ToxicsWatch, Journal of Earth, Science, Economy and Justice

To

Chairman

Central Pollution Control Board 

Union Ministry of Environment, Forests & Climate Change

Government of  India

Chairman

Andhra Pradesh Pollution Control Board

Government of Andhra Pradesh 

Date:07, 2020

Subject- Styrene Gas Leak Disaster in the factory of South Korean company LG Chem's subsidiary LG Polymers India Private Limited located at Gopalapatnam, Visakhapatnam

Sir, 

With reference to the above mentioned subject, I wish to draw your attention towards the fact that under the Manufacture, Storage and Import of Hazardous Chemical Rules, 1989 and Chemical Accidents (Emergency Planning, Preparedness and Response) Rules, 1996 farmed as per Environment (Protection) Act, 1986 it is the "occupier" who is responsible for preparation of on-site emergency plan as per Rule 13, Schedule 11 of 1989 Rules. The duty of ensuring compliance with this provision is required to be fulfilled by CPCB or SPCB as per it's Schedule 5. 

I submit that as per Rule 13 (3), this on-site emergency plan is required to be prepared before the industrial activity commences. The "occupier", the person who has control over the affairs of the factory or the premises and the person who is in possession of the substance as per 2(f) of 1986 Act is supposed to ensure that a mock drill of the on-site emergency plan is concluded every six months. 

I submit that given the fact that Part II of Schedule I, item no. 583 of the 1989 Rules includes "Styrene", an organic compound in the list of hazardous chemicals under Rule 4( 2), the occupier is required to provide evidence that he has identified the major accident hazards and has taken adequate steps to prevent such major accidents and to limit their consequences to persons and environment besides providing information, training and equipment including antidotes necessary to persons working on the site. 

The disaster in the factory of LG Chem's subsidiary demonstrates that these provisions of the rules have not been complied with. There has been dereluction of duty on the part of both the occupier and the concerned officials of the Pollution Control Board. 

Both the occupier and the officials have failed to give required attention to the hazardous and carcinogenic nature of 

Styrene. It is a "known carcinogen", especially in case of eye contact, but also in case of skin contact, of ingestion and of inhalation. Styrene is largely metabolized into styrene oxide in humans. Styrene oxide is considered toxic, mutagenic, and possibly carcinogenic.The USA's Environmental Protection Agency (EPA) has described styrene to be "a suspected toxin to the gastrointestinal tract, kidney, and respiratory system, among others". The precautionary principle too required abundant caution from both the occupier and the officials. 

In view of the non-compliance with the environmental laws, injury and loss of lives, ToxicsWatch Alliance (TWA), a research and advocacy group demands that a high powered transdisplinary committee be set up to inquire into the causes and effects of this industrial disaster and to fix accountability for the acts of ommission and commission in the matter of 7th May 2020 gas leak disaster from the factory of LG Chem's  LG Polymers India Private Limited. 

Thanking You 

Warm Regards

Gopal Krishna

Director

ToxicsWatch Alliance (TWA)

Mb:9818089660

Web:www.toxicswatch.org