Cleaning up our Kodaikanal site - our position, in full
In 2001, it was brought to our attention that glass scrap, containing residual mercury had been sold to a scrap dealer about three kilometres away from the factory, in breach of our guidelines. On discovering this, Hindustan Unilever (HUL) immediately shut down the factory and took all the glass scrap with residual mercury along with the soil from the scrap yard back to the factory for safe storage. Subsequently in 2003, HUL sent all mercury bearing material including the glass scrap from the scrap yard to a mercury recycler in the USA, after obtaining appropriate permissions.
The ceasing of operations in March 2001, the removal of all mercury-bearing material in 2003 and subsequently the decontamination and safe disposal of plant, machinery and materials used in thermometer manufacturing in 2006, have removed any risk of contamination to the ecologically sensitive region. However, we need to remediate soil within our factory premises.
To begin the clean-up, we need to receive consent from the Tamil Nadu Pollution Control Board (TNPCB) – the statutory authority. Permission to begin the clean-up at the set soil remediation standard of 20 mg/kg was granted in July 2008. The pre-remediation work began in 2009. However, in 2010, the TNPCB decided to have additional studies conducted by eminent national institutions in response to some activists contesting the soil clean-up standard of 20 mg/kg and subsequently asked HUL to stop the remediation work.
The TNPCB and the Scientific Experts Committee (SEC), appointed by Supreme Court Monitoring Committee, reviewed the studies and set the site specific clean up standard of 20 mg/kg. The Central Pollution Control Board (CPCB) – the foremost organisation that deals with issues concerning pollution control under the Ministry of Environment and Forests, Government of India – to whom the TNPCB had referred the matter, also approved the clean-up standard.
Some activists have made misleading claims about this complex issue which has resulted in further confusion. We want to make sure that the facts are accurately represented.
Determining the clean-up standard
The proposed clean-up standard of 20 mg/kg mercury has been determined based on a site specific risk assessment study. Taking into consideration factors such as soil type, exposure scenarios, and the sensitivity of receptors, both human and environmental. Important inputs to this proposal were:
- A risk assessment study done by NEERI in 2007 as directed by the Supreme Court Monitoring Committee and the Site Specific Human Health & Ecological Risk Assessment study conducted by IIT Delhi in 2010.
- A study on the impact on soil and soil erosion by Indian Institute of Soil and Water Conservation Research Centre, Ooty, in 2010.
- A study on the impact and preservation of trees by National Botanical Research Institute, Lucknow, in 2011.
The expert studies conducted by these institutions of national repute were reviewed by the TNPCB and SEC before confirming 20 mg/kg as the applicable remediation standard in May 2013. The CPCB also confirmed this standard in April 2015 after reviewing the results of all these studies.
However, some activists are campaigning for the 20mg/kg standard to be arbitrarily lowered by incorrectly referring to preliminary screening criteria of various countries to make their case.
This is misleading because these screening criteria are solely intended to identify if a risk assessment of the site is warranted. They do not mean the affected site should be cleaned up to that level.
International best practice dictates that if soil remediation is required, the clean-up standard should then be determined based on a site-specific risk assessment - taking into consideration factors like the surrounding ecology, the soil type, and the expected human exposure levels.
The 20 mg/kg standard set by the TNPCB for the soil in the factory has been determined based on this site-specific risk assessment approach. At this level, not only would the soil be safe for a child to play in and to grow vegetables in, but the clean-up would be protective both for humans and the environment.
Remediating the soil at a lower standard will result in uprooting of more trees and greater soil excavation thereby leading to risk of much greater ecological damage in the hilly terrain where soil content is not uniform.
- An estimated 300 trees will be affected / removed if the standard is 20 mg/kg. If the standard is taken to 6.6 mg/kg (as currently suggested by activists based on current Canadian Soil Quality Guideline), an estimated 3 to 4 times the number of trees would be affected / removed.
- We estimate that the area to be excavated would be approximately 10,000 m2 if the standard is 20 mg/kg. If the standard is taken to 6.6 mg/kg, the area to be excavated would be around five times more – causing significantly greater disturbance of a fragile ecosystem, and implications for soil run-off and landslides.
Getting to work
TNPCB is the statutory authority to set the soil remediation standard. In consultation with SEC they have set the remediation standard to 20 mg/kg based on the risk assessment study at our former factory site in Kodaikanal. The CPCB has confirmed this standard which is based on science and follows international best practice. We believe it is in the best interests of Kodaikanal that we remediate the soil as soon as possible to a rigorous science-based standard, which is protective of both human health and the environment.
On December 31, 2016, HUL received permission from TNPCB to commence preparatory work and trials for soil remediation at former factory site in Kodaikanal.
HUL commenced soil remediation on a trial basis at its former factory site in Kodaikanal on August 16, 2017. The trial was conducted for a period of three months and was successfully completed in November 2017 in accordance with the Detailed Project Report and as per the approval given by TNPCB. To read more about this, please click here.
In February 2018, HUL submitted the final soil remediation plan for remediating the soil inside the factory premises to the TNPCB. The company is engaging with the TNPCB on next steps.
HUL is committed to cleaning up the site.