INTRODUCTION

INTRODUCTION: From time immemorial Leather' sector have always been a part of heritage and after the emergence of an independent Bangladesh in 1971; the industry received a fresh impetus. Today the country earns a sizeable amount of foreign exchange every year through export of leather, footwear and leather products to the overseas market. The leather industry of Bangladesh has been given particular attention for developing its infrastructure. By combining the latest technology with abundant raw materials and inexpensive skilled labor, leather, footwear and leather products are now playing an important role in earning foreign exchange for the country.

But

recently

some countries

have

imposed

some restriction for importing leather

from developing countries like Bangladesh. They want to see that, the companies of developing countries are following various compliances like environmental, Safety, Social and chemical etc, according to the rules and regulation of the countries.

It may impact the leather trade of our country to world market. So we should know various compliances to fulfill the buyers satisfaction for increasing the export of leather.

PART-1 Chapter-1

Compliance

1.1 Introductions:
Compliance is the totality of rules, regulation operating in a working place of which an employer and an employee are bound to obey; some of them are either mandatory or directory. The notion of compliance is to ensure the security of life of a worker, to keep environment workable and to prefect the environment from pollution. 1 D itio o C m lia ce .2 efin n f o p n Compliance in a regulatory context is a prevalent business concern, perhaps because of an ever-increasing number of regulations and a widespread lack of understanding about what is required for a company to comply with new legislation. Compliance normally consists of ensuring that activities undertaken agree with both the letter and the spirit of the standards, laws and /or regulations that govern a business or activity and the internal policies and procedures set down by that business for its own activities. Enforcing compliance means ensuring that the business adheres to the regulations stated. In data storage terminology, the word compliance is used to refer to industry-wide government regulations and rules that cite how data is managed and the need for organizations to comply with those regulations. The term encompasses data storage, data archiving, data encryption, and also data retrieval. Compliance has become a major concern for organizations and businesses, due largely in part to increasing regulatory requirements which often require organizations to invest in new technologies in order to address compliance issue. 1.3 D itio o R u to C m lia ce efin n f eg la ry o p n In general, compliance means conforming to a rule, such as a specification, policy, standard or law. Regulatory compliance describes the goal that corporations or public agencies aspire to in their efforts to ensure that personnel are aware of and take steps to comply with relevant laws and regulations. Due to the increasing number of regulations and need for operational transparency, organizations are increasingly adopting the use of consolidated and harmonized sets of compliance

controls. This approach is used to ensure that all necessary governance requirements can be met without the unnecessary duplication of effort and activity from resources. Regulatory compliance refers to systems or departments at corporations and public agencies to ensure that personnel are aware of and take steps to comply with relevant laws and regulations. Compliance is conformation to the minimum applicable standard in a timely fashion. Compliance may include documenting processes, procedures, conditions, and changes. Compliance often requires planning and actions to maintain. It is easier to maintain compliance than to regain compliance. Finally, compliance is in the eye of the beholder. Compliance is a word defining the extent to which any entity or any part of it such as people, resources, processes...etc. is adhering to certain rules, policies and regulations governing its act and behavior and without which a certain risk might be imposed. In general, compliance means conforming to a specification, standard or law that has been clearly defined. 1 C ssifica no C m lia ce .4 la tio f o p n Compliance can be classified in the following way. 1. Ethical compliance describes the following subject: a. Wage b. Leave c. discharge d. Child care e. License etc

2. Environmental Compliance discuses various types of Environmental issue. 3. Safety Compliance discuses the followingsa. Operational b. Chemical c. Fire safety d. Electrical e. Occupational

1 C m lia ce M n g en S stem .5 o p n a a em t y A compliance management system is the structure by which a company manages their compliance issues so that they are not breaking the law. Regulatory compliance management refers to a standard of legal frameworks and codes that corporate entities should adhere to or be compliant with. Failure to do so can result in large financial penalties and even imprisonment in cases of deliberate fraudulent activity. Almost all companies and business have a compliance management team or compliance officer who monitors the business operations to ensure that no legal problems arise from their activities. Compliance management involves performing inspections of a business to make sure that all standardized rules and regulations are being met. The compliance officer may direct a business to make changes and give the business a timeline for implementing these changes that will better protect its workers. A compliance officer can also recommend that a business should cease its operations if it fails to comply with important regulations. Effective compliance management may involve being responsible for handling the complaints of employees who feel their health and safety could be compromised by a certain business practice. There are many laws that govern most organizations. An effective compliance management system can successfully navigate through the legalities of certain business practices and provide a business with ways to stay compliant with laws in order to avoid accidental non-compliance. Laws and regulations for businesses frequently undergo changes so a compliance management practices needs to stay updated. That way it can efficiently implement new compliance policy changes to reflect the new rules and regulations. Nowadays compliance software and technology is gaining

greater popularity in the corporate world. By utilizing compliance software, the process of monitoring important legal issues can be a automated process. In general, compliance means conforming to a specification, standard or law that has been clearly defined. 1.6 C m o en o p n ts o a g o co p n f od m lia ce p g m ro ra :

A good compliance program should include (but not necessarily be limited to): a code of ethical and professional conduct for firm employees and agents clearly delineated duties for COs, branch managers, administrative staff, and other employees and agents of the firm procedures for trade and employee supervision at the branch and head office levels requirements for registration, renewal and maintaining required proficiency levels procedures to ensure completeness of records and adequate trade and exception reporting procedures for suitability checks, which should include comparison of know-yourclient (KYC) forms to source documents an adequate training program procedures for handling complaints, including documentation and follow-up procedures for addressing conflicts of interest a complete catalogue of all required disclosures to clients In addition, for a compliance program to be effective, it must be designed to anticipate and prevent wrongdoing. Procedures should be written, regularly updated, and widely accessible to employees. Finally, a good compliance program must include evidence of review. COs may document their activities in periodic reports to the firms principals. If branch managers play a supervisory role, they should also be completing regular reports. In their reports, the CO or branch manager should specifically highlight issues or concerns that they have uncovered in the course of their compliance reviews, and should follow-up where appropriate. Any follow-up undertaken by the firms principals should also be documented.

Various Compliances

Chapter-2
ENVIRONMENTAL COMPLIANCE

2.1. Background:
People from all walks of life in different places of the country narrated their sufferings due to industrial pollution. The farmers & the fishermen are suffering the most as wastes & effluents from industrial units are dumped in croplands and water bodies. Instead, due to mismanagement inferior technology, lack of facilities for treating wastes, wrong approach towards industrialization and so forth, environment problems in the industry sector is concerning. The industries are highly concentrated around Dhaka. Many polluting industries, tanneries for example are located within the city. These industries discharge toxic chemicals like chromium and mercury directly into the river. There are 1176 units in the country that heavy pollute the environment. This was told in the Jatiya Sangshad, the Bangladesh legislature in July 2001. The concerned authorities have identified these industries units and legal procedures have been initiated against them. At the same time, a division bench of the High Court asked the concerned department to ensure pollution control measures in 903 industrial units that have been identified as polluters. The orders were served in July 2001. A long time has passed since these initiatives were taken.

2.2. Rules and Regulation

The environment protection Act (1995): Aims to protect the environment and to control and mitigate environmental pollution .It establishes the Department of Environment (DOE) under the Ministry of Environment and Forest (MOEF), headed by a director General. The act has been implementing by the Environment Conservation Rules (1997), according to which all new industries and projects must apply for an Environment Clearance Certificate (ECC).
The Environment court Act (2000) institutes an Environment Appeal Court and establishes enforcement powers and jurisdiction over environmental proceedings.

2.3. Environmental Clearance Certificate (ECC)

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The documents need to be submitted with the application for each category of industry or project include. Initial Environment Examination (IEE) Report includes. Effluent Treatment plan (EMP) No objection certificate Environment Impact Assessment (EIA) Report and Feasibility Report etc.

2.4. Industry specific Impact:

The most significant environmental impacts occur during the operational phases of the Textile Dyeing manufacturing. Tanneries and the Pharmaceuticals include the following:

Hazardous materials Waste water Effluents Emissions to air Energy and water use Production of Solid/ Liquid waste Noise pollution

2.5. First Aid:

There should always be at least one number of staff on each shift that is trained First Aid and who is made responsible for all first aid requirements during their shift. At least one first aid box should be made available in an area that is accessible to all the workers. The box should be clearly marked and include some basic materials such as Liquid antiseptic, Band aid, sterile gauze, sterile cotton pain killers. The first aid box should be properly maintained by a nominated person and checked regularly.

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2.6. Safety Protocol: 2.6. a. Laboratory Safety protocol

Record keeping (all the chemicals, dyes, and other auxiliaries). Protective gear (gloves, safety glasses, masks, wearing of laboratory coat). Training (use of machinery, laboratory equipment, the use of dyes and chemicals, handling of solvents, and other harmful chemicals, dealing with the accidental spills, contact with skin and eye, and ingestion of chemicals)

2.6. b. Factory Floor Safety Protocol:

Protective gear Environment (Exit passageway and stair cases. Emergency exit, proper lighting and ventilation/ air circulation, cleaning, disposal of hazardous wastes according to the manufacturers, guidelines ad national policies). Training (use and maintenance of machinery and other equipment, health and safety, electrical safety, fire hazards and emergency). Lifting and carrying Heavy objects.

2.7. Responsibility:
The management Commitment The senior management and all other levels of management and supervision must indicate a commitment to safety by Being seen as placing as high priority on safety as on productivity, cost and quality. Encouraging discussion on safety issues and demonstrating a commitment to participate in resolving problems. Setting an example by following all procedures, such as the wearing of car defenders in a car protection zone. Leading safety tours ad chaining safety committees.

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2.8. Co-operation- encourage participation consultation

The recent minutes of the safety committee meeting must show that the following are discussed: Accidents Progress following previous meeting Safety audits New safety information from HSE or industry associations Reports from safety representatives Works rules, Safe systems of work, Safety training Workplace safety publicity and target setting and performance. Communication to make sure that people know what they need to The Health and Safety Law what you should Know poster should be displayed prominently. The safety signs should be displayed where necessary to make employees aware relevant safety and health hazards and preventive measure. The employees should report hazards and concerns immediately. The employees should be aware of consultation arrangements. A requirement of the health and safety (Safety Signs and Signals) Regulations 1996. A sign may take the from of a signboard, safety color, illuminated sign, acoustic signal, verbal communication or hard signal. There are two types of sign, permanent and occasional: Permanent signs must be used for signs relating to prohibitions, warning and mandatory requirements and the location and identification of emergency escape routes and first aid facilities. Meaning or safety of purpose colors:
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Red: Prohibition, danger alarm, fire-fighting equipment.

2.9. How to control general risks:

Noise control procedure Use of hank knives Control of flammable substances ad process fire precautions Personal protective Equipment (PPE) Falls from height Slips and Trips Work place transport Emergency response Control of contractors and visitors Shared premises Arrangement

2.10. Role of Factory staff:

Each employee should Be aware of the contents of MSDS and of potential H & H hazards. Follow all protocol in the safe handling ad disposal of dye and chemicals Be aware of the fire protocol Wash hands before meals and should not have the meals in the work area.
Maintain correct posture when lifting or carrying heavy objects

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2.11. Health Safety Environment Management system

2.11. a. Introduction:
The health, Safety and Environmental management systems have been developed to implement any organization Health, Safety, and Environmental Objectives Defined in the Organizations Health, Safety and Environmental Policy. HSE Management System

Continual Improvement

HSE Policy Management review

Planning

Checking & corrective action

Implementation & Operation

HSE Management System 1. HSE Policy 2. Planning 2.1 Planning for Hazard Identification risk analysis and control. 2.2 Legal and other Requirements 2.3 Objectives 2.4 HSE Management and Awareness programs 3. Implementation and Operation 3.1 Structure and Responsibility
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3.2 Training, Awareness and competence. 3.3 Consultation and Communication 3.4 Documentation 3.5 Documents and data collection 3.6 Operational control 3.7 Emergency preparedness and response 4. Checking and Corrective Action 4.1 Performance Measurement and Monitoring 4.2 Accidents, incidents, non-conformances, corrective and preventive action 4.3 Records and record management. 4.4 Audit 5. Management Review 5.1 Management Review

2.11. b. HSE POLICY: Policy Statement

Organization is committed to performing its work in the safest Practicable manner consistent with good industry practices, to protect the health of its employees and contractors while minimizing any adverse impact on the community or the Environment from its operations.

Management Responsibilities:
We will manage our health, safety and environment risks with Equal ranking as our other co-operate objectives. We will make personnel aware that health, safety and Environmental management responsibility. We will ensure that all specific responsibilities identified in the Health, safety and environmental management systems are clearly assigned.

2.11. c. Reduction of Health, Safety and Environmental Risk:

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We will take full account of health & Safety and environmental risks in all aspect or our operations. This includes design, construction and installation of facilities as well as operation of process plants and well activities such as drilling and work-overs. We will take into account health and safety and environmental performance when selecting contractors and equipment and material supplies. We will implement and maintain procedures to minimize the risk of accidental spillages and emissions and we will maintain appropriate emergency response and clean-up plants in case of accident.

2.12. ENVIRONMENTAL REQUIREMENTS AND MARKET ACCESS: 2.12. a. INTRODUCTION:

Environmental and health requirements are becoming more frequent and more stringent in certain sectors of export interest to developing countries. In the context of an increasingly globalize world economy and liberalization of international trade, creating awareness and understanding of environmental and health requirements in international markets and enhancing the ability of developing countries to address market access issues and the need to comply with market requirements is of growing importance. It is also important to enhance understanding of and address developing countries' concerns in the area of environmental requirements and health standards, in particular sanitary and phytosanitary (SPS) measures.

2.12. b. ENVIRONMENTAL REQUIREMENTS AND STANDARDS:

Environmental and health-related requirements may take various forms, of which the following: Direct regulatory instruments SPS measures Labeling Financial and economic instruments Public procurement
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 Informal requirements

A. Direct regulatory instruments:

1. Product standards, which are legally binding, can relate to the composition of products (e.g. heavy metals content), their quality (e.g. longevity) and their performance (e.g.: energy consumption, emissions). 2. Bans on environmental grounds arc becoming increasingly frequent due to the widespread public concern over hazardous substances and because it may sometimes be easier to legislate bans than technical standards involving complex risk assessment. 3. Bans on substances that are hazardous to the environment or public health may affect trade in products containing such substances. Such bans are emerging in sectors of export interest to developing countries, such as textiles, leather and footwear. For example, in Germany, products containing pentachlorophenol (PCP) have been banned for several years, and the use of hazardous substances, such as dioxin and formaldehyde, has been restricted, affecting leather exports from developing countries. Azo dyes have also been prohibited. These are coloring agents used in leather and textile industry, particularly in developing countries. They are considered carcinogenic and are prohibited for use in textile and leather clothing in Germany. 4. Bans of products containing hazardous substances are aimed at protecting the domestic environment and public health in the importing country against the harmful effects of the consumption or disposal of domestically manufactured and imported products. WTO rules allow countries to impose bans as long as such bans apply equally to domestic products. 5. Among the problems reported by UNCTAD's country case studies in complying with .environmental product regulations are the costs and difficulties of testing and verification procedures; the perceived lack of scientific data for specific thresholds or limit values; and the uncertainty arising from rapidly changing requirements in overseas markets. 6. Take back obligations require producers and/or retailers to take back and reuse or dispose of used products and packaging. Take-back obligations exist concerning products such as waste oil, cars, batteries, cans, and consumer electronics. 7. Take-back obligations are aimed at encouraging reuse and recycling, and the costs involved may induce more environmentally conscious product development. Take back obligations
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involve an extended producer responsibility for the product, in particular for its reclaiming, recycling and final disposal. 8. Take-back obligations apply to both domestically produced and imported products and may have impacts on international trade. In practice, the importer rather than the foreign producer is held responsible for compliance with the law, and service companies can be used to take care of recycling. 9. Trade effects may arise when importers or foreign producers face administrative and procedural problems in discharging their legal responsibilities or when the associated costs have significant effects on the competitiveness of imported products. In addition, take-back obligations could affect the competitiveness of specific materials which in many aspects are environment friendly but difficult to recycle in the importing country, such as materials that are not commonly used in the importing country.

B. Labeling:
10. Producers and consumers may need information to assist them in their efforts to reduce environmental impacts. Labeling may be compulsory or voluntary. Such labels provide information related to inter alias health and environmental ingredients, use, and/or disposal of products. The need to provide such information may imply additional costs. Conversely, it may increase awareness and may induce producers to improve the environmental quality of a product for reasons of competitiveness. 11. Compulsory labels generally give environment-related information on one aspect of a product and are normally required by the government. These labels may constitute negative warnings such as "flammable" and "eco-toxic" or indicate positive environmental characteristics such as "biodegradable". 12. The International Standards Organization (ISO) has classified voluntary environmental labels under three types: Type I are multi-issue voluntary labels. These labels give environment-related information on the overall environmental quality or characteristics of a product. Eco-labeling programs are generally government-supported, third party certification programs. They are voluntary systems since manufacturers have the choice of whether or not to apply for an eco-label.
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 Type II environmental labels are informative self-declaration environmental claims made by manufacturers, importers, distributors or retailers. Type labels provide information on a product in the form of a bar graph of various indices, without any judgment about their relative importance. Without weighing of different environmental attributes, such schemes leave it up to the consumer to decide which products are environmentally preferable. 13. The trade and environment debate on eco-labels has focused on type I eco-labels. This indicates the challenges that arise when product standards take into account the processes and production methods (PPMs) of a product. The WTO rules, based on the concept of like product, is not clear as to whether or not products may be distinguished based on their PPMs. WTO rules have generally been interpreted as not providing the opportunity to differentiate products based on their PPMs unless these have an impact on the final characteristics of the product. 14. Concerns have been raised by developing countries that eco-labels developed for products of export interest to them, may discriminate against foreign products if they take into account the PPMs. The criteria for the objection of the eco-label may address issues of concern to importing countries without taking into consideration differences in local conditions and preferences of the producing country. So far, the effects of type I environmental labels on the market place and in international trade have been limited, including for imports from developing countries.

C. Financial instruments:
Product taxes and changes: (e.g. taxation of energy consumption) 15. Product taxes and charges can be based on some characteristics of the product (e.g. on the sulphure content in mineral oil) or on the product itself (e.g. mineral oil). Product charges maybe imposed with two aims: (a) To raise revenues; (b) To discourage the production and consumption of products on which the tax is levied. 16. According to the WTO rules, a country can not impose a higher tax on an imported product than on a domestic product. However, different tax rates can be levied on products that are not considered "like products". From an environmental point of view, it maybe desirable to

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differentiate products based on their environmental attributes. From a trade point of view, the question is whether such differentiation can serve protectionist purposes.

D. Public procurement:
17. Public procurement practices could have effects on producers from developing countries if products of significant export interest to them were to be affected.

E. Informal requirements based on consumer demand

18. Due to increased consumer demand for environmentally preferable products, importers may impose certain environmental requirements upon their suppliers in developing countries. For example, they can require that their suppliers meet the criteria to obtain an eco-label

2.12.c. WTO RULES A. General rules

1. Basic principles 19. The Most Favored Nation principle should be respected and on this basis there should be no discrimination between like products of different Member countries. The same regulations should apply to all countries. 20. On the basis of the National Treatment principle, imported products must be accorded a treatment no less favorable than like domestic products. 21. like products. The interpretation of like products and the treatment of processes or production methods (PPMs) remains an essential issue of the trade and environment debate. WTO rules have generally been interpreted as not providing the opportunity to differentiate products based on their processes or production methods (PPMs), unless the PPM has an impact on the final characteristics of a product. For instance, a country can impose restrictions on pesticide use during agricultural production if the final product contains pesticide residues that are deemed harmful to the consumer in the importing country. Two products will be considered as like products if the final characteristics of the product are the same although their PPM maybe different. Therefore, it

21

is generally considered that WTO rules do not permit WTO Members to impose restrictions on imports of a product purely on the basis of how the product is produced . B. Relevant WTO Agreements 22. Two WTO agreements deal with the effects of environmental requirements and standards on international trade: The Agreement on Sanitary and Phytosanitary measures and The Agreement on Technical Barriers to Trade. 23. The SPS agreement applies to measures taken for the protection of human, animal and plant life and the non transmission of diseases. The TBT Agreement is meant to ensure that technical regulations, standards and conformity assessment procedures do not create unnecessary obstacles to trade.

The WTO Agreement on Technical Barriers to Trade

25. Environmental regulations and standards address the characteristics of a product, such as quality, performance and safety as well as requirements regarding packaging or labeling. The TBT Agreement makes a distinction between mandatory and voluntary standards. 26. The TBT Agreement encourages countries to adopt existing international standards. It is generally recognized that international standards contribute to a greater efficiency in international trade and avoids obstacles to trade.

International standards
27. Both the SPS and the TBT agreements have recognized the importance of harmonizing standards internationally. Standards apply to all types of products and at all stages of production. In response to the proliferation of different national standards that may affect trade, harmonization using international standards is essential to facilitate international trade. 28. For the private sector, it is both easier and less costly to conform to the same standard in all export markets than to comply with different standards depending on the country. However,

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harmonization of standards does not take into account geographical differences and local preferences. .

2.12. d. TRADE IMPLICATIONS FOR DEVELOPING COUNTRIES

32. Environmental requirements and standards do no affect all economic sectors and products in the same manner, . Developing, countries are concerned about the potential impact of environmental requirements and standards on products of export interest to them. Developing country exports arc generally concentrated in a small number of sectors and products. Developing countries are particularly concerned about the environmental requirements and standards which apply to: textiles and clothing, leather and leather products, footwear, forestry products such as timber, furniture and paper, and food products, such as fish. As these sectors account for a significant share of total exports, and an even larger share of manufacturing exports of developing countries, environmental policies could potentially affect export competitiveness and export promotion strategies.

A. An illustration of important leather sector:

33. The leather and footwear industry has also been affected by bans or limitations in the use of certain hazardous materials such as azo dyes, PCP, cadmium, polychlorinated biphenyls (PCB) and tetraphenyles (PCT). In Germany, for example, products containing pentachlorophenol (PCP) have been banned for several years, and the use of hazardous substances, such as dioxin and formaldehyde, has been restricted, affecting leather exports from developing countries. Example of China: The PCP content in Chinese leather has been considered too high in several European countries. Since a large share of leather products go to OECD countries the limits on the use of PCP in leather can affect Chinese exports of this product. Leather exports are also potentially affected by regulations regarding dyestuffs. Concern is linked to the fact that compliance costs with external environment PPM related regulations are likely to increase and impact on competitiveness since most exports from China tend to compete in the OECD market largely on account of their low prices.

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Example of India
34. According to a case study carried out in 1995, several environments related regulations affected India's performance on the international market. Germany has banned the use of PCP and in the EU the threshold was of 1000 ppm. The use of formaldehyde has also been limited in Germany. As the uses of chemicals which are preferable to the environment have become mandatory, this has restricted the process by which leather may be manufactured. At the time the case study was carried out, most tanneries were resorting to the use of an imported substitute, BUSAN 30, which is acceptable to the external market. The price of this substitute is deemed on average to be ten times higher than the price of PCP. All chemical inputs together accounted for approximately 10 per cent of costs and was considered likely to affect the competitiveness of leather products. The costs of compliance with external requirements were considered hard to estimate but it was felt that the cost of the tests alone could increase the price of shoes by $3-$4 per pair. Overall, exporters stated that the cost of replacing all chemicals with environmentally preferable ones raised total costs by 10 to 15 per cent. These costs were considered particularly onerous for SMEs that represent 70 per cent of the total leather exports from India.

2.12. e. CHALLENCES FACED AND POSSIBLE SOLUTIONS A. Constraint

35. Market access is a key issue for developing countries. Developing countries have been concerned that domestic environmental policies in the developed countries may deny market access to products from developing countries. This is because producers in developing countries may lack the technical and financial ability to comply with the environmental regulations of the industrialized nations 36. In practice, the potential impacts of environmental and health requirements on exports of developing countries vary from case to case. Several factors may have a bearing on the trade effects of environmental policies, of which the following: The

Destination of exports: Greater trade effects are to be expected when export product are directed
towards countries imposing stringent environmental regulations; The basis for export competitiveness: Export competitiveness based on low prices may be affected by the need to comply with environmental requirements;
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 Firm size: SMEs may find it particularly difficult to comply with environmental requirements; Availability of raw materials, specialized inputs, technology and information facilitates compliance; Corporate structure: Companies which are vertically integrated and can exercise sonic control over their suppliers will have a greater ability to control the environmental quality of their product throughout the whole life cycle; Relationship with foreign firms: Strong links with foreign firms can facilitate compliance by, for instance, increasing access to and transfer of environmentally sound technologies. 37. Whereas such points have to be taken into account in examining specific cases, there are several constraints of general concern to developing countries, some of which are highlighted below. 38. Information: Lack of accurate and timely information on emerging environmental policy instruments may have unintended adverse effects on developing countries. In the area of waste management, for example, packaging requirements have created uncertainty, in particular with regard to the type of packaging materials that will be acceptable to importers. Exporters have at times incurred costs, delayed decisions, or shifted to other materials because of lack of sufficient information 'regarding requirements in importing countries. 39. Transparenc y: Lack of transparency may create significant problems for exporters, in particular since some emerging environmental policy instruments do not have provisions regarding notification and established mechanisms allowing foreign producers to comment. The strong reliance on voluntary measures may raise questions as to accountability to international trade rules. While voluntary product standards are indeed covered by the TBT Agreement, in some aspects they may be subject to less rigorous rules and procedures than arc mandatory regulations. 40. Testing and verification: The problems of developing country exporters faced with standards and regulations can be the costs and difficulties of testing and verification procedures, the perceived lack of scientific data for specific thresholds or limit values, and the uncertainty arising from changing requirements in overseas markets. : 41. International standards: Many international standards developed without effective participation of developing countries. Fear that international standards may not be taken into consideration and therefore be appropriate to the production structure in developing countries.

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Materials and processes generally used in developing countries may not be taken into consideration in formulating international standards that may disadvantage developing countries B. How to address these difficulties?

General appraisal
42. In order to reduce the likelihood that environmental requirements and standards will restrict trade, a number of policy measures can be considered as mentioned above, including: The harmonization of product standards; The recognition by importing countries of tests, verification and certification conducted in exporting countries; Access to information and transparency; Facilitating the access to and transfer of technology; Financial and technical assistance; Due implementation of measures on special and differential treatment included in the SPS and 43. At the national level, in the exporting country, Government and the business sector can adopt policies and measures aimed at promoting standards and quality with a view to enhancing trade performance. These include: establishing and/or improving supporting infrastructure and human capabilities; Dissemination of information; promoting cooperation between the Government and the business community; promoting cooperation between retailers/importers and producers/exporters. 44. A number of issues should also be considered at the bilateral or multilateral level with trading partners, including in relevant international fora such as the WTO: Capacity constraints requiring technical and technological solutions may not be overcome only by efforts of the Government. International cooperation may be necessary in this area. The reviews of TBT and SPS agreement should factor these constraints into the recommendations for changes or special and differential treatment. Capacity building is also necessary to overcome market diversion or distress sales. The exporters need to be advised to shed their fears of market loss and report distress sales to the Government so that environment and health related requirements could be analyzed for possible disguised protectionism.
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TBT agreements,

 The enquiry points for TBT and SPS Agreements need to create institutional support for the dissemination of drafts standards notified in the WTO to exporters and to get their feedback for sending comments to Governments abroad.

2.12. f. CONCLUSION
45. Overall, there is no empirical evidence to suggest that existing environmental policies have widespread effects on market access. However, effects could be more significant for some sectors and for SMEs. Environmental policies may have differentiated competitiveness effects on developed and developing countries. In most cases, however, competitiveness effects of environmental policies can be addressed by appropriate policies at the national, regional and international levels.

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CHAPTER 3
SOCIAL COMPLIANCE

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Social Compliance initiatives in Bangladesh

3.1. Social Compliance forum at a glance

3.1. a. Functions of Social Compliance forum

To review existing policies on social compliances especially occupational safety and workforce welfare aspects and to provide guidelines for necessary policy reforms. To provide necessary guidance to issue-specific taskforce, compliance Monitoring cell (CMC) and relevant. Ministries/departments/ stakeholders on compliance standards (benchmarks). To organize capacity enhancement measures/ programs for / through focal points created at relevant ministries/ departments SCF to meet at least once in every 3 months Forum may co-opt any number of members.

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3.1. b. Functions of the Taskforce on Labor Welfare

To collect and compile relevant rules & regulations on labor welfare such as working hours, maternity leave, weekly holiday, minimum wages fixation, provided fund, etc. for the preparation of work plan.

Based on the guidance received from the social Compliance Forum, to prepare work plan for short, medium and long term activities.

To communicate the activities of the work plan to the relevant ministries/ department/ Organization/ Association for implementation.

To monitor and report the progress of the work plan to the forum through CMC, and Any activities assigned by the forum.

3.1. c. Functions of the Taskforce on Occupational Safety To collect and compile relevant rules & regulations on occupational safety such as building safety, fire prevention, environment, security matters etc. for preparation of the work plan. Based on the guidance received from the social compliance Forum to prepare work plan for short, medium and long term activities. To communicate the activities of the work plan to the relevant

ministries/department/organization/association for implementation. To monitor and report the progress of the work plan to the Forum through CMC.

3.1. d. Functions of CMC Provide secretarial support to the SCF and the taskforce on compliance issues. Review the reports received from the taskforces and report to the SCF. Keep regular contacts with the international buyer groups on compliance issues. Raise awareness on social compliance among those involved in Leather Goods production and export process. Recommended EPB and MOC on activities undertaken on compliance for building images abroad.
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Seek consultant and gather information from related ministries/departments/stakeholders including international buyers on compliance and safety related issued/ aspects. Create database on industry and Other activities assigned by the forum.

3.2. Workers' rights and working conditions in the export-oriented industry:

Workers' rights encompass rights of persons both as human beings and as workers. According to the 1948 declaration of the United Nations I, human rights are basic natural rights, which are inalienable' and belong to all humans. Such rights are necessary for freedom and the maintenance of a reasonable quality of life. Workers' rights include these human rights and at the same time some additional rights, which are necessary to ensure a safe, secured and dignified work-life. Moreover, there are some provisions that are not imperative for such a work-life but presence of those facilitates a better work-life. All these rights of workers have earned different degrees of attention in international and national laws and policies. In the era of globalization, the imperative to address workers' rights, especially in export sectors, comes from two different forces working in opposition. On the one hand, the pressure of global competition induces entrepreneurs to lower product price as far as possible, causing them to cut the `real' wage of the workers, which, in most cases, means violation of workers' rights in some form. On the other hand, unwillingness of the developed country markets to accept goods produced without adequate protection of workers' rights compels the entrepreneurs to take measures to protect workers' rights, which often get translated into higher Cost of production. As a result of such conflicting natures of motivation behind addressing workers' rights, countries differ in addressing rights. Moreover, the gender division of labor associates additional dimension in addressing workers' rights. Often female workers' rights are violated n1pqopltheir male counterparts; nature of labor relationship takes a different form in case of females because of their dual role in workplace and in the reproductive; economy (domestic work). Thus the issues related to rights of workers are complex and deserves proper analysis.

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3.2. a. Labor rights and legislation: A gendered approach

In Bangladesh, as elsewhere, labor market institutions are constructed from and operate within a gendered economy and reflect socially derived gender division of labor. In nonagricultural manufacturing employment generally male workers are concentrated in permanent paid market work in the formal sector, i.e. operating through formal labor relations, while female workers are largely engaged in paid work through informal labor relationship, moving flexibly between the productive and reproductive economies (unpaid domestic work, care giving work) and seen as secondary workers. The employment of the female workforce in the export garment sector is a good example of this gender divide. In the manufacturing sector, labor relations are premised upon this model of permanent formal employment for males and flexible informal and temporary employment for females.

3.2. b. International labor standards and national labor laws:

The International Labor Origination (ILO) is the prime body formulating international regulations on labor rights. These regulations, known either as ILO Conventions or ILO Recommendations, are the tools used to help nations improve the conditions of labor in their own countries; Conventions are international treaties which are binding on the countries which ratify them voluntarily. Recommendations are non-binding guidelines for national policy and practice. These are not international treaties. These may encompass a particular subject or clarify the provisions in the conventions. Both conventions and recommendations are intended to have a concrete impact on working conditions and practices in every country of the world. Together, they are referred to as the ILO International Labor Standards (Cairola and Chiarabini, 1998).

3.2. c. Laws to protect fundamental rights

In Bangladesh, the fundamental human rights of workers, as covered by the core ILO labor standards, have been addressed by national labor laws and regulations relating to formal employment. The core conventions of ILO cover eight fundamental human rights in the work place. These are freedom of association and the right to collective bargaining (Conventions 87 and 98), freedom from forced labor (Conventions 29 and 105), freedom from discrimination
32

(Conventions 100 and 11I), freedom of children from child labor (Conventions 138 and 182). These core conventions are elaborated below.

3.2. d. Freedom of association and the right to collective bargaining

The right to form unions is basic to industrial relations, as it enables a channel for negotiations between workers and employers. According to the ILO Convention 87, workers and employers have the right to establish and to join organizations of their own choosing without previous authorization. But they have to follow the rules of the organization concerned. Convention 98 also provides the right for collective bargaining. This convention calls for the right of receiving adequate protection against any acts of interference by the other party (employer or worker) in establishment, functioning or administration of an association. The Industrial Relations Ordinance of 1969 states the right to form association. The Bangladesh Constitution also guarantees freedom of association, the right to join unions, and, with government approval, the right to form a union. With the exception of workers in the railway, postal, telegraph, and telephone sectors, government civil servants are forbidden to join unions. The ban also applies to security-related government employees, such as in the military and police. The workers of export processing zones (EPZs) were not also allowed to form unions. Later the Industrial Relations Bill 2004 has allowed limited trade unionism in EPZs from November l, 2006. The law has made it mandatory to obtain permission of owners before forming trade unions in the EPZs.

3.2. e. Freedom from forced labor

Forced labor is prohibited under ILO Conventions 29 and 105. There are exceptions depending on the nature of work. For example, forcing would be possible in case of some emergency or national crisis etc. Countries ratifying this convention are supposed to take effective measures to secure the immediate and complete abolition of forced or compulsory labor.

3.2. f. Freedom from discrimination

ILO Convention 100 calls for equal remuneration and Convention 1I1 forbids discrimination in treatments of facilities among workers of equal qualifications. According to this convention, there should not be any gender difference in remuneration and treatments.

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However, any distinction, exclusion or preference in respect of a particular job based on the inherent requirements thereof shall not be considered as discrimination.
3.2. g. Freedom of children from child labor

Employing children for work is prevented under ILO Conventions 138 and 182. Any person of less than 15 years old is considered to be a child according to this Convention. However, an exception to this will be applied if a country's educational facilities are under-developed and in that case the minimum age for work should be 14. In case of health hazardous works the minimum age should have to be 18. Employing children in such work is termed as worst form of child labor Persons of 13 to 15 years old can only be employed for light work. Bangladesh has law that prohibits labor by children. The Factory Act 1965 bars children under the age of 14 from working in factories. This law also stipulates that young workers (i.e. children and adolescents) are only allowed to work a maximum of 5-hours a day and only between the hours of 7 a.m. and 7 p.m. The penalty for violation of this Act is a fine up to Tk 1000. The Employment of Children Act, 1938 (as amended in 1974) prohibits employment of children under 14 years in a factory. Other laws relating to child labor include the Shops and Establishments Act 1865 and the Children's Act 1974 and Children's Rules, 1976.Laws to protect formal rights. Formal rights of workers are the very basic rules of formal employment. Such rights ensure job security, regular wage payment, and appropriate working conditions.

3.2. h. Letter of appointment

The most important formal right of a worker is to have written contract of letter of appointment Whether or not other rights are established will depend upon the conditions laid down in the contract letter. Unfortunately no such law prevails in Bangladesh. The Factory Act 1965 has only specified that every factory shall maintain a register of workers and the workers should be supplied with identity cards and attendance tickets. The register should record information about every worker such as name, type of employment, nature of job etc. All types of workers i.e. permanent, temporary or casual, should receive tickets or cards. However such a ticket or card is not a good substitute of a letter of appointment in ensuring the security of the job.

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3.2. i. Working hours

Long work hours leave long run impact on the health and family life of workers, especially the females who have to perform lots of household responsibilities after their work in the factory. This is violation of their right to Decent Work as laid down by ILO in their Fundamental Principles and Right at Work ILO Convention I specifies that the working hours of persons employed in any public or private industrial undertaking shall not exceed eight in the day and forty eight in the week, though there are some exceptions. Also the Factory Act 1965 specifies forty-eight hours of work in a week. An adult worker may work for more than nine hours in a day or forty-eight hours in a week only in case of extra allowance for overtime. The overtime allowance should be at the rate of twice the ordinary salary of the worker. However the total hours of work of an adult worker shall not exceed sixty Fours in any week and on an average fifty-six hours per week in any year.

3.2. j. Weekly rest and occasional leave/holidays

The right to get weekly rest for industrial workers is addressed in the ILO Convention 14. It is specified that the whole of the staff employed in any industrial undertaking shall enjoy in every period of seven days a period of rest comprising at least twenty-four consecutive hours. Weekly rest is included both in The Factories Act, 1965 and The Factories Rules, 1979. According to the Factories Act 1965, there should be a full day holiday in every week. If an emergency occurs then there should be substitution for the regular prescribed day provided that no worker works for more than ten consecutive days. Though Bangladesh has not ratified the ILO Convention 52, which covers the right to receive occasional leave or holiday, the Factories Act, 1965 has notified the right o the workers annual leave with wages, festival holidays and casual leave and sick leave. The law sets a standard of 48-hour workweek with one mandated day off. A 60 hour workweek, inclusive of maximum 12 hours of overtime, is allowed. Every worker should be allowed at least 10 days festival holidays with wages in a year. The employer can decide on the dates of such holidays.

3.2. k. Minimum wages

Regulations regarding minimum wages, hours of wage vary depending on the type of occupation and industry. Minimum wage implies that workers receive adequate wages to meet basic needs for nutrition, medical care, hygienic living conditions, etc, for effective production.
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The right to a minimum wage is a fundamental formal right, recognized in the Factory Act 1965 as well as in the Bangladesh Constitution and in the ILO Conventions (though Bangladesh has not ratified the IL0 conventions 26, 99, 100 and 131 on this issue). The Ministry of Labor and Employment of the Government of Bangladesh has formed a Minimum Wage Commission.

3.2. l. Regular wage payment

According to the Factory Act 1995 all factories having less than 1000 workers must ensure that wages are paid regularly and by the seventh of each month. Laws to protect informal rights In addition to formal rights, labor laws also provide for some other rights, which facilitate and ensure the quality of their working life and relate to work conditions and security of employment. Work environment is important both for the comfort of workers and for maintaining efficiency and productivity.

3.2. m. Night work

For safety reasons, ILO convention 89 has prohibited the employment of female workers at nigh.4 Bangladesh has ratified this convention. Moreover, every employee should have enough time to take rest at right.

3.2. n. Addressing unusual incidents

To address unusual situation like sickness, invalidity, employment injury, unemployment, workers should get benefits from the employer. ILO Convention 19 requires equal treatment in receiving accidental compensation. There are several acts and rules in Bangladesh to provide the workers' compensation in case of accidents and other unusual events. These include the Workmen's Compensation Act, 1923, the Workmen's Compensation Rule, 1924, the Fatal Accident Act, 1955 and the Workmen's Protection Act, 1938. These regulations indicate various amount of compensation that could be received by workers or their families in case of work related accidental events.

3.2. o. Laws to protect rights related to reproductive activities:

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Rights related to the smooth management of work and family life of workers, especially reproductive activities, are also provided under the ILO conventions. These provisions include child care facilities during working hours, maternity benefits, and education facilities for the children of workers, etc.

3.3. Conclusion
Success story of the leading export industry of Bangladesh, is associated with the tireless efforts of thousands of workers who are considered to be very `cheap'. However, being a cheap' labor does not exclude a person from enjoying the basic rights of human life as well as rights as a worker. Four categories of rights are seen as essential for decent human life and work life. These were basic rights, formal rights, informal rights and the rights related to reproductive activities. Although Bangladesh has not ratified some important ILO conventions, in many cases existing national laws cover those rights. For example, Bangladesh has not yet ratified ILO conventions protecting the right of workers to receive minimum wage but there are national laws protecting this right. The next step was to look at the level of addressing the international and national labor laws in the export leather sector of Bangladesh. Notable gap between labor laws and level of implementing them has been identified. Such violation of rights not only hampers decent life of workers, but also poses threat to their life (factory fire etc.). Factories differ in addressing these rights. There are factories where rights are addressed quite reasonably. Still sometimes the absence of a law allows the employer not to address certain rights. For example, since there is no law in Bangladesh to give appointment letter to the workers, workers generally do not receive any appointment letters. An attempt to look to the nature of changes in the workers' rights issues shows that over time the situation has encountered some improvement but that is not enough. One notable achievement is the elimination of child labor from this industry.

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Chapter-4
SAFETY COMPLIIANCE

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4 B sic req irem t o sa .1 a u en f fety co p n m lia ce

According to the order of the govt. and fire service as well as civil defense which safety measurement should take those is 1. For electric fire on the floor of factory there should have carbon-di-oxide (main Switch, sub-main switches for distribution board its need per one) and other fire there should have DCP fire cooler machine (At least one for 1000 sq. ft.) 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. 17. 18. 19. 20. 21. 22. Should be check up whether it is full or active enough. There should have two fire points in each floor and for every fire point it needs a water full dram. (45 gallon) and four bucket should be hanged up. Emergency stairs should be made (wide 45 inch and 450 angle step). During the working period all stairs including substitute should be open on. There will be no obstacles on the stairs and in the way of factory. Emergency lighting system should be kept in the factory and in the way of factory. Entrance and exist such kind of works should be kept in written on each doors indicating arrow. Hanging wires need to be changed and electric wires should be conduit or concealed. In the factory there should have 18 fire fighters per 100 people. Hose reel should be set up. Smoke detector should be set up. Public Announcement system (P.A) should be set up. Yellow color dress should be donated by fire fighters. Adequate medicine and first aid box should be provided. Fire service, primary treatment and rescuer team should be answered in the factory. To keep a Gang Bell on every floor. At least one Lock cater should be reserved. To preserve two inch Dia manila rope for the factory to make the rescue activities easier. To keep at least four (4) pair of gloves in the factory. To reserve three pair of masks in the factory. To keep Fire Hook in the factory.
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23. 24. 25. 26. 27. 28. 29.

On every floor, at least a quit should be put in the factory. Each switch board should be made with Ebonite plate. The factory should be separated with Boiler curtain. To keep a stretcher to carry the injured. To preserve Torch lights on every floor. Telephone number of Fire service, police station and electric sector adjacent to the factory should be preserved in a particular place. Electric connection should not keep in the bonded wire house / in the store.

4 .1 W rk S fety .1 o ers a :
Aisles to be kept clear and unblocked. Must have 1 extinguisher per 1000 square feet with Traveling distance of 75 feet radius. Operating instruction in local language to be attached near the extinguisher and monthly check card to be attached with the extinguisher. Evacuation floor plan in local language to be on floor. Battery operated EXIT lights to be posted on top of all Exits. Must to have proper aisle marking with arrow indication towards exits. Must provide 1 first aid box per 150 workers. Must have battery operated Fire alarm with activation procedure in local language. Should have fully equipped First aid room with a full time nurse for a factory having workers above 500. Worker working with electrical heating elements, dry iron, etc to be provided with rubber mat. Rubber mat to be provided in front of all electrical distribution board. Danger sign to mark on all electrical distribution board. Yellow marking (box) in front of all exits, extinguishers, electrical distribution board to be done.

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 Need to form proper trained uniformed fire fighters. Minimum 40% of the work force should also need to know how to use the extinguishers. All sewing machines to have pulley guards; needle guards. And any required guards that deemed to be required. Total use of THINNER is to be avoided. All workers to be provided with mask. Workers to be trained on health issues. Need to conduct one fire drill per month. Workers working on job by standing need to be provided with floor mats.

4 .2 P d ct S fety .1 ro u a :
Need to maintain broken needle, replaced needle log. Maintain pin distribution procedure. Trimmers, scissors and pointers to be tied with draw string. No broken needle, plans etc should be inside machine oil bath. Machine maintenance card to be used.

4 .3F S fety .1 ire a

1. There should be at least two exits in every room at opposing sides 2. Exits should be clearly marked, unobstructed and unlocked and easy to open. 3. Fire drills to be conducted at least twice a year or as required by local law. 4. There should be fire alarms on each floors and emergency lights placed above exits and stairwells. 5. The ratio of the extinguisher should not be less than 01 per 1000 square feet and traveling distance from work station to extinguishers should not be more than 75 feet. 6. Fire extinguishers should be of appropriate size so that workers can lift it properly. Extinguishers should be checked periodically. 7. Fire extinguishers locations should be market properly and fire extinguisher operation instruction should be posted with extinguishers in local language.

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8. A Yellow Box or other marking should be in front of all fire fighting equipments, control panels and potential fire source areas indicating areas to be kept clear at all times. 9. Direction of Fire evacuation plan to be posted through out the factory.

4 .4F A : .1 irst id
There should always be at least one number of staff on each shift that is trained in First Aid and who is made responsible for all first aid requirements during their shift. At least one first aid box should be made available in an area that is accessible to all the workers. The box should be clearly marked and include some basic materials such as Liquid antiseptic. Band aid, Sterile gauze, Sterile cotton Pain killers. The first aid box should be properly maintained by a nominated personal and checked regularly.

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4 .5 H lth H g e &W re: .1 ea , y ien elfa

Need to provide safe drinking water. Need to provide clean toilets, requirement: Female- one toilet per every 25 worker. Male -1st hundred 4 toilet and text every 50 workers one toilet. Sink or taps one sink or tap for every 50 workers. Crche for factory with more than 50 female workers. Need to provide dining space for workers. Toilet should be cleaned at regular intervals and should use proper disinfectants. Lights in production area should be between 50-60 foot candles. Factory should have proper ventilations. Temperature should not be above 86o Fahrenheit

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4 C d o C n u (P licy o b a io w .2 o e f o d ct o n eh v r ith th w rk e o ers)

1. To vituperate, to torture to the workers orally or mentally as well as bodily is strictly forbidden. It so do and if it turns into proof, stern step will be taken against the contravener according to law (2006) section- 23 and 24. 2. If there is any grievance then and then necessary steps must be taken. 3. No penalty should be bucked on the workers and they are not bound to work without wages. 4. Workers are not compelled to do overtime duty against at their sweet will. 5. Workers must not be sheared from their rights. 6. Sympathy and commiseration should be brought in workers private problems. 7. In time of in taking women workers, all sorts of pregnant oriented question should be avoided from asking. 8. Equal base recruitment is mandatory aside from child workers. 9. All the workers have opportunities to appraise their grievance to the senior officer. In case of awareness they could put their complain in the box. Such kind of boxes is available in the factory. 10. If any workers fall into illness they will be given medical aid straight off. If on duty, officer fails to do so, stern action will be taken against him. 11. Every workers posses of getting urgent leave, for this their wages will not decrease. 12. Workers have organizing right. 13. Production is counted on the basis of experiences. Workers have equal right to get promotion and salary, In this case any discrimination is not grated and it is punishable according to the law in (2006) section-23 and 24. 14. There is personal safety system in factory, for this they are introduced with its system, utility. It is mandatory for each worker to use personal safety materials, as they enter into factory.

4 T e B n la esh L b r C d 2 0 .3 h a g d ao oe 06
61. Safety of building and machinery: -

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(1) If it appears to the Inspector that any building or part of a building or any part of the ways, machinery or plant in an establishment is in such a condition that it is dangerous to human life or safety, he may serve to the employer, an order in writing specifying the measures which, his opinion, should be adopted, and requiring them to be carried out within a specified time. (2) If it appears to the Inspector that the use of any building or part of a building or any part of the ways, machinery or plant in an establishment involves imminent danger to human life or safety, he may serve on the employer an order in writing prohibiting its use until it has been properly repaired or altered.

62. Precautions in case of fire:(1) Every establishment shall have an alternative stair connected to every .floor as a means of escape in case of fire and be equipped with fire extinguisher as may be prescribed by rules. (2) If it appears to the Inspector that any establishment is not provided with the means of escape prescribed under sub-section (1), he may serve on the employer of the establishment an order in writing specifying the measure which, in his opinion, should be adopted within a time specified in the order. (3) In every establishment the doors affording exit from any room, shall not be locked or fastened so that they can be easily and immediately opened from inside while any person is within the room, and all such doors, unless they are of the sliding type, shall be constructed to open outwards or where the door is between two rooms, in the direction of the nearest exit from the building and no such door shall be locked or obstructed while work is being carried on in the room. (4) In every establishment every widow, door, or other exit affording means of escape in case of fire, other than the means of exit in ordinary use, shall be distinctively marked in red in Bengali language or by some other effective and clearly under stable sign. (5) In every establishment there shall be provided effective and clearly audible means of giving warning in case of fire to every person employed therein.

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(6) A free passage-way giving access to each means of escape in case of fire shall be maintained for the use of all workers in every room of the establishment. (7) In every establishment wherein more than ten workers are ordinarily employed in any place above the ground floor, or explosive or highly inflammable materials are used or stored, effective measures shall be taken to ensure that all the workers are familiar with the means of escape in case of fire and have been adequately trained in the routine to be followed in such case. (8) In every establishment or factory wherein fifty or more than fifty workers are employed a demonstration of fire extinguishing at least once a year must be held and the employer shall maintain a record book specified for this purpose.

63. Fencing of machinery:(1) In every establishment the following shall be securely fenced by the safeguards of substantial construction which shall be kept in a position while the part of machinery required to be fenced are in motion or in use, namely- .. (a) Every moving part of a prime move and every fly wheel connected to a prime mover; (b) The head-race and tail-race of every water wheel and water turbine; (c) Any part of a stock-bar which projects beyond the head stock Of a lathe; and (d) Unless they are in such position or of such construction as to be as safe to every person employed in the factory as they would be if they were securely fenced(i) Every part of an electric generator, a motor or rotary converter; (ii) Every part of transmission machinery; and (iii) Every dangerous part of any machinery: Provided that, of the purpose of determining whether any part of machinery is in such a position or is of such construction as to be safe as aforesaid, account shall not be taken of any occasion when it being necessary to make an examination of the machinery in accordance with the provisions of section 64. (2) Without prejudice to any other provision of this Code relating to the fencing of machinery, every set screw, bolt and key on any revolving shaft, spindle wheel or pinion and all
46

spur, worm and other toothed or friction gearing in motion with which such worker would otherwise be liable to come into contact, shall be securely fenced, to prevent such contact.

64.Work on or near machinery in motion:(1) Where in any factory it becomes necessary to examine any part of machinery referred to in section 63 while the machinery is in motion, or as a result of such examination, to carry out any mounting shipping of belts, lubrication or other adjusting operation while the machinery is in motion, 'such examination or operation shall be made or carried out only by a specially trained adult male worker, wearing tight fitting clothing whose name has been recorded in the register prescribed in this behalf and while he is so engaged such worker shall not handle a belt at a moving pulley unless the belt is less than 15 centimeter in width and unless the belt-joint is either laced or flush with the belt. (2) The Government may, by notification in the official Gazette, prohibit, in any specified establishment, the cleaning, lubricating or adjusting of specified parts of machinery when those parts are in motion.

65. Striking gear and devices for cutting off power:(1) In every establishment(a) Suitable striking gear or other efficient mechanical appliances shall be provided and maintained and used to move driving belts to and from fast and loose pulleys which form part of the transmission machinery, and such gear or appliances shall be so constructed, placed and maintained to prevent the .belt from cropping back on the first pulleys. (b) Driving belts when not in use shall not be allowed to rest or ride upon shafting in motion. (2) In every establishment suitable devices for cutting off power in emergencies from running machinery shall be provided and maintained in every work-room.

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66. Self-acting machines:No traversing part of a self-acting 'machine in any factory and no material carried thereon shall, if the space over which it runs is a space over which any person is liable to pass whether in the course of his employment or otherwise be allowed to run on its outward or inward within a distance of 45 centimeter from any fixed structures which is not part 0; the machine; Provided that the Chief Inspector may permit the continued use of a machine installed before the commencement of this Code which does not comply with the requirements of this section on such condition for ensuring safety as he may think fit to impose.

67. Casing of new machinery:(1) In all machinery driven by power and installed in any establishment after the commencement of this Code(a) Every set screw, belt or key or any revolving shaft, spindle, wheel or pinion shall be so sunk, encased or otherwise effectively guarded as to prevent danger; and (b) All spur, worm and other toothed or friction gearing which does not require frequent adjustment while in motion shall be completely encased unless it is so situated as to be as safe as it would be if it were completely encased.

68. Cranes and other lifting machinery:(1) The following provisions shall apply in respect of cranes and all other lifting machinery, other than hoists and lifts, in any establishment(a) Every part thereof, including the working gear, whether fixed or movable, ropes and chains and anchoring and fixing appliances shall be(i) Of good construction, sound material and adequate strength; (ii) Properly maintained;

48

(iii) Thoroughly examined by a competent person at lest once in every period of twelve months, and a register shall be kept containing the prescribed particulars of every such examination; (b) No-such machinery shall be loaded beyond the safe working, to load, which shall be plainly marked thereon; and (c) while any person is employed or working on or near the wheel-tract of a traveling crane in any place where he would be liable to be struck by the crane, effective measures shall taken to ensure that the crane does not approach within 6 meter of that place.

69. Hoists and lifts:(1) In every establishment every hoist and lift shall, be (i) Of good mechanical construction, sound material and adequate strength; (ii) Properly maintained, (iii) Shall be thoroughly examined by a competent person at last once in every period of six month and a register shall be kept containing the prescribed particulars of every `such examination. (2) Every hoist way and lift way shall be sufficiently protected by an enclosure fitted with gates, and the hoist or lift and every such enclosure shall be so constructed as to prevent any person or thing from being trapped between any part of the hoist or lift and any fixed structure or moving part; (3) The maximum safe working load shall be plainly marked on every hoist or lift, and no load greater than such load shall be carried thereon; (4) The cage of every hoist or lift used for carrying persons shall be fitted with a gate on each side from which access is afforded to landing; (5) Every gate referred to in clause (2) or clause (4) shall be fitted with-interlocking or other efficient device to secure that the gate cannot be opened except when the cage is at the landing and that cage cannot be moved unless the gate is closed. (6) The following additional requirements shall apply to hoists and lifts used for carrying person and installed or reconstructed in an establishment after the commencement of this Code, namely49

(a) where the cage is supported by rope or chain there shall be at least two ropes or chains separately connected with the cage and balance weight, and each rope or chain with its attachments shall be capable of carrying the whole weight of the cage together with its maximum load; (b) Efficient devices shall be provided and maintained capable of supporting the cage with its maximum load in the event of brakeage of the ropes, chains or attachments; (c) An efficient automatic device shall be provided and maintained to prevent the cage from over-running. (7) The Chief Inspector may permit the continued use of a hoist or lift installed in an establishment before the commencement of this Code which does not fully comply with the provisions of subsection (1), (2), (3), (4), and (5) upon such conditions for ensuring safety as he may think fit to impose. together

70. Revolving machinery:(1) In every room in an establishment in which the process of grinding is carried on, there shall be permanently affixed to, or placed near, each machine in use a notice indicating(a) The maximum safe working peripheral speed of every grind stone Or abrasive wheel, (b) The speed of the shaft or spindle upon which the wheel is mounted; and (c) The diameter of the pulley upon such shaft or spindle necessary tosecure such safe working peripheral speed. (2) The speeds indicated in notices under sub-section (1) shall not be exceeded. (3) Effective measure shall be taken in every establishment to ensure that the safe working peripheral speed of. every revolving \ vessel, cage, basket, flywheel, pulley disc or similar appliance driven by power is not exceeded.

71. Pressure plant:If in any establishment any part of the plant, or machinery used in manufacturing process is operated at a pressure above atmospheric pressure, effective measures shall be taken to ensure that the safe working pressure of such part is not exceeded.
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72. Floors, stairs and means of access:In ever establishment(a) all floors, stairs, passages and gangways shall be of sound construction and properly maintained and where it is necessary to ensure safety, steps, stairs, passages and gang ways shall be provided with substantial handrails; and (b) there shall, so far as is reasonably practicable, be provided and maintained safe means of access to every place at which any person is, at any time, required to work. (c) All floors, stairs and gangways shall be wide and obstacle free.

73. Pits, sumps, opening in floors, etc:In every establishment, every fixed vessel, sump, tank, pit or opening in the ground or in a floor which, by reason of its depth, situation, construction or contents, is or may be a source of danger, shall be either securely covered or securely fenced.

74. Excessive weights:No person shall be employed in any establishment to lift, carry or move any load so heavy as to be likely to cause him injury.

75. Protection of eyes:The Government may, in respect of any manufacturing process carried on in any establishment, by rules, require that effective screens of suitable goggles shall, be provided for the protection of persons employed on, or in the immediate vicinity of a process which involves(a) Risk of injury to the eyes from particles or fragments thrown off in the course of the process, or (b) Risk to the eyes by reason of exposure to excessive light or heat.

76. Powers to require specifications of defective parts or tests of stability:If it appears to the Inspector that any building or part of a building, or any part of the ways, machinery or plant in an establishment, is in such a condition that it may be dangerous to human
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life or safety, he may serve on the employer an order in writing, requiring him before a specified date(a) To furnish such specifications and other particulars as may be necessary to determine whether such buildings, ways, machinery or plant can be used with safety, or (b) To carry out such test as may be necessary to determine the strength or quality of any specified parts and to inform the Inspector of the results thereof.

77. Precautions against dangerous fumes:(1) In any establishment no person shall enter or be permitted to enter any chamber, tank, vat, pit, pipe, flue or other confined space in which dangerous fumes are likely to be present to such an extent as to involve risks of persons being overcome thereby, unless it is provided with a manhole of adequate size or other effective means of egress. (2) No portable electric light of voltage exceeding twenty-four volts shall be permitted in any establishment for use inside any confined space such as if referred to in sub-section (1) and where the fumes present are likely to be inflammable, lamp or light other than of flame proof constitution shall be permitted to be used in such confined space. (3) No person in any establishment shall enter or be permitted to enter any confined space such as is referred to in sub-section (1) until all practicable measures have been taken to remove any fumes which may be present and to prevent any ingress of fumes and unless either(a) a certificate in writing has been given by a competent person, based on a test carried out by himself, that the space is free from dangerous fumes and fit for persons to enter; or (b) The worker is wearing suitable breathing apparatus and a belt securely attached to rope, the free end of which is held by a person standing outside the confined space. (4) Suitable breathing apparatus, reviving apparatus and belts and ropes shall, in every establishment, be kept ready for instant use beside any such confined space as aforesaid which any person has entered, and all such apparatus shall be periodically examined and certified-by a
52

competent person to be fit for use; and a sufficient number of persons employed in every establishment shall be trained and practiced in the use of all such apparatus and in the method of restoring respiration. (5) No person shall be permitted to enter in any establishment, any boiler furnace, boiler, flue, chamber, tank, vat, pipe or other confined space for the purpose of working or making any examination therein until it has been sufficiently cooled by ventilation or otherwise to be safe for persons to enter.

78. Explosive or inflammable dust, gas, etc:(1) Where in any establishment any manufacturing process produces dust, gas fume or vapor of such character and to such extent as to be likely ,to explode on ignition, all practicable measures shall be taken to prevent any such explosion by(a) Effective enclosure of the plant or machinery used in the process; (b) Removal or prevention of the accumulation of such dust, gas, fume or vapor; (c) Exclusion or effective enclosure of all possible sources of ignition. (2) Where in any establishment the plant or machinery used in a process such as is referred to in sub-section (1) is not so .constructed as to withstand the probable pressure which such an explosion as aforesaid would produce, all practicable measures shall be taken to restrict the spread and effects of the explosion by the provision in the plant or machinery of chokes, baffles, vents or other effective appliances. (3) Where any part of the plant or machinery in an establishment contains any explosive or inflammable gas or vapor under pressure greater than atmospheric pressure, that part shall not be opened except in accordance with that following provisions, namely(a) Before the fastening of any joint of any pipe connected with the pat of the fastening of the cover of any opening into the part is loosened, any flow of the gas or vapor into the part of any such pipe shall be effectively stopped by a stop-valve or other means;

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(b) Before any such fastening as aforesaid is removed, all practicable measures shall be taken to reduce the pressure of the gas or vapor in the part or pipe to atmospheric pressure; (c) where any such fastening, as aforesaid, has been loosened or removed, effective measures shall be taken to prevent any explosive or inflammable gas or vapor from entering the part or pipe until the fastening has been secured; or as the case may be, securely replaced; Provided that the provisions of this sub-section shall not apply in the case of plant or machinery installed in the open air. (4) No plant, tank or vessel, which contains or has contained any explosive or inflammable substance shall be subjected in any establishment to any welding, brazing, soldering or cutting operation which involves the application of heat unless adequate measures have first been taken to remove such substance and any fumes arising there from or to render such substance and fumes non explosive or non-inflammable, and no such substance shall be allowed to enter such plant, tank or vessel after any such operation until the metal has cooled sufficiently to prevent any risk of igniting the substance. Chapter VII Special provision with regard to health and safety:

79. Dangerous operations:Where the Government is satisfied that any operation carried on in an establishment exposes any person employed in it to a serious risk of bodily injury, poisoning, or disease, make rules applicable to such " establishment in which such operation is carried on(a) Specifying the operation and declaring it to be hazardous, (b) Prohibiting or restricting the employment of women, adolescents or children in the operation; (c) Providing for the periodical medical examination of persons employed in the operation and prohibiting the employment of persons not certified as fit for such employment. (d) Providing for the protection of all persons employed in the operation or in the vicinity of the places where it is carried on and
54

it may

(e) Providing for notices with regard to-careful use of any harmful chemicals in connection with the operation.

80. Notice of certain accidents:(1) Where in any establishment an accident occurs which causes death, or any bodily injury or any explosion, fire, forceful entrance of water or fumes as a result of accident, the employer shall send notice there of to the Inspector within two working days following the accident. (10) Where any person injured as a result of accident as mentioned in sub-section (1) above, is prevented from resuming his work in the factory during the forty-eight hours immediately following the accident this must be entered into a register prescribed by rules. (11) A copy of register referred to in sub-section (2) must be sent to the Chief Inspector within fifteen days following 31st December every year starting from 30th June.

81. Notice of some dangerous occurrences:Where in any establishment any dangerous occurrences specified by rules in this behalf occur, the employer shall send notice thereof to the Inspector within three working days following the accident although no death or bodily injury has been caused to any person.

82. Notice of certain disease:1) Where any worker in an establishment contacts any disease specified in the Second Schedule, the employer or the worker or any person appointed by him shall send notice thereof to the Inspector in such form and within such time as may be prescribed. (2) If any registered medical practitioner attends on a person who is, or has been employed in an establishment and who is, or is believed by such medical practitioner to be, suffering from any disease specified in the Second Schedule, the medical practitioner shall, without delay, send a report in writing to the Chief Inspector stating(a) The name and full postal address of the patient;
55

(b) The disease from which he believes the patient to be suffering; (c) The name and address of the factory in which the patient is or was last employed. (3) The Government may add to or subtract from the Second Schedule any disease by notification in the official Gazette.

83. Power to direct enquiry into cases of accident or disease:(1) The Government may, if it considers it expedient so to do, appoint a competent person under intimation to all concerned to enquire into the causes of any accident, any explosion, fire, forceful entrance of water or fumes as a result of accident occurring in an establishment, or into any case where a disease specified in the Second Schedule has been, or is suspected to have been, contacted in an establishment and may also appoint one or more persons possessing legal or special knowledge to act as assessors in such enquiry. (2) The person appointed to hold an enquiry under this section shall have all the powers of a Civil Court under the Code of Civil Procedure, 1908, for the purposes of enforcing the attendance of witnesses and compelling the production of documents and material -objects, and every person required by the person making the enquiry to furnish any information shall be deemed to be legally bound so to do within the meaning of section 176 of the Penal Code, 1860 (XLV of 1860). (3) Such person may also, so far as may be necessary for the purpose of the enquiry, exercise any of the powers of an Inspector under this Code; (4) The person holding an enquiry under this section shall make a report to the Government stating the cause of the accident, or as the case may be, disease, and any attendant circumstances, and adding thereto any observations which he, or any of the assessors, may think fit to make. (5) The Government may, if it thinks fit, cause to be published any such report in the manner and time as fixed by it.

84. Power to take samples:-

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(1) An Inspector may, at any time during the normal working hours of an establishment, after informing the employer, take, in the manner hereinafter provided, a sufficient sample of any substance used or intended to be used in the establishment, such use being, in the opinion of the Inspector in contravention of any of the provisions of this Code or the rules made there under, or likely to cause bodily injury to or injury to the health of, workers in the establishment. (2) Where the Inspector takes sample under sub-section (1), he shall, in the presence of the employer unless the employer willfully absents himself, divide the sample into three portions and effectively seal and suitably mark them, and shall permit the employer to add his own seal and mark thereon. (3) The employer shall, if the Inspector so requires, provide the appliances for dividing, sealing and marking sample taken under this section. (4) The Inspector shall forthwith give one portion of the sample to the employer, send the second portion to a Government Analyst for analysis and report thereon; and retain the third portion for production to the Court before which proceeding, if any, are instituted in respect of the substance. (5) Any document, purporting to be a report under the hand of any Government Analyst upon any substance submitted to him for analysis-and report under this section, may be used as evidence in any proceedings instituted in respect of the substance.

85. Power of the Inspector in case of some dangers:(1) If it appears to the Inspector, where no provision for any matter has been provided for in this Code, that any establishment or any part of it or anything or any matter or principles related to it or controlled by it is dangerous to the life and safety of people or such faulty that it may cause physical injury to human being, he will inform, by writing, the employer of it and may direct in the letter to rectify the fault in the manner and by the time prescribed by him.

57

(2) Without prejudice to the provisions of sub-section (1) the Inspector' may prohibit, by order in writing, the owner of an establishment to reduce or demolish any pillar of his establishment or part of it which, in his opinion, is likely to be the reason of fall of any other pillar or any part of the establishment or is dangerous to the establishment. (3) If the Inspector thinks that the life and safety of any worker working in an establishment is under imminent danger, he may inform that same to the owner in writing by describing his reasons and may prohibit, until he is satisfied that the danger has been removed, the employment of any worker in that establishment. However, such order shall not be applicable to the person who is engaged in removing the danger. (4) Any owner aggrieved by the order under sub-section (3) may appeal to the Chief Inspector within ten days of receipt of such order and the Chief Inspector may confirm, modify or cancel the order. (5) With regard to every order under sub-section (1) and (3) the Inspector shall immediately make report to the Government and inform the concerned owner about this reporting. (6) With regard to every order under sub-section (4), except .order cancellation, the Chief Inspector shall immediately make report to the Government and inform the concerned owner also about this reporting. (7) Any owner aggrieved by the order under sub-sections (1), (3) or (4) may appeal to the Government within thirty days from the receipt of the order and the Government shall send such appeal a committee for decision. (8) The owner shall be- bound to comply with the order against which he has filed appeal until any decision has been given on it: Provided that on the application by the Committee may suspend the order under sub-section (1) temporarily until decision is given on the appeal.
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86. Giving information of dangerous building s and machinery:(1) Where any worker discovers in an establishment that any building or machinery of it which the workers usually use is in such dangerous condition that this may cause physical injury to any worker, he shall inform that same immediately to the owner by writing. (2) If the owner, after receiving such information, fails to take appropriate measures and any worker is physically injured as a result of such dangerous building or machinery, he shall compensate the- worker-which will be double the rate of compensation given in chapter 12 for .such type of injury.

87. Restriction of employment of woman in some cases:Provisions under sections 39, 40 and 42 are applicable to woman workers as they apply to young persons.

88. Power to make supplementary rules:The Government may make rules by framing rules(a) Direct to take additional measures for safety of workers in an establishment; (b) Prohibit production by electricity supply to any building until a certificate of fitness, in a prescribed form by an appropriate person fixed by rules is reached by the Chief Inspector.

4 C m lia ce C .4 o p n ertifica n A th rity tio u o :

SA -8000 (Social Accountibility) WRAP (World Wide Responsible Appearal Production) FLA (Fair labor Association) ETI (Ethical Traning Initiative) ILO (International Labor Organization)

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60

C ap h ter-5
C em C m liance h ical o p

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5 G era C u n .1 en l a tio :
Dont eat, drink or smoke near chemicals. Dont hurry or rush carelessness can cause accidents. Never smell or feel a substance in order to entity what it is. Identifying a product should only be done by its label and or MSDS. Bring the smallest quantity of chemicals needed for a job outside of storage rooms or cabinets. Keep work areas clean to eliminate potential accidents and fires. Good housekeeping is more than just sweeping the floor and wiping off machines and equipment. Keeps put chemicals back in storage rooms or when done using or at the end of the work. When hands thoroughly before leaving the work area at the end of the work shift/day.

5 H za o s su sta ce: .2 a rd u b n
Hazardous substances include: Substances used directly in work activities (e.g. adhesives, solvents, cleaning agents). Substances generated during work activities (e.g. fumes from soldering and welding). Naturally occurring substance (e.g. dusts); and Biological agents such as bacteria ad other micro- organisms.

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5 S m o A b ia na dd .3 y b ls, b rev tio n escrip n tio : Symbol Sign Category

Safe Procedure

Meaning
SAFE emergency escape route or first aid

Shape/Colors
Square or oblong. White symbol or symbol and text on a green background

Use of Sign
To show the way to medical assistance To show the way to an area of safety To indicate that a course of action is safe to take To convey actions that must be carried out To confirm emergency procedures in the event of fire To indicate the location of fire equipment To comply with the fire precautions (workplace)reg ulations, which require any non automatic fire fighting equipment to be indicated by signs

Mandatory

YOU MUST

Circular. White symbol or symbol and text on a blue background

Fire Equipment FIRE - Fire Fighting

Square or oblong. White symbol or symbol and text on a red background

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Symbol

Sign Category
Warning

Meaning
BE CAREFUL - Warning

Shape/Colors
Triangular. Black symbol or symbol and text on a yellow background surrounded by a black triangular band. Circular with cross band. Black symbol on a white background, inside a red circle with a red cross bar

Use of Sign
To warn staff and public of the potential dangers in and around the workplace To convey prohibited actions To reduce the risk of fire To prevent personal injury To provide further information

Prohibition

DO NOT Danger, alarm

Supplementary

Supplementary Information

Square or oblong. Black text on a white background or the safety color of the safety sign that is supplemented, with text in the relevant contrasting color

S mo y bl

A b iatio b rev n

H azard
explosive oxidizing extremely flammable

D escrip n o tio f h azard

Chemicals that explode. Chemicals that react exothermically with other chemicals. Chemicals that have an extremely low flash point and boiling point, and gases that catch fire in contact with air.

(P y ch ical) h sico em E O F+

S mo y bl

A b iatio b rev n

H azard
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D escrip n o tio f

H azard
(H ealth )
T+ T Xn C Xi very toxic toxic harmful corrosive irritant Chemicals that at very low levels cause damage to health. Chemicals that at low levels cause damage to health. Chemicals that may cause damage to health. Chemicals that may destroy living tissue on contact. Chemicals that may cause inflammation to the skin or other mucous membranes. Chemicals that may present an immediate or delayed danger to one or more components of the environment

(E v n en n iro m tal)
N dangerous for the environment

5 M .4 aterials S afetyD S eet ata h

(M D ): S S

Review and follow Materials Safety Data Sheet (MSDS) instructions for handling and using chemicals this will help minimize the risk of spills and accidents. Factory workers should review this important information each time they use a chemical and most importantly, before using any new material. Follow all instructions and procedures on the MSDS carefully and do not be afraid to ask questions if something is unclear or missing. Dont use any hazardous material that does not have an MSDS available.

5 L els: .5 ev
Ensure that all containers are properly labeled (chemical name, type of hazard, special precautions and emergency information). Dont use any product that cannot be identified.

5 T n o gC em ls: .6 ra sp rtin h ica

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 Inspect drums to ensure that they are in good condition before being moved around the factory. Transport drums around the factory in a safe manner to avoid puncturing or damaging the drum (i.e. dont roll the drum). Use material handling equipment to transport chemicals around facility (i.e., carts, dollars, pallet jacks, etc.). 5 T n .7 ra sferrin C em ls: g h ica Pour chemicals carefully to avoid spills. Use spigots, pumps, hides and funnels as necessary. If reusing containers, ensure that the container is compatible with the new material being added and that it is property labeled with the new chemical name and hazards associated with the new chemical.

5 W rk P tectio : .8 o er ro n
PPE: Always wear required Personal Protective Equipment (PPE). The factorys Health & Safety Program should communicate PRE requirements to workers. Ventilation: Maintain adequate ventilation in the areas where chemicals are used. The Factory environmental compliance. Specialist should periodically monitor the air concentrations for

5 S ills: .9 p
Always attempt to wipe up spills, whenever possible, rather than hosing down an area. This helps to collect and confine the hazardous material being cleaning up. Dont spread the substance or wash it down the drain.

5 0 C em l S ra e: .1 h ica to g
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 Make sure that sheaves are secure and that they are not overloaded. Allow for adequate aisle space in all storage areas for easy access, transfer and inspection for leaks/spills. Keep storage areas clean and orderly. Dont store trash or debris in chemical storage areas. Dont store flammable liquids in glass containers since they may break more easily. Flammable liquids need to be grounded (and bonded if dispensing from). Be aware of locations of exhaust fans since they are an ignition source. Store metal containers on plastic pallets to prevent the corrosion that can result from containers contacting concrete floors. (Wooden pallets should not be used where flammables are stored.) Safety cans should be no larger than 5 gallons. Transfer contents from a leaking drum/container immediately. Proper spill control equipment must be available in storage areas. Make sure that all storage and factory work areas (where chemicals are used) are adequately ventilated.

5 1 M in sto g R o s: .1 a ra e o m
Keep a sign on the storage area door (danger, hazardous materials storage area). Storage areas should be inspected every weekly. Post an inspection sheet roster on the storage area door, noting the date and inspector of the last inspection. 5 1 F m a le S ra e C b ets: . 2 la m b to g a in A chemical inventory list should be posted on the outside of flammable storage cabinets. Be aware of the quantity limitations for the factorys flammable storage cabinet. Dont overstock the cabinet, resulting in secondary containment capacity being exceeded.

5 3 S n a C n in en .1 eco d ry o ta m t:
Secondary containment is a second line of defense against (a) chemical spills and releases into the environment and (b) incompatible chemicals being mixed together or coming into contact with each other. Because accidental releases of hazardous chemicals can result. In fires, explosions or worker exposure. Secondary containment provides an additional means of minimizing or eliminating these occurrences.
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5 4R A .1 isk ssessm t o C em ls en f h ica The MSDS is simply the management process for the risk assessment of all the chemicals and dyes used in the factory by providing much of the information required in this risk assessment. The risk assessment should consider how chemicals are stored and handled. The information in the risk assessment should be made available to all the workers. Risk assessment is necessary for the management of changes to operation: To manage safety effectively, existing activities must be assessed for risks. There should be a schedule of risk assessments for all current operations. Employers must take account of the capabilities and vulnerabilities of young persons and new or expectant mothers when assessing the risks to which they will be exposed. This should be included in the risk procedure. Who carries out the assessment will depend on the activity. For most activities in the textile industry, it will be sufficient for the assessment to be carried out in house. For more complex and specialist situations, specific expertise may be necessary. It is important that consistent standards are applied throughout the company, and if more than one person is responsible for carrying out assessments, then some central oversight is necessary. The significant findings of assessments need to be recorded by employers who employ more than 5 persons. The record should comprise an effective statement of hazards and risks, which leads to the actions necessary to protect employees. The results of a risk assessment must be considered in line with the General Principles of Prevention. This is the application of risk management that seeks to avoid risks if possible or reduce to acceptable levels prior to the application of procedural controls and protective equipment. Managers, supervisors, and workers should have the assessment brought to their attention. It should part if any training. Employers must review an assessment when the situation changes or new experience shows the assessment to be inadequate.

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C AT R H P E -6

E G N M S R O O IC

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6 In d ctio .1 tro u n
The term ergonomics is derived from two Greek words: ergon, meaning work and nomoi, meaning natural laws. The word ergonomics means laws of (nomos) work (ergon). Ergonomics is the science of adapting the job and/or the equipment and the human to each other for optimal safety and productivity. Ergonomists study human capabilities in relationship to work demands.

6 D itio : .2 efin n
Ergonomics is an engineering discipline that addresses the effect work environments and tasks have on the employee. Ergonomics involves workstation set-up and design, body posture, injuries and more. Ergonomics education is often included in physical therapy treatment for back and neck injury, and chronic pain. Also Known As: human factors, human factors engineering.

6 W a is erg n m .3 h t o o ics?
The technology concerned with the design, manufacture, and arrangement of products and environments to be safe, healthy, and comfortable for human beings. 1) An applied science concerned with designing and arranging things people use so that the people and things interact most efficiently and safely -- called also human engineering. 2) The applied science of equipment design, as for the workplace, intended to maximize productivity by reducing operator fatigue and discomfort. This is also called biotechnology. Most people have heard of ergonomics and think it is something to do with seating or with the design of car controls and instruments. It is...but it is much more! Ergonomics is the application of scientific information concerning humans to the design of objects, systems and environment for human use. Ergonomics comes into everything which involves people. Work systems, sports and leisure, health and safety should all embody ergonomics principles if well designed.

6 U g E o o ics: .4 sin rg n m
Ergonomics incorporates elements from many subjects including anatomy, physiology, psychology and design. Ergonomists apply their diverse knowledge to ensure that products and environments are comfortable, safe and efficient for people to use.
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6 W a is E o o ic d n .5 h t rg n m esig ? Ergonomic design is a way of considering design options to ensure that people's capabilities and limitations are taken into account. This helps to ensure that the product is fit for use by the target users.

6 E .6 ffects fro p o E o o ics: m o r rg n m

Work-related musculoskeletal disorders (MSD) result when there is a mismatch between the physical capacity of workers and the demands of the job. Musculoskeletal disorders are the leading cause of disability of people in their working years.

6 P cip o E o o ics: .7 rin le f rg n m

Knowledge of basic ergonomics principles is important for both workers and employers because both share responsibility for a safe work environment. One can easily imagine the potential hazards in manufacturing settings where equipment is operated and heavy materials are handled, but hazards exist in other environments, too. And technology has brought about widespread changes in how work is accomplished. Attention to ergonomics principles helps to reduce workplace injuries and illnesses that result in workers' compensation costs, medical claims, and lost work time. Many disorders and injuries are preventable when work conditions are designed for human safety and comfort. People need training in how to recognize hazards and safety problems as well as how to control their own behaviors for maximum comfort and health. One of the key considerations in ergonomics is adjustability of physical elements. People come in all shapes and sizes, and the "average" workstation configuration will not fit everyone. Making changes during a workday in the physical setup of equipment, such as adjusting chair height, can alleviate discomfort and fatigue. Work surfaces should be at comfortable heights in relationship to a chair or to a standing position. Equipment and related items should be arranged conveniently.

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Whenever a mismatch occurs between the physical requirements of a job and the physical capacity of a worker, musculoskeletal disorders can result. People working with intense concentration or at high speeds often work with poor posture. Cumulative trauma disorders (also called repetitive strain injuries) are caused by repeating the same motion in awkward positions or with noticeable force, such as in lifting heavy objects. Posture in standing and in seated positions is important to avoid musculoskeletal disorders. The natural curve of the spine should be maintained, with the head balanced over the spine. When a person is seated: Feet should rest on the floor, with legs and body forming 90 to 110 angles. The body should be straight, with the neck upright and supporting the head balanced on the spine (not forward or twisted to the sides). Upper arms should be perpendicular to the floor; forearms should parallel the floor. Indoor air quality involves more than heating and cooling air should be cleansed of pollutants (bacteria, dust, fumes, etc.), with fresh air added before circulation. Many factors affect the efficiency of HVAC (heating, ventilation, and air conditioning) systems. These systems must be designed for the number of people and the equipment to be used in each area because devices can produce almost as much heat as a human body produces. Another important concept is adjustability of work pace. Jobs may require redesign to allow workers to accomplish tasks at varying speeds or to enable workers to rotate to different tasks or to use a variety of work methods that permit different movements. Rest breaks are important, too, and micro breaks can be taken to interrupt in tense situations, to rest arms and wrists, or to rest eyes.

6 A p tio o E o o ics: .8 p lica n f rg n m

Ergonomics has wide application to everyday domestic situations, but there are even more significant implications for efficiency, productivity, safety, and health in work settings. For example: (i) Designing equipment and systems, including computers, so that they are easier to use and less
72

likely to lead to errors in operation particularly important in high stress and safety-critical operations such as control rooms. (ii) Designing tasks and jobs so that they are effective and take account of human needs such as rest breaks and sensible shift patterns, as well as other factors such as the intrinsic rewards of work itself. (iii) Designing equipment and work arrangements to improve working posture and ease the load on the body, thus reducing instances of Repetitive Strain Injury/Work Related Upper Limb Disorder. (iv)Information design, to make the interpretation and use of handbooks, signs, and displays easier and less error-prone. (v) Design of training arrangements to cover all significant aspects of the job concerned and to take account of human learning requirements. (vi)Designing working environments, including lighting and heating, to suit the needs of the users and the tasks performed. Where necessary, design of personal protective equipment for work in hostile environments. (vii) In developing countries, the acceptability and effectiveness of even fairly basic technology can be significantly enhanced.

6 T e co p n ts o erg n m .9 h m o en f o o ics:
Ergonomics deals with the interaction of technological and work situations with the human being. The basic human sciences involved are anatomy, physiology, and psychology. These sciences are applied by the ergonomist towards two objectives: the most productive use of human capabilities, and the maintenance of human health and well-being. In a phrase, the job must fit the person in all respects, and the work situation should not compromise human capabilities and limitations.
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The contribution of basic anatomy lies in improving the physical fit between people and the things they use, ranging from hand tools to aircraft cockpit design. Achieving good physical fit is no mean feat when one considers the range in human body sizes across the population. The science of anthropometrics provides data on dimensions of the human body, in various postures. Biomechanics considers the operation of the muscles and limbs, and ensures that working postures are beneficial, and that excessive forces are avoided. Our knowledge of human physiology supports two main technical areas. Work physiology addresses the energy requirements of the body, and sets standards for acceptable physical workrate and workload, and for nutrition requirements. Environmental physiology analyses the impact of physical working conditions thermal, noise and vibration, and lighting and sets the optimum requirements for these. Psychology is concerned with human information processing and decisionmaking capabilities. In simple terms, this can be seen as aiding the cognitive fit between people and the things they use. Relevant topics are sensory processes, perception, long- and short-term memory, decision making, and action. There is also a strong thread of organizational psychology.

6 0 T e en iro m t a w rk .1 h v n en t o :
It is particularly important for the equipment which a person is using in a noisy environment to be designed ergonomically. In quiet surroundings a person can usually hear when he is operating equipment correctly: switches may produce audible clicks when they are pressed, and the tap of a hammer has a higher pitch when it hits a nail or rivet than when it misses and hits wood or canvas. In noisy surroundings such cues may not be audible, or may be difficult to distinguish one from another. If in operating equipment a person has to use his eyes, or sense of touch, instead of his ears, and if these senses are already heavily engaged, he may fail to notice mistakes. The medical problems of the environment at work are now giving ergonomics a new impetus.
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Loud noise causes industrial deafness, as well as masking sounds, and calls for noise control and hearing protection. Industrial processes produce dusts, vapors, and gases which may cause cancer or other illnesses. Ionizing radiation and electromagnetic radiation of short wavelength can also damage the human organism. Dosimeters have to be designed and worn. The more generally harmful effects of atmospheric pollution need to be reduced by changes in industrial activity. Ergonomists today require knowledge of chemistry and physics in addition to their traditional knowledge of displays and controls.

6 1 E o o ics inth w rk la .1 rg n m e o p ce:

Outside of the discipline itself, the term 'ergonomics' is generally used to refer to physical ergonomics as it relates to the workplace. Ergonomics in the workplace has to do largely with the safety of employees, both long and short-term. Ergonomics can help reduce costs by improving safety. This would decrease the money paid out in workers compensation. For example, over five million workers sustain overextension injuries per year. Through ergonomics, workplaces can be designed so that workers do not have to overextend themselves and the manufacturing industry could save billions in workers compensation. Workplaces may either take the reactive or proactive approach when applying ergonomics practices. Reactive ergonomics is when something needs to be fixed, and corrective action is taken. Proactive ergonomics is the process of seeking areas that could be improved and fixing the issues before they become a large problem. Problems may be fixed through equipment design or task design. Equipment design changes the actual, physical devices used by people. Task design changes what people do with the equipment. Environmental design changes the environment in which people work, but not the physical equipment they use.

6 2 A p tio o E o o ics insew g .1 p lica n f rg n m in : Workers involved in sewing activities, such as manufacturing garments, shoes, and airplane or car upholstery, may be at risk of developing musculoskeletal disorders (MSDs). Sewing-related
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injuries have been documented in the areas of sewing stations, performing fine work or scissor work, and material handling, among others. Stitching involves taking cut material, placing it on the sewing mount, then running it through a sewing machine. This operation may require pinch grips and awkward arm, neck, and trunk postures. Force may also be required to push material through the machine. Some of the common risks and possible solutions associated with stitching are listed below. Moving Material Setting Up Material Manipulating Material Stitching Material

6 2 .1 .1

M v g M teria o in a l
:

P ten l H za s o tia a rd

Workers reach overhead, to the side, behind, or down into bins to pick up or place Material. This action can cause stress on the arms, neck, shoulders, and back. Workers bend/twist to pick up component, which can hurt a worker's back and shoulders.

P ssib S lu n o le o tio s

Using height-adjustable portable racks or tables. Minimize reaches to the side or behind associated with picking up new product by: placing bins closer to the worker ; placing bins at table height; using height-adjustable material containers; adding an extension to work table; or Using an automated or conveyor system that transports the material directly to and from the worker.

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 Use swivel chairs, which allow workers to turn to get bundles and pieces, rather than twisting to reach to the side or behind. Swiveling can also make it easier for workers to sit down and get up from the workstation.

6 2 .1 .2

S ettin u M teria g p a l
:

P ten l H za o tia a rd

When setting up material for stitching, workers may have to flex or bend their necks to view the position of the components. P ssib S lu n o le o tio s :

Use automatic feeding and set up, which eliminates the operator using awkward postures. Provide proper lighting: Use adjustable task lighting to make it easier for the worker to see product during set up.

Fig. Adjustable task lighting.

Ensure bulbs are replaced frequently so they are functional at all times. Provide properly positioned general overhead lighting.

6 2 .1 .3

M n u tin M teria a ip la g a l
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P ten l H za o tia a rd

While manipulating material, employees repeatedly use a forceful pinch grip between the thumb and index finger.

Fig. Pinch grip.

P ssib S lu n o le o tio s: Use friction-increasing aids on fingers to reduce amount of force exerted in the pinch grip.

Fig: Friction-increasing aid.

Analyze tasks to determine force requirement and use job/task rotation through tasks not requiring pinch grip.

6 2 .1 .4

S titch g M teria in a l
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P ten l H za : o tia a rd

Employees push material through the sewing machine, which may require extending arms, bending at the waist, and applying force.

Fig. Awkward posture causing ergonomic stress to arms, shoulders, and back.

P ssib S lu n o le o tio s: Use height adjustable tables, which, when properly adjusted, may reduce arm extension and bending at the waist.

Fig. Height-adjustable table

Allow the machine to pull the material through rather than having the operator push the material. Reduce the distance between the operator and the machine.

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PART-2 LEATHER MARKETING

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CHAPTER 7 INTRODUCTION OF MARKETING

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MARKETING- THE CORE CONCEPT Marketing is a social and global as well as managerial process by which individuals and groups obtain and want through creating, offering and exchanging products of value with others. Needs, wants, demands, value, cost and satisfaction exchange and transaction; relationship and network; markets and finally marketers and prospects are the basic core concepts of marketing. The activities connected with advertising, distribution, merchandising, product planning, promotion, publicity, research and development, sales, transportation and warehousing of goods or services. CONCEPT OF MARKET A market consist of all the potential customers sharing a particular need or want who might be willing and able to engage in exchange to satisfy that need or want. Thus the size of the market depends on the number of people who exhibit the need or want, have resources in exchange for what they want. Traditionally a market was a place where buyers and sellers gathered to exchange their goods, such as a village square. Economics use the term to refer to a collection of buyers and sellers who transect over a particular product or product class. Business people often use the term "market" colloquially to cover various groupings of customers. Essentially manufacturers go to resource market (raw materials, labor markets, money market and so on) buy resources and turn them into goods and services. And then sell the finished products to intermediates who sell them to consumers. MARKETERS AND PROSPECTS: The concept of marketers brings us a full of circle to the concept of marketing. Marketing means working with market to actualize potential exchanges for the purposes of satisfying human needs and wants. The marketer can be a seller or buyer. Suppose several people want to buy.

International Marketing
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International marketing is simply the application of marketing principles to more than one country. However, there is a crossover between what is commonly expressed as international marketing and global marketing, which is a similar term. Many American and European authors see international marketing as a simple extension of exporting, whereby the marketing mix is simply adapted in some way to take into account differences in consumers and segments. It then follows that global marketing takes a more standardized approach to world markets and focuses upon sameness, in other words the similarities in consumers and segments. So let's take a look at some generally accepted definitions. "At its simplest level, international marketing involves the firm in making one or more marketing mix decisions across national boundaries. At its most complex level, it involves the firm in establishing manufacturing facilities overseas and coordinating marketing strategies across the globe." Doole and Lowe (2001). Doole and Lowe differentiate between international marketing (simple mix changes) and global marketing (more complex and extensive). "International Marketing is the performance of business activities that direct the flow of a company's goods and services to consumers or users in more than one nation for a profit.

International Marketing Environment

Environment analysis for international marketing One of the fundamental steps that need to be taken prior to beginning international marketing is the environmental analysis. Of course there are many tools on Marketing Teacher that would prove useful at this stage such as lessons on the marketing environment, PEST Analysis, SWOT Analysis, POWER SWOT and Five Forces Analysis. However, the very specific and unique nature of each individual nation needs to be looked into. Below we consider the nature of an international PEST Analysis, and the influence of tariff and non-tariff barriers.

International Marketing and Culture

What is the influence of culture on international marketing?

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Culture is the way that we do things around here. Culture could relate to a country (national culture), a distinct section of the community (sub-culture), or an organization (corporate culture). It is widely accepted that you are not born with a culture, and that it is learned. So, culture includes all that we have learned in relation to values and norms, customs and traditions, beliefs and religions, rituals and artifacts (i.e. tangible symbols of a culture, such as the Sydney Opera House or the Great Wall of China). Therefore international marketing needs to take into account the local culture of the country in which you wish to market.

The Terpstra and Sarathy Cultural Framework helps marketing managers to assess the cultural nature of an international market. It is very straight-forward, and uses eight categories in its analysis. The Eight categories are Language, Religion, Values and Attitudes, Education, Social Organizations, Technology and Material Culture, Law and Politics and Aesthetics.

The International Market Entry Evaluation Process

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How to Enter a Foreign Market This lesson gives an outline of the way in which an organization should select which foreign to enter. The International Marketing Entry Evaluation Process is a five stage process, and its purpose is to gauge which international market or markets offer the best opportunities for our products or services to succeed. The five steps are Country Identification, Preliminary Screening, In-Depth Screening, Final Selection and Direct Experience.

Marketing Plans
Marketing plans are vital to marketing success. They help to focus the mind of companies and marketing teams on the process of marketing i.e. what is going to be achieved and how we intend to do it. There are many approaches to marketing plans. Marketing Teacher has focused upon the key stages of the plan. It is contained under the popular acronym AOSTC.
ANALYSIS. OBJECTIVES. STRATEGIES. TACTICS. CONTROLS.

Stage One - Situation Analysis (and Marketing Audit).

Marketing environment. Laws and regulations. Politics. The current state of technology. Economic conditions. Socio cultural aspects. Demand trends. Media availability. Stakeholder interests. Marketing plans and campaigns of competitors. Internal factors such as your own experience and resource availability.

Stage Two - Set marketing objectives.

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SMART Objectives.

Specific - Be precise about what you are going to achieve. Measurable - Quantify you objectives. Achievable - Are you attempting too much? Realistic - Do you have the resource to make the objective happen (men, money, machines, materials, and minutes)? Timed - State when you will achieve the objective (within a month? By February 2010?).

If you don't make your objective SMART, it will be too vague and will not be realized. Remember that the rest of the plan hinges on the objective. If it is not correct, the plan may fail.

Stage Three - Describe your target market

Which segment? How will we target the segment? How should we position within the segment? Why this segment and not a different one? (This will focus the mind). Define the segment in terms of demographics and lifestyle. Show how you intend to 'position' your product or service within that segment. Use other tools to assist in strategic marketing decisions such as Boston Matrix, An offs Matrix, Bowmans Strategy Clock, Porter's Competitive Strategies, etc.

Stage Four - Marketing Tactics.

Convert the strategy into the marketing mix (also known as the 4Ps). These are your marketing tactics.

Price Will you cost plus, skim, match the competition or penetrate the market? Place Will you market direct, use agents or distributors, etc? Product Sold individually, as part of a bundle, in bulk, etc? Promotion Which media will you use? E.g. sponsorship, radio advertising, sales force, point-of-sale, etc? Think of the mix elements as the ingredients of a 'cake mix'. You have eggs, milk, butter, and flour. However, if you alter the amount of each ingredient, you will influence the type of cake that you finish with.

Stage Five - Marketing Controls.

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Remember that there is no planning without control. Control is vital.

Start-up costs. Monthly budgets. Sales figure. Market share data. Consider the cycle of control.

Finally, write a short summary (or synopsis) which is placed at the front of the plan. This will help others to get acquainted with the plan without having to spend time reading it all. Place all supporting information into an appendix at the back of the plan.

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CHAPTER-8 An Abridged Overview of Bangladesh Leather Sector

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1.0 Status of the Export-Oriented Business Sector: Leather and Leather Goods The business sector leather and leather goods of the country, which experienced a major setback after the liberation of the country in 1971 due to the departure of the non-Bengali entrepreneurs, got a considerable push at the beginning of the 80s. During the 80s and the 90s some Tanneries and manufacturing units were setup and then began a new era for leather and leather goods sector of the country. So in place of raw leather Bangladesh began to export high-quality processed leather and various leather goods. The demand of leather goods, especially for footwear, increased progressively with the growth of the population and economic development not only in international but also in domestic market. For example from 1950 to 2000 has increased from 2.1 billion to 11.3 billion, i.e. by nearly 438%, far wicker than the population growth of the world. Besides, even during economic crisis the demand for main leather goods, especially footwear, remains fast unchanged, which indicates that leather and leather goods have a sound and stable world market. 2.0 International Market Situation and Export Prospect of Bangladesh Leather and Leather Goods The location of the production site for world leather goods and its consumers show that at present most of the leather goods are produced in so-called newly industrialized and developing countries. The majority of the products, however, are consumed by highly developed, affluent countries. World regional movement of the production site of leather goods show that it has been moving away from countries with high labor cost to countries with cheap labor cost. Besides, Bangladesh has a huge raw material base which provides extra opportunities for the development of this sector. These days world footwear production is absolutely being dominated by China, India, Thailand, Indonesia, Pakistan and other developing countries. Most of the leather goods, however, is being consumed by the USA, EU, Japan and Canada. The USA, EU, Japan and Canada are, however, consuming most of the leather goods. The experiences of China and India indicate that for the development of this sector foreign investment and transfer of know- how is vital. For this, however, international experiences should be studied and supportive policies worked out and implemented, as well as be constantly reviewed and improved.

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3.0 Problems and International Challenge of Bangladesh Export-Oriented Leather and Leather Goods Sector

Political instability; Insufficient initiatives to ensure development of this sector; Insufficient incentives for the development of this sector; Insufficient support for international marketing; Insufficient support for the improvement of quality and standard; Insufficient support to cope with environmental, child labour, and other vital international marketing issues; Underdeveloped infrastructure; Insufficient research and development initiatives and facilities; Inadequate training and educational facilities.

Besides, Bangladesh has been facing some international challenges. One of which is the dominance of the world market by China, India, Thailand, Indonesia, etc. These countries are relatively stable politically and developed, have big local markets and are preferred by foreign investors and buyers. The International image problem is another constraint, which hinders high value addition. Internationally Bangladesh is known as a low-quality and cheap goods producer country which does not care for environment and employs child labour. Furthermore, the world market is dominated by consumers and there is hard international competition to gain and increase market share- which demands that the quality of the products constantly be improved and the price of products be competitive. Moreover, the global market demands that environmental issue, question of quality, design, material usage, prices and after sales services must be kept in consideration and all necessary development and marketing steps must be initiated. 4. Recommendations On the basis of its findings the study recommends that the following steps must be taken to support the development of this sector: 4.1 National Political Measures

Introducing measures to ensure national political consensus so that under all political circumstances that export remains unaffected. Introducing sound law and order situation so that all operations of the export-oriented industry can take place without interruption or hindrance; Social and economic condition of the workers should be improved so that politically motivated forces do not find the upper hand from labour organisation and disrupt the Labour-Management relationship.

4.2 Development Measures

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Strengthening co-operation & co-ordination between regulators, policy makers and stakeholders of this sector; Introducing financial incentives and other necessary supporting policies to raise investment and productivity, improve quality and make this sector internationally competitive; Supporting the establishment of linkage industries such as lasts, cutting dies etc to reduce high import dependence and promote price competitiveness of this sector in international market; Enabling Duty-Free imports of rawhides and skins as well as wet blue and finished leather for leather footwear exporters; Promoting technological modernisation of this sector, enabling adaptation of new and modern technology and sending high-level delegations to China, India, Thailand, Pakistan, Uruguay, Paraguay, Bolivia, Panama, Mexico, etc. Supporting the up-gradation of the components and industries like lasts, cutting dies and shoe trims through duty concessions, duty-free stock facilities, etc.; Introducing financial and other incentives to increase local investment in this sector; Ensuring legal, institutional and other supports for the development of backward linkage industries of this sector; Introducing attractive incentives and non-bureaucratic and easy operating policies to promote foreign investment in this sector.

4.3 Marketing Support Measures

Supporting diversification of export products; Supporting the exporters of this sector by visiting important international footwear and leather trade fairs; Supporting a marketing campaign especially in Canada, USA, EU and Japan to promote the image "MADE IN BANGLADESH"; Supporting sellers-buyers meetings; Ensuring consumer safety and International Standard of packaging to improve marketing of leather and leather goods; Ensuring occupational safety and labour compliance issues to improve international reputation and image; Introducing effective measures to protect the environment and improve international image and reputation; Opening the local market for exporters of this sector, with a well-though through taxation access, so that exporters they do not suffer from stock lots due to cancellations of export orders and that there is healthy competition in the local market; Well thought discrepancy in the import policy should be introduced to support value addition and reduce import, this means, introduction of import duty on finished shoes and shoe components and accessories so that import of finished product decreases; Taking the initiative to wake producers and exporters aware of international quality standards, Eco-labelling and packaging, occupational standards and environmental management requirements and their growing importance to foreign markets; Supporting quality management and improvement, export documentation, and in the cases of difficulties, ensuring payment from abroad;

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Supporting efforts for market diversification, i.e. expanding market in the countries other than USA, EU, Japan and Canada;

4.4 Financial Measures

Ensuring direct fiscal incentives in the form of export cash subsidies, import license benefits against export performance, tax-free export earnings, reduced airfreight costs, duty drawback, etc to promote export; Introducing an export credit guarantee scheme to retain export earnings as foreign exchange; Providing financial supports for backward linkage industries of this sector; Exempting tax and VAT from export of this sector much like what is done with Ready Made Garments (RMG); Introducing open account facilities or likely systems in place of L/C, should be introduced to promote export in this sector; Developing and introducing of new and innovative payment terms for buyers to retain competitive advantage; Carefully adjusting the national currency to other currencies especially that of the international competitors' or introducing dual exchange rate to support export of this sector; Providing long-term Tax Holiday to encourage local and foreign investment in this sector; Making value addition for high value items flexible so that high value-added leather and leather goods become competitive in the international market; Removing all anomalies and corruption from bank operations.

4.5 Infrastructural Supporting Measures

Removing all Port congestion so that the export-import operation can take place without any delay; Ensuring rush free and well-developed national transport system so that communication among export-oriented industries of this sector and transport of goods to the ports can take place without any delays; Regulating shipment charges so that it does not affect the competitiveness of this sector; Introducing measures to ensure uninterrupted power supply; Equipping custom offices with modern information and other technology to ensure prompt custom service; Removing all anomalies and corruption from custom services.

4.6 Development Management and Institutional Measures

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Establishing world class training and research facilities such as a Leather Research Institute, Footwear Development and Design Institute and manning these with highly experienced and trained instructors and consultants to ensure development of this sector; Establishing design, product development and product testing capability for this sector.

4.7 Measures to Ensure Proper Development of Human Resource

Creating education facilities for potential employees and workers of this sector; Creating Training facilities for potential employees of this sector; Creating training opportunities for the workers of this sector; Organizing workshops, seminars and symposiums to explain the laborers the necessity and importance of discipline and quality work and improved productivity for export, national economic development and welfare of the workers themselves.

4.8Different Table Shows the Different status of Bangladesh Leather Sector at Different Time

Table 1: Composition of Leather Industry and Production Capacity in 1997 Type of industry Units Annual production capacity Tanneries and its production capacity Tanneries Product 65 230 mill sft Export Oriented Leather product industries and its production capacity Export-oriented leather footwear 21 22 million pairs Export-oriented leather 16 1.5 million pieces Export oriented leather goods 29 10 million Pieces (Sft: Square Feet) Source: 2nd Dhaka Leather Goods Fair 1997, GTZ, Dhaka 1997, page22

Table 2: Development of the export of leather and leather goods from 1990 to 1999 (Million US $)
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Year 1990 1991 1992 1993 Year 1994 1995 1996 1997

Leather 134.29 144.46 147.0 168.17 Leather 202.08 211.70 195.26 190.26

Leather Goods 2.84 4.39 10.72 23.84 Leather Bags Footwear 6.33 12.54 6.96 19.13 3.81 17.78 4.47 38.02

Total 137.13 148.85 157.72 192.02 220,95 237.79 216.85 232.75

Source: 2nd Dhaka Leather Goods Fair 1997, GTZ, Dhaka 1997, page 25.

The data from Table 2 show that the export of leather and leather goods has grown relatively fast during the last decade, after 1994 certain changes haven taken place in the structure of the export of leather goods. The export of leather bags has shrunk rapidly; while the export of footwear has grown at approximately the previous rate. The reason for this lopsided development is the lack of emphasis on product diversification. World market and introduce supporting policies for the development of this sector accordingly. Table 3: Development of the world population (in million) and the footwear production(in million pairs) from 1950 to 2005 Category/Year 1950 1970 Footwear 2,100 4,881 Population 2,250 3,697 1980 7,972 4,444 1990 9,794 5,285 1995 10,300 5,702 1998 2000 2005 11,300 12,300 14,500 6,158 6,594

Source: Market Report, Fashion Trends and Forecasts up to 2005, Steve Lee, Sam 4/1998, page 4 & 13.

At the same time comparison of the value of export of Bangladesh leather and leather goods shows that although the export value grew rapidly, from US$ 137.13 million in 1991 to US $ 233.75 million in 1997 (table 2), it still comprises less than 0.50% of the world trade value (Table 4). Besides, 91% of the export value comes from the export of leather. It means that this sector has all the potential to grow equally fast (table 4) as both sufficient raw materials and cheap labor are available in Bangladesh

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Table 4: World and Bangladesh trade value (in million US$) in leather and leather goods in 1994-95 Share of leather and leather goods at total export of this sector (%) 91% 9% 100%

Type of product World total Bangladesh Share at world export trade (%) Leather 17,264.07 202.08 1.17 Leather goods 26,287.58 18.87 0.07 Total 4,3551.65 220.95 0.50

Source: 2nd Dhaka Leather Goods Fair 1997, GTZ, Dhaka 1997, page 26.

Table 5: Development of Production, Export, Import and Consumption of Footwear (in million pairs)in Asia Pacific from 1990 to 2005

Year WE EE ME/A AM AP Total 1990 1147 1297 603 1369 5378 9794 1991 1103 1063 604 1251 5442 9463 1992 1102 630 504 1413 5720 9369 1993 1075 620 530 1430 5895 9550 1994 1080 640 530 1460 6200 9910 1995 1100 700 550 1500 6450 10300 1996 1120 750 600 1550 6780 10800 1998 1160 850 610 1500 7180 11300 2000* 1180 950 650 1600 7900 12280 2005* 1250 1200 800 1700 9300 14250 Estimated from trend, (WE: West Europe, EE: East Europe, ME/A: Middle East/ Africa, AM: America, AP: Asia Pacific) Source: Market Report, Fashion Trends and Forecasts up to 2005, Steve Lee, Sam 4/1998, page 13 Table 5 shows that the Asia Pacific share of the world footwear production has been increasing steadily since 1990. In 1990 if accounted for only 54.91% of the world production, and in 2000 it will reach an estimated 65.26%. The production of West Europe sank in the mid 90s and then recovered slightly; the production of East Europe suffered a setback in the last decade because of political change, which forced those countries to adapt to the global market situation. The production of Middle East and Africa remained nearly unchanged till the end of the last century, and it is estimated that in the next few years it will increase. The production of America has increased during this period and will increase in the years to come. In this relation it must mentioned, however, that the production of Brazil, Argentina and other developing countries from Latin and central America has grown whilst that of USA and Canada have shrunk. The data of Table 5 indicates that the footwear production is dominated by newly developed, developing and least developed countries. So countries like Bangladesh have all the opportunities to earn an increasingly higher share of the world market. The production,
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export and consumption data of the countries of Asia Pacific (Table 6) undoubtedly support this conclusion. China, India and Indonesia who produce most of the footwear of the world also export most of the footwear of the world. China for example produced in 1994, 3,850 million pairs of footwear out of which it exported 2,160 million pairs; India produced 580 million pairs and exported 100 million pairs and Indonesia produced 436 million pairs and exported 268 million pairs. It is expected that in 2000, China and India will produce and consume 4,600 and 810, and 2,600 and 250 pairs of footwear respectively. Further, it is expected that in the next few years the export of India will increase faster. In addition, India's own consumption will increase faster and its local market has a vast potential. Other Asia Pacific countries like Indonesia, Thailand, Pakistan and South Korea have been increasing their share of the world footwear market for over one decade. The Table 6 shows that the newly developed and developing countries are not only dominating the world market but also, with their growing economic well-being, increasingly consuming more and more footwear and other leather goods. This means that these countries are not solely dependent on foreign markets but have also their own market, which ensures sustainable development of this sector.

Table 6: Development of Production, Import, Export and Consumption of Footwear in Asia Pacific from 1994 to 2000 (million pairs) 2000 Prod. Import Export 4,600 35 2,600 810 15 250 650 12 415 245 380 3 220 1 23 210 27 100 145 24 90 450 11 350 340 2 265 258 135 98 7,928 643 4,194

1994 Prod. Import Export China 3,850 6 2,160 India 580 2 100 Indonesia 436 2 268 Japan 245 340 6 Pakistan 175 1 9 S. Korea 210 14 126 Taiwan 145 8 108 Thailand 390 1 277 Vietnam 135 1 75 Others 236 116 79 Total 6,402 491 3,208

Cons. 1,696 482 170 579 167 98 45 114 61 273 3,685

Cons. 2,035 575 247 622 198 137 79 111 77 296 4,377

Source: Market Report, Fashion Trends and Forecasts up to 2005, Steve Lee, am 4/1998, page 11.

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 Table 6: Export Volume and Value of leather and Footwear According to Metropolitan Chamber of Commerce and Industry, Dhaka.

Items Leather Footwear

EXPORTS (VOLUME AND VALUE) 2006-07 2007-08 (P) Value Value Volume (million) Volume (million) (million US$) (million US$) 53.75 sft 266.08 61.16 sft 284.41 135.94 169.60 2005-06 2006-07 (P) Value (million US$) 53.75 sft 266.08 135.94 2005-06 (P) Value Volume (million) (million US$) 77.77 sft 261.87 sft 98.47 2004-05 (P) Value Volume (million) (million US$) 62.96 sft 214 sft 84 Volume (million)

Items Leather Footwear Items Leather Footwear Items Leather Footwear

Value (million US$) 76.57sft 257.27 95.44 2004-05 Value Volume (million) (million US$) 59.71 sft 220.93 87.55 2003-04 Value Volume (million) (million US$) 72.15 sft 211.41 68.30 Volume (million)

5. Conclusion

It has studied development prospect of the leather and leather goods sector especially its vast potential to increase export and thus formulated a set of recommendations to ensure its development. It is hoped that all concerned will pay due consideration to the recommendations, which are not only essential for the expected contribution of this sector but also for the economic development of the country.

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C AT R H P E -9 F L IE D S R E UVY

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FIELD SURVEY Bangladesh is exporting leather to different countries of the world such as Italy, Korea, China, Hong Kong, French, Germany, Japan, Spain etc. Though the EU members has banned certain hazardous materials like azo dyes, PCP, cadmium, polychlorinated biphenyles (PCB) and teraphenyles (PCT). In Germany, for example, products containing pentachlorophenol (PCP) have been banned for several years, and the use of hazardous substances, such as dioxin and formaldehyde, has been restricted but most of the tanning industries are not aware of using banned chemicals. The leather industries do not follow ISO standard testing method. But they follow the ILO labor rules somewhat. Most of the leather industries have no waste management system and recycling plant. The workers of the industries are not conscious about the hazardous impact of various toxic chemicals though they are using them frequently. Beside of this most of the tanning industries do not follow the EU rules on product safety. Some of the companies have bonded warehouse facilities.

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C AT R 0 H P E -1 C M L N EINT R S O P IA C E M O M R E IN F AKT G

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ANALYZING PRESENT SITUATION OF COMPLIANCE IN TERMS OF MARKETING

The leather and footwear industry has also been affected by bans or limitations in the use of certain hazardous materials such as azo dyes, PCP, cadmium, polychlorinated biphenyles (PCB) and teraphenyles (PCT). In Germany, for example, products containing pentachlorophenol (PCP) have been banned for several years, and the use of hazardous substances, such as dioxin and formaldehyde, has been restricted, affecting leather exports from developing countries.

Example of China: The PCP content in Chinese leather has been considered too high in several European countries. Since a large share of leather products go to OECD countries the limits on the use of PCP in leather can affect Chinese exports of this product. Leather exports are also potentially affected by regulations regarding dyestuffs. Concern is linked to the fact that compliance costs with external environment PPM related regulations are likely to increase and impact on competitiveness since most exports from China tend to compete in the OECD market largely on account of their low prices.

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Example of India 34. According to a case study carried out in 1995, several environment related regulations affected India's performance on the international market. Germany has banned the use of PCP and in the ED the threshold was of 1000 ppm. The use of formaldehyde has also been limited in Germany. As the use of chemicals which are preferable to the environment have become mandatory, this have restricted the process by which leather may be manufactured. At the time the case study was carried out, most tanneries were resorting to the use of an imported substitute, BUSAN 30, which is acceptable to the external market. The price of this substitute is deemed on average to be ten times higher than the price of PCP. All chemical inputs together accounted for approximately 10 per cent of costs and was considered likely to affect the competitiveness of leather products. The costs of compliance with external requirements were considered hard to estimate but it was felt that the cost of the tests alone could increase the price of shoes by $3-$4 per pair. Overall, exporters stated that the cost of replacing all chemicals with environmentally preferable ones raised total costs by 10 to 15 per cent. These costs were considered particularly onerous for SMEs that represent 70 per cent of the total leather exports from India.

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C AT R 1 H P E -1 S G ET N U G S IO

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SUGGESTION:
In order to reduce the likelihood that environmental requirements and standards will restrict trade, a number of policy measures can be considered as: The harmonization of product standards; The recognition by importing countries of tests, verification and certification conducted in exporting countries; Access to information and transparency; Facilitating the access to and transfer of technology; Financial and technical assistance ; Due implementation of measures on special and differential treatment included in the SPS and TBT agreements, At the national level, in the exporting country, Government and the business sector can adopt policies and measures aimed at promoting standards and quality with a view to enhancing trade performance. These include: Establishing and/or improving supporting infrastructure and human capabilities; Dissemination of information; Promoting cooperation between the Government and the business community; Promoting cooperation between retailers/importers and producers/exporters. A number of issues should also be considered at the bilateral or multilateral level with trading partners, including in relevant international forum such as the WTO: Capacity constraints requiring technical and technological solutions may not be overcome only by efforts of the Government.

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International Cooperation may be necessary in this area. The reviews of TBT and SPS agreement should factor these constraints into the recommendations for changes or special and differential treatment. Capacity building is also necessary to overcome market diversion or distress sales. The exporters need to be advised to shed their fears of market loss and report distress sales to the Government so that environment and health related requirements could be analyzed for possible disguised protectionism. The enquiry points for TBT and SPS Agreements need to create institutional support for the dissemination of drafts standards notified in the WTO to exporters and to get their feedback for sending comments to Governments abroad. Where standards in the producing country differ from standards in the buyers market, equivalence may be attempted, particularly where harmonization is not possible because of domestic constraints or incapability of foreign standards to local conditions. At last we can say, in order to avoid potential barriers to trade, developing country like Bangladesh should focus on developing national infrastructure and human capacities for the elaboration of national standards and the setting up of a proper system of testing, verification, control and certification of national products.

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C AT R 2 H P E -1 C NL S N O C U IO

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CONCLUSION The export earnings from leather sector have increased significantly. Leather sector has the potentiality of earning a huge amount of foreign exchange to develop our country economy as well. Market access is a key issue for a developing country like Bangladesh. Developing countries have been concerned for various compliances(such as social, chemical, environmental, safety) imposed on their exporting trade. Domestic environmental policies in the developed countries may deny market access to products from developing countries. This is because producers in developing countries may lack the technical and financial ability to comply with the environmental regulations of the industrialized nations. Developing countries are also particularly concerned about the emergence of environmental policies based on PPMs, which may not reflect their environmental priorities. There is no empirical evidence to suggest that existing environmental policies have widespread effects on market access. However, effects could be more significant for some sectors and for SMEs. Environmental policies may have differentiated competitiveness effects on developed and developing countries. After completing my project work it is crystal clear that it is very necessary to follow various compliance to export leather to the world market without arty barrier. Some of the companies are trying to follow the compliance according to the buyers satisfaction. But most of the tanning industries of our country do not maintain various compliances strictly.

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C AT R 3 H P E -1 Q ET N A E U S IO N IR

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ANNEXTURE Questionnaire
1. What is your name? Ans: 2. How long are you serving in this sector? Ans: 3. How many employees are there in your company? Ans: 4. Which kind of leather do you produce? Ans: Article Wet-blue Crust Finished 5. Have you ever faced any kind of problem to export your leather? Ans: 6. Which kind of problem did you face? Ans: 7. Has your leather been returned back any time? Ans: 8. Why has your leather been returned back? Ans: Amount (sq.ft)

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9. Did you recover the problem? Ans: 10. How did you recover that problem? Ans: 11. In which countries do you export your leather? Ans: 12. What types of criteria of a leather does a buyer demand in term of quality? Ans: 13. Does it require to make a test report of leather for quality to export your product? Ans: 14. Do they want test report with your leather? Ans: 15. Do you follow the international management system: ISO-14001 on environment? Ans: 16. Do you have any recycling plant in your industry? Ans: 17. Do you have any waste management system? Ans:
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18. Do you follow the international ILO standard on working condition? Ans: 19. Is there any under aged employee in your industry? Ans: 20. Do you pay them according to the international ILO standard on working condition? Ans: 21. How long do they stay in your industry for working purpose? Ans: 22. Do you follow the EU-rules on product safety? Ans: 23. Do you use restricted or banned chemicals to make your leather? Ans: 24. Are your workers aware of the detrimental impacts of banned chemicals? Ans: 25. Have any conflagration occurred in your industry? Ans: 26. Is, there any fire extinguisher in your industry? Ans: 27. Do you have alternative way in your company to exit if any accident occurs? Ans: 28. Do you have supply of pure drinking water for the worker? Ans:

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29. Do you maintain international management system: ISO 9000 on quality? Ans: 30. Do you maintain supply chain management according to market access requirements? Ans: 31. Do you maintain international management system on process control? Ans: 32. Are you aware of the compliances imposed on exporting leather to other countries? Ans: 33. Did you ever get any kind of quota facilities? Ans: 34. Do you have bonded warehouse facilities in your industry? Ans: 35. Do you have any assistance for opening exporter's offices in abroad? Ans: 36. Do they want any security compliance of your product from you? Ans:

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BIBLIOGRAPHY
1. UNCTAD, the Least developed Countries 1998 Report, United Nations, New York and Geneva, 1998 2. WTO, Technical Barriers to the market access of developing Countries, restricted, WT/CTE/W/101, G/TBT/103, 25 January 1999. 3. Eco-labeling Manual, Environmental Challenges for exporting to the European Union, August 1998. 4. UNCTAD, Future Multilateral Trade Negotiators; from Least developed Countries, United Nations, New York and Geneva, 1999. 5. The Bangladesh Labor Code 2006. 6. Bangladesh Garment Development Corporation (gpz) 7. Reports on workers right and working conditions into export oriented garment section in Bangladesh. Prepared by-Farhan Akhter 8. Report on Environmental Safety By Ms Ishrat Jabee, Lecture, Development of Environmental Science and Technology North South University 9. Reports on Management system of health safety and environment Prepared by- Chowdhary Nishat BCAS. 12. Environment and Labor law and Rules Prepared by- Barrister Fatema & Chowdhary. 13. www.wikepedia.com 14. MCCI

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