From:
Socialist Party (India)
Lucknow/New Delhi/Hyderabad
and
Save Our Urban Lakes (SOUL)
Hyderabad
To
Shri. Chandra Kishore Mishra
Secretary
Ministry of Environment, Forests and Climate Change
Indira Paryavaran Bhavan, Jor Bagh Road
New Delhi 110003
Reg:
1. Comments on G.S.R. 44 (E) Dated 23.01.2020 – Environment (Protection) Amendment Rules, 2020.
2. ‘Bulk Drug Units May Not Have to Assess Environmental Impact’ – Economic Times of 14 March 2020
3. Pharma pollution to water bodies, Hussain Sagar and Moosi Nadi
Ref: https://drive.google.com/open?id=1NjD7id3jZbDJ3ZApgEXSYDxU8_U9xaqq
Dear Secretary, MoEF&CC,
We trust the following ‘Note’ in your notification would be strictly adhered to:
“Note: ZYD = Zero Liquid Discharge system in Bulk Drug and formulation industry is considered when treated effluent meeting the limits prescribed for compulsory parameters shall be used in Pius or Utilities (boiler/ Cooling tower etc.). The reuse of treated effluent in gardening/ horticulture shall not be considered as ZLD in Bulk Drug and formulation industries.”
Implementation of the above Note, should promptly make the 25kms pipeline carrying effluents towards Hussain Sagar and into Hussain Sagar redundant. Kindly confirm. We further have the following to state:
A. We share the concerns expressed in the following representations as received from former Union Secretary, Govt of India, and from citizen collectives:
1. Representation from Dr EAS Sarma, former Union Secretary, regarding Economic Times of 14 March 2020 on exemption of Environment Impact Assessment for bulk drug manufacturing units.
2. Representation from GAIA-India on Bulk Drug Effluent Standards notification, 23 January 2020
3. Representation from Dr Dhonti N Reddy on Bulk Drug Effluent Standards notification, 23 January 2020.
B. We also draw your urgent attention to our earlier representations on the irreversible damages done on a continuum by the existing Bulk Drug units in and around Hyderabad and our objections to Hyderabad Pharma City in the public interest.
C. We also enclose our correspondence with USFDA regarding GMP — Good Manufacturing Practices — wherein they have clarified that GMP are restricted to the internal production standards of the medicine to be exported and consumed by destination countries, but not concerned regarding the hazardous environment impact on the life of residents where these bulk drug units are located.
The above representations and our earlier ones to the state, national level and to USFDA are available at: https://drive.google.com/open?id=1NjD7id3jZbDJ3ZApgEXSYDxU8_U9xaqq
Best,
Lubna Sarwath, Sandeep Pandey, Jasveen Jairath, G Balaswamy
Lucknow/Hyderabad
