Open letter to the Madhya Pradesh Pollution Control Board

To the Chairman, MP Pollution Control Board, Paryavaran Parisar, E-5, Arera Colony, Bhopal 462 016

    Sub: Personal and Organizational Responsibility for Toxic Injury to six workers at the MP Waste Management Project, Pithampur, Dhar on June 25, 2010.


We survivors of the December 1984 Union Carbide disaster in Bhopal and people exposed to ground water contaminated by Union Carbide’s hazardous wastes are writing to you to come clean on your personal and organizational responsibility for the toxic exposure and injury of six contract workers on June 25, 2010 at the MP Waste Management Project at Pithampur, Dhar run by Ramky Enviro Engineers Limited.

As you should know these workers were injured during the trial run of the Incinerator which was approved by your organization despite several blatant and ongoing violations.

There is documentary evidence to substantiate that you and your organization know full well that:

1. The village Tarpura is located within 500 meters of the Waste Management Project facility and the proposed Incinerator. (mentioned in Inspection Report of March 2007 and Status Report of January 2008)

2.The facility has collected and stored incinerable waste in an unauthorized manner.( mentioned in Inspection Report of February 2009, Inspection Report of July 2009, Status Report of January 2008, Status Report of February 2009 and Compliance Report of July 2008)

3.The facility has built landfills that are not as per approved design of CPCB. mentioned in Inspection Report of July 2009, Status Report of January 2008, and Compliance Report of July 2008)

4. Leachate from land fills is being used to quench the incinerator, causing toxic emission. This is being done by REEL instead of installing a Multi Effect Evaporator as per the CPCB guidelines.

5.There is no system of mechanical stabilization at Ramky’s facility that was directed on September 03, 2008 following joint inspection by MPPCB and CPCB.

Further during the transport of 40 MT of Union Carbide’s hazardous waste in June 2008 there were several violations as under:

6.One of the three trucks (Vehicle Regn No. HR 55A 1851) used for transporting the hazardous waste did not have the requisite Insurance, the national permit papers or the Pollution Under Control Certificate.

7.Another truck (Vehicle Regn No. HR 55A 7853) used for transporting the hazardous waste did not have the Pollution Under Control Certificate.

8.There was no off-site or on-site disaster management plan.

9.Local residents in Bhopal and Pithampur had no knowledge about the proposed transportation of hazardous waste which was carried out in darkness at about 2 AM in Bhopal.

10. The drivers of the trucks did not have fitness certificates and none of them were educated till 10th class.

Despite the knowledge of the above violations of the Hazardous Waste Management Rules, 1989 your organization gave Consent for Operation on March 18, 2010 and approved the trial runs at this incinerator that led to toxic exposure and injury to six workers.

In June 2005 because of your organization faulty regulation, workers and hundreds of neighbourhood residents were exposed to toxic pesticide dust during a Ramky operation at the Bhopal Union Carbide factory.

You owe an immediate explanation for your criminal negligence towards the health and safety of workers and residents and complicity with Ramky group of companies.

Awaiting your early reply.

Safreen Khan
Children Against Dow-Carbide
Mob. 9826994797

Balkrishna Namdeo
Bhopal Gas Peedit Nirashrit Pension Bhogi Sangharsh Morcha
Mob. 9826345423

Abdul Jabbar
Bhopal Gas Peedit Mahila Udyog Sangathan
Mob. 9406511720

Syed M Irfan
Bhopal Gas Peedit Mahila Purush Sangharsh Morcha
Mob. 9329026319

Rashida Bee, Champa Devi Shukla
Bhopal Gas Peedit Mahila Stationery Karmchari Sangh
Mob. 9425688215

Rachna Dhingra, Satinath Sarangi
Bhopal Group for Information and Action
Mob. 9826167369

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