ENVIRONMENTAL AUDIT REPORT VINILYON

ENVIRONMENTAL AUDIT REPORT OF VINYLON FOOTWEAR INDUSTRY KM 3 KIJAWAL DABI DISTRICT RINGIM L.G JIGAWA STATE Email: [email protected] i AUDIT PREPARERS ALIYU BABA NABEGU, PhD, MWMS, mni Prepra Nig. Ltd Eng. SULAIMAN MUHAMMAD Prepra Nig. Ltd Kabiru Sani Vinylon Footwear Industry limited AMINU ALIYU PrepraNig.ltd Idris Muhammad, Prepra Nig ltd ii LIST OF FIGURES Figure 2.1: Location of Vinylon Footwear Industry limited in Jigawa State Figure 3.1: Average Monthly Rainfall for the Study Area Figure 3.2 Average Monthly Maximum and Minimum Temperature for Study Area Figure 3.3 Average monthly relative humidity Figure 3.4 Average wind speed in the project area Figure 5.1: Communication channels Footwear Industry Limited iii and Responsibilities in Vinylon LIST OF TABLES Table: 3.1 Soil characteristics of the study area Table 3.2 Groundwater characteristics of the study area Table 3.3 Noise level in some sections of Vinylon Footwear Industry Limited Table 3.4: Air quality in Vinylon Footwear Industry Limited Table 3.5: Comparison of Vinylon footwear industry limited wastewater in comparison with NESREA standard Table 4.1: Legal /Regulatory Requirement Criteria Table 5.1: Training programme-summary of training needs Table 5.2 Reporting plan- process summary Table 5.3: Emergency response Table 6.1: NESREA Recommended Personnel Protective Equipment according to hazard type iv LIST OF PLATES Plate 2.1 Google earth Image of the facility Plate 2.2 Snap shot of the main offices of the facility Plates 2.3 and 2.4 Plants and machinery in use in Vinylon footwear industry limited Plate 4.1 A waste collection drum in the facility Plate 4.2 General waste collection point in the facility Plate 4.3 Dump site for the collection and storage of PVC waste Plate 4.4 PVC grinding plant Plate 4.5 Fuel tanks in Vinylon footwear industry limited Plate 4.6 Safety sign in the facility Plate 4.7 Muster point and fire extinguisher Plate 4.8 Fire fighting truck in the facility v TABLE OF CONTENT Title page List of Prepares List of figures List of Tables List of Plates Table of contents Acknowledgement Exclusive Summary CHAPTER ONE: 1.0 INTRODUCTION 1.1 Background 1.2 Objectives of the Environment Audit (EA) 1.3 Terms of Reference of the EA 1.4 The Audit Criteria 1.5 Scope of the Audit 1.6 Approach and Methods CHAPTER TWO: 2.0 OVERVIEW OF VINYLON FOOTWEAR INDUSTRY LIMITED 2.1 Company Profile 2.2 Location of Vinylon Footwear Industry limited 2.3 The Process Technology CHAPTER THREE: 3.0 DESCRIPTION OF SURROUNDING ENVIRONMENT 3.1 Climate 3.2 Geology and Hydrology 3.3 Hydrology 3.4 Soil characteristics 3.5 Groundwater 3.6 Vegetation 3.7 Noise Levels 3.8 Air Quality 3.9 Waste Water CHAPTER FOUR: 4.0 AUDIT FINDINGS 4.1 Observation and Evaluation of General housekeeping 4.2 Impact valuation 4.3Waste Generation from the operation of Vinylon footwear industry limited vi i ii iii iv v vi-vii Viii ix 1-4 4 4-5 5 5-6 6 6-13 14 14 15-17 18-21 22 22-23 23 24 24 24 24-26 27 27-28 28-30 31 31 31 32-35 4.4 4.5 4.6 4.7 Waste Management In Vinylon Facility Impact Analysis Compatibility Fuel Dump 35-39 39-42 42 42 4.8 Cloakroom/Conveniences 4.9 Safety Signs 4.10 Muster Point and Fire fighting equipments 42 43-44 44-45 45-46 4.11 Compliance with Extant regulations 4.12 Compliance to other regulations 46 5.2 Scope and context of Vinylon Environmental Management Plan 47 47 47 5.3 Environmental Policy of Vinylon footwear industry limited 47 5.4 Implementation Of Vinylon Environmental Management Plan 48-49 5.5 Environmental Training Plan of Vinylon Footwear Limited 49-50 5.6 Environmental Reporting 5.7 Health, Environment And Safety Plan (Hse) 51 CHAPTER FIVE: 5.0 ENVIRONMENTAL MANAGEMENT PLAN 5.1 Basis of Environmental Management Plan (EMP) 5.8 Emergency Response Plan 52 52 5.9 Checking And Corrective Action 53 5.10 Management Review 53 5.11 Monitoring Plan 5.12 Covid 19 Management Plan CHAPTER SIX: 6.0 RECOMMENDATIONS 53-56 6.1 General Recommendations 6.2 Specific Recommendations CHAPTER SEVEN: 7.0 FOLLOW UP ACTION PLAN 56-61 62 62 62-69 70 7.1 Completion and submission of EA 70 CHAPTER EIGHT: CONCLUSION 71 APPENDIX 1 72-82 vii ACKNOWLEDGEMENT Prepra Nigeria acknowledges the full cooperation and support of the management and staff of Vinylon Footwear Industry limited. In particular, the support and disposition of Mr Benny has been invaluable to the success of this report. Prepra Nig. Ltd is also grateful to Vinylon Footwear Industry limited for its patronage and the opportunity to be involved in the company‘s quest towards environmental sustainability. Prepra Nigeria ltd wishes to stress that in line with its policy, all information obtained in the course of this Audi exercise as well as those contained in this report will be accorded the strictest confidentiality. viii EXECUTIVE SUMMARY In recent years the growth of waste - solid, gaseous and liquid from industrial processes is the most telling symbol of the new era, even more so than the smoking chimneys. The increasing waste from industrial activities has damaged the esthetic and productivity of the environment and has become a clear factor that could destroy the entire functioning of the earth system. Desirous of complying with extant environmental laws and regulations, Vinylon Footwear Industry limited appointed MESSR PREPRA NIGERIA LTD – a NESREA accredited consultant to conduct the audit. In order to evaluate the impact of the activities of Vinylon Footwear Industry limited, an assessment of the location in terms of compatibility and of the processes and housekeeping of the factory was undertaken. This initial contact ensured management consent and selection of audit team from the company. Standard questionnaire was administered to the management and key staff to obtain information that was used in the facility inspection as well as examination of records and documents of the company. This environmental audit (EA) was carried out with strict adherence to the guidelines and regulation of the National Environmental Standards and Regulations Enforcement Agency (NESREA) in particular, NESREA Act, Section 7 (a) which vests in the Agency the responsibility to enforce compliance with laws, guidelines, policies and standards on environmental matters;Section 7 (j), that empowers the Agency to enforce environmental control measures through registration, licensing and permitting systems; Section 7 (k) of the Act that empowers NESREA to conduct environmental audit and establish data bank on regulatory and enforcement mechanisms of environmental standards;Regulations S. I No 29, that requires existing industries to undertake environmental audit and submit reports of such every three (3) years. The main activity in Vinylon Footwear Industry limited is the production of footwear from PVC. A major in put in the production process is the use of recycled material thereby reducing the amount of PVC going into landfill and more significant the reduction in the use of virgin material thereby conserving resources. This Audit exercise indicated that the operation of Vinylon Footwear Industry limited will result in short and long term adverse impact to the environment as well as nuisance to the community especially from emission of gasses which is by far the most dominant waste product. Thus various strategies for mitigation have been proffered as well as to minimize the generation. In addition, suggestions were made in the report that will ensure environmental management through the use of monitoring. ix Prepra Nigeria Limited 1.0 CHAPTER ONE: INTRODUCTION 1.1 BACKGROUND Plastics are a range of synthetic or semi-synthetic polymerization products that can be molded into a permanent object having the property of plasticity. They are also called polymers, which are high molecular weight materials consisting of repeating units of hydrocarbon molecules. Plastics are classified in different ways: by the method of production, density differences, chemical structure, and other classifications, each of which can be identified by available standards. When classified based on the chemical structure, there are acrylics, polyesters, silicones, polyurethanes, and halogenated plastics; when based on method of production, there are condensation, poly-addition and cross-linking (Joanne and Stephanie, 2011). In terms of application, it is classified in terms of response to temperature as thermoplastics and thermosetting. Thermoplastics do not undergo chemical change in their composition when heat is applied and can be remolded while thermosets once melted, undergo an irreversible chemical process and can only take shape once. Examples of thermoplastics are polyethylene, polypropylene, polystyrene and polyvinyl chloride, while the commonest example of thermoset is rubber (Perry and Green, 2008). Plastics are basically high molecular weight materials derived from petroleum chemicals. They are made of repeating units of small molecules called monomers (Ebewele, 2000). It is one of the most commonly used materials in daily life world over, owing to its light weight, easy shaping and colouring, and poor conduction of heat. Plastics are one of the most commonly used materials in present day applications due its properties which includes, resistance, durability, low cost and ease of production (Gao, 2010). Despite its versatility, plastic and in particular PVC, it does not degrade easily. Consequently, there has been growing concerns on the impact of solid wastes to the environment, 1 Prepra Nigeria Limited especially non-biodegradable wastes. In Nigeria, plastic wastes have been found to be the second most abundant solid waste (Nabegu, 2010 and Ayuba et al, 2013). At present, the vast amount of PVC-containing wastes in Nigeria is disposed of in landfill. Most of the remaining PVC waste is co-incinerate with municipal solid waste (MSW) by scavengers. Other related concerns include the possible formation of traces of toxic chlorinated organic compounds from emissions of hydrogen chloride (a major combustion product), and its impacts on other releases and discharges from burning fires at the dump site. However, its major advantage is that is cheap or easy to recycle. However, despite its recycling potential, the realization of the potential damaging consequences of continued generation of PVC waste necessitate, its management in order to ensure sustainable development. Environmental protection is considered the most important consideration for sustainable development. Consequently, globally, environmental regulatory agencies now embrace comprehensive, multi-statute solutions to facility permitting, compliance and regulatory development issues. In relation to organization‘s activities, sustainable development involves meeting the current need of the organization while protecting recourses so that future generations are able to meet their needs. In Nigeria a key regulatory requirement put in place to ensure sustainable operation of facilities is the Environmental Audit. Environmental Audit (EA) is a systematic, documented, periodic and objective evaluation of how well organizations, management and equipment are performing with the aim of safeguarding the environment and human health in order to meet the requirements for sustainable development. It is designed to protect the environment with the aim of: 2 Prepra Nigeria Limited  Assessing performance against a set of requirements or targets related to specific issues  Evaluating compliance with environmental legislation and corporate policies  Measuring performance against the requirements of an environmental management system standard  Exploring the potential economic, social and environmental benefits that an improved performance can achieve. The National Environmental Standards and Regulations Enforcement Agency (NESREA) is responsible for ensuring that all businesses and organizations comply with environmental laws that protect the environment and public health in Nigeria through;  The NESREA Act, Section 7 (a) vests in the Agency the responsibility to enforce compliance with laws, guidelines, policies and standards on environmental matters  Section 7 (k) of the NESREA Act empowers NESREA to conduct environmental audit and establish data bank on regulatory and enforcement mechanisms of environmental standards other than in the oil and gas sector  Section 8 (k) of the NESREA establishment Act also empowers the Agency to make Regulations. One of such made is the ―National Environmental (Permitting and Licensing System) Regulations, 2009; S. I No. 29‖  All the extant national sectorial environmental regulations require existing industries to undertake environmental audit and submit reports every three (3) years. 3 Prepra Nigeria Limited  In relation to Vinylon facility, NESREA regulation on National Environmental (Domestic and Industrial Plastic, Rubber and Forms Sector) Regulations, 2011. Organizations that conduct environmental audit clearly demonstrate to its employees, customers and stakeholders that it is committed to improving its environmental performances. In addition, it portends that the professionals within the organization are interested in environment issues and wish to maintain regulators‘ environmental concern of governance. obtaining Environmental effective Audit day-to-day regulatory compliance with limited resources. addresses monitoring of In addition, it aids in targeting enforcement actions because it differentiates between compliers and non-compilers. Environmental auditing has the long-term potential for improving relations between the regulators and regulated. Besides pursuing sanctions, NESREA acknowledges and encourages organizations that demonstrate innovative approaches to environmental management through its NESREA GREEN MARK. Tis audit report is the second to be submitted by Vinylon footwear industry limited having submitted successfully its first audit in July 2020. This is a further demonstration of its commitment to environmental regulations and compliance in particular to the extent regulation of NESREA. 1.2 OBJECTIVES OF THEENVIRONMENTAL AUDIT (EA) The objectives of this EA include:  Generation of adequate environmental information of Vinylon footwear industry limited facility for the potential environmental risks that are likely to emerge from its operations on the immediate environs.  Achieving resources optimization and improved process performance by Vinylon footwear industry limited. 4 Prepra Nigeria Limited  Encouraging Vinylon footwear industry limited to self - regulate their environmental practices and to increase their responsibilities to stakeholders and society.  Ensuring compliance by Vinylon footwear industry limited not only with laws, regulations and standards, but also with company policies and the requirements of the approved NESREA endorsed Environmental Management Plan.  Enabling Vinylon footwear industry limited to anticipate and respond adequately and effectively to environmental problems and risks  Minimizing human exposure to risks from environmental health and safety problems to staff and community in the vicinity of Vinylon footwear industry limited. 1.3 TERMS OF REFERENCE OF THE EA For the purpose of the mandatory Compliance Audit due every three (3) years; this audit assesses compliance of Vinylon footwear industry limited with criteria derived from:  National Environmental standards and Regulations enforcement Agency provided in sections 21 of the S.I.9 regulations of 1991 on National Environmental protection (pollution abatement in Industries and facilities generating wastes)  National Environmental (Domestic and Industrial Plastic, Rubber and Forms Sector) Regulations, 2011.   Corporate or management policy of Vinylon footwear industry limited NESREA Approved Environmental management footwear industry limited 1.4 THE AUDIT CRITERIA Audit criteria considered in this study include: 5 plan of Vinylon Prepra Nigeria Limited  Industry codes of practice  Specified organizational requirements (e.g. compliance with company environmental policy)     Environment protection Act Environment protection regulations Conditions of licenses, workers approvals and exemptions Other applicable Federal/State / Local government - environment legislations  Standards, rules, orders, etc., made under an act and having the force of law  International agreements such as, conventions, protocols, and treaties which have been ratified by the government.  Conditions contained in facility permits  Codes of professional practice/ international code of conduct  Good environmental management 1.5 SCOPE OF THE AUDIT The scope of this Audit exercise covers the following:  Evaluation of Vinylon footwear industry limited‘s existing Environmental management system  The existing environmental policy and objectives  Housekeeping and records  Existing strategies for environmental improvement  Vinylon footwear industry limited compliance status with statutory laws and regulations 1.6 APPROACH AND METHODS This environmental audit was undertaken in three phases: 6 Prepra Nigeria Limited  Pre – audit  On – site audit  Post – audit 1.6.1 PRE – AUDIT PHASE This is the audit preparation phase prior to visit by an audit team. It entailed:  Obtaining full management commitment for PREPRA NIG LTD to embark on the audit  Setting overall goals, objectives, scope and priorities for the audit  Selecting a team to ensure objectivity and professional competence  Sending out prepared pre-audit questionnaire to management and staff of Vinylon footwear industry limited ( Appendix1)  Reviewing background and operational information with the management of Vinylon footwear industry limited.  Conducting initial site visit at Vinylon footwear industry limited‘s facility. Plate 1 shows the consultant with audit team on the initial site visit to generate check-list of issues that require in-depth investigation.  Reviewing audit plan and arranging logistics. Plate 1.1 Initial site visit at Vinylon footwear industry limited‘s facility 7 Prepra Nigeria Limited i) Management commitment A letter from the management of Vinylon footwear industry limited to Prepra Nigeria to conduct the audit was duly signed by the CEO. This signaled the commencement of the audit. ii) Team selection The audit team was carefully selected and includes employees of Vinylon footwear industry limited and Prepra Nigeria. The team leader was a NESREA accredited consultant while the other team members have skills and knowledge relevant to the audit process. Each member of the team was assigned his/her role and responsibilities and pre-audit training was done to ensure that all the team members are adequately prepared for the task. In addition to other relevant information requested for in the questionnaire used (Appendix1), the following information was also collected by the team members:  Identifying types of pollutants and waste generation, storage, transportation, treatment and disposal as well as the general practice:  Identifying requirements, regulations and limitations as applicable in the form of Permits and Licenses  Federal and State database relevant to Vinylon footwear industry limited, such as, any nearby abandoned, inactive or uncontrolled hazardous waste sites; Industrial landfill; Municipal landfill; Solid waste sites and Drinking water sources 1.6.2 On site audit phase The purpose of the on-site audit phase was to collect verifiable evidence to determine whether audit criteria are being complied with. This entailed well defined and systematic use of check list which started with: 8 Prepra Nigeria Limited 1.6.2.1 Conducting opening meeting with factory manager and site personnel to:  Identify areas to be inspected  Outline procedures  Outline schedules  Identify records and documents to be reviewed during audit  Review health and safety requirement  Review how confidential data will be handled 1.6.2.2 Undertaking a review of relevant documents such as:  Corporate or/and management policy  NESREA endorsed Environmental Management Plan (EMP)  Management system documentation  Operational procedures and records  Records (inventory, utility, monitoring, transportation, training)  Environmental monitoring/quality records  Correspondence on environmental committee/team meeting minutes  Previous environmental audit report (if available) 1.6.2.3 Conducting staff interview to obtain information on actual practices; awareness level; expectations and possible suggestions through:  Identifying key facility personnel  Scheduling ahead of time, meeting in work areas  Confirming interview time 1.6.2.3 Conducting detailed on - site inspections with the relevant audit checklist This exercise was conducted to investigate the presence of sensitive sites within the neighborhood of Vinylon footwear industry limited that are capable of impacting on the data collected such as the nature of the past 9 Prepra Nigeria Limited and present usage of the factory; nature and operations in adjourning properties - type and use past and present; above ground storage tanks; Air sources mobile and stationary; Presence of Asbestos; Boilers usage; Contaminated sites; Drinking water quality cross connections; Discharges to groundwater; Neighboring wetlands and waterways protection; PCB containing transformers and/or other PCB regulated equipment; Sewage and septic system discharges etc. 1.6.2.4 Collecting samples for Analysis 1.6.2.4.1 Procedure for collection of water samples Samples of groundwater representing the existing conditions in Vinylon footwear industry limited were collected from 7 wells at different locations over a period of seven days in suitable polythene containers with screw cap for laboratory analysis. In addition waste water from the drainage within the facility was collected for the determination of physio-chemical characteristics. 1.6.2.5. Conducting a material balance The mass balance approach that was used in this study is based on the simple principle that the total mass of material going into the process should equal the total mass going out i.e. Input – Losses=Outputs The mass of inputs to the process in Vinylon footwear industry limited should balance the mass of outputs as products, emissions and wastes, plus any change in stocks. This simply entailed the following steps.  Assembling unit process input and output information  Deriving a preliminary material balance for unit processes  Evaluating the material balance  Refining the material balance 10 Prepra Nigeria Limited 1.6.2.6 Debriefing of the management on audit findings, recommended corrective actions This exercise involved meeting with the management of Vinylon footwear industry limited in order to discuss the observations made with a view to identifying actual and/or imminent threats to health and the environments; identifying actual noncompliance; identifying potential non-compliance; identifying and discussing information gaps; identifying and discussing unclear audit findings. 1.6.2.7 Environmental monitoring data In evaluating environmental monitoring data, the following amongst others were considered:  That the sampling analysis and procedures are appropriate and that results comply with relevant national guidelines  That the steps taken to collect, review evaluate or verify data are consistent with accepted best practices  That management of data obtained in the course of audit process such as: index, facility records, correspondence, include date, time, what, when etc. 1.6.3 Post audit activities The objectives are to produce an environmental audit report with audit findings and recommendations and to contribute toward formulation of an action plan for continuous improvement of operations of Vinylon footwear industry limited. 1.6.3.1 Actions in post audit phase  Collation of information and follow up on outstanding issues 11 Prepra Nigeria Limited  Evaluation of findings including outcome of material balance and impact evaluation of Vinylon footwear industry limited process on the environment.  Preparation of the draft audit report in the approved presentation format  Circulating draft audit report for comments to managements and audit team  Incorporating or resolving all comments  Preparation of an action plan with consultation with the management of Vinylon footwear industry limited to incorporate the following:  A list of recommended actions in terms of increasing cost effectiveness in addressing the facility‘s critical environmental issues.  Interim and long term targets/objectives and a time-table for achieving them for environmental improvement in the operation of Vinylon footwear industry limited  An indication of investments and other resources (human and information) that would be required at Vinylon footwear industry limited without compromising commercial confidential information  Produce report for use of Vinylon footwear industry limited and NESREA  Facilitate the implementation of action plan at the management level of Vinylon footwear industry limited 1.6.3.2 Evaluation of findings The information gathered and data collected together with the overall findings of this Audit report will be reviewed in line with the extant regulations with the Vinylon footwear industry limited management. key rules in discussing the findings are:  The exact nature of the problems should be clearly stated. 12 The Prepra Nigeria Limited  Communicating the extent of the problem fully stating whether there is compliance or noncompliance.  Providing good management practices suitable to Vinylon footwear industry limited 1.6.3.3 Steps After analyzing the result of findings:  Prioritizing the problems/impacts and Allocating responsibilities/roles  Developing a plan of action and Assessing the effectiveness of plan and effect a change if it is not effective  Making all necessary agreed changes with facility management and documenting and communicating the changes to the management of Vinylon footwear industry limited. 1.6.3.4 Implementation of the action plan Responsibilities needed to be undertaken according to unit and timeline for completion within the environmental action plan framework will be stated. 1.6.4 AUDIT PERIOD The audit was conducted between 6th June and 20th July, 2023. 13 Prepra Nigeria Limited 2.0 CHAPTER TWO: OVERVIEW OF VINYLON FOOTWEAR INDUSTRY LIMITED 2.1 COMPANY PROFILE The Company VINYLON FOOTWEAR INDUSTRY LIMITED RC. NO. 617050 Date of Incorporation 18/2/2005 Registered office KM 3 KIJAWAL DABI DISTRICT RINGIM L.G JIGAWA STATE Telephone No 234 (0) 08036546890 Email [email protected] Nature of Activity PVC FOOTWEAR Installed Capacity 3,000 Bags per day (1)PVC 1091 Raw Materials (2)STABILZER-LCB330 (3) D.O.P. (4)PLASTICIZER E-03 Manpower Total Workforce Female 992 workers 32 Male 960 14 Prepra Nigeria Limited 2.2 LOCATION OF VINYLON FOOTWEAR INDUSTRY FACILITY Vinylon footwear industry limited is located at Km 3 Kijawal, Dabi, Ringim local government of Jigawa state. The location is shown in Figure 2.1. Figure 2.1: L Location of Vinylon footwear industry limited within Jigawa state 15 Prepra Nigeria Limited The factory is sited between latitude 120. 09`629 and longitude 80.88`531.Based on the coordinates, the exact position of the factory is shown in Plate 2.1 as extracted from Google earth. Plate 2.1 Google earth Image of the facility The factory site is very firm, relatively level and well drained. Vinylon Footwear Industry Limited is located off - the main trunk, A road that links Kano and Ringim. More 70% of the land area of the facility is built up with structures consisting of the main factory, office, power house, fuel storage tank, water treatment area, recycling plant and parking lot. The surface ground is covered in concrete with landscape consisting of various trees and flowers. The whole structures on the premises have been approved by 16 Prepra Nigeria Limited Jigawa state urban planning development authority. Plate 2.2 shows a typical machinery used in the facility. Plate 2.2. Atypical machinery in use in the facility 17 Prepra Nigeria Limited 2. 3 THE PROCESS TECHNOLOGY 2.3.1 PVC production PVC has found widespread use because of its desirable properties of very low cost, and versatility. It starts as a powder that is derived from salt and fossil fuel. The ability to manipulate its characteristics through selection of the appropriate manufacturing and fabrication processes and the use of appropriate additives, including plasticizers for flexible products, is unmatched by any other thermoplastic material. Ninety-four percent of PVC is produced by suspension polymerization in which the monomer is suspended in an aqueous mixture containing buffers, initiators, and colloidforming agents, and reaction conditions are controlled to produce material with the desired molecular weight distribution, particle size, and particle morphology. The finished PVC resin is separated from the aqueous mixture, dried, and sold in powder form. PVC is made by other polymerization techniques when material with specific properties is required. For example, emulsion polymerization is used to produce plastisols, which are fluid dispersions of PVC in plasticizers that are used to make calendared and coated products such as shower curtains and raincoats. Non-aqueous solution polymerization in organic solvents is used to produce specialty polymers and copolymers that are used in other coating and calendaring applications such as floor tiles. The PVC-containing products that consumers such as the footwear produced by Vinylon footwear industry limited use every day are always produced from mixtures of PVC resin that have been compounded with other materials, sometimes into pellet form, before being fabricated into their final forms. In addition, to produce the footwear, PVC products are added with about 10 to 20% by weight of various additives and fillers. The additives include stabilizers, pigments, impact modifiers, and processing aids that are used to facilitate the fabrication processes. PVC products used in Vinylon 18 Prepra Nigeria Limited footwear industry limited also incorporate significant amounts of recycled materials that reduce product costs without compromising flexibility, toughness, and mechanical strength. The use of recycled materials is also significant in reducing large amount of waste that will otherwise end up in the landfill with the attendant environmental damages. It also serves to conserve the use of fresh/virgin material thereby conserving resources. PVC processing techniques Footwear produced by Vinylon footwear industry limited emanates from a number of processes, including extrusion, injection molding, calendaring, coating and thermoforming. Extrusion: This is a manufacturing process that uses a device similar to a pasta machine. The PVC resin is fed into the extruder which typically contains two screw-like shafts. The shafts are rotated to push the resin forward where it is extruded through the outlet die. This technology is used to make pipe, conduit, siding, window frames, interior moldings, film, and sheet. Injection molding: This is a manufacturing process that injects PVC resin into a metal mold by pressure. This process is best suited for production of three-dimensional structures. This technology is used to produce pipe fittings, containers, and buckets. Calendaring: This is a manufacturing process in which resin is heated and kneaded while passing through several pairs of rollers to be pressed to the required thickness. This technology is used to produce wide, flat products like floor tiles, geomembranes, artificial leather, and wall coverings. Coating: This is a manufacturing process that applies a PVC-based solution to one surface of PVC film or fabric and then dries it by heat to produce the final product. This technology is used to make large tents, connecting sections of trains, sign boards, and table cloths. 19 Prepra Nigeria Limited Thermoforming: This is a manufacturing process in which PVC sheet or film (either extruded or calendared) is heated to soften it, and then is pulled into a metal mold by a vacuum. This technology is used to make egg cartons, food trays, blister packaging, and press-through packaging for pills. Both rigid and flexible forms of PVC can be extruded, but the equipment and processing techniques required are tailored to the properties of the compounded materials, and differ from those used with other thermoplastics. Injection and blow molding techniques are used to produce a variety of rigid products, while other molding techniques are used to produce flexible products. Calendaring is used to produce both rigid and flexible products in film or sheet form, often with a backing material to form laminated products. PVC resins compounded into plastisols are applied to various substrates to produce a range of coated products for industrial and consumer applications such as dishwasher racks and tool handles. Plates, 2.3 and 2.4 shows a snap shot of the facility. 20 Prepra Nigeria Limited Plates 2.3 and 2.4 Snap shot of the Vinylon footwear industry limited facility 21 Prepra Nigeria Limited 3.0 CHAPTER THREE: DESCRIPTION OF SURROUNDING ENVIRONMENT OF VINYLON FOOTWEAR INDUSTRY LIMITED 3.1 Climate Table 3.1 shows the average monthly maximum and minimum distribution of climatic elements in the area for the period 1981and 2022. The climate of the study area is the tropical dry-and-wet type. The seasonal migration of the Inter-Tropical Convergence zone (ITCz), also known as the InterTropical Discontinuity (ITD), gives rise to two seasons, one dry and the other wet. The wet season lasts from June to September although May is sometimes humid. The dry season extends from mid-October of one calendar-year to mid-May of the next. Table 3.1: Mean Climate Conditions in Ringim Month Temperature oC Rainfall (mm) Evaporation (mm) Sunshine (hr/day) Relative Humidity (%) Mean Range Jan 21.2 17.8 0.0 133.3 9.0 28 Feb 23.7 20.9 0.3 141.1 9.0 25 Mar 27.7 18.5 1.8 182.8 8.6 23 Apr 30.5 16.4 8.9 195.5 8.4 36 May 30.4 13.6 70.2 187.9 8.8 51 Jun 2S.1 13.0 132.7 156.3 8.7 65 Jul 25.7 10.7 210.9 126.4 7.5 7S Aug 24.9 9.0 314.0 112.7 6.0 S3 Sep 25.9 10.9 132.8 126.5 7.9 79 Oct 26.8 16.5 12.8 144.0 9.5 58 22 Prepra Nigeria Limited Nov 24.6 19.7 0.0 139.9 9.8 37 Dec 21.7 18.7 0.0 127.4 9.2 32 There are three main temperature seasons. A cool and dry season lasts from November to February, during which the mean monthly temperature is between 21 and 23 o C with a diurnal range of 12-14 oC. The Harmattan winds prevail at this time. This period is usually followed by a hot and dry season which lasts from March to mid-May. The mean monthly temperature during this period is in excess of 30 oC and the daily range is up to 20 oC. This is followed by the wet season which is warm, with mean monthly temperatures about 26 oC and a diurnal range of about 10 oC, rising to 13 oC in September. The average monthly relative humidity for the area is between 51.7% and 74.2% during the rainy season (June to September), where the maximum is recorded in the month of August. Lower values are recorded during the dry season months. The average monthly wind speed in the study area ranged from 6.88 to 11.79 Knots with the maximum recorded in June. There are some occasional calmness within significant wind speed mostly experienced between August and November. There are two major wind directions in the region, namely, the south-west and north-east directions. The northeast wind predominates during the dry season bringing a large amount of dust while the southwest winds are predominant during the wet season. 3.2 Geology and Hydrogeology The project area is located in the northwestern part of Nigeria and it falls within the Chad formation that consists predominantly of recent Aeolian deposits. Within the proposed project site, the Chad sediments are concealed by sand dunes with no surface out crops. 23 Prepra Nigeria Limited 3.3 Hydrology Jigawa State is blessed with both surface and subsurface water resources, with its greatest potential based on ground water. The drainage of the Jigawa state is mainly part of the inland drainage system of the Chad Basin. The main drainage consists of the headstreams of the river system known as the Yobe in Borno State, particularly the Kano, Challawa and Gaya Rivers. 3.4 Soil characteristics Soil samples in 30 different process areas of the factory was taken to get a representative sample were analyzed in the laboratory to determine the characteristics of the soil. The analysis is shown in Table 3.2. The purpose is to use the data as baseline data for control/monitoring. 3.5 Groundwater The amount of groundwater available in the study area is determined by the amount of rainfall each year. The result of the analyses on ground water is presented in Table 3.3. The parameters analyzed are good indicators of groundwater quality. 3.6 Vegetation The typical natural vegetation of the study area is the savanna vegetation which is a response to the long dry season lasting 5- 8. The vegetation is characterized by expanse of short grasses, usually 1.0 to 1.5 meters tall and scattered low trees with wide canopies. Continuous cultivation which has been in practice for centuries has all but destroyed the natural vegetation giving way to man-made vegetation consisting of his cropped land, reserved forests, planted forests, shelterbelts and other such establishment 24 Prepra Nigeria Limited Table: 3.2 Soil Characteristics in Vinylon Footwear Industry Limited S ID SS1 SS2 SS3 SS4 SS5 SS6 SS7 SS8 SS9 SS10 SS11 SS12 SS13 SS14 SS15 SS16 SS17 SS18 SS19 SS20 SS21 SS22 SS23 SS24 SS25 SS26 SS27 SS28 SS29 SS30 pH (H2O) EC (dS/m) O.C (%) 6.09 6.03 5.9 6.22 0.04 0.04 0.04 0.15 0.17 0.05 0.04 0.05 0.07 0.07 0.03 0.03 0.05 0.05 0.04 0.03 0.01 0.02 0.02 0.09 0.14 0.03 0.03 0.02 0.02 0.03 0.03 0.03 0.04 0.04 6.26 6.75 6.63 6.31 6.12 6.02 6.09 6.03 6.08 6.09 6.03 4.52 4.79 4.78 5.18 6.27 6.49 6.77 6.29 6.1 5.93 5.76 5.65 5.75 5.76 5.91 0.35 0.10 0.49 B (mg/kg) 5.85 7.48 4.68 Na (cmol/kg) 0.25 0.14 0.18 0.41 0.48 0.37 0.06 0.32 0.65 0.56 0.34 0.11 0.13 0.53 0.51 0.32 0.61 0.57 0.41 0.45 0.75 0.61 0.57 0.26 0.18 0.32 0.41 0.14 0.30 0.10 3.74 5.29 4.02 5.89 4.86 4.35 4.49 3.98 4.21 4.16 4.26 6.41 3.98 5.19 4.21 5.24 4.26 4.30 3.70 3.13 3.41 3.51 3.60 4.02 4.40 4.02 4.40 0.17 0.19 0.16 0.40 0.17 0.53 0.20 0.22 0.16 0.16 0.17 0.18 0.27 0.25 0.19 0.22 0.18 0.17 0.19 0.17 0.27 0.15 0.12 0.12 0.23 0.24 0.14 Texture loamy sand Sand Sand Ca(cmol/kg ) 2.22 1.83 2.74 Cu (mg/kg) 1.725 2.974 1.655 Fe (mg/kg) 14.89 0.40 6.52 Mn (mg/k g) 75.211 47.37 37.10 Zn (mg/k g) 26.27 19.59 23.57 Cr (mg/k g) 0.53 0.49 0.38 Cd (mg/k g) 0.64 0.23 0.09 Pb (mg/kg ) 1.28 4.82 0.71 loamy sand loamy sand Sand loamy sand Sand loamy sand Sand Sand Sand Sand Sand Sand sandy loam Sandy loam loamy sand Sand Sand Sand Sand Sand Sand Sand Sand Sand Sand Sand Sand 3.38 3.58 2.39 4.28 2.63 2.62 2.28 2.22 2.56 1.87 3.10 2.22 2.80 2.70 2.60 4.10 2.47 2.31 2.22 3.26 2.92 2.15 2.09 1.82 2.82 4.05 2.08 6.882 4.147 3.471 1.794 3.255 2.108 0.767 2.013 1.435 1.771 1.586 2.157 2.171 3.28 3.21 2.367 2.275 2.269 2.346 2.342 2.308 2.341 2.666 2.377 2.775 0.919 2.352 26.92 128.59 11.58 9.07 14.24 20.77 9.71 7.72 8.60 9.74 7.73 10.95 32.28 17.956 10.693 8.49 12.19 10.24 7.34 6.97 6/10 6.75 2.50 9.72 25.96 19.85 17.65 108.02 137.93 45.78 30.37 30.568 78.55 50.805 8.22 6.68 8.23 6.91 12.26 25.11 21.29 24.97 20.85 67.91 60.29 25.08 24.16 22.97 35.72 18.06 31.82 46.99 48.03 49.76 26.65 25.54 32.89 18.44 23.59 28.45 28.45 24.15 21.6882 114.08 38.31 17.27 19.8319 18.50 20.08 17.68 20.82 24.77 14.3553 10.52 17.30 15.01 14.62 14.28 19.51 20.46 17.84 0.51 0.50 0.56 0.65 0.68 0.81 0.86 0.73 0.66 0.97 1.00 0.61 0.57 0.56 0.88 0.90 1.06 0.69 0.61 0.89 0.61 0.66 0.94 0.80 1 0.89 0.73 0.15 0.14 0.48 0.45 0.31 0.28 0.26 0.10 0.67 0.19 0.20 0.19 0.47 0.05 0.15 0.15 0.322 0.27 0.587 0.45 0.41 0.04 0.20 0.07 0.07 0.19 0.02 4.13 2.38 1.33 2.08 1.78 3.03 2.16 0.37 1.33 0.86 2.18 3.28 3.20 3.63 1.26 2.73 1.04 2.41 1.23 1.78 67.40 1.00 123.01 1.55 1.44 1.44 0.84 25 Prepra Nigeria Limited Table 3.3 Groundwater characteristics in Vinylon facility pH (H2 0) 7.32 EC (ds. m) 0.22 B (mg/ l) 2.95 Na (mg/ l) 8.96 S (mg/ l) 10.29 Ca(m g/l) 67.62 T Hardnes s 88.06 Cu (mg/ l) 0.03 Fe (mg/ l) 0.21 Mn (mg/ l) 0.93 Zn (mg/ l) 0.89 Cr (mg/ l) 0.06 Cd (mg/ l) 0.08 7.31 0.23 7.39 3.13 8.62 9.31 74.06 94.42 0.03 0.48 0.29 4.04 0.03 0.08 0.12 0.24 4.26 12.60 12.75 45.95 60.42 0.02 0.94 0.43 0.82 0.01 0.07 0.14 7.21 0.20 4.44 10.12 9.80 55.36 66.58 0.15 0.84 1.09 3.96 0.05 0.08 0.11 7.14 0.21 3.88 7.96 11.27 42.32 56.79 0.01 0.38 0.90 1.90 0.07 0.07 0.20 7.2 0.26 3.41 12.27 10.78 32.24 48.37 0.01 0.26 0.62 1.80 0.06 0.04 0.22 6.88 0.46 3.70 11.11 9.31 32.33 44.84 0.01 0.16 1.02 1.17 0.05 0.03 0.16 7.12 0.32 3.98 9.12 10.78 60.01 77.63 0.03 0.22 1.61 0.67 0.05 0.04 0.07 6.97 0.24 4.16 9.78 8.33 34.38 45.92 0.02 0.13 0.46 0.25 0.01 0.02 0.09 7.00 0.20 3.65 5.64 15.20 86.62 107.42 0.01 1.13 1.35 1.41 0.03 0.05 0.14 6.97 0.06 3.79 6.63 10.29 62.19 83.35 0.10 0.20 1.34 0.97 0.05 0.04 0.02 6.83 0.23 3.84 8.62 11.27 63.17 87.51 0.02 0.59 0.80 1.50 0.05 0.06 0.07 6.64 0.27 4.30 8.79 11.76 57.88 77.35 0.01 0.05 0.60 0.76 0.06 0.01 0.07 6.81 0.24 3.60 12.27 24.51 65.23 81.83 0.01 2.20 0.89 1.96 0.04 0.09 0.00 6.61 0.07 3.70 8.62 25.00 37.17 46.87 0.04 1.89 0.48 4.02 0.05 0.15 0.07 26 Pb (mg/ l) 0.07 Prepra Nigeria Limited 3.7 Noise levels Noise level within identified units of Vinylon Footwear Industry Limited plant were measured and compared with the NESREA permissible limits as shown in table 3.4. Most units of Vinylon Footwear Industry Limited is within the limit but the area in the vicinity of the power house limit, however, since there is no presence are well above the of workers all the time in the area, it does not constitute a risk to the long term health of the workers. Table 3.4 Noise level in some sections of Vinylon Footwear Industry Limited Sites within Noise level NEAR THE GENERATOR HOUSE 118dB AVERAGE WITHIN THE FACTORY 60dB NEAR THE OFFICES 30dB NESREA STANDARD FOR 90dB INDUSTRY 3.8 Air Quality Air qualities within identified units Vinylon Footwear Industry Limited plant were measured as shown in table 3.5. The main sources of the gases identified in the facility are emission from boilers, power plant and heavy duty vehicles. 27 Prepra Nigeria Limited Table 3.5: Air quality in Vinylon Footwear Industry Limited S/N Measured Parameters UNIT Average NESREA values from LIMITS 3 sites in GUIDLINE Vinylon VALUE 1 PM Mg/Nm3 12 20 2 Nitrogen Oxides Mg/Nm3 170 300 3 Hydrogen Chloride Mg/Nm3 5 10 4 Sulphur Oxides 5 Vinyl Chloride(VCM) 6 Acrylonitrile 115 500 g/t s-PVC 40 80 g/t e-PVC 170 500 Mg/Nm3 0.3 5 (15 from dyers) 7 Ammonia Mg/Nm3 4 15 8 VOCs Mg/Nm3 15 20 9 Dioxins/Furans Ng TEQ/Nm3 NIL 0.1 Most areas have emission of gases within the limit but the observed variation not only indicated differences in the levels of air quality, but also potential problem that require attention especially the area in the vicinity of the power house and the Boiler/cooling systems 3.9 Waste water The main source of wastewater in Vinylon footwear industry limited is from domestic use. However substantial amount of water is also sourced from the washing of waste plastic prior to recycling and the cooling system of the power plant. Table 3.6 shows the analysis of the waste water in comparison with the NESREA standard for wastewater. Clearly, the waste water is devoid of any chemical impurities. The major impairment is related to solids which 28 Prepra Nigeria Limited are dirt and sand from the collected waste PVC used for recycling. Another major impairment of quality in the waste water is the oil and grease from the power house fuel and spent oil from the injection machinery that requires lubrication. Other sources of impairment are residue of chemicals associated with soaps and detergents used domestically and in cleaning of waste material used for recycling. Table 3.6: Comparison of Vinylon footwear industry limited wastewater in comparison with NESREA standard Parameter NESREA Vinloyn footwear industry Remark permissible limited wastewater limits Analysis 0 Temperature Less than40( C) 35.70 OK Colour Colourless Grey OK Ph 6-7 6.4 OK 0 BOD5 at 20( C) 50 44 OK Total suspended solids 25 15 OK Total dissolved solids 2,000 1140 Fair Chloride (as Cl ) 600 520 OK 2Sulphate (as SO4 ) 500 489 OK -2 Sulphide (as S ) 0.2 Nil OK Cyanide (as CN ) 0.1 Nil OK Detergents (linear 15 20 Fair alkylate sulphonate as methylene Oil and grease 10 8.5 Fair Nitrate (as N03 ) 20 14 Fair 3Phosphate (as PO4 ) 5 4 Fair Arsenic (as AS) 0.1 Nil OK Barium (as BA) 5 0.12 OK Turbidity 10 14 Poor Iron (as Fe) 20 9.76 OK Manganese (as Mn) 5 1.67 OK Phenolic compounds (as 0.2 0.45 Poor phenol) Chlorine (free) 1.0 0.11 OK Cadmium (Cd) Less than 1 0.1 OK 29 Prepra Nigeria Limited Chromium Trivalent and hexavalent Copper Lead Less than 1 Nil OK Less than 1 Less than 1 Nil Nil OK OK 30 Prepra Nigeria Limited 4.0 CHAPTER FOUR: AUDIT FINDINGS 4.1 EVALUATION OF GENERAL HOUSE KEEPING 4.2 IMPACT EVALUATION 4.2.1 Impact Evaluation The evaluation of impact is to determine the significance of identified impacts based on the following clearly defined criteria:  Legal/Regulatory requirement  Risk posed by impact  Frequency of occurrence of impact  Importance of affected environmental component and impact  Public interest/concern & perception The above criteria and the rating adopted for the evaluation are described as follows: Legal/Regulatory Requirement Impacts were weighed against existing legal/regulatory requirements to determine if the issue is affected by legislation or whether permits are required. Such legal/regulatory requirements were identified from the laws/guidelines, as well as those regulations in the source references relating to the Vinylo n foo tw ear industry limite d operations. The rating used for this criterion is as shown in table 4.1 Table4.1: Legal/Regulatory Requirement Criteria Legal/Regulatory Ratin Condition Requirement Low g 1 No Medium 3 carrying out the activity Legal/regulatory requirement High 5 carrying out the activity A p e r m i t i s required prior to carrying out legal/regulatory the activity 31 requirement for exist for Prepra Nigeria Limited 4.3 WASTE GENERATION FROM THE OPERATION OF VINYLON FACILITY The following are the wastes that are generated from the manufacturing process in Vinylon Footwear Industry Limited. Solid waste - PVC waste  Trimmings and remnants from injection and blow processes  Dust from cleaning of recycled PVCs,  Plastic and cartons from packaging  General sweepings Liquid waste  Oil and greases from power house  Spent oil from servicing of equipments‘ and vehicles  Hydraulic oil used in the pneumatic plants Gaseous waste  Emission form power house  Emission from heavy duty vehicles  Dust from recycling  Dust from additives Noise  Noise from power house  Noise from grinders in the recycling plant Sources of PVC Wastes There are two principal sources of PVC wastes: 1. Pre-consumer 32 Prepra Nigeria Limited 2. Post-consumer wastes. 1. Pre-consumer wastes Pre-consumer wastes consist of both production and installation wastes. Production waste comprises compound left over from the manufacture of PVC products, such as batch remainders from extrusion moldings and various trimmings and off-cuts from sheet and profile manufacture. This material is available in a clean condition at the point of production and consequently most is recycled internally within the manufactory process and so never enters the external waste stream. Additional pre-consumer waste comes from trimmings left over from installation wastes. Pre-consumer wastes account for about 12 per cent of waste and all are currently recycled in-house. 2. Post-consumer wastes The post consumer waste is the predominant source of waste and accounts for about 88 per cent of all solid waste in the facility. Post-consumer wastes consist of products that have been discarded at the end of their useful lives. As a result, post-consumer wastes tend to be dispersed in low abundance over a large number of users and typically require extensive cleaning to remove contaminants before they can be used for recycling. The expense of collection, sorting and processing combine to make recycling costs much higher than the mainstream options of landfilling and incineration, yet a substantial amount (89%) of post-consumer PVC waste is currently recycled. Thus only about (11%) of post-consumer wastes are not recovered. Examples of non-recovery are PVC shoes that are buried in the ground after being mixed with general domestic waste. As a result predictions of future PVC waste arising are subject to considerable uncertainty. Estimates are based on the amount that is likely to be recovered (i.e. ‗available‘ waste), which is in turn based on the history of consumption and the estimated 33 Prepra Nigeria Limited lifetime of the products. For some products with a relatively short life most of the PVC consumed enters the waste stream within one year of production, so waste production is closely coupled to consumption pattern. But for other products with much longer lives, the link between consumption pattern and waste production is much less certain. For short lived products, the ratio is over 80 per cent, but decreases to only 18 per cent for other products. The range of uncertainty in the overall quantities of PVC waste arising as a result of these factors has been estimated to be +/- 15 percent. Sources of liquid waste The main sources of liquid waste is from domestic activities, washing of waste PVC recovered for recycling and cooling system in the power house and the plants used in the facility. Sources of Gaseous waste The principal discharges in terms of mass to atmosphere from waste combustion are carbon dioxide and water vapors. All of the carbon in PVC that is incinerated is converted to carbon dioxide and discharged. The dust consists of mineral particles enriched in volatile metals and other elements and traces of soot from incomplete combustion. Dust emissions are essentially a function of the operation of the facility. All dust emissions are in the form of particles of less than 10 micrometers diameter (PM10). Lead and cadmium Metals are emitted bound to traces of dust that escape removal from the combustion gases. Nitrogen oxides (principally emitted as nitrogen monoxide, NO, which oxidizes to the more toxic nitrogen dioxide, NO2, in the atmosphere) originates from combustion of nitrogen compounds in the waste (fuel NOx) and from high temperature oxidation of nitrogen in the combustion air (thermal NOx). PVC contains only negligible amounts of nitrogen, so effectively all of the NOx from this source will be of thermal origin. 34 Prepra Nigeria Limited Source of Noise Sound from generators and machinery as well as heavy duty vehicles are the main sources. They are intermittent and therefore were not considered a major issue. 4.4 WASTE MANAGEMENT IN VINYLON FACILITY A substantial amount of solid waste from damaged PVC, trimmings and left over recyclables PVCs and solid residue from other ancillary product such as plastic and paper from packaging, are the major constituents of solid waste generated in the facility. This is presently deposited in waste collection drums located in strategic points in the facility and is eventually evacuated to the main dump site in the rear of the facility. Plates 4.1 shows the types of waste drum in the facility, while plate 4.2 shows the main dump site in the facility. Clearly, because substantial part of the raw material used in the production process is from the recycled material, very little waste is generated. PVC Recycling The main method employed by Vinylon footwear industry limited in solid waste management is recycling. The company has established extensive network of dealership for collectors of its used product that cover not only Nigeria but the whole of West Africa. Current estimate indicate that as much as 89% of the available waste of the company are recovered for recycling. The dealers supply recovered PVC shoes and supply to the facility. Plate 4.3 is the main collection area for the recovered PVC, while plate 4.4 shows the grinding plants. PVC wastes are recycled by mechanical or feedstock processes. In mechanical recycling, the PVC products are collected, sorted and processed to produce a recyclate that can substitute for virgin PVC compound of a 35 Prepra Nigeria Limited similar composition and thus be recycled into similar products, sometimes defined as ‗high quality recycling‘. Plates 4.1 A waste collection drum in the facility Plate 4.2 General waste collection point in the facility Because often the post consumption waste PVC is collected from dump site, it is often dirty and requires washing and sorting. Vinylon footwear industry limited has put in place dump site for the collection, sorting, washing and grinding of the PVC waste. 36 Prepra Nigeria Limited Plates 4.3 Dump site for the collection and storage of PVC waste Plate 4.4 PVC grinding plant Economics of mechanical recycling of PVC PVC recycling is subject to the interplay of market forces which ultimately dictate whether recycling can be done profitably on a commercial basis. The principal stages in PVC recycling as follows:  Mobilization costs are lowest where the largest quantities of recyclable materials are available in the highest concentrations, so helping to reduce transport and sorting costs.  Processing costs can be minimized where products are easy to dismantle, contain a high proportion of the material to be recovered 37 Prepra Nigeria Limited and are available with minimal contamination, so reducing the need for costly washing and cleaning procedures.  For the recycling process to be commercially profitable, the total costs must be less than the sales value from the sale of recyclables.  The price of recycled PVC is at best about 70% of virgin compound. The latter is subject to considerable volatility, being closely dependent on oil prices and foreign exchange changes in Nigeria; this volatility can act as a significant deterrent to the development of recycling capacity. For example, between 2018 and 2019, virgin PVC prices varied between 90 and 140 per cent of base year (2015) average. Prices ranged from € 560 to 680 /ton for the early part of 2015, but have since increased dramatically, finishing the year 2019 at € 740 to 850 /tonne.  Pre-consumer wastes are generally available at high concentrations in a clean condition, but even so, even pre-consumer PVC waste recycling is not always profitable.  Highest recycling rates are achieved for those product groups where production wastes make up the bulk of pre-consumer wastes, such as shoe soles and injection molded components, where recycling rates over 70 per cent may be achieved.  Less than 70 per cent recycling rates are typical where installation wastes dominate the pre-consumer waste arisings.  Recycling rates are likely to pick up if the currently high price of virgin resin is maintained. Similar considerations apply to post-consumer wastes, where the mobilization and processing costs are even higher than for pre-consumer wastes and as a result recycling rates are very low 38 Prepra Nigeria Limited Incineration of PVC In addition to the currently dominant waste management by recycling, landfill and incineration are also a method of management of PVC waste. Although, incineration rate is very low, it is still practiced as PVC is often mixed with municipal solid waste and dumped at the waste dump where scavengers often set it on fire in order to recover other materials. Predicting the extent of PVC incineration in the future is uncertain, given the difficulties in predicting the subsequent development of recycling and incineration facilities to cope with waste diverted from landfill. However, over the coming decade, it is envisaged a major reduction in incineration due to emergence of independent recyclers across Kano state that collect all residual wastes at the dump site. 4.5 IMPACT ANALYSIS A partial life cycle analysis was undertaken of the principal environmental impacts associated with the operation of Vinylon footwear industry limited. Impacts from the following processes were considered in the analysis: • Incineration of PVC that is mixed with municipal solid waste • Impacts of PVC recycling • Transportation of wastes, residues and reagents. Direct impact from incineration The direct burdens from incineration result from discharges of combustion products, residues and effluents to the atmosphere, land and water. The quantities and composition of these discharges depend on the composition of the waste. For PVC combustion, the most significant reagents are alkalis for acid gas control. Chlorine is converted into hydrogen chloride gas and volatile salts during combustion. An appreciable proportion is absorbed onto 39 Prepra Nigeria Limited alkaline ash particles and is so retained in the grate ash and fly ash. Sulphur is converted to sulphur dioxide and sulphate salts, some of which may also be retained by the ash residues. The distribution of chlorine, lead and cadmium is variable. Volatilization of chlorine from waste during incineration was found to vary from 70 to 90 per cent and for sulphur, from 30 to 60 per cent. For lead and cadmium percentages of 63% and 18% have respectively been taken for the grate ash, whilst the remaining quantities are found in the fly ash (37% for lead and 82% for cadmium). Lead and cadmium are found in APC residues or stack gases only in trace quantities. Impacts from land filling Disposal to landfill is assumed to be safe if it done in a modern sanitary landfills with effective measures to prevent the escape of leachate into surrounding strata, and having leachate collection and treatment facilities so that any discharges of treated leachate comply with all relevant legislation. This is not the case here as all landfill in the environment are unsanitary with no safety precaution. Emissions of greenhouse gases from landfills takes place mainly in the form of methane, produced by the decomposition of biodegradable organic matter under the air-less condition inside landfills. In addition to methane, carbon dioxide is also emitted from the decomposition of organic matter in landfills. In the case of mixture with municipal waste, effectively all of the carbon dioxide comes from contemporary carbon sources, such as paper, food and vegetable remains and garden wastes and is therefore neutral in greenhouse gas terms. PVC and its resin are essentially non-biodegradable. However, plasticizers made from fossil carbon may leach out of the resin matrix into the landfill leachate. Plasticizers released into the leachate can be at least partially mineralized to carbon dioxide whilst a proportion appears to bind strongly to colloidal organic matter and resist further decomposition. Long-chain phthalic acid esters, such as DEHP, appear to be more resistant to 40 Prepra Nigeria Limited decomposition than shorter chain homologues. Estimating carbon dioxide emissions from this source is therefore subject to great uncertainty. Impact from recycling Energy requirements for processing PVC during mechanical recycling are typically in the range 10 to 15 MJ/kg. There are also various other burdens associated with PVC recycling. These include the use of ancillary reagents, such as detergents and flocculants used in the washing and cleaning process. There is also the question of emissions of volatile material during the heating, melting and blending stages, although these are thought to be relatively insignificant. Many other volatile materials can also be present (for example, low molecular weight compounds from the stabilizer system, emulsifiers and viscosity depressants). Clearly, the relatively enclosed heating/blending/melting operations in recycling would give rise to much lower emissions. There is also the issue of solid waste disposal from PVC recycling, which depends largely on the quality of the input reclaimed material. The waste is comprised of dirt, paper, glue, and traces of concrete and contamination by other polymers, and moisture. Impacts from PVC manufacture High quality PVC recycling displaces the burdens of manufacturing an equivalent quantity of virgin material that the recyclate replaces. However, for low quality recycling, no virgin PVC manufacture is avoided since the recyclate produced from this operation does not take the place of new resin. Low quality recyclate may substitute for mixed plastic wastes or even wood or concrete, depending on the application to which it is put. Impacts from transportation Vehicles involved in transporting materials to the faculty are the major sources of emission. Transport relates to the conveyance of virgin PVC, 41 Prepra Nigeria Limited additives and oils from the port, collected materials for recycling, movement of finished products to warehouse in Kano as well as reagents residues are by road transport using diesel-powered heavy goods vehicles. 4.6 COMPATIBILITY The factory is located in area that is compatible with the existing approved land use of section 3.2 of the National policy on environment and Jigawa state urban planning development authority requirement. 4.7 FUEL DUMP Vinylon Footwear Industry Limited has 11,000 and 5,000 litres capacity surface storages for LPF4. The tanks are constructed according to international standards with mechanical devices to prevent leakages from the tanks and contingency plan against rupture of the tanks. Plate 4.5 shows the tank area Plate 4.5 Fuel tanksin Vinylon footwear industry limited 4.8 CLOAKROOM/CONVINIENCES There are separate cloak room and toilets especially for both the female and male employees. Both the cloakroom room and toilets are kept clean with attendants at all times. 42 Prepra Nigeria Limited 4.9 SAFETY SIGNS The facility has clear guidelines to guide workers conduct and safeguard their safety. The guideline is conspicuously put at strategic locations within the facility. Plate 4.6 shows the guidelines. Plate 4.6 Safety guidelines of the facility There are safety signs to warn staff and visitors within the factory as illustrated in plate 4.7 43 Prepra Nigeria Limited Plate 4.7 Safety sigh in the facility In addition the facility maintains a 24 hr clinic in-house with nurses working on 2 shifts. It also maintains a retainership with two private hospitals, one in Kano BAMAIYI SIA ALLAH Hospital and the other in Ringim namely RAHAMA Hospital. All staff are kitted with appropriate protective working gear at all times. The facility also maintains an accident register with records of all work related incidents and the response. 4.10 MUSTER POINT AND FIRE FIGHTING EQUIPEMENTS There are muster points located in strategic part of the facility shown in plate 4.7. In addition the facility has 2 fire fighting trucks strategically positioned in the premises as shown in plate 4.8 Plate 4.8 Muster point and fire extinguisher 44 Prepra Nigeria Limited Plate 4.9 Fire fighting truck in the facility 4.11 COMPLIACE WITH EXTANT REGULATIONS Environmental Regulations  Section 7 (k) of the NESREA Act empowers NESREA to conduct environmental audit and establish data bank on regulatory and enforcement mechanisms of environmental standards other than in the oil and gas sector  Section 8 (k) of the NESREA establishment Act also empowers the Agency to make Regulations. One of such made is the ―National Environmental (Permitting and Licensing System) Regulations, 2009; S. I No. 29‖  All the extant national sectorial environmental regulations require existing industries to undertake environmental audit and submit reports every three (3) years.  Section 1 (1) of Regulation S.I.8 of 1991  Section 3 (1) of Regulation S.I.8  Section 17 of Regulation S.I.9l  National Environmental (Domestic and Industrial Plastic, Rubber and Forms Sector) Regulations, 2011. 45 Prepra Nigeria Limited Vinylon Footwear Industry Limited is in compliance with the existing regulations as enumerated above by establishing a functioning effluent treatment plant and engaging a NESREA accredited consultant to prepare an Environmental Management plan (EMP) which has been submitted to NESREA and now an Environmental Audit. 4.12 Compliance to other regulations Vinylon Footwear Industry Limited is in partial compliance to most of the regulations, but needs to be aware of the laws currently in place that require adherence to. 46 Prepra Nigeria Limited 5.0 CHAPTER FIVE: ENVIRONMENTAL MANAGEMENT PLAN 5.1 BASIS OF ENVIRONMENTAL MANAGEMENT PLAN (EMP) Both international and Nigeria‘s environmental guidelines and standards require environmental monitoring for facilities such as Vinylon Footwear Industry Limited. The basis of environmental monitoring is to provide information that will aid impact management to achieve a better understanding of cause-effect relationships and to improve mitigation measures. 5 .2 SCOPE AND CONTEXT OF VINYLON ENVIRONMENTAL MANAGEMENT PLAN The management of Vinylon Footwear Limited is fully committed to the protection of the environment from the potential adverse impact associated with the utilization of the plant through the implementation of the following actions: a) Developing an Environmental Policy b) Environmental Monitoring schedule c) Risk assessment and emergency response plan d) EMP review 5.3 ENVIRONMENTAL POLICY OF VINYLON ENVIRONMENTAL MANAGEMENT PLAN The environmental policy of Vinylon footwear limited is predicated on the following objectives: i) Maximizing resource utilization and reduce waste ii) Complying with all applicable environmental protection regulations iii) Minimizing damage to the environments from its project 47 Prepra Nigeria Limited 5.4 IMPLEMENTATION OF VINYLON ENVIRONMENTAL MANAGEMENT PLAN In order to fully implement the environmental management plan, Vinylon footwear limited has developed a robust communication plan that ensures information is timely and appropriately delivered to all concerned. The communication implementation plan will be ensured based on the schedule in Figure 5.1 Figure 5.1: Communication channels and Responsibilities in Vinylon Footwear Industry Limited To ensure smooth implementation of the EMP environmental, the following plans are put in place; i) Staff training Plan and establishment of environmental management committees to ensure in-house enforcement and compliance. 48 Prepra Nigeria Limited ii) Environmental Reporting III) Health and Safety plan iv) Emergency Response Plan v) Checking vi) Review vii) Environmental monitoring plan 5.5 ENVIRONMENTAL TRAINING PLAN OF VINYLON FOOTWEAR LIMITED The environmental training plan will include General staff awareness induction Familiarization with the EMP Requirement Environmental emergency response training Familiarization with the operation of environmental controls The details of the environmental training are shown in Table 5.1. 49 Prepra Nigeria Limited Table 5.1: Training programme-summary of training needs Training topic Summary of training Recipients (staff Targeted date purpose and content and/or contractor Induction of EMP  Overview of All EMP including contractor operation information, pollution risk and controls and programme & system Refresher to EMP  Refresher overview EMP Cleaner method production Emergency response training All staff staff/ At the beginning of employment contract After one year of  Detail of Environmental After the activity or area officer and commissions specific risks& technical Staff of the plant control;  Overview air, noise waste water treatment process precautionary measures & maintenance program  Identification of Field officers & c ASAP on-site assistance environmentally hazards that require rapid response 50 Prepra Nigeria Limited 5.6 ENVIRONMENTAL REPORTING In order to comply with statutory regulations, statutory reports will be compiled and submitted as at when due to the relevant agencies. Table 5.2 shows the needed documentation required as well as the areas to submit. Table 5.2 Reporting plan- process summary Documents EIA EMP Material sheet Submitted to By who  Federal NESREA Ministry of Accredited Environment consultant  Kano State Ministry of Environment  NESREA, NWZ, Office  Kano State Environmental Ministry of officer Environment Data   Date JULY, 2023 JULY, 2023 ASAP NESREA, NWZ, Office Environmental Kano State officer Ministry of Environment 51 Prepra Nigeria Limited 5.7 HEALTH, ENVIRONMENT AND SAFETY PLAN (HSE) Vinylon Footwear Industry Limited has put in place a section to handle Health, safety and Environment(HSE) matter(s), by establishing policies, providing perspectives and resources to achieve ―Flawless operations‖ in all aspects of the company‘s business. The HSE department will organize monthly safety meeting/HSE seminar and or workshop which centers on crisis Emergency plan. This will raise the level of safety awareness as well as the safe usage of safety gadgets. The schedule for monthly safety meeting covers the following issues: - Disciplinary procedures - Permit to work system - Lockout/ Tag out procedures - Incident/Accident investigation and reporting procedure - Contractor safety policy - Personnel protective equipment - Emergency preparedness - Housekeeping - Breathing Apparatus - Handling of firefighting equipment - Hazard communication 5.8 EMERGENCY RESPONSE PLAN A key requirement in the utilization and operation of Vinylon Footwear Industry Limited is to have an emergency response plan. The procedure in emergency response for Vinylon Footwear Industry Limited is set out in table 5.3 52 Prepra Nigeria Limited 5.9 CHECKING AND CORRECTIVE ACTION In order to ensure that this environmental management plan is adhered by all in Vinylon Footwear Industry Limited, there is a verification of the implementation by a committee on environment. The committee meets regularly and report to the production manager on quarterly basis for evaluation and continuous improvement in meeting the objectives. 5.10 MANAGEMENT REVIEW Routine management review is conducted using a checklist to ensure full implementation of the plan. 5.11 MONITORING PLAN Monitoring is used to:  Establish baseline trends and conditions  Measure the impacts that occur during project construction and operation  Check their compliance with agreed conditions and standards  Facilitate impact management, e.g. by warning of unanticipated impacts  Determine the accuracy of impact predictions and the effectiveness of mitigation measures. A sound baseline is a critical reference point for the conduct of monitoring, as, monitoring establishes the basis for corrective action when actual impacts are unanticipated or worse than predicted. Compliance monitoring, carried out through repetitive or periodic measurement, may suffice as a safety net for the project. However, compliance monitoring will trigger impact management only if regulatory standards or specified conditions are exceeded. 53 Prepra Nigeria Limited Table 5.3: Emergency response Risk identification Implementation control Authorization Contact required  Air quality related risk  Time frame Monitoring to Environment ensure it is within officer the acceptable Plant ASAP Manager limits.  Excess above limit should be reported  Water related  Monitoring to Environment ensure it is within officer the acceptable Plant ASAP Manager limits  Excess should be reported  Terrorist Attack  Be alert and keep Environment Plant aware Manager of surrounding your your officer Heed instincts. you feel something If that isn't right, leave.  If someone acting is strangely, or if you see a suspicious package, 54 ASAP Prepra Nigeria Limited especially if it is unattended, inform a police officer or security personnel. Explosion   Take cover away Environment Plant from area as soon officer as possible. Manager If you are trapped in debris, cover your mouth with a handkerchief or clothing to avoid dust inhalation.  Signal to workers rescue to let them know where you are.  Use a flashlight, whistle, or knock on a pipe or wall.  Refrain from shouting if possible, as this may result in dust inhalation.  If your 55 ASAP Prepra Nigeria Limited surrounding are on fire, keep low to the ground,  Cover your mouth and nose with a (preferably) wet cloth, and get out of the area by the safest route possible as quickly as you can. Other unexpected emergency  Discretion best and Environment possible officer Plant ASAP Manager practice. 5.12 COVID 19 MANAGEMENT PLAN To reduce the impact of COVID-19 outbreak conditions on workers, customers, and the public, it is important for Vinylon footwear industry limited to plan for COVID-19. The plan for COVID-19 involves addressing the specific exposure risks, sources of exposure, routes of transmission, and other unique characteristics. A major impact of COVID 19 in workplace may include: ■ Absenteeism - Workers could be absent because they are sick; are caregivers for sick family members; are caregivers for children if schools or day care centers are closed; have at-risk people at home, such as family members; or are afraid to come to work because of fear of possible exposure. 56 Prepra Nigeria Limited ■ Change in patterns of commerce. Consumer demand for items related to infection prevention (e.g., respirators) is likely to increase significantly, while consumer interest in other goods may decline. Consumers may also change shopping patterns because of a COVID-19 outbreak. Consumers may try to shop at off-peak hours to reduce contact with other people, show increased interest in home delivery services, or prefer other options, such as drive through service, to reduce person-to-person contact. ■ Interrupted supply/delivery. Shipments of items from geographic areas severely affected by COVID-19 may be delayed or cancelled with or without notification. The COVID 19 Plan entails: Developing an Infectious Disease Preparedness and Response Plan An infectious disease preparedness and response plan can help guide protective actions against COVID-19. Implement guidance from federal, state, local, governments and consider how to incorporate those recommendations and resources into workplacespecific plans. Plans should consider and address the level(s) of risk associated with various worksites and job tasks workers perform at those sites. Such considerations may include: ■ Where, how, and to what sources of COVID-19 might workers be exposed, including: { The general public, customers, and coworkers; and { Sick individuals or those at particularly high risk of infection (e.g., international travelers who have visited locations with widespread sustained (ongoing) COVID-19 transmission, healthcare workers who have had unprotected exposures to people known to have, or suspected of having, COVID-19). ■ Non-occupational risk factors at home and in community settings. 57 Prepra Nigeria Limited Controls necessary to address those risks ■ The need for social distancing, staggered work shifts, downsizing operations, delivering services remotely, and other exposure-reducing measures. ■ Options for conducting essential operations with a reduced workforce, including cross-training workers across different jobs in order to continue operations or deliver surge services. ■ Interrupted supply chains or delayed deliveries. Plans should also consider and address the other steps that can reduce the risk of worker exposure to COVID- 19 in their workplace. Prepare to Implement Basic Infection Prevention Measures Protecting workers will depend on emphasizing basic infection prevention measures. As appropriate, Vinylon footwear industry limited should implement good hygiene and infection control practices, including: ■ Promote frequent and thorough hand washing, including by providing workers, customers, and worksite visitors with a place to wash their hands. If soap and running water are not immediately available, provide alcoholbased hand rubs containing at least 60% alcohol. ■ Encourage workers to stay home if they are sick ■ Encourage respiratory etiquette, including covering coughs and sneezes. ■ Discourage workers from using other workers‘ phones, desks, offices, or other work tools and equipment, when possible 58 Prepra Nigeria Limited ■ Maintain regular housekeeping practices, including routine cleaning and disinfecting of surfaces, equipment, and other elements of the work environment ■ Prompt identification and isolation of potentially infectious individuals is a critical step in protecting workers, customers, visitors, and others at a worksite. ■ Inform and encourage employees to self-monitor for signs and symptoms of COVID-19 if they suspect possible exposure ■ Develop policies and procedures for employees to report when they are sick or experiencing symptoms of COVID-19 Where appropriate, Vinylon facility shall develop policies and procedures for immediately isolating people who have signs and/or symptoms of COVID-19, and train workers to implement them. Move potentially infectious people to a location away from workers, customers, and other visitors. Although most worksites do not have specific isolation rooms, designated areas with closable doors may serve as isolation rooms until potentially sick people can be removed from the worksite. ■ Take steps to limit spread of the respiratory secretions of a person who may have COVID-19. Provide a face mask, if feasible and available, and ask the person to wear it, if tolerated. Note: A face mask (also called a surgical mask, procedure mask, or other similar terms) on a patient or other sick person should not be confused with PPE for a worker; the mask acts to contain potentially infectious respiratory secretions at the source (i.e., the person‘s nose and mouth). ■ If possible, isolate people suspected of having COVID-19 separately from those with confirmed cases of the virus to prevent further transmission— particularly in worksites where medical screening, triage, or healthcare 59 Prepra Nigeria Limited activities occur, using either permanent (e.g., wall/different room) or temporary barrier (e.g., plastic sheeting). ■ Restrict the number of personnel entering isolation areas. ■ Protect workers in close contact with (i.e., within 6 feet of) a sick person or who have prolonged/repeated contact with such persons by using additional engineering and administrative controls, safe work practices, and PPE. Workers whose activities involve close or prolonged/ repeated contact with sick people are addressed further in later sections covering workplaces classified at medium and very high or high exposure risk. Develop, Implement, and Communicate about Workplace Flexibilities and Protections ■ Actively encourage sick employees to stay home. ■ Ensure that sick leave policies are flexible and consistent with public health guidance and that employees are aware of these policies. ■ Talk with companies that provide your business with contract or temporary employees about the importance of sick employees staying home and encourage them to develop non-punitive leave policies. ■ Do not require a healthcare provider‘s note for employees who are sick with acute respiratory illness to validate their illness or to return to work, as healthcare provider offices and medical facilities may be extremely busy and not able to provide such documentation in a timely way. ■ Maintain flexible policies that permit employees to stay home to care for a sick family member. Employers should be aware that more employees may need to stay at home to care for sick children or other sick family members than is usual. 60 Prepra Nigeria Limited ■ Recognize that workers with ill family members may need to stay home to care for them. ■ Be aware of workers‘ concerns about pay, leave, safety, health, and other issues that may arise during the lockdown. Provide adequate, usable, and appropriate training, education, and informational material about essential job functions and worker health and safety, including proper hygiene practices and the use of any workplace controls (including PPE). Informed workers who feel safe at work are less likely to be unnecessarily absent. 61 Prepra Nigeria Limited 6.0 CHAPTER SIX: RECOMMENDATIONS 6.1 GENERAL RECOMMENDATIONS  Vinylon Footwear Industry Limited needs to consider both the short and long term environmental issues arising from its operations with a strong view to sustainable development  The importance of the Materials safety data sheet for the different raw materials especially chemicals should be made clear to the store keeper And other production staff  Vinylon Footwear Industry Limited must integrate environmental issues in its operation by introducing environmental accounting procedures to all its staff 6.2 SPECIFIC RECOMMENDATIONS 6.2.1 Air Quality Mitigation measures for air quality include Boiler emissions regulations  Regulations governing stack emissions given by NESREA should be adhered to  Regulations by NESREA and FMEnv with respect to CO, NOx, SOx, volatile organic compounds and heavy metals emissions should be adhered to The following techniques to minimize boiler stack emissions from boilers fitted with dry dust collectors shall be in place:  Maintaining the boiler plant to ensure the dry dust collector systems operate as per design specifications  Ensuring the dust collector system matches current boiler operational load rather than design MCR 62 Prepra Nigeria Limited  Tuning the boiler plant to minimize the dust collector inlet particulate levels  Dust should be sucked away from any area where it is generated and filtered in bag filters 6.2.2 Noise In order to reduce potential noise impacts on neighboring communities, workers and wildlife, the following mitigation measures are recommended:   Restrict noise generating activities to working hours during the day Install suitable mufflers on engine maintenance of all exhausts and compressor components  Ensure the equipment in accordance to manufacturer‘s specifications  Ensure vehicle travelling within and around project area are operated in accordance with speed limits to reduce vehicle noise levels   develop a mechanism to record and respond to noise complaints Provide and enforce the usage of hearing protection devices (ear plugs/muffs) for workers exposed to noise levels >90 dB(A) for a duration of more than 8 hours per day  Institute a Hearing Protection Program for workers in work areas with noise in excess of 85 dB(A). 6.2.3 Occupational Health and Safety In order to mitigate the impacts of the operation of Vinylon footwear industry limited on workers health the following measures are proposed:  Put in place an active health and safety policy  Ensure External audits of safety performance by recognized authorities  Ensure internal audits are conducted by a multidisciplinary team  Regular training and retraining of employees  Put in a procedure for reporting all occupational, health and safety incidents, and a system of record keeping should be operational 63 Prepra Nigeria Limited  Proper use of PPE is essential  Risk management should consider all potential hazards and where possible take action to mitigate them  Good housekeeping for higher safety standards  Commitment and participation of management in matters of health and safety  Health and safety company procedures are constantly disclosed and properly deployed to all employees Specifically, the following are measures to mitigate occupational health to prevent accidents and ensure healthy working environment in the proposed sugar mill  A lock-out system is necessary on electrical equipment, to enable safe maintenance on conveyors and plant equipment  lock-out system is necessary on steam and vapors valves, to enable safe cleaning and maintenance on internal parts of evaporators and vacuum pans  Put controls in place to ensure that no fire/explosion incidents occur  Working at heights above 2 m and working in confined spaces should require special permits , 6.2.4 Training o Training and retraining of all employees on health and safety issues shall be on a regular basis. o Provisions should be made to provide OHS orientation training to all new employees to ensure they are apprised of the basic rules of work on the site and of personal protection o Regular updating training should be provided for all employees on a routine basis. The training should cover: ฀฀Knowledge of materials, equipment, and tools ฀฀Known hazards in the operations and how they are controlled 64 Prepra Nigeria Limited ฀฀Potential risks to health ฀฀Precautions to prevent exposure ฀฀Hygiene and health requirements ฀฀Wearing and use of protective equipment and clothing ฀฀Correct use and care of personal protective equipment ฀฀How to identify and use safety signs ฀฀Appropriate response to operation extremes, incidents and accidents ฀฀Knowledge of safe routes to escape in case of an accident 6.2.5 Safety equipment Personal Protective Equipment (PPE) as recommended by NESREA ( table 6.1) provides additional protection to workers exposed to workplace hazards in conjunction with other facility controls and safety systems. PPE is considered to be a last resort that is above and beyond the other facility controls, and provides the worker with an extra level of personal protection. Recommended measures for use of PPE in the workplace include: ฀฀Active use of PPE ฀฀Identification and provision of appropriate PPE that offers adequate protection to the workers and occasional visitors, without cleaning when incurring unnecessary inconvenience to the individual ฀฀Proper maintenance of PPE, including dirty and replacement when damaged or worn out ฀฀Proper use and care of PPE should be part of the recurrent training programs for employees Encourage workers to report to management all: ฀฀Occupational injuries and near misses ฀฀Suspected cases of occupational disease ฀฀Dangerous occurrences and incidents ฀฀Potential risk areas 65 Prepra Nigeria Limited Occupational health and safety monitoring programs should verify the effectiveness of prevention and control strategies. The OHS monitoring program should include: ฀฀Safety inspection, testing and calibration: This should include regular inspection and testing of all safety features and hazard control measures focusing on engineering and personal protective features, work procedures, places of work, installations, equipment and tools used. The inspection should verify that issued PPE continues to provide adequate protection and is being worn as required ฀฀Legal requirements: Safety testing associated with boilers, rigging equipment, etc. are often prescribed by law. These must be undertaken at the required frequency ฀฀Training: Training activities for employees and visitors should be adequately participants). monitored and Emergency documented exercises, (curriculum, including fire duration, drills, should and be documented adequately. Service providers and contractors should be contractually required to submit to the employer adequate training documentation before the start of their assignment ฀฀Security audit: Checking services standards and safety procedures, reporting non-conformities and always looking for improvements 66 Prepra Nigeria Limited Table 6.1: NESREA Recommended Personnel Protective Equipment according to hazard type Objective Workplace Hazard Suggested PPE Eye and face protection Flying particles, molten Safety glasses with side metal, liquid chemicals, shields, gases or vapours, light shades, etc. protective radiation Head protection Falling objects, inadequate height clearance and overhead Plastic helmets with top and side impact protection power cords Hearing protection Noise, ultra-sound Hearing protectors(ear plugs or ear muffs) Foot protection Falling or rolling objects, Safety shoes and boots pointed for objects. Corrosive or hot liquids protective against moving and falling objects, liquids and chemicals Hand protection Hazardous materials, cut Gloves made of rubber or or laceration, vibrations, synthetic extreme temperature materials(Neoprene), leather, steel, insulating material, etc Respiratory protection Dust, fogs, fumes, mist, Facemasks gases, smoke, vapour appropriate dust with filters removal purification masts, and for air (chemicals, vapors and gases). Single or multigas personal monitors, if Available 67 Prepra Nigeria Limited Oxygen deficiency Portable or supplied air (fixed lines). On site rescue equipment Body/leg protection Extreme temperatures, hazardous materials, biological agents, cutting Insulating clothing, body suits, aprons etc of appropriate materials and laceration 6.2.6 COVID - 19 Control Engineering Controls Engineering controls involve isolating employees from work related hazards. In workplaces where they are appropriate, these types of controls reduce exposure to hazards without relying on worker behavior and can be the most cost-effective solution to implement. Engineering controls for COVID- 19 include: ■ Installing high-efficiency air filters. ■ Increasing ventilation rates in the work environment. ■ Installing physical barriers, such as clear plastic sneeze guards. ■ Encouraging sick workers to stay at home ■ Establishing alternating days or extra shifts that reduce the total number of employees in a facility at a given time, allowing them to maintain distance from one another while maintaining a full onsite work week. ■ Discontinuing nonessential travel to locations with on-going COVID-19 outbreaks ■ Developing emergency communications plans, including a forum for answering workers‘ concerns and internet-based communications, if feasible. 68 Prepra Nigeria Limited ■ Providing workers with up-to-date education and training on COVID-19 risk factors and protective behaviors (e.g., cough etiquette and care of PPE). ■ Training workers who need to use protecting clothing and equipment how to put it on, use/wear it, and take it off correctly, including in the context of their current and potential duties. Training material should be easy to understand and available in the appropriate language and literacy level for all workers. Safe Work Practices Safe work practices are types of administrative controls that include procedures for safe and proper work used to reduce the duration, frequency, or intensity of exposure to a hazard. Examples of safe work practices for COVID-19 include: ■ Providing resources and a work environment that promotes personal hygiene For example, provide tissues, no-touch trash cans, hand soap, alcohol-based hand rubs containing at least 60 percent alcohol, disinfectants, and disposable towels for workers to clean their work surfaces. ■ Requiring regular hand washing or using of alcohol-based hand rubs. Workers should always wash hands when they are visibly soiled and after removing any PPE. ■ Post hand washing signs in restrooms 69 Prepra Nigeria Limited 7.0 CHATER SEVEN; FOLLOW UP ACTION PLAN 7.1 Completion and submission of EA 7.1.1 Submission of EA report JULY 2023 to i) NESREA NWZ, Kano ii) NESREA Headquarters, Abuja iii) Kano State Ministry of Environment 7.1.2 Monthly effluent/ emission monitoring and sending results to NESREA and Kano state Ministry of Environment 7.1.3 Implementation follow on the management of the company‘s EMP 7.1.4 Awareness training for staff 7.1.5 Quarterly inspection 7.1.6 Establishment of quality assurance unit to ensure timely repairs to leaking oil/water pipes 70 Prepra Nigeria Limited 8.0 CHAPTER EIGHT: CONCLUSION This is the 2nd compliance audit report conducted in the facility. The exercise as usual examines the operations of Vinylon Footwear Industry Limited – a plastic footwear producer as well as the compliance status of the plant with respect to environmental regulations and the contingency plans. Relevant general and specific regulations in these regards were proffered on the basis of the data collected during the exercise. The audit report has dwelt in depth on the issues related to potential pollution emanating from the operation as well as the HSE relating to workers . The current practice clearly shows compliance to all extant regulations with respect to environmental protection and the safety and health of the workers and the neighboring communities. 71 Prepra Nigeria Limited APPENDIX 1 Environmental Audit Questionnaire 1.0 IDENTIFICATION OF FACILITY 1.1 Registered Name of facility ………………………………………………………………………………………………. 1.2 Registered Address of facility ………………………………………………… 1.3 CAC Registration No of facility ………………………………………………………… 1.4 Date and Year of registration of facility ………………………………………………………… 1.5 Email address and mobile tel. No of facility ………………………………………………… 1.6 Name, tel no and email of Contact person ……………………………………………… Type of Industry : - Food, Beverages, Tobacco, Distilleries and Breweries - Textile, Paint, Tanneries, Pulp and Paper - Rice mill, Allied agricultural processing - Asbestos, Asphalt, Cement, Iron and Steel - Petrochemicals, Plastics, Cosmetics, Chemicals/pharmaceuticals and Allied Products. 72 Prepra Nigeria Limited - Others (please state clearly). ……………………………………………………………………………………………… 1.5 Year of commencement of operation …………………………………………………………………………………………… 1.6 Number of Employees Total:…………………………………………………………………………………… Plant employees:………………………………………………………………………… Skilled/management……………………………………………………………………… (indicate if you operate shift system): Yes/No If yes, specify shift periods: ……………………………………………………………………………………………… 1.7 Number of Working Days Per Week: ………………………………………………………………………………………………… GENERAL SANITATION OF SURROUNDINGS: 2.1 How would you rate the general cleanliness of your surroundings? - Above average - Average - Below average 2.2 How often do you clean your surroundings - Once a week - Fortnightly - Monthly - Other 2.3 Are there any beautification plans in place i.e planting of trees and/or shrubs? Yes/No 2.4 If yes, how frequent is the landscape managed. 73 Prepra Nigeria Limited - Once a week - Fortnightly - Monthly - Yearly - Other 2.5 How would you rate the conditions of your drains and pipes? - Good - Fair - Poor 2.6 How do you keep the floors of your facility free from spent oil/grease and lubricants? ……………………………………………………………………………………………………… 3 MACHINERY AND RAW MATERIALS: 3.1 Please list all items of plant and machinery with dates of purchase/manufacture ………………………………………………………………………………………………… ………………………………………………………………………………………………… ………………………………………………………………………………………………… 3.2 Do you have a boiler? if yes indicate size and type of fuel used ………………………………………………………………………………………………… 3.3 Please list raw materials used and indicate quantities used per day. (a) (b) (c) List all raw materials including Average industrial chemicals per day …………………………………… ………………………………… …………………………… …………………………………… ………………………………… …………………………… quantities used Storage conditions (Grms./ Kgs). 74 Prepra Nigeria Limited 4. PRODUCTS: 3.2 Please list your products and indicate quantities produced per day. ………………………………………………………………………………………………… ………………………………………………………………………………………………… INSTALLATION OF POLLUTION ABATEMENT EQUIPMENTS AND DATE OF INSTALLATION 3.3 List all types of pollution abating equipment you have installed in your facility. ………………………………………………………………………………………………… ………………………………………………………………………………………………… Do you have Primary effluent treatment plant? ………………………………………………………………………………………………… 3.4 What is the capacity of the ETP in liters? ……………………………………………………………………………………………… 4 USE OF WATER 4.1 Please indicate source of water used in plant - Well - Municipal supply - Surface water - Borehole - Other (specify) ………………………………………………………………………………………………… 75 Prepra Nigeria Limited 4.2 How is the inlet water used and please specify volume used. - Process ………………………………………………………………………… liters/day - Cooling ……………………………………………………………………......... liters/day - Boiler …………………………………………………………………………… liters/day - Sanitation/ washing etc …………………………………………………………. liters/day - Other (specify) ………………………………………………………………….. liters/day - Total daily consumption ……………………………………………………….. .liters/day 4.3 Please give a brief summary description of the processes involved in the use of water …………………………………………………………………………………………………………………………… …………………………………………………………………………………………………………………………… Waste water What are the means by which waste water is collected in your facility? (Please indicate volume). - Combined for all effluents……………………………………………. liters/day - Separate for process water, domestic water, Rain run-off ……………………………………………………………liters/day - Other (specify) ………………………………………………………….liters/day 6.5.1 How many waste water outfalls are in your facility? ……………………………………………………………………………………………… 76 Prepra Nigeria Limited 6.5.2 Indicate volume discharge for each outfall……………………………. litres/day 6.6 TREATMENT Do you treat your waste water Yes/No? If yes (specify)……………………………………………………………………………………………………………… …………………………………………………………………………………………………………………………… 6.7 if yes (specify briefly summaries steps undertaken by your establishment in treatment of waste-water before discharge) …………………………………………………………………………………………………………………………… …………………………………………………………………………………………………………………………… If No, give reasons. …………………………………………………………………………………………………………………………… …………………………………………………………………………………………………………………………… 6.8 Where do you discharge the treated/untreated water? - Into general sewers (………………………….... liter/day) - Into receiving waters (……………………………. liter/day) - Recycle -Reuse 6.9 What are your general observations on the quality of the receiving water (attach analysis log sheet of the receiving water) ……………………………………………………………………………………………………… 77 Prepra Nigeria Limited 6.10 MONITORING Are samples of the waste stream analyzed? - Yes - No 6.11 if yes please indicate frequency of sampling and analysis. - Weekly -Fortnightly - Monthly - Others (specify) ………………………………………………………………………………………………….. 6.12 Please indicate which effluent monitoring methodology is used? - NESREA - KANO STATE MINISTRY OF ENVIRONMENT - WHO/GEMS (World Health Organization/ Global Environmental Monitoring system) - Others (Specify) 6.13 – Please attach your effluent analysis log sheet 7.0 SOLID WASTE 7.1 At what point along your production process do you generate solid wastes? ………………………………………………………………………………………………….. 78 Prepra Nigeria Limited 7.2 Do you have any waste segregation/sorting mechanisms or plans in place? - Yes ……………………. No………………………….. 7.3 If Yes, how? / If No why? ………………………………………………………………………………………………….. ………………………………………………………………………………………………….. ………………………………………………………………………………………………….. 7.4 What is the total annual industrial solid waste generated by your firm……………….. kg/day (give estimate)…………………………………………. 7.5 How do you manage your solid waste? Compression/compaction:………………………………………………………………… kg Recover from sorting:……………………………………………………………………. Kg Incineration:………………………………………………………………………………. Kg Store/bury in premises:…………………………………………………………………….. kg Others (specify)……………………………………………………………………………. Kg 7.6 How do you dispose of your solid wastes? …………………………………………………………………………………………………………………………… 7.7 Where is the final waste disposal site? ……………………………………………………………………………………………………… 7.8 How do you treat and dispose of any corrosive, flammable or radioactive waste materials?............................................................................................ 79 Prepra Nigeria Limited 7.9 How do you dispose of your expire raw materials and or products? ........................................................................................................... ........................................................................................................... .................................................................................. 8.0 GASEOUS WASTE: 8.1 List major air contaminants emitted by your facility. ........................................................................................................... ........................................................................................................... ...................................................................................... 8.2 Indicate the type of gaseous emissions abatement equipment in place. (Filter, scrubber, electrostatic precipitator, others). .………………..………………………………………………………………………………………………………… 8.3 What is the maintenance schedule if any? …………………………………………………………………………………………….. 11. ENVIRONMENTAL AUDIT 11.1 Do you have any in-house environmental pollution monitoring unit? Yes ………………………………………. No………………………………… 11.2 Do you employ the services of a consultant to advice you on environmental issues from time to time? Yes ………………………………… No …………………………………. 11.3 Does your consultant have NESREA Accreditation? …………………………………………………………………………………………………………………………… ……………………………………………………………………… 11.4 When last did you carry out environmental audit on your facility? …………………………………………………………………………………………………………………………… ……………………………………………………………………… 11.5 Have you sent your audit report to NESREA office for review? Yes ………………………………… No …………………………………. 80 Prepra Nigeria Limited 11.6 Which of the recommendations in the audit report have you implemented? Specify please…………………………………………………………………………… ………………………………………………………………………………………………… 12.0 HEALTH AND SAFETY 12.1 Number of accidents recorded yearly within the last three years. Year …………………………….. No. of accidents ………………………………. Year …………………………….. No. of accidents ………………………………. Year …………………………….. No. of accidents ………………………………. 12.2 Number of fatalities Year …………………………….. No. of fatalities ………………………………. Year …………………………….. No. of fatalities ………………………………. Year …………………………….. No. of fatalities ………………………………. 12.3 Number and type of illness reported by workers in the last three years Type of illness ………………………. No. of staff………………………. Year ……… ………………………. No. of staff………………………. Year ……… ………………………. No. of staff………………………. Year ……… 12.4 State the type of safety warning signs in place. …………………………………………………………………………………………………………………………… 12.5 List the safety gears you provide for your staff …………………………………………………………………………………………………………………………… ………………………………………………………………………………………………… 12.6 How do you enforce usage of these safety gears? …………………………………………………………………………………………………………………………… ……………………………………………………………………… 81 Prepra Nigeria Limited 13.0 GENERAL 13.1 What impact do the activities of your facility have on the immediate environment? …………………………………………………………………………………………………………………………… ……………………………………………………………………… 13.2 Has there been any complaints from the public on the activity of your facility? …………………………………………………………………………………………………………………………… ……………………………………………………………………… ………………………………………………………………………………………………… 13.3 Any prosecution or warning notice and when? …………………………………………………………………………………………………. 82