Pakistan _CA

StrategicApproachtoInternationalChemical
Management
SAICM
NationalCapacity
Assessment
forImplementationofSAICM
InPakistan
Dr.KhalidMehmood
November,2009

InternationalCooperationWing,MinistryofEnvironment
GovernmentofPakistan,Islamabad

NationalCapacityAssessmentofPakistanforImplementationofSAICM
The 2006-2009 pilot project in support of National SAICM implementation to "Strengthen
Governance, Civil Society Participation and Partnerships within an Integrated National Chemicals
and Waste Management Programme" in Pakistan has been supported by the United Nations
Institute for Training and Research (UNITAR) with the financial support of the Swiss Agency for
Development and Cooperation.
International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Pagei

Acknowledgements
The National Capacity Assessment was conducted as part of the SAICM project
initiated under the Supervision of Mr. Abid Ali, Joint Secretary, International
Cooperation Wing, Ministry of Environment and Focal Person for SAICM from
Pakistan. I acknowledge with gratitude the support of Mr. Zaheer Ahmed Gillani
National SAICM Coordinator, National Project Manager, Multilateral
Environmental Agreements Secretariat (MEAS) and Syed Hashim Raza, Subject
Specialist SAICM and MEAS, Ministry of Environment, Government of Pakistan,
who provided us guidance and their continued support throughout this project.
This work could not have been accomplished without the generous and gracious
cooperation and contributions of our stakeholders, especially, Federal Ministries of
Environment, Agriculture, Commerce, Health, Labour and Manpower, Production,
Law Justice, Industry, Communication, Science and Technology, Federal Bureau of
Statistics and their departments; provincial departments of Agriculture and
Environment; a large number of R & D organization and Non-Governmental
Organizations(NGOs).
I wish to extend our deep gratitude to United Nations Institute for Training and
Research (UNITAR) for providing guidance and financial support towards the
production of this report and for supporting workshops related to this project.
Special thanks are also extended to my all associates who worked diligently and
provided support during the production of this document. We have endeavored to
ensure our assessment based on situation analysis during preparation of National
Chemical Profile and inputs provided by our stakeholders, however, we would invite
commentonanyerrorsorinaccuracies.
Dr.KhalidMehmood
Senior Adviser and
Team Leader for
SAICMProject
International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Pageii

ExecutiveSummary
The Capacity Assessment and Priority Setting for the Sound Management of Chemicals and
National SAICM Implementation is a national project of the Government of Pakistan. The
Ministry of environment is responsible for the implementation of the project.
The primary objective of the project is to identify national priorities and needs for capacity
building in the key areas of chemical management throughout their life cycle, with the aim of
catalyzing domestic and / or externally assisted action to meet those needs in a coordinated and
plannedmanner.
The National Capacity Assessment was undertaken at three levels - individual, institutional, and
systemic capacity. Individual and institutional capacities are well known concepts. Systemic
capacity describes the policy and legislation framework and identifies relationships, collaboration,
and linkages amongst institutions involved in chemical management and use. The national
assessment also investigated cross-cutting issues such as povertyand decentralization, on sectors
including the chemicalmanagement.
Challenges to chemical management were identified and prioritized during the first part of
capacity assessment. Although Pakistan has the ability to adequately address some of these
challenges, there is a strong feeling that capacityconstraints centre around three themes: Financial
shortfalls; Lack of equipment, tools, physical support, and infrastructure; and Shortage of trained
and skilled personnel. From these, certain priority issues for action were identified:
Lack or limited technical and scientific capacity;
Indicatorsandmonitoringmeasuresforsound chemicalmanagement;
Insufficient laboratories, technical research institutions, tools and equipments;
Identification of adaptationmeasuresto chemicalmanagement challenges;
Lack of legislation dealing with disposal transportation and storage of chemicals;
Lack or limited data availability related to chemicals during its life cycle; and
Promotion of synergies across the government and other related institutions.
Thesepriorityissuesneed tobeapproached witha synergisticapproach.
Duringcapacityassessment, it wasfound that awareness levelsand knowledge about the chemical
management is very limited in the country. Within the implementing agencies, there is lack of
awareness of existing regulatory framework. The decision-makers have limited knowledge of FAO
and WHO specifications on pesticides. The decision makers and legislators are unaware of the
chemical safety measures. Even the environmental managers have low level of awareness and
knowledge of life cycle management concept. The academia and public are generally unaware of
International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Pageiii

the international conventions on chemical management and the concept of chemical management at
all. Individuals and institutions that indicate awareness of the chemical management concept and
conventions are not necessarily familiar with the contents as such. There is some level of
awareness among NGOs and trade associations, and they are playing their role to raise public
awareness to some extent, but they need capacity building exclusively in chemical management.
People involved at various stages of the chemicals life cycle, are unaware of the health and
environmental implications of the chemicals theyare exposed to.
Pakistan is striving in the right direction with regard to chemical management and awareness
related activities. There are key ministries, non-governmental organizations, and private
institutions involved in the sound management of chemicals in the country. The mandates of
ministries and departments are clearly defined and there does not exist any overlapping. There is
no need for a separate ministry dealing with chemical management. Trade associations, research
institutions and community groups are playing a vital role in creating awareness among public and
implementation of voluntary initiatives like ISO standards 9000, 14000 and OHSAS 18001. They
are also cooperating in Pak-EPA's SMART programme for self monitoring and reporting. NGOs
especiallyare playing very important role in raising awareness and educating the public for effective
participation in national environmental management initiatives (e.g. as stated in agenda 21 or the
implementation of Stockholm Convention) as well as access to justice in environmental matters.
Thepoorchemicalmanagementcanresultinincreaseindiseasescausedbyvariouschemicalssuch
as cancer, abnormal births, etc; unbelievable damage to environment and chemical accidents
causingfinancialand life lossas wellasdamage toenvironment.Therefore, chemicalmanagement
should be given due consideration bythe government and funds should be allocated accordingly.
Individual, institutional, and systemic capacity to address the concerns of the SAICM at the
national level is present to some extent. In terms of institutional capacity, despite clearly defined
mandates, relationships, collaboration, and linkages among institutions do not exist. An
environmental advisory committee, NTACC, has been established to complement existing
institutional capacity and enhance coordination among various institutions but the representation
of some ministries, NGOs, industries and academia is lacking. There is also a capacity constraint in
terms of identification of important information that could assist in the implementation of
different activities. Lack of external financing has also been identified a concern for most
government sectors. It has been found that government divisions that have access to additional
funding from international donors have access to relevant information and they have acquired
necessary capacity and facilities. Another major constraint identified is lack of technical human
resource available to the institutions. There is also lack of infrastructure for chemical management.
Capacity must be built in institutions so that they can capture data, negotiate effectively, and
addressthelegalaspectsrelatingtothechemicalmanagement.
International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Pageiv

Individual capacity constraints identified are related to lack of knowledge and awareness of the
concept of chemical management, lack of translation of expert knowledge to local communities,
lack of training and work incentives, lack of relevant infrastructure, lack of authority and limited
networking opportunities among technical experts and local environmental managers. Individual
capacity needs to be strengthened as well. There are no specific courses available for chemical
management. The additional modules are required in the curricula of the universities with
reference to the chemical management, waste management, waste treatment etc. There is a need
for the proper awareness and technical training of the workers. Most of the government
institutions are overworked, they should be provided with proper work incentives like promotions,
bonuses,etc.
Systemic capacity is inadequate with regard to policy and legislative framework, because there is
lack of coordination. Legislation related to different aspects of life cycle of chemicals, especially
with reference to import, export, production, use and disposal is very comprehensive, but the
legislation dealing with disposal transportation and storage of chemicals is insufficient. Most of the
existing legislation was not enacted for the specific purpose of chemical life cycle management in
particular. The penalties are not reformatory and stringent enough to deter the crime. The major
drawbacks behind the ineffectiveness and non-enforcement of regulatory framework are with the
inspections, monitoring, vigilance and public awareness. Therefore, no new acts are proposed but
few amendments in existing laws will be sufficient. With regard to international conventions, a
multilateral approach is being adopted for chemical management in the country through
implementation of SAICM. The international conventions have been incorporated in the national
legislation and are being implemented. Beside, GHS is yet to be implemented in the country. The
major loophole to the implementation of international conventions is the poorly managed
national data system related to chemical life cycle. It is therefore suggested that an integrated
approach to the safe use of chemicals should be adopted byestablishing effective mechanismsfor
following up and updating information on international instruments related to hazardous
substances.
Capacity at the systemic level requires effective implementation and monitoring impacts of laws
andpolicies.
International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Pagev

Acronyms
BAT
BEP
CBOs
CCI
EIA
EPA
FAO
FBR
FBS
GPA
GHS
GSP
HDIP
HEJ
HIES
IAC
ICCM
ICwing
IFCS
IGOs
ILO
ILO-OSH
IMO
INFOCAP
IOMC
ISO
LFS
LPG
MDGs
MEAs
NARC
NIAB
NDMA
NDMC
BestAvailableTechniques
BestEnvironmentalPractices
CommunityBoard Organizations
Chambersof Commerce andIndustry
EnvironmentalImpactAssessment
Environmental Protection Agency
Food and Agriculture Organization
FederalBoardofRevenue
FederalBureauofStatistics
Global Plan of Action
GloballyHarmonized System of Classification and Labeling of
Chemicals
GeologicalSurveyofPakistan
Hydrocarbon development Institute of Pakistan
Husein Ebrahim Jamal Research Institute of Chemistry
HouseholdIntegratedEconomicSurvey
Industrial Analytical Centre
International Conference on Chemicals Management
International Cooperation wing
IntergovernmentalForum on ChemicalSafety
Intergovernmentalorganizations
International Labor Organization
ILO guidelineson occupationalsafetyandhealth management
System
International Maritime Organization
Inter-Organization Programme for the Sound Management of
Chemicals
International Organization for Standardization
LabourForceSurvey
Liquefiedpetroleumgas
Millennium Development Goals
Multilateral Environmental Agreements
National Agricultural Research Centre
Institute for Agriculture and Biology
National Disaster Management Authority
NationalDisaster Management Commission
International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Pagevi

NGOs
NPRI
NTACC
OECD
OHSA
S
OPS
PAEA
PBTs
PCSIR
PDS
PEPA
PIHS
POPs
PPD
PRTRS
QSP
R&D
SAICM
SMAR
T
SOPs
TDS
TOC
TRI
UNEP
UNITAR
WHO
WSSD
Non-governmentalorganizations
National Pollutant Release Inventory
National Technical Advisory Committee on Chemicals
Organization for Economic Cooperation and Development
OccupationalHealthandSafetyAssessmentSeries
OverarchingPolicyStrategy
PakistanAtomicEnergyAgency
Persistentbio-accumulativeandtoxicsubstances
Pakistan Council for Scientific & Industrial Research
PakistanDemographicSurvey
Pakistan Environmental Protection Act
PakistanIntegratedHouseholdSurvey
Persistent organicpollutants
Plant Protection Department
PollutantReleaseandTransferRegisters
QuickStartProgramme
ResearchandDevelopment
Strategic Approach to International Chemicals Management
Self-Monitoring and ReportingSystem
StandardOperatingProcedures
TotalDissolvedSolidsTotal
Organic Carbon
ToxicReleasesInventory
United Nations Environment Programme
United Nations Institute for Training and Research
World Health Organization
World Summit on Sustainable Development
International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Pagevii

Contributors
MuhammadZafarIqbal
Mrs.NuzhatMahmud
HumaAfzal
MuhammadUmairSheikh
AishaSuddle
FromMinistryofEnvironment
SyedZaheerAhmedGillani
SyedHashimRaza
NationalSAICMConsultant,
Environmental/AnalyticalChemist
ResearchAssistant
DataAnalyst
ITSpecialist
Editor/National SAICM Coordinator,
NPMMEAsSecretariat,MoE
Coordinator,MEAsSecretariat,MoE
International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Pageviii

TableofContents
1.
1.1.
1.2.
1.3.
1.4.
2.
2.1.
2.2.
2.3.
2.3.1.
2.4.
2.4.1
3.
3.1
3.2
3.
3.1
3.2.
4.
INTRODUCTION
ContextandOverview
BackgroundonSAICM
OverviewofSAICMOutcomesandDecisions
LinkagesbetweenSAICMandAgenda21
NATIONAL SAICM CAPACITY ASSESSMENT
Objectives
MainComponentsofSAICMCapacityAssessment
AssessmentoftheGovernanceFramework
AreasforGovernanceAssessment
AssessmentofCapacitiesforImportantChemicalsManagementIssues
AreasforChemicalManagementAssessment
PRIORITY ISSUES RELATED TO CHEMICAL LIFE CYCLE MANAGEMENT IN
PAKISTAN
PriorityIssueRelatedtoGovernance
PriorityIssuesRelatedtoCapacitiesforChemicalsManagement
RECOMMENDATIONS
RecommendationsforGovernanceIssues
RecommendationsforImportantandUrgentChemicalsManagementIssues
CONCLUSION
2
2
2
3
4
5
5
6
6
6
14
14
26
26
27
29
29
30
32
ANNEXURES 38
Annexure1:WorksheetforGovernanceAssessment 39
Annexure2:WorksheetforIdentificationofImportantandUrgentChemicalsManagementIssues 69
International Cooperation Wing, Ministry of Environment, Government of Pakistan, Islamabad Page1

1. Introduction
1.1. Context and Overview
The Strategic Approach to International Chemicals Management (SAICM) was adopted by the
International Conference on Chemicals Management (ICCM) at its first session in Dubai in
February 2006. An important objective of SAICM at the national level is to build upon existing
chemicals management initiatives in various sectors and strengthen coordination and
coherence among various government and stakeholder initiatives. A second important
objective is to link these activities to national development planning (e.g. National Sustainable
Development Strategies, UN Development Assistance Frameworks, Poverty Reduction
Strategies, etc). In order to achieve these objectives, the SAICM Overarching Policy Strategy
(OPS) states that: "To sustain an integrated approach to managing chemicals, each
Government should establish arrangements for implementing the Strategic Approach on an
inter-ministerial or inter-institutional basis so that all concerned national departmental and
stakeholderinterestsare representedandallrelevantsubstantiveareasare addressed" (SAICM
OPS,Para.23).
SAICM provides valuable opportunities to build upon these activities and develop a long-term
strategic approach at the national level towards reaching the WSSD 2020 goal for sound
chemicals management. Such a strategic approach for national management of chemicals
would need,as calledforbySAICM, action bygovernment and non-governmental stakeholders
(including the business sector and non-governmental organizations), as well as between two or
moreplayersinvolvedinchemicalsmanagement.
1.2. Background on SAICM
The SAICM development process, which started formally through a series of sessions of a
Preparatory Committee ("PrepComs") commencing in 2003, included a number of key
milestones, including:
UNEP Governing Council, February2002
World Summit on Sustainable Development, Johannesburg, September2002
World Health Assembly, May2003
International Labour Conference, June 2003
World Summit, NewYork, September 2005
SAICM PrepComs 1, 2 & 3
First session of the International Conference on Chemicals Management (ICCM),
February2006
The development process was multi-sectoral and multi-stakeholder in nature, involving
representatives of governments, non-governmental organizations (NGOs) and
intergovernmental organizations (IGOs) drawn from sectors such as agriculture, environment,
health, industry, and labour. UNEP, the Inter-Organization Programme for the Sound

Management of Chemicals (IOMC), and the Intergovernmental Forum on Chemical Safety
(IFCS)wereco-convenersoftheprocess.
Development of SAICM culminated with its adoption by the International Conference on
Chemicals Management (ICCM) at its first session, which was held in Dubai in February 2006.
SAICM consists of three core documents (see below), supplemented by four resolutions
adopted by the ICCM on implementation arrangements, the Quick Start Programme, a tribute
to the Government of the United Arab Emirates and on the IFCS. It is expected that the
second session of the ICCM will be held in 2009 in order to review implementation and take
stockofprogress.
1.3. Overview of SAICM Outcomes and Decisions
The overall objective of the Strategic Approach is to support the achievement of the 2020 goal
agreed at the 2002 Johannesburg World Summit on Sustainable Development (WSSD). The
mainoutcomesof theSAICMprocessarethree keydocuments:
i. Dubai Declaration on International Chemicals Management
The Dubai Declaration, adopted by Ministers, heads of delegation and representatives of civil
society and the private sector, provides an agreed overview of the political commitments made
for SAICM. It reflects their "firm commitment to the Strategic Approach and its
implementation." In particular, in reinforces the importance of issues such as the linkage of
sound chemicals management to sustainable development and poverty eradication,
contribution of SAICM to the MDGs (Millennium Development Goals), implementation of
international agreements, and the roles of non-governmental stakeholders and importance of
partnerships.
ii. Overarching Policy Strategy (OPS)
The OPS provides information on the scope of SAICM, identifies needs for effective SAICM
implementation, and outlines objectives, principles, and financial and implementation
arrangements.Thefive categoriesof SAICMobjectivesfound in the OPS are:
Risk reduction;
Knowledge and information;
Governance;
Capacity-building and technical cooperation; and
Illegal international traffic.
iii. The Global Plan of Action (GPA)
The GPA is a more detailed document that outlines proposed work areas, activities, actors,
timeframes, targets, and indicators of progress related to SAICM implementation. The GPA
contains 36 work areas, and 273 activities, structured in accordance with the five categories of
SAICM objectives set out in the OPS. It is recommended for use and further development as a
working tool and guidance document for stakeholders implementing SAICM. Implementation

of the Strategic Approach at the national level (including the initial "enabling phase") is
suggested to include the development of national implementation plans.
Initial capacity building activities for implementation of Strategic Approach objectives are
supported, inter alia, bya Quick Start Programme (QSP).3 The QSP contains a voluntary, time-
limited trust fund, administered by UNEP, and may include multilateral, bilateral and other
forms of cooperation. The objective of the QSP is to "support initial enabling capacity building
and implementation activities in developing countries, least developed countries, small island
developing States and countries with economies in transition" (ICCM Resolution I/4).
1.4. Linkages between SAICM and Agenda 21
From a national capacity building perspective, SAICM gives more specific guidance to
countries for the implementation relevant provisions of Agenda 21, agreed at the Rio "Earth
Summit" in 1992. When adopting Chapter 19, the Heads of State at the Rio Summit
concluded that elements of sound national chemicals management should include the
following:
a. adequate legislation;
b. information gathering and dissemination;
c. capacity for risk assessment and interpretation;
d. establishment of risk management policy;
e. capacity for implementation and enforcement;
f. capacity for rehabilitation of contaminated sites and poisoned persons;
g. effective education programmes; and h.
Capacityto respond to emergencies.
In developing the approach and methodology for the national SAICM capacity assessment, a
practical approach has been taken by building upon and bringing together the core elements
outlinedabove.
Pakistan is signatory to the SAICM. The Implementation of SAICM in Pakistan will affect a
large number of stakeholders belonging to public, private sectors and civil society along with
interest groups like labour organizations. The IC Wing Ministry of Environment is the focal
point for implementation of SAICM in Pakistan which is striving to carve out a way forward in
consultation with major stakeholders. First consultation with civil society organizations was
held on 14th November 2008. First meeting for establishment of Inter-Ministerial
Coordination Mechanism was held on 3rd January 2009. International Coordination has been
established through UNITAR (United Nations Institute for Training and Research). A
UNITAR Mission arrived in Pakistan from 19-27 January 2009 which held discussions with the
Federal Minister, Secretary, Additional Secretary and Joint Secretary Ministry of Environment
as wellaswith some otherstakeholderssuch asPakEPA and FBRetc. The Mission discussed in
detail the possible course of action and possible pitfalls with the National SAICM
Coordinator /National Project Manager MEAs Secretariat. Meeting of National Technical

Advisory Committee on Chemicals (NTACC) was held on 21st April 2009 which made
decisions on regulating manufacture, import, export and use of various chemicals falling under
international conventions.
The initial consultations built consensus that following actions need to be taken on priority for
the development of an action Plan for integrated chemicals management in Pakistan: 1.
Development of a National Chemicals Profile.
2. Capacity Assessment for Implementation of SAICM
3. Mass Awareness through Civil Society organizations about harmful effects of chemicals on
daily life of citizens with special reference to labour working in industries and agriculture.
NationalProfilePreparation
Assessing and diagnosing the existing infrastructure for the sound management of chemicals is
an important step towards building national capacity in a systematic way and is also an
important element of preparing for SAICM Implementation. In order to provide baseline
information about existing chemicals management infrastructure and activities, the National
Chemical Profile was prepared through an extensive consultative process with the stakeholders
from across the country. These stakeholders are involved in activities related to chemical life
cycle. The National Chemical Profile has provided us a broader understanding of the current
situation related to chemical life cycle i.e. production, import, export, transport, storage, use
and disposal. It has also provided with the information about ministries/agencies which are
involved in the field of chemicals management, and their respective roles, mandates, existing
legal instruments, technical infrastructure, coordination mechanism and data available related to
chemicalsinPakistan.
CapacityAssessmentandPrioritySetting
As called for by ICCM in relation to the SAICM QSP, an important enabling activity for
national SAICM implementation is the development of a capacity assessment (including
identification of priorities) as an essential step towards preparing a SAICM implementation
plan.
2. NationalSAICMCapacityAssessment
2.1. Objectives
Building on the information in a National Profile and other sources, the capacity assessment is
intended to document and evaluate existing national capacities of Pakistan for SAICM
implementation. Specific objectives of the Assessment include the following:
to catalyze a process of collaboration between government and stakeholders towards
understanding and identifying priority needs for SAICM implementation;
to facilitate identification of action in government and within stakeholder groups
which collectively contribute to SAICM implementation;
to identify selected areas where partnership projects between government and
stakeholdergroups,orbetween variousstakeholdergroups,maybefeasible;and

To set the stage for preparation of a SAICM Implementation Plan which is linked to, as
appropriate, an integratednationalprogrammefor sound chemicalsmanagement.
The Overarching Policy Strategy (OPS, paragraph 2) of SAICM calls for the involvement of
government and all relevant non-governmental stakeholder groups. While developing the
capacity assessment, the involvement of various stakeholder groups has been considered, for
example, industry, labour organizations, environmental and health NGOs, research and
academia, etc. In this regards the guideline developed byUNITAR have been followed.
2.2. Main Components of SAICM CapacityAssessment
National Capacity Assessment for sound management of chemicals involves two main
components:
i) Anassessmentofthenationalgovernanceframework
ii) Anassessmentofcapacitiesforselectedchemicalissuesandpriorities
2.3. Assessmentofthe Governance Framework
Development of a governance framework for SAICM implementation is very significant for
sound management of chemicals. Sound governance can provide an important enabling
platform which can help to ensure that chemical management activities are effectively planned
and co-ordinated, that working relationships for government and stakeholders in SAICM
implementation are in place, and that chemical management issues are "mainstreamed" in
national development planning. An assessment of governance issues and taking action where
needed can assist in ensuring that there is high-level support to implement SAICM and provide a
basis for developing a coordinated national programme for SAICM implementation.
2.3.1.
i.
ii.
iii.
iv.
v.
AreasforGovernanceAssessment
Integrating chemicals management into national development priorities
Sound institutional and programmatic national framework
Effective project planning, implementation, monitoring, and evaluation
Legislationandenforcement
Participation of private sector and civil society in chemical management
For each of the five issues during the assessment information was collected on the following;
i. Strength of existing capacities (high, medium, low)
ii. Existinggapsorproblemsiii.
Possibleaction
iv. Level of Priority
The worksheet in Annex 1 has been developed to assist in compiling and analyzing the above
information. Activities related Global Plan of Action (GPA) has been considered while making
theassessment.

2.3.1.1. Mechanisms for Integrating Chemicals Management into Development
Priorities
Strengths:
The backbone of Pakistan's environmental protection system is Pakistan Environmental
Protection Act (PEPA) 1997, which provides a comprehensive legislative authority to address
the range of environmental issues with its jurisdiction over all environmental mediums and
grant of broad powers to regulatory bodies to implement any rules developed under the act.
Under the provisions of PEPA various rules have been made and implemented for national
environmental quality standards, pollution charge for industry, environmental sampling,
sustainable development fund, environmental impact assessment of development projects and
establishment of environmental tribunals.
Under the PEPA the federal government has the authority to delegate any of its environmental
management functions and powers to provincial governments, government agencies, or local
authorities. Provincial governments in turn may delegate powers to any lower-tiered
government agency. This provision establishes a framework for environmental federalism
within which environmental management responsibilities are shared among federal, provincial
andlocalgovernments.
The ministerial setup required for sound chemical management is well established with clearly
defined mandates. No new ministry is required exclusively for chemicals management. Beside,
due attention has been given to the pests and pesticide management in national and provincial
sustainable development strategies and poverty reduction paper of Pakistan. SAICM is being
implemented and the National Chemical Profile hasbeen prepared and capacityassessment is
being carried out which will be followed by National Action Plan.
Socio-economicdata which isessentialforchemical life cycle management isprimarilycollected
and analyze by Federal Bureau of Statistics FBS. These data are collected from primary and
Secondary Sources. The primary data are collected through different surveys such as Labour
Force Survey (LFS), Household Integrated Economic Survey (HIES), Pakistan Integrated
Household Survey(PIHS), and Pakistan Demographic Survey(PDS) etc. Secondarydata such
as Foreign Trade Statistics, Industrial Statistics, Transport and Communication Statistics,
Social Statistics, Agriculture Statistics, Environment statistics etc. are collected from the records
of concerned Ministries/Departments.
Gaps:
According to the Principle 16 of the Rio Declaration there is a need to promote the
internalization of the environmental costs and the use of economic instruments. Adaptation of
such approaches is required that polluter should bear the cost of pollution, with due regard to
the public interest and without distorting international trade and investment.

There is a lack of harmonized national chemical information system in Pakistan. Usually the
information is collected for various other purposes on different parameters and synthesis of
such data is difficult for chemical management. There is no inventory system related to
chemical accidents, chemical poisoning cases, drinking water contamination, food
contamination, hot spots of chemical pollution, stocks and storage sites of obsolete chemicals,
transportation and storage of chemicals, required for chemical management.
Although pest and pesticide management have been included in the national poverty reduction
strategy paper but the capacity building for sound management of chemicals in general is not
included. There is a limited coordination between policy makers industry and in policy making
process. The capacity to undertake social and economic impact assessment of chemical
production and use is also low in the country.
There is a dire need of integrating capacity building policies for sound management of
chemicals within ministries involved in chemical life cycle. Generally the capacities of
government institutions in terms of technical human resource, financial resource and
infrastructure are limited. The capacity building for sound management of chemicals in general is
not included in the national poverty reduction and strategy paper and country assistance
strategies.
2.3.1.2. ASoundInstitutionalandProgrammaticNationalFramework
Strengths:
A multilateral approach is being adopted for chemical management in the country through
implementation of SAICM. For the implementation, the focal points are well defined, their
duties are laiddown and implementations are at various stages. NTACC has a cross sectoral
representation and will be playing a vital role in technical guidance and decision making
process in future. At present some resources have been provided for implementation of various
Chemical Conventions under National Development Framework.
Chemical management in Pakistan is done through a well defined governmental structure
where responsibilities and mandates of various ministries, agencies, and attached departments
related to different aspects or categories of chemicals are defined through these legal
instruments. By acts enacted by the parliament, specific institutions have been created and
theirauthoritiesand powers have been defined to manage chemicals.
Officials of ministries and government agencies often attend training courses, seminars,
workshopson policyissues, legalframeworkandenvironmentalmanagementin general. Trade
organizations/ chambers of commerce also participate in activities organized by ministries and
other government institutions. A multi-stakeholder approach was adopted while preparing
National Chemical Profile and Action Plan. This involved stakeholders from all relevant
ministries, government departments, NGOs, CSOs, and industry.

Trade organizations are playing an important role in implementation of international voluntary
initiatives like ISO etc. Few NGOs and trade organizations are also involved in information
dissemination and policy analysis. Industries are cooperating to some extent in Pak-EPA's
SMART programme and playing some role in raising public awareness. Integrated pest
management strategies have been developed and implemented in the country. E-government
has been established for the fast pace communication system within the government, for public to
government as well as with other countries.
Gaps:
Globally Harmonized System of Classification and Labelling of Chemicals (GHS) are yet to be
implemented in Pakistan. National information system related to chemical life cycle and global
information network at national level for delivery of chemical safety information are not
present.
Government departments have low capacities to implement integrated pest management
strategies at grass root level due to lack of financial and technical capacities. The cooperation
and coordination among ministries is also lacking. There is a very limited interaction of trade
organizations with inter-governmental institutions. Despite considerable role in awareness
raising and implementation of voluntary programmes, there are no initiatives taken by trade
unions and NGOs for capacity building and development of expertise for sampling, testing and
research on environmental pollution caused by industrial processes. There is a need to create
some mechanism of standardizing NGOs so that they can play some vital role in monitoring
andinspections.
The role of women is limited in chemical management especially in agriculture sector due to
lack of awareness. Moreover, there is no harmonized data collection system, inventory and
reporting system. Information network for early warning systems, for cross-boundarymovement
of hazardous substances and chemical waste is lacking. Preliminary hazard analysis and
guidelines for hazard identification for government institutions, industry, importers and
exporters are also absent. Storage facilities are devoid of any health and safety measures.
Clearing House Mechanism is not present in the country. Access to updated information in
government departments and industry is difficult for academia and common public.
There is no global information network established for early warning systems regarding cross-
boundarymovement of hazardous chemicals in Pakistan. Such system may be developed with
help of UNEP, ILO, WHO, and FAO etc.
2.3.1.3. EffectiveProjectPlanning,Implementation,MonitoringandEvaluation
Strengths:
To give due attention to environmental issues and sustainable development projects in the
country funds are allocated in annual, Medium Term and Long Term Development
Framework.

Gaps:
The capacities of Planning Commission and provincial departments to plan projects relevant to
management of chemicals are generally very low. The main constraints to project
implementation are the lack of capacities of government departments due to lack of technical
knowledge, poor infrastructure, and limited experienced human resource. Beside these, the
funds are often diverted to cater other urgent needs due to financial crunches.
The targeted chemical riskassessment approach isseldom seen in majordevelopment projects.
The capacity and technical knowledge regarding the monitoring of priority contaminants is
generally low. There is a lack of evaluation of socioeconomic and chronic impacts of chemicals
used in different sectors. The disaster management, development planning and environmental
management institutions operate in isolation. There is dearth of knowledge and limited
capacity of hazard identification, risk assessment & management, and linkages between
livelihoods and disaster preparedness related to chemical accidents, within disaster
managementbodies.
2.3.1.4. LegislationandEnforcement
Strengths:
Pollution prevention concept is present in various legislations and environmental policies e.g.
Pakistan Environmental Protection Act. Stockholm Convention, Rotterdam Convention, Basel
Convention, ILO conventions and IMO conventions related to chemicals have been ratified
and are being implemented in the country. The implementation plans have been made,
whereas focal points are established and working for implementation of multilateral
environmentalagreementsrelatedtochemicals.
Pollution prevention concept is present in various legislations and environmental policies.
Pakistan Environmental Act clearly defines pollution prevention and need to implement
programmes and activities to control chemical pollution. There exists sufficient legislation
related to different aspects of life cycle of chemicals, especially with reference to import, export
and production. No new laws are required but certain amendments are urgently required to
address the priority issues identified for chemical management in the country.
For promoting private-public partnerships in the sound management of chemicals and wastes,
National Technical Advisory Committee on Chemicals is established consisting of members
from public as well private sector.
The relevant international instruments on chemicals and hazardous waste e.g. Stockholm
Convention, Rotterdam Convention, Basel Convention, ILO conventions and IMO
conventions have been ratified and are being implemented in the country. Their
implementationplanshavebeenmadeinmostcases.

Gaps:
Most of the existing legislation was not enacted for the specific purpose of chemical life cycle
management in particular e.g. Carriage of Goods by Sea Act, The Motor Vehicle Act, The
Railways Act, Explosive Substances Act, Mines Act, fatal Accidents Act, does not cover all
aspects of chemical management. Therefore their environmental content is ancillary.
There does not exist any law directly related to transport and storage, use and disposal of
chemicals. Explosive act is present but that too does not cover all aspect of chemical handling
and safety. Legislation related to consumer chemicals including food product is very poor. This is
causing serious health hazards due to uncheck use of chemicals in consumer and food
products.
Penalties for environmental offences are generally punitive rather than reformatory. The
approach is counterproductive since punishment may induce future restraint but it does not
rectifythe damage committed. For anylawto be successfullyimplemented the penaltymust be
stringent enough to deter the felon. A fine of Rs. 500 on an industrialist for discharging his
units'industrialwaste inthe nearbystreammayprovidenodeterrence.
The cases of adulterations in chemicals, if any are dealt with under the pure food rules.
Similarly, no specialized legislation exists to control the import, production, storage,
transportation, distribution, use/handling of any kind of chemicals except that the
disposal/handling of toxic and hazardous substances are dealt with under the Pakistan Penal
CodeandtheExplosivesAct,1884andHazardousSubstancesRules,2006.
The effectiveness and enforcement of regulatoryframework is verypoor. The major drawbacks
are with the inspections, monitoring, vigilance and public awareness. There is a serious lack of
trained technical human resource in every related department. This can be enhanced with the
properlyaccredited NGOsfor such purpose.
Pakistan, at present, like manydeveloping countries of the world, does not have comprehensive
occupational health and safety laws. The incidence of injuries and illnesses is probably very
high in Pakistan because thousandsof workersare routinelyexposed to hazardouschemicalsin
many industries and agriculture. However, there is no reliable data on occupational safety and
health injuries and illnesses because a majority of accidents are not reported to the regulatory
agencies. The regulatory agencies do not have an effective enforcement policy or strict
requirements for reporting injuries and illness at workplaces.
An overview of current laws/regulations related to occupational safety and health shows that
there are several laws on the book, such as Factories Act, 1934; Provincial Factories Rules;
Hazardous Occupations Rules, 1963; Mines Act, 1923; West Pakistan Shops and
Establishments Ordinance, 1969; Provincial Employees Social Security Ordinance, 1965;
Workmen's Compensation Act, 1923 and Dock Labourers Act, 1934. The current regulations
are, however, fragmented and there is no single comprehensive piece of legislation dealing with
occupationalsafetyandhealth.

There is no formal legislative process for setting up new standards, codes of practice and
occupational exposure limits. Whatever exists on the book is frequently hampered with
repeated martial laws. The current outdated Factories Act, established in 1934, requires only a
very basic level of safety and health measures. There are no guidelines for minimum
qualifications or employment of health and safety professionals in the industry. Several
important sectors, such as agriculture, construction and informal/self-employed are not even
coveredunderanylaw.
Although, several occupational diseases, such as anthrax, Byssinosis, compressed air illness,
poisoning by lead tetraethyl, poisoning by nitrous fumes, lead poisoning, phosphorus
poisoning, mercury poisoning, poisoning by benzene & homologues, chrome ulceration,
arsenic poisoning, pathological disorders due to X-rays, radium or radioactive materials,
primary epithliomatous cancer of skin, silicosis, etc., are covered under the Social Security
Ordinance and Workmen's Compensation Act but the reporting mechanism is so poor that
veryfewgetthebenefits.
The implementation of existing environmental laws, policies, international conventions,
programmes and activities is low due to low level of technical and financial capacities of law
enforcing institutions, lack of proper infrastructures, limited knowledge of FAO and WHO
specificationson pesticides among decision makersand lowlevelof awareness and knowledge of
lifecyclemanagementconceptamongenvironmentalmanagers.
There is a need to develop national strategies for prevention, detection and control of illegal
traffic, including the strengthening of laws, judicial mechanisms and the capacity of customs
administrations and other national authorities to control and prevent illegal shipments of toxic
andhazardouschemical.
The Representation of ministry for Petroleum & Natural Resources, Labour, Railway,
Communication, Ports & Shipping, National Disaster Management Cell, and Rescue 115
Service is lacking in NTACC. The participation of academia, heads of departments of chemical
technology, chemistry and environmental sciences of the major universities of the country may
also be included in the committee.
A sustainable financial mechanism for capacity building of institutions is lacking consisting of
incentive measures for skilled human resource. The same is also required for introduction of
new technologies.We need also to consider approaches to facilitate and strengthen synergies
and coordination between chemicals and waste conventions, including by developing common
structures. In this regard pilot projects to pursue implementation of coordination between the
national focal points of chemicals-related multilateral environmental agreements (Rotterdam,
Stockholm and Basel Conventions and Montreal Protocol) may be developed to achieve
synergies in their implementation. At present Pakistan has limited technical as well as financial
capacitiesto implementtheseconventions.

There is a low capacity of agencies responsible for compliance and accountability and effective
enforcement and monitoring programmes. There is a little development and application of
economic instruments for pollution control. The economic incentives should be given to
industriesto reduce theirwaste emission and properdisposalof wastes.
The measures taken to encourage sustainable and cleaner production technologies, in
particular best available techniques and best environmental practices (BAT/BEP) are
ineffective so far and their impact is very little. These technologies are very expensive therefore
need specialincentive measuresto promote these technologies in the industry.
2.3.1.5. Participation of the Private Sector and Civil Society in Chemical
Management
Strengths:
There are a large number of non-governmental organizations and community based
organizations working in the country in areas like consumer protection, environment, natural
resource management, pollution control, labour welfare, health and gender issues etc. These
organizations are working in isolation.
Participation of private sector and civil society in policy making and policy implementation is
very important for chemical management in the country. Although in Pakistan these
stakeholders are playing their role in policy making and implementation process but there
participation is limited.
The private sector and civil society fully participate in meetings, seminars, conferences and
workshops. Some of the important NGOs, CSOs and trade associations are part of
committees made for chemical management. These organizations are playing a vital role in
implementation of international voluntary initiatives like ISO standards 9000, 14000 and
OHSAS 18001. They are also cooperating in Pak-EPA's SMART programme for self
monitoring and reporting.
NGOs have direct linkage with local communities hence their role in dissemination of
information and creating awareness among workers and local population is veryeffective. They
arrange seminars, workshops, focal groups meetings and interact with common man. NGOs
have right to access to environmental tribunals, labour courts and other similar institutions for
any complaint related communities benefit.
NGOs have the capacities for policyanalysis, legislation, and research on alternatives, trainings,
education, data collection/dissemination and raising awareness. Only few NGOs have these
capabilities collectively. The cross cutting capacities are very important to deal with the
chemicalmanagement in the country.
Gaps:

A good number of NGOs and CSOs are working for environmental issues but there is no
NGO, CBO, working exclusively for chemical management in Pakistan. There role is indirect.
NGOs and CSOs require capacity building in chemical management exclusively. There is very
little coordination among these organizations and government agencies. There is need to
develop a framework to promote the active involvement of these non-governmental
organizations, CSOs, managers, workers and trade unions in all enterprises - private, public
and civil service (formal and informal sector) - in the sound management of chemicals and
wastes.
Thereisaneedto create somemechanismof standardizingtheseorganizationssothattheycan
play some vital role in monitoring and inspections. Once some mechanism for accredit non-
governmental organization is brought in they can play better role in dealing with
environmentalissues.
Through an innovative consultation processes, such as mediated discussions, with the help of
private sector, NGOs and CSOs, efforts should be made to find common ground and
agreement amongaffected sectorsof societyon critical issuesthat impede effortsto achieve the
soundmanagementofchemicals.
There should be a broader representation of civil society and private sector in National
Technical advisory Committee on Chemicals (NTACC), carrying out and monitoring SAICM
implementation plans.
Private sector should be encouraged for use of voluntary initiatives (e.g., Responsible Care and
FAO Code of Conduct) to promote corporate social responsibility for the safe production and
use of all products, including through the development of approaches that reduce human and
environmentalrisks.
2.4.AssessmentofCapacitiesforImportantChemicalsManagementIssues
The assessment of chemicals management capacities includes specific chemical management
issues such as chemicals information generation and dissemination, risk reduction, import
control, etc.
2.4.1
i.
ii.
iii.
iv.
v.
AreasforChemicalManagementAssessment
Information Generation and dissemination
Risk reduction
EducationandAwarenessraising
Accident Prevention and Control
Analyticaland LaboratoryCapacity
While doing assessment of chemical management issues, classification and labelling, safe
handling and use of pesticides, training and chemical accidents have been considered

important areas. For each of the five issues during the assessment information was collected on
the following;
i. Strength of existing capacities (high, medium, low)
ii. Existinggapsorproblemsiii.
Possibleaction
iv. Level of Priority
The worksheet in Annex 2 has been developed to assist in identifying the priorities of the
various issues. The activities included in SAICM GPA have been considered while doing
ChemicalManagementAssessment.
2.4.1.1. Informationgenerationanddissemination
Strengths:
Pakistan has implemented "Harmonized System" (HS) of nomenclature to assign specific HS
codes to individual chemicals or group of chemicals listed in Annex III to the Rotterdam
convention, adopted by World Customs Organization in June 2004. The HS Code system is a
system of progressivelymore specificidentifiersfora commodity.
EPA has setup emission inventory system in major cities. Pesticides residue research centers
have been established in various cities in the country. Eco-toxicology centre has been
established at NARC. A programme is being implemented through it to monitor pesticide
residues in food and the environment.
At present few toxicology centers are working in Karachi, Faisalabad Multan and Islamabad.
Other facilities associated with manyhospitals are just treating the poisoning cases
Gaps:
Chemicals, through their life cycle, i.e. production, import, export, transport, use, storage and
disposal pose a real danger to human health and environment. People of any ages, from
children to elderly, using many different languages and alphabets, belonging to various social
conditions, including illiterates, are daily confronted to dangers of chemicals and pesticides. To
face this danger and keeping in mind the extensive global trade in chemicals and need for safe
handling of these chemicals through their life cycle, a new system "Globally Harmonized
System for Classification and Labelling of Chemicals" (GHS) has been introduce. This system
addresses classification of chemicals by types of hazards, and proposes harmonized
communication elements including labels and safety data sheets. GHS aims at ensuring that
information on physical hazards and toxicity from chemicals is available in order to enhance
the protection of human health and environment during chemical life cycle. The third revised
edition has been published on GHS has been published in July2009.
GHS is not implemented in Pakistan and the present capacities for its implementation in
Pakistan are very low. In fact there is a very little knowledge about GHS in Pakistan. In this

regard, GHS awareness-raising, training and capacity-building, GHS action plan development,
national situation analysis and implementation plan should be developed on priority basis.
A key component of the sound management of chemicals, and one required in many
international agreements, is the capacity to gather information. This is also a priority area in
many developing countries. Information gathering and systemization may take the form of
chemical inventories or lists, supplemented by a means for disseminating the gathered
information (information exchange). This can be done by developing separate inventories of
chemicals or emissions, or consolidate the efforts within more integrated approaches such as
the development of Pollutant Release and Transfer Registers (PRTRS). Pakistan has to yet
initiate its toxic releases inventory (TRI) or National Pollutant Release Inventory (NPRI). Such
inventories should include industries, residential, transportation, incineration, roads, forest
fires and more. Pollutants from mobile sources such as trucks and cars, households, facilities
that release pollutant on smaller scale by certain sectors such as agriculture, education, and
mining activities mayalso be included.
Pakistan has low capacities for assessment of exposure to different chemicals. There is a need
for setting priorities for action for determining the impact of chemicals on human health. A
mechanism has to be established to share and disseminate information that can be used to
reduce uncertainty in risk assessment. Health surveillance programmes should be established
with more poisoning information and control centers and systems for data collection and
analysis and enhance the capacity of present facilities. The pesticide monitoring facilities are
present in the countryin some regions but their technical capacities should be enhanced.
At present few toxicology centers are working in Karachi, Faisalabad Multan and Islamabad.
Other facilities associated with many hospitals are just treating the poisoning cases. Eco-
toxicology centre has been established at NARC. These facilities are often facing shortage of
trained human resource and technical facilities. Collection of data is very poor on the use
patterns of chemicals to support risk assessment characterization and communication. There is a
need to develop objective indicators for evaluating the influence of chemicals on human
health and the environment.
Institutional as well as individual capacities in Pakistan for risk assessment of chemical use and
exposures are poor. Very few studies have been made by individual efforts but without
developing indicators. There is a need to develop training and guidance programmes to assist
in the preparation of initial national assessments of groups of chemicals posing risk for human
health and the environment, including, persistent bio-accumulative and toxic substances,
(PBTs); verypersistentandverybio-accumulative substances; chemicalsthatarecarcinogensor
mutagens or that adversely affect, inter alia, the reproductive, endocrine, immune or nervous
system; and persistent organic pollutants (POPs), children's environmental health, and the
identification of priority concerns.

Infrastructure for research that may reduce uncertainty in risk assessment is required in related
organizations. There is a big gap in scientific knowledge for risk assessment among concerned
people. Public organizations as well as NGOs should develop a general framework for capacity
building in risk assessment in order to improve understanding of the impact of natural
disasters on releases of harmful chemicals and resulting human and wildlife exposures, as well
aspossiblemeasurestomitigatethem.
2.4.1.2. RiskReduction
Strengths:
Programme for integrated pest management is being implemented. EIA has been made
mandatory for all development projects. Chemicals listed in Rotterdam Convention have been
banned in Pakistan. Lead has been eliminated from gasoline where as mercury programme is
being implemented in the country. Pesticide registration and control system has been
established which controls risks from the initial point of production and formulation.
Few studies have been conducted to identify obsolete Pesticides contaminated sites under the
implementation of Stockholm Convention. Very limited facilities for remediation of
contaminated sitesand disposalof obsolete chemicals exist in somemajorcitiesin Pakistan.
Gaps:
There is lackof preventive strategiesforchemicalsafetyand targeted riskassessment approach
in the country. FAO International Code of Conduct on Distribution and Use of Pesticides is
not being fully implemented. Pesticide registration and control system does not control the
disposal of obsolete products or containers. Few studies have been conducted to identify
obsolete Pesticides contaminated sites under the implementation of Stockholm Convention.
There are limited facilities, know-how and technical expertise available for remediation of
contaminatedsitesanddisposalof obsoletechemicals.Integratedpestmanagementprogramme is
being implemented but there isno integrated vectormanagement programme.
Present legislation related to health and safety of workers at their workplace is insufficient.
There is a lack of health impact assessment system in development activities. Occupational
health & safety policies are also not present in the country; therefore, there is lack of training
and sensitization on chemical safetyfor those exposed to chemicals at various work places. The
existing legislation does not cover the entire spectrum of work situations in which chemicals are
handled, including such sectors as agriculture and health, to protect the health of workers and
the public.
Existing system of health and environmental impact assessment in chemicals handling is poorly
managed such assessments should be incorporated in occupational safety and health
programmes. ILO safe work standards, ILO guidelines on occupational safety and health
management system (ILO-OSH 2001) are poorly implemented in industry in Pakistan. The
chemical life cycle management approach is lacking in national occupational safety and health
policies. Integrated health and safety programmes for public health and safety practitioners and

professionals with an emphasis on identification, assessment and control of occupational
chemical risk factors at workplaces in industry as well as agriculture are established only in few
enterprises.
Workers are exposed to chemicals in most of the small and medium enterprises. They are not
provided with appropriate protective equipment. There does not exist national inspection
systemsfor the protection of employeesfrom the adverseeffectsof chemicalsand to encourage
dialogue between employers and employees to maximize chemical safety and minimize
workplace hazards. The role of Public media is limited in chemical-safety-related information
dissemination among generalpublic.
The know-how and technical expertise are not available for remediation of contaminated sites
and disposal of obsolete chemicals. There are few incinerations facilities present in some
hospitalsoperatedbyprivatesector.TheWastedisposalplanshavebeenpreparedandin some
cases under implementation in fewmajor cities of Pakistan.
The monitoring mechanism for chemical impacts of dumps and landfills and waste facilities on
human health and national strategies for prevention, detection and control of illegal trans-
boundarymovementsof wastearealsolacking.
2.4.1.3. EducationandAwarenessRaising
Strengths:
The education related to chemistry, biochemistry, chemical engineering and chemical
technology is well established in nearly all universities in Pakistan in public as well as private
sector. Chemistry is taught as a compulsory subject in schools and as elective in colleges.
Workshops, seminars and lectures are arranged on chemical issues and pollution in public
organizations as well as by NGOs. Health and safety awareness raising measures are taken in
large enterprises especially in multinational organizations. Ministry of Environment celebrate
Environment Days and walks are arranged for awareness of common public on environmental
issues.
Gaps:
With reference Chapter 19, Agenda 21, a national Chemical Information system is required by
standardization of chemical information on electronic data interchange formats according to
UN EDIFACT procedures. Pakistan is lacking such harmonized chemical information and
dissemination system. There is no Toxic Releases Inventory (TRI) or National Pollutant
Release Inventory (NPRI) system developed with free access to general public in the country.
There isalso nonational inventorysystemfor chemicaluse, transport, storage and disposal.
Chemical risk assessment and chemical hazard assessment studies and chemical life cycle
management issues and requirements are not included in university curricula. At present, there
are no degree programs in the environmental health and safety (EHS) discipline in the country.

Few institutions, such as the Institute of Public Health, Lahore, and the University of Lahore,
however, offer some basic courses. Also, there are no guidelines on EHS core curriculum at
national level.
Several limitations have prevented the development of occupational health and safety (OHS)
culture in the country. The lack of formal education, absence of a national focal institution for
providing training and advisory services, lack of strict requirements by the enforcement
agencies for authentic data collection and reporting, lenient enforcement of the law, lack of
technically qualified personnel for inspection services that can recognize and evaluate
occupational hazards, lack of Inter-agency coordination at the government level, inadequate
funding for OSH programs and limited expertise at the policy making level, as well as illiteracy of
the workforce are some of the handicaps which have inhibited growth of safety culture.
TheseissuesneedtobeaddressedbeforeOSHculturecanestablishitsrootsinPakistan.
There are limited opportunities for trainings of people at risk to chemical exposure on safe
handling of chemicals, policy makers and planners. In small industries workers are
uninformed of the hazards posed by the chemicals they are using at their workplace. Illiteracy
and poverty are the main causes among others for it besides the lake of capacities and
knowledge of law enforcing agencies. There are no measures taken for awareness raising of
waste handlers and small-scale recyclers from the hazards of handling and recycling chemical
wasteacrossthecountry.
Training opportunities needed to develop capacity in legislative approaches, policy
formulation, analysis and management, to detect and prevent illegal traffic in toxic and
dangerous goods and hazardous wastes, cleaner production techniques and to create linkage
between trade and environment, including needed negotiating skills are required.
R & D organizations have very few training programmes for necessary testing of chemicals for
their management across their life cycle. The know-how of technical manpower engaged in
these organizations is limited for safe handling and chemical management issues. The
capacitiesandknow-howof emergencyresponseagenciesispoorindealingchemicaldisasters.
Moreover, the knowledge for cleaner production technologies is low.
Awareness of consumers, in particular on best practices for chemical use, about the risks that
the chemicals they use pose to themselves and their environment and the pathways by which
exposuresoccurislow.Consumersarealwaysatriskof chemicalhazardsposedbypreservatives
and other chemicalsusedin food items.
2.4.1.4. Accidentpreventionandcontrol
Strengths:
National Disaster Management Commission (NDMC) headed by the Prime Minister and the
National Disaster Management Authority (NDMA) has included Industrial/Chemical
Accidents Contingency Plan in its major initiatives. NDMA has been mandated to established

technical committees to assist local, provincial or national authorities in identifying issues and
problems and devising solutions in areas like, Industrial and mines accidents, Major
transportation accidents, Marine disasters, including oil spills, Nuclear, chemical, biological
and radiological accidents, Urban and forest fires, etc.
Roles and responsibilities described in this part refer to functions that are expected to be
performed by concerned stakeholders with relation to disaster risk reduction, preparedness,
response and recovery after disasters. The Ministry of Environment is responsible for following;
Develop disaster risk management plan for risk reduction and response with relation to
Ministry'smandate;
Incorporate Natural Disaster RiskAssessment in theEnvironmentalImpact Assessment
guidelines;
Develop technical capacities of the staff of ministry to undertake disaster risk
assessment and disaster risk reduction activities in the environment sector;
Undertake assessment of vulnerability of natural resources (forest, lakes, streams,
mangroves, coral reefs, protected areas, coastal areas) to natural and human induced
hazards;
Implement programmes for conservation and rehabilitation of natural resources in
order to reduce risks of natural hazards; e.g. reforestation, mangrove plantation,
combatingdesertification,conservation of specialnaturalresources; e.g. wetlands, lakes,
reefs,mangroves,andcoastalareas;
Allocate resources for implementation of programmes to conserve and rehabilitate the
natural resource base,particularlyin up-stream areas of the IndusRiverbasin;
Develop mechanisms for assessment of environmental losses and damages in the
aftermath of disasters and their rehabilitation;
Ministry of Industries, Production and Special Initiatives is responsible for following;
Develop disaster risk management plan with regards to the mandate of the Ministry;
Develop guidelines for industrial sector to ensure safety of industry and its production
processesinhazard-proneareas;
Establish systems to monitor implementation of guidelines by industrial sector;
Develop system of incentives and disincentives for industry to promote application of
disastersafety;
Implement awareness raising programmes for industrial sector including Chambers of
Commerce and Industry (CCI) on integrating disaster risk assessment and vulnerability
reduction in project planning and implementation stages;
Prepare inventories of industries based upon the type of chemicals and raw materials
used in theirproductsand the dangersposed byvarious typesof industries;
Initiate demonstration programmes on industrial disaster preparedness;

Develop safetycodesfor all industries to reduce risks of industrial and chemical hazards
and to ensure vulnerability reduction from natural hazards;
DevelopSOPsforemergencyresponsetoindustrialdisasters;
Develop physical capability to manage all types of likely industrial disasters including
chemicaldisasters;
Monitor and encourage implementation of safety codes in industry;
And Ministry of Petroleum and Natural Resources is required to;
Develop disaster risk management plan with regards to the mandate of the Ministry;
Develop guidelines for safety in oil/gas, fire and mining sectors;
Integrate risk assessment and risk reduction in planning and implementation of
projectsintheabovesectors;
Implement awareness raising programmes for staff in the oil, gas, fire and mining
sectors;
DevelopSOPsforemergencyresponsetodisastersintheabovesectors;
Through the GeologicalSurveyof Pakistan (GSP)conduct research on hazard mapping
andproduceuserfriendlymaps;
Gaps:
There is no formal or informal mechanism in place to investigate a chemical incident and its
outcome in the country, a standardized format for collecting the information about the
incident should be developed by the Pak-EPA. Investigations leading to a formal enquiry about
the causes and responsibilities of various parties involved are often made these investigations
never lead to a follow-up activity, in general. The record for chemicals incidents and disasters
is never kept in organized manners at any agency. The do not exist any follow-up surveillance
and rehabilitation mechanism in the health service for exposed persons who may suffer long
term disabilities and sequelae and Government level. Generally some NGOs are involved in
such surveys and rehabilitation activities.
Disaster management in Pakistan basicallyrevolves around flood disasters with a primaryfocus
on rescue and relief. After each disaster episode the government incurs considerable
expenditure directed at rescue, relief and rehabilitation. The Disaster management related to
chemical accidents though part of framework but still not implemented.
Disaster management, development planning and environmental management institutions
operate in isolation and integrated planning between these sectors is almost lacking. Within
disaster management bodies in Pakistan, there is a dearth of knowledge and information about
hazard identification, risk assessment & management, and linkages between livelihoods and
disaster preparedness. Disaster management policy responses are not generallyinfluenced by
methodsand toolsfor cost effective and sustainable interventions.

There does not exist any mechanism for inventories of installations and transport routes at risk
of chemical incidents. Fire, police and other emergency services does not have specific
equipment, including protective clothing, to deal with chemical incidents and staffs are not
specifically trained for such incidents. There are no chemical hazard identification systems both
in the transport and industrial/commercial sectors except in very few large enterprises.
There are no dedicated chemical emergency services in the country. Only few hospitals have
proper patient decontamination facilities and stocks of antidotes, medicines, and appropriate
equipment for chemical emergencies. But in small towns and agricultural rural areas there are
no such facilities to meet the emergency situation like pesticides poisoning. Health or
emergency services are not properly trained and equipped for transportation of chemically
exposedpersons.
There is no special training programme to prepare the emergencyservices (e.g. fire, police, and
civil defence) personnel in dealing with a chemical incident, as well as medical and paramedical
staff in handling and treating chemically exposed persons. Only in major cities veterinarians
are available and not all of them have enough knowledge/trainings concerning treatment of
exposedanimalstotoxicsubstances.
The capacities for remediation of contaminated sites caused by chemical accidents are limited.
The National Disaster Management Plan does not include strategies for chemical
accidents/industrial accidents. In Karachi, Faisalabad, Multan and Islamabad, few poison
treatment and control centers have been established with reasonable technical and monitoring
facilities.
2.4.1.5. AnalyticalandLaboratoryCapacity
Strengths:
For support of national legal instruments, policies and plans related to chemical management,
numerous R & D organizations, institutes and laboratories have been established throughout
the country over the last decades. The main objectives of these facilities are quality control of
chemicals includingpetroleum products, residue analysis, and research on unknown substances
and monitoring of harmful effects of chemicals. Among them a number of laboratories have
been accredited through National Accreditation Council of Pakistan, where the laboratory
quality standards are being maintained. But still there are other laboratories which still require
certification.
Laboratories established under Pakistan Council for Scientific & Industrial Research (PCSIR)
in Karachi, Quetta, Peshawar, Lahore and Islamabad have capacities for investigation and
R&D on organic, inorganic and microbiological contamination in water, wastewater, foodstuff,
industrial emission, automobile emission and particulate matters analysis, ambient air
monitoring, pharmaceutical chemicals/ products, Plastic and Polymers, marine products, food
products, fuels, leather industry chemicals and for chemical characterization and analysis of

ores and minerals. PCSIR laboratories are also conducting research on industrial wastes
treatment and designing of treatment plants, preparation of environmental impact assessment,
carrying out environmental impact assessment, evaluation / characterization of materials and
wastes, carryingoutenvironmentrelatedsurveys.
Hydrocarbon development Institute of Pakistan (HDIP) is the sole R & D Institution in energy
sector of Pakistan. HDIP has established state of the art Petroleum Testing Labs for checking of
quality, standards and specifications of hydrocarbons including crude petroleum, petroleum
products, liquefied petroleum gas and natural gas in downstream petroleum sector and
geochemicallabsinupstreampetroleumsector.
The Geochemical labs in HDIP have facilities for Bitumen Classification, Source Rock Typing,
Gas Analysis by Chromatography, TOC and Rock Eval (S1, S2, S3 and Tmax), Gas
Chromatography of Saturated Hydrocarbons, Biological Marker Analysis by Gas
Chromatography/Mass Spectrometry, Natural Gas Analysis by Gas Analyser, Calorific Value
and Gravity Estimation of Gas by Calculation Method, Compositional Analysis of LPG,
Density Estimation by Calculation Method, Light Hydrocarbon Analysis by Head Space Gas
Analyser.
The Combustion Engineering Labs of HDIP have facilities for study of environmental
pollution for the CO2, CO, Soots, Nitrogen and Sulphur, in ppm level, Exhaust Emission
Study, Energy Conservation Study for the Industries, Study for the Substitute Fuel
Performance in I.C. Engine, Efficiency Monitoring of Domestic Heating Appliances. HDIP has
also expertise in Environmental analysis for Water Portability (Dissolved), Alkalinity,
Conductivity, pH, Chloride, Iron, Bicarbonate, Nitrate, Sulphate, Carbonate, Sodium,
Hydrocarbons, TDS Hardness, Calcium and Magnesium,Water Salinity (Dissolved), Calcium,
Chloride, Magnesium, pH, Potassium, Sulphate, Sodium and Conductivity. Studies for Trace
Elements in Salt/Sediments/Water, Trace Metal Analysis by Atomic Absorption (15 Elements)
arealsodone.
Industrial Analytical Centre, IAC, (HEJ), Karachi is involved in wide range of chemical
analysis, microbiological testing, food science, biotechnology, pharmacology, and material
testing.
Surveillance of pesticide poisoning is done through National Poisoning Control Center
Karachi at Jinnah Post Graduate Medical Centre Karachi. This centre is acting as a registry,
information investigation, treatment and research centre at Federal level. The provincial
centers at different hospitals are only acting as treatment centers for pesticides cases. The
Nutrition Division of NIH, Islamabad is running programme for quality testing of food and
feed. The pesticide residue study programme was started in 1981 and a project on food
contamination studyand control in Asia and Far East was completed.

The Plant Protection Department (PPD) has a network of laboratories throughout the country.
PPD labs are dealing with pesticides formulations being marketed in the country. Pesticide
Chemistry Lab, nuclear Institute for Agriculture and Biology (NIAB), Faisalabad under
administrative control of Pakistan Atomic Energy Agency (PAEA) is conducting pesticides
residue analysis by employing radio labelled techniques for elucidating fate of pesticides in
different agro-ecological conditions.
In addition to these there are some analytical facilities established by private sector which have
capacitiesto conduct variouschemicalanalysis.
Gaps:
Although education in chemistry, chemical engineering, environmental management and
environmental studies is available in the country but there are no specific course available
related to life cycle chemical management. The additional modules are required in the
curricula of the universities with reference to the chemical management, risk assessment and
risk reduction, waste management, waste treatment etc. Due to lack of qualified and well
trained human resource in related R & D organizations their capacity in above mentioned
areasofchemicalmanagementispoor.
Institutional capacities are needed to be strengthened in terms of improved availability of
information, filling gaps in the understanding of chemicals related health issues, risk
assessment methods, protection of vulnerable groups including children, workers and
population in general, promotion of safe alternatives and needs for prevention.
There is a dire need for development of emergency response infrastructures in the country fro
chemical disaster management. The National Disaster Management Plan does not include
chemicalaccidentsresponseandmanagementplan init.
The capacities of analytical laboratories are low to medium. Monitoring and analytical
capacities of chemical and social data are low as well. Most of the institutions lack proper funds
to acquire and maintain equipment.
Surveillance of pesticide poisoning is through National Poisoning Control Center Karachi at
Jinnah Post Graduate Medical Centre Karachi. This centre is acting as a registry, information
investigation, treatment and research centre at Federal level. The provincial centers at different
hospitals are only acting as treatment centres for pesticides cases. The existing poison control
centers are insufficient for catering the needs of the large population. There is an urgent need
to increase such facilities with required technical human resource and infrastructure. The
capacity building of existing poison control centers in terms of trained persons and technical
support isalso required.

The inter-linkage of National Poison Control Center and Provincial Centers is also very
important. There is a need for coordination mechanism between these centers, registration
authority at Plant Protection Department, and Ministries of Health and Environment.
There is a need for strong National Public Health Pesticides Resistance Monitoring System.
Public health authorities need to be involved in the licensing process of public health
pesticides.
Ministry of Health should be involved in the national information exchange system and strong
public health pesticide management awareness should be done, in collaboration of ministry of
health. To address the poisoning due to different agents, whether acute or chronic, the
integrated and collaborative approach of government, nongovernmental organizations along
with industries and private sector representatives is required.
Most of the Pesticides monitoring laboratories/ institutes conduct research on the efficacy
trials of pesticides and developing pest management packages. Very little attention is paid to
ecological studies. Whereas all the provincial institutes are mainly concerned with the quality
of the pesticides, the institute of Ecotoxicology has gone beyond and is looking into the
residues in cropsand food products.
Although some federal and provincial institutes conduct research on fertilizer production, use
and formulating recommendations for improving crop productivity through balanced fertilizer
application, there is no independent institute and /or non-governmental body/entity in
existence to carryout research on detrimental effectsof overuse of fertilizers.
The Standard Reference chemicals are very expensive and there availability in the country is
insufficient. The laboratory grade chemicals required for lab analysis are although available in
the country on demand but their quality standards are required to be monitored as the
practices of adulteration iscommon.

3. PriorityIssuesRelatedtoChemicalLifeCycleManagementinPakistan
3.1PriorityIssueRelatedtoGovernance
i)
ii)
iii)
iv)
v)
vi)
vii)
viii)
ix)
x)
Insufficient legislation dealing with transportation, storage, use of chemicals and
disposal obsolete chemicals/pesticides as well as protection of health of workers in
their working environment. There is no provision about remediation of
contaminatedsitesinthelaws.
There are certain gaps in implementation of existing environmental laws, policies,
project planning, implementation, monitoring and evaluation due to various factors,
i.e., low capacities of implementing government agencies, lake of proper
infrastructures, lake of funds, lake of trainings, low salary structure, corruption, social
values,socio-economicissuesetc.
Poor capacities of government institutions for sound management of chemicals in
terms of technical human resource, awareness, technical know-how, financial
resourcesand infrastructure.
Penalties for environmental offences are not generally reformatory and stringent
enough to deter the felon.
Pesticide related laws do not control the storage, use and disposal of obsolete
pesticides. Complete FAO and WHO codes for use and disposal of pesticides is not
fully implemented in the country. There is a low level of awareness and knowledge of
life cycle management concept among environmental managers including limited
knowledge of FAO andWHO specifications on pesticides.
Lack of Occupational Health & Safety (OHS) and Environmental Health and Safety
(EHS)policiesand lawsand protective measuresfrom chemicalexposuresforworkers
attheir workplaces.
Disaster management, development planning and environmental management
institutions operate in isolation. There is a lake of preventive strategies for chemical
safety. National Disaster Management Plan does not include strategies for chemical
accidents/industrial accidents and remediation mechanism. The capacities and
technical knowledge for remediation of contaminated sites is poor.
The capacity building for sound management of chemicals in general is not included
in the nationalpovertyreduction and strategypaperand countryassistance strategies
Lack of cooperation and coordination among ministries and other related
institutions. Limited coordination between policy makers and industry in policy
making process. Stakeholders from some ministries related NGOs, academia, labour
unions and civil society neither are nor present in NATCC.
Lack of initiatives by trade unions/private sector for capacity building and
development of expertise for sampling, testing and research on environmental
pollution caused by industrial processes. There is a very limited interaction of trade
organizations with inter-governmental institutions

xi)
xii)
xiii)
xiv)
xv)
xvi)
xvii)
xviii)
There is a need to create some mechanism of standardizing NGOs so that they can
play some vital role in monitoring and inspections.
The role of women is limited in chemical management especially in agriculture sector
duetolackofawarenessandeducation.
Role of electronic media in dissemination of information about chemical hazards is
very limited especially for consumer products/house hold products containing
hazardouschemicals. In this regardslackof consumer societiesforawarenessof such
harmful products is another bottleneck.
Limited evaluation of socioeconomic impacts and chronic impacts of chemicals used
in different sectors.
Lack of preliminary hazard analysis system and guidelines for hazard identification for
government institutions, industry, importers and exporters. Hazard information on
chemicals used in industry is seldom displayed. Targeted chemical risk assessment
approachisseldomseeninmajordevelopmentprojects.
Globally Harmonized System of Classification and Labelling of Chemicals (GHS) are
yet to be implemented in Pakistan.
Absence of continuous monitoring system for trans-boundary movement of
hazardous waste. Lack of critical infrastructure, trained human resource and financial
resources required for monitoring.
The information management and dissemination system for chemicals is absent in
the country which play a critical role in life cycle management of chemicals. Non
availabilityof relevant and harmonized data, absence of inventorysystem and records
by industry as well as related institutions, related to chemical accidents, chemical
poisoning cases, drinking water contamination, food contamination, transportation
and storage of chemicals is the key obstacle to sound management of chemicals
Information regarding unknown chemicals imported which are used in numerous
micro-levelunits isalso lacking.
3.2PriorityIssuesRelatedtoCapacitiesforChemicalsManagement
i) Poor technical infrastructure for recycling, recovery and disposal of obsolete
pesticides as well as lack of sustainable monitoring mechanism for obsolete storage
sitesofobsoletepesticides
ii)
iii)
Inadequate patient poison control/decontamination facilities and stocks of antidotes,
medicines, and appropriate equipment in hospitals for chemical emergencies like
pesticidespoisoning. Lackof poison analysis, research and information centres.
Majority of farmers are uneducated and unaware of health and environmental
implications of use of agricultural chemicals like pesticides and fertilizers. Due to
illiteracy farmers do not have access to information about integrated pest
management and proper pesticide/fertilizer use.

iv)
v)
vi)
vii)
viii)
ix)
Dearth of knowledge and limited capacity of hazard identification, risk assessment &
management, and linkages between livelihoods and disaster preparedness related to
chemical accidents, within disaster management bodies. The industries do not have
any chemical disaster management plans and training programme developed for
workers. Fire fighting departments do not have necessary facilities/ equipment know-
howto cope with chemical fires.
Lack of degree programmes in universities about chemical management, risk
assessment/prevention, occupational health and safety, environmental health and
safety issues, waste management, waste treatment technologies, cleaner production
technologies and international environmental Conventions and Protocols.
Cleaner production technologies were introduced by the private sector with the
technical assistance of Cleaner Production CenterSialkot few years back especiallyin
leather tanneries. In order to bring about environmental and economic improvement a
program to promote cleaner production technologies in every industrial sector in Pakistan is
needed. These technologies are very expensive and the there is a limited know-how about
thesetechnologies, therefore incentiveshould begivenandcapacity building programmes for
SMEsmaybeinitiated.
Absenceof integrated vectorcontrolprogrammeand pestmanagementprogramme.
There are very few poison control and information centers working in the country.
These centers are not fully equipped with necessary technical infrastructure according
to guidelines of IPCS. There is an urgent need of establishment of new poison
control and information centers especially in industrial and agricultural hubs of
Pakistan.
The capacities of analytical laboratories are low to medium. Generally there is a lack
of sustainable financial mechanism required for R & D in environmental sector.
There are no special allocations for chemical management/research in Pakistan. The
other bottle neck is lack of technical human resource. During the last two decades
due to economical crises in the country there was a brain drain from the institutions.
This has become a critical issue. The relevant institutions lack critical monitoring
infrastructure.

3. Recommendations
3.1RecommendationsforGovernanceIssues
Establish a centralized chemical information management and dissemination system for
including chemical hazard data sheets and inventory system of chemicals use, storage,
transportanddisposalsystem.
Build capacity of industries and EPA to establish Pollutant release and Transfer
Registers(PRTRs)
The Globally Harmonized System of Classification and Labelling of Chemicals (GHS)
should be implemented in the country.
Develop the recyclingandrecoveryfacilitiesfordisposalof obsolete pesticides.
Additional poison control centers should be established near agricultural hubs, with
technical human resource and medical facilities required for treatment of
pesticides/otherpoisoningcasesaccordingto the IPCS guidelines.
Capacity building for sound management of chemicals should be given priority in
national development plans and poverty reduction strategies. Sufficient financial
resources should be allocated for capacity building of ministries and related institutions
forlife cycle management strategies includingeconomicimpact assessment of chemical
use.
Stakeholders from trade and industry should be involved in policy making process and
a coordinationmechanism should be evolved.
Addition of Representatives of Ministries for Petroleum & Natural Resources, Labour,
Railway, Communication, Ports & Shipping, National Disaster Management Cell,
EmergencyServices, is required. Academia, industries and NGOs should also be given
representation. A broader representation should be ensured in NTACC to bring
synergiesfrom related initiativeson chemicalmanagement.
A mechanism should be evolved to enhance cooperation between trade organizations
with inter government issues through participation in their initiatives for global
chemicalmanagement.
Mechanism to accredit NGOs should be brought in so that they can play better role in
monitoringthe chemicalmanagementissues.
Training and awareness programme is required exclusive for women workers including
agriculture workforce.
Need for improvement in advertisement laws with reference to include safety concerns
of chemicals used in agriculture and consumer products for public awareness. Enhance
the capacity and role of electronic media for information dissemination on chemical
hazards.
Develop a Clearing House Mechanism for information on chemical safety for optimum
useofresources

A sustainable monitoring system should be established for trans-boundarymovement of
hazardous waste and illegal chemicals and law enforcing agencies should be provided
necessaryequipmentand training.
There is a need to further enhance public private partnership for exchange of
information, technologyand expertise required for chemical management
Explore cooperation with other countries and IOMC organizations in the field of
education,scienceandtechnology.
Global information network may be developed with help of ILO, WHO, UNEP and
FAOetc.
Enhance integration planning between disaster management, development planning
and environmental management institutions.
University curricula should be revised to include courses related to chemical life cycle
managementandintegratedwastemanagement.
Implement/introduce voluntary initiatives like environmental management system to
prevent pollution in industry and R & D institutions.
Give incentives for introduction of pollution prevention technologies like cleaner
production technologies and enhance corporate responsibility of environmental
managementincorporatesector.
Penalties to be made reformatory and stringent by increasing the amount of fine so that
they deter the offence and beside penalties economic incentives should be given to
industriesto reduce theirwaste emission and properdisposalof wastes.
3.2. RecommendationsforImportantandUrgentChemicalsManagementIssues
Develop harmonized data elements on occupational health and safety for recording
relevant workplace data in company specific databases. Set time frames for industry, in
cooperation and coordination with other stakeholders, to generate hazard information
for high-production volume chemicals not addressed under existing commitments
Promote training in risk/hazard assessment, classification and preparation of safetydata
sheets and implement GHS in the country.
Establish more poisoning information and control centers and systems for data
collection and analysisand enhance the capacityof presentfacilities.
Develop PRTRs tailored to variable national conditions as a source of valuable
environmental information for industry, so that risks are communicated in a timely and
accurate fashion without unduly alarming the public.
Fill gender specific gaps in scientific knowledge (e.g., gaps in understanding of
endocrinedisruptorsandspecialwomenconcernsrelatedtochemicalexposures)
Develop and establish targeted riskassessment approachesto evaluatingexposureand
impacts, including socio-economic impacts and chronic and synergistic effects of
chemicals on human health and the environment Harmonize chemical safetynorms)
Encourage full implementation of the FAO International Code of Conduct on the
Distribution and Use of Pesticides.

Pakistan _CA

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