Industrial Safety

in the
Plastic Sector
A Review of Policies, Laws, and Institutions

Khondaker Golam Moazzem

Jebunnesa
INDUSTRIAL SAFETY IN THE PLASTIC SECTOR
A Review of Policies, Laws, and Institutions

Khondaker Golam Moazzem

Jebunnesa

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Publisher

Centre for Policy Dialogue (CPD)

House 40/C, Road 11 (new)
Dhanmondi, Dhaka-1209, Bangladesh
Telephone: (+88 02) 48118090, 55001185, 58156979
Fax: (+88 02) 48110414
E-mail: [email protected]
Website: www.cpd.org.bd

First Published June 2023

© Centre for Policy Dialogue (CPD)

Disclaimer: The Yiews expressed in this paper are those of the authors alone and do not necessarily reߕect
the Yiews of the CPD or the FE6 Bangladesh 2fߔce.

Cover Design
Avra Bhattacharjee

Page lay-out and typesetting

Md Shaiful Hassan

Citation: Moazzem, K. G., & Jebunnesa (2023). Industrial Safety in the Plastic Sector : A Review of
Policies, Laws, and Institutions. Dhaka: Centre for Policy Dialogue (CPD) and Friedrich-Ebert-Stiftung (FES)
Bangladesh.

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Abstract

The frequent incidents of industrial accidents in the plastic sector indicate that the
Occupational Safety And Health (OSH) standards of plastic factories are below the
minimum level of compliance. A total of 1,034 workers were killed in workplace accidents
in 2022, according to a survey by the Bangladesh Institute of Labour Studies (BILS).
However, undertaking OSH-related remedial measures in the plastic sector is difߔcult.
Unlike the RMG sector, which operates in the global value chain, most plastic sector
enterprises operate within the domestic value chain.

In this backdrop, the study reviews the existing law, rules and regulations related to OSH
in the plastic sector, apprehend the speciߔc responsibilities assigned to the regulatory
bodies and traces out the policy gaps. Based on the analysis, the study puts forward a
set of recommendations for ensuring the monitoring, transparency, accountability, and
efߔciency of public actions.

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Acknowledgements

This study has been conducted by the Centre for Policy Dialogue (CPD) in partnership
with the Friedrich-Ebert-Stiftung (FES), Bangladesh. The study is authored by Dr
Khondaker Golam Moazzem, Research Director, CPD, and Ms Jebunnesa, Programme
Associate, CPD.

The research team would like to thankfully acknowledge Dr Shah Md. Ahsan Habib,
Professor (Selection Grade), Bangladesh Institute of Bank Management (BIBM), and
Shamim Ahmed, President, Bangladesh Plastic Goods Manufacturers and Exporters
Association (BPGMEA), for their continuous support to the team.

The research team also would like to register its sincere thanks to a number of ofߔcials
of public and private organisations for participating in the interviews and sharing
valuable insights on the state of industrial safety in non-RMG enterprises. These include
representatives of the Department of Inspection in Factories and Establishments (DIFE),
Fire Service and Civil Defence (FSCD) and International Labour Organization (ILO).

The research team gratefully acknowledges the valuable support received from Avra
Bhattacharjee, Joint Director, Dialogue and Outreach, CPD and Md Shaiful Hasan,
Programme Associate, CPD, as well as the copy editor of the report, ARM Saidul Huq.

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Contents

Abstract iii
Acknowledgements iv
Acronyms vi

1. Introduction 1

2. Current Proߔle of the Plastic Sector in Bangladesh 2

3. Industrial Safety Concerns in Plastic Sector 9

4. National Policies, Rules, and Regulations Related to the Plastic Sector: 10

Implications on Industrial Safety

5. Monitoring and Regulatory Authorities Accountable for Industrial Safety 15

6. Current Occupational Health and Safety Scenario of the Plastic Industry 17

in Bangladesh

7. Recommendations 18

Bibliography 20

List of Tables and Figures

Table 1: Structure and Composition of the Plastic Industry 4

Table 2: Raw Materials Used in the Plastic Sector 7
Table 3: Accidents from FY2015–16 to FY2020–21 9
Table 4: Fire Incidents Reported in different Places and Sectors (Year wise) 9
Table 5: Labour Inspection Status of Import-Oriented Non-RMG Sectors (As of 15
November 2021)

Figure 1: Value Chain of the Plastic Sector in Bangladesh 3

Figure 2: Plastic Factories Distribution – By Location 5
Figure 3: Direct and Deemed Export of Plastic Products 6

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Acronyms

BBS Bangladesh Bureau of Statistics

BERC Bangladesh Energy Regulatory Commission
BFSCD Bangladesh Fire Service and Civil Defence
BIDA Bangladesh Investment Development Authority
BILS Bangladesh Institute of Labour Studies
BLA Bangladesh Labour Act
BLR Bangladesh Labour Rules
BMD Bulk Mixing and Delivery Vehicles
BNBC Bangladesh National Building Code
BPGMEA Bangladesh Plastic Goods Manufacturers & Exporters Association
BSCI Business Social Compliance Initiative
CO Carbon Monoxide
CoC Code of Conduct
CSOs Civil Society Organisations
DIFE Department of Inspection for Factories and Establishments
DoE Department of Environment
DoL Department of Labour
ECC Environmental Compliance Certiߔcate
ECR Environmental Conservation Rules
EIA Environmental Impact Assessment
EO Employers’ Organisations
ERP Enterprise Resource Planning
FBCCI Federation of Bangladesh Chambers of Commerce and Industry
FGD Focus Group Discussion
FSCD Fire Service and Civil Defence
GoB Government of Bangladesh
GVC Global Value Chain
ILO International Labour Organization
ISO International Organisation for Standardisation
ITC International Trade Centre
KIIs Key Informant Interviews
Kg Kilograms
kV Kilovolt
LIMA Licensing Industry Manufacturers Association

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m2 Metres Squared
MoPEMR Ministry of Power, Energy, and Mineral Resources
MSDS Material Safety Data Sheet
OSH Occupational Safety and Health
PPE Personal Protective Equipment
PVC Polyvinyl Chloride
RAJUK Rajdhani Unnayan Kartripakkha–Capital Development Authority
SMEs Small and Medium-sized Enterprises
SMI Survey of Manufacturing Industries

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 Industrial Safety in the Plastic Sector

1. Introduction and Civil Society Organisations (CSOs), let

alone ensuring compliance standards. Given the
1.1 Background weak state of transparency and accountability in
monitoring and enforcement of compliances by
The challenge of industrial safety in Bangladesh different public agencies, such as Department
has been exposed again through an accident at of Inspection in Factories and Establishments
a plastic factory, located in Chawkbazar, Dhaka, (DIFE), Department of Labour (DoL), Fire Service
causing the deaths of six workers. Once again, and Civil Defence (FSCD), Rajdhani Unnayan
industrial accidents of Bangladesh have made it Kartripakkha–Capital Development Authority
to the headlines in the international media. Failure (RAJUK), City Corporations, and Union Parishad,
to address this vital issue and undertake proper these factories have been in operation with lack of
remedial measures in industrial establishments safety standards.
across the country would frequently cause similar
incidences. Bangladesh’s growing reputation, 1.2 Objective
as an industrial hub, would be at risk at regional
and global levels. Overall, workers’ safety and The main objective of this study is to identify the
rights issues would continue to face a crisis. state of progress of industrial safety, particularly in
While the export oriented Readymade Garments plastic factories and establishments in Bangladesh,
(RMG) sector has been undertaking necessary through the necessary review of policies, laws, and
remediation measures since 2013, such actions rules; identifying the safety concerns at the micro
are mostly absent in the non-RMG sectors. level; providing a set of recommendations that
are expected to contribute to workers’ workplace
The safety standards of the non-RMG factories safety and security in the plastic factories. More
and establishments are still poor and insufߔcient speciߔcally, the objectives of the study include the
compared to what RMG factories had been following-
practising even before the pre-Rana Plaza
catastrophe in Savar in April 2013. Since most (a) To review the policies, laws, and rules related
of these non-RMG factories operate with fewer to ߔre, electrical, and structural safety of
workers vis-à-vis those of RMG factories, industrial and commercial units; to identify
the casualities in a single incidence were weaknesses in legal issues for undertaking
comparatively lower. Treated as negligible, such proper remediation measures.
casualties could thus hardly catch the attention of (b) To review the institutional capacities of public
the concerned authorities. Fire incidences have, and private agencies, particularly DIFE,
however, been increasing over the years with a FSCD, RAJUK, City Corporations, and Union
rising number of casualties. Unless necessary Parishads, etc., in undertaking technical
remediation measures are undertaken fast, the assessments involving ߔre, electrical and
number of accidents will rise further, which will structural issues of industrial and commercial
cause more casualties of workers. units and pursuing regular monitoring of the
compliance standards of those units.
Undertaking remedial measures in non-RMG (c) To verify the ߔeld-level scenario of the
factories would, however, be a difߔcult task. While Occupational Safety and Health (OSH) proߔle
the RMG sector operates in the Global Value in the plastic sector from different stakeholders,
Chain (GVC), most non-RMG sectors operate followed by some recommendations to
within the domestic value chain. These domestic improve the status.
value chains hardly follow any Code of Conduct
(CoC) in respect of either workplace safety or 1.3 Methodology
workers’ rights. Moreover, there is no pressure
for compliance around such CoCs from other The study focused on industrial safety-related
stakeholders, including consumers, workers, issues from the point of view of OSH in the plastic

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sector. The OSH-related issues are examined in 2. Current Proߔle of the Plastic
terms of workers’ workplace safety, particularly Sector in Bangladesh
related to ߔre, electrical and structural safety in
industrial premises. The study focused on the laws, To better understand the OSH status of the plastic
rules, and practices to understand the signiߔcant sector, it is important to have a better knowledge
regulatory challenges in ensuring compliance. of the full structure of the plastic industry in the
It covered the safety issues of the plastic sector, country with reference to the complete value
which is labour-intensive in nature and involves chain, size, spatial distribution, raw materials,
signiߔcant safety threats. types of products produced, domestic enterprises,
investment proߔle, market size, demand-supply
The secondary data on industrial safety were situation, key market players, etc.
collected from web-based platforms, public
agencies, and media reports. Primary data and 2.1 Value Chain of the Plastic Sector in
information to verify the current scenario were Bangladesh
gathered from eight Key Informant Interviews
(KIIs), and a Focus Group Discussion (FGD) Plastic sector value chain in Bangladesh is nearly
was conducted with key stakeholders. The KIIs identical to that of the RMG sector except for a few
and the FGD highlighted workplace safety at changes (Figure 1). According to the Bangladeshi
the ߔeld-level, like the level of awareness and RMG sector’s industrialisation trend, the sector’s
preparedness of factory management on industrial performance greatly contributes to that sector’s
safety, the level of engagement of public agencies welfare. To understand if the trend also persists in
in factory inspection, the focus on domestic and the plastic sector, it’s important to look at this sector’s
export markets, and the ߔnancial situation of the total value chain and overall performance. The
enterprises, etc. Such data provided a strong base Bangladeshi plastic sector has a weak backward
to understand workplace safety and worker-related linkage like the RMG sector. Most of the raw
compliances. Based on that knowledge, the study materials, in both cases, are imported from abroad.
team identiߔed the activities undertaken by the
public and private sector agencies to understand Micro and small industries in the plastic sector
their effectiveness and put forward necessary primarily rely on contract manufacturing, whereas
suggestions for maintaining transparency, medium and large manufacturers rely on there
accountability, and efߔciency in those initiatives. own-account manufacturing. In the case of selling

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 Industrial Safety in the Plastic Sector

Figure 1: Value Chain of the Plastic Sector in Bangladesh

Input
Suppliers

Granules Additives Moulds Machines

Importer Importers/ Importers Importers/
& Wholesaler Wholesaler /Suppliers Suppliers

Manufacturers

SME (Contract SME (Own Account SME (Own Brand

Manufacturers) Manufacturers) Manufacturers)

Marketers

Independent Company
Principal
Wholesalers Distributors Owned
Wholesalers
/Ret ailers (Company Showrooms,
/Retailers
Managed) Sales Centers

Buyers

Institutional Deemed Direct

Household
(National) Export Export

Recyclers

Recycling Sub-sector

Source: Prepared based on UNESCAP (2013).

the ߔnal products, which is the ߔnal stage of the a vital role in their OSH proߔle. Up-to-date data
value chain, large manufacturers sell their products on the size and the number of factories within
to domestic and global markets. On the other hand, the sector in Bangladesh has yet to be made
small and micro manufacturers sell their products available. Classiߔcations of the factories are
at the national level, particularly to households. also not uniform. According to the Survey of
Manufacturing Industries (SMI) in 2019, published
2.2 Size and Spatial Distribution of Plastics by the Bangladesh Bureau of Statistics (BBS),
Factories the number of enterprises producing rubber and
plastic items includes 943 enterprises. About 4 per
There is a signiߔcant diversity of enterprises cent of those are micro enterprises (employing 10–
(Table 1) ranging from large players to very 25 workers), and 33 per cent are small enterprises
small manufacturing units in the plastic sector (employing 25–99 workers). While medium-sized
of Bangladesh. The size of these factories plays enterprises constitute 22 per cent (employing

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Table 1: Structure and Composition of the Plastic Industry
Size Class Person Engaged Total Manufactures in Total Manufacturing
Plastic & Rubber Industries in Bangladesh
Large TEP>=250 persons 29 2,856
Medium 100<=TPE>250 49 3,178
Small 25<=TPE>99 399 23,306
Micro 10<=TPE>25 466 16,770
Total 943 46,110
Source: SMI Report 2019.

over 100 workers), large enterprises constitute The OSH proߔle of the plastic sector is not only
only 5 per cent (employing 250 workers). But characterised and differentiated by factory size,
unfortunately, the SMI deߔnition does not include but also somewhat related to its location and/or the
factories with less than ten workers, and thus the positioning of the factory. The factories established
total number of factories and people engaged in in old Dhaka have different safety issues than the
the plastic sector is underestimated in the SMI factories in any other place.
report. According to Bangladesh Plastic Goods
Manufacturers & Exporters Association (BPGMEA) Approximately 65 per cent of the plastic industries
data, over 5,000 plastic manufacturing units are in Bangladesh are located in Dhaka and
currently in operation, with the majority being surrounding areas, 20 per cent in Chattogram,
small-scale (roughly 70 per cent) and concentrated 10 per cent in Narayangonj, and the remaining 5
on the domestic market. Currently, nearly 20 per per cent in Khulna, Cumilla, Bogura, and Rajshahi
cent of units are involved in the export market. This Districts. (Figure 2) However, given the increase in
may lead to complications in including the marginal domestic and export demand, plastic enterprises’
factories under any initiatives. constituents have undergone some changes in
recent years.

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 Industrial Safety in the Plastic Sector

Figure 2: Plastic Factories Distribution – By Location

Plastic Locational Distribution

5%

10%

20%

65%

Dhaka Chattogram Narayangang Others

Source: BPGMEA, Export Promotion Bureau.

2.3 Global and Domestic Market million was direct export (Figure 3). With more
than BDT 40,000 crore worth of annual domestic
International brand buyers play a vital role sales, the industry meets more than 80 per cent
in ensuring occupational health and safety of local demand. According to the Bangladesh
worldwide due to their brand value. Plastic goods Investment Development Authority (BIDA), the
from Bangladesh are exported in two ways: country has 5,030 plastic factories, with small and
directly to the international market and indirectly medium-sized businesses owning 98 per cent of
as packaging materials and accessories for other them.1 According to the BPGMEA data, the local
ߔnished export items. According to the BPGMEA, market for the plastic sector is worth approximately
the direct export market was worth USD 982.7 USD 2.5 billion. As a result, Bangladeshi plastic
million (in FY2020–21), of which USD 867.4 products have a global market share of about 0.5
million had been deemed export and USD 115.3 per cent at home and abroad.

1
https://www.tbsnews.net/economy/bangladesh-plastics-aim-global-market-pie-301183

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 Figure 3: Direct and Deemed Export of Plastic Products

1000 70

900 60

800 50

700 40

600 30

500 20

400 10

Direct and Deemed Export

300 0

200 -10

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Percentage Change in Direct and Deemed Export

100 -20

0 -30
2010–11 2011–12 2012–13 2013–14 2014–15 2015–16 2016–17 2017–18 2018–19 2019–20 2020–21 2021–22

Years

Direct Export Deemed Export % Change (Direct Export) % Change (Deemed Export)

Source: BPGMEA, Export Promotion Bureau.

 Industrial Safety in the Plastic Sector

2.4 Types of Products and the Raw Apart from that, plastic production requires reߔning
Materials petroleum products, the most common of which
are crude oil and natural gas. Fires in the plastic
The plastic industries in Bangladesh have industry can produce black, acrid smoke and
successfully been producing nearly all the poisonous gases such as Carbon Monoxide (CO).
plastic items required for household purposes Fire can spread quickly which can be difߔcult to put
and for other uses. According to the BPGMEA, out. To avoid the ߔre ignition, sources should be
nearly all of the plastic packaging used by the controlled by prohibiting cigarette smoking and hot
country’s export markets are now manufactured work in high-risk areas.
in Bangladesh. Domestically produced materials
are used by various industries to meet different The plastic industry is constantly evolving in
purposes like retail packaging, industrial and bulk terms of technological development. Production
packaging, household uses, ofߔce equipment, process and other relevant activities are becoming
building materials, engineering and industrial parts, increasingly mechanised. Traditional types of
medical instruments, agricultural products, poultry machinery used in producing plastic products,
and ߔshing items, automobile and cycle parts, such as injection molding, circular weaving loom,
electronics, textile articles, engineering products, ߕexographic printing, gravure printing, offset
musical products etc. printing, sewing machines, lamination, vacuum
molding, and mould injection, etc., are likely to
The thermoplastic moulding compound is the be replaced by more sophisticated machines and
primary raw material used in all plastic industries advanced system. Bangladesh did not yet capture
to produce speciߔed products. Bangladesh lacks the industry to produce the capital equipment
a backward linkage industry for the plastics sector, needed for plastic production. As nearly all raw
particularly for raw materials. As a result, almost all materials and equipment are imported from other
raw materials are imported from various countries. countries,local workers ߔnd it diffߔcult to operate
However, most of the raw materials used by plastic the machines efߔciently since most of the guiding
factories (Table 2) are highly ߕammable, making manuals are written in English. Due to a lack of
them more vulnerable to ߔre and electric accidents. investment on training in medium and smaller

Table 2: Raw Materials Used in the Plastic Sector

HS Code Description
32121000 Stamping Foils of a kind used in the Printing of Book Bindings or Hatband Leather
32129000 Pigments (Metallic.) dispersed in non-Aqueous Media. Ex. Stamping Foils
32151100 Printing, Ink, Black
32151900 Other Inks, Whether Concentrated or Solid
32159010 Fountain Pen Ink
32159020 Ball Pen Ink
32159090 Printing Ink, Writing or Drawing Ink and Other Inks, whether or not Concentrated or Solid
39011000 Polyethylene having a speciߔc gravity of less than 0.94
39012000 Polyethylene having a speciߔc gravity of 0.94 or more
39013000 Ethylene-Vinyl Acetate Copolymers
39019000 Other Polymers of Ethylene
39021000 Polypropylene
39022000 Poly Iso Butylene
39023000 Propylene Copolymers
39029000 Plastic Granules
(Table 2 contd.)

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(Table 2 contd.)
HS Code Description
39031100 Expansible Polystyrene in Primary Forms
39031900 Polystyrene (Excl. Expansible), in Primary Forms
39032000 Styrene-Acrylonitrile (San) Copolymers, in Primary Forms
39033000 Acrylonitrile-Butadine-Styrene (Abs) Copolymers
39039000 Styrene Polymers, in Primary Forms
39041000 Polyvinyl Chloride, not mixed with other Substances, in Primary Forms
39042100 Non-Plasticised Polyvinyl Chloride, in Primary Forms
39042200 Plasticised
39043000 Vinyl, Chloride, Acetate
39044000 Polymers of Vinyl Chloride or other Halogenated Oleߔns, in Primary Forms
39046100 Polytetraߕuoroethylene, in Primary Forms
39046900 Fluoropolymer, in Primary Forms
39049000 Polymers of Halogenated Oleߔns, in Primary Forms, Nes
39051200 Polyvinyl, Acetate, Aqueous
39051900 Other Polymers of Vinyl Acetate or of other Vinyl Esters, in Primary Forms
39052100 Vinyl Acetate Copolymers: in Aqueous Dispersion
39052900 Vinyl, Acetate, Copolymers
39053000 Polyvinyl Alcohol, whether or not Containing Unhydrolysed Acetate Groups
39059100 Copolymers, Vinyl, Primary.
39059900 Polymers of other Vinyl Esters & other Vinyl Polymers in Primary Forms Nes
39061000 Polymethyl, Methacrylate, Primary
39069000 Flocculating Agent Chemical
39071000 Polyacetals, in Primary Forms
39072000 Polyethers, other than Polyacetals, in Primary Forms
39073000 Epoxide Resins
39074000 Polycarbonates, in Primary Forms
39075000 Alkyd, Resins, Primary
39076010 Poly (Ethylene Terepthalate)
39076090 Poly (Ethylene Terepthalate): other (including clean, Colorless Grades)
39077000 Other Polyesters: Poly (Lactic Acid)
39079100 Unsaturated Polyester Primary Forms
39079900 Polyethylene Naphthalene-2,6-Dicarboxylate”, Saturated, in Primary Forms
39081000 Polyamide-6, -11, -12, -6,6, -6,9, -6,10 Or -6,12 in Primary Form
39089000 Polyamides in Primary Forms
39091000 Urea, Resins, Thiourea
39092000 Melamine Resins, in Primary Forms
39093000 Amino-Resins, in Primary Forms (Excl. Urea, Thiourea and Melamine Resins and Mdi)
39094000 Phenolic, Resins, Primary
39095000 Amino - Resins, Phenolic Resins and Polyurethanes, in Primary Forms—Polyurethanes
39100000 Silicones, in Primary Forms
(Table 2 contd.)

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 Industrial Safety in the Plastic Sector

(Table 2 contd.)

HS Code Description
39204910 Pvc Film & Pvdc Film for Blister Pack for Medicine
39204920 Plates, Sheets, Film, Foil and Strips, of Non-Cellular Polymers of Vinyl Chloride
Source: BPGMEA, International Trade Centre (ITC).

factories, the common method of training on extensive hot work and constant use of machinery.
operating these types of machinery are carried Because of the work processes and unsafe working
out by mid-level or junior-level workers. According conditions in Bangladesh, accidents, deaths, and
to the management of small and medium-sized injuries are taking place frequently on small and
factories, there is higher rate of migration among medium sized factories (Table 3).
mid-level workers, which make it difߔcult to ensure
using the machine in a proper and safer way. There were 14 ߔre incidents in the plastic sector from
January to September 2022, mostly resulting from
3. Industrial Safety Concerns in the electric short circuits and gas cylinder explosions,
Plastic Sector causing seven deaths, according to the authors’
compilation from the different newspapers. This
Plastic industry workers are regularly engaged in trend of accidents is increasing, as seen in table
activities on technical processes such as moulding, 4 on ߔre incidents reported in different places and
casting, curing, trimming, crashing and demolding. sectors. Besides that, many workplace injury cases
Involvement in these tasks requires knowledge remain unreported in absence of proper monitoring
about chemical management, boiler usage, and record-keeping in the plastic sector.

Table 3: Accidents from FY2015–16 to FY2020–21

Total Establishment Export Oriented Establishments Total Incidents
Registered Non-Registered Registered Non-Registered
Plastic 607 421 19 0 4
Rubber 102 16 1 0 0
Total 709 437 20 0 4
Source: Safety Council, Federation of Bangladesh Chambers of Commerce and Industry (FBCCI).

Table 4: Fire Incidents Reported in Different Places and Sectors (Year wise)2
Sectors and Places Number of Fire Incidents
2015 2016 2017 2018 2019 2020
Home and Kitchen 6316 6451 7005 7216 8466 8776
(36.9) (38.8) (39.4) (37.2) (35.4) (42)
Cow-house and Haystacks 2666 2480 2436 2741 4714 3091
(15.6) (14.9) (13.7) (14.1) (19.7) (14.8)
Shops and All Bazaars 2829 2855 3012 3312 4057 2984
(16.5) (17.2) (16.9) (17.1) (17) (14.3)
Factories and Warehouse 1099 934 1157 1281 1245 401
(6.4) (5.6) (6.5) (6.6) (5.2) (2.4)
(Table 4 contd.)
2
Value in parenthesis is in percentage (%).

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(Table 4 contd.)

Ofߔces, Hospitals, Schools, 533 656 654 819 738 495

Boarding, and Hotels (3.1) (3.9) (3.7) (4.2) (3.1) (2.4)
Jute related Warehouse, Mills, 145 198 249 155 207 80
Shops and Transports (0.8) (1.2) (1.4) (0.8) (0.9) (0.4)
Ships, Automobile, Cars, and 991 397 359 505 364 307
Normal Transports (5.8) (2.4) (2.0) (2.6) (1.5) (1.5)
Others 2532 2644 2905 3359 4134 4666
(14.8) (15.9) (16.3) (17.3) (17.3) (22.3)
Grand Total 17111 16615 17777 19388 23925 20896
Source: Authors’ illustration from FSCD yearly statistics 2015, 2016, 2017, 2018, 2019, 2020.

4. National Policies, Rules and In Bangladesh, an adequate number of legal

Regulations Related to the Plastic bindings are in place under the cover of rules and
regulations to ensure workplace safety, and these
Sector: Implications on Industrial need to be maintained properly. The objective of
Safety the existing and newly developed policies, rules,
and regulations relating to OSH can be categorised
Ensuring OSH involves adequate measures as a) mitigating hazards, b) lowering the risk of
to address and mitigate workplace hazards, accidents, and c) preventing the spread of disease.
accidents, and diseases. The process starts Policies, rules, and regulations that fall under the
with structural integrity and ends with proper and three categories are summarised below:
constant monitoring of safety-related issues. The
National OSH Policy clearly stipulates the need 4.1 Legal Provisions for Mitigating Hazard
to ensure workplace safety and health protection
considering international conventions/declarations/ Factory Construction and Storage Facilities:
recommendations / documents (Art. 3.a.1); According to the National OSH policy (Clause
implement national laws and regulations in relation 4.d.1), it is mandatory to ensure maximum safety
with workplace safety and occupational health (Art. standards during factory construction and to comply
3.a.2); setting up national standards on OSH (Art. with all standards and regulations on the internal
3. a15, Art. 4a. 20); develop a strategy and action safety environment. The Bangladesh National
plan to ensure proper implementation of national Building Code (BNBC) 2006 provides in detail for
laws and regulations (Art.4. a.3); including OSH building safety, like minimum ceiling heights, wall
issues in the policies and programs of all related width, and staircases requirements etc. According
ministries and agencies (Art.4.a13); establishing to the BNBC 2006, an industrial establishment
labour courts in the industrial zone for implementing must have a ceiling height of 3.5 metres for non-
mandatory OSH provisions (Art. 4. A.15); imposing air-conditioned buildings and 3.0 metres for air-
mandatory terms and conditions upon construction conditioned buildings (Section 1.12.2.), and the
agencies to follow OSH policies during government minimum width of the staircases must be at least
run construction works (Art. 4. A.22); providing 2.0 metres. Handrails will have a minimum height of
ߔnancial support to the establishments that maintain 0.9 metres (Section 1.12.5). Additionally, according
and practice the OSH rules and regulations (Art. to section 2.4.1, the exterior walls of industrial
4.a.24); and ensure maximum safety standards buildings shall have a ߔre resistance option lasting
during factory construction and implementing for at least 2–3 hours, which would help to minimise
all standards and regulations on internal safety the damage from ߔre-related accidents.
environment (Art. 4.d.1).

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 Industrial Safety in the Plastic Sector

As the plastic sector is deeply chemical-oriented, Chimneys, Ventilation, and Boiler Management:
the Environmental Conservation Act (ECA), 1995, The Bangladesh National Building Code 2006
Environmental Conservation Rules (ECR) 1997 mandates that all chimneys, vents, and ventilation
and National 3-R strategy 2010 are also valid for ducts should be designed with non-combustible
storing and using chemicals in establishments or materials. The code also stipulates that every
facilities. These acts and rules provide necessary boiler, central heating plant, electrical room, or hot
standards for properly using chemicals depending water supply boiler must be separate and placed
on their categories (i.e., Green, Orange-A, at a distance from the main workplace building(s)
Orange-B, Red category) for industrial units. to prevent major hazards (Section 2.11.7). Apart
from that, the boiler owner cannot use or permit
Material Safety Data Sheet: Bangladesh the boiler function unless it has been registered
Labour Rules 2015 states that the factory and per the Boilers Act of 1923.
establishment owners shall place the Material
Safety Data Sheet (MSDS) of dangerous materials Floor Safety: All ߕoors, stairs, passages, and
in an easily noticeable place within the factory gangways of the factories should be of sound
premises so that the employed workers can be construction and properly maintained, and strong
well informed about the possible hazard (Rule railing should be in place as applicable to ensure
68, 10). The factory owner must get the factory’s safety. The passages and stairs ought to be kept
layout plan and extension layout plan approved open to facilitate easy exit during the continuance
by DIFE (Section 326, BLA and Rule 353, BLR). If of work (Section 72 BLA (Amendment) 2013).
asbestos is used, there should also be a specially
constructed facility for the removal and handling of )LUH/LFHQFH)LUH5HVLVWDQFHDQG)LUHÀJKWLQJ
it in the yard, alongside the necessary provisions Requirements: According to the Fire Prevention
relevant to asbestos handling systems and also for and Extinction Act 2003, to use a building or
‘showering it off’ (Section 17.9). certain part of a building or establishment as a
warehouse or workshop, a certain person/group
Electric Supply and Safety: According to the needs a permissible licence under the Act from
Bangladesh Labour Rules 2015, electricity supply the Director General of the Fire Service and Civil
lines and accompanying apparatus in all factories Defence Department (Section 4, 7).
will have to be of sufߔcient size, strength and risk-
absorbing and should be set, installed, protected, The ߔre hazard-related directives in Bangladesh,
and maintained in such a manner that would not the National Building Code 2006, necessitates that
pose a risk of serious bodily harm to workers all elevator shafts, vent shafts, and other vertical
(Section 58, BLR). openings in the workplaces shall have to be fully
enclosed with the provision of a minimum four-
Additionally, according to Electricity Grid Code hour ߔre-resistance protection option and that all
2019 adopted by Bangladesh Energy Regulatory ߔre exits to be compatible with existing National
Commission (BERC), at least one busbar protection Acts (Section 2.11.5). The Bangladesh Labour Act
system shall be installed at the 132 Kilovolt (kV) 2006 (BLA) requires that every establishment shall
level, and redundant (Main-1 & Main-2) busbar have a ߔreߔghting apparatus/ߔre extinguisher and
protection systems shall be installed at the 230 kV ߔre exit. Where the factory owner employs 50 or
and 400 kV levels. The busbar protection relay is more workers for his business, the employer shall
designed for high-impedance applications in utility have to arrange ߔre-ߔghting drills at least once
substations and industrial power systems. The relay every six months and maintain a record book for
can also protect generators, motors, transformers, monitoring compliance (Section 62, BLA). The BLA
and reactors in restricted earth-fault and residual (Amendment 2013) requires every establishment
earth-fault applications, decreasing the probability to provide means of exit, including at least one
of ߔre incidents out of electrical fault. alternative staircase linked to every ߕoor and
the requisite number of ߔreߔghting equipment on

Page | 11
every ߕoor (Section 62(1)). Also, the amended Act factory has 50 or more workers, the factory owner
ensures that in every factory/establishment, no must form and ensure the functioning of a safety
room exit shall be kept locked during work, no exit committee following the instructions detailed in
shall be hindered, or no barrier shall be put in the Bangladesh Labour Rules (BLR) (Section 90A,
way (Section 62(3a). In factories with more than BLA 2006). Procedures for formulation and role of
50 workers, mock ߔre drills should be carried out the safety committees are speciߔed in Bangladesh
at least once every six months (Section 62(8)) Labour Rules (Chapter 8 and Schedule 4, BLR
2015).
The BNBC 2006 also provides detailed provisions
for ߔre exits; they must be easily discernible and Load Handling: No person should be engaged in
accessible from any part of the building. In addition, any factory to lift, carry or move any heavy load
all exit points should be located and arranged so susceptible to causing injury (Sections 74, 83-
that they provide continuous and unobstructed 86, 90,323, BLA.). Adding to it, the highest load
ways and means for an escape to the exterior of capacity for adult males has been speciߔed as 50
the building, leading to a street or other designated kilograms (Kg) and 30 Kg for adult females.
areas of refuge (Section 3.4). It also requires
the installation of automatic ߔre and smoke Safety of Machinery Use: BLA 2006 prescribes
detection systems when the size, arrangements, that inspectors may prohibit any building,
and occupancy within the factory/establishment machinery, or plant of any establishment if it
become such that the ߔre itself cannot provide appears dangerous to human life or safety (Section
adequate warning to its occupants for their safety. 61 (2)). When the machines are in motion or in use,
The automatic ߔre and smoke detection system they should be securely fenced by/encircled within
shall include lien-type heat-sensitive and optical, substantially protected construction (Section 63,
ionised, or chemical-sensitive type and smoke BLA). Every screw, belt, key, revolving shaft,
detectors (Section 4.41). spindle wheel, pinion or any other spares shall
have to be encased or otherwise effectively
The Code also recommends the correct type of ߔre guarded to prevent minimum damage and danger
extinguishing system to be installed for necessary (Section 67, BLA).
use in different industrial establishments. In low-
hazard industries, manually operated ߔre alarm Safety Equipment/Tools and Facilities: No
systems and portable ߔre extinguishing sets must factory owner, industrial boss or any authority shall
be installed. For moderate hazard industries, engage any worker(s) in work whatsoever without
areas up to 750 Metres Squared (m2) should be providing them with personal safety equipment/
covered by automated ߔre alarm systems and have protective gear and ensuring the correct use
portable ߔre extinguishers. In areas above 750 m2, thereof. The BLA 2006 states that suitable goggles
the unit should be ߔtted with automatic sprinklers should be provided for workers where eyes are
or automated ߔre alarm systems, along with a at risk of exposure to excessive light or heat
portable ߔre extinguishing system (Section 5.8). (Section 75.).

4.2 Legal Provisions for Reducing the Risk The BLA section 78A sets clear guidance on
of Accidents the use of safety appliances; the employer is
required to provide safety appliances to factory
Safety Committee: The BLA 2006, section 90a, workers and shall not employ any person before
calls for the formation of a safety committee in ensuring the use thereof. By law, a record book
every factory where 50 (Fifty) or more workers shall have to be maintained by the employer in a
are employed. The safety committee has to be prescribed manner. The workers concerned shall
constituted as prescribed in section 30 of the Act. be held responsible if they do not use the safety
As per Bangladesh Labour Rules 2015, if the equipment supplied by the employer. Additionally,

Page | 12
 Industrial Safety in the Plastic Sector

all the workers would have to be well-trained on the establishment, there has to be the ߔrst-aid box
safety issue and made aware of the risks at work, or cupboard equipped with necessary primary
thereby ensuring occupational health, safety, and treatment items prescribed by BLR to be readily
protection in the workplace. accessible to all during working hours (Section 89);
in addition, a sick room furnished with a dispensary
Record Keeping and Planning: The employer of suitable size and possessing required equipment
shall maintain a record book on this matter in the and such facilities as prescribed under section 77
prescribed manner (Section 78A, BLA (Amendment) of the BLR has to be provided and managed by
2013). The National OSH Policy obligates the a medical practitioner and nursing staff as may
employer(s) to provide training and guidelines to be prescribed under the BLR, (Section 89 (5) and
the workers on safety and Personal Protective Section 77, BLR 2015), where 300 (Three Hundred)
Equipment (PPE) and ensure their use in the or more workers are ordinarily employed.
workplace (Clause 4.d.7). It suggests necessary
OSH-related guidelines for the employers to pass Medical Centre: In respect of any establishment(s)
on to the workers (Clause 4.e.1). It also states that where 5,000 (Five Thousand) or more workers are
workers should take care of their own as well as employed, the employer/employers thereof shall
co-workers’ health and safety (Clause 4.e.2). be required to maintain and operate a permanent
medical centres in such manner as may be
Imminent Danger: The BLA clearly states that if prescribed by BLR (Section 89 (6), BLA 2006 and
a labour inspector ߔnds a building, or any part of Section 78, BLR 2015).
a building, or its machinery and plant, posing a
serious threat to workers, then s/he is duty-bound to :HOIDUH2IÀFHU The employer of any establishment/
issue a written notice to the factory/establishment factory running with 500 (Five Hundred) workers or
owner to do the needful. The owner must seek more shall have to appoint a welfare ofߔcer in the
necessary remediation for the building and act on manner prescribed by section 79 of the BLR (Section
the notice according to the deadline (Section 61). 89 (8), BLA 2006 and Section 79, BLR 2015).

4.3 Legal Provisions for Preventing the Drinking Water: The BLA 2006 mandates that
Spread of Disease factories/establishments provide puriߔed potable
water for workers at a suitable point in the factory/
Disease Prevention and Safeguards: Both the establishment (BLA Section 58 (1)). During hot
National OSH Policy and the National Child Labour summers, provisions shall be made for cooling
Elimination Policy include disease(s) prevention potable water for establishments / factories
and safeguarding clauses. The National OSH employing more than 250 workers (Section 58.3).
Policy calls for identifying the risk of health and
safety (Clause. A3), imparting orientation to the Restroom: BLA makes it mandatory that a an
persons engaged in formal and informal workplaces employer operating a factory with more than
on the risk of a possible accident as well as health 50 workers has to maintain a restroom for the
risks and safety issues (Clause 3.4), and making workers, with an arrangement for drinking water,
provisions for a specialist doctor who can identify where they can have their meals and also take rest
occupational diseases’ and ensure health safety in (Section 93 (1), BLA)). Separate restrooms shall be
the factory and establishment (Clause 3.10). The provided for male and female workers where the
Penal Code ensures punishment by law in case number of female workers is more than 25 (Section
of negligent and malignant acts resulting in the 93(3), BLA)).
spread of infection of diseases dangerous to life
(Sections 269 and 270). 4.4 Legal Provisions on Overall Concerns

Sick Room and Dispensary: According Awareness Raising: Section 78A (3) of the
to Bangladesh Labour Act 2006, in every BLA mentions that a factory owner must arrange

Page | 13
training for all workers to make them aware of The policy also recommends that the respective
workplace hazards. The National OSH Policy 2013 institutions use the data and information to make
describes the role of employers in identifying OSH action plans and take guidance from OSH specialists
risks and informing every person in the workplace for ensuring OSH standards in the workplace
about occupational health and safety risks. (Clause 3.a.8,4. a.9 and 4.d.65). Section 90 of
BLA 2006 provides for the compulsory obligation of
According to the rule 351 of Bangladesh Labour keeping and maintaining a safety record book and
Rules 2015, one of the key roles of a labour a safety board in every establishment and factory,
inspector is to conduct trainings and workshops wherein more than 25 workers are employed.
to raise the knowledge and skills of workers, According to the Bangladesh Labour Rules 2015,
members of trade unions, and employers. the authorities of all factories are obliged to keep
a register of all accidents and dangerous incidents
The National OSH Policy mandates the treatment that occur from time to time in that factory (Rule 73).
and compensation of any injured worker and
rehabilitate victimised workers as per his/her Penalty System: The Labour Law of Bangladesh
capability (Clause 4.b.11 and 3.a.12). For raising provides many ߔnancial and imprisonment
awareness on OSH issues, the policy includes a penalties for violating labour law. Some of these
number of clauses/obligatory directives like regular penalties (Section 289, 290, 291, and 294) are (a)
observance of Occupational Health and Safety imprisonment for a term, which may extend to one
Day on April 28 each year by the state (Clause year, or ߔne up to ߔve thousand takas (BDT 5,000)
4.a.25); publicity and promotional measures on or both for the employer if he pays a wage below
OSH related issues through government and than the rate of minimum wage; (b) Failure to give
private TV channels and other media (clause proper instructions in case of any ߔre incidents
4.a.26); inclusion of OSH issues in the curriculum will result in ߔne up to three thousand takas (BDT
of Secondary and Higher Secondary Education 3,000) and imprisonment up to six months, or
(Clause 4.a.27); motivate all employers to both. Apart from that, based on the severity of
implement the OSH policy, BLA and related laws accidents, due to the lack of compliance, the same
on OSH (Clause 4.b.1.); arrange discussions, penalties will be imposed. (c) maximum ߔne of ten
consultations and trainings, for employees of the thousand takas (BDT 10,000) and imprisonment
member organisations (Clause 4.b.2); provide up to two years for unfair labour practices; and
information on laws related to OSH, rights and (d) one-year imprisonment and a ߔne up to ߔve
responsibilities of trade unions regarding safe and thousand takas (BDT 5,000), or both for illegal
healthy workplaces and arrange orientation to the strike or lock-out. These penalties are not severe,
workers (Clause 4.c.1); and motivate the workers and trade union leaders of Bangladesh and civil
through the trade unions to follow the laws on society actors have long been demanding for a
OSH (Clause 4.c.2). Employers must identify all stronger punishment system. Yet, for many types
OSH risks and orientate all workers on such risks of law violations, the penalty has been reduced
and the potential causes of accidents (Clause to a low amount (BDT 5,000), and imprisonment
4.d.2). The policy also suggests developing a provision has been waived to absolve the labour
safe work-plan and ensuring its effective practice law violating employers from imprisonment
(Clause 4.d.8.) punishment. In the recent move, change has been
brought in Article 307 of the BLA 2006 related to
Record Keeping and Planning: The National penalties for offences for which no speciߔc penalty
OSH Policy stresses the collection and maintenance has been imposed in other law articles. According
of all records on OSH-related accidents, injuries, to this change, employers are now required to pay
death, treatment, compensation, cases, and only BDT 5,000 as a ߔne instead of the previous
decisions, etc., (Clause 3.a.7; 4.a.8; and 4.d.5). punishment—‘Imprisonment up to three months,

Page | 14
 Industrial Safety in the Plastic Sector

or ߔne up to BDT 1,000, or both’. Accordingly, planning, estates and resources, plot allotment,
the current penalty system does not consider and construction approvals in respect of relevant
the need for striking a balance between savings proposals from public and private entities. The
accrued by violating labour law provisions and the RAJUK is responsible to prepare the Master
cost of compliance. Plan, structural and detailed area plans within
its jurisdiction area, accord approval, monitor
Apart from these national rules and regulations, and supervise development and control of
many international CoCs regarding workplace building construction and private residential land
safety need to be fulߔlled to enter the international development projects.
market. Some of them are—Basel, Rotterdam,
Stockholm Conventions, Business Social 5.2 Department of Inspection for Factories
Compliance Initiative (BSCI), Enterprise Resource and Establishments (DIFE)
Planning (ERP), International Organisation for
Standardisation (ISO), etc. But most of them, The DIFE is the national labour inspectorate under
apart from BSCI, focus on the health and climate Bangladesh Labour Act 2006 and has got working
impact for consuming plastics rather than on linkage with International Labour Organization
worker-level safety. (ILO) Labour Inspection Convention, 1947 (No 81);
it is solely responsible for enforcing labour laws
5. Monitoring and Regulatory and rules through inspection at the workplaces.
The DIFE is responsible for implementing all the
Authorities Accountable for Industrial
provisions of the Labour Act 2006 except Chapter
Safety 13—Trade Union and Industrial Relations and
Chapter 14—Arbitration, Labour Courts, Labour
5.1 Capital Development Authority of the Appellate Tribunal, and Rules of Procedures. The
Government of Bangladesh (GoB) — key functions of DIFE include: inspecting factories,
RAJUK shops, industries, and commercial establishments,
especially high-risk ones; enforcing the terms of
The RAJUK, Capital Development Authority, employment, safety, and health issues, and labour
is the authoritative national board on building welfare under the Bangladesh Labour Act 2006 and

Table 5: Labour Inspection Status of Import-oriented Non-RMG Sectors (As of November

2021)
Sector/ Factory Group Total Factories Proactive Reactive Follow-up
Inspection Inspection Inspection
Food Production 12678 2934 1227 124
Engineering 2721 542 472 6
Brick Field 5611 884 491 3
Chemical 1209 235 52 3
Wood and Construction 2798 791 147 3
Plastic 1166 295 129 3
Textile 4323 878 196 3
Leather 435 36 7 0
Packaging3 562 106 53 0
Source: Website of FBCCI; LIMA, and DIFE.

Page | 15
Bangladesh Labour Rules 2015; and prosecuting enquires into boiler or steam pipes accidents,
the violators in labour courts. Table 5 displays that inspect hydraulic testing of every working
1,166 plastic factories out of 5000 manufacturing boiler annually, and awards certiߔcates thereof, if
units (according to BPGMEA data) have been found ߔt.
inspected at least once so far. This shows that
the extent of inspection, conducted in the plastic 5.5 Department of Environment (DoE)
sector, is very low.
As speciߔed in the Environment Conservation
Apart from conducting inspections, DIFE is also Rules 1997, clause 7, all new industries and
responsible for examination and veriߔcation of projects must apply for an Environmental
certiߔcates issued by the relevant authorities Compliance Certiߔcate (ECC). ECC certiߔcates
relating to safe and secure operation in factories/ are issued by DOE after their initial ߔeld visit and
establishments. Investigation of complaints, assessment. Industries are classiߔed according
received from workers on their labour rights, to their potential impact on the environment into
working environment, establishing communication four categories: Green, Orange-A, Orange-B,
with various government organisations, employers’ and Red. Industries belonging to Green category
associations, and trade unions for the proper are automatically granted ECC. Those under
implementation of labour laws, also fall under their Orange-A category must submit further information
supervision. and plans and may be subject to ߔeld inspection.
And those belonging to highly polluting categories,
5.3 Bangladesh Fire Service and Civil Orange-B and Red, are required to conduct a
Defence (BFSCD) detailed Environmental Impact Assessment (EIA)
and prepare environmental management plans
Bangladesh Fire Service and Civil Defence, an satisfactory to the Department.
important wing within GoB Ministry of Home Affairs,
is responsible for ߔre prevention, ߔreߔghting, 5.6 Department of Explosives
rescue missions, and ߔre safety during any natural
or man-made disaster as per the Fire Prevention The Department of Explosives, under the Ministry
and Extinction Law 2003. It responds to ߔre of Power, Energy, and Mineral Resources
hazard occurrences through a network of more (MoPEMR), controls the use of explosives to
than 340 ߔre stations across the entire country minimise hazards. Some of the major functions of
and maintains a hotline, 9555555, to receive ߔre the Department of Explosives include: (i) scrutiny
incidents notiߔcation. and approving site, layout, and construction plans
for explosives manufacturing factories, explosives
5.4. Ofߔce of the Chief Inspector of Boilers storage premises, manufacturing of explosives at
the site in Bulk Mixing and Delivery Vehicles (BMD);
This division inspects boilers and ensures boiler (ii) public display of ߔreworks, storage installations
safety throughout the country. It advises the for compressed gases in unߔred pressure vessels,
factory owners regarding the design, construction, ߔlling plants for gas cylinders; (iii) advising Sea/
maintenance, working of boilers, water treatment River Port, Airport, and Railway authorities on the
of feed water, and cleaning of boilers. The classiߔcation of hazardous substances; (iv) packing
division also examines the design, drawings, and determination of conditions for storage/
and speciߔcations of the boilers to be imported transport of dangerous substances; (v) setting and
from abroad or manufactured within the country, layout of facilities for the loading/unloading and

3
The number of factories for all sectors is considered from the sectoral priority list of DIFE except the packaging sector
which is collected from the LIMA establishment list.

Page | 16
 Industrial Safety in the Plastic Sector

transit storage of explosives, ߕammable and other Based on the FGD, the OSH situation in the
dangerous substances; (vi) examination/testing of plastic sector can be portrayed on the basis of the
explosives/hazardous substances for classiߔcation following groups: Large factories, medium factories
of hazard; (vii) advising the Government, the and small factories.
Industry, and various organisations on matters
relating to the handling of explosives, ߕammable 6.1 Large Factories
and other dangerous substances.
Most of the large category factories own a bigger
5.7 Private Sector Organisations portion of the domestic market share or export
globally; they seem to fulߔll structural compliances
Employers’ Organisations (EOs) are formal groups like layout approval, well-structured chemical
of employers/factory owners, set up to represent, pipelines, separate storage for raw materials,
advise, and defend afߔliated employers and to and ߔnished products, sprinklers, busbar, and
strengthen their position in the industrial sector electric cables as per the Labour Act and Rules
concerning labour matters. Bangladesh Plastic of their own accord. They also have their inter-
Packaging Association, Roll Manufacturers company safety protocols/guidelines to follow, and
Owners Association, Bangladesh Plastic ensures trainings on ߔreߔghting, using PPE, and
Babosayee Samity, Bangladesh PVC Compound machinery operation. Risk assessment reports are
Manufacturers Association, Bangladesh PVC available for every section of the factory, covering
Pipe Manufacturers Association, etc., are some of the production process comprising various work
the private sector organisations that work for the events. These factories also claim to be fulߔlling
betterment of plastic industries. many international rules and regulations to get
the licence for entry into the domestic market.
The principal objective of these associations is Almost all of the licences the factories arrange for
to safeguard the interest of the plastic sector of operation focus on the quality of the plastic and
Bangladesh and the development of trade and the environmental impact of the used product.
business across national and international ߔelds They also seem to have information on forming the
by removing challenges like industrial accidents safety committee and claim it is available in their
and injuries. Some of the responsibilities of these factories. But whether or not they are functioning
organisations include: promoting and protecting properly is still a concern.
the interest of employers engaged in industry; trade
and commerce in the country; studying, analysing, 6.2 Medium Factories
and disseminating information relating to labour
policy; labour management relations; collective Owners of medium-sized factories have the bare
bargaining and offering advice to member factories minimum to get away with getting the licences
concerning various aspects of labour policy. to operate in the market. There is still a need
to set-up in-house company policies regarding
6. Current Occupational Health safety issues. Most medium-category factories
and Safety Scenario of the Plastic do not have safety committees and very few of
them recruit safety ofߔcers. According to them,
Industry in Bangladesh
the severe accidents might hardly occur in their
factories. However, workers frequently get injured
According to the ߔndings from KIIs conducted at
in small and medium factories while operating
the management level, the safety culture has
machinery, since they mostly use manually
not been developed in the plastic sector. The
operated machines. Very few factories own the
informants conߔrm that the factory owners do not
whole building and mostly operate on a single ߕoor
consider safety and security in the workplace as
of an apartment or market building, making it more
a vital component and thus consider investment
difߔcult to be structurally compliant.
on account of safety as ߔnancially not beneߔcial.

Page | 17
6.3 Small Factories iv. A Separated Plastic Zone for Small and
Medium-sized Enterprises (SMEs): Most
Small-sized factories have to maintain and fulߔll micro and small factories cannot ensure
the lowest number of compliances. Even after that, bare minimum safety protocol; they need to
comparatively, they are mostly lagging behind in be relocated to a different plastic zone, if not
safety issues. They work with little to no capital to given any ߔnancial assistance.
hire a safety ofߔcer solely for safety purposes. They v. Awareness of the Factory Owners on
claim to acquire more capability and competence Legal Issues: Even though Bangladesh has
to afford to be structurally compliant as they mostly recently been focusing on occupational health
operate in rented facilities. and safety, it still needs factory-level law
enforcement to be alert about these frequent
7. Recommendations accidents in the workplace. Most factories are
not aware of the legal bindings or guidelines
i. Relevant Information: Availability of for factory-level compliances.
required, relevant and appropriate information vi. Proper Investigation of the Previous
needs to be ensured among different Accidental Incidents: Increase of risk is
stakeholders. Availability of data is the ߔrst directly proportional to the increase in incident
requirement to fulߔll the process towards occurrences as well as increase in the
working with a sector. With the prevalence of severity of injuries. Proper investigation of the
different classiߔcations, mismatch in the total past accidents and injuries sustained by the
number of plastic factories creates barriers in workers and effective analysis thereof would
implementing any legal procedure. According help minimise the incidence of accidents to a
to BLA, every establishment needs a licence great extent and injury severity can also be
to start operating in the economy whereas the reduced.
number of plastic factories registered to DIFE vii. Training on Safety Issues and Cooperation
shows only 712 factories on their website from Government Bodies: Training the
LIMA. To bring every plastic factory under any workers as well as the factory employers on
initiative, the availability of correct information the overall issue of safety in the workplace is
needs to be increased. contributory to better risk-free environment
ii. Designing Factory-level Safety Book there. Although the migration of trained labour
Manual: The availability of guidelines, from the factory might imply some sort of loss
consisting of a set of manuals, such as manuals for the employer(s), it bears good results for
for handling chemicals, electric wiring and hot the industry as a whole as workers who left
work, and for operating machinery, was the the company do not necessarily leave their
ߔrst claim that the representatives of different ߔeld of expertise. Educating the employers
factories made during the KII. A machine and workers regarding the character, scope,
operating guide, speciߔcally focusing on the importance, and needs of industrial safety,
machines used in plastic industries, should sometimes with joint initiatives from the
be available in the factory when the industries government bodies, would prove helpful to
proceed to register their company. decrease the risk of injury and accidents.
iii. Financial Assistance towards Investment viii. Strengthening the Trade Bodies: With the
in Safety: Since factory owners need to constant increase of establishments/factories,
invest in the overall safety and security of all it would be difߔcult for public institutions to
concerned in the workplaces regardless of single-handedly ensure occupational safety
their sizes, factories that lack the affordability followed by proper compliance. In this case,
to invest in safety ought to be covered under trade bodies and associations can be effective
a loan scheme with the provision of a longer in the primary and ߔeld-level screening for OSH
period of repayment.

Page | 18
 Industrial Safety in the Plastic Sector

compliances. If they are responsible enough x. Further Survey and Analysis: While the
during the ߔrst stage of screening to register study thoroughly covered existing laws, rules,
their organisation as part of government and policies on OSH, the current scenario of
monitoring and accountability compliance, it the plastic sector containing various ߔndings
would lessen the non-compliance aspect and were depicted solely on the basis of KIIs and
make it more efߔcient to keep all the factories in consideration of some documents; but,
under the radar. extensive review of relevant facts, ߔgures
ix. Proper Monitoring and Inspection with and aspects relating to the issue in hand,
better Transparency: According to the viz., industrial safety and work-related issues
factory owners, some factories get inspections could not be undertaken as such due to
regularly done in a repeated way, while others time and budget constraints. While the KIIs
do not seem to have any contact with the with management, owner, and association
inspector after acquiring the licence. Some of level representatives provided a broader
them contact FSCD for ߔre safety training, but perspective, there is still a need to assess
the owners who are unwilling to invest money the micro-level scenario through a nationally
and spend time in occupational health and representative survey from both management
safety can easily get away without arranging and workers points of view. Hence, further
such trainings. Proper monitoring and regular survey and analysis on the subject-matter
inspection with required transparency on the need to be attempted in near future for the
issue is likely to involve all the factory owners sake of proper scenario of the plastic sector.
in the process.

Page | 19
Bibliography

Bangladesh Bureau of Statistics. (n.d.). Survey of manufacturing industries preliminary

ߓQGLQJV 0D\. https://bbs.portal.gov.bd/sites/default/ߔles/ߔles/bbs.portal.gov.bd/
page/745673c8_c7ed_49bc_a4e2_e7b05fe7a9d4/Preliminaryper cent20Findings.pdf

Bangladesh plastics aim at global market pie. (2021, September 11). The Business
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pie-301183.

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and civil defence. http://www.ߔreservice.gov.bd/sites/default/ߔles/ߔles/ߔreservice.portal.
gov.bd/files/5610afd7_2775_4e4f_9ab8_392d42764ace/Requestper cent20forper
cent20informationper cent20form.pdf

International Labour Organization. (2021). 1DWLRQDO SURߓOH RQ RFFXSDWLRQDO VDIHW\

and health in Bangladesh 2019. https://www.ilo.org/dhaka/Whatwedo/Publications/
WCMS_819727/lang--en/index.htm

International Trade Centre. (n.d.). Trade map — Trade statistics for international business
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Moazzem,K.G., & Sehrin,F. (2015, January 27). Export-oriented plastic industry of

Bangladesh. The Financial Express. https://cpd.org.bd/export-oriented-plastic-industry-
bangladesh-khondaker-golam-moazzem-farzana-sehrin-cpd/.

Page | 20
 A recent industrial accident in Bangladesh highlighted the urgent
need for improved safety measures in non-RMG factories. Failure to
address this issue could result in more casualties and risk the
country's reputation as an industrial hub. Non-RMG factories in
Bangladesh have poorer safety standards compared to the RMG
sector, and fire incidents with rising casualties are becoming
increasingly common. Undertaking remedial measures in these
factories is difficult due to the lack of compliance standards and
stakeholder pressure. This study aims to identify the state of
progress of industrial safety in plastic factories and establishments
in Bangladesh, review policies and laws related to safety concerns,
and provide recommendations for improving workplace safety and
security. The study examines OSH-related issues, including fire and
electrical issues, from the perspective of structural safety. It also
identifies regulatory challenges in ensuring compliance. Primary
data was gathered through interviews with key stakeholders,
providing insights into workplace safety and worker-related
compliances. The study recommends maintaining transparency,
accountability, and efficiency in public and private sector initiatives
to improve industrial safety. It emphasises the need for compliance
standards and stakeholder pressure to drive change and reduce the
risk of future industrial accidents.

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Centre for Policy Dialogue (CPD)

House 40/C, Road No 11 (new), Dhanmondi, Dhaka – 1209, Bangladesh
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