Document VG7OB8MyGepLYK5VgZzDyEEB8

Pennsylvania Avenue, N W Washington, D C 20004 202*737*6330 Organization Resources Counselor^ Inc December 22, 1986 Memorandum To: ORC ERPG Task Force ORC Occupational Safety and Health Group ORC Occupational Safety and Health Physicians Group ORC Occupational Safety and Health Lawyers Group ORC International Safety and Health Forum From: Darrell K. Mattheis Subject: A Potential "Bhopal" in Bombay, India Hope is said to spring eternal, and one might hope that governments and businesses everywhere, but especially in India, would take every possible precaution to avoid another incident such as Bhopal. If the article that was published in Business India. (September 22October 5, 1986, (here included) is accurate, the Indian Government and local businessmen have learned nothing! Bhopal has been an expensive lesson for American industry as a whole, and particularly so for the chemical industry. But, because we did not "make hay while the sun shines", we can expect to face even greater difficulties. The environmental, health, and safety legislation currently on the books can be used in ways that could cause us major difficulties. We still have two years in which to take some significant action; if we do not we can only blame ourselves for what happens. We have also included here an interesting article by Professor Lester Lave, from the University of Pittsburgh, which was published in the Wall Street Journal December 17, 1986. Dr. Lave discusses some of the problems that may face the business community in the next two years. DKM/bd/25 Cover Feature This project will make TK** gf>srmment o: Mph.i'.ishvj mu<! be ereKited with i sense ot hur.iuf ii m.thing .<se fO' how else would one describe a not as a bizarre gAe. t pouts rh.ii industry Bombay a Bhopal and even Ihe wholesale mjrlsct> io hnt nut ot Bombov city in the interest 01 public health but permits, m their place, the Construction 01 an enormous chemical storage tacilits espe cially earmarked tor estremeh hazardous Incredible as it may seem, a large scale storage facility for 'hazardous' and 'extra hazardous' chemicals is under chemicjls. and that loo.located m the sets heart oi the city' Lniuriunately. it is all too real. V\ ithm tour sears. Bombas will claim the construction in the heart of Bombay city. The Antop Hill Warehousing Corporation, a Rs 34-crore project promoted by tlislinction ot housing what might well be the single most dangerous chemical storage tat ibis in the world. the Indian Merchants Chamber and approved by the government of Maharashtra and the Bombay Municipal The Antop Hill Warehousing Compans Ltd iAHWCi was conceded in imt j as a solution 10 (he problem posed bv the haphazard land Corporation, violates even the most basic requirements of safe chemical storage and constitutes a hazard to the people of otten unauthorised! stnrjge ot hazardous chemicals within the cits ot Bombas. The chemical trade has tradmonails been con Bombay on a scale that could exceed even the horrors of Bhopal centrated in the city's den*-is populated B and t ssatds then pros-imits in me pon made this area a njtura' choice 'or a trjoe that has 42 Busmt'Ss'ndig ieptrmber JJ-October S. IVSn The Antop Hill Warehousing Corporation has a capacity to store 30,000 tonnes of extremely hazardous chemicals. Considering that in Bhopal just 40 tonnes of MIC escaping from a tank spread over 40 sq km in the space of one hour, killing 2,500 and injuring more than 200,000 people, the consequence of a mishap at Antop Hill can well be imagined Cover Feature been principally centred on the import ot chemicals. Unfortunately, however, the stor age of chemicals within this area, usually in godowns located in the basements or groundfloors of predominantly residential buildings, exposed their inhabitants to extreme risk. In the last 15 years, this area has witnessed at least three maior chemical fires, the most re cent of which, m Vadgadi in 1975, claimed 40 lives and completely destroyed 8 buildings. It was thus only a matter of time before the government decided to relocate these stores in a less densely populated part of the city. After considering several possible sues, the govern ment offered to lease, through the Bombay Municipal Corporation (BMCl. 19 acres of land at Antop Hill m Wadala. to the north east of the island city (see mapi, tor the construc tion of a large warehousing complex. It was to be used exclusively for the storage of chemi cals that are classified as either 'hazardous' or 'extra hazardous' under the BMC Act. The protect was promoted by the Indian Merchants' Chamber (IMC) on behalf of its four member associations in the chemical trade: the Bombay Kariana. Colour and Chem ical Merchants Association; the Chemical and Alkali Merchants Association; the Chemists and Druggists Associations and the Indian Chemical Manufacturers' Association. In *982 the AHWC was incorporated with a there capital of Re 25 crores. a 20-member board of directors with equal representation of fhe participating associations and with IMC *-president |. N. Cuzder as chairman. The complex, which is estimated to cost 14 crores. consists of it large warehouses k>r chemical storage. Of these. 6 will be three- U(>reyed structures comprising a total of 1,040 independent units of approximately 6,000 cubic feet each, to store 'hazardous' chemi cals. The other 10 buildings are ground floor structures which together contain 140 units of the same size, but exclusively meant for 'extra hazardous' chemicals. Since the terms 'hazardous' and 'extra hazardous' were understood to refer primarily to the materials' explosive or inflammable properties, approval was sought and obtained from the Chief Controller of Explosives at Nagpur for the project's design and in particu lar its safety features. The chief controller of explosives, along with the fire department, were the only authorities to carry out some sort of technical and safety evaluation of the project: and it will be seen later how inade quate these were. A population of over 75,000 resides on the perimeter of the site. Within a one kilometre radius lie Parel, Dadar, Matunga, Dharavi and Wadala -- the combined population of which would be more than 1.5 million. Within a radius of 5 km, the better part of Greater Bombay falls Briefly, the safety features mcorporaied m the design of these buildings include S mch thick reinforced concrete walls, capable o> containing a blaze for four hours- a double layered floor with a sump in between 10 saieiv dispose material that spilled: large courtyards within each building and a 4 leet verandah encircling each floor to enable easier access to the storage units in the event of fire, two entrances to each unit lor ease ot movement and an automatic water sprinkler system tor the extra hazardous units. The -extra hazardous units are grouped m two rows on either side of an 11 too: wide uncovered corridor. Each unit is separated bv a 2 teet air gap from the next, and is prov .dod vv ith a large ventilator in its root f jcI Ihocx 01 14 suih units is further protesterI mrh .v.itei u'lams. The complex will n-i-p large quantities of water on site, in two i h cubic metre tanks, which can be pumped ou .it the rale of a WOO gallons per minute To minimise the risk pi accidental `pdls while handling containers, the movement oi chemicals within the rumples will be entirelv havexf on a system ot trnllvs and rlwjto'v The complex will also include a -pecai me station, a 1.200 line telepftone exchange and an electrical sub-station. The 1.190 units will be sold to members ot the panicipaling associations, subiect to a max imum of 1.200 sq feet each and restnenonv on the right of re-sale The purchaser shall be bound to use the space for the speemeo purpose, to be ensured bv a special allotment committee which will have 2 BmC repre<entjtives with "the right to veto an application on grounds ot improper use of valuable spare . as Cuzder puts it. Busmesslndia Septembe'22-October 5. PrSe 43 Cover Feature When the site was selected in 1975 the area was virtually uninhabited. Since then huge hutment colonies have sprung up in the vicinity As for the hazardous substances in question, they will include.any or the thousand odd items listed m parts II and III of Schedule M of the BMC Act of >888. including combustible solids and liquids, materials that emit inf lammable gases when brought in contact with water, substances liable to spontaneously combust, oxidising agents, corrosives and poisonous substances. All these materials would have to be packed m discrete contain ers or drums in the case of liquids, since AHWC does not provide iot bulk (tank) stor age Originally, the protect was to have inc luded storage of explosives as well, but permission for this was denied by the control ler or explosives. Cuzder describes the protect as "unique"; to the best of his knowledge, this is the only "integrated" warehousing complex for storing such a large variety and volume ot hazardous chemicals anywhere in Asia, perhaps the world. This could well be true Savs S. S. Barodia senior protect manager. Gherzi Eastern Limited, architects and consultants to the protect. "We asked our principals in Zurich for plans ot similar facilities in Europe or the L'S. but thev couldn't tmd any ". And that is precisely what is disturbing about the protect. It doe` not seem to have occurred to its promoters that the reason why nobody else m the world has thought of stor ing such a vast number ot chemicals in such large volumes m a single facility might he that the very concept ot such a facility constitutes i unique invitation to disaster. An important lesson the chemical industry learnt from the Bhopal gas disaster was that more than just the degree of toxicity or volatil ity of a chemical, it is the volume of the chemi cal m storage that determines the degree of risk involved. In the Bhopal gas leak, there can be little dispute that it was the sheer volume of chemical released that transformed what might otherwise have been just another chem ical accident into a catastrophe. This is why much of the efforts of the chemical industry since then have focussed on the need to minimise -- and wherever possible totally eliminate -- the storage of hazardous in termediates by their conversion into end products. This, in fact, was also one of the most im portant recommendations of the Environmen tal Safety Committee set up by the government of Maharashtra in the wake of Bhopal disaster, under the chairmanship of Dr. R. K. Carg. then director, chemical engineering group. BARC. The Carg committee, which was asked to evaluate saiety systems in hazardous in dustries m Maharashtra, recommended: "Storage of intermediate products which are hazardous m nature should be restricted to eight hours' requirements, and betore any plant is shut down all such intermediate products should be consumed". It is ironic that a committee set up to investi gate and recommend measures for preventing other catastrophic accidents on the scale of Bhcpal should have overlooked the one pro ject with such a potential. Carg says that AHWC was neve' brought to his committee's nonce. Worse still is the realisation that even after Bhopal, neither the government nor the industry no the extent that the Indian Chemi cal Manufacturers Association is a participat ing body i have learnt their lesson, and that the government is actually giving fresh induce ments to industry to store large volumes of extra hazardous chemicals in densely populated areas. AHWC'S proposed system of storing thousands ot tonnes of chemicals in drums and cylinders cannot be described as an ac cepted method of chemical storage at all. Drums, cylinders and carboys are used for temporary storage of chemicals and for ease of transport. Storage for any duration and on a large scale is an extremely complex (not to say. hazardous) affair, requiring extensive knowledge of the properties ot the chemicals, especially their affinities and behaviour under different circumstances (temperature, pressure etc). Bulk storage poses enormous technical problems of maintaining the material m a stable state, and in the event of an emergency of disposing it sately. Established industrial practices therefore stipulate that storage and safety svstems should be specincallv adapted to the material being stored. The tanks holding the chemical must be constructed of materials that the chemical does not corrode, the themical might have to be stored under pressure m an inert atmosphere or insulated irom moisture m the air: it might have to be continuousiv agitated to maintain urnc-m con sistency and temperature: the tank might have to be insulated and refrigerated depending upon the storage temperature required Some < hemicjls 'eouire the addition ot inhibitors to prevent the material from reacting wuh n.eit upon prolonged -touge. others have to be trequentlv mniinred with the help 01 pressure lempetjture and level indicating instruments In spue ot these precautions, were ihe stored material to become contaminated, there could arise the possibility ot its unde-go ing a violent reaction, generating heat and pressure and resulting in an explosion or m the material escaping into the atmosphere To cope with such an exigency, the storage unit would have to be provided with pressure/eiiet systems which allow excess pressure to ty* relieved, water deluges to rapidly cool the tanks and finally, scrubbers and incinerators to neutralrse the material before its release mio *4 Busmesslndia September .''-October 5. 1986 Cover Feature the atmosphere. The design of the AHWC does not relfect any awareness of these essential require ments. Conceived as a temporary storage or transhipment facility, the warehouses will not be equipped with either storage or safety de vices. But there is reason to believe that in practice, the facility will be used for more than temporary storage. The few safety features that have been incorporated in the design are based on the mistaken assumption that fire constitutes the mam hazard. (Recall, for inst ance. that there was no fire in Bhopai.i And here again, the emphasis is on effective fire control, quite oblivious of the fact that it is the proposed storage plan lor rather the lack of one) that, more than anything else, increases the risk of fire. The crucial flaw in the proposed storage plan lies in its indifference to the danger of violent chemical reactions occurring between stored chemicals, ie the problem of chemical incompatibilities and affinities. The Safety Data Sheet for every chemical lists, under a separate head, 'reactivity data', ie. the subst ances that the chemical in question is known to react with and should thereiore be kept away from, for example. Ammonia (which is used in the manufacture of explosives, synth etic fibres and nitric acid) "reacts vigourously with chlorine, bromine, iodine, chlorate and hypochlorites releasing heat and poisonous gases... and may form explosive compounds with mercury, gold and silver". Or Acetone la solvent tor pamts. plastic and rubber and a chemical intermediate! "reacts explosivelv in contact with potassium tert-buioxide. sulphuric acid-dichromate solution . and may react explosively with oxidising agents such as chlonne. oeroxides or permanganate." Over a decade ago. recognising the dangers ot chemical reactivity, the UN committee of experts on the transport or dangerous goods devised a nine fold classification 01 hazard ous substances, explosives comprtnw*! or liqumed gases, inflammable liquids, inflamm able solids, oxidising substances, toxic vuhstances. radioactive substances, corrosives and miscellaneous substances. On the basis of this classification, the International Maritime Organisation developed guidelines for stow ing these substances on board ships, specify ing the minimum distance to be maintained between goods of different classes. The lowest category (requiring relatively smaller physical separationi specifies that the substances must be ''separated by a horizontal distance of not less than 3 metres"; the second category specifies 12 metres; the third states that the two substances should be "separated by a complete hold or compartment" and a distance of not less than 20 metres; the fourth category raises this to 40 metres. For instance, explosives, almost in every case, are grouped under category 4; organic peroxides are also grouped in category 4 in respect of inflamm able gases, category 3 in respect of inflamm able liquids and category 2 in respect of all other groups: and soon. By contrast AHWC's two fold classification of all the substances it intends to store as 'hazardous' and extra hazardous' is utterly in adequate and quite meaningless. It relies on a distinction made in schedule M of the BMC Act which groups combustible liquids into three categories to determine the maximum permissible limits for unlicensed storage. Thus the extra hazardous' category includes any liquid that has a flashpoint of less than j:C. while hazardous' applies to those with flash points ranging between J3`C and (>i:C. (Flashpoint is the temperature at which vapour from a chemical can ignite.) This classification is meant for licensing purposes and was never meant to function as the basis for a rational storage plan. AHWC has arbitrarily selected an index of volatility tflashpointi as the basis for its storage classification. Apart from the obvious fact that this index is specific to inilammable liquids, which makes it quite irrelevant as a basis for classifying either solids or gases, the more im portant point is that this classification comp letely ignores both the toxicity and the reacti vity of the materials stored. Why AHWC should insist on separate buildings tor storing the two classes of subst ances is something of a mystery, considering that within these buildings, and in fact within every one of the units, wholly incompatible chemicals are permitted to be stored. The word 'permitted' is a bn misleading be cause there is no indication that the AHWC's promoters have even considered the issue This is apparent from the fact that every one ot the >40 units for 'extra hazardous' goods has been provided with an automatic water sprinkler system for tire control. Clearly, units with water sprinklers are highly unsuued for storing chemicals listed under section 4.3 oi the UN code, ie substances which on contact with water emit inilammable gasses. Where, tor instance, would AHWC store methyl isoevanate (MIC), the gas involved in the Bhopal tra gedy f It has a flashpoint of -- 'B'C and reacts explosively with water. Little wonder then that S. B. Chandalia. professor of chemical en gineering, University department of chemical technology. Bombay, describes the protect as "absurd" and highly inconceivable." lust how serious this problem of chemical reactivity is can be seen from the fact that the only other warehouse used for storing hazard ous goods, operated by the Bombay Port Trust (BPTl at Haji Bunder, has seen 3 major tires since 1975, in each of which an entire godown was destroyed. In everv case, the cause of the tire was ultimately traced to the improper storage of highlv reactive chemicals. The BPT. at least, appears to have learnt some thing from these accidents. Its new hazardous cargo warehouse currently under construction at Hap Bunder incorporates the International Maritime Organisation guidelines, with sepa rate storage areas for the 8 different classes ot goods. The absence of a segregated storatte plan, coupled with the fact that the storage units will be privately owned, makes the al'eadv dntivult tob of regulating chem-cal xtotage quite impossible. Even if a detailed inventors of the materials stored, their quantity and location within the complex was to be maintained, this would not ensure against im- The AHWC's share capital is Rs 25 crores. It is headed by a board comprising representatives of the participating trade associations Busmesslndia September 22-October 5. /9flt> 45 Cover Feature proper storage Nothing prevent* " indi vidual from placing container* of incompati ble substance* in close proximity to one another. Given the present arrangement, the only way to ensure sale storage would be to keep the 1,190 units under continuous surveill ance. but the BMC'* team of lour inspectors from the licensing department, or lor that mat ter any staff that AHWC might employ for the purpose, are hardly likely to be able to monitor even a fraction of these. And their job is not made any easier by such routine trade tmailpractices as mis-labelling containers, understating the quantities stored and disguis ing the containers to resemble non-hazardous cargo. It need hardly be stressed just how difficult this will make the task of fire control within the complex. Here, for instance, is what the Shell safety manual recommends: "Most im portant: know what you have got and where it s. Have a ground plan kept up to date... so that correct fire fighting procedures can be ap plied with maximum speed... group products tor nre-nghring purposes into lots where water or roam can be used and into lots where only dry powder can be used." It should be evident from this that the "ap provals" obtained from the Chief Controller of Explosives amount to very little. AHWC'S ran dom storage methods blatantly disregard even such elementary and self-evident rules not only preclude the possibility of effective fire control, but actually increase the possibility ot tire. Cuzder qune candidly admits that the pro tect's planners have not given any thought to the problem of chemical artmities. Theoreti cally. nothing prevents AHWC even at this stage from regrouping the individual storage units along the lines of the Haji Bunder Warehouse, but would this be acceptable to the users' Very unlikely, for the reason that each trader deals in a variety 01 chemicals and would insist on keeping the enure lot in his possession. This allows him great flexibility in his operation, and more important, makes him so much less liable to any form of regulation or control Consider the wealth of information that a detailed inventory plan would provide to the tax department' Civen the current busi ness practices of chemical dealers and small manufacturers, any storage plan based on complete and detailed disclosure of informa tion about the materials stored would be sure to run into stiff opposition. Even if the warehousing protect were not so obviously unsafe, its location in the midst of the island city is sufficient cause for grave anxiety. When the sue was selected m 1975. the area to the east ot Antop Hill, stretching from Kohwada to Sewn, was virtually unin habited It had the advantage of being situated Over ten years ago a chemical fire claimed 40 lives and gutted 8 buildings at Vadgadi, a traditional trading centre on the northern boundary ot the dock estate, thus permitting direct transport of these hazardous materials irom H.t|. Bunder without having to use publu fhoroughiare*. Moreover. BMC officials claim that Antop Hill provides a natural barrier between the site and neigh bouring communities in W atlula and Matunga to the west final's thev aryue that a north east location is iv-t -i ii-.si inr naz.irriouv in dustry as the dominant wind pattern over Bombay ifrom the North we-t or South westi ensures that emissions or escaping malenjl would be cameo awa* irom populated areas. However, m the ten sears that have elapsed since its selection, the vile has lost almost ev ery feature that had once recommended it. Huge hutment colonies have sprung up m the vicmitv. some or which a'e actuallv located on land earmarked tor the p-tnect Some ot these might be relatives recent but others like Kamla Nagar. Shanti Nagar. Dalit Nagar. Barkat Alt and Canesh Nagar have been inc luded m the last census m tart, the largest of the bastis Sangam Nagar. probably has a population in ever-- u' .'S iHXj To the north ot the site, across the Indian Hume Pipe plant, lies sector 7 ot the Central Government Staff Quarters with at least another .>0.000 inhabit ants. To the south west, the BPT has con structed a large housing complex tor ns workmen. All this could mean a total population of Over 75.000 residing on the perimeter ot the tile! In fact, if one were to draw a one kilometre arc with the AHWC site at its centre, the area enclosed would include Sewn to the south, Parel. Prabhadevi. Naigaon. Dadar. Matunga. Mahim. Dharavi, Sion and Wadala -- the combined population of which would be in excess of 1.5 million. Extend the radius to 5 km and the better part of Greater Bombay is covered. To put the issue in perspective, it may be useful to consider that |ust 40 tonnes of MIC seeping from a tank m Bhopal spread over 40 sq km in the space of 1 hour, killing over 2.500 people and injuring another 200.000. AHWC, with over 7 million cubic feet of stor age space, could potentially hold 50.000 tonnes of extremely hazardous chemicals. In a 'worst case' scenario, the consequences of a mishap involving such huge quantities can well be imagined. As it this were not sufficient, the Indian Oil Corporation operates a tank farm on Antop hill, where over '0 million litres of kerosene are stored The distance between the site and the tank does not exceed 500 metres Aw-explosion in the chemical complex could have a disastrous impact on the tank tarm. And offi cials of the Indian Oil Corporation are not even aware of the nature of the AHWC proiect coming up right in their backyard! In the event of an emergency, the neighbpurmg population svould have to be evacuated But both the maior routes leading out of the city on the east pass so close to the site that thev would in all likelihood be un approachable. In any case the siting ot the citv s new truck terminus adiacem to the AHUC site will oniv increase the volume ot tr.vnc on :`ir-e mutes, rendering them impassabie ip th, event 01 an evacuation. Fma'l*. the dominant wine pattern oieo in support ot the location does not give a verv good indication ot condition* on the ground. In tact, as meteorological department itself stales, the surrace winds blow from the NE sector upto li'JU hrs 1ST. From I >J0 hrs onwards winds blow irom Si\ sector upto 21 JO hrs Subsequentlv the wind graduall* weakens with in creasing calm conditions and turns to the NE sector The point being that land breezes blowing through the night would carry anv airborne material from the site towards the city. In the context of a maior chemical 'ire which generated toxic fumes or even an acci dental leak on the scale of Bhopal a '00 rt hill otters very little protection indeed. It isn I very surprising thereiore that almost everybody familiar with the protect, except of course its promoters, agree that it is fraught fc Businesslndia September 22-October 5. I9ht> Cover Feature That such an ill-conceived project should have progressed so far speaks volumes about the competence of our regulatory authorities and the recklessness of those involved with risk. R. K. Garg. for instance, points out that the project having been conceived 9 years before Bhopal should be subjected to a fresh scrutiny by a committee of experts. At the same time, government as well as BmC offi cials try to justify the project on the ground that even in its present form the project pre sents a safer alternative to the present system of unplanned storage in the congested B & C wards. But is this really true? For one thing, instead of the present widely dispersed storage. AHWC seeks to concentrate these extremely hazardous and volatile chemicals at one point, thereby actuaiy increasing the risk man ifold. Secondly, the dangers that the residents of Vadgadi are spared are instead inflicted on those of central Bombay. The argument about the proximity of the site to the port, which therefore obviates the dangers of transponing chemicals by road is equally specious: con sidering that the bulk of these chemicals are intended for consumption outside the city of Bombay they will in any case have to be transported on city roads. Besides the user in dustries in the city are in any case under pres sure from the government to relocate. Why should they be allowed to enter the city at all? Consider that the BPT does not allow the stor age of extremely hazardous substances fwhat it classes under group A) anywhere in the dock estate. These goods have to be unloaded ip mid stream, carried in barges to Haji Bunder and immediately taken possession of by the consignee. Explosives are unloaded only in the Naval Dockyard. But more important, AHWC significantly in creases the risk of catastrophic failure by en couraging a larger quantity of chemicals to be stored, ft is estimated that about 25.000 sq feet of godown space is currently used to store chemicals in the city. AHWC seeks to increase this to almost 6,00.000 sq ft. BPT handles a total of 40,000 tonnes of hazardous goods a year through its Haji Bunder terminal. AHWC can store this entire quantity at one timet So what is the alternative? The storage of hazardous chemicals within the city's B and C wards cannot be allowed to continue: but neither would it be prudent to relocate them elsewhere within the city. The most obvious solution would be to shift the entire project to the mainland as in the case of wholesale markets for agriculture produce and iron and steel. Nhava Sheva port offers a point of dis charge for these materials and a separate pier could be provided (or reserved) for this purpose. The Maharashtra Industrial Develop ment Corporation (MIDCl has several sites earmarked for development as industrial zones. One of these could perhaps be allotted for constructing a warehousing complex along the lines of the new Haji Bunder warehouse. Such a location would also be advantageous in view of its proximity to existing centres of chemical manufacture at Thana, Belapur. Taloja, Rassayani, Patalganga. Thai Vaishet and Nagothane. the sue of IPCL's Rs 1.200 crores gas cracker project. While shifting the protect to a less densely populated area makes eminent good sense, such a measure would still not eliminate the intrinsic-hazards of large scale chemical stor-' age. Ultimately, the answer would have to lie along the lines suggested by the Carg Commit tee: reduce inventories of hazardous in termediates to an absolute minimum; elimi nate the need for process storage by adopting continuous process, closed loop systems: and most important, like the BPT. insist that users take delivery of these materials directly from manufacturers. Says Professor Chandalia. "Why should traders be allowed to import such hazardous chemicals? Let users do it. When the law is weak and authorities incap able of enforcing it. how can we permit such a decentralised method of storing and handling highly toxic materials?" One could go a step further and asJrwhv the government permits the handling and storage of dangerous substances by small traders and manufacturers who lack the financial and technical capacity to do so safely. Instead of complaining about the inadequacy of re sources for creating an enforcement machin ery, the government should consider whether it wouldn't make more sense to restrict the possession or use of such materials to those who can make the requisite investment in safety equipment, and who can afford to con tinuously monitor and improve the process employed with a view to making it safer to' the public at large. In reconsidering the Antop Hill project and in evaluating possible alterna tives. the government would do well to extend the scope of its deliberations to answer these questions. It is shocking that such an ill-conceived pro ject should have progressed so far. It speaks volumes about the competence of our regulat ory authorities and the recklessness of those involved. That even the catastrophe at Bhopal has not sufficed to force a re-examination o' the project, let alone its abandonment, is truly amazing. Every single element that combined to produce the horror of Bhopal is present m the Antop Hill venture -- large quantities o' highly volatile materials, insufficient care m storing the materials, inadequate safety pre cautions and a large neighbouring community at risk. That a threat of such a magnitude could be so casually overlooked by all concerned sugests something more than callousness, it is as if Bhopal never happened. ARUN SUBRAMANIAM Businesslndia September 22-October 5. 198b 51 A New Wave of Environmental Laws Looms By Lana Lux Jut a. WM will mark u>e onset of t Oood ot arw Vaflh. safety and environ wimtai refutation that wit: nunp that of the rirly irfc Impossible* Didn t refula tion dry ip a MB with Ronald Reifans maivdxif to "pt tkr fovenunent off our tarts ' To hr suit. Rail. Burlord lr Co. anempted 10 runail refutation. or al trail to tort Uv flow But they soon departed as babiMiei. leavmf Utr afencies with Techurn: admimsirators and instructions tot 10 aatafontae either Utr public or busi- arts For ait stirs Mr Rraran has forused on tain, the budfe: drlint and defense fx prndnurrs. Inmrmion has no: soKrd Utr hralih and mvironmrmal problems Su years of arrumulatini pressure is about to eiplndf Tbr majority of Amrncans ton unur to wan: aomethmf donr about tout waste dumps, viler quality', air pollution and occupational haaards. Ko one should doubt the politicaJ appral of these lasurs Conpess delayed adjourn ment and rampaipunf lor rrrlmwn to pals tnr Suprrtund and Drinking Rater Arts Overwhelming majonttrs voted for lavs that will impose major costs, that could be used to halt industry and that wil: dr tittle to improve hralih or thr envi ronment Thr bills torus on unrralisiir worst rases and hypothetical risks, and emcndv unattainable foals they diver, at muon (ran present tnvtronfflmul pcob Irms such u rvdon ut homes Jus before an election. Mr Reagan could have tested his 1MB mandate, vrtoinr burdensome, tinBund lefulauon. If he had. the Republican Senate vas ready to override. Separately, he did veto an egrefwus pork bairrl ' clean water'' bill that in cluded sewer projects It s I feed bet Conpress will put that one over Uve top when it reconvenes. Unking ahead to IMS. will presidential candidates tell the voters in New Hamp shire tha: Mr. Reagan vas npht to do aothtnp about acid rain eacept some ill-fo cused research? Who mill say that the Rea pan regulatory apencies have done such a food job that no further action need be taken an atr pollution, dnnkmf water, vaste dumps, occupational health and safety. and nuclear power? No presidential candidate could wm without atienduif to the environmentalafety issues that have been tpnored by President Reapan Candidates will vie to he responsive to perceived needs, widening the rift between business and the public. The day will have passed when tela lively' inexpensive controls on sulfur emis sions. which could have been tned but haven't, will buy tune for understandinp arid rain The slowness in settmt occupatmal carrinofen standards sill prompt Yesterday's News Today By D'vxir C Smith 1 don't remember a lot about my col teg- journalism classes. 1 d<- recii: the introductory- course brinf deioted to memuruinf Who-What When Where ino Why and tryinf 10 remember wh< John Peter Zrnff was In Journalism II r learned to ask tmpeninent questions, and i he rest of the four years was spent vntinf anti-esublishm*n: articles for the school paper Our paper a as markedly short or hard nrvs and lonf on inti-astablishmr: editonals Or.r thing tha- vasn t taufht vas that vonderdul new (paper crutec- Anniver tarv Jourhalisr- or two for the pmr of one or, every nes story This allots the paper to vait for 12 months and then re hash thr same thing undet the "Time Flies' or "Has It Realty Been a Year" category I wax firs: impressed with this thoufh: one pi*a,an: spnnj day a fe* years agi-- iUrrt. i JVC i<. be pmise-vher. J uv ar. unt'-ided mnminf paper and knew that the fume John Hinckley vould present it sel* snmevhere on the first tv pares It did Tre- day vas the first anniversary of Hmraiey s unsuccessful stiemp; to remove Ronald Reafar fruen office I ran already inncipate murh of the , n-v spa per output for ttie commf year In ]V' r vu: see remembrance. or. the ioth i anniversary of thr Lindte-rrh li.fh: iMay I >:: and the firs: mutuc. pict-.r- mnn a : sound trark The Jay Singer itrt * * Thor vfK- prefer ye; anro er*anev ran I read alaai- tty Hindennurg disaster 'May t e ano tre Japanev- smkinr nt tin Amen far. j"sh:f Panav 'Le-i 12--vr wit! see It all replayed before our apalheur eyes. For those who want aomethinf a bit more current, and perhaps a tad more folksy. Billy Carter introduced Billy Beer on Oct. 11. Itrr. and Key West. Fla., se ceded from the Union lor one day lApnl D m IK. establishinf Itself as "The Conch Republic.'' Those writers lookinf for M- and five-year anniversaries are already halfway home on those days What we are talktnf about here a frowmf trend in the newspaper business to five the archives more prominence than the traditional helper, or tacaup. role that those treat vaults ha ye always played. (RTiat s more, papers these days have re minder lerrices lest they forfet 11 suspect that many newspaper writers start the day m the files, lookinf for anythinf that hap petted on whatever date it happens to be: and if they have to settle for a lire tn a ahoelare factory, b be It. Frankly. I would like to see the end of Anniversary Journalism With thr rxrrp tmr. of the Fourth of July and possibly Er rol Flynn t bmhdav Uunr 2ft-. 1 done see a lot tha. is worth commemorattnf In aewspnn: I want to know what is happrnms now and what mifht happen tomorrow, and I have little interest in a droll down memory lane with thr unstained wretches It all Orals down to a desire lor more who whai when-where-ind whvinda tor less ternpus fuftt I think that Horace Greeley and William Allen White would ifTre with mr Thr vremi atmtman of Ifr Smirk's Joonuit drbvf comes ap Mama bans ar Impossibly stringent standards. The failure io develop a profram on toxic ehrmicais in thr environment has led to wastutf buttons of dollars and given rue to Superfund and California a Prep C. an even harsher measure that passed with m of thr vote last month Chlorefluorecarton rrfnferants may be banned imme diately to protect atmospheric otone. rather than vis a five-year phase-out that would aJkrw development of environmen tally brnifn substitutes. Not takinf umely action shifts the de bate to moms and trust, away from how 10 accomplish near-term foals effectively. By 1M9 a Utoufhtful approach will be pre cluded by the perceived need to act. TV nation is about to repeat the mis takes of the ll?bs with ieftsliuon tnd refu tation that are inefficient and ineffective. The scientific -basts of the lfTOs decisions ns slim and often reflected outmoded or even incorrect science Billions of dollars were wasted on aewiff-trraunent plants that were never operated, tall stacks to dif fuse air pollution over a larfer area, and Jerry-ntfed auto-emissions control. In the haste to V responsive to public demands. Conyiest and the repulsion fuessed rather than wait for farts and analysis to ftude mulubilDon dollar decisions Offi cials failed io inform the public about what was possible. A repeit buife in IMP will result in par tial paralysis, more markets lost to foretfn produren. and an environment not appre ciably cleaner oor Americans appreciably safer. If the scenario seems pessimistic or cynical, look tt the extern to which the foundation for decisun-makmf has been Unproved. Scientific advances in the past decade have done little to resolve the de bate about tV health effects of sulfur ox ides and otone m the air or trxer amounts of cVnucals in water. Of the ftt.dOO com monly used chemicals, only a tiny portion has hem tasted far totuctty (Xir tgno- Notable & Quotable Jetnc Kirkpatrick. former V.S am bassador to flu t ailed .Various. Ii a re port pabtishri earlier rAis pear bo the fffhirs ami Public Paltry Crefrr. "His tory. Geopraphp. and Citunskiy: Thr Tterkrr j Mole ": How can wa prepare ourselves, not to mention our students. tor responsible par ticipation as democratic omens in such s society and world as ours* 1 believe that, u teachers, we must do our very best to communicate to students the basic condi txtninf factors of the world in our time. Amonf these are the basic facts of feofrapby I truly brlieve that many of our moat bitter foreifn-pohry disputes are a direct consequence of the fact that Americans de cided sometime not to sludv feomphy anymore My tens attended French schools lor two yean, and I know that the French, at least as of five or sta yean sgo. had not abandoned frofraphy It was tn impor tant. intensive course I myself live as rooms with world maps on the walls It is Impossible to think seiuiblj about foreifn affain without knowing what tt whrre nan has actually increased since the sue af tV problem has frown more rapidtv than anentifx understtndinf A more premising scenario is possible We aren't lemmmfs and can see the ett!! TV Reagan administration and business hare two more years at bat to demon Brute that health-ernrwunenu: programi can V effective and efficient tn meetin; tV public s foals, as many hoped would occur m IttJ Twenty-live months remain to show that air and water quality ran be improv ed without needless expenditures ot disruption, tha: the most ur.por.am occu pstiona! health and product safety issues can V handled, and that a policy can be developed to handle the prrssinj toxics problems, despite the controversy about IV ultimate solutions Even it the White House doesn l act. business and the afett ciaa cas work cooperatively io shore up the scientific foundation, learn about tv basis of public fears and desires, and learn how to initiate a dialofue with the public io de cide how safe is sale enoufh and how clean Is clean enoufh. Twenty-five months is not sufficient tune to complete this foundation, but beftnninf now is fir less cosily than davdreaminf until IMS Anyone w-uh the cour iff to look will see the Phoenix snrnnf in the ashes of environmental policy Mr. Lltvr is Jfipoies processor o' frosormrl af ContyirMtlwi i Gmit-nii School of Mustnnl idii.ins.'-n-ni nr - n consultant to the Emiromhcmn! Pratertn--. Atncu. THE WALL STREET J01R.VU. . ObfME Cktrl iwft ra sik# Prrhtdrnt WiwNikB QrinPr Cdtia* L Iwiflvr f>Mr tdm* PotbiAii Ptisbe II'mttimFfrhmtJfmnt.ui|u* La* Mot iirr ^vtasrni Crr+U/sot Tr%*k C. LU Itrr Ppp^f+t C^WVWb wot IMf DOW JONES 4 COMPANY. INC CAiurttJ ul frpOTi m LiW>r towv \mk. S \ iBJt T4rf*MOT (1tl141*IMC MtIUpau ^>i htJrni DwK A MiriniM > ** TAdt/m** WUb* L Duba A Kma tiPT*tn* \ mm NWhih AfmotA L SnOTAft Vm A D**L C JtM H. On*B Sotoot r? riw^f Inwlll eW'Ma*'* t>OTiK L MOOT Sf/rKbmp ; (Lmr* PbBMhrw m0 Cm*rr%Ur PeOTn a .Vhm.ii. 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