Karachi Industry

About the Author
Farhan Anwar did his Bachelor in Civil Engineering and Master in Urban and Regional
Planning. His portfolio includes urban sustainability planning, smart cities, public policy,
climate adaptation, urban resilience, institutional strengthening and change management.
He has extended consulting services to the World Bank, Asian Development Bank (ADB),
the Japanese International Corporation Agency (JICA), the World Conservation Union
(IUCN), WWF Pakistan and several prominent Pakistani consulting firms. Anwar is a Member,
Provincial National Climate Change Policy Implementation Committee, Government of
Sindh. Anwar is also a Member, IUCN Commission on Environmental, Economic and Social
Policy (CEESP) and the Standing Committee on Environment – Federation of Pakistan
Chambers of Commerce and Industry (FPCCI). He presently serves as a Visiting Faculty at the Indus Valley
School of Arts & Architecture, Karachi, where he teaches Bachelors Course in Architecture on Urban Theories
and Urban Open Space Design. He is also a Visiting Faculty, at the Department of Architecture & Planning,
NED University of Engineering & Technology, Karachi - teaching Human Development in the Bachelors Course
on Development Studies. Anwar is the Lead Author of the Sanitation Strategy, Government of Sindh and the
Author of Pakistan’s National Strategy and Action Plan for the Mangroves of the Future Regional Program.
He has a number of publications to his credit and contributes a weekly column – Elasti-cities focused on urban
planning, environment, and development issues of Karachi City in the Express Tribune Newspaper.
fanwar@sustainableinitiatives.org.pk
The author will welcome reproduction and dissemination of the contents of this report with proper acknowledgement.
Shehri - Citizens for a Better Environment
88-R, Block 2, P.E.C.H.S. Karachi 75400 – Pakistan
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E-mail: info@shehri.org
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Tel: +92-51-2 65 57 50, 2 65 57 51
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No of printed copies: 1,500
First Edition: 2015
ISBN: 978-969-629-159-6
Disclaimer:
Every effort has been made to ensure the accuracy of the contents of this publication. The author or the organization do not accept
any responsibility of any omission as it is not deliberate. Nevertheless, we will appreciate provision of accurate information to
improve our work. The views expressed in this report do not necessarily represent the views of the Friedrich-Naumann-Stiftung
für die Freiheit.
CONTENTS
Introduction 00
KARACHI’S INDUSTRIAL ESTATES: AN ENVIRONMENTAL ASSESSMENT
A. Context 00
B. Profiling The Industrial Estates In Karachi Focus On Site And Kite 00
C. Environmental And Social Concerns 00
D. Engaging The Citiens Environmental Assessment Survey 00
Conclusions 00
ENVIRONMENTAL LAWS RELEVANT TO NON-EXTRACTIVE INDUSTRY,
COMMERCIAL OPERATIONS APPLICABLE IN THE PROVINCE OF SINDH
Karachi Building And Town Planning Regulatins 2002
Notifcatin No. So(Land)Htp/Kbca-3-39/2000 00
Pakistan Environmental Protectin Act 1997 (No. XXXIv) 00
Hospital Waste Management Rules 2005
Sro 1013(1)/2005 Dated 3 August 2005 00
Pakistan Environmental
Protectin Agency Review of Initil Environmental
Examinatin and Nvironmental Impact Assessment
Regulatins 2000 Sro 339(I)/2000 Dated 13 June 2000 00
Natinal Environmental Quality Standards
Sro 742(I)/93 Dated 29 August 1993 00
Coastal Development Authority Act 1994 (No. XXvIII) 00
Sindh Small Industries Corporatin Act 1972 (No. XXvI) 00
Sindh Industries (Control on Establishment and Enlargement)
Ordinance 1963 (Wp No. Iv) 00
Sugar Factories Control Act 1950 (Nwfp No. XXII) 00
Factories Act 1934 (No. XXv) 00
0
Sindh Factories Rules 1975 00
Boilers Act 1923 (No. v) 00
PAKISTAN ENVIRONMENTAL LEGISLATION
AND THE NATIONAL ENVIRONMENTAL QUALITY STANDARDS 00
NEQS INDUSTRIAL GAS 00
SURVEY QUESTIONNAIRE 00
INTRODUCTION
Karachi is faced with a number of development challenges. The city is

expanding both vertically and horizontally without any viable planning
framework or regulatory mechanisms channeling its growth. Land use is
being violated, civic services are crumbling and the many responsible
institutions for local and urban governance are facing institutional bankruptcy
and failing to deliver on their mandates. A very significant outcome of this
urban decay is the rising levels of urban pollution and the resultant
environmental degradation.
Pollution is generated from a number of urban activities, including industrial.

Karachi has a large industrial base with a number of Industrial Estates spread
across the city. These Estates were originally placed on the urban periphery
of Karachi but as the city spread over the years these Industrial Estates are
now surrounded by human settlements - both residential and commercial
in nature.
As is the case with other urban activities in Karachi, the industrial sector is
poorly regulated when it comes to monitoring and checking the industrial
liquid and solid wastes and air emissions. While some research has been
conducted on the scale of untreated liquid industrial discharge on the coastal
ecology and urban vegetation, there is very limited data or research available
on the adverse impact on the people and land in the surroundings of these
Industrial Estates.
Through this research study, Shehri-Citizens has tried to document the views
of the people living in close proximity to the largest Industrial Estates in
Karachi, the Sindh Industrial Trading Estate (SITE) and Korangi Industrial
Trading Estate (KITE). A number of related aspects have been documented
such as impacts on health - psychological and physical health, the multiple
causes of pollution such as liquid, solid wastes, air and noise pollution etc.
The types of pollution have also been related with the type of industrial
activities such as air emissions from stacks, vehicular pollution, liquid discharge
and solid waste dumping. Also documented have been issues such land
encroachments and industrial accidents and the response of government
and industry to citizen complaints.
It is hoped that this study would contribute in efforts to bring into the
regulatory net the environmental aspects of industrial activities. The issue
has now gained even greater importance and urgency in the wake of the
realization of how drastically the global climate is being impacted in terms
of climate change brought about by concentration of green house gases in
the atmosphere.
Amber Alibhai
General Secretary
Shehri-CBE
November, 2015
1
KARACHI'S INDUSTRIAL ESTATES:
AN ENVIRONMENTAL ASSESSMENT
A. Context
Industrialization is important for accelerating economic growth. However, unregulated practices and
unchecked industrial processes have a damaging impact on the surrounding settlements and overall
environment in general, that can easily not only negate the monetary gains but also cause irredeemable
damage to the environment and health of citizens.
Karachi, the largest metropolis of Pakistan, has a population of over 20 million with a significant industrial
and financial base. It is a city that generates 65% of the total national revenue and promises economic
prosperity and growth for millions in the country. However, the city is also beset with high levels of
environmental degradation that are rooted in a crisis of urban governance. Within this context, the weakly
regulated industrial estates in Karachi, operating with minimal environmental safeguards are considered
as major sources of environmental pollution in the city - both land based and also via discharges of their
mostly untreated liquid wastes into precious coastal ecosystems.
There are currently over 6000 big and small registered industrial units operating in Karachi. These industrial
units are located in Sindh Industrial Trading Estate (SITE), Landhi, Korangi, Malir and the Port Qasim
Authority area (PQA). There are more than 65 categories of industrial plants in the established industrial
estates including, textile industries, tanneries , pharmaceuticals, plastic and rubber industries, steel
foundries, metallurgical industries, electroplating and metal coating industries, glass, ceramics and tiles
industries, cement industry, soap and detergents, fish processing industries, chemical industries, power
plants, fertilizers and pesticides, edible oils, automobile cable and conductor manufacturing etc.1
This study aims to undertake a systemic study to evaluate the impact of two major industrial estates in
Karachi, namely, Sindh Industrial Trading Estate (SITE) and Korangi Industrial Trading Estate (KITE), as
perceived and experienced by area residents and industrial employees. While significant research has
been conducted on the technical aspects and pollution data of the industrial estates, there is minimal
documentation of how those people who are most probably the worst effected in terms of their physical
exposure, are being impacted in terms of the social, environmental and economic implications. Industrial
emissions are also a major cause of carbon and greenhouse gas emissions that as a consequence are
bringing about climate change - now considered as the foremost challenge facing mankind. The aspect
of climate change will also be considered and accommodated in the project research work.
B. Profiling the Industrial Estates in Karachi - Focus on SITE and KITE

This section focusses on the industrial sector in Karachi, covering various aspects such as the historical
growth of the sector, the system of administration and management and the environmental and social
implications relevant to industrial activities in the city.
1. Strategy for Industrial Waste Water and Pollution Control, Pakistan Business Review, October 2010, Dr. Shahid Amjad, College of Computer
Science and Information Systems, Institute of Business Management, Karachi.
2
Karachi's Industrial Estates: An Environmental Assessment
Historical Growth of Industrial Estates in Karachi

During the colonial period, a few small industries were established at Nishter Road (Lawrence Road) in Karachi.
Dalmia Cement Factory was established in 1924 in what constituted as the suburban areas of Karachi at that
time. Industrial growth gained momentum after the creation of Pakistan. Adjacent to Karachi Port at the West
Warf area, an industrial area was established in 1947, known as Karachi Port Trust Industrial Area. The location
of the port and proximity to the city center was considered important incentives to attract investors to this
area where infrastructure like roads, railways, electricity etc. were available. Offices of traders, shipping
companies and Government offices were located near to the industrial area. The area was also accessible
to the industrial workers and as a result, the industrial area was soon occupied by large and medium size
industries. In 1948, SITE was established and is now the largest industrial estate of Karachi (Karachi Development
Authority-KDA-, 1964). In 1958, under Greater Karachi Resettlement Schemes (GKRS), the Government planned
to develop industrial areas at Landhi and Korangi to provide employment to the newly developed satellite
towns. The Government policy of denationalization and privatization in the 1970s and 1980s, completion of
Malir River Embankment Project in 1987 and improvement in infrastructure accelerated industrial development
in the Korangi and Landhi Industrial Areas (KDA, 1974). The small industrial areas of Mansoora (Federal B
Area) and North Karachi were developed in the 1960s and 1970s as part of residential schemes located along
the Layari River. In the 1980s, the Government established three new industrial areas, Karachi Export Processing
Zone, Bin Qasim Industrial Area and Super Highway Industrial Estate at the periphery of the city (KDA, 1990).
Textile is the most dominant of all industrial categories in Karachi. Other important industries are food
processing, tannery and leather goods, chemical and pharmaceutical, auto industries, shipyard, oil refineries,
metal industries and printing.
Salient Features of the Industrial Sector in Karachi

The general pattern of industrial land use in Karachi is that industrial areas are located far away from the
more settled and high value residential areas and closer to the residential areas inhabited by lower income
communities. Industrial land use occupies about 75 sq. km. area, which is about 4.6 per cent of the total city
area. Industries are located in 12 scattered areas. Most of them were originally developed in the suburbs
and at the outskirts of the city, but with the growth of the city some of them are now surrounded by residential
areas. Industrial areas in Karachi exhibit marked variation in land values.
The Karachi Port Trust Industrial Area is a small industrial area occupying about 2 sq. km consisting of 20
industrial units including two large size industries, namely, the Karachi Shipyard and Engineering and Naval
Dockyard. Additionally, oil depots and oil processing plants, ghee, edible oil, pharmaceutical, chemical and
motor vehicle assembling factories are also located in this area.
SITE is located about 5 km north-west of the city center and is spread over approximately an 18 sq. km. area.
In terms of industrial establishments it is the largest industrial area of the city (SITE, 1995) with textiles,
chemical, re-rolling mills, pharmaceutical, food and beverage, and auto vehicle assembling plants being the
main industries (Table1).
3
The Korangi Industrial Area was established in 1960 and is located about 14 km south-east of the city center
along the Malir River. Its total area is about 34 sq. km. The major industries in this area include tannery and
leather products, textile, chemical, food and engineering. Two large oil refineries are also located in this
industrial area (Korangi Industrial Area, 2000).
Federal B Industrial Area (Mansoora) is a small industrial area occupying about 2 sq. km located about 15 km
from the city center and is mainly dominated by cottage industries. Originally established in 1960 by Karachi
Development Authority (KDA) on the periphery of Karachi as a part of Federal B Area (Mansoora) Housing
Scheme, with two blocks (21 and 22) allocated for industries, the area now falls within the populated area
of Karachi (Federal B Industrial Area, 2000).
Landhi Industrial Area, New Karachi Industrial Area and Karachi Export Processing Zone are all located on the
outskirts of the city. Landhi Industrial Area was established in 1958. It is located at a distance of 21 km from
the city center. Its total area including extension of Landhi Industrial Area is about 5 sq. km. There are 300
industrial units of different categories mainly textile, food, chemical, pharmaceutical, engineering. North
4
Organizational Chart of SITE (Board of Directors)

SITE Ltd., is governed by Board of Directors consisting of 15 Members (8 from Government officials and 7
from Tenants of SITE). Managing Director is the Chief Executive Officer of the Company appointed by the
Government of Sindh
1. Secretary Industries Department

2. Secretary, Planning & Development Department
3. Secretary, Excise & Taxation Dept.
4. Managing Director, Sui Southern Gas Co. Ltd.
5. Chief Executive Officer, K.E.S.C.
6. Managing Director, KW & SB
7. Chairman, Area Electricity Board, Hyderabad
8. Managing Director SITE Limited
9. M. Nisar Shekhani, Chairman, SITE Association of Industry, Karachi
10. Mr. Arshad Tanveer, Tenant Directors from SITE Karachi
11. Mr. Mr. Abdullah Rafi, Tenant Directors from SITE Karachi
12. Dr. Arshad Vohra, Tenant Director from SITE Super Highway Karachi
13. Mr. Siraj Kasam Taili, Tenant Director from SITE Nooriabad
14. Mr. Mazharul Haq, Tenant Director from SITE Hyderabad/Kotri
15. Mr. Khalad Mehmood Khan, Tenant Director from SITE Sukkur
5
Karachi's Industrial Estates: An Environmental Assessment Karachi's Industrial Estates: An Environmental Assessment
SITE INDUSTRIAL AREA
6 7
Karachi's Industrial Estates: An Environmental Assessment Karachi's Industrial Estates: An Environmental Assessment
8 9
KITE - The Korangi Industrial area is administered by the Korangi Association of Trade & Industry (KATI). All
the industries located within the area are members of KATI and the Association's mandate is administered
by an Executive Committee headed by a Patron-in Chief and a number of Standing Committees, the names
of which are listed below:
Organizational Chart of KATI (Executive Committee)

Patron-in-Chief: Mr. S.M. Muneer
President: Mr. Zahid Zaeed
Sr. Vice President: Mr. Saleem-uz-Zaman
Vice President: Mr. Syed Wajid Hussain
Member: Mr. Rashid Ahmed Siddiqui
Member: Mr. Nadeem Khan
Member: Mr. Faraz-ur-Rehman
Member: Mr. Zaki Ahmed Sharif
Member: Mr. Muhammad Ghazanfar Ali Khan
Member: Mr. Mahmood Hasan
Member: Mr. Syed Johar Ali Qandhari
Member: Mr. AmjadUllah Khan
Member: Mr. Tariq Malik
Member: Mr. Muhammad Danish Khan
Member: Mr. Saleem Uddin
Member: Mr. Rehan Jawed
Member: Mr. Juniad Naqi
Secretary, KATI Mr. Nihal Akhtar
KATI Standing Committees

• Export Insurance
• Health, Safety & Environment
• Information Technology
• FBR, SRB & Taxation
• Investments & Industrial Activities
• KATI Building & Tenants
• SSGC
• Diplomatic Affairs
• KATI Finance & Accounts
• Press & Media
C. Environmental and Social Concerns

Discussed below are some documented (secondary data) concerns regarding the environmental and social
implications of industrial activities in a larger context in Pakistan, Sindh province and in particular for the
SITE and KITE estates in Karachi.
10
Environmental Concerns
It is estimated that approximately 362 million gallons (MGD) of sewage and waste-water is generated in
Karachi and its adjacent areas everyday from domestic (approximately 40%) and industrial sources (approximately
60%). The industrial waste-water and sewage are discharged into the two seasonal rivers: the Lyari River and
the Malir River of Karachi. These rivers act as the main open sewers for liquid waste disposal from the city.
The Lyari and Malir Rivers contribute about 59% and 25% of the total pollution load of Karachi City respectively,
while 15% of the pollution load is directly discharged into the adjacentopen seacoast or discharged via the
Gizri, Korangi and Gharo Creeks (Amjad and Rizvi, 2000).
Much of the sewage effluents discharged through the Lyari River find their way inside the semi enclosed
Karachi Harborarea. During high and low tide, the discharged effluents oscillate within the Karachi Harbor
(length 8.2 Km). As far back as 1995, Ali and Jilani, conducted a chemical analysis of seawater samples taken
from the Korangi industrial area effluent discharge site and found that the values of heavy metal in seawater
far exceeded the permissible limits of the National Environment Quality Standards prescribed by the Pakistan
Environmental Protection Agency (NEQS, the Gazette of Pakistan 2000).
Harmful components such as heavy metals, suspended solids, oil and grease, salts etc., in the discharged
effluents, create a chemical imbalance and alter the chemistry of the seawater which subsequently enters
the coastal food chain. The tainted heavy metal seafood if consumed, can negatively impact the human brain,
causing nerve damage, damage to the kidneys, and may also cause birth defects. Absorption of excessive
levels of carbon dioxide in the surface seawater also lowers the pH of seawater converting it into a weak acid
(Carbonicacid) and such altered seawater chemistry can be corrosive for vessels, harbor crafts and coastal
installations.2 Additionally, such altered seawater chemistry is also injurious to the environmental health of
a productive coastal ecosystem.
Karachi has a population of about 20 million and generates approximately 12,000 tons of domestic solid waste
perday. Essentially, there is no arrangement for the disposal of hazardous solid waste except for the hazardous
waste from hospitals and the few garbage / refuse collection sites within the city. The solid waste; about 100
truckloads, is carried from the collection sites and taken away by vehicles (open trucks and specially designed
garbage vehicles) to either the composting center or to the two designated dumping / landfill sites for refuse
located in the outskirts of the city in Deh Jam Chakro landfill site near Surjani Town and Deh Gond Pass landfill
site near Hub Chowki.
The area surrounding SITE is densely populated and includes and is bordered by Gadap Town to the North,
Liaquatabad and North Nazimabad to the east across the Orangi stream, Lyari and Saddar to the South across
the Lyari River and Kemari to the West. The different types of industries operational in SITE include garments,
bonecrushing, coloring, metal processing, pharmaceutical, textile, chemicals and battery manufacturing
industries that discharge different kinds of waste effluents and solid waste which are polluting the soil of
2. Strategy for Industrial Waste Water and Pollution Control, Pakistan Business Review, October 2010, Dr. Shahid Amjad, College of Computer
Science and Information Systems, Institute of Business Management, Karachi.
11
nearby places, thus causing deleterious effects to plant communities of the industrial areas. In a study titled
'Vegetation Pattern and Soil Characteristics of the Polluted Industrial Area of Karachi', conducted by M. Kabir,
M. ZafarIqbal, Z.R. Farooqi and M. Shafiq of the Department of Botany, University of Karachi in the year 2010,
it was found that vegetation of the study area was very disturbed due to constructions of new industries day
by day. As during the establishment of new industries natural vegetation is destroyed on large scale if few
species survive in such area they are threatened by different types of pollutants discharged from industries.
In February 2006, a factory in the SITE area of Karachi allegedly dumped hazardous chemical waste in an
empty plot (F620-621) within the vicinity of SITE Town. The dumping of this waste subsequently led to several
serious and minor injuries of young boys who are residents of the surrounding areas. Over a period of three
months, a total of 20 such cases were recorded where mainly children from the nearby areas were found
seriously injured in the hazardous waste material. Of the injured, one child, Iftikhar, also died (28th April
2006) due to the severity of his burns, while another, Shiraz, has had both his legs amputated and has lost
his fingers as well. The family members of the injured children initially thought that their children had been
burnt in the garbage set on fire by rag pickers in the area. However, later upon learning that it was actually
the toxic chemical waste that had been responsible for their children's condition, they grew more concerned
and willing to take action against the offenders.3
The pollution problems have arisen due mainly to the indiscriminate discharge of effluent from industrial and
agriculture sources and disposal of untreated liquid and solid wastes generated from domestic sources into
the coastal environment. The 1991 Pakistan National Environmental Plan estimates that three main coastal
industries located near the port with the largest volumes of effluents are the steel mill, power plants, and
refineries and notes that many smaller industrial units are having more significant polluting effects on the
marine environment. In addition to the growing export industries contribution to the pollution, trade activity
in the Karachi Port is expected to rise steadily. Moreover, because "recent changes have led to a major
realignment in trading patterns in the region leading to the expansion of the Economic Cooperation Organization
(ECO) to include the Central Asian states and Afghanistan along with Pakistan, Iran, and Turkey...Pakistan
stands already committed to provide a suitable deep water port for the landlocked countries of the ECO."
Without improvements in the shipping industry, pollution is overburden the environment along the Karachi
coastline. The heavy metals are being accumulated in the sediments and marine organisms. The accumulation
of eight heavy metals (As, Cd, Co, Cr, Cu, Hg, Ni, Pb and Zn) in the fauna of coastal waters of Karachi is especially
in higher concentration in marine organisms comprising of resident fauna of the polluted localities. Some of
the marine life was contaminated with lead, which if consumed by humans through seafood, has been linked
to anemia, kidney failure, and brain damage.
Social Concerns - Occupational Safety and Health

For assessing concerns of a social nature the issue of labor rights and occupational safety are being considered
and the following section covering occupational safety issues is sourced from the publication Status of Labor
Rights in Pakistan 2014, published by the Pakistan Institute of Labor Education and Research (PILER).
3. Environmental Policy & Urban Pollution, Case Study: Dumping of Hazardous Industrial Waste in SITE.
Adnan Millwala and Erum Haider, July 2006.
12
Occupational Safety and Health

Occupational safety and health, the core element of a decent work environment, remains the lowest priority
of the stakeholders despite the rising incidences of work related injuries, diseases and fatalities in recent
years. The Baldia Factory Fire 2012- that killed 255 workers - did not compel the state officials and the
employers to devise a comprehensive plan for prevention of industrial accidents. Neither the granting of the
GSP Plus motivated the stakeholders to push for a preventative safety and health culture.
The International Labor Organization (ILO) has devised more than 40 standards specifically dealing with
occupational safety and health, as well as over 40 Codes of Practice. There are three fundamental standards:
the Occupational Safety and Health Convention 1981 No. 155, Occupational Health Services Convention 1985
No. 161, and the Promotional Framework for Occupational Safety and Health Convention 2006 No. 187.
Pakistan has not ratified any of these conventions reflecting low State priority to the safety and health of
workers.
In Pakistan, the most hazardous occupation in terms of safety and health remains agriculture where mechanized
farming and pesticide use - combined with workers' lack of access to education and protective measures -
cause injuries and diseases to the workers. According to the latest official data, of the workers who reported
occupational disease or injury, 49.1 per cent belonged to the agricultural and fisheries sector, 15.2 per cent
were engaged in the construction sector and 13.3 percent were involved in the manufacturing sector. The
Labor Force Survey does not provide estimates of the number of cases pertaining to accidents, injuries, or
occupational diseases. The Pakistan Statistical Year Book records inadequate and outdated data on industrial
accidents in registered factories. According to the latest Year Book 2012, there were 326 industrial accidents
in the country in 2009 and of them, 45 were fatal. Though the Factories Act 1934 stipulates that the factory
managers must notify accidents to the Labor Department, it is seldom done. Pakistan has ratified the ILO
Labor Inspection Convention No. 81 and thus committed to evolve an efficient labor inspection system. Under
this Convention, labor inspection needs to be placed under the supervision and control of a central authority
and should apply to all workplaces to secure the enforcement of the legal provisions relating to conditions
of work and the protection of workers. In contravention of the ratified ILO convention, previous national and
provincial policies and practices in Pakistan have severely undermined labor inspection. Under the existing
system, only registered factories and shops are covered and the larger informal sector, including agriculture
and the services sectors are excluded from the ambit of the inspection system. Workers are not consulted
in the inspection and are not made aware of what the inspection has revealed. The provincial Labor Departments
are mandated to document industrial accidents under various laws. Due to a weak labor inspection system,
poor governance, and inefficient functioning, documentation is not done regularly and rarely shared with
the stakeholders. Hence the only source of information on industrial accidents is the media.
According to the Human Rights Commission of Pakistan's (HRCP) latest report, 39 industrial accidents causing
deaths of 92 workers were reported in the media in 2014. Officially 73.6 per cent workers are employed in
the informal sector comprising small to medium-sized industrial units that avoid registration and violate labor
laws. In medium-sized units, conditions are not better as the employers evade implementation of related laws
and bust unions. Even large production units in the country often do not have adequate occupational health
13
and safety management systems in place as was manifest in the case of the Baldia factory, Ali Enterprises
which employed around 1500 workers.
The factory was not registered with the Labor Department though it was a registered member of the Pakistan
Ready made Garments Manufacturers and Employers Association. It is not only at the factories that workers
confront risks to their safety and health, a significant number of workers who reside near industrial areas
face hazards. Industrial units in Pakistan violate environmental by-laws and often release untreated effluents
and dangerous chemical in streams, rivers and water bodies surrounded by the workers settlements. 22 Status
of Labor Rights in Pakistan An industrial accident was reported in May 2014 at the Chashma Sugar Mill &
Ethanol Distillery, Ramak, and Tandlian-Wala Sugar Mill, Miran. Ten people, including women and children,
died of toxic fumes released by the mills and the distillery on to a stream. As there was no bridge, the
community used wooden boards to cross over the stream. A girl slipped and fell in the drain. The people who
tried to rescue her also succumbed to the toxic fumes. Ensuring safe and healthy work environment is a
political choice which the government is not willing to make. Underneath violation of labor and environmental
laws, failure of the monitoring and inspection systems and the complicity of the certification agencies with
corporate lies a strong nexus between industrialists, state officials and political elite that resists implementation
of safety and health laws at work places.
Labor Laws in the Province of Sindh

The Sindh Industrial Relations Act 2010 remained the only labor law enacted by the Provincial Government
of Sindh till the end of 2014. The Sindh Labor Department circulated five draft laws - The Sindh Factories Act,
Companies' Profit (Workers Participation) Act, Sindh Shops and Establishments Act, Sindh Workers Welfare
Fund Act, Sindh Industrial and Commercial Standing Orders Act - in July 2014 seeking input from concerned
stakeholders. However, the Labor Department, did not call the tripartite meeting to receive feedback from
the stakeholders on the draft laws circulated. The Sindh Labor Department shared the draft of, and received
input to, the provincial policy on Occupational Safety and Health with the stakeholders in a tripartite
consultation held in September 2014. The policy was drafted as part of the tripartite Joint Action Plan for
Promoting Workplace Safety and Health in Sindh. The Joint Action Plan for Promoting Workplace Safety and
Health in Sindh (2013-2016) was formulated by the Government of Sindh, Employers Federation of Pakistan
and Pakistan Workers Federation after a tripartite consultation in December 2012 as a response to the 2012
factory fire in Baldia, Karachi which claimed lives of 255 workers.
The 3-year plan, launched in January 2013, proposed to formulate policies on occupational safety and health
and labor inspection, reform/amend laws and undertake capacity building of the labor department. An 8-
member Task Force was created to implement the Plan. With the exception of the formation of the Steering
Committee, and its meeting, nothing came out if by the end of 2014. The absence of widely applicable laws
in Sindh, such as the Industrial, Commercial, and Employment Standing Order Ordinance 1968, Companies
Profit Act 1968, Workers Welfare Ordinance 1972, Workman Compensation Act 1923, Payment of Wages Act
1936, Shops and Establishment Ordinance 1969, Minimum Wages Ordinance 1961, and Road Transport
Workers Ordinance 1961, has led to an almost abeyance of the judicial process and prolonged the delay in
justice. Also, the labor circle has registered its apprehensions about whether the laws currently being drafted
14
would prove beneficial to the workers. According to a labor lawyer the labor department has not inducted
labor representatives in the drafting process as required under the law. An anti-labor clause was identified
by him in the draft Sindh Companies Profit Act where the number of employees in an establishment has been
increased from 50 to 100 employees. An official revealed that drafts of 36 laws have been sent to the Labor
Department for vetting but these are yet to be forwarded to the Sindh Assembly.
D. Engaging the Citizens - Environmental Assessment Survey

The field survey was conducted in the vicinity of the SITE and KITE areas. Prior to evaluating the findings
of the survey, detailed as follows is the way the field research was conceptualized, the survey methodology
developed and pre-field work processes conducted. The research process was divided into various
components in order to get a holistic view of the research objectives:
Phase I: Literature Review

This included review of the available researches reports and articles of renowned authors and
newspapers/journals on the subject matter to develop a better insight and identify knowledge gaps to
be addressed through project research interventions, laws relating to industrial estates, SEPA, labour laws,
land laws pertaining industrial estates, the number and kind of industries (multi or local) etc.
Phase II: In-Depth Interviews (IDI's)

In order to develop an effective research instrument, In-Depth-Interview (IDI's) with relevant experts and
government officials were conducted This methodology facilitated in getting valuable insights in terms
of associations, perceptions and attitudes towards environmental and its related practices and behaviors
by authorities and industries.
Phase III: Qualitative Survey

In this project component, face to face interviews using a structured questionnaire were undertaken. The
questionnaire included pre-coded and close ended responses to gauge the perceptions and attitudes of
the respondents. The research instrument allowed gathering relevant and required information without
deviating from the main objectives. A total of 200 interviews through random sampling were conducted
with residents and workers in the selected industrial estates living around the target industrial areas. The
sample split is given below.
Survey Methodology
Selection of starting points: Based on the sample size, the required number of areas (sampling points) was
randomly selected.
Once the area list was developed, one starting point (sampling point) was selected in each area. Starting
points were mostly famous landmark, market, plaza or important place that is considered the centre of
the area. Five interviews around each starting point were conducted. This methodology provided a
reasonable number of starting points in each area, thus, providing maximum geographical spread within
the area.
15
Selection of Households (HHs): For the selection of a household around a particular starting point Right Hand
Rule (RHR) was used for female and Left Hand Rule (LHR) was used for male respondents. After each successful
interview three households were skipped. This methodology enables to adopt a systematic procedure to
minimize surveyor's bias.
FIELD OPERATIONS
Training Guides
Interviewing guides were designed based on the questionnaire and survey methodology for the interviewers.
These interviewers were (staff and students of the Department of Architecture & Planning, NED University
of Engineering & Technology, Karachi) thoroughly briefed before the start of each survey about how respondents
will be selected; under what circumstances and how substitution can be made; use of questionnaire; routing
instructions given in it, and how questionnaires will be filled out.
Training of Enumerators (Interviewers)

Classroom Training: In line with normal enumerator
training procedures, enumerators participated in a
thorough training program. In the General Training
component sessions are undertaken in the form of class
room training and start with general training on the
sample selection procedures, recruitment and
administration of the questionnaire. Interviewers are
also briefed on the expected work timings and control
procedures that will be implemented.
Project Specific Training: Once the general training was complete, a more detailed session was conducted
specially focusing on the actual questionnaire by reading the questionnaire and identifying any language
difficulties, flow etc. Mock sessions were conducted under the guidance and supervision of the Project
Coordinator and Field Manager. Trial interviews continued until the Project Coordinator/Field Manager
were satisfied that each interviewer is competent (in reading, comprehending and administering) the
interview.
Training of interviewers - Field Training

• Each interviewer completed (on average) 2 trial interviews in the field.
• All interviewers were accompanied to their starting points by a Supervisor; questionnaires were edited
immediately, so that any possible problems are resolved in time.
• A minimum 10% of each interviewer's questionnaires were back-checked either by telephone or
personally for quality check.
16
Field Quality Controls

Thorough quality controls at each stage of fieldwork and processing ensured consistently high standards of
data collection and analysis for all projects. At the field level, back checking is carried out on 10% of all
interviewers' work on a daily basis. At the completion of fieldwork, the supervisors also check 100% of the
questionnaires for any editing issues.
Phase IV: Data Processing& Report

All questionnaires were manually screened for consistency and quality at two stages:
• In the field after an interview is completed; and
• After the scrutinized questionnaires are received for analysis
Findings and analysis

Following are discussed the findings and analysis of the field survey conducted in the SITE and Korangi areas:
Training of Enumerators
17
KORANGI
The gender split in the respondents in this survey was 71% male and 29% female. It was found that females
were a bit reluctant to be interviewed even though there was always a female enumerator available. The
question on the occupancy status of the house in relation to the number of years living in the neighbourhood
gave an interesting finding (Fig. 1).
Gender
Figure 1
It was found that those living for a period of up to 30 years had over 90% ownership occupancy status and
those living beyond 30 years were all residing on an ownership basis. In comparison, those residing for a
period of up to 15 years were about 35% on a rental basis and among the most recent residents - those
18
residing for only up to 5 years were predominantly, up to 60% on a rental basis. This finding implies that there
has been a progressive change in land use and occupancy status with more people migrating from other
urban localities and also people renting out portions of their houses, accompanied by minimal introduction
of apartment dwellings. The household size was predominantly 4-7 (47%). The household income indicated
a mostly low income community presence with 44% of the households having a household income of less
than Rs. 20,000/- per month and only 18% having a household income of more than Rs. 30,000/- per month
(Fig. 2).
Figure 2
People living in your house Household income
57% of the households surveyed had a family member working in the Korangi industrial area (Fig 3).
Figure 3
Q1. Is any member of your family working in the
industry?
19
When asked what were the major health related impacts that they were facing as a result of industrial activities
than it was found that 44% had breathing problems while 35% were having skin related ailments (Fig. 4).
Figure 4
Q4. In your opinion which health concerns you attribute
to industrial activities?
When asked in a multiple choice question as to what were the major environmental impacts being caused
than the most predominant impact identified was air pollution (35%), while 23% also opted noise pollution
(Fig. 5).
Figure 5
Q5. Environmental issues that are causes of major concern
20
When asked to specify as to where the air pollution was mainly sourced from, most (39%) felt that it was
directly coming from the industries themselves. For noise pollution, most felt (42%) that it was because of
the industrial vehicular movement. When asked to rate the noise levels, the highest percentage (44%) opted
for the worst 'very noisy' option (Fig. 6).
Figure 6-A Figure 6-B

Q6. If industrial air pollution is a concern, then identify Q7. If industrial noise pollution is a concern, then identify
the major causes of air pollution the major causes of noise pollution
Figure 6-C
Q8. Rate the amount of noise made by industries in
your area?
21
It was interesting to find that when asked in a multiple choice question to indicate their major concern
regarding the spillage of liquid waste coming from industries on the streets, the highest percentage (27%)
opted for the option that liquid waste on the streets serves as an accident hazard. Solid waste management
came out as a major concern as a whopping 96% of the respondents said that solid waste gets randomly
dumped in the neighbourhood, most of which they said either gets dumped on the streets (43%) or in drains
(42%). A very revealing finding came when asked as to which agency then collects the waste. Only 3% of the
respondents felt that industries engaged in collection while the largest percentage (36%) came for the 'others'
option where it was implied that people largely themselves found ways to take care of the garbage, rather
than official agencies (Fig 7).
Figure 7-A
Q9. Major concern if industrial liquid waste discharge is a concern
Figure 7-B
Q12. If solid industrial waste is dumped, who collects it?
22
Figure 7-C
Q10. Does the industrial solid waste get randomly dumped
in neighbourhoods?
When asked as to how frequently the garbage was collected, the highest percentage of respondents (42%)
said 'not even once a month' (Fig. 8).
Figure 8
Q13. How often is industrial solid waste collected?
When asked to identify the worst industrial polluters, (44%) indicated the tanneries, while next came (38%),
the chemical industries (Fig. 9).
23
Figure 9
Q14. Which type of industry causes the most environmental concerns?
When the respondents were asked as to whether industrial activities result in the neighbourhood spaces
being encroached, then 73% answered in the affirmative (Fig. 10).
Figure 10
Q15. Does industrial activities in any way result in
encroachments?
As to which spaces were most encroached, in a multiple choice question, 62% said streets, while 56% also
said that storm drains and open drains were being encroached (Fig. 11).
24
Figure 11
Q16. Which type of spaces are encroached?
A very revealing answer came when the respondents were asked if any industry had done some neighbourhood
improvement works in their localities. Of all the respondents surveyed, 92% replied in the negative (Fig. 12).
Figure 12
Q17. Has any industry done some neighbourhood
improvement or community help works in your locality?
When asked if some accident has happened in their locality as a result of industrial activity then quite a
significant percentage (64%) replied in the affirmative and identified fire incidents as the most predominant
(31%) and then traffic (23%) incidents (Fig. 13).
25
Figure 13-A
Q19. Has there been any accident in your locality due to
industrial activity
Figure 13-B
Q20. What type of accident has happened?
When asked if when they made a complaint with any agency what was the response than none of the
respondent indicated that the problem got solved and 47% respondents indicated that they had to mobilize
themselves to get their issues resolved (Fig. 14).
26
Figure 14-A
Q20
Figure 14-B
Q21
27
SITE
The gender split in the respondents in this survey was 62% male and 38% female. It was found that female
were a bit reluctant to be interviewed even though there was always a female enumerator available. The
question on the occupancy status of the house in relation to the number of years living in the neighbourhood
gave an interesting finding different to what was the finding in Korangi (Fig. 15).
Gender
Figure 15
It was found that those living for a period of more than 30 years had over 72% tenancy occupancy status. In
comparison, those residing for a period of up to 15 years were about 60% on a rental basis and among the
most recent residents - those residing for only up to 5 years were predominantly, up to 70% on an ownership
28
basis. This finding implies that there has been a progressive change in land use and occupancy status with
more people begging to buy property in the area. Comprehensive land us and demographic studies are needed
to understand the reasons and implications of these interesting findings.
The household size was predominantly more than 7 (58%). The household income indicated a mostly low
income, 38% with less than Rs. 20,000/- per month household income., though a more mixed variable was
found as compared to Korangi with 24% having a household income of more than Rs. 30,000/- per month
(Fig. 16).
Figure 16
Household income
19% of the households surveyed had a family member working in the SITE industrial area (Fig. 17).
Figure 17
Q1. Is any family member working in the industry?
29
When asked what were the major health related impacts that they were facing as a result of industrial activities
than it was found that 46% had breathing problems while 24% were having skin related ailments (Fig. 18).
Figure 18
Q4. In your opinion which health concerns you attribute
to industrial activities?
When asked in a multiple choice question as to what were the major environmental impacts being caused
than the most predominant impact identified was air pollution (39%), while 22% also opted for solid waste
pollution (Fig. 19).
Figure 19
Q5. Environmental issues that are causes of major concern
30
When asked to specify as to where the air pollution was mainly sourced from, most (36%) felt that it was
directly coming from the industries themselves. For noise pollution, most felt (52%) that it was because of
the industrial vehicular movement. When asked to rate the noise levels, the highest percentage (49%) opted
for the worst 'very noisy' option (Fig. 20).
Figure 20-A Figure 20-B

Q6. If industrial air pollution is a concern, then identify Q7. If industrial noise pollution is a concern, then identify
the major causes of air pollution the major causes of noise pollution
Figure 20-C
Q8. Rate the amount of noise made by industries in your
area?
It was found when asked in a multiple choice question to indicate their major concern regarding the spillage
of liquid waste coming from industries on the streets, the highest percentage (56%) opted for the option that
solid waste got dumped in the streets. Solid waste management came out as a major concern as 78% of the
31
respondents said that solid waste gets randomly dumped in the neighbourhood, most of which they said
either gets dumped on the streets (42%) or in drains (31%). A very revealing finding came when asked as to
which agency then collects the waste. Only 9% of the respondents felt that industries engaged in collection
while the largest percentage (37%) came for the 'others' option where it was implied that people largely
themselves found ways to take care of the garbage, rather than official agencies (Fig. 21).
Figure 21-A
Q9. Major concern if industrial liquid waste discharge is a concern
Figure 21-B Figure 21-C

Q11. If solid waste is randomly dumped then where is it
dumped? Q12. If solid industrial waste is dumped, who collects
When asked as to how frequently the garbage was collected, the highest percentage of respondents (30%)
32
said 'not even once a month' (Fig. 22).
Figure 22
Q8. Rate the amount of noise made by industries in your
area?
When asked to identify the worst industrial polluters, (28%) indicated the chemical industries. When the
respondents were asked as to whether industrial activities result in the neighbourhood spaces being encroached,
then 62% answered in the affirmative (Fig. 23).
Figure 23-A
Q14. Which type of industry causes the most environmental concerns?
33
Figure 23-B
Q15. Does industrial activities in any way result in
encroachments?
As to which spaces were most encroached, in a multiple choice question, 50% said streets, while 24% also
said that parks were being encroached (Fig. 24).
Figure 24
Q16. Which type of spaces are encroached?
When asked if some accident has happened in their locality as a result of industrial activity then quite a
significant percentage (54%) replied in the affirmative and identified drain incidents as the most predominant
34
(31%) and then traffic (27%) incidents (Fig. 25).
Figure 25-A
Q19. Has there been any accident in your locality due to
industrial activity?
Figure 25-B
Q20. What type of accident has happened?
When asked if when they made a complaint with any agency what was the response than 5% of the respondent
indicated that the problem got solved and 68% respondents indicated that they had to mobilize themselves
35
to get their issues resolved (Fig. 26).
Figure 26-A
Q21. If a complaint has been registered with a polluting industry then how has
been the response?
Figure 26-B
Q22. Who has been the most helpful in resolving the environmental issues in
the area related with industrial activities?
36
Following are comparative findings for the surveys between SITE and Korangi areas:
Figure 27 Figure 28
Age Gender
Figure 29 Figure 30
People living in your house Household income
Figure 31 Figure 32
Is any member of your family working in the industry? No. of family members working in a factory
37
Figure 33 Figure 34
In your opinion which health concerns you attribute to
In what ways has your quality of living been impacted? industrial activities?
Figure 35 Figure 36
If industrial air pollution is a concern, then identify the
Environmental issues that are causes of major concern major causes of air pollution
Figure 37 Figure 38
If industrial noise pollution is a concern, then identify the Rate the amount of noise made by industries in your area?
major causes of noise pollution
38
Figure 39 Figure 40
Major concern if industrial liquid waste discharge is a Does the industrial solid waste get randomly dumped in
concern neighbourhoods?
Figure 41 Figure 42
If solid waste is randomly dumped then where is it If solid industrial waste is dumped, who collects it?
dumped?
Figure 43 Figure 44
Which type of industry causes the most environmental
How often is industrial solid waste collected? concerns?
39
Figure 45 Figure 46
Does industrial activities in any way result in Which type of spaces are enroached?
encroachments?
Figure 47 Figure 48
Has any industry done some neighbourhood improvement What type of industry has done neighbourhood
or community help works in your locality? improvement or community help?
Figure 49 Figure 50
Has there been any accident in your locality due to What type of accident has happened?
industrial activity?
40
Figure 51 Figure 52
If a complaint has been registered with a polluting industry Who has been the most helpful in resolving the
then how has been the response? environmental issues in the area related with industrial
activities?
41
Conclusions
There are a number of interesting findings which have been documented that demand consideration. They
are assessed as follows:
It has been indicated quite clearly that the industrial estates housing hundreds of industrial units are located
in densely populated localities with average household sizes mostly in the range of about 7 and more household
members. This is not proper practice. Anywhere in the world where industrial zones are properly planned
and developed they are located at a distance from human settlements. However, there is not much that can
be done about this now. But this implies even greater provision of environmental safeguards that are presently
missing as has been indicated by various survey findings.
With regards the health impacts of environmentally unregulated industrial activities, the major concern has
been in both the localities, breathing and skin ailments. This finding also gets correlated with the finding that
the major environmental concerns are related with air pollution and random dumping and burning of solid
waste.
The air pollution problems in turn has mostly been associated with industrial vehicular activity that is an
activity that is happening round the clock thus adding to the complexity of the problem. When it comes to
solid waste management, it was revealed that the solid waste in many cases does not even get picked up on
once a month basis and that forces the residents to dispose themselves which often is through open burning.
Physical handling of the garbage and also open burning can find a direct relation with the finding of respiratory
and skin problems.
Noise pollution also registers and that too in the most-noisy category. It was again interestingly found that
respondents related noise mostly with industrial vehicular movement.
The drainage network that needs to be managed by the industrial estates is a source of multiple concerns.
Mostly untreated liquid discharges from industries find their way in the drains, garbage also gets dumped
in the drains while the drains are also being encroached upon by constructions taking place on the drains,
mostly it was observed, commercial structures.
In terms of grievance redress, a very negative response was received with mostly the residents having to take
it on their own to handle the environmental concerns. Neither from the government, political representatives
or the industries a positive response it seems has been received that indicates a total collapse of governance.
What is indicated is a complete absence of working systems and mechanisms for resolving of the multiple
environmental issues that are being faced by the residents on a daily basis. It is not that administrative and
regulatory systems do not exist. The Industrial estates are both empowered and financially capable to take
the required actions. The relevant government agencies also have a mandate when it comes to residential
42
areas. Then we have the Sindh Environmental Protection Agency that has the required regulatory role to play.
It would appear that these responsibilities are not being assumed and the mandate not being enforced.
Discussions with the industrial estate officials, government agency representatives including the environmental
protection agencies has indicated that while they recognize that problems exist but generally engage in
passing the buck and a blame game. Cited are weak enforcement powers when it comes to the regulatory
agencies, lack of finances when it comes to the government civic agencies and lack of government support
when it comes to the industrial estates. What is needed is an effort to bring all stakeholders on the table to
resolve their conflicts and find a greater clarity in terms of powers, functions and accountability mechanisms.
The problems also find a resonance in the larger land use management crisis in the city. Land has become a
financial commodity rather than as a means for providing a social good. This means to corruption and
subsequent violation of land use regulations.
There is now a growing focus on climate change globally that is being considered as the most urgent challenge
that is faced by humanity at large. Subsequently, a lot finances and planning is being directed to make cities
more environment friendly having a lesser carbon footprint. When it comes to the urban context, industrial
activities are considered as a major cause contributing to climate change if being operated in the absence
of relevant social and environmental safeguards. Pakistan can avail of this opportunity by directing the
available funding and resources to making their industrial operations compatible with the requirements of
the time. A beginning can be made from Karachi where already a vibrant mix of relevant stakeholders exists
- the industry, civil society, government. There needs to be an effort to merge the potentials and capacities
of all stakeholders to develop and implement a policy and implementation framework for positive change.
43
ENVIRONMENTAL LAWS RELEVANT TO
NON-EXTRACTIVE INDUSTRY, COMMERCIAL OPERATIONS
APPLICABLE IN THE PROVINCE OF SINDH
Provincial laws governing this sector provide for the promotion and development of industries, and regulate
matters related to the general administration of factories and the employment of labor. These laws contain
no provisions concerning the disposal of industrial waste.
Even where older provincial laws have been amended in recent years, no environmental provisions have been
added. The Sindh Small Industries Corporation Act 1972, for example, was amended to gradually phase out
small industry and focus on large-scale operations without any provisions to manage or mitigate the greater
pollution impacts of larger industries. Similarly, the Sugar Factories Control Act 1950 was amended in 1995,
making it mandatory to install quality control devices, but pollution control devices are not required.
Specified industrial and commercial activities are, however, subject to the restrictions imposed by PEPA 1997
regarding EIAs and the regulation of emissions. At the provincial and local level, industrial and commercial
operations are also governed by local government, building control and development authority laws which
aim, with varying degrees of coverage, to regulate the location of industrial units, particularly those involved
in processes or products considered to be dangerous, flammable or hazardous.
Karachi Building and Town Planning Regulations 2002

Notification No. SO (Land) HTP/KBCA-3-39/2000
These Regulations, issued under the Sindh Buildings Control Ordinance 1979, provide exhaustive rules and
procedures governing construction and development activities in the city (section 1-2). They apply to all of
Karachi except for cantonment areas (section 1-1.3). The government may also declare "special areas" that
are exempt from the application of these Regulations (section 1-3). Specified "dangerous trades" (section 25-
6.12.1) and "offensive trades emanating obnoxious smells/effluents" (section 25-6.12.2) may only be carried
out in "specially designated/approved areas" (section 25-6.12). Zoning provisions require all industrial effluent
to be discharged "in keeping with" federal, provincial or local government "environmental standards" (section
25-6.7). All "hazardous waste" is to be disposed of according to the provisions of the NEQS (section 25-6.11).
Waste treatments plants are required to comply with the NEQS, as are hospitals and industries (section 12-
3). The Regulations also contain "general standards" for various development activities (chapters 20-23).
General standards with respect to industrial development, defined to include extractive industry (section 22-
1.1.3), include requirements for the removal of waste (section 22-3.1.1) and the elimination of noise pollution
(section 22-3.1.2).
6.4.4 Pakistan Environmental Protection Act 1997 (No. XXXIV)

Industrial activity is defined in PEPA as "any operation or process for manufacturing, making, formulating,
synthesizing, altering, repairing, ornamenting, finishing, packing or otherwise treating any article or substance
with a view to its use, sale, transport, delivery or disposal, or for mining, for oil and gas exploration and
development, or for pumping water or sewage, or for generating, transforming or transmitting power or for
any other industrial or commercial purposes" (section 2 (xxii)). The wide scope provided by the definition for
regulating industrial activity is reflected in the operative provisions of the law, particularly the prohibition
44
Environmental Laws Relevant to Non-Extractive Industry,
Commercial Operations Applicable in the Province of Sindh
on certain emissions with provisions for levying pollution charges (section 11); IEE/EIA (section 12); licensing
(sections 14 and 15); and environmental protection orders (section 16).
A project is defined to include construction, operation, alteration, expansion, repair, decommissioning or

abandonment of factories or other installations (sections 2 (xxxv) (c) and 2 (xxxv) (f)). PEPA requires parties
desiring to commence a project to submit an EIA or IEE to the Federal Agency (section 12). Meanwhile, the
Federal Agency may issue an environmental protection order in cases where discharges, emissions, waste
disposal or the handling of hazardous substances are causing or likely to cause an adverse environmental
effect (section 16).
The penalty for violating provisions governing discharges and emissions (section 11), and environmental
protection orders (section 16), is a fine that may extend to 1 million rupees for a first offence (section 17 (1)).
For non-compliance with provisions governing the handling of hazardous substances (section 14), fines may
extend to 100,000 rupees (section 17(2)). In addition to imprisonment for up to two years, penalties for repeat
offenders may include closure and confiscation of the factory, machinery and equipment; an order to restore
the environment at the violator's own cost; and an order to pay compensation for any loss, bodily injury or
damage to health or property caused by the violation (section 17 (5)).
Hospital Waste Management Rules 2005

SRO 1013(1)/2005 dated 3 August 2005
These Rules, framed under section 31 of PEPA 1997, make hospitals responsible for the "proper management"
and disposal of waste (section 3). Several categories of waste are specified in the Rules, including chemical
(section 2 (1) (a)), "genotoxic" (section 2 (1) (c)), infectious (section 2 (1) (h)) and radioactive (section 2 (1) (n)).
Every hospital is required to set up a waste management team (section 4) which prepares, implement and
monitors a waste management plan (sections 4 and 15). Hospitals are defined broadly to include clinics,
laboratories, pharmacies and a wide range of health care, research and veterinary institutions and centers
(section 2 (1) (f)). The remaining provisions of the Rules deal with the responsibilities of hospital officials;
matters related to waste segregation, storage, transportation and disposal; and measures to be taken in case
of accidents or "spillages". The federal government may exempt any class of hospitals from any or all of the
provisions of these Rules (section 25).
Pakistan Environmental Protection Agency Review of Initial

Environmental Examination and Environmental Impact Assessment Regulations 2000
SRO 339(I)/2000 dated 13 June 2000
Under these Regulations, manufacturing and processing projects are required to undergo prior IEE or EIA.
Relatively small-scale industries and commercial operations, which require a prior IEE, are listed In Schedule
I, part C. Larger-scale manufacturing and processing operations requiring a prior EIA are Listed in Schedule
II, part B. At the local level, the district law office is responsible for assisting in the implementation of PEPA
45
1997 (Sindh District Government (Conduct of Business) Rules 2001, section 3(2), read with schedule II, item
8 (ii)).
National Environmental Quality Standards SRO 742 (I)/93 dated 29 August 1993
This Order was issued under the Pakistan Environmental Protection Ordinance 1983 (No. XXXVII). although
the 1983 Ordinance is repealed, these standards remain in force. The NEQS specify maximum limits for various
types of effluent and emissions, including liquid industrial effluent (section 2, read with annex I) and industrial
gaseous emissions (section 2, read with annex II). The NEQS have been revised and amended periodically,
and substantively so in the year 2000.
Box 1
National Environmental Quality Standards (SRO 742 (I)/93 dated 29 August
1993) amended by:
• SRO 1023 (I)/95 dated 16 October 1995
• SRO 549 (I)/2000 dated 8 August 2000
Coastal Development Authority Act 1994 (No. XXVIII)

This Act establishes an Authority for the development, improvement and beautification of the coastal areas
of Thatta and Badin districts. The Authority is responsible for planning and implementing schemes in a number
of areas including "entrepreneur development" (section 7 (2) (i)), and providing credit for industrial development
and "other allied activities" (section 7 (2) (d)). It also assists in the establishment of coconut palm plantations,
and makes arrangements for extraction and refining (section 7 (10)).
Sindh Small Industries Corporation Act 1972 (No. XXVI)

This Act establishes a Sindh Small Industries and Handicrafts Development Corporation (section 3), which
was re-named the Sindh Small Industries Corporation in 1979. The Corporation assists in the establishment
of cottage and small industry (section 16 (1)), providing loans and furnishing bank guarantees (section 16 (2))
for industries operating in small industries estates (section 19). The Corporation establishes small industries
estates (section 25 (xiv)), and carries out a wide range of functions related to the promotion and operation
of small industries, including the supply of raw materials (section 25 (xviii)). It is also required to introduce
"better means of production" (section 25 (xx)) and to establish "model projects" (section 25 (v)). Although
the law contains no provisions that directly address the environmental impact of industrial operations, these
clauses allow the Corporation to promote projects with minimal adverse effects on natural resources and the
environment.
At the time of its inception, the Corporation was responsible for developing small industries with total fixed
assets, excluding land, worth up to 2 million rupees (section 2 (n)). By 1987, it was responsible for relatively
larger industries with an "original value" of fixed capital investment, including land and buildings, of up to
46
10 million rupees (section 2 (n), as amended in 1987). The functions of the Corporation, however, remain
unchanged.
Box 2
Sindh Small Industries and Handicrafts Development Corporation Act 1972 (No. XXVI)
Adapted and amended by:
• Sindh Adaptation of Laws Order 1975
• Sindh Repealing and Amending Act 1975 (No. XVII)
• Sindh Small Industries and Handicrafts Development Corporation (Amendment)
Ordinance 1977 (No. XI)
Ordinance 1978 (No. VIII)
• Sindh Small Industries and Handicrafts Development Corporation (Second
Amendment) Ordinance 1978 (No. XII)
Ordinance 1979 (No. II)
• Sindh Small Industries Corporation (Amendment) Ordinance 1979 (No. XIV)
• Sindh Small Industries Corporation (Amendment) Ordinance 1983 (No. XIV)
• Sindh Small Industries Corporation (Amendment) Act 1987 (No. III)
• Sindh Small Industries Corporation (Amendment) Act 1989 (No. I of 1990 [sic])
Repeals:
• Sindh Small Industries and Handicrafts Development Corporation Ordinance 1972
(No. XXIII)
Sindh Industries (Control on Establishment and Enlargement) Ordinance 1963 (WP No. IV)
This Ordinance allows a prohibition to be imposed on the establishment of new industry or the expansion
of an existing industrial concern in any "local area" to which its provisions are extended (section 1(3), read
with section 3). For the purposes of this Ordinance, an industrial undertaking is defined as any industry
manufacturing or processing goods or commodities, and employing 20 or more workers "without the aid of
power" or 10 or more workers "with the aid of power" (section 2 (c)). Exemptions may be granted at the
discretion of the government (section 11) but no criteria for exemptions have been provided in the law. The
provincial government may delegate its powers and make rules to carry out the purposes of this Ordinance.
The law contains no other provisions. This Ordinance appears to have been promulgated for the sole purpose
of keeping industrial operations from being set up in certain areas. It is specifically saved by the Constitution
of 1973, where it is included in the list of instruments that must be brought into conformity with the
fundamental rights guaranteed to all citizens within a specified period of time (article 8(4), read with the First
Schedule, part II, item V (4)). The law was adapted specifically for the province of Sindh in 1975. No legal
instrument specifically repealing this Ordinance could be identified.
47
Box 3
West Pakistan Industries (Control on Establishment and Enlargement) Ordinance
1963 (No. IV) Adapted and amended by:
• Sindh Amendment of Laws Act 1976 (No. V)
Sugar Factories Control Act 1950 (NWFP No. XXII)

This NWFP Act was adapted first for all of West Pakistan, and subsequently amended and adapted for the
province of Sindh. It regulates the supply of sugarcane to sugar factories (section 14), the price at which it
may be purchased (section 16), and other related issues. The provincial government may designate "reserved"
areas (section 10), establish a Sugar Factories Control Board (section 3) and appoint inspectors (section 7).
Box 4
Sugar Factories Control Act 1950 (NWFP No. XXII)
Adapted and amended by:
• North West Frontier Province Sugar Factories Control (Amendment) Ordinance
1961 (No. III)
• Sugar Factories Control (West Pakistan Amendment) Ordinance 1963 (No. XLV)
• Sugar Factories Control Act (Sindh Amendment) Ordinance 1971 (No. XI)
• Sugar Factories Control (Amendment) Ordinance 1980 (No. XVI)
• Sugar Factories Control (Amendment) Ordinance 1985 (No. II)
• Sugar Factories Control (Sindh Amendment) Act 1993 (No. VIII of 1994 [sic])
• Sugar Factories Control (Sindh Amendment) Act 1995 (No. IX)
Also see:
•Sugar Factories Control Rules 1950
Factories Act 1934 (No. XXV)

This law governs the employment of labor, working hours, working conditions and facilities to be provided
in the workplace. The Act deals primarily with matters related to labor relations but contains a detailed
chapter on the health and safety of workers (chapter III, sections 13-33). The law requires that factories be
kept clean and that "effluvia arising from any drain, privy or other nuisance" be removed at regular intervals
(section 13). These and other health and safety stipulations apply only to workers within the premises of a
factory. The Act does not mention the disposal of waste generated during the manufacturing process or
require measures to mitigate the impact of such waste on the environment. All powers under this Act, including
the power to make rules, lie with provincial governments (section 59).
48
Box 5
Factories Act 1934 (No. XXV)
Amended by:
• Central Laws (Statute Reform) Ordinance 1960 (No. XXI)
• Factories (West Pakistan Amendment) Ordinance 1966 (No. IV)
• Factories Act (Sindh Amendment) Ordinance 1971 (No. V)
• Federal Laws (Revision and Declaration) Ordinance 1981 (No. XXVII)
Sindh Factories Rules 1975

These Rules, made under the Factories Act 1934, govern the employment of factory labor, providing For the
health and safety of workers. They contain detailed provisions regarding facilities and safety Equipment to
be provided to workers.
Boilers Act 1923 (No. V)

This federal Act consolidates and amends the law relating to steam boilers exceeding a capacity of five gallons,
and requires that all boilers be registered (section 6). The law does not apply to boilers on board a ship or
mechanically propelled vessel, boilers belonging to the Pakistan Navy, or boilers less than 20 gallons in capacity
if they are used by hospitals for sterilizing equipment (section 3). The provincial government has the power
to make rules (section 29) while the Boilers Board constituted under this Act may make regulations (section
28). Although most powers under this law lie with the provincial government, the federal government retains
the power to appoint members of the Board (section 27-A) and may grant exemptions to certain classes of
boilers operated by the railways (section 3(2)).
Box 6
Boilers Act 1923 (No. V) Amended and adapted by:
• Boilers (West Pakistan Amendment) Ordinance 1958 (No. XXXIII)

• Central Laws (Statute Reform) Ordinance 1960 (No. XXI)
• Central Adaptation of Laws Order 1964 (President's Order No. 1)
• Boilers Act (Sindh Amendment) Ordinance 1971 (No. VIII)
• Federal Adaptation of Laws Order 1975 (President's Order No. 4)
• Boilers (Amendment) Act 1975 (No. XXX)
• Federal Laws (Revision and Declaration) Ordinance 1981 (No. XXVII)
49
PAKISTAN ENVIRONMENTAL LEGISLATION AND THE
NATIONAL ENVIRONMENTAL QUALITY STANDARDS
50
Pakistan Environmental Legislation and the
National Environmental Quality Standards
51
52
53
54
55
56
57
NEQS INDUSTRIAL GAS
58
Neqs Industrial Gas
59
Neqs Industrial Gas
60
SURVEY QUESTIONNAIRE
Name: 2. Then how many family members are working in

Age: the industries?
• 0-18 years • One
• 19-40 years • Two
• 41-60 years • More than two
• Above 60 years
3. In what way has your quality of living been
Gender: impacted?
• Male/Female • Ill health
• Security concerns
Occupation: • Traffic accident hazards
Type of Residency: • Any other
• Ownership/Rental (Multiple choice possible)
(If ill health is not a choice indicated by the
Period of residence: respondent, go to Q. 5)
• 0-5 years
• 6-15 years 4. In your opinion which health concerns you
• 16-30 years attribute to industrial activities?
• More than 30 years • Skin ailments
• Lungs and respiratory problems
No. of family members: • Hearing impairment
(including the interviewed) • Psychological stresses/tension
• No family member • Any other
(living alone) (Multiple choices possible)
• 1-3
• 4-7 5. Rate according to priority from the following
• More than 7 industry related environmental issues as causes
of major concern:
Household income range: • Air pollution
• Less than Rs. 10,000 • Noise pollution
• Rs. 11,000 – Rs. 20,000 • Liquid waste discharges
• Rs. 21,000 – Rs, 30,000 • Solid waste dumps
• Rs. 31,000 or more
6. If industrial air pollution is a concern, then
Contact # identify the major causes of air pollution:
Address: • Air emissions from the industries
• vehicular air emissions
1. Is any member of your family working in the • Burning of solid waste
_____ industries? • Any other
Yes/No (Multiple choices are possible)
If answer to Q.1 is ‘yes’,
61
Survey Questionnaire
7. If industrial noise pollution is a concern, then • Is openly burnt

identify the major causes of noise pollution: • Any other
• Industrial operations
• Industrial vehicular noise 13. How often is the industrial solid waste collected?
• Any other • Every day
• Once a week
8. Rate the amount of noise made by industries in • Once a month
your area? • Not even once a month
• very noisy
• Moderate noise 14. Rate according to your opinion as to which type
• Less noise of industrial activity causes the most
• No noise at all environmental concerns?
• Chemicals
9. If industrial liquid waste discharges is a concern, • Tannery
then rate according to priority, the major • Pharmaceutical
concerns: • Electrical
• Spills over on streets • Any other
• Enters into homes/shops
• Creates odor problems 15. Do industrial activities in any way result in
• Enters into water supply lines encroachments?
• Serves as an accident hazard (Prompt - Yes/No
example fire, people falling in drains carrying (If answer to Q.17 is No, then go to Q.20)
the waste)
(Multiple choices is possible) 16. Which types of spaces are encroached?
• Parks/playgrounds
10. Does the industrial solid waste get randomly • Streets and pavements
dumped in the neighborhoods? • Nallahs (Drains)
Yes/No • Any other
(Multiple choices are possible)
11. If the solid waste is randomly dumped then
where is it dumped? 17. Has any industry done some neighborhood
• Parks/playgrounds improvement or community help works in your
• On the roadside locality?
• Nallahs (drains) Yes/No
• Any other
(Multiple choices are possible) 18. If any industry has done some neighborhood
improvement or community help works in your
12. If industrial solid waste is randomly dumped locality, then what has been the nature of work?
then who collects it? • Health
• The industry • Education
• Some government authority • Green spaces
62
Survey Questionnaire
• Water & sanitation

• Any other
19. Has there been any accident in your locality due

to industrial activity?
Yes/No
20. What type of accident has happened?

• Traffic accident
• Fire
• Person falling in drain
• Person contacting toxic discharges
• Any other
21. If a complaint has been registered with a polluting

industry than how has been the response?
• very good (problem solved)
• Have noted the complaint but problem not
solved
• Have refused to note the complaint
• Any other
22. Who has been the most helpful in resolving the

environmental issues in the area related with
industrial activities?
• Polluting industry
• Government authority
• Local MP/MNA
• Councilor
• Some political party
• Any other
Name/signature of enumerator
63
Sindh Industrial Trading Estate (SITE) designated as an Industrial Area in 1963. It is the
oldest designated Industrial Area of Pakistan, encompassing 4700 acres (19 km²) of land.
It contains approximately 2,400 factories.
Korangi Industrial Area (KIA) is one of the largest industrial estates of Pakistan having an
area of around 8500 acres. It was established in mid 60s and made operational in 1970.
According to a rough estimate more than 4500 industrial, commercial, and service concerns
operate here. Leading garment export industries are located in KIA, it supplies about 78%
of the total petroleum products in Pakistan. About 90% of Tanneries and leather industries
of Sindh are clustered in KIA and 75% of leather export is catered from KIA. The largest
biscuit factory English Biscuit Manufacturers, top two spices manufacturers companies like
Shan Foods (Pvt) Ltd and Mehran Spice and Food Industries located in KIA. 80% industries
in KIA are export oriented.

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About the Author

Karachi is faced with a number of development challenges. The city is

Pollution is generated from a number of urban activities, including industrial.

B. Profiling the Industrial Estates in Karachi - Focus on SITE and KITE

Historical Growth of Industrial Estates in Karachi

Salient Features of the Industrial Sector in Karachi

Organizational Chart of SITE (Board of Directors)

1. Secretary Industries Department

SITE INDUSTRIAL AREA

Organizational Chart of KATI (Executive Committee)

KATI Standing Committees

C. Environmental and Social Concerns

Social Concerns - Occupational Safety and Health

Occupational Safety and Health

Labor Laws in the Province of Sindh

D. Engaging the Citizens - Environmental Assessment Survey

Phase I: Literature Review

Phase II: In-Depth Interviews (IDI's)

Phase III: Qualitative Survey

Training of Enumerators (Interviewers)

Training of interviewers - Field Training

Field Quality Controls

Phase IV: Data Processing& Report

Findings and analysis

Figure 6-A Figure 6-B

Figure 20-A Figure 20-B

Figure 21-B Figure 21-C

said 'not even once a month' (Fig. 22).

(31%) and then traffic (27%) incidents (Fig. 25).

to get their issues resolved (Fig. 26).

Karachi Building and Town Planning Regulations 2002

6.4.4 Pakistan Environmental Protection Act 1997 (No. XXXIV)

A project is defined to include construction, operation, alteration, expansion, repair, decommissioning or

Hospital Waste Management Rules 2005

Pakistan Environmental Protection Agency Review of Initial

Coastal Development Authority Act 1994 (No. XXVIII)

Sindh Small Industries Corporation Act 1972 (No. XXVI)

Sugar Factories Control Act 1950 (NWFP No. XXII)

Factories Act 1934 (No. XXV)

Sindh Factories Rules 1975

Boilers Act 1923 (No. V)

• Boilers (West Pakistan Amendment) Ordinance 1958 (No. XXXIII)

Name: 2. Then how many family members are working in

7. If industrial noise pollution is a concern, then • Is openly burnt

• Water & sanitation

19. Has there been any accident in your locality due

20. What type of accident has happened?

21. If a complaint has been registered with a polluting

22. Who has been the most helpful in resolving the

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