Implementation of SAICM
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
International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Page 45
National Capacity Assessment of Pakistan for Implementation of SAICM
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,
International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Page 46
National Capacity Assessment of Pakistan for Implementation of SAICM
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
International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Page 47
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
National Capacity Assessment of Pakistan for Implementation of SAICM
chemical management
Work to ensure broad and
meaningful participation of
stakeholders, including
women, at all levels in
devising responses to
chemicals management
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
International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Page 48
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
National Capacity Assessment of Pakistan for Implementation of SAICM
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
International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Page 49
National Capacity Assessment of Pakistan for Implementation of SAICM
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
International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Page 50
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.
National Capacity Assessment of Pakistan for Implementation of SAICM
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
International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Page 51
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
National Capacity Assessment of Pakistan for Implementation of SAICM
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
International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Page 52
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
National Capacity Assessment of Pakistan for Implementation of SAICM
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
National Capacity Assessment of Pakistan for Implementation of SAICM
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
International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Page 54
National Capacity Assessment of Pakistan for Implementation of SAICM
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
International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Page 55
technologies
Gaps:
• The existing opportunities do
not fulfil the requirement of
capacity building for chemical
management in the country;
National Capacity Assessment of Pakistan for Implementation of SAICM
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
International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Page 56
National Capacity Assessment of Pakistan for Implementation of SAICM
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
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National Capacity Assessment of Pakistan for Implementation of SAICM
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
capacities: of taking
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
International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Page 58
National Capacity Assessment of Pakistan for Implementation of SAICM
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
International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Page 59
National Capacity Assessment of Pakistan for Implementation of SAICM
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
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National Capacity Assessment of Pakistan for Implementation of SAICM
A.4 Legislation and Enforcement
Category Level of Summary of Strengths and Possible action Urgency and
(and related GPA activities) existing Gaps importance
capacities: of taking
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
International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Page 61
National Capacity Assessment of Pakistan for Implementation of SAICM
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
International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Page 62
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
National Capacity Assessment of Pakistan for Implementation of SAICM
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
International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Page 63
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
National Capacity Assessment of Pakistan for Implementation of SAICM
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
International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Page 64
National Capacity Assessment of Pakistan for Implementation of SAICM
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
International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Page 65
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
National Capacity Assessment of Pakistan for Implementation of SAICM
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
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National Capacity Assessment of Pakistan for Implementation of SAICM
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
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National Capacity Assessment of Pakistan for Implementation of SAICM
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
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National Capacity Assessment of Pakistan for Implementation of SAICM
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
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National Capacity Assessment of Pakistan for Implementation of SAICM
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
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National Capacity Assessment of Pakistan for Implementation of SAICM
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
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National Capacity Assessment of Pakistan for Implementation of SAICM
the progress of SAICM
• Develop mechanisms to share
and disseminate information
that can be used to reduce
uncertainty in risk assessment
• 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
International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Page 72
implemented to monitor
pesticide residues in food and
the environment at NARC
Ecotoxicology Center
National Capacity Assessment of Pakistan for Implementation of SAICM
• 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
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• 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
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National Capacity Assessment of Pakistan for Implementation of SAICM
• Establish needed infrastructure
for research that will reduce
uncertainty in risk assessment
• 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
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National Capacity Assessment of Pakistan for Implementation of SAICM
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
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
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
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management is being
implemented
National Capacity Assessment of Pakistan for Implementation of SAICM
• 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
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National Capacity Assessment of Pakistan for Implementation of SAICM
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
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National Capacity Assessment of Pakistan for Implementation of SAICM
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
chemicals management
• 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
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National Capacity Assessment of Pakistan for Implementation of SAICM
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
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National Capacity Assessment of Pakistan for Implementation of SAICM
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
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National Capacity Assessment of Pakistan for Implementation of SAICM
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
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National Capacity Assessment of Pakistan for Implementation of SAICM
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
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National Capacity Assessment of Pakistan for Implementation of SAICM
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
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National Capacity Assessment of Pakistan for Implementation of SAICM
• 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
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
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
International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad
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
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National Capacity Assessment of Pakistan for Implementation of SAICM
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,
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National Capacity Assessment of Pakistan for Implementation of SAICM
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.
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National Capacity Assessment of Pakistan for Implementation of SAICM
• 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
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National Capacity Assessment of Pakistan for Implementation of SAICM
B-4 Accident prevention and control
Category Level of Summary of Strengths and Possible action Urgency and
(and related GPA activities) existing Gaps importance
capacities: of taking
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
International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad
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
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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.
National Capacity Assessment of Pakistan for Implementation of SAICM
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
Category Level of Summary of Strengths and Possible action Urgency and
(and related GPA activities) existing Gaps importance of
capacities: taking action:
High/Medium High/
/Low Medium/
Low
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National Capacity Assessment of Pakistan for Implementation of SAICM
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
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facilities for chemicals.
• Establish accredited testing
facilities to undertake testing
of hazard characteristics of
chemicals for classification and
verification of label
information
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