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Comprehensive Environmental Services Comprehensive Environmental Consultancy Services Package (General)
Questions & Answers Are you Approved or Recognised?In view of the Notification dated 20.12.1999, by MoEF, under EPA 1986, the following ambiguity is solved once for all. It specifically addresses that MoEF Recognised Laboratory results are good for submitting Consent Renewal Application, Monthly Monitoring Results as per Emission Regulations Part III frequency. Answer to question whether a laboratory is recognised, raises the question, approved from whom?, Who all have such authority to recognise?, Why it is required? Many local Corporations and State Boards had the practice of recognising the laboratories and/or consultants in various fields including Environment engineering. However, such approvals were without proper authority and hence were not acceptable all over the country. Way back from 1986, Municipal Corporation of Greater Bombay (MCGB) had the practice of recognising the environmental consultants and laboratories. The acceptance of such letters was only limited to Bombay area. We had such letter. This practice was to be discontinued by MCGB when MPCB started giving recognition under Water (Prevention & Control of Pollution) Act, 1974 (WA) and Air (Prevention & Control of Pollution) Act, 1981 (AA) Section 17(2). The acceptance of such letters was only limited to the respective State including MCGB. We had to even then apply to all other individual states by paying their fees and filling up their forms for their approval. We had such recognition letter for long ten years, till the practice was done away by MPCB. The approvals under these acts were only for testing of water and air pollutants. The apex Act known as Environment (Protection) Act, 1986 (EPA) came in to effect and Ministry of Environment & Forests, Govt. of India, New Delhi (MoEF) started giving recognition under Section 12 & 13 of the EPA. This is under Union Act and is valid all over India. Other State Pollution Control Boards have no other option than to accept it as part of India. We are pleased to inform you that we are directly recognised by Ministry of Environment & Forests, (MoEF) Govt. of India, New Delhi by Extraordinary Gazette Notification dated 31.8.1994 under Sec12 & 13 of Environment Protection Act, 1986. MoEF after inspection and scrutiny was further pleased reiterate their faith by attaching the seal of approval and extended our validity till 31.8.1999 by a fresh letter dated 21.4.98. Our report is acceptable even in Court of Law as per the provisions of the Act. We are the ONLY Recognised Private Laboratory, for the last six years in whole of the State of Maharashtra, which is directly approved by the Ministry of Environment & Forests, Govt. of India, for carrying out monitoring of Water, Waste water, Air, Noise, Soil and Hazardous Waste. There is no private laboratory otherwise in whole State that has recognition from the Govt. of India. This recognition is from supreme Govt. authority in India and is independent of the jurisdiction and control of Maharashtra Pollution Control Board. We are in technical as well as equity participation with native experts of USA. We have approval from Reserve Bank of India in 1986. Our pollution sampling and analysis procedures and hence results can be authenticated by US experts. This is useful for presentation to EPA, USA. Our services are not so expensive and are much economical considering our measurable service quality parameters. To name a few are laboratory set-up, range of services, speed, efficiency, accuracy, reliability, acceptability, presentation, quality procedures, technical qualifications, experience, legal expertise etc. finely blended with few other important non-measurable parameters such as wide public contacts, political advantage and so on. CPCB has published clear-cut guidelines for establishment and classification of laboratories. In the past State PCB used to visit, check and verify whether basic testing facilities are available or not. Since MPCB and many SPCB’s have discontinued this practice, there is now no control to check the set-up of the laboratory. Therefore the investment and salaries vary a lot as compared to few new entrants or laboratories with junior staff. Responsibility of clients is now much more to check and compare the quality of the vendor laboratory. We wish to elaborate the point as to how there can be a cost difference with specific example. Carbon Monoxide in ambient air or heavy metals in water can be tested by ordinary wet chemistry using glassware & a spectrophotometer (total cost Rs.0.6 lakhs). However, MoEF (and CPCB guidelines) insists on use of Gas Chromatograph (capital cost alone Rs.4 lakhs) and Atomic Absorption Spectrophotometer (Rs.12 lakhs). The capital investment alone is more than 11 times. This insistence is for better accuracy, reliability, repeatability and results traceable up to international quality standards. This is in the direction of suggested guidelines under ISO9000, ISO14000, QS9000, NABL (National Accreditation Board for Laboratories Calibration & Testing) & ILAC (International Laboratory Accreditation Certification). We are specifically recognised for the laboratory and the staff by name, directly by MoEF under the apex Environment (Protection) Act, 1986 (EPA). Our set-up is checked and approved after verification. It involves checking of laboratory instrumentation, its type as categorically specified and technical manpower qualified and experienced. Our Certification therefore has the much-needed seal of authenticity and lawful Govt. acceptance. So even if the cost is little high, the acceptability is wide and hence overall economical. We have given many services to you since 1988. Environment Impact Assessment Study for expansion and new project, Air Pollution testing, Workroom environment monitoring, ETP O & M and so on. You are our esteemed client. This was only possible because of the constant back up and blessings from our esteemed clients. Obliged by the unparalleled faith and support from our clients, we have devised numerable ways to reciprocate what we got from you, Sir. Here are few to list: We are the first to effectively design and install the practice for Pollution Monitoring Work, which is traceable to National Standards, a must for many clients now days. We are the first to think and apply for ISO9002 in this Pollution Monitoring and Operation & Maintenance of Effluent Treatment Plant field. We will be soon applying to QS900, and NABL registration to have results traceable up to international standards. We are the first to have the private quarterly journal dedicated to ‘Environment’ circulated to our wide clientele of 4,560 absolutely free of cost. We Guarantee 100% refund, forthwith on demand, without any deductions whatsoever with 2% interest p.m. in case of unsatisfactory service. There was no occasion for our clients to exercise this option for 152,600 analysis reports given by us in the last 13 years. We have achieved 100% computerisation way back in 1985, i.e. 16 years ago. Our ALL records generated are fully computerised, achieving 92% reduction in paper handling, except the final report we give to our clients. Our all 18 branches all over India and abroad are connected through modem (and now through Website) from 1994. We owe this all to our valuable clients like you and continuing support given by them. This scope of work appears unnecessarily blown-up & fabricated. Is it really required?The scope of work includes all aspects that are covered under all Environmental Laws and good business practices. This includes only what is required. Scope appears blown-up, but it is not. It is only compiled and consolidated. Various statutory related agencies anyhow ask this information in pieces at different time. As such, one never knows the comprehensiveness of the information as brought out by us. Is everyone doing this?Yes, willingly or unwillingly, knowingly or unknowingly, everyone has to generate all this information, if not today then at least tomorrow, at the last moment. It is generally cheap and convenient to generate it in time for its effective and timely use. It becomes easy to maintain continuity and consistency if it is dealt comprehensively and collectively by the same agency at a time. And whether some body does this or not, as an environmentally conscious corporate citizen, you are welcome to do it on your own without waiting for external agency to tell this. What if we do it later when asked for?You may manage to generate or fabricate the data, but the purpose is lost. You may pay the same, but without getting any benefit out of it. The purpose of this is self-assessment, improvement in the working and control of pollution. This can not be achieved if the reliable authentic date is not generated in time, not interpreted properly, and not presented to the management with proper suggestion for control. Why this data is required?There are three main Applications, which are submitted, to State Pollution Control Board (SPCB) for their scrutiny and assessment. In the past this processing of Applications was mechanical. However, in the last 3-4 years, the scrutiny is quite thorough and exhaustive. Few other aspects which are in fact not directly covered under any of the environmental laws such as general house keeping, work room environment, plant ventilation etc. too is being critically examined. We do not aim to say that data is required to only get the Consent Renewal. But the data is meticulously verified to bring out the truth. SPCB is having now set methodology, Joint Vigilance Sampling procedure, and increased random scrutiny in depth by higher rank officers. Why not engage different consultancy agencies recommended by different local SPCB officers, so that every one is happy?The scrutiny is now more objective. There is little scope for subjective satisfaction. Even if the applications are managed and cleared by the local field staff, the staff at other higher offices such as Sub-Regional & Regional Office & Water Pollution Abatement Engineer, Air Pollution Abatement Engineer, Senior Scientific Officer, Regional (Head Quarter) Office level, deals in depth with these applications more technically. As such, it is more important to be correct and consistent. Different agencies for different jobs can think on different lines causing discrepancy in the information submitted. The picture in totality can be disappointing and may give rise to suspicion even in bonafide cases. While dealing for technical scrutiny, different consultants may dodge the bug and responsibility. Information prepared by one may not be suitable for scrutiny on the other front. Which Govt. or other agencies are concerned with this?Local Municipal Corporation, Fire Bridged, Industrial Corporation (MIDC), Financial institutions (Bank, IDBI, ICI, MSFC), Factories Inspector, Safety Committee by Industries Dept., Police, Collector, Parliamentary Committee, Central Pollution Control Board, Ministry of Environment & Forests, New Delhi, State Govt. Environment Dept. and State Pollution Control Board.
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