BANGLADESH

COUNTRY ASSESSMENT REPORT

Table of Contents
EXECUTIVE SUMMARY ........................................................................................................... 4
LIST OF ACRONYMS ............................................................................................................... 6
LIST OF FIGURES .................................................................................................................... 7
LIST OF TABLES ...................................................................................................................... 7
1. Existing Knowledge of National Health and Economic Impacts from Lead ..................... 8
a. Estimated Childhood Blood Lead Levels................................................................. 8
b. Available Burden of Disease Data Associated with Lead Exposures .................... 9
c. Economic Impacts from Lead Exposures ...............................................................10

2. Known and Suspected Sources of Lead Exposure ..........................................................11

a. Industrial Sources ....................................................................................................11
i. Lead Acid Battery Manufacturing and Recycling .............................................11
ii. Jewelry Making and Gold Waste Processing ..................................................13
iii. Pesticides ......................................................................................................13
iv. Coal Mining ...................................................................................................14
v. Shipbreaking ..................................................................................................14
b. Products Containing Lead .......................................................................................15
i. Turmeric ..........................................................................................................15
ii. Other Foodstuffs.............................................................................................16
iii. Aluminum Cookware......................................................................................17
iv. Paint ..............................................................................................................17
v. Cosmetics and Religious Powders .................................................................18
vi. Amulets and Jewelry .....................................................................................19
c. Geographic Priorities and Known Contaminated Sites .........................................19
d. Industry Analysis for Priority Lead Sources ..........................................................20
i. Lead Acid Batteries .........................................................................................21
ii. Turmeric .........................................................................................................23

3. Stakeholder Mapping ..........................................................................................................26

4. Prior and Ongoing National and Subnational Programs

Relevant to Lead Exposures and Health Impacts .............................................................32

5. Health Systems ...................................................................................................................33

a. Service Provider Awareness ...................................................................................33
b. Available Services and Capacities ..........................................................................34
i. Prevention .......................................................................................................34
ii. Monitoring ......................................................................................................35
iii. Diagnostics, Care, and Treatment .................................................................35
c. Ministry of Health Institutional Capacity .................................................................36
d. School Health Programs ..........................................................................................37

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 e. Local Government Capacity and Engagement .......................................................37
f. Role of Non-Governmental Actors ...........................................................................39

6. Lead Pollution/Source Management Capacities ...............................................................41

a. Background and Context of Lead Management .....................................................41
b. Assessment of Chemicals Management Capacity .................................................41
i. Relevant Agencies and Specific Mandates......................................................41
ii. Inter-Ministerial and Department Coordination................................................42
iii. Laboratories and Environmental Quality Monitoring .......................................43
iv. Information Management Systems and Databases .......................................45
c. Legal Framework ......................................................................................................46
i. Policy-making Process ....................................................................................46
ii. Existing Legislation .........................................................................................46
d. Role of NGOs ............................................................................................................49
e. Involvement of Academia and Research Institutes ................................................50

7. Information Gaps ................................................................................................................52

REFERENCES .........................................................................................................................55

APPENDIX A. EXISTING ORGANIZATIONAL EXPERIENCE AND ASSETS ...........................62

a. Pure Earth .................................................................................................................62
b. UNICEF......................................................................................................................67

APPENDIX B. Used Lead Acid Batteries In Bangladesh 70

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Executive Summary
Bangladesh, a previously agrarian economy has rapidly grown to one based more on diversified
services and manufacturing. While this has allowed the country to move up the income scale, it has
also created new challenges around pollution control and environmental contamination. Lead has
emerged as a particularly salient threat to the country’s children.

The average concentration of lead in children’s blood in Bangladesh is estimated to be among the
highest in the world at approximately 8 micrograms per deciliter (μg/dL) (Ericson et al., 2021). This
concentration is significantly above the reference level of 5 μg/dL that triggers government
intervention and case management for a child in the United States. A recent systematic review
suggests that nearly 28.5 million children in Bangladesh have blood lead levels (BLL) above 5 μg/dL,
and that more than 21 million have BLLs above 10 μg/dL (Ericson, 2021). At these levels, it would
be reasonable to expect significant IQ reductions among the tens of millions of chronically exposed
children. Lead exposure is responsible for an estimated annual loss of more than 690,000 years of
healthy life across the population of Bangladesh (IHME, 2019).

The illegal and substandard recycling of used lead acid batteries (ULABs) has been identified as a
source of significant levels of environmental lead pollution and is suspected of being a contributor to
high BLLs among the population in Bangladesh. The demand for ULABs in Bangladesh has steeply
risen in the last decade, especially in the transportation sector (cars and e-rickshaws),
telecommunications, and for power storage in solar energy collection systems or in backup systems
where there is unreliable grid electricity service. The informal economy represents a substantial
portion (89% of the labor force) of Bangladesh’s workforce and productivity (Asian Development
Bank, 2012). With an overall increase in resource-recovery activities in the country, collection of
ULABs and their smelting have become widespread, especially in the informal sector. Bangladesh is
estimated to have more than 1,100 informal and illegal ULAB recycling operations across the
country (World Bank 2018). According to the Accumulator Battery Manufacturers and Exporters
Association of Bangladesh (ABMEAB), there are around 50 battery factories operating in
Bangladesh apart from the registered ones, and they are largely foreign-owned. These unregistered
factories produce 500,000-600,000 units a year and are depriving revenue to the government
(Amader Shomoy 2018).

There is strong evidence from multiple studies that adulterated turmeric is the leading contributor to
elevated BLLs among pregnant women in rural Bangladesh (Forsyth et al. 2018). Other household
products found to contain lead include paint, cosmetics, and aluminum cookware, which all have the
potential for significant human exposure.

Given that the cognitive deficits caused as a result of lead exposure are irreversible, prevention
should be an overwhelming priority. Despite the alarming estimates of the extent of this public health
threat in Bangladesh, there is only a patchwork of laws and agencies involved in implementing the
relevant regulations around lead exposure. Similarly, the health system does not currently have the
capacity, infrastructure, or supplies to identify and monitor children with elevated BLLs, or to
promote and implement preventative programs pertinent to lead exposure. Enforcement efforts are

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extremely limited due numerous reasons, including: lack of capacity and resources to enforce
environmental regulations effectively, weak governance, political pressures, lack of motivation to
engage with the ULAB manufacturers and recyclers, and an insufficient number of trained inspectors
who can visit these recycling sites to ensure that they abide by the regulations.

This report is a situational analysis of the current landscape in Bangladesh regarding lead exposure
and sources. It also includes the health and economic impacts of lead exposure; the known and
suspected sources from both industry and consumer products; the stakeholders involved;
government capacity in both the health and environmental sectors; the regulatory framework; and
gaps in our current understanding of this issue. This assessment can serve as the basis for setting
priorities and developing activities going forward that will help identify, address, and mitigate the
environmental exposure risk associated with lead.

The Country Assessment is an internal document between Pure Earth and UNICEF intended to
provide Pure Earth and UNICEF with appropriate situational awareness regarding lead sources,
childhood lead exposures, impact on child health, and national environmental and health
management capacities. The assessment also maps existing lead programs, relevant stakeholders,
and other information that will aid in the successful planning and implementation of national
activities.

This Country Assessment was developed jointly by Pure Earth and UNICEF Country Offices. It
includes and is informed by outreach to relevant government and non-government stakeholders,
including national and potentially sub-national government agencies, UN organizations, relevant
industry representatives, and NGOs and other civil society groups. The Country Assessment will
inform and be followed by a Pure Earth/UNICEF Joint Country Implementation Plan, building on the
existing joint logframe.

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List of Acronyms
ABMEAB Accumulator Battery Manufacturers and Exporters Association of Bangladesh
BBS Bangladesh Bureau of Statistics
BCSIR Bangladesh Council of Scientific and Industrial Research
BDS Bangladesh Standards
BFSA Bangladesh Food Safety Authority
BFSN Bangladesh Food Safety Network
BLL Blood Lead Level
BSTI Bangladesh Standards and Testing Institution
CAB Consumer Association of Bangladesh
CBHC Community-Based Health Care
CCHPU Climate Change and Health Promotion Unit
DAE Department of Agricultural Extension
DGFP Directorate General of Family Planning
DGHS Directorate General of Health Services
DGNM Directorate General of Nursing and Midwifery
DNCRP Directorate of National Consumer Rights Protection
DoE Department of Environment
ESDO Environment and Social Development Organization
HMIS Health Management Information System
HSM Hospital Services Management
icddr, b International Centre for Diarroheal Disease Research, Bangladesh
IEDCR Institute of Epidemiology, Disease Control and Research
IHME Institute for Health Metrics and Evaluation
ILA International Lead Association
LAB Lead Acid Battery
MAC Maximum Allowable Concentration
MCRAH Maternal Child Reproductive and Adolescent Health
MNCAH Maternal Newborn Child and Adolescent Health
MoEFCC Ministry of Environment, Forests and Climate Change
MoHFW Ministry of Health and Family Welfare
MoLGRD&C Ministry of Local Government and Rural Development and Cooperatives
NCDC Non-Communicable Diseases Control
NIPSOM National Institute of Preventive and Social Medicine
POPs Persistent Organic Pollutants
PMR Planning, Monitoring and Research
SHS Solar Home Systems
SRO Statutory Regulatory Order
TSIP Toxic Sites Identification Program
ULAB Used Lead Acid Battery

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List of Figures
Figure 1: Death and DALY rates per 100K people between 1990 and 2017 associated with lead
exposures (green) and unsafe water sources (purple) (Institute for Health Metrics and Evaluation,
2019). 9
Figure 2: Map of Bangladesh showing the geographic distribution of all 340 TSIP assessments
(conducted between 2011 and 2020) at which lead was identified as the key pollutant.
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Figure 3: Collection chain of ULABs in formal and informal sector (Pure Earth, 2020b). 23
Figure 4: Stakeholder map of industrial sources of lead exposure. 29
Figure 5: Map of stakeholders related to lead exposures from consumer products. 30
Figure 6: Map of health sector stakeholders relevant to lead exposure and response. 31

List of Tables
Table 1: Testing details of products in BSTI Laboratories. 43
Table 2: Testing details of lead in BCSIR Laboratories. 45

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1. Existing Knowledge of National Health and Economic Impacts
from Lead
Lead is a known neurological and cardiovascular toxicant with long-term health and developmental
impacts, and more than half of Bangladesh’s children are estimated to have elevated blood lead
levels (UNICEF and Pure Earth, 2020). Lead exposure affects children’s cognitive, social, and
behavioral skills and undermines their potential. Lead can enter the body through a range of
exposure pathways, including the ingestion of contaminated dust, water, and food stuffs, or by
inhalation.

a. Estimated Childhood Blood Lead Levels

According to the Bangladesh Institute for Health Metrics and Evaluation (IHME) (2017), the average
estimated background blood lead levels (BLLs) among children in Bangladesh is 6.83 μg/dL (lower
estimate: 6.22; upper estimate 7.50; Ericson et al. [2021] estimate this figure is 7.87 μg/dL). For
reference, 5 μg/dL is the value used by the U.S. Centers for Disease Control and Prevention to
identify children who have been exposed to lead and require case management. IHME also
calculated an estimate of the number of children in Bangladesh with a BLL above 5 μg/dL. This
figure is more than 35.5 million children (mean estimate: 35,527,67, lower estimate: 23,639,658,
upper estimate: 45,959,260). The estimated number of children with a BLL above 10 μg/dL is nearly
10 million (mean estimate: 9,675,388, lower estimate: 4,207,907, upper estimate: 17,832,455).

Beyond these national estimates, previous studies have documented elevated BLLs among children,
and these studies highlight the geographic heterogeneity of this problem. In Sirajdikhan (Munshiganj
District), a primarily rural area, nearly 80% of children tested had BLLs above 5 μg/dL (Gleason et
al., 2014). Mitra et al. (2009) found that the percentage of children above 10 μg/dL varied depending
on land use, with 5% in an urban nonindustrial are (Azampur, Uttara), 14% in a rural nonindustrial
zone (Chirirbandar, Dinajpur), and a shocking 99% in an urban industrial zone (Rajabari, Turag,
Tongi). A number of studies were also carried out in and around Dhaka between 2000 and 2010;
these studies reported mean BLLs in children between 7.6 and 15 μg/dL (Amin Chowdhury et al.,
2021).

Blood lead levels among children have been found to be even higher at known lead hotspots. Pure
Earth, University of Dhaka Department of Geology, International Centre for Diarrhoeal Disease
Research, Bangladesh (icddr,b), and Stanford University collected data on soil contamination and
BLLs among children at an abandoned, informal used lead acid battery (ULAB) recycling operation
in the small town of Kathgora, in the Ashulia area north of Dhaka. Contaminated soils in public areas
used by children had lead concentrations exceeding 100,000 parts per million. Contaminated battery
waste was left in large piles, and children played directly on these waste piles. Before completing a
series of risk reduction activities in the community, BLLs among the local children were measured.
The mean BLL among 69 local children prior to risk-reduction activities was approximately 19 μg/dL.
All of the children tested in Kathgora had BLLs exceeding 8 μg/dL, with the highest BLL exceeding
approximately 48 μg/dL. It is important to note that Kathgora is one example of the estimated similar

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1,100 informal ULAB recycling sites spread across the country putting more than a million people at
risk of exposure (World Bank, 2018).

The existing BLL data demonstrates the pervasive nature of lead exposure and the need for
immediate preventative actions (UNICEF and Pure Earth, 2020). Overall, there is limited data on
childhood BLLs for Bangladesh. As a result, awareness of lead poisoning is still low within the
community and among the health workers.

b. Available Burden of Disease Data Associated with Lead Exposures

Lead exposure results in both mortality and morbidity among adults and has significant
neuropsychological effects on children (Pure Earth, 2020). According to the estimates of the Global
Burden of Disease study by IHME, in Bangladesh, nearly 31,000 deaths annually are attributed to
exposure to lead—3.6% of all deaths nationally—making Bangladesh one of the most severely
lead-impacted countries in the world (IHME, 2019). Lead exposures are responsible for an annual
loss of more than 690,000 years of healthy life across the population of Bangladesh (IHME, 2019).

These health impacts from lead exposure, quantified as deaths and disability-adjusted life years
(DALYs), have not declined in Bangladesh over the past 30 years, despite the ban of leaded petrol
in 1999. This trend stands in contrast to the gains made in other sectors over this same timeframe,
particularly unsafe water (Error! Reference source not found.). Recently, the death rate from lead
exposure has in fact exceeded that from unsafe water sources.

Figure 1: Death and DALY rates per 100K people between 1990 and 2017 associated with lead exposures
(green) and unsafe water sources (purple) (Institute for Health Metrics and Evaluation, 2019).

Exposure to lead has well-documented health impacts, particularly for children, and can permanently
impair cognitive development and impact intellectual quotient (IQ). Increases in BLLs as low as 0.1-
1.0 μg/dL in children are associated with the loss of one IQ point (Budtz-Jørgensen et al., 2013).

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Elevated blood lead in children has been associated with attention deficits, impulsivity, and
hyperactivity, as well as depression and anxiety (U.S. Environmental Protection Agency, 2013).

c. Economic Impacts from Lead Exposures

Pervasive childhood lead exposure not only leads to health consequences, but also weakens a
country’s economy (Pure Earth, 2020). Lead is a potent neurotoxin that even at low-level exposure
is associated with a reduction in IQ scores, shortened attention spans, and potentially violent and
even criminal behavior later in life (UNICEF and Pure Earth, 2020). Children with BLLs of 5 μg/dL
may score 3-5 or more points lower on intelligence than unaffected peers (Lanphear et al., 2018).
This IQ reduction undermines children’s future potential and as a result depresses a country’s
economic productivity as a whole. It has been estimated that each year Bangladesh loses US $15.9
billion in GDP from reduced lifetime earning potential among the exposed population (Attina et al.,
2013). This figure includes only lost earning potential due to IQ decrements, and does not include
healthcare costs, lost earnings from premature death, or lost taxes from illegal ULAB recycling
operations (Grosse et al., 2002).

Childhood lead exposure is a major, underrecognized determinant of public health as well as

national economic development. It perpetuates intergenerational poverty affecting health, education,
and economic goals of the communities, government, and development agencies. Therefore, it is
important to quantify this impact in order to help raise awareness about its severity as well as inform
policies aimed at reducing overall lead exposure (Pure Earth, 2020).

The annual cost to Bangladesh’s GDP due to lead exposure is estimated as a staggering $16 billion,
or 6% of the country’s GDP (Attina and Trasande, 2013). For comparison, the productivity losses
associated with reduced IQ from lead exposure are equal to half of the country's income from
textiles and apparel (Attina and Trasande, 2013).

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2. Known and Suspected Sources of Lead Exposure
Globally, lead has been found widely distributed throughout the environment in which children live
including the water they drink, the soil they walk or crawl on, the food they eat, the paint on the
walls, the air they breathe, and to some extent even the toys they play with. The Bangladeshi
government does not currently have a comprehensive inventory of environmental lead levels or
exposure sources. Thus, this assessment relies on the data and experience of Pure Earth, UNICEF,
and our partner organizations, as well as on published literature. The description of lead sources is
broadly divided two categories, namely, industrial sources and consumer products. Industrial
sources include both formal and informal operations. The industries of concern presented below are
lead acid battery manufacturing and recycling, jewelry making and gold waste processing,
pesticides, coal mining, and ship breaking. Consumer products are goods that are bought by an
individual for personal or household use and include spices, other foodstuff like meat and milk,
aluminum cookware, paint, cosmetics and religious powder, jewelry, and amulets. The patchwork of
laws and regulations for managing lead in the environment are laid out in Section 6.

Leaded gasoline was a significant historical source of lead exposure, and residual contamination
from this use remains common globally. Bangladesh instituted a ban on leaded gasoline in 1999.
Around the same time, cities in Bangladesh also saw rapid conversion of vehicles to run on natural
gas as it was a cheaper alternative fuel. Analyses of air and dust samples indicate that lead
concentrations remain correlated with heavy traffic areas and industrial activities (Begum and
Biswas, 2008; Rahman et al., 2019a). Despite the gains in reducing lead exposure following the
phase out of leaded gasoline, the large proportion of children with elevated blood lead levels (BLLs)
as described above indicates a significant ongoing threat. Current known and suspected sources of
lead exposure are described below.

a. Industrial Sources

i. Lead Acid Battery Manufacturing and Recycling

In Bangladesh, the growth of automotive vehicles expanded the market for lead acid batteries
(LABs) coupled with the spread of Solar Home Systems (SHS) and electric auto-rickshaws (locally
known as easy-bikes). Electric rickshaws alone account for 65-75% of LABs used in Bangladesh.
Estimates for the number of e-rickshaws vary from the Dhaka Tribune’s report of approximately
500,000 to the e-rickshaw’s association’s estimate of 1.5 million. These vehicles are typically
powered by 4-6 LABs. The number of motor vehicles registered in Bangladesh is reported to be
about 500,000 units as of December 2019. This figure, however, is dwarfed by the number of
motorcycles (over 2 million) that are not included in the official vehicle registration data published by
the government (International Lead Association, 2020). Battery manufacturers in Bangladesh aim to
significantly raise their annual export in the next five years, which would contribute to the increasing
demand for lead acid battery manufacturing and recycling industries (Dhaka Tribune, 2019). Typical
LABs used in Bangladesh have a useable life of about two years, after which they must be recycled.

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While Bangladesh does have industrial operations for recycling used lead acid batteries (ULABs),
the capacity of battery manufacturers and dedicated recyclers in the formal sector has not grown in
step with the volume of ULABs generated. Furthermore, regulation and enforcement around this
issue are not robust, creating conditions for informal recyclers to proliferate throughout the country
engaging in illegal smelting activities. It is estimated that there are about 1,100 informal and illegal
ULAB recycling units across the country, putting more than one million local community members
living near these sites at risk (World Bank, 2018). The decentralized nature of the informal economy
poses regulatory challenges which have implications for environmental quality and health.

The informal recycling of ULABs creates highly localized contamination hotspots and severe risks to
children that live, play, or go to school near active or legacy informal recycling sites. Lead dust is
released on site through the breaking and separating of battery components. Because lead is quite
heavy, it generally falls back to the ground within several hundred meters of the source. Field
investigations by local Pure Earth staff indicate that site operations included breaking open ULABs,
draining out sulfuric acid, removing lead plates, and processing other internal battery components
and the plastic battery carcasses. Site operations also included the uncontrolled smelting of the lead
battery components in open pits with no vapor controls. These lead vapors from the melting of
battery plates quickly condense and accumulate near the source. The smelting operations can
cause extensive lead contamination of the surrounding surficial soil and leaf litter through
atmospheric deposition. These operations leave behind residual battery component wastes (e.g.,
separators and carcasses), concrete processing pads containing the smelting pits, and highly
contaminated soil not only in the area of operations, but in a widespread surrounding area.
Contaminated site remediation projects conducted by Pure Earth have shown that lead released
during informal recycling is generally confined to the top 2 cm of local surface soils outside of the
immediate smelting area. Lead-contaminated waste left behind from these operations can contribute
to elevated environmental lead levels, putting local residents, particularly children at risk.

The predominant pathway of human lead exposure at a ULAB recycling site is likely incidental
ingestion of contaminated dust. The ingestion of soil and dust as an exposure pathway for lead and
other environmental contaminants has been documented among Bangladeshi children (Kwong et
al., 2019). This occurs via hand-to-mouth activity, mouthing objects, and, among the youngest
children, directly ingesting soil. Kwong et al. 2019 also found that soil consumption in a rural
Bangladeshi setting was substantially higher than existing estimates for children in high-income
countries. As most inhaled lead dust particles are too large to penetrate the lungs, they are cleared
from the lungs and then ingested. In addition, children often engage in hand-to-mouth behaviors,
play in and around waste piles due to proximity to these sites, thereby ingesting whatever lead dust
they have on their hands. A further possibility for lead exposure is the use of lead-contaminated leaf
litter in open fires.

Bangladesh is believed to have more than 1,100 informal and illegal ULAB recycling sites across the
country, putting more than a million local community members at risk (World Bank, 2018). More than
250 individual recycling sites have been identified and assessed by Pure Earth under the Toxic Sites
Identification Program (TSIP) from 2011 to the present in conjunction with the University of Dhaka

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and with the engagement of several Bangladesh government agencies. The industry dynamics
surrounding LABs are further elaborated in Section 2d.

ii. Jewelry Making and Gold Waste Processing

The handmade production of jewelry remains culturally important in Bangladesh, and there are a
range of roles for artisans in this industry. Sikder et al. (2017) performed a toxicity assessment of
ash and dust from gold jewelry manufacturing shops in Tanti Bazar of old Dhaka’s historical
downtown. Handmade gold jewelry is an old profession in Bangladesh using ancient production
process without any occupational safety. Elevated concentrations of lead in dust samples were
found that most likely originated from the use of poor quality zinc and copper. During the soldering
process, heating of lead at high temperatures can generate dangerous fumes endangering the
artisans (Sikder et al., 2017).

Furthermore, certain small clusters of villages and urban centers engage in a form of gold recycling
by which they recover precious metals from waste materials generated from jewelry making
operations. In early 2020, investigators under Pure Earth’s Toxic Sites Identification Program (TSIP)
assessed 11 sites in Chittagong and Dhaka Districts where this method is being used (Table 1). The
process used involves the extensive use of lead, which, based on evidence at the sites, is sourced
from ULABs (Pure Earth, 2020a). These industries are typically located in densely populated areas,
with very limited controls to ensure waste, emissions, or effluent are contained, putting the nearby
community at risk.

Investigations conducted by Environment and Social Development Organization (ESDO) and Pure
Earth suggest that these recyclers purchase ashes and discarded ceramic pots used in jewelry
making from around the country. The process involves washing the waste; drying it in the sun;
grinding it in a manual grinder; mixing the waste with charcoal and lead and shaping it into balls;
drying the balls and then mixing them with borax. The balls are then fired in an oven furnace, where
the gold and silver combine with the lead. The lead and precious metals are then separated using
nitric acid. The lead is released as vapor during the burning process, as dust, and through the water
used for washing. In the villages that engage in this recycling, most families are engaged directly in
the process and the work is carried out in very close proximity to residences, putting the whole
community, including children at risk. It is reported that for every 400 kg of waste material, 150 to
180 kg of lead are used to recover 60 gm of gold and 150 gm of silver (ESDO, unpublished data).

iii. Pesticides

Agriculture is one of the largest employment sectors in Bangladesh, and pesticide consumption in
the country has increased four-fold in the last decade (Rodriguez Eugenio, McLaughlin and
Pennock, 2018). Lead-based pesticides were widely used in the first half of the 20th century.
Although they were banned in the U.S. and Australia in the 1980s, it is unclear to what extent these
pesticides were used or continue to be used in Bangladesh, or if the larger concern is lead
contamination of pesticides with other active ingredients.

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Recent reports from the popular press indicate that lead and heavy metals may still be present in
pesticides, but further investigation into these findings is required. Recently, 63 of 67 pesticides
tested by the Bangladesh Food Safety Authority (BFSA) were found to contain heavy metals,
including lead, cadmium, and chromium (Hossain, 2020), although concentrations were not
reported. In another instance, lead and cadmium were found in the pesticides Fana 5G, Brifur 5G,
and Unizoom, in which heavy metals are not the active ingredient (Rahman, 2019). It is suspected
that heavy metals may be added intentionally because they are cheaper than the approved active
ingredients, or the heavy metals are present in low quality inert materials used in the formulation
(Hossain, 2020). Although licenses for importing pesticides are given by the Department of
Agricultural Extension (DAE), the imported pesticides are not routinely tested (Hossain, 2020).

Forsyth et al. (2018) examined the impact of the use of agrochemicals on lead levels in soil and rice
in rural Bangladesh and assessed possible impacts on blood lead levels (BLLs) among pregnant
women. Although there were statistical associations between elevated BLLs and the use of Rifit (a
pretilachlor-based herbicide) and Basudin (a banned organophosphate pesticide), there was minimal
evidence of lead contamination in the agrichemicals. Forty-nine samples of Rifit and one sample of
Basudin were analyzed, none of which contained detectable lead. The maximum lead concentration
among all pesticides and herbicides analyzed was 8.3 μg/g and 6.3 μg/g, respectively. The authors
do note, however, that this may have been a larger source of lead exposure in the past.

The presence of lead in food products is discussed in Section 2b.

iv. Coal Mining

Pollution and soil contamination by lead is a localized concern near the only coal mine operating in
Bangladesh. The Barapukuria coal mine is located in Dinajpur district of northwest Bangladesh, and
assessment of soil quality in the surrounding area indicates high levels of lead contamination
(Sahoo, Equeenuddin, and Powell, 2016). Heavy metal contamination was also observed in both
drainage water and groundwater in the area around Barapukuria (Bhuiyan, Islam, Dampare, Parvez,
and Suzuki, 2010). The Barapukuria Coal Fired Thermal Power Plant also generates significant
quantities of solid by-products which are conventionally known as fly ash. A 2016 study of the fly ash
from Barapukuria found that all major and minor parameters were within what the study’s authors
noted were allowable limits, although publicly available regulations in English were not found
(Howladar et al., 2016). Lead was detected at 6 ppm in the fly ash.

v. Shipbreaking

Shipbreaking has been an important economic activity in Bangladesh for more than 30 years. The
method relies on stranding large vessels on the coast utilizing high tide while workers cut it into
pieces, which are dragged closer to the beach (Hossain, 2017). Shipbreaking is concentrated in
Sitakunda, north of Chittagong situated in a complex zone of marine, coastal, urban, and rural
land-based environments with ship recycling activities representing second/third largest facility in the
world. It has been reported that large amounts of hazardous materials with high concentration of
metal pollutants accumulate in the sediments of Sitakunda as a result of shipbreaking. In addition to

14
the release of various paints, coatings, oils, and persistent organic pollutants, heavy metals are
released into the surrounding water and sediments during the process (M. S. Hossain et al., 2016).
The metals observed include lead, mercury, chromium, arsenic, copper, zinc, and aluminum (M. S.
Hossain et al., 2016). This industry is the biggest source of trace metal pollution to the environment
in the Sitakunda Upazila (Rahman et al., 2019b). Lead dust and fumes can also be generated from
boats with paint containing lead that are broken during the process. Many boats have been painted
with marine paints that are high in lead which can create a health hazard. The traditional safety
colors such as red and orange typically contain high levels of lead. The paint chipping off these
boats into water is also a serious threat to water quality (Department of Agriculture, Water and the
Environment, n.d.).

Through its Toxic Sites Identification Program (TSIP), Pure Earth collected soil data from four
shipbreaking areas in 2019. Two area were visited in Chittagong, and two along the Shitalakhya
River in Dhaka. Using a portable X-ray fluorescence analyzer, investigators assessed the lead
concentration along the shoreline and in nearby residential areas, and all readings were found to be
below 400 ppm, which is the U.S. EPA’s standard for residential areas.

b. Products Containing Lead

i. Turmeric

Turmeric is a very widely used spice throughout Bangladesh. Consumers in Bangladesh favor
vibrantly colored turmeric. When the roots are not a high enough quality (i.e., they are dull colored),
lead chromate may be added as a pigment to add color. However, lead chromate is an industrial
pigment and unsafe for consumption. The practice of polishing dried turmeric roots with yellow
pigment began during the 1980s by wholesalers in Dhaka to cope with flood damaged turmeric,
which is dull in color. The practice passed on from wholesalers to polishers in turmeric-producing
districts so that the color can be added early on (Forsyth et al., 2019a). Lead chromate is a common
industrial pigment that can be sourced from color merchants, although it was never intended for use
in food products.

The addition of lead chromate to turmeric is currently a widespread problem in Bangladesh, with
evidence of adulteration found in 7 out of 9 turmeric-producing districts. The Bangladesh Standards
and Testing Institution (BSTI) sets a limit for allowable lead in turmeric of 2.5 ppm (Turmeric powder
BDS 991: 2001). Lead levels in turmeric have been found to exceed the national limit by up to 500
times and reached as high as 1,151 ppm (Forsyth et al., 2019). Eight of 28 market turmeric samples
contained lead above the 2.5 ppm limit (Forsyth et al., 2019).

This practice has had measurable impacts on public health in Bangladesh. Forsyth et al. (2019b)
explored potential sources of BLL contamination in three rural districts. They were able to identify
turmeric adulterated with lead chromate as the primary contributor to BLLs using isotope analysis
when comparing women with BLLs above 5 μg/dL to individuals with BLLs below 2 μg/dL.

15
Among common cooking spices, lead contamination has not been isolated to turmeric. A descriptive
study by Hore et al. (2019) of lead contamination in spices systemically collected as part of lead
poisoning cases in New York City showed that spice mixes used for South Asian cuisine such as
curry masala contain elevated lead levels, with maximum concentrations ranging from 2,700 ppm
(turmeric and masala) to 21,000 ppm (curry). About half of these spices had detectable lead, with
average concentrations exceeding the reference level of 2 ppm.

Adulterated spices are a source is of particular concern because lead is directly ingested and
children may face continuous exposure through their meals. Further analysis of turmeric as a priority
lead source industry is provided below in Section 2d.

ii. Other Foodstuffs

Beyond spices, lead has been identified in a number of common foods in Bangladesh. A nation-wide
sampling of commonly grown and consumed vegetables collected from 64 districts across
Bangladesh showed lead concentrations above a health-based guidance value (the FAO/WHO
Codex Alimentarius: General Standard for Contaminants and Toxins in Foods) in 29.47% of the
samples (Hossain et al., 2016). This standard for lead varies from 0.1 ppm to 0.3 ppm depending on
the type of vegetable. The study authors converted these fresh vegetable standards to a dry weight
equivalent and found concentrations above the standard in all vegetable types sampled (white
potatoes, green cabbage, red spinach, white radish and green beans). Furthermore, samples above
the standard were collected from 49 of the 64 districts, indicating the source of lead is likely
non-point in nature (Hossain et al. 2016). Islam et al. (2014) similarly identified concentrations of
lead in vegetables that exceeded a health-based standard.

Rice has also been examined as a potential source of lead. Jahiruddin et al. (2017) looked at 10
sub-districts in Bangladesh and found four had average concentration levels above the Codex limit
of 0.2 ppm. In areas where both rain-fed and irrigated rice were collected, higher concentrations
were found in the irrigated rice, and the study authors noted that this could be linked to industrial
effluent contamination.

The issue of lead in milk was one that captured the public’s attention in recent years. In 2019, BFSA
reported finding lead beyond the permissible limits in 11 out of 14 pasteurized milk samples from
brands approved by Bangladesh Standards and Testing Institutions (BSTI). The maximum
permissible limit of lead in milk (according to both the BFSA and FAO/WHO Codex Alimentarius) is
0.02 ppm but BFSA found up to five times that amount (0.1 ppm) (Rahman, Nabi and Shovon,
2019). Possible sources include contaminated cattle feed and elevated background levels of lead
(Rahman, Nabi and Shovon, 2019).

Another potential route for the passage of lead in animals to humans is via consumption of meat. A
research study testing four types of meat samples for toxic heavy metals found lead concentrations
above the maximum allowable concentration in meat (0.1 ppm according to Codex), with the highest
mean concentration observed in chicken meat (1.9±3.0 mg/kg) and the lowest found in mutton

16
(0.78±0.61 mg/kg) (Islam, 2018). Poultry feed has been identified as a potential source of lead and
other heavy metals (Islam et al., 2007).

The storage or processing of food also has the potential to introduce lead contamination. In a study
analyzing the BLLs of pregnant women from the central part of rural Bangladesh (Mymensingh,
Kishorgani, and Tangail), individuals with BLLs ≥ 7 μg/dL were more likely to consume food from
cans (Forsyth et al., 2018). The researchers identified a common practice of recycling or repairing
cans with lead solder. While Forsyth et al. (2018) identified a statistical association between
elevated BLLs and individuals grinding rice, they did not identify physical evidence of grinding slates
being repaired with lead solder as has been seen in other parts of the world.

iii. Aluminum Cookware

Lead and other heavy metals have been found in aluminum cookware in Bangladesh. Aluminum
cookware is common in South Asia including Bangladesh, given its cost effectiveness and heat
conductivity. Low-grade aluminum cookware found in the local markets of Bangladesh is often made
from scrap metals.

In 2018, the Environmental and Social Development Organization (ESDO) published a report on
high levels of lead in aluminum cookware. Four pieces of aluminum cookware from the local market
of Bangladesh were collected by the ESDO team and analyzed in a laboratory in the United States.
The researchers simulated cooking by boiling acetic acid in the pots and analyzed the liquid for
leachable lead. This sampling effort appears to be part of a larger study carried out by Weidenhamer
et al. (2017) on aluminum cookware from 10 developing countries. Four items for Bangladesh were
tested, and three of the items underwent three boils. Of the 10 boils, only one had a detectable lead
concentration, with a reading of 2 μg/serving. According to ESDO, there are no standards for lead
content in cookware in Bangladesh. To put the result in context, the U.S. Food and Drug
Administration has calculated the current Interim Reference Level (IRL) for lead to be 3 µg per day
for children and 12.5 µg per day for adults; the IRL is the amount a person would need to consume
daily that would result in blood lead levels of 5 µg/dL (US FDA, 2020). Additional research is needed
to understand the prevalence of lead leachate from a wider range of cookware and cooking
scenarios, and to compare the relative magnitude of this daily dose to other sources.

ESDO also conducted a follow up survey about people’s level of awareness and use of aluminum
cookware. They surveyed 1600 people in total, from Dhaka, Munshiganj, Manikganj, Savar, Gazipur,
and Tongi. In total, they found that 98% of the people (both urban and rural) use aluminum utensils
(cookware, bakeware, cutlery etc.). They also found that the level of awareness of potential lead
exposure was very low; only about 5% of respondents knew of the potential risks of aluminum
cookware.

iv. Paint

The extent of lead-based paint in use and for sale in Bangladesh is not well documented. Children
can be exposed to lead from paint through the ingestion of dust or flakes, or by mouthing toys.

17
Standards for the paint manufacturing industry on the lead content in household or decorative paints
were not finalized by the Bangladesh Standards and Testing Institutions (BSTI) until 2018, when the
limit was set at 90 ppm. Although the paint industry supported the promulgation of the standard,
monitoring framework is still unknown and policy attention is lagging on labelling and legacy issues
left by old paints (Hossain, 2013).

v. Cosmetics and Religious Powders

Many cosmetics and religious powders popular in Bangladesh and South Asia more broadly have
been found to contain lead for pigmentation. While lead is not readily absorbed through the skin,
exposure can occur through the eye (conjunctival absorption) and through hand-to-mouth transfer
(Goswami 2013).

Kajal (also known as kohl or surma) is an eye cosmetic used extensively in South Asian countries
including Bangladesh. Culturally, it is believed that these products have medicinal purposes and is
applied as part of the tradition. In fact, putting black makeup around baby’s eyes is a common
tradition where parents believe these eyeliners can protect the eyes or improve sight. Studies and
reports from around the world have reported kajal with high levels of lead (NYC Open Data, 2020;
Mohta, 2010; Hardy et al., 2008). Kajal may contain galena (lead sulfide, PbS) as a major
component, as well as lead oxide (Pb3O4, also known as “red lead”). Careless application of kajal,
eye rubbing, and lacrimation may cause absorption of lead through the conjunctiva.

Sindoor, also known as vermilion, is a traditional powder used for religious purposes in Hinduism
and as a symbol of marriage for Hindu women. The orange or red pigment is used on both children
and adults and is intended for topical use only. There are many varieties and manufacturers of
sindoor and not all products labeled sindoor contain lead. It is difficult for users of these products to
tell the difference between safe and dangerous brands. Lead may be added as a red pigment (lead
oxide Pb3O4). A product may contain high levels of lead even if lead is not listed as an ingredient on
the label. When a person uses these products, some of the sindoor can get onto the hands. Lead
can enter the body if the user puts their hands in their mouth. There have also been lead poisoning
cases where people used sindoor as a food coloring.

Shah et al. (2017) conducted a study with sindoor from 66 Asian stores in New Jersey and 23
samples from India. The analysis determined that 83.2% of the sindoor samples purchased in the
U.S. and 78.3% samples purchased in India contained ≥ 1.0 ppm of lead. Among the U.S. samples,
19% contained more than the U.S. FDA’s limit of 20 ppm; 43% of the samples from India exceeded
this standard. The maximum lead content among all samples was more than 300,000 ppm (30%
lead).

While kajal and sindoor are the most widely cited as being of concern regarding lead content,
elevated levels have also been found in other cosmetics in Bangladesh. A recent investigation of
skin creams purchased in Dhaka found that all six samples contained lead concentrations above the
U.S. FDA and Health Canada maximum allowable concentration of 10 ppm, with the highest
concentration found to be 50 ppm (Alam et al., 2019).

18
vi. Amulets and Jewelry

In many South Asian cultures, it is a custom for children to wear amulets (sheesha, tabeez and
metal charms) on necklaces and bracelets for reasons including speech therapy, good luck, and
protection (NYC Health, 2019). These can contain high levels of lead and pose a hazard to a child’s
health when the child mouths the amulet or when the amulet is accidentally ingested.

There are case reports of the health impacts caused by the ingestion or mouthing of such amulets,
but the available information largely comes from the U.S.. Mitra et al. (2009) noted that a child in
Bangladesh with a highly elevated blood lead of 44 μg/dL was given a tabeez to wear in order to
keep “evil spirits'' away from her, although they drew no conclusions about the causality. Therefore,
it is important to note that despite the awareness of widespread usage of these amulets including
sheesha, tabeez and metal charms in Bangladesh, there is very little information about the potential
impacts on health. This indicates a data gap which hampers evidence-based practice and decision
making.

c. Geographic Priorities and Known Contaminated Sites

One of the most robust sources of information about the location, contamination levels, and potential
public health risks of chemical contamination hotspots in Bangladesh is the database of the global
Toxic Sites Identification Program (TSIP). TSIP is designed and managed by the non-profit
organization Pure Earth and implemented in Bangladesh in partnership with the Department of
Geology of the University of Dhaka and with consultation from the Bangladesh Department of
Environment (DoE). The TSIP endeavors to identify and screen industrially contaminated sites in
low- and middle-income countries that have a potential human health impact. The TSIP in
Bangladesh began in 2011 and since then, several phases of the Program funded by different
development partners have been completed. While some of these phases looked at a broad
spectrum of chemical contaminants including pesticides, more recent phases have focused
specifically on lead contamination resulting from informal recycling of used lead acid batteries. There
are currently more than 300 sites at which lead has been identified as the key pollutant in the TSIP
database (Figure 2). Further analysis of lead acid batteries as a priority lead source industry is
provided below.

19
Figure 2: Map of Bangladesh showing the geographic distribution of all 340 TSIP assessments (conducted
between 2011 and 2020) at which lead was identified as the key pollutant.

d. Industry Analysis for Priority Lead Sources

The section below is an industry analysis of two major lead sources to help elucidate market
dynamics. Based on the suspected influence of these sources on blood lead levels (BLLs), the
available data, literature, and each organization’s experiences were used to create detailed industry
analyses for two major sources—lead acid batteries and turmeric production. Understanding these

20
industry dynamics is critical for informing feasible approaches to addressing these two major lead
sources.

i. Lead Acid Batteries

The generation of used lead acid batteries (ULABs) in Bangladesh has grown considerably in the
last decade, as demand for lead acid batteries (LABs) increased in several sectors. With this growth,
environmental health risks have emerged from both the manufacture and recycling of the batteries.

The size of the market for LABs assembled in Bangladesh is approximately US $129M (BDT 11B, or
11,000 crore) (Babu, 2020) and growing at a rate of 12% (Ahmed and Hasan, 2020). Currently
around 25 local companies are catering to domestic needs by manufacturing batteries for
three-wheelers, hybrid and electric cars, scooters, commercial vehicles, cars, instant power supplies
(IPS), and solar home systems (SHS). The phenomenon that led to rapid growth of the battery
market is the rise of the battery-powered rickshaws and easy-bikes, accounting for around Tk 8,000
crore ($92 million) worth of purchased batteries (Pure Earth, 2020b). This market demand has also
invited unregistered and non-compliant battery factories that have now captured 70% of the local
market share (Babu, 2020). The emergence of these illegal factories has significant implications for
ULAB recycling as they have now become the major buyer of recycled lead typically from low-cost,
informal recyclers.

According to the Accumulator Battery Manufacturers and Exporters Association of Bangladesh

(ABMEAB), there are around 50 battery factories, including 30 Chinese owned, operating in
Bangladesh apart from the registered ones, producing 500,000-600,000 units per year. These
unauthorized battery manufacturing factories—located in Khulna, Bagerhat, Narsingdi and around
Dhaka city—neither have permission to install such plants nor have license from Bangladesh
Standards and Testing Institution (BSTI) for purchase, use, or storage of sulfuric acid (Pure Earth,
2020b).

According to the International Lead Association (ILA), the annual generation of ULAB in Bangladesh
is 118,000 metric tons (mt) (ILA, 2020). ULABs hold value as the lead is readily recyclable into new
batteries or other goods. Only four battery manufacturers have their own recycling facilities, and
there are another two government authorized recyclers operating in the country. The known formal
sector ULAB recyclers are:

• Panna Battery Ltd. – West Rasulpur, Kamrangirchar, Dhaka

• Khorshed Metal Industries (HAMKO Group) - Bangladesh Small and Cottage Industries
Corporation (BSCIC) Industrial Area, Khulna
• RIMSO Battery - Masabo, Borpa, Narayanganj
• Kishan Accumulators Ltd. – Kashiyara, Uzirpur, Bokultala, Narail
• BengalXpo Ltd – Pabna

Additionally, Rahimafrooz Batteries Ltd. (Zirani Bazar, Zirani Kashimpur Road, Panisail, Dhaka) has
a recycling facility, but has stopped recycling.

21
A major driver for the emergence of an informal sector is that they are able to offer higher prices for
ULABs because they do not have to direct funds to environmental controls and they do not have to
pay a goods and service tax (GST) on the batteries that they purchase, which the formal sector
does. The locations of these recyclers near major towns and cities also poses a challenge, as they
are situated far away from many end-users. Additional factors include lax regulatory enforcement
and lack of awareness of lead exposure by stakeholders involved in the informal smelting activities.
These conditions have enabled the growth of hundreds of unauthorized recyclers as part of an
informal economy, posing hazards to the environment as well as occupational safety for the workers
involved.

According to the experiences of Pure Earth’s TSIP investigators in seeking out and identifying ULAB
sites, the northern part of the country (such as Gaibandha, Rangpur, Dinajpur, Bogra, Shirajganj,
Pabna) and the southwestern region (such as Khulna and Jessore) are currently more likely to have
active informal recycling sites (M. Lutful Kabir, personal communication, December 17, 2020). Active
sites surrounding Dhaka city are no longer common. However, contamination remains at former
sites that have since stopped smelting (known as legacy sites). Many legacy sites have been
identified surrounding Dhaka, followed by Tangail, Mymensingh, Sirajganj, Bogra, Gaibandha,
Rangpur, Dinajpur, Jessore, Khulna, and others (M. Lutful Kabir, personal communication,
December 17, 2020). It is estimated that there are more than 1,100 informal and illegal ULAB
recycling sites across the country, putting more than one million local community members that live
in close proximity to these sites at risk (World Bank, 2018).

Figure 3 illustrates the collection chain of ULABs in both the formal and informal sector. The
dominant route is through small buyers in the form of battery repair shops, auto and tire repair
garages as well as urban feriwallas collecting old electronics through barter and trade (Pure Earth
2020b). A survey by Chakraborty and Moniruzzaman (2017) found 106 secondhand battery shops in
Dhaka city alone, offering new and old batteries for vehicles, IPS units, and SHS. Approximately 250
– 15,000 kg of battery waste is sold in each shop per month, which the shop then resells for 72 - 75
taka per kg. The monthly collection of old batteries from these Dhaka-based shops range from 10 -
100 tons (Chakraborty and Moniruzzaman, 2017). A broker transfers these ULABs from small
buyers to re-builder or vangari shops, some of whom also operate as smelters. The less prominent
route is that from user to smelter directly, and it is mainly practiced by institutional users such as
government vehicle pools, corporate offices etc.

22
 Figure 3: Collection chain of ULABs in formal and informal sector (Pure Earth, 2020b).

The value of a ULAB increases along this collection chain; Waste Concern (2006) reported that the
price can increase by as much as 100% each stage of the transfer. The different components of the
battery can be separated, accumulated, and recycled in bulk. The vangari/smelters are interested in
ULABs because they can reuse hard containers, and partially reuse the negative plates and
separators along with the lead. Smelters also use bad plates as raw materials for smelting whereas
rebuilders/vangaris can reuse good plates for battery repair. If an entrepreneur wants to open up a
ULAB recycling facility in the formal sector, the price offered for an old battery must be equal to or
higher than the average price of a separated battery to ensure supply of sufficient batteries for
recycling (Waste Concern, 2006).

ii. Turmeric

According to Bangladesh Bureau of Statistics (BBS), turmeric production in 2018-2019 was 147,439
MT with an estimated cultivation area of 70 thousand acres (BBS, 2020). For the same financial
year, 52,583 kg of turmeric was exported from Bangladesh fetching 24.6 million taka (approximately
$300,000), which is five times the value received in 2015-2016 when export quantity was 22,805 kg
(BBS, 2020). Bangladesh is the fifth-largest turmeric producing country in the world, supplying 3
percent of global turmeric demand (The Financial Express, 2019). Following harvest, turmeric is
cleaned, cured, boiled, dried, polished, and ground. Dried turmeric is polished to remove the outer
dirty skin, roots, and soil particles, eventually transforming into relatively smooth, bright, and
yellowish rhizomes.

23
Three traditional methods of polishing turmeric fingers are found in Bangladesh. In one method, 3 to
4 kg of turmeric are placed in a sack and beaten on cement floors by hand. This operation is carried
out manually, which is slow, tedious, and labor intensive. Another method used in hilly areas of
Bangladesh involves putting 5 to 7 kg of turmeric in bags and beaten by a simple paddle operated
device (Hoque and Hossain, 2018). Forsyth et al. (2019a) describes another method of agitating by
foot in a clay pot known as chari. Addition of color takes place at the polishing stage to reduce the
manual effort and time necessary to achieve the desired color (Forsyth et al., 2019a). Even with
machine polishing, shorter polishing times can reduce wasted weight of the turmeric batch, creating
incentives for machine polishers to add color. Based on field observations, Forsyth et al. (2019a)
found that acquiring polishing machines reduced the use and especially the amount of color added.

Tracing the supply chain for turmeric poses some difficulties. For example, Square Food &
Beverages Ltd. (Radhuni brand) imports whole turmeric from India because it is cheaper and has
better quality (Masoom, 2018). Existing market assessments do not separate out turmeric from the
spice category. In the packaged spice market, Radhuni, Pran, BD, and Arku are the key players.
Radhuni has approximately 66% market share, Pran holds 19% market share, BD Food holds 7%
market share, Arku holds 3% market share and other brands hold 5% market share (EBL Securities
Ltd., 2017). In 2013, the U.S. Food and Drug Administration found excessive lead levels in Pran
brand turmeric prompting a recall.

Although large-scale brand name Bangladesh spice processors have incentives to limit the amount
of lead added to turmeric destined for export, the same cannot be said for other processors serving
the local market and other export destinations lacking strict controls. The current practice of periodic
food safety checks may catch only a fraction of the adulterated turmeric being traded worldwide.
These adulterated spices are not just limited to the country of origin, but they may also be
transported around the world through unregulated export by friends and relatives. Hore et al. (2019)
found average lead content in spices was significantly higher for spices purchased abroad than in
the United States. In Bangladesh, regulations had not focused attention on polishing mills and color
merchants who sell lead- and chromium-containing yellow pigments. Previously, turmeric-related
food inspections had focused on grinding mills to check use of rice flour being mixed in, which is an
offense that can result in fines of up to 600,000 taka ($7,000) and 3 years in jail (Forsyth et al.,
2019a).

When the Forsyth et al. (2019) study assessing the practice of adding lead chromate pigments in
turmeric was published in early September 2019, the Bangladesh Food Safety Authority (BFSA)
organized meetings with the technical team of International Centre for Diarrhoeal Disease Research,
Bangladesh (icddr,b). Following the meeting, public announcements were placed in six daily
newspapers in order to raise public awareness against buying artificially colored and openly sold
turmeric from the market. A five-member specialized monitoring team was established, which started
its first enforcement drive in October 2019 at Dhaka’s Shyambazar turmeric wholesale market,
collecting samples and distributing leaflets. Enforcement with mobile courts is ongoing. These courts
are run by executive magistrates punishing or fining an offender based on the surrounding evidence
and statements from witnesses. Established under the Mobile Court Act 2009, one of the primary
intentions of the Act was to curb food adulteration. Two wholesaling entities in Shyambazar were

24
fined 400,000 taka each under section 24 of Safe Food Act 2013 after finding traces of lead
chromate in their stored turmeric. A total of 900 kg of contaminated turmeric were later destroyed
(BFSA, 2019).

Simultaneously, the Ministry of Commerce is convening committees to control import of lead

chromate and its use in the country. The ministry suggested imposing a complete ban on lead
chromate imports until a complete proper testing protocol is formed by the appropriate authorities
(The Financial Express, 2019).

25
3. Stakeholder Mapping
Due to the diverse range of sources of lead exposure identified in Bangladesh, a range of
stakeholders are involved, or could be activated, to better quantify the issue of lead exposure and
develop coordinated strategies. This includes governmental bodies, ranging from local governments
to Ministries, encompassing both the health and environmental sectors. Without systematic
monitoring from the government, research organizations play an important role in quantifying the
extent and sources of elevated blood lead levels. Non-governmental and community groups are
critical for reaching affected populations and consumers of lead-containing products. Finally,
industry must be involved to change work practices that contribute to community exposures.

Figures 4 through 6 lay out relevant organizations related to industrial sources of lead exposure,
lead exposure from consumer products, and the health response to lead exposure. These
stakeholders include industry, consumers, civil society organizations, researchers and academia,
and the government.

In Figure 4, several priority industries are highlighted, including used lead acid battery (ULAB)
recycling and manufacturing. The whole supply chain should be considered as stakeholders, to
understand market drivers and opportunities for interventions. Industry associations also play an
important role in educating and supporting their members. As for government bodies, the
Department of Environment, under the Ministry of Environment, Forest, and Climate Change, has a
critical role in environmental monitoring and enforcement. Other ministries, such as Agriculture or
Mining, may be engaged on specific lead sources. Researchers and academia, such as International
Centre for Diarrhoeal Disease Research, Bangladesh (icddr,b) and the University of Dhaka, are
needed to assess and build evidence for interventions.

There are also a number of prominent groups in Bangladesh focused on policy advocacy and
activism on environmental issues:

Bangladesh Poribesh Andolon (BAPA): BAPA is the largest and pioneering civil society
organization (CSO) in Bangladesh. Launched in 2000, it was formed to create a nationwide, united,
and strong civic movement to protect Bangladesh’s environment. The organization works on
problems such as degradation of biodiversity, water pollution, air pollution, and climate change in
order to help Bangladesh’s rapidly deteriorating environment. BAPA prioritizes the sustainability of
Bangladesh’s environment and some of their work includes influencing the government to provide
environmental conservation laws or spreading awareness to stakeholders about the drastic effects
of environmental pollution.

Bangladesh Environment Network (BEN): Bangladesh Environment Network (BEN) was set up in
1998 to mobilize non-resident Bangladeshis and their international networks for the protection of
Bangladesh and the global environment. In fact, BAPA is one of the outcomes of an International
Conference on Bangladesh Environment (ICBEN) which was an initiative of BEN. Using the
technical expertise that exists among non-resident Bangladeshis, BEN has set up panels to study
and suggest policy recommendations regarding all major environmental issues faced by

26
Bangladesh. The network has several panels focusing on issues including household, industrial
waste, urbanization, arsenic and water contamination, energy, and the economic and legal aspects
of managing the environment.

The Bangladesh Environmental Lawyers Association (BELA): Their legislative advocacy has
culminated in several constitutional and legal amendments (Khan, 2017). Their legal action against
owners of shipbreaking yards and government agencies were instrumental in bringing changes to
the regulatory framework concerning shipbreaking.

For consumer products (Figure 5), the public is an important stakeholder because of both the risks
they face from these products, as well as their purchasing power in shifting market demand.
Government actors include: the Bangladesh Food Safety Authority, Ministry of Commerce, the
Bangladesh Standards and Testing Institution, Directorate of National Consumer Rights Protection,
and the Ministry of Health and Family Welfare. There are also advocacy groups that are vocal on
issues related to food and product safety. The food safety network includes Consumers Association
of Bangladesh (CAB), B-SAFE, Shishuk, Hunger Free World, and UBINIG. Their activities in dealing
with lead-contaminated turmeric are not publicly available. These organizations are working primarily
on food safety issues in the areas of consumer education, monitoring and food product testing,
advocacy, research, and grassroots mobilization.

Consumers Association of Bangladesh (CAB): The Consumers Association of Bangladesh

(CAB) is a non-government and non-profit voluntary organization dedicated to the protection and
promotion of consumers’ rights and interests in the country. Its mission is to empower consumers
with the knowledge and skills for the effective protection of their rights and interests. The major
areas of CAB activities are consumer information and education, monitoring of market prices and
quality of essential commodities and utility services, consumers complaint handling, campaigns for
safe foods and commodities, ethical drug promotion, and safe environment.

B-SAFE Foundation was established in 2009 as a not-for-profit CSO and is active in the agriculture
and food sector for improving safe and nutritious food intake of the people of Bangladesh.

Hunger Free World: Hunger Free World is a non-profit organization working in Bangladesh since
2001 that promotes right-to-food and organic farming.

UBINIG is a policy and action research organization in Bangladesh, formed in 1984 by a group of
activists to support peoples' movement for social, economic, political, and cultural transformation.

Bangladesh Food Safety Network (BFSN): The CAB and FAO’s Food Safety Project formed the
Bangladesh Food Safety Network (BFSN) in 2011. The organizations are working primarily on food
safety issues in the areas of consumer education, monitoring and food product testing, advocacy,
research, and grassroots mobilization.

The agencies involved from the health sector are presented in Figure 6 and are explained in further
detail in Chapter 5. These stakeholders range from the local to national level. Beyond health

27
providers and researchers, it is also important to involve educators and local government to improve
public awareness and ensure the necessary health services are provided.

28
Figure 4: Stakeholder map of industrial sources of lead exposure.

29
Figure 5: Map of stakeholders related to lead exposures from consumer products.

30
Figure 6: Map of health sector stakeholders relevant to lead exposure and response.

31
4. Prior and Ongoing National and Subnational Programs
Relevant to Lead Exposures and Health Impacts
In addition to Pure Earth’s collaboration around the Toxic Sites Identification Program described
previously (see Chapter 2), Pure Earth and UNICEF are currently members of a
multi-disciplinary working group consisting of organizations active on the issue of lead in
Bangladesh. The members include:

● United Nations Environment Programme (UNEP)

● Department of Geology, University of Dhaka
● Environment and Social Development Organization (ESDO)
● International Centre for Diarrhoeal Disease Research, Bangladesh (icddr,b)
● Stanford University
● International Lead Association (ILA)

This working group has quarterly calls to share updates and findings, as well as coordinate on
upcoming activities. The group aims to evolve into a more formal and public-facing coalition.

Each of these members have ongoing lead-related work in Bangladesh. For example, icddr,b
and Stanford University have a long-term collaboration to research sources of lead exposure in
Bangladesh. icddr,b is in the process of developing an intervention to reduce lead exposure
among pregnant and lactating women in Bangladesh, and has active programs on turmeric and
used lead acid battery (ULAB) recycling. In addition, icddr,b has formulated a training strategy
fostering collaboration with key partners including universities and donors with the aim to deliver
quality and need-based education and training services. ESDO has undertaken a project in
collaboration with UNEP and Pure Earth titled “The Environmentally Sound Management (ESM)
of Used Lead Acid Batteries (ULAB) in Bangladesh” which resulted in a national strategy on the
ESM of ULAB in Bangladesh. ESDO has also done research on lead in cookware and paint.

Although there is currently no known coordinated lead program within the government, certain
agencies have undertaken lead-related activities and appear to be devoting more attention to
the issue of lead exposure. Until recently, there was no designated office within the Department
of Environment to address chemical pollution specifically. However, in 2020 a Waste and
Chemical Management branch was formed. Furthermore, the Ministry of Commerce has been
active on the issue of turmeric adulteration. They have convened committees to control import
of lead chromate and its use in the country, and have suggested imposing a complete ban on
imports of lead chromate until proper testing protocol is completed by the appropriate authorities
(The Financial Express, 2019).

32
5. Health Systems
The health systems of Bangladesh are organized in several layers from community health
systems to specialized hospitals. Community health is the primary healthcare delivery platform
at the grassroots level including routine immunization, preventive and curative care, and family
planning services. Community Clinics, Union Sub-centers, Union Health, and Family Welfare
Centers are stationary facilities in the community, while Upazila Health Complexes (UHC)
provide the primary referral care. At district and divisional levels, 250-bed general hospitals and
medical college hospitals function as secondary and tertiary referral units, respectively. There
are also specialized hospitals in megacities such as the Institute of Child and Mother Health
(ICMH) and Dhaka Shisu Hospital.

Administratively, the health systems of Bangladesh have multiple streams. Ministry of Health
and Family Welfare (MOHFW) oversees health service delivery and health education. Health
Services Division of MOHFW provides health services through the Directorate General of Health
Services (DGHS), Directorate General of Family Planning (DGFP) and Directorate General of
Nursing and Midwifery (DGNM). The DGHS provides most of the health services via operational
plans (OP), such as Maternal Newborn Child and Adolescent Health (MNCAH), Non-
Communicable Diseases Control (NCDC), Community-Based Health Care (CBHC), Hospital
Services Management (HSM) and Planning Monitoring and Research (PMR). The DGFP is
responsible for family planning and reproductive & sexual health related services through the
Maternal Child Reproductive and Adolescent Health (MCRAH) Operation plan. The City
Corporations and Municipalities are responsible for providing primary health, public health, and
nutrition services in urban areas. The Ministry of Health and Family Welfare (MOHFW),
however, is the designated ministry for all matters related to health and nutrition, and for
ensuring and/or arranging health and nutrition services for the entire country, including urban
and rural.

a. Service Provider Awareness

There are about 140,000 sanctioned posts under the Ministry of Health and Family Welfare
(MOHFW) and its agencies, of which 56% belong to the Directorate General of Health Services,
29% to the Directorate General of Family Planning and 13% to the Directorate of Nursing.
Although a substantial number of employees were recruited during implementation of the
Health, Population and Nutrition Sector Development Program, there is still a shortage of
human resources. Moreover, it is a challenge for the MOHFW to retain the health workforce,
especially physicians and nurses, in remote and hard-to-reach areas. There is a need to
undertake capacity and preparedness assessment of health-care facilities and health
professionals to identify the strengths, weaknesses, and gaps in responding to the rising threats
of emerging infectious diseases and non-communicable diseases in the context of lead
poisoning and environmental health risks.

33
Health professionals in the public-sector lack adequate knowledge on the adverse impacts of
lead poisoning on human health. Environmental health impacts a wide range of program areas,
including communicable diseases, maternal and child health, and nutrition. Although the
Directorate General of Health Services (DGHS) is responsible for addressing environment-
related health problems, they lack the technical capacity and institutional mechanisms to
mitigate the impact of environmental pollution in all health programs. They often remain
uninformed of environmental pollution and related health risks, and thus lead poisoning remains
unaddressed in the health sector program. There are neither routine datasets available in
Health Management Information Systems (HMIS) on blood lead levels (BLLs) nor lead
poisoning-related data among children. Hence, awareness of lead poisoning is still low among
the health workers. This presents the challenge of how to improve the data availability for
evidence-based decision making. This situation can be improved through sentinel surveillance
of BLLs or syndromic data on lead poisoning; thereby capturing wider environmental health
issues and establishing a HMIS database.

b. Available Services and Capacities

Childhood lead poisoning is preventable and therefore providing a healthy environment for
children should be the key strategy. Primary prevention (i.e., the elimination of exposure to lead
at its source) would be the single most effective intervention against childhood lead poisoning.
This would entail better management of lead in local industries to prevent exposure and the
elimination of lead in consumer goods. Creating public awareness can promote preventive and
educational measures to protect young children from lead exposure in their environment. The
health systems can be strengthened by establishing a database for blood lead levels (BLLs) and
lead poisoning-related symptoms for children and raising awareness about the issue among
health workers and beneficiaries in communities and schools. Health workers could further be
trained on the early detection and management of lead poisoning cases.

In addition, the country’s public health system should consider conducting a cost-effectiveness
analysis and implementation of educational and nutritional support for children with high risks of
lead exposures, as well as instituting therapeutic management using chelating agents
(something not yet in place). Identifying and eliminating the source of exposure is also highly
critical for management of children with lead poisoning.

i. Prevention

Childhood lead poisoning can have long-term, irreversible consequences. Therefore, effective
prevention strategies are required to ensure every child reaches their potential for development.
The health sector, however, currently focuses on survival programs (Maternal Newborn Child
and Adolescent Health, Communicable Diseases Control, HIV/TB, Non-Communicable
Diseases Control, National Nutrition Services, and alternative medical care) and does not have
adequate funding, infrastructure, human resource capacity, logistics, and services required to
fully address the impact of environmental pollution on human health. The Ministry of Health and
Family Welfare (MOHFW) should play a pragmatic role by developing programmatic activities

34
that build resilient health systems to address lead poisoning. Such activities include awareness
building among health workers and the public and conducting campaigns on preventive actions
against lead exposure. Therefore, it is necessary to build capacity of the Directorate General of
Health Services (DGHS) and the Climate Change and Health Promotion Unit (CCHPU) of
MOHFW, as well as mainstreaming environmental health activities and monitoring indicators on
operational plans (OPs) of the DGHS and the Directorate General of Family Planning. At the
sub-national level, health services (human resources, logistics, and warning system) and health
facility infrastructure needs to be strengthened to manage environmental health issues.

Gaps exist in the current disease surveillance system with regard to linking the impact of
environmental risks and lead poisoning to health outcomes. Insufficient epidemiological data
and limited monitoring of environment-sensitive diseases impedes the health system to provide
early warnings, forecasts, and adequate responses to environmental hazards. Overall, there is
no mechanism in place to measure the quality of data, including collection methods, thus
leaving the health information system weak. Environmental health-sensitive data needs to be
integrated within the mainstream health management information systems (HMIS).

ii. Monitoring

Bangladesh has a real-time health information system starting from the community clinic to
tertiary level health facilities. UNICEF supports health system strengthening (HSS) through
building the capacity of human resources in areas of technical skills, leadership, and information
management of evidence-based planning and decision making. UNICEF strongly promotes
capacity development for health managers, particularly in web-based HMIS across the country.
With the strong leadership of DGHS, Bangladesh has successfully implemented HMIS
programs with District Health Information Systems 2 (DHIS2) platform as the database. In the
health sector, over 90% health facilities in all 64 districts have been regularly reporting health
data. With its high versatility, DHIS2 can accommodate newly emerging needs for monitoring
including environmental health and lead poisoning.

However, its high capacity for real-time monitoring and tracking of health data is limited with the
capacity of the users of the data, i.e., the quality of data is compromised when the data is not
actually reviewed and used by the health authorities including health managers and service
providers. Therefore, to develop a comprehensive HMIS that is transparent and accessible to
the public, it would be necessary to prioritize building the capacity of the health sector to
implement programs on lead poisoning. Such a database should allow stakeholders to review
environmental health status in the country, source and mapping of pollution including
contaminated site data, and other information that would increase public awareness and
accountability.

iii. Diagnostics, Care, and Treatment

Lead can be measured in a range of human tissues and fluids, including hair, teeth, bone, blood
and urine; however, measuring the concentration of lead in whole blood is the most accepted

35
tool for screening, diagnostic, and management purposes (WHO, 2011). For screening
purposes, point-of-care testing for lead involves the use of a portable analytical device that can
be taken and used near the site of exposure or patient care. Subclinical and clinical effects with
blood lead concentrations are non-specific and develop gradually over time, including damages
to the neurological systems. Provided with adequate diagnostic tools and necessary skills for
identifying suspected cases, clinicians and community health workers can identify children with
lead poisoning and thereby initiate necessary interventions.

In Bangladesh, however, health-care facilities lack capacity to diagnose lead poisoning and
provide necessary care. Measurement of BLLs is unavailable in the current Bangladesh health
systems, and health workers’ capacity to diagnose lead poisoning among suspected cases is
largely missing. Health staff do not have access to treatment guidelines and are not skilled in
treatment of environmental health-related diseases including lead poisoning. Community
members, especially vulnerable populations among lower income groups, women and children,
often do not have the resources to access health care.

c. Ministry of Health Institutional Capacity

Under the Ministry of Health and Family Welfare (MOHFW), the Directorate General of Health
Services (DGHS) is the responsible organization for the implementation of health programs,
management, planning, and execution of various policies. It can encourage the development
and implementation of strategies to identify and protect populations at risk, such as developing
guidelines for environmental health. Among the many responsibilities, it also ensures timely
detection and effective response to potential chemical risks and/or events in collaboration with
other sectors responsible for chemical safety, industries, transportation, and safe disposal. The
non-communicable diseases control (NCDC) program of DGHS is the directorate responsible
for control of chronic diseases including cardiovascular diseases and diabetes, injury and
disabilities as well as environmental health and poisoning by toxicants. However, the NCDC
does not yet have the capacity to address environmental health and lead poisoning, and the
mainstreaming of such programs has not yet been initiated.

The Institute of Epidemiology, Disease Control and Research (IEDCR) under the Ministry of
Health is responsible for epidemiological research and disease surveillance in Bangladesh.
IEDCR’s scope extends beyond communicable disease and they also specialize in surveillance
and research in various health issues including environmental health and pollution, though
these issues have not been prioritized due to emerging infectious diseases including COVID-19.
The National Institute of Preventive and Social Medicine (NIPSOM) conducts research on
environmental health, occupational health, child and maternal health, and other related
community health issues. It also has potential for developing educational courses on
environmental health and providing training for health workers. However, studies in these fields
are sporadic, and largely driven by temporary collaborations with international development
partners and by the research of students pursuing degrees in public health.

36
d. School Health Programs

The school health program is a collaboration between the Ministry of Health and Ministry of
Education. A few school health and nutrition interventions are in place, such as deworming
programs. The Human Papilloma Virus (HPV) vaccination program has been piloted in schools
and UNICEF is working with Ministry of Education and MOHFW on school health education
programs, both at primary and secondary education levels. The extent to which environmental
risks have been included is limited.

Adolescent health (AH) is one of the major agenda items for the Government of Bangladesh.
The AH program has been incorporated into the Adolescent and School Health Program of the
Directorate General of Health Services (DGHS) in Health Population Nutrition Sector Program
2017-2022. Directorate General of Family Planning (DGFP) has been implementing the
Adolescent Friendly Health Services (AFHS) at the district level, and the Union Health and
Family Welfare Centre (UH&FWC) at the union level. DGHS has been implementing AFHS at
school health clinics at the district level, district hospitals, and Upazilla Health Complexes
(UHC).

The inclusion of environmental health and lead poisoning in the mainstream School Health
Program will be efficient for reaching out to children in need. Awareness building activities
around dangers of consumer products including turmeric, paint, and other local lead exposure
sources generated locally can be easily conducted through school health programs. Capacity
building of service providers in school health programs will be necessary for providing adequate
services for prevention and management of lead poisoning among children in school. It is
necessary to facilitate multi-sectoral coordination among health, education, and communication
sectors for increasing awareness and capacity building on lead poisoning.

e. Local Government Capacity and Engagement

The Ministry of Local Government and Rural Development & Cooperatives (MOLGRD&C) and
local government institutes (LGIs) in Bangladesh are placed in a unique position for lead
poisoning related programs. LGIs (municipalities and city corporations) are responsible for
providing primary healthcare services in urban areas. Therefore, they can potentially be
engaged in the control of environmental pollution and the provision of environmental health
services at the same time. However, the capacity of LGIs and MOLGRD&C is still weak for
addressing environmental hazard and lead pollution, let alone providing environmental health
services.

Urban areas in Bangladesh are administered by the Ministry of Local Government, Rural
Development and Cooperatives (MOLGRD&C). At the ministry level, the Local Government
Division, within the MOLGRD&C, is responsible for developing overarching policies and
regulations, and monitoring and evaluation for these sectors. At local institute levels,
municipalities and city corporations are responsible for the implementation of programs and
administration of social services and have the environmental mandates. These entities are

37
responsible for handling and disposal of solid waste, as well as the maintenance of water supply
and sanitation systems (World Bank, 2006). The Department of Public Health Engineering
supports local governments with technical capacity, plans and constructs the health facilities
including water, sanitation, and hygiene (WASH) services.

Urban healthcare in Bangladesh falls under the responsibility of two main government
ministries—Ministry of Health and Family Welfare (MOHFW) and Ministry of Local Government,
Rural Development and Cooperatives (MOLGRD&C). MOHFW is the designated ministry for all
matters related to health, and for ensuring and/or arranging health services for the entire
country, urban, and rural. In rural areas, the Health Services Division of MOHFW provides
health services through DGHS and DGFP from community health to primary, secondary and
tertiary referral hospitals, which forms the backbone of public healthcare delivery systems of
Bangladesh. MOHFW, in addition to being responsible for national health and family planning
standards, strategy and policy development and regulation, is also responsible for secondary
and tertiary health care provision through the public hospitals and other facilities in urban areas.
The Local Government Division (LGD) within MOLGRD&C is responsible for providing primary
health and public health services in urban areas. The Local Government/City Corporation Act of
2009 and the Paurashava Act of 2009 mandate LGD deliver and maintain all social services,
including education and basic health care in urban areas.

Although the responsibility for urban health service delivery is shared by MOHFW and
MOLGRD&C, the lack of meaningful coordination between these ministries significantly
constrains the provision of urban health care services, resulting in fragmented governance
arrangements and inadequate coverage for the urban poor. Even though MOLGRD&C, through
its LGD, is expected to provide financial and human resources to help Local Government
Institutions (LGIs) for health services, inadequate participation of LGIs in the planning process,
unearmarked funding for health services, and lack of clear monitoring and accountability
structures for the use of these funds result in the inconsistent implementation by LGIs of the
provisions of the acts. Inadequate capacity of LGIs and the conflicting responsibilities with the
relevant sector ministries, coupled with the parallel delivery of health services (e.g. primary
health care) by non-governmental organizations (NGOs) and the private sector, has led to
inefficient planning and poor resource management in urban areas. There are gaps in clear
strategies and coordination amongst the line ministries—Ministry of Health and Family Welfare
(MOHFW), Ministry of Environment, and the Ministry of Local Government, Rural Development
and Cooperatives (MOLGRD&C), and Local Government Institutions—for establishing a strong
primary healthcare delivery model.

There are wide health disparities within urban populations, including in maternal and newborn
health, and gaps remain, most notably in terms of outcomes and health service utilization of
poor people. Urban primary health care services are fragmented and have been operating in a
time-bound project mode for over twenty years. Piecemeal, fragmented, and donor-dependent
primary health care services for urban Bangladeshis has compelled the population to seek
health services from the private sector, thereby causing a high proportion of out-of-pocket
expenses (67%) out of the total health expenditures in Bangladesh (BNHA 1997-2015).

38
Lead poisoning and environmental health have not yet been mainstreamed in the urban health
systems. As the government of Bangladesh, with support from UNICEF and development
partners, is preparing to develop a sustainable model of primary health care (PHC) systems in
the upcoming UNICEF Bangladesh Country Program Documents 2022-2026, there are
opportunities to link the PHC delivery model with lead poisoning and environmental health.

f. Role of Non-Governmental Actors

Bangladesh has relied on a pluralistic health system—with government, private and non-
government (NGO) providers—to procure community and facility-based health services to its
population. Both the pluralistic approach to health and Community Health Workers (CHWs)
programming have been deemed as success factors in improving the country’s health.
Currently, Bangladesh has over 185,000 CHWs with diverse scopes of work and profiles
delivering health services across the country. About 70,000 CHWs work for the government,
50,000 work for the Bangladesh Rural Advancement Committee (BRAC), and the remainder
work for other NGOs and the private sector.

However, the bifurcated nature within the Ministry of Health and Family Welfare (MOHFW)
between the Health and Family Planning divisions has persisted for decades and is deeply
institutionalized within the health system structure. The Directorate General of Health Services
and Directorate General of Family Planning each manage their own health facilities and staff,
and maintain their own supervision, training, referral mechanisms, and health information
systems. At the community level, insufficient coordination and integration of activities negatively
impact the effective provision of services. Frontline health workers (Community Health Care
Providers, Family Welfare Assistants, and Health Assistants) have roles that are sometimes
complementary, others overlapping, and they are often lacking the appropriate forums and tools
for coordination. Job descriptions, training, and supervision systems are not aligned, posing
challenges for a harmonized and integrated service delivery. In addition to challenges with
government CHWs, the various NGO cadres have not, among themselves, coordinated the
delivery of health services.

In 2009, the MOHFW reprioritized the Community-Based Health Care (CBHC) program through
the project “Revitalization of the Community Health Care Initiative in Bangladesh” (RCHCIB),
2009-2016. The RCHIB initiative aimed to strengthen community and local government
engagement in the provision of health services through a public-private partnership with the
community. First, the government constructs the Community Clinic (CC) on community donated
land and covers the costs of service providers, medicines, and equipment. Then, Community
Groups (CG) and Community Support Groups (CSG) provide management and oversight
support to the CC, and mobilize local resources to support management of the CC.

Community Clinics perform better when there are well functioning CGs and CSGs. Active
participation of members of the Union Parishad (UP), the smallest rural administrative and local
government units, as chairs of CGs can facilitate good performance of CGs and a well-

39
functioning CG makes health workers more accountable. However, most CG and CSG do not
meet regularly, do not have workplans, and do not have mechanisms for periodic monitoring
and evaluation. Members do not always have clarity on their role and their ability to provide
management support to the CC is constrained by the availability of funds (e.g. payment of
cleaners, guards, electricity bills, repairs). UPs as the grassroot administrative unit of local
governments, are supposed to provide 15 per cent of their total budget to the implementation of
their health and family planning functions, including the overall monitoring and management of
the CC. However, UP members are usually unaware of their official roles and responsibilities
and do not participate in CG meetings. Union Health Education and Family Planning (UHE&FP)
Standing Committees are often inactive and do not allocate funds to CC management.

Once revitalized, the community health systems can be the key resource for mobilizing local
society and awareness building campaign. CGs and CSGs members can be trained for
environmental health and lead poisoning issues and actively participate in various activities
including prevention and mitigating risks of environmental pollution and lead poisoning. With
support from UNICEF, the Government of Bangladesh can build capacity of CG and CSG to
increase routine oversight, liaise with community members to share information and mobilize
local resources for improvements.

40
6. Lead Pollution/Source Management Capacities

a. Background and Context of Lead Management

A patchwork of laws and regulatory agencies are pertinent to lead pollution and lead exposures.
Because lead has been identified as a threat both industrial areas and consumer products,
agencies with seemingly very different missions are implicated.

b. Assessment of Chemicals Management Capacity

Chemicals management in Bangladesh has largely been addressed in a piecemeal fashion with
industry- or medium-specific policies (Syeda, 2020).

i. Relevant Agencies and Specific Mandates

Department of Environment (DoE)

This agency under the Ministry of Environment, Forest and Climate Change (MoEFCC) is
tasked with maintaining ambient environmental standards and regulating environmental aspects
and discharge standards of industries. Permitting authority for lead acid battery recycling and
operating any industrial activity using lead belongs to the DoE.

As laid out in the Environmental Conservation Act (1995), DoE is mandated to grant
environmental clearances; undertake inspections of industrial units; prevent activities likely to
cause environmental degradation; direct remedial measures for environmental harm; and
formulate environmental guidelines. However, DoE has significant staffing limitations. According
to the World Bank (2018), the agency has 735 approved positions. This translates to 220,000
citizens per employee, whereas this same figure is approximately 56,000 in the Philippines and
20,000 in Mexico. The shortage of staff is particularly evident at the divisional and district levels.
Divisional offices typically have 5-6 staff and district offices typically have only 3 staff. These
limitations are also evident in MoEFCC’s budget. According to the 2017 Country Investment
Plan for Bangladesh, the financing required to achieve the country’s stated objectives in
reducing industrial pollution is 651.6 million USD (MoEFCC, 2017); currently, only about 10% of
that funding is available.

Based on Pure Earth’s interactions over the past 10 years, the issues of chemical pollution and
contaminated soil have in particular been under-resourced. Encouragingly, DoE has recently
established a Waste and Chemical Management branch, under which lead pollution
management falls.

Bangladesh Food Safety Authority (BFSA)

The BFSA, under the Ministry of Food, is a facilitating agency which coordinates the activities of
the various agencies and organizations engaged in both policy formulation and implementation

41
decisions around food safety, food production, import, processing, stockpiling, supplying,
marketing and sales.

They support the entities/organizations directly involved in updating and upgrading the food
safety standards or guidelines; in determining permissible limits at its highest safe level for use
of contaminants and residue, additives or preservatives; in determining permissible limits of
radiation in food; in formulating and implementing accreditation policies; in formulating
procedural guidelines for accrediting food testing laboratories; and requesting the government to
increase the capacity of safe food controlling agencies and organizations.

Additional agencies involved in the food control system in Bangladesh include the Ministries of
Agriculture; Fisheries and Livestock; Commerce; Law and Legislative Affairs; Bangladesh
Standards and Testing Institution (BSTI); Directorate of National Consumer Rights Protection
(DNCRP); and local governments, among others.

Bangladesh Standard and Testing Institution (BSTI)

The institute works for standardization of services and products, introduction of the international
unit system of weights and measures, promotion of metrology services, promotion of quality
assurance activities, rendering testing facilities for services and products, and preparation,
promotion and adaptation of national standards. BSTI hosts and updates the Bangladesh
Standards (BDS) catalogue outlining product types and standards these must adhere to.
Currently, there are standards for turmeric and lead paint which have been found to have lead
levels above tolerable levels.

Ministry of Commerce and Ministry of Industry

Both the Ministry of Commerce and the Ministry of Industry are crucial in efforts to tackle lead
pollution caused by used lead acid batteries given their role in amending/adding regulations and
implementation of policies applicable to both domestic and foreign trade. Furthermore, the
Directorate of National Consumer Rights Protection (DNCRP) sits under the Ministry of
Commerce. The DNCRP was founded in 2009 through the Consumer Rights Protection Act,
2009. Anyone can file a complaint against anti-consumer activities that includes adulteration of
food items. The DNCRP has officers in 48 districts of which 16 districts are covered by giving
additional responsibilities to different officers, instead of them working exclusively for the
directorate.

The Ministry of Commerce has also been active on the issue of turmeric adulteration. They have
convened committees to control import of lead chromate and its use in the country, and have
suggested imposing a complete ban on lead chromate imports until proper testing protocols are
established by the appropriate authorities (The Financial Express, 2019).

ii. Inter-Ministerial and Department Coordination

According to UNICEF, the Directorate General of Health Services, under the Ministry of Health
and Family Welfare, has recently established a committee specific to implement the “Protecting
Every Child’s Potential” (PECP) initiative, as detailed below. Planning, Monitoring, and

42
Research (PMR) will lead this committee and other relevant directorates will be invited to
participate, such as Institute of Epidemiology, Disease Control and Research (IEDCR). The
recommendation will be made to PMR to include DoE on this committee as well.

Multiple authorities have also engaged on the issue of spice adulteration. Bangladesh Food
Safety Authority’s (BFSA) mission statement highlights its role as a coordinating body across
different government bodies. This was demonstrated in the response to the data released in
2019 by Stanford and International Centre for Diarrhoeal Disease Research, Bangladesh
(icddr,b) on the extent of this issue. BFSA took a lead role in formulating the response, but the
Ministry of Commerce also became involved. They convened committees with the aim of
controlling the import of lead chromate and its use in the country.

iii. Laboratories and Environmental Quality Monitoring

Laboratory facilities for elemental analysis such as lead vary for products and environmental
mediums. The Department of Environment has laboratories in six divisional offices engaged in
environmental monitoring of water and air quality. Laboratories are not available near industrial
clusters of Gazipur, Narayanganj, and Narsingdi which complicates enforcement of discharge or
ambient standards.

Analytical capability is limited in the Department of Agricultural Extension (DAE) laboratories to

test all of the pesticides marketed in Bangladesh. This has affected checking for heavy metals
such as lead, cadmium, and persistent organic pollutants (POPs) impurities with low
concentration in active ingredients. In 2007, it was reported that none of the existing laboratories
in Bangladesh had yet to achieve Tier 1 capacity recommended by UNEP guidance for global
monitoring for any of the POPs (DoE, 2007).

BSTI operates laboratories for cosmetics and food products. Cosmetics products are tested in
specialized labs under the Chemistry division, while there is a dedicated spice and condiments
laboratory under the Food and Bacteriological division. Table 1 lists testing details of product of
interest for this report.

Product Normal Testing Fee (normal) Urgent Testing Fee (urgent)

Time (days) Tk. Time (days) Tk.

Turmeric powder 14 2099 8 4198

Paint 14 5625 – 6875 8 11250-13750

Unleaded motor 14 3423 8 6845

gasoline (petrol)
Table 1: Testing details of products in BSTI Laboratories.

Although the role of Bangladesh Council of Scientific and Industrial Research (BCSIR) is to
engage in basic and applied research in multiple disciplines, their laboratories in three divisions
(Dhaka, Chattogram, and Rajshahi) can conduct elemental analysis of both consumer products

43
and environmental samples. Table 2 below shows lead-related analysis BCSIR laboratories are
equipped to deliver.

Name of Sample Test Methodology Fee (Tk.) Duration

Parameter (days)

Water (surface/river Lead (Pb) APHA/In House 2000 7

water/sea
/ground)
- only in Dhaka Lab

Air (lead in air) (to be Lead in air NIOSH 7082 5000 10

done manually)

Cream (cosmetic) - Lead (Pb) In House 2000 7

only in Dhaka Lab

Fertilizer - only in Dhaka Lead (Pb) In House 2000 10

Lab

Heavy metal and metals Lead (Pb) In House 2000 10

in all types of samples
(except pure metal) -
Dhaka Lab

Henna, food, drug & Heavy In House 2000 7

cosmetic grade dyes & metals
pigments (lead)

Paint-varnish, lacquer, Heavy In House 2000 7

resin and adhesive metals
products (lead)

Plastic/rubber/paper Heavy In House 2000

products (plastic bottles metals
for drinking water, oil, (lead)
soft drinks, fruit juices,
drug solutions &
suspensions, plastic
tableware, baby toys &
feeders, food packaging
paper etc.)

44
 Sediment and riverbed Lead SSSA 2000 10
sediment

Sludge Lead SSSA 2000 10

Soil – only in Dhaka lab Lead SSSA 21-4 2000 10

Textile fabric/fiber/ Heavy In House 2000 7

yarn/RMG/jute goods metals
(lead)

Wastewater/effluent – Lead APAH/In House 2000 7

only in Dhaka Lab

Table 2: Testing details of lead in BCSIR Laboratories. Soil Science Society of America (SSSA); National
Institute for Occupational Safety and Health (NIOSH), American Public Health Association (APHA).

Mohiuddin (2019) lists other laboratories also involved in food safety analysis:

● Public Health Laboratory (IPH)

● SGS Bangladesh (private internationally recognized laboratory)
● Bangladesh Atomic Energy Commission (autonomous-government organization)
● Food Testing Laboratory (Ministry of Food and Disaster Management)
● Food Testing Laboratory (Dhaka City Corporation)
● Institute of Food Radiation Biology, Bangladesh Atomic Energy Commission
● Institute of Food Science Technology, BCSIR
● Institute of Nutrition and Food Science, University of Dhaka

iv. Information Management Systems and Databases

As Pure Earth is now connected with the Waste and Chemicals Branch, Pure Earth will be
seeking a clearer understanding of existing data management practices. At this point, Pure
Earth is not aware of any inventory of lead-contaminated sites in Bangladesh beyond the Toxic
Sites Identification Program database. Pure Earth seeks to understand what systems DoE
currently has for tracking environmental compliance and enforcement actions within the formal
sector.

Similarly, Pure Earth will be seeking further information on how BFSA tracks compliance among
turmeric producers regarding adulteration, and if the DNCRP holds such information regarding
consumer products.

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c. Legal Framework

i. Policy-making Process

The policy making process in Bangladesh is an overall outcome of incentives created by

patronage politics. Factors strongly affecting the public policy formulation and implementation
process include assistance, pressure, and persuasion from international development partners,
and the capacity to mobilize and manage resources. The most critical determinant of policy
formulation and implementation in Bangladesh is political commitment (Shakil and Noman,
2016).

Despite Bangladesh’s declining dependency on foreign aid, external stakeholders still influence
the country’s internal policy making process. The eventual impact on the quality of governance
depends on the strategic interplay among all actors including politicians, bureaucrats, private
sectors, and NGOs. The Planning Commission is another central planning body of Bangladesh.
It includes professionals and sector specialists engaged in formulating the government’s macro-
and micro-economic plans and policies (Shakil and Noman, 2016).

ii. Existing Legislation

1. National Regulation

Environmental Conservation Rules 1997 (ECR)

The Environmental Conservation Rules 1997 (ECR) Schedule-3 (B) sets the standard for lead in
drinking water at 50 ppb. This standard is now more than twenty years old, and an amendment
to the ECR is currently under consideration. It would lower the standard for lead to the WHO
guideline value of 10 ppb.

Currently, there are standards for wastewater emissions from specific sectors (ECR Schedule-
12) and a set of catch-all standards for industrial units which do not fall within those sectors and
which depend on where the effluent is being discharged (ECR Schedule-10). The standard for
lead under Schedule-10 is 100 parts per billion (ppb). These standards apply to the effluent
itself, not the receiving water body where dilution would occur, and thus allow a comparatively
high concentration. Changes to the sector-wise and catch-all standards are under consideration
in the upcoming amendment.

There is no standard for the maximum allowable concentration of lead in soil that was identified
for Bangladesh.

Statutory Regulatory Order (SRO) No. 175-Act/2006

This regulatory order laid out instructions on collection and recycling of used/non-functional
batteries for controlling and preventing environmental pollution. According to this SRO, no
battery recycling will be permitted without environmental clearance from DoE. Restrictions were
imposed on improper disposal of used batteries or any parts of used batteries in open space,

46
water bodies, waste bins, etc. All cast-off batteries must be sent to the DoE-approved battery
recycling industry at the earliest convenience and no financial transaction is allowed for
used/non-functional batteries. This SRO was later amended in 2008 (SRO No. 29-Act/2008
dated February 11, 2008) to allow financial transactions on mutually agreed fixed cost (IDCOL,
2018). In 2018, another amendment to this SRO was proposed and stakeholder meetings were
organized jointly by the DoE and Accumulator Battery Manufacturers and Exporters Association
of Bangladesh (ABMEAB), which was adopted in February, 2021.

The SRO is applicable only to formal facilities and does not present any strategy to address the
widespread informal battery recycling and manufacturing, despite the prevalence of these
operations and the high level of contamination they leave behind, as documented in Pure
Earth’s Toxic Sites Identification Program (TSIP) database.

Hazardous Waste and Ship-Breaking Waste Management Rules 2011

This law implemented by DoE applies to battery recyclers binding them to submit information
periodically about the volume of recycled products, recycling processes, and environmental
impacts. The rules also direct the parties (transport included) to follow environmentally sound
processes—failure of which can result in penalties according to Section 15 of the Environment
Conservation Act 1995, which is the umbrella Act for environmental matters. This law also lays
out a classification system for hazardous waste. A substance is considered hazardous if it
contains one of 684 chemicals above a specified concentration. The concentration for lead and
lead compounds is 5000 ppm. There is very little information regarding how industries and the
Government use or enforce these standards in practice, as Bangladesh does not have a
hazardous waste landfill where hazardous materials could be safely disposed (World Bank,
2018).

Consumer Rights Protection Act 2009

The Act identified sale of any goods containing any ingredient that is injurious to human health
and the mixing of such ingredients with any food item an anti-consumer rights practice. Section
42 of the Act mentions that any person mixing any ingredient with foodstuff which is injurious to
human life or health and the mixing of which with foodstuff is prohibited by any act or rules, shall
be punished with imprisonment for a term not exceeding 3 (three) years, or with fine not
exceeding taka 2 (two) lacs, or both. However, it is not clear if this Act can be used to effectively
control spice adulteration since Section 60 of the Act limits acceptance of a complaint if not
made within 30 days of any anti-consumer rights practice. Furthermore, Section 71(1) states
that a consumer cannot file a case directly before the court of the magistrate as under this law
permission needs to be obtained from the Director General of DNCRP (Chandan, 2017).

Safe Food Act 2013

This Act replaced the earlier patchwork of pure food ordinances that was first enacted in 1959
and amended in the following decades. This Act came into force on 1st February 2015 and
created BFSA as the implementing agency. Section 24 of the Act restricts “use or inclusion in
any article of food or food ingredient any radioactive or irradiated matter or naturally of
otherwise occurring similar matter or heavy metal in violation of maximum acceptable limit

47
prescribed by regulations or by any other law for the time being in force.” First time violation of
section 24 can result in imprisonment for 3 to 4 years or a fine not less than four lakh taka and
maximum eight lakh taka. Repeat offenders can be penalized with imprisonment for four years
or a fine of sixteen lakh taka, or both.

Food Safety (Contaminants, Toxins and Harmful Residues) Regulations, 2017

This technical standard provides maximum tolerable limits for food additives. Schedule 1 lists
food categories and maximum tolerable limits for heavy metals including lead. Interestingly,
turmeric or spice as a broader category is not listed in Schedule 1.

Pesticides Act, 2018

This Act is the latest version that adds to the series of ordinances and previous legislations on
this issue. It only covers the registration process and licensing for selling or manufacturing
pesticides, but there is no mention of pollution or environment protection issues (Arifuzzaman,
2019). Pesticides are not routinely tested for lead.

Product Standards Enacted by BSTI

The following product standards enacted by the BSTI relates to the major sources of lead
exposure in Bangladesh (BSTI, 2018).
Paint: BDS 106:1960, BDS 107:1960, BDS 110:1960, BDS 1215:1989
Most recent standards limit lead content at maximum 90 ppm
(Hossain, 2018).

Lead Acid Batteries: BDS 206, BDS 479. BSTI recently announced development of
standards for lead acid batteries used in solar home systems
(Parvez, 2020).

Gasoline: BDS 346:2010, BDS 347:2010, BDS 1320:1991

Turmeric: BDS 991:2001, BDS 992:2015
It sets 2.5 ppm as the maximum allowable level of lead in turmeric.
Utensils: BDS 1108:1984, BDS 1109:1984

2. International Conventions

Bangladesh has signed and ratified the Basel Convention on the Control of Transboundary
Movements of Hazardous Wastes. To address hazardous wastes under the Basel Convention,
Bangladesh has done the following (Abdullah. M.M., 2007):
● Defined hazardous waste under the Bangladesh Environment Conservation Act,
1997.
● Banned import of all sorts of waste in the Import Policy Order.
● Prepared the “Regulatory Framework on Import of Hazardous and Toxic Materials”
through a project funded by the Asian Development Bank.
● Organized training programs on “Toxic Chemicals and Hazardous Waste” and “Risk
Assessment and Management.”

48
 ● Drafted a position paper on use of toxic chemicals and disposal of toxic and
hazardous wastes in Bangladesh.
● Drafted a National Chemical Profile.

As of 2020, Bangladesh participates in the Strategic Approach to International Chemicals

Management (SAICM) (Syeda 2020). Although Bangladesh is a member of the International
Labor Organization (ILO) and has ratified a number of its conventions, the country a of 2020 has
not signed the Chemicals Convention 1990 (No. 170) providing the basis for the sound
management of all types of chemicals at the workplace and Prevention of Major Industrial
Accidents Convention, 1993 (Syeda 2020).

d. Role of NGOs

Non-governmental organizations engage on the issue of lead through various lenses in

Bangladesh. For advocacy and activation specifically around lead, the Environment and Social
Development Organization (ESDO) has played a vital role for over a decade. To address the
issue of lead paint, ESDO tested paint samples, drafted guidelines, and organized meetings
with DoE and BSTI. ESDO has also conducted research on aluminum cookware and is currently
partnered with Pure Earth and UNEP to generate national policy recommendations around used
lead acid batteries.

For policy advocacy and activism on environmental issues in general, prominent groups include
Bangladesh Poribesh Andolon (BAPA), and Bangladesh Environment Network (BEN), and
perhaps most prominently, the Bangladesh Environmental Lawyers Association (BELA). Their
legislative advocacy has culminated in several constitutional and legal amendments (Khan,
2017). Their legal action against owners of shipbreaking yards and government agencies were
instrumental in bringing changes to the regulatory framework concerning shipbreaking.

For consumer products, advocacy groups such as Consumers Association of Bangladesh

(CAB) are vocal on issues related to food and product safety. CAB and FAO’s Food Safety
Project formed the Bangladesh Food Safety Network (BFSN) in 2011. Along with CAB, four
other NGOs—B-SAFE, Shishuk, Hunger Free World, and UBINIG—make up the food safety
network. Their activities in dealing with lead-contaminated turmeric are not publicly available.
These organizations are working primarily on food safety issues in the areas of consumer
education, monitoring and food product testing, advocacy, research and grassroots
mobilization.

The Accumulator Battery Manufacturers and Exporters Association of Bangladesh (ABMEAB)

represents the formal battery sector and is an important partner in addressing ULAB recycling.
They have provided input to the DoE and have expressed an interest in collaborating with Pure
Earth on future initiatives.

49
e. Involvement of Academia and Research Institutes

The following academic institutions support research and/or training related to environmental
health, pollution and toxic site identification.

Since 2011, the Department of Geology at the University of Dhaka in collaboration with Pure
Earth has implemented the Toxic Sites Identification Program (TSIP), which aims to identify and
screen contaminated sites and assess public health risks. Prior to initiating TSIP site
assessments, all investigators are trained in the assessment methodology and the TSIP
database, as well as principles of environmental health and exposure science. A field visit is
made by the group to demonstrate the methodology. A range of representatives have
participated in these trainings since the inception of the TSIP program in Bangladesh, including
staff from the Department of Environment and ESDO. Under the TSIP program, investigators
identified and assessed the Kathgora site in Savar district of Dhaka that is among the 288
informal battery recycling sites in Bangladesh.

In terms of academic training at the University of Dhaka, the B.S (Honors) in Geology included
relevant courses aimed at building country capacity on environmental health. These comprised:
environmental chemistry (introduction to solid waste pollution, toxic metal analyses),
geochemistry (toxic pollutants and their impact on environmental health and ecology) and
environmental geology (human interaction with the environment, including pollution, waste
disposal, and environmental laws).

The International Centre for Diarrhoeal Disease Research, Bangladesh (icddr,b) and Stanford
University, in the United States, have a long-term collaboration to research sources of lead
exposure in Bangladesh. Forsyth et al. (2018) conducted a case control study to evaluate the
prevalence of elevated blood lead levels among pregnant women in rural Bangladesh and to
identify sources of lead exposure. Raihan et al. (2018) conducted a cross sectional study of
children under 2 years of age in Bangladesh slum to examine the relationship between blood
lead level and stunting, wasting, and underweight. The icddr,b is in the process of developing an
intervention to reduce lead exposure among pregnant and lactating women in Bangladesh, and
has active programs on turmeric and ULAB. In addition, icddr,b also formulated a training
strategy fostering collaboration with key partners including universities and donors with the aim
to deliver quality and need based education and training services. The flagship training courses
also include urbanization and environmental health.

The National Institute of Preventive and Social Medicine (NIPSOM) is a national public health
institute in Dhaka which offers graduate level public health training. The institute has also been
involved in lead-related research. In a collaboration between Dr. Arif Sikder of Virginia
Commonwealth University and NIPSOM, a toxicity assessment of ash and dust from handmade
gold jewelry manufacturing workshops in Bangladesh was conducted in 2017. SEM/EDS
analysis revealed high concentration of cadmium, chromium, and lead. Ahmad et al. (2014)
conducted a cross-sectional study among workers of lead acid batteries manufacturing located

50
in Dhaka to measure the blood lead concentration and to assess the magnitude of health
problems attributable to lead toxicity.

At North South University, a graduate program MS in Environmental Science and Management

has been established in collaboration with University of Manitoba, Canada. This program
focuses on environmental and natural resource governance and management capacity in
Bangladesh. The courses here include: resources and ecological economics; pollution control:
scientific, regulatory, fiscal and other instruments; causes and effects of water, air, soil and
noise pollution; air quality standards; gaseous and particulate matter pollution control
techniques; noise measurement and control; water quality standards; effluent treatment and
plant solid waste management, hazardous waste management and risk analysis; and case
studies of pollution control strategies and regulations from national to global contexts.

51
7. Information Gaps
Lead is a well-studied developmental and systemic neurotoxin. At lower levels of exposure, lead
can affect a child’s neurological development, resulting in permanently reduced intelligence
quotient (IQ), lower educational attainment, and reduced lifetime earnings (Nevin, 2000;
Schwartz, 1994). In adults, exposures to lead can result in heart disease, stroke, and kidney
disease. Through these negative health outcomes, lead exposures are responsible for an
annual loss of 690,000 years of healthy life across the population of Bangladesh (IHME 2019).

Despite the large public health toll related to lead exposures, public understanding of the
dangers of lead appears to be very low. There is a lack of information linking sources of lead in
the environment to the burden of lead exposure in the population. This makes priority setting
difficult. Beyond used lead acid batteries and turmeric, we also have limited information on the
supply chains and market forces governing lead-containing products.

Inventory of industrial sources

TSIP has characterized more than 300 lead sites and provided access to this data to DoE.
Beyond this, however, there is no known government-held database of contaminated sites,
which would support the identification of hotspots and allow for a more targeted response to
industrial sources.

Further research to quantify the lead content of pesticides

Pesticides are historically known to have been a major source of lead exposure. Despite their
widespread use across Bangladesh, there are still data gaps regarding their actual lead content.
Given the conflicting reports in the media in Bangladesh versus peer-reviewed literature, it is
important to conduct further research to know the lead content and the severity of its impact on
the community.

Limited monitoring by regulatory agencies

Food safety inspectors and other consumer rights groups may not be adequately equipped to
detect turmeric adulteration (Forsyth et al., 2019a). While color changing test strips do exist,
reliability of results is not guaranteed. Portable handheld XRF analyzers are better alternatives,
but these are expensive equipment. DoE also lacks an effective monitoring program for
measuring and compiling data on soil and/or water contaminated with lead.

Filling in of regulatory and enforcement data gap

There is a gap in the available regulatory data regarding complaints related to food adulteration
or lead poisoning. The data that is available is not in English which complicates easy access to
information. As part of consumer rights the government needs to make this information widely
available to the public.

Relative contribution of household/background sources

Most of our information on common lead exposures comes from research studies, rather than
systematic surveys at the national level. For instance, no data specific to Bangladesh were

52
found that quantified the prevalence of lead-containing kajal, sindoor, or amulets. Much of our
current understanding comes from testing of such products in South Asian communities in the
U.S. The current prevalence of lead-containing paint among households is also lacking.
Furthermore, there is a lack of information linking these household sources to the burden of lead
exposure in the population.

Dose estimates from food sources

While we did identify sporadic data on lead concentrations in certain types of food, further
quantification of how these levels translate into human health risk is necessary to prioritize
interventions. For example, while several categories of food (vegetables, milk, and meat for
example) were found to exceed standards, the severity of these exposures versus other
sources in Bangladesh, such as industrial sites, should be characterized.

Survey of small and medium enterprises (SMEs) engaged in polishing turmeric

Since use of polishing machines is related to color addition tendency in turmeric roots (Forsyth
et al., 2019a), further surveys on turmeric polishers can outlay the scope of interventions that
can be targeted for technology adoption.

In the health sector, there is also a substantial lack of data and reporting systems on the extent
of elevated blood lead levels. Major gaps are outlined below:

Lack of capacity for blood lead level testing as part of the health system
The availability of blood lead level (BLL) data is critical to understanding the scope of this issue
in Bangladesh, and to developing strategies that are responsive to specific needs, such as in
addressing regional differences or trends in the ages of children exhibiting high blood lead
levels. Blood lead level testing is needed to identify contributing sources and build evidence for
policy reforms. Access to BLL is also important to monitor and keep track of the impact of new
regulations.

Data availability for evidence-based decision making

The Non-Communicable Diseases Control (NCDC) program of the Directorate General of
Health Services (DGHS), which is responsible for addressing environment-related health
problems, lacks technical capacity and the institutional mechanisms to fully address the impact
of environmental pollution in all health programs. As a result, other health programs often
remain uninformed of environmental pollution and related health risks, and thus lead poisoning
remains unaddressed in health programs. There are no routine datasets available in Health
Management Information Systems (HMIS) on blood lead levels or lead poisoning among
children. As a result, awareness of lead poisoning is still low among the health workers.

Data for prevention

Insufficient epidemiological data and limited monitoring of environment-sensitive diseases also
impedes the health system to provide early warnings, forecasts, and adequate responses to
environmental hazards. Overall, there is no mechanism in place to measure the quality of data,

53
including collection methods, thus leaving the health information system weak. Environmental
health-sensitive data needs to be integrated within the mainstream HMIS.

Diagnostics, care and treatment

Health staff do not have access to lead poisoning treatment guidelines and are not skilled in
treatment of environmental health-related diseases. The health workers are also not provided
with adequate diagnostic tools and necessary skills for identifying suspected cases.

54
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Islam, M.S., Ahmed, M.K., Habibullah-Al-Mamun, M., Islam, K.N., Ibrahim, M. & Masunaga, S. (2014)
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Islam, Md. Saiful. (2018). Heavy metals in meat with health implications in Bangladesh. Journal of Food
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Jahiruddin, M. Y. Xie, A. Ozaki, MR Islam, TV Nguyen, and K. Kurosawa. (2017). Arsenic, cadmium, lead
and chromium concentrations in irrigated and rain-fed rice and their dietary intake implications. Australian
Journal of Crop Science. 11(07): 806-812.

Khan, B. F. (2017). Governance for Green Growth in Bangladesh: Policies, Institutions, and Political
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Kwong LH, Ercumen A, Pickering AJ, Unicomb L, Davis J, Leckie JO, Luby SP. (2019). Soil ingestion
among young children in rural Bangladesh. J Expo Sci Environ Epidemiol. 2019 Oct 31. doi:
10.1038/s41370-019-0177-7.

Lanphear, Bruce P., Richard Hornung, Jane Khoury, Kimberly Yolton, Peter Baghurst,
David C. Bellinger, Richard L. Canfield et al. "Low-Level Environmental Lead Exposure
and Children’s Intellectual Function: An International Pooled Analysis." (Environmental
health perspectives 113, no. 7, 2005): 894-899. DOI:10.1289/ehp.7688

Lanphear BP, Dietrich K, Auinger P, Cox C. “Cognitive Deficits Associated lead Concentrations <10
microg/dL in US Children and Adolescents. (Public Health
Rep. 2000);115(6):521-529. doi:10.1093/phr/115.6.521. DOI: 10.1093/phr/115.6.521
Lead Poisoning of a Child Associated with the Use of a Cambodian Amulet-New York City , 2009. Centre
for Disease Control and Prevention. 2011. 60(03)

MoEFCC. (2017). Bangladesh Country Investment Plan for Environment, Forestry and Climate Change
(2016-2021). Government of the People’s Republic of Bangladesh.

Mitra. A.K., Haque. A, Islam.M., Bashar S.A.M. 2009. Lead Poisoning: An Alarming Public Health
Problem in Bangladesh. Int. J. Environ Res Public Health. 6(1): 84-95.

Mohiuddin, A. (2019). The Mysterious Domination of Food Contaminants Adulterants in Bangladesh.

Journal of Environmental Science and Public Health, 3(1), 34-56.

Mohta A. (2010). Kajal (Kohl)-A dangerous cosmetic. Oman J. Opthalmol. 3(2): 100-101.

NYC Health. (2020). Hazardous Products: Cosmetics and Religious Powders.

https://www1.nyc.gov/site/doh/health/health-topics/hazardous-cosmetics-powders.page

NYC Health. (2019). South Asians and Lead Poisoning.

https://www1.nyc.gov/assets/doh/downloads/pdf/lead/lead-south-asian-brochure.pdf

NYC Open Data. (2020). Metal Content of Consumer Products Tested by the NYC Health Department.
https://data.cityofnewyork.us/Health/Metal-Content-of-Consumer-Products-Tested-by-the-N/da9u-wz3r

Parvez, S. (2020, October 16). BSTI certification now required for solar home system batteries. The Daily
Star. Retrieved from: https://www.thedailystar.net/business/news/bsti-certification-now-required-solar-
home-system-batteries-1978897

Pure Earth (2020a). Analysis of Findings from the Toxic Sites Identification Program in Bangladesh.

Pure Earth (2020b). Assessment of Informal Used Lead Acid Battery Recycling and Associated Impacts
in Bangladesh

Pure Earth (2020c). Institutional Capacity Assessment and Legal Framework for the Management of
Chemical Contamination in Bangladesh.

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Rahman, I. (2019, December 13). েীটনােদে যরৈেি রসসা. Daily Jugantor. Retrieved from:
https://www.jugantor.com/todays-paper/city/254921/ েীটনােদে-যরৈেি-রসসা

Rahman, M. S., Khan, M. D. H., Jolly, Y. N., Kabir, J., Akter, S., & Salam, A. (2019a). Assessing risk to
human health for heavy metal contamination through street dust in the Southeast Asian Megacity: Dhaka,
Bangladesh. Science of The Total Environment, 660, 1610-1622. DOI: 10.1016/j.scitotenv.2018.12.425

Rahman IMM, Mutsuddi R, Jii N, Barua S, Ahmmad B, Kibria MG, Hossain MM, Begum ZA, Dey BK,
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Shah.M.P., Shendell D.G., Strickland P.O., Bogden J.D., Kemp F.W., Halperin W. (2017). Lead Content
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manufacturing workshops in Bangladesh. Environmental monitoring and assessment, 189(6), 279. DOI:
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Generation of Future Potential.

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Appendix A. Existing Organizational Experience and Assets

a. Pure Earth

i. Relevant programmatic experience

Pure Earth’s work in Bangladesh began with the implementation of the Toxic Sites Identification
Program in 2011. Since then, several phases of the Program funded by different development
partners have been completed. While some of these phases looked at a broad spectrum of
chemical contaminants, more recent phases have focused specifically on lead contamination
from used lead acid battery recycling. As such, the national TSIP database for Bangladesh
contains a significant amount of data on lead contamination, but comparatively little on other
chemicals.

Through TSIP, Pure Earth identified a highly contaminated used lead acid battery (ULAB)
recycling site in Kathgora, Bangladesh, with concentrations of lead in soil exceeding 10,000
ppm in areas. Prior to initiating a demonstration risk reduction project at the site, Pure Earth and
its partners collected blood lead samples from approximately 70 children below the age of 7.
While there is now known safe level of lead in blood for children, the United States Centers for
Disease Control has set a reference value of 5 μg/dL. All children tested in Kathgora exceeded
this reference value; the average blood lead was above 20 ug/dL, with a maximum of 47 ug/dL.
A year and a half after the completion of the project, which involved the removal and
containment of contaminated soil, house cleaning, and an education campaign, blood leads had
dropped by 42% on average.

Beyond these field-based activities, Pure Earth has conducted numerous reports on topics
related to lead in Bangladesh, including a chemical contamination scoping document, a
government capacity assessment, and a ULAB industry analysis.

ii. Staff

In December 2020, Pure Earth recruited a full time Country Director to overlook implementation
of programs in Bangladesh. This is in addition to two senior advisors and two field investigators.
Bangladesh-based staff are supported by head office staff, including the Regional Director and
Program Associate for South Asia, as well as numerous communications, development, and
technical staff.

iii. Data

One of the most robust sources of information about the location, contamination levels, and
potential public health risks of chemical contamination hotspots in Bangladesh is the global
TSIP database. TSIP is designed and managed by Pure Earth and implemented in Bangladesh
in partnership with the Department of Geology of the University of Dhaka, and in consultation

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with the Bangladesh Department of Environment. The TSIP database of contaminated sites is
publicly accessible at www.contaminatedsites.org.

The TSIP endeavors to identify and assess industrially contaminated sites in low- and middle-
income countries with a potential human health impact. As part of the TSIP, more than 3,600
sites have been assessed in 47 countries since 2009. The purpose of TSIP is to quantify the
approximate scope and severity of industrial soil and water contamination in a given country.
Using the information gathered during on-site investigations, high priority sites can be targeted
for more detailed assessment and for intervention to mitigate exposures.

The TSIP utilizes a rapid assessment protocol known as the Initial Site Screening. The Initial
Site Screening is completed on site over a period of 1-2 days by professionally trained
investigators and is designed to collect information related to human health risks. Investigators
collect various types of qualitative and quantitative data, including an analysis of soil and/or
water samples collected from points of likely public exposure. Data from completed Initial Site
Screenings are entered into an online database that is shared with relevant government
agencies, donors, development agencies, and other interested stakeholders.

TSIP project leaders identify sites for screening through a variety of methods, including
consultations with DoE and other national agencies and civil society groups, information
collected from national and international reports on chemicals and waste, newspaper articles,
suggestions by local officials, and through recommendations by local residents and workers
received in the processes of conducting screenings.

As of April 2020, the TSIP in Bangladesh had resulted in more than 340 initial site screenings at
contaminated sites across the country. Of these sites, 289 are contaminated with lead resulting
from informal or substandard ULAB recycling.

Beyond TSIP, Pure Earth has collected blood lead data on children at the Kathgora site,
providing evidence of the health impacts of this industry. The results of this project also
demonstrated the positive impact of interventions such as soil remediation.

iv. Media assets

Through both the Bangladesh staff and head office, Pure Earth uses a number of channels to
bring attention to the issue of lead exposure and share findings. Recently, Pure Earth
Bangladesh has been publishing a series of articles related to lead exposure in the local
newspaper Daily Star. This is a part of an ongoing process to create awareness about various
sources of lead and its harmful health impact. Through its global reports, such as the Toxic
Truth, Pure Earth is also able to bring attention within the international community and highlight
the severity of lead exposure in South Asia in particular.

Pure Earth also publishes in peer-reviewed journals, thereby providing scientifically vetted
evidence for government officials. Two relevant recent titles include:

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Ericson, B., Hu, H., Nash, E., Ferraro, G., Sinitsky, J., & Taylor, M. P. (2021). Blood lead levels
in low-income and middle-income countries: a systematic review. The Lancet. Planetary health,
5(3), e145–e153.

Chowdhury, K., Nurunnahar, S., Kabir, M. L., Islam, M. T., Baker, M., Islam, M. S., Rahman, M.,
Hasan, M. A., Sikder, A., Kwong, L. H., Binkhorst, G. K., Nash, E., Keith, J., McCartor, A., Luby,
S. P., & Forsyth, J. E. (2021). Child lead exposure near abandoned lead acid battery recycling
sites in a residential community in Bangladesh: Risk factors and the impact of soil remediation
on blood lead levels. Environmental research, 194, 110689.

v. Partners/networks

In recent years, Pure Earth has developed, and now leads, a growing coalition of agencies
working to reduce lead exposures in Bangladesh. This coalition meets regularly and includes
the United Nations Environment Program (UNEP); UNICEF; Stanford University; International
Centre for Diarrhoeal Disease Research, Bangladesh (icddr,b); Environment and Social
Development Organization (ESDO); International Lead Association (ILA); Bangladesh
Accumulator & Battery Manufacturers Association; and the University of Dhaka. While these
agencies communicate and collaborate, they are not guided by an agreed set of goals and
strategies that is supported by the government and aids their program design and
implementation. An agreed set of goals, priorities, and strategies would allow for a more holistic
and coordinated response, particularly with the support of the government. The proposed
program aims to provide that unified vision and strategy, and Pure Earth is well-placed to
facilitate the design of such a product.

vi. Ongoing and Future

Project name: Protecting Every Child’s Potential

Funder: Clarios Foundation
Partners: UNICEF, Clarios Foundation, Global Alliance on Health and Pollution
Pure Earth has brought together major partners, including UNICEF, Clarios Foundation, and the
Global Alliance on Health and Pollution, to implement the ambitious “Protecting Every Child’s
Potential” initiative (PECP), funded by the Clarios Foundation, to significantly reduce lead
exposures in low- and middle-income countries. PECP is a four-year, $15M USD, ground-
breaking project that will operate in, and share lessons across, five countries: Bangladesh,
Georgia, Ghana, Indonesia, and Mexico. PECP funding from Clarios Foundation has been
provided to Pure Earth and UNICEF separately for each organization’s distinct but coordinated
activities. Pure Earth’s work will build on successful projects carried out by Pure Earth around
the world and will further develop existing relations with government, NGOs, and the private
sector in Bangladesh to develop resources to reduce lead exposure from substandard ULAB
recycling and adulterated spices.

With the support of Clarios Foundation, Pure Earth will work in Bangladesh to:

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 • identify and assess sites and products contaminated with lead;
• educate communities about the dangers of lead and how to protect themselves;
• conduct remediation projects in contaminated communities to reduce or eliminate
sources of lead exposures;
• train government representatives and other stakeholders to identify, assess, and
mitigate lead contamination;
• provide technical guidance to lead acid battery recyclers and other industry
representatives to ensure environmentally sound practices; and
• provide policy recommendations to provincial and national governments to protect
workers and community members from lead exposures.

The PECP partnership seeks to mobilize international action and work collaboratively with local
and national governments, businesses, United Nations agencies, academia, and civil society to
combat childhood lead poisoning. The partners are grounded in a fundamental belief that every
child has a right to health and well-being and all children should have the chance to achieve
their full potential.

Project: Sustainable Manufacturing and Environmental Pollution (SMEP)

Funder: UK Foreign Commonwealth and Development Office (FCDO)
Partner(s): The Asia Foundation, Stanford University
SMEP is funded by the Foreign Commonwealth and Development Office (FCDO) and is
implemented in partnership with the United Nations Conference on Trade and Development
(UNCTAD). The SMEP program seeks to address the problem of pollution from the
manufacturing sector through interventions (technological and non-technological, process, or
regulatory), and by enabling widespread market uptake of successful solutions. The overall
SMEP project aims to identify and invest in emerging technologies or processes that mitigate
the harmful environmental and social impacts of pollution from manufacturing sectors in South
Asia and sub-Saharan Africa.

In Bangladesh, Pure Earth is partnering with the Asia Foundation in conducting a targeted
analysis in Bangladesh to identify the suitable pollution mitigation solutions - specifically
addressing pollution from hexavalent chromium and other heavy metals resulting from the
tanneries industry. In addition, Pure Earth is also addressing the problem of lead pollution from
used lead acid batteries (ULAB) through technological and production process solutions that
can help reduce or eliminate the amount of lead expelled into the surroundings. These include
including those that enable by-product capture and treatment, reduction of emissions or polluted
effluent, and circular economy solutions including industrial symbiosis.

Project: Lead Pollution and Health Roadmap

Funder: USAID
The overall goal of the project funded by USAID is to assist governments and communities
heavily impacted by toxic pollution in poor countries to take locally led action at the community,
regional and/or national level to mitigate health exposures by breaking pollution exposure
pathways and preventing future toxic emissions, and mainstreaming this information to cultivate

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broad interest in pollution issues. Aspects of the mainstreaming activities are targeted at
stakeholders, decision makers and donors, while other aspects are oriented toward civil society
activation to promote change and awareness. The programmatic focus in Bangladesh continues
to be on lead. The team was scheduled to undertake the Mirzapur pilot remediation project
funded by the Tauw Foundation, with the investigation work supported by USAID. However, due
to unprecedented circumstances presented by COVID-19 and the associated lockdown, the
pilot project has been postponed.

In July 2019, Pure Earth proposed a Health and Pollution Action Plan (HPAP) to the
Government of Bangladesh, as described in the Global Alliance on Health and Pollution
(GAHP)/Pure Earth HPAP manual. At that time, representatives from the Ministry of
Environment, Forests, and Climate Change and the Department of Environment suggested a
program with a narrower focus and requested an emphasis on lead and chromium. While Pure
Earth has worked on chromium contamination issues in the past, the organization has more
experience working to reduce exposures to lead and lead is the subject of all of Pure Earth’s
current and future programs in Bangladesh. To date, Pure Earth has conducted 293 screening
assessments at sites contaminated with lead across Bangladesh and has secured funding to
continue working on lead exposures for the next four years. As such, the organization’s potential
to add value to the country is greatest with respect to lead.

The broader objective of the proposed program is to provide that unified vision and strategy
allowing for a more holistic and coordinated response, particularly with the support of the
government. This roadmap, which closely mirrors GAHPs Health and Pollution Action Plan
process, will be an important first step in solving lead pollution in Bangladesh. The specific
objectives will result in a Lead Pollution and Health Roadmap, a strategy document created with
multi-stakeholder input that will outline the extent of lead pollution in Bangladesh and provide a
strategic roadmap or plan for reducing lead exposures and lead pollution.

Project: Management of Lead Contaminated Sites in Bangladesh

Funder: Tauw Foundation and USAID
Pure Earth, the consulting engineering firm Tauw, and the University of Dhaka Department of
Geology are conducting a pilot project at a former used lead-acid battery (ULAB) recycling site
to reduce the impact of lead contamination on human health in the surrounding community. This
upcoming project will incorporate lessons learned from Pure Earth’s previous pilot remediation
in Bangladesh, conducted in 2017 and 2018 in Kathgora, Ashulia District.

The new project site is located in Mirzapur, Tangail District. It was identified through Pure
Earth’s Toxic Sites Identification Program and it was selected for remediation based on the level
of contamination and the proximity of the community. The site was home to an informal
recycling operation processing ULABs. These activities occurred on the site for more than three
and a half years before it was abandoned in February 2019. Investigations at the site by local
Pure Earth staff indicate that site operations included breaking open ULABs, draining out
sulfuric acid, removing lead plates, and processing other internal battery components and the
plastic battery carcasses. Site operations also including the uncontrolled smelting of the lead

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battery components in open pits with no vapor controls. These operations left behind residual
battery component wastes (e.g., separators and carcasses), concrete processing pads
containing the smelting pits, and highly contaminated soil not only in the area of operations, but
in a widespread surrounding area.

Technical experts from Pure Earth and Tauw visited the site in November 2019 to conduct a
detailed site assessment. We have identified two source areas in the village, each with
abandoned smelting pits and large quantities of battery waste. The area is surrounded by
residential and agricultural land. Local shops, schools, and mosques are in close proximity to
the contaminated area. Approximately 600 people live in range of the contamination, with
another 450 people traveling in to work or visit the area. The project was scheduled to be
undertaken in 2020. However, due to COVID-19 the timeline has changed, and Pure Earth is
hopeful that the remediation activities will be undertaken in 2021.

b. UNICEF

i. Relevant Programmatic Experience

UNICEF has been working in Bangladesh since 1952. Bangladesh, a country in South Asia,
hosts a population of 160 million, 40 percent of which are children. UNICEF as a UN agency
focuses on children, provides support to youth facing challenges in this developing, while
densely populated nation. UNICEF reaches out to communities in all 64 districts, through our
field offices covering eight administrative divisions of Bangladesh. The UNICEF program for
Bangladesh follows a life-cycle approach that addresses children’s needs as they pass from
infancy to adolescence. The method relies on separate arms that unite for action, including
Education, Health, Nutrition, Child Protection, Water, Sanitation and Hygiene, Communication
for Development, Advocacy and Partnerships and Emergency response.

UNICEF Bangladesh in collaboration with the Ministry of Health and Family Welfare (MoHFW),
elaborated the health program to address country challenges that are also linked to global
health priorities and targets. The health program focuses on three main areas: i) health service
interventions across the country and focused on the district health system including maternal
and neonatal health, adolescent health, and expanded program on immunization (EPI); ii) health
system strengthening, focused on Community Health, Health Management Information System
(HMIS), District Evidence-Based Planning and Budgeting (DEPB) and Leadership Development
Program (LDP); and, iii) humanitarian support, focused mainly on the Rohingya refugee areas.
UNICEF also supports Bangladesh Preparedness and Response Plans (BPRP) for COVID-19
responses. UNICEF strengthens risk communication and community empowerment, infection
prevention and control, quality improvements for case management including liquid medical
oxygen supplies, capacity building and research and evidence generation.

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ii. Staff

The health section of UNICEF Bangladesh has 17 staff members in Dhaka and 18 in field
offices. A health specialist functions as a focal person for PECP, supported by a health manager
(health systems strengthening) and the Chief of Health. A national consultant for PECP was
recruited for working closely with UNICEF and the Government of Bangladesh.

iii. Data

UNICEF Bangladesh has supported Directorate General of Health Services (DGHS),

Government of Bangladesh for establishment of strong national Health Management
Information Systems (HMIS), using District Health Information Systems 2 (DHIS2), which is
used for real-time reporting and monitoring of data. UNICEF supports DGHS for emergency
responses including Rohingya refugees and COVID-19 outbreak for creating dashboards and
information systems for rapid responses to crisis.

iv. Media Assets

UNICEF Bangladesh has social media channels in Facebook, Twitter, and Instagram, through
which important national campaign messages have been shared with millions of followers.
UNICEF Bangladesh also has vast network with local and international broadcasting media and
newspapers with support from the communication section. UNICEF’s national events have also
been broadcasted via live streaming in Facebook for reaching a wider audience.

v. Partners/Networks

The health program builds on the program cycle as defined in the 2017-2021 Country
Programme. The activities of the program have been implemented in partnership with the
Government of Bangladesh and other national stakeholders. UNICEF plans are aligned with the
Government of Bangladesh, as the biggest partner, as it advances the 2030 Agenda for
Sustainable Development. UNICEF’s success in attaining equitable results for children relies
heavily on collaborations with partners, donors, civil society organizations, and local people.
UNICEF also supports development of Bangladesh jointly with other UN agencies upon United
Nations Sustainable Development Cooperation Framework.

vi. Ongoing and future complimentary/overlapping programs

The health section of UNICEF Bangladesh is implementing a climate change project—Building

Climate Resilient Health Systems for Vulnerable Women and Children of Patuakhali District of
Bangladesh (2019-2021)—to build institutional capacity for strengthened climate resilient health
systems, and to mainstream climate risks into health planning, policies, and programming.

UNICEF Bangladesh is currently in the phase of development for the Country Program cycle
2022-2025. The health program will mainly focus on achieving three areas 1) Strengthen

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government policy and institutional capacity thorough evidence-based policy advocacy on
primary health care (PHC) model scale-up, quality of care system building, integrated HMIS and
immunization financing for a sustainable and resilient Maternal Newborn Child and Adolescent
Health (MNCAH) and immunization service delivery systems for Upazilla Health Complexes
(UHC) through PHC including for (re)emerging diseases and emergencies 2) Ensure equitable
coverage of quality MNCAH and immunization services in selected districts through improved
capacity of the district to plan, implement, monitor, and manage evidence-based programming
for a district focused approach, including for (re)emerging diseases and emergencies 3)
Improve access and utilization of essential service package (ESP) through implementation of a
sustainable PHC model integrating social accountability system including in emergencies.

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Appendix B. Used Lead Acid Batteries in Bangladesh
Prepared by the International Lead Association, April 2020

1. Introduction
Bangladesh is one of the world's most
densely populated countries, and
especially in the delta region where the
rivers of the Ganges Delta flow into the
Bay of Bengal.

Poverty is widespread, but Bangladesh

has in recent years reduced population
growth and improved health provisions
and education services.

Bangladesh was formerly part of Pakistan and known as East Pakistan, a legacy of Indian
Independence and only came into being in 1971, when West Pakistan split with East Pakistan
after a bitter war that was only brought to an end when the Indian army intervened on the side of
East Pakistan.

Following the war, the population of the new country of Bangladesh spent 15 years under military
rule and, although democracy was restored in 1990, the political scene can, at times, seem
somewhat unstable.

Islamist extremism has also been rising in the traditionally tolerant country.
Much of Bangladesh is low-lying and vulnerable to flooding, cyclones and potentially climate
change if sea levels continue to rise.

Dhaka is the capital of Bangladesh and largest city with a population of over 18 million. It is also
the country’s main financial centre and cultural hub. Chittagong, the largest seaport, is also the
second largest city. The population of Bangladesh is approaching 169 million citizens.

The country's biodiversity includes a vast array of plants and wildlife, including the world’s largest
mangrove forest and the endangered Bengal tiger, the national animal. Bangladesh is a major
textile and clothing manufacturer and exporting with the sector contributing USD$ 35 billion to the
economy.

Total GDP amounts to nearly $317.5 billion USD (2019) and the annual growth rate is 8%1.

2. Vehicle population
The number of motor vehicles registered in Bangladesh is reported to be 504,130 units as of units
December 2019. The number of vehicles is, however, dwarfed by the number of motorcycles,

1 World Bank

70
amounting to over 2 million, that are not included in the official vehicle registration data published
by the government.

Up to-
Type of Vehicles 2 010 2011 2012 2013 2014 2015 2016 2017 2018 Total
1 Ambulance 2793 219 181 243 338 480 378 495 172 5299
2 Auto Rickshaw* 126763 20423 23545 15697 19897 20000 11173 9168 2425 249091
3 Auto Tempo* 14266 175 626 395 500 1095 1322 1592 451 20422
4 Bus 27778 1761 1439 1107 1488 2391 3833 3760 817 44374
5 Cargo Van 3522 489 282 687 608 399 1017 1413 413 8830
6 Covered Van 5658 2354 1421 2271 2869 2354 3340 5176 1675 27118
7 Delivery Van 17063 1004 774 894 1176 1719 2181 2410 715 27936
8 Human Hauler* 6520 1152 715 385 225 1142 3487 3393 497 17516
9 Jeep (Hard and Soft 32286 2134 1569 1314 1870 3601 4892 5425 1346 54437
top)
10 Microbus 66379 4051 3044 2537 4313 5224 5804 5575 1248 98175
11 Minibus 25644 276 249 148 256 323 472 492 102 27962
12 Motorcycle 759257 114616 101588 85808 90685 240358 332057 326550 94740 2145659
13 Pick Up (D/Cabin) 32240 10460 7625 6553 9554 10257 11371 13512 3587 105159
14 Private Passenger 219830 12950 9224 10472 14699 21062 20304 21959 5160 335660
Car
15 S P Vehicle 6371 396 226 227 172 296 620 993 305 9606
16 Tanker 2706 317 195 226 362 324 394 319 96 4939
17 Taxicab 44380 75 172 51 374 88 44 15 32 45231
18 Tractor 20600 5200 3494 1885 1522 1699 2576 2777 1114 40867
19 Truck 82871 7327 4335 5129 8136 6330 7275 10353 3325 135081
20 Others 1317 7 1 1080 1595 2073 3870 5021 1558 16522
TOTAL 1498244 185386 160705 137109 160639 321215 416410 420398 119778 3419884
Bangladesh's Motor Vehicle Registrations: Totals from 1995 to 2019 (RTA)

The vehicle described as a “Human Hauler*” may not be a term familiar to anyone outside of
Bangladesh, but it is best described as a converted open truck that carries people.

71
 A typical “Human Hauler”

To avoid any confusion with the vehicles described and known as “Auto Tempo” and “Auto
Rickshaw”, here are illustrations of both vehicles. As can clearly be seen in the photographs, the
Tempo can carry more passengers than the Rickshaw.

Typical Auto Tempo Typical Auto Rickshaw

Human haulers, auto tempos and auto rickshaws are currently banned from main highways in
Bangladesh due to the high accident rates associated with these vehicles2.

2 Road Transport Authority, Bangladesh

72
 Estimates for the number of e-rickshaws vary from the Dhaka tribune’s report of
approximately 500,000 to the e-rickshaw’s association’s estimate of 1,500,000. These
vehicles are typically powered by 4 to 6 lead acid batteries3 weighing 20 to 30 kilos, and
taking about four hours to fully recharge providing a range that will serve for a full days’
work.

It should also be noted that the number of auto rickshaws of all descriptions listed in the
official government statistics may be a serious underestimate of the actual number of
rickshaws on the road. The reason being that some 30 years ago the Dhaka City
Corporation stopped issuing licences to rickshaws, because the rickshaws were considered
by the City Corporation to be one of the main contributors to traffic gridlock in the capital.
Since then, it would appear that licence plates are still being issued, albeit illegally, with
some drivers paying up to Tk 15,000 (USD$ 180), which amounts to about 3 months
earnings. On top of the initial outlay, in order to “keep” the license plate, divers are required
to pay about Tk 500 every quarter. This trade in license plates means the municipal
authority is losing income and worse still, the government have no idea how many rickshaws
are on the streets. According to the two Dhaka city corporations, there are nearly 80,000
licenced rickshaws in the capital, but a Buet4 study put the number of illegal rickshaws at
about one million, in fact, more that the total number of officially licensed rickshaws in
Bangladesh, which number nearly 290,000.

3. Solar Power Generation

More than a quarter of the rural population in Bangladesh do not have access to a main grid
electricity supply and that means for millions of families, cooking, working and studying are
difficult, or even impossible, after sundown.

However, the Government of Bangladesh have initiated one of the world’s most ambitious
domestic solar energy programmes. With the support of the World Bank and other
international development organizations and donors, together with the private sector,
affordable home and workplace solar-powered electricity is being installed in locations
where grid electricity would be too expensive to install or where the geography makes it
difficult to reach.

The small-scale solar systems have been installed in more than 4 million properties,
including 13 mini-grid installations, providing electrical power to over 20 million of the
population and irrigation to over 1,000 small holdings and 6,000 farmers5.

Of note here is the fact that the energy storage media of choice is the lead acid battery.

4. Telecommunications
Mobile communications in Bangladesh are improving at a pace, and need to, to maintain the
economic momentum. Currently there are four main players, namely:

3 https://www.dhakatribune.com/bangladesh/power-energy/2017/09/27/pdb-bringing-battery-run-vehicles-tariff-
regulations
4 Rickshaws Revisited: Saimum Kabir, 2018 - https://contextbd.com/rickshaw-revisited/
5 World Economic Forum, 2018, Riccardo Puliti: https://blogs.worldbank.org/energy/grid-bringing-
power-millions

73
 • Banglalink (by International Vimpelcom)
• Grameenphone (joint venture with Telenor)
• Robi-Airtel (Malaysian Axiata Group and Indian Bharti Airtel merging their networks).
• Teletalk (state-owned)
•
Out of the Four operators, Teletalk, Grameenphone, Robi, & Banglalink offer 3G nationwide, and
4G services in 64 districts of Bangladesh, and Banglalink provides a 3G service in all regions.
None of the telecoms companies have any CDMA Base Stations and only have GSM systems.
In total there are over 47,269 GSM stations, but most of them are equipped with lithium ion
batteries and not lead batteries. It would appear that the telecoms equipment adopted by the
companies in Bangladesh has been imported from China6, and the equipment would have been
installed with batteries manufactured in China. As telecoms batteries are made to a high
specification with a guaranteed life of at least 15 years, it is not unreasonable to assume the any
replacement batteries would be imported from China. Assuming that is the case, then the
replacement batteries would be recorded in the Comtrade database as industrial batteries.
Although it is not possible to determine exactly how many tonnes of used lead batteries are
generated currently, because many, if not most of the GSM stations are not 15 years old and so
will not be adding to the recycling burden for a few more years. However, as and when
replacement Telecoms VLRA batteries do come to the end of their working lives, it is likely that
they will be replaced on or just before their guaranteed life expectancy, so that the telecoms
network does not fail. Therefore, in a mature Bangladesh telecom network nearly 2,000 mt of
ULAB will be generated annually, assuming no growth in the network. Going forward as
consideration is given to developing a strategy for managing the lead risk posed by ULAB
recycling, this estimate of telecoms ULAB will become more significant and so it is included in the
current estimates, especially as the mobile network will expand.

GSM VRLA @ ULAB Weight

Network LAB Weight mt
Stations7 24/unit mt
Banglalink 14,000 336,000 9,744 584
Grameenphone 15,900 381,600 11,066 664
Robi 8,392 201,408 5,841 350
TeleTalk 8,977 215,448 6,248 375
Totals 47,269 1,134,456 32,899 1,973

For many people in Bangladesh, affordability is an issue, but despite this barrier, the mobile
communications industry in Bangladesh has increased dramatically over the last decade to
become the fifth largest mobile market in the Asia Pacific region with over 85 million subscribers

6 https://www.ceicdata.com/en/indicator/china/exports-telecommunication-equipment
7 Source: Environment and Social Development Organization (ESDO)

74
in 2017, or half the population of Bangladesh8. Projections suggest that by 2022 the number of
mobile phone subscriber will reach 100 million.

5. Used Lead Acid Batteries (ULAB) in Bangladesh

Bangladesh is a hot country and the average life of SLI automotive and motive lead batteries in
such countries is normally two years, although e-rickshaw batteries are sometimes failing after 3
or 6 months. Nevertheless, assuming that SLI vehicle battery life is about two years and the e-
battery lasts for about 6 months, the following tabulation can be prepared and the approximate
number of ULAB determined. Other assumptions are that the lead average weight of automobile
SLI batteries is 14 kilos, the fully electric e-rickshaw battery weighs around 20 kilos and the cycle
version 14 kilos with one LAB in the cycle version and at least four in the e-version, and the
average weight of truck and bus batteries is 25 kilos. The average weight of a solar system battery
is taken at 10 kilos with a useful life of 5 years.

Lead Battery Numbers Av. Weight kg Total Weight ULAB Generated mt

Use mt
Automotive – cars 613,977 14 8,596 4,298
+ vans and taxis**
Motorcycles** 2,245,659 5 11,228 5,614
All Rickshaws (+ 1,000,000 5 5,000 2,500
microbuses)**
e-rickshaws 1,500,000* 30 45,000 90,000
Trucks + Tractors 186,116 25 4,653 2,326
+ Ambulances**
Buses (+ mini- 88,858 25 2,221 1,111
buses + others)**
Telecom9 1,134,456 29 32,899 1,973
10
Industrial Unknown Unknown 10,330 2,066
Solar systems11 4,000,000 10 40,000 8,000
Totals 159,927 117,888
* Estimate based on data provided by the e-rickshaw association

** Bangladesh RTA

8 GSMA Country overview: Bangladesh, Mobile industry driving growth and enabling digital inclusion,
Mike Rogers, 2017:
https://www.gsmaintelligence.com/research/?file=a163eddca009553979bcdfb8fd5f2ef0&download
9 Source: Eco-Social Development Organization (ESDO)

10 COMTRADE

11 Ministry of Power, Energy and Mineral Resources, Bangladesh

75
 Motorcycles and e-Rickshaws dominate the LAB replacement market (RTA)

The data once collated and analysed shows that the amount of lead batteries in use is nearly
160,000 mt and ULAB generated annually is almost 118,000 mt. This figure also represents the
LAB replacement market.

77% of the ULAB generated annually are from e-rickshaws

The estimates calculated from the data collected indicates that the ULAB generated by the e-
rickshaws account for 77% of the total ULAB generated annually.

76
 6. UN COMTRADE Data Analysis

The only full set of COMTRADE12 data available is from 2018.

6.1 Imports of Lead Acid Batteries

HS Code Type of LAB Tonnage – Metric tonnes

850710 Automotive for cars, trucks, buses and motorbikes 1,044
850720 Non-Automotive Industrial batteries 3,939
Total 4,983

The cost of the automotive battery imports was USD$ 3,297,767 and the cost of the industrial
battery imports amounted to USD$ 19,682,116. 55% of the automotive lead battery imports were
from India and 24% from China. 92% of industrial lead battery imports were from China.

The fact that 92% of industrial LAB imports were from China adds weight to the assumption that
the OEM Telecom LAB used in the GSM stations were manufactured in China and the
replacement LAB are also being imported from China together with Industrial LAB for other
applications.

It is therefore likely that the 3,939 mt. of imported industrial LAB were replacement LAB and if just
over 1,900 mt. of LAB were destined for the Telecommunications sector, then the amount of
replacement Industrial LAB is just over 2,000 mt. On the basis that industrial LAB are
manufactured to last at least 5 years, the amount of industrial LAB in use is in the order of about
10,000 mt.

6.2 Imports of Refined Lead and Lead Scrap

HS Code Type of LAB Tonnage – Metric tonnes

780110 – Refined Lead 19,417
780191 -
780199
780200 Lead Scrap 1,729
Total 21,146

The cost of importing the refined lead was USD$ 56,574,885 and the cost of the lead scrap was
USD$ 495,000. Bangladesh does not have any indigenous supplies of lead and so any shortfall
in supply that cannot be met by domestic recycling must be imported either as refined lead ingots
or scrap lead.
Of the imported refined lead, 47% of the refined lead was imported from India, 22% from Thailand,
15% from the Republic of Korea and 9% from other non-specified countries in Asia (listed as Asia

12 https://comtrade.un.org/

77
NES). One significant omission from the Comtrade data was ULAB and cross-referencing every
country in the world exporting ULAB confirmed that Bangladesh is not importing ULAB.

6.3 Exports of Lead Acid Batteries and Refined Lead

HS Code Type of LAB Tonnage – Metric tonnes

850710 Automotive for cars, trucks, buses and motorbikes 11,277
850720 Non-Automotive Industrial batteries 99
780110 - Refined Lead 7,189
780191 -
780199
Total 18,565

Bangladesh exports automotive LAB to over 70 countries and in 2018 exported nearly 11,300mt
of batteries earning USD$ 29,115,528 for the industry.

The UAE purchased 15% of the exports, Kuwait 14%, Singapore 11%, India and the Russian
Federation 10%, China 9% and Australia 7%.

Exports of Industrial LAB amounted to 99 mt, valued at USD$ 422,392 and 83% of the exports
were shipped to Australia. The export of 99 mt of Industrial LAB to Australia confirms that
Bangladesh does manufacture industrial LAB, but the amount is so small that the trade is probably
linked to one specific item of equipment. Bangladesh also exported 7,189 mt of refined lead to
India adding USD 17,346,213 to earnings for the recycling industry sector.

Total sales of automotive and non-automotive LAB and refined lead in 2018 amounted to USD$
46,884,133. Whilst export sales of LAB and refined lead are impressive, it must be borne in mind
that imports of LAB, refined lead and lead scrap amounted to USD$ 80,049,768 leaving a lead
trading deficit of USD$ 33,165,635.

78
 There is a USD$ 33 M trading deficit in LAB, Refined Lead and Lead Scrap (COMTRADE)

7. LAB Manufacturers and ULAB Recyclers in Bangladesh

19 companies that either manufacture LAB, recycle ULAB, or are integrated and perform both
operations are registered with the government. 17 are listed below.

• Panna Group - http://www.pannagroupbd.com/about-us/

• Rahimafrooz Batteries - http://www.rahimafrooz-batteries.com/about/
• Silva- Abdullah Battery Co. Ltd. (HAMKO Gp) - http://www.hamko.com.bd/about_us.php
• Rimso Battery and Co. - https://rimsobd.com/rb.php
• J. Co. Battery Engineering Works - http://www.jcobattery.com.bd/profile
• Suntech Energy Ltd. (Update Group) - https://updategroupbd.com/index.html
• A&P Battery Industries Ltd. - http://www.poushigroup-bd.com/about/
• Geli Industrial Co. Ltd. - Ansar Road, Shripur , Gazipur, Gazipura, Dhaka, Bangladesh 1040
• General Battery Co. Ltd. - 192, Shahid Syed Nazrul Islam Swarani (5, Bijoy Nagar), Dhaka
1000, Bangladesh
• Rangs Power Ltd. - http://rangspower.com.bd/about/
• ECO Batteries Ltd. – Distributer
• Electro Battery Co. Ltd. - http://electrogroupbd.com/index.php/page/view/377
• SAIF-Saif Powertec Ltd. - http://www.saifpowertecltd.com/aboutus.php
• DJDC-DongJin Longevity Industry Ltd. - http://www.dongjin-battery.com/company/company-
profile.html
• Silicon Power Ltd. – Auto battery store
• Navana Batteries Ltd. - http://navana-battery.com/about-us/
• Fatema Traders Lead Smelting - Goalbari, Shimulia, Savar, Dhaka

Rahimafrooz Batteries Ltd is the largest lead-acid battery manufacturer in Bangladesh and the
main exporter to overseas markets. The company manufactures about 200 different varieties of
batteries for automobiles, IPS and other appliances at its manufacturing plants located at Ishwardi
in Pabna, and Birulia and Zirani Bazar of Savar in Dhaka.

Further investigation is required to confirm which companies recycle ULAB.

8. Conclusions

Motor vehicle ownership at just over 2 vehicles per thousand of population in Bangladesh is one
of the lowest in the world and this is reflected in the estimates for the tonnage of motor vehicle
LAB in use at nearly 8,600 mt. However, motorcycle ownership amounts to nearly 2,500,000 and
consumes over 11,000 mt of LAB.

The excellent weather conditions for Solar Energy production in Bangladesh and the
government’s drive and commitment to introduce green energy generation has led to the
installation of over 4,000,000 home and business units with LAB the preferred energy storage
medium.

The size and capacity of the LAB storage batteries will vary from about 10 kilos up to 50 kilos
depending on the energy requirements, but initial estimates of the number of LAB units in
operation indicates that about 40,000 mt of LAB are in use with an average useful life of 5 years.
The solar energy program is still in the implementation stage and the number of installations is

79
due to increase considerably as more villages in rural areas are supplied with the solar energy
kits.

Bangladesh is more likely to feel the adverse impacts of global warming than most countries,
because so much of the land mass is not much above sea level and prone to flooding if the sea
levels increase. There is, therefore, every reason for the Government of Bangladesh to implement
green policies so that it can make its case for other nations in the world to reduce greenhouse
gas emissions.

In this respect the government has embraced the introduction of electric rickshaws, so much so,
that unlike the owners of gasoline or LPG powered rickshaws (Tuc Tuc), the owners of e-
rickshaws are not obliged to register them with the Road Transport Authority. The owners of the
e-rickshaws welcome the fact that registration is not required, but the lack of any registration
means that it is very difficult to determine how many e-rickshaws are in use. The best estimates
are from local and national newspaper reports that suggest about 500,000 are in use, but the e-
Rickshaw driver’s association puts the estimate at 1.5 million.

What is clear from an economic perspective is that irrespective of any environmental benefits with
the introduction of e-rickshaws, the fact that they cost about one tenth of the running costs of a
traditional gasoline Tuc Tuc and that they pay for themselves in about 7 months, means that the
number of e-rickshaws on the roads will increase.

The power assisted pedal e-rickshaws have only one LAB and the larger 4- and 6-seater models,
between four and six LAB. Feedback from owners and drivers of e-rickshaws suggest that there
is a problem with the motive LAB that are available for the e-rickshaws because many drivers
have to buy replacement LAB every three to six months.

Ideally the LAB should last for at least 12 months and the fact that the useful life is so short,
suggests that either the LAB on sale in Bangladesh are poor quality or they are the wrong type of
LAB. Of course, it is also possible that the drivers are buying cheap and poor-quality motive LAB.

LAB used for motive power, especially in a country where only 9.5% of the roads are paved,
should be of the absorbent glass mat (AGM) type of LAB. The AGM battery is specially designed
and assembled so that they are extremely resistant to vibration because the plates are
compressed in an electrolyte gel with the battery sealed and under vacuum, thereby rendering it
spill proof and maintenance-free.

If there are 1,500,000 e-rickshaws in operation13, then there is likely to be about 45,000 mt of LAB
in use. Considering the short useful life of a rickshaw LAB, then the replacement market for motive
LAB for e-rickshaws will be in the region of 90,000 mt per annum based on information from the
drivers that LAB only last about 6 months.

The precise data available for LAB use and consumption in the state-owned and private
telecommunications companies GSM base stations (global system for mobile communication),
reveals that most of the stations are using lithium ion batteries. Nevertheless, LAB account for
over 1.1 million units in the GSM stations amounting to over 33,000 mt. The LAB currently in use
in the GSM stations are manufactured to a very high standard and have a life span of 15 years.

13 Data supplied by the e-rickshaw association

80
At present it is unlikely that the GSM LAB are at the end of their useful life as most of the stations
are not 15 years old.

As the mobile network matures so will the tonnage of ULAB generated. If the network remains
the same size as it is currently, then the tonnage of ULAB generated will be in the order of 2,000
mt., but the network will continue to grow for a number of years and the tonnage of telecoms
ULAB will increase annually.

Only a few LAB manufacturers in Bangladesh appear to manufacturer Industrial LAB, such as
those used in Forklift Trucks (FLT), Rahimafrooz Batteries being one. Over 90% of the industrial
LAB imported are from China and could be a mix of Telecoms and Industrial LAB, indicating that
the non-telecoms market for replacement LAB is just over 2,000 mt. This would imply that the
amount of industrial LAB in use will be in the order of 10,000 mt, given that the life of industrial
LAB is about 5 years.

The total amount of ULAB generated annually in Bangladesh is estimated to be in the region of
118,000 mt, based on the LAB inventory analysis and the various life cycles for each category of
LAB and their

respective applications. The annual tonnage of ULAB generated means that it is entirely possible
for three or four medium sized ULAB recycling plants (30,000+ mt capacity) to operate in a
sustainable, environmentally sound manner and be financially viable.

Such a scenario would be a major improvement in the environmentally sound management of

ULAB, because the Lead Battery Manufacturers Association in Dhaka believes that upwards of
80% of the lead recycled in Bangladesh is produced in the informal sector. Without knowing
exactly the tonnage of ULAB recycled in the formal sector, it is difficult to confirm the amount of
ULAB recycled informally, but in the absence of any official lead production data or records of the
capacities of LAB manufacturers licensed to recycle ULAB, the default position is that the informal
sector may well be the major source of lead for the LAB manufacturing sector.

In addition to the domestic LAB replacement market of about 118,000 mt, the LAB industry sector
also exports nearly 11,500 mt of automotive and industrial LAB indicating that the LAB
manufacturing output from Bangladesh is in the order of 130,000 mt of LAB.

The refined lead required to produce 130,000 mt of LAB is in the region of 78,000 mt. The ULAB
generated annually will yield just over 70,500 mt of lead, leaving a shortfall of approximately 7,500
mt.

However, in 2018 just over 19,400 mt of refined lead was imported together with over 1,700 mt of
lead scrap (normally lead scrap has a high lead content approaching 99%), a total of
approximately 21,150 mt.

The fact that the shortfall in refined lead to produce LAB and the imports of refined lead and lead
scrap to enable the LAB manufacturers to meet demand do not match, indicates:
The licensed LAB manufacturers and ULAB recyclers are not collecting all the ULAB and recycling
them within the licensed sector of the Industry.

• Just over 13,500 mt of Lead content in ULAB is unaccounted for in the inventory

81
 • The informal sector might be selling the Lead bullion they produce for export – albeit
informally through a cross border trade
• That if the licensed LAB manufactures and ULAB recyclers could collect and recycle all
the available ULAB, the shortfall in refined Lead would be close to 7,500 mt and save
approximately USD$ 35,000,000 on the balance of payments, because the industry
would only need to import 7,500 mt of lead instead of 21,000 mt.

The prices paid by LAB manufacturers in Bangladesh for the imported refined lead included a
premium to cover the cost of transport and so on, meaning that the price per metric tonne of lead
was over USD$ 700 above the LME price per metric tonne. Paying such a premium over the LME
Lead price would be unnecessary if more ULAB could be recycled by the formal industry sector.
In house ULAB recycling means that the refined lead can be transferred from the recycling cost
centre to the LAB manufacturing sector at the LME price without any premium and a very low
transport cost if the LAB manufacturer is integrated, that is manufacturing LAB and recycling
ULAB in the same unit. Such measure will directly improve the bottom line of the balance sheet
for any LAB manufacturer with and integrated LAB and ULAB operation.

82
Bangladesh Import / Export Trade Analysis 2018
Bangladesh Bangladesh Bangladesh Bangladesh Bangladesh Bangladesh Bangladesh Bangladesh Bangladesh Bangladesh

Imports Imports Imports Imports Imports Exports Exports Exports Exports Exports
Auto LAB Other LAB Ref. Lead Lead Scrap ULAB Auto LAB Other LAB Ref. Lead Lead Scrap ULAB
780110 780191 780110 780191
Customs HS Code 850710 850720 780199 780200 854810 850710 850720 780199 780200 854810
Asia NES 70 1,766,517
Australia 1,404,710 752,658 83,120
Austria 10
Bangladesh
Bahrain 63,844
Belgium 2,380 27
Benin 74,000
Bolivia 112,390
Burundi 94,845
Chile 1,080,247
China 246,453 3,609,160 120,906 50,000
Czech Republic 98
Estonia 1,674
France 16,513
Germany 2,262 1,714
China, Hong Kong SAR 2,215
Indonesia 51,883 306,487
Italy 12,409
Cote d'Ivoire 45,234
Japan 55,209 2,547 94,788
Rep. of Korea 11,920 2,340 2,886,598
Lebanon 390,769
Kenya 32,972 15
Kuwait 1,601,990
Malaysia 615 309 700,850 9,071
Maldives 35,196 13,754
Mauritius 78,432
Myanmar 147,274 200,000
Pakistan 656 1,619
Philippines 70,169
Poland 92,527
Qatar 474,327
Russian Federation 163 1,152,545
Saudi Arabia 79,818
Sechelles 47,503
India 577,752 171,610 9,104,229 1,165,894 646 7,139,000
Singapore 1,354 73,950 1,221,620
South Africa 477,288
Spain 7
Switzerland 1
Tanzania 129,826

Thailand 6,187 13,171 4,188,620 485,344

Turkey 10,968
UAE 16,380 2,409 1,657,886
United Kingdom 13,690 24,360 33
USA 1,191 124,004

Totals 1,044,015 3,938,598 19,416,642 1,728,714 0 11,277,098 99,155 7,189,000 0 0

Totals in Metric Tonnes 1,044 3,939 19,417 1,729 0 11,277 99 7,189 0 0
Total Weight of Lead Metric Tonnes 626 2,363 19,417 1,729 0 6,766 59 7,189 0 0
Estimated value USD$ 3,297,767 19,682,116 56,574,885 495,000 29,115,528 422,392 17,346,213

Gross Weight of Lead Imports mt 24,135

Gross Cost of LAB and Lead Imports USD$ 80,049,768

Gross Weight of LAB Exports mt 14,015

Gross Income from LAB Exports USD$ 46,884,133

83