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Eco-friendly Brick Industries

Introduction
Brick remains the major construction material in our country as we have limited source of
construction rocks. Topsoil from agricultural lands, river floodplains are used for making the
green bricks which is burnt later at the kilns mainly using the imported coal and domestic fire
wood. Brick kiln owners mainly use imported Indian poor quality coal for burning bricks in
the seasonal brick kilns operated during November to May every year. A recent UNDP study
suggests that fire wood share approximately 33 per cent of the fuel used in the seasonal brick
kilns in the country. Bangladesh Brick Manufacturing Owners Association (BMOA) claims
that there are approximately 8,000 brick fields that manufacture bricks of different grades in
the country. About 60 per cent of the produced bricks in the country are consumed by
different government departments, such as the Roads and Highways Department, Public
Works Department and Local Government Engineering Department annually. The rest is
consumed by private sector users. As reported by BMOA, brick making industry employs
around 2 million workers during the peak season and 0.8 million in the off-season. According
to a UNDP source, the country produces over 8.66 billion bricks a year and the sector has
grown at 5.3 per cent over the last decade. But there are reasons to believe that total brick
production in the country is almost three times the above estimate per year. It is not easy to
replace the existing brick kilns with new technology very quickly, although there is
availability of proven technology capable of producing quality bricks using one-third fuel
(coal) compared to conventional FCK or BTK. Installation of a fixed chimney brick kiln
involves approximately Tk 3 million, while a Zigzag kiln installation requires double the
amount (excluding land price or rent). A Hybrid Hoffman kiln may require an investment of
Tk 80-100 million (excluding land price) to be installed. Hoffman and Hybrid Hoffman brick
kilns are generally installed in the highlands, and BTK, FCK and the Zigzag brick kilns can
operate both at high and low lands as they are seasonal kilns. UNDP started providing
technical assistances in Bangladesh to improve the brick kiln technology with the support of
the Global Environment Facilities (GEF) fund. Seven Hybrid Hoffman Kilns are set at
different locations of the country which operate round the year to produce quality bricks
using significantly less amount of coal. These projects are attracting new entrepreneurs to
replicate the environment-friendly brick kiln technology. The Chinese Xian Design Institute
of Wall and Roof Materials is helping the efforts to implement the HHK technology viably.
HHK includes among others, using pulverized coal mixed with clay to form green bricks.
This technology helps to improve reduced fuel use for brick burning and Green House Gas
emission. As reported, almost 80 per cent of the total energy required for burning bricks in
the HHKs is met by the coal mixed with the clay used in the green bricks. The remaining 20
per cent coal is fed externally into the firing chambers of the specially designed hybrid
Hoffman Kiln. And because of proper air circulation inside the kiln, almost all the coal used
for brick making and for firing is burnt efficiently. The system also includes the preheating
arrangements for the green bricks in the stacks put inside the properly insulated dryer
chambers with the help of exhausts directed in the dryer chambers from the previous firing in
the kiln. Due to the efficient drying and burning technology, HHK require only 13-14 tons of
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coal for making one hundred thousand quality bricks. A single unit HHK may produce
45,000-50,000 bricks every day. Thus a HHK can replace 5-7 conventional FCK or BTK or
Zigzag kilns as the HHK can operate round the year. HHK requires an investment of Tk 100-
110 million initially including the land price. As the HHK saves approximately 9-10 tons of
coal for burning 100,000 bricks (compared to FCK or BTKs), entrepreneur may claim the
carbon credit from the global carbon trading market. A rough estimate suggests that a HHK
may claim approximately Tk 700,000 annually from carbon credit by producing 15 million
bricks in HHK. And the carbon emission saving benefit is on top of the regular business
returns from the brick production and selling. To implement environment friendly brick
manufacturing project, financial feasibility is a must. As this technology is capital intensive,
this report aims to identify the parameters to achieve to implement a green brick technology.

Traditional brick making industries in Bangladesh

Bangladesh is the 8th largest populous country with 160 million people. Each year 3,00,000
to 4,00,000 rural people migrate in Dhaka. The existing people as well as new migrants need
housing facility. At present in our country the annually required shelter varies from 3 lakh to
5.5 lakh units. Bangladesh will need to construct approximately four million new houses
annually to accommodate the growing population (Rahim, 2011, p. 2). Rapid urbanization in
the country has created a booming construction industry and spurred the production of 8.6
billion bricks each year, with demand for the bricks rising at an annual rate of about 5.28
percent (UNDP; 2011).
Bangladesh has about 6,000 authorized brickfields and numerous illegal ones. (Bayron,
2009). The illegal brickfields do not have proper resources to run and proper license to keep
the fields into track. The brickfields are typically small independent units and operate 24
hours during the dry season. They are located near towns or major construction sites; i.e.,
Gabtali, Savar, Ashuliya, Keraniganj, Narshingdi, Gazipur and Manikganj. In Dhaka, there
are around 4,500 brick kilns in operation, producing about 9.0 billion bricks per year. The
largest brick making zone is on the north of Dhaka city, where more than 1,000 brickfields
are situated (Khan, 2009). The existing technology for firing kiln are fixed chimney kiln
(FCK) and bull's trench kiln (BTK); though last one is banned in Bangladesh contributes 16%
of production. The main raw materials used in brick kilns to dry bricks are firewood and coal.
In case of unavailability of coal brick fields (about 33%) use firewood illegally to dry bricks.
As a result a large number of trees like Keora, chaila, sundari, mehguni, bain etc. are being
felled indiscriminately. If Bangladesh maintains its current economic growth rate, continued
use of this outdated brick-firing technology would raise the level of greenhouse gas emissions
to 8.7 million tons by 2014 by using coal in the purpose. Furthermore, using of firewood in
kilns also results in significant deforestation and this wood still account for about 25 percent
of the fuel used in Bangladesh's brick making kilns every year. The department of
environment said that the 4,000 brick kilns burn nearly 20 lakh tons of coal and another 20
lakh tons of wood every year to meet the demand for 400 to 1200 tons of fuel (Roy, 2004).
Inquiry suggested that many brick manufacturers set up their kilns near forests with the
intention to plain the forests illegally. Another investigation reveals that workers of the brick
field not only cut many trees but also built dikes to stop water from entering its premises
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during high tide which results in sudden flood in the adjacent areas. Beside this, people
working in the brickfield because of deadly air and poor water quality have to accept a
subhuman life. On an average the workers receive 80 taka every day for over 12 hours of
extremely hard or hazardous work (Akter, 2010). The following Table-1 summarizes the
main characteristics of the brick sector in Bangladesh.
Table-1: The main characteristics of the brick sector in Bangladesh

Parameter Value
Estimated total number of coal-fired kilns 5,000
Number of natural gas fired kilns 20
Annual brick production 17.2 billion
Value of output TK83 billion (US$1.2 billion)
Contribution to GDP ~1%
Coal consumption 3.5 million tons
Value of imported coal TK22.6 billion (US$322 million)
Firewood consumption 1.9 million tons
Emissions CO2 9.8 million tons
Clay consumption 45 million tons
Total employment (incl. supply of clay and coal,
1 million people
transport of bricks)
Growth rate of the construction industry
5.6%
(1995-2005)
Estimated future growth rate of the brick sector over
2-3%
the next ten years

In Bangladesh there are three major sources of air pollution; i.e. (a) vehicular emission, (b)
small industries like brick kilns and other biomass inclinators and (c) re-suspended road dust
(Ferdausi, Vaideeswaran & Akbar, 2008). In manufacturing seasons of brick, October to
March, pollution goes to peak in Dhaka and around the city depending on the monsoonal
rains. The Figure-1 shows air pollution of Dhaka throughout the year because of brick
manufacturing. Most brick fields have set up 25-feet tin chimneys in place of 120-feet ones,
defying government rules. In the brick kilns smokes are wafting out of the chimneys
polluting the environment of the area. According to the Brick Kiln Control (amended) Act
(2001), there must be no establishment of brick kilns within a three-kilometer radius of
human inhabitation as well as fruit garden. But lack of proper monitoring, brickfields have
sprung up like mushrooms and the situation has created a serious threat to environment and
biodiversity while the people in the neighboring areas face health hazards and fertility of
farms is going down (The Daily Star, 2011). The brick kilns emit toxic fumes containing
suspended particulate matters rich in carbon particles and high concentration of carbon
monoxides and oxides of sulphur (SOx) that are harmful to eye, lungs and throat.
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F
igure-1: Air pollution of Dhaka caused by brick manufacture (Source: Impact analysis of brick
kilns on the air quality in Dhaka, Bangladesh; Dr. Guttikunda; 2009, May)

Potentiality of Green Brick

As an effort to reduce greenhouse gases, Bangladesh has adopted smokeless brick-making
technology introduced by the UN Development Program as part of its project "Improving
Kiln Efficiency in the Brick Making Industry". The UNDP, which started its pilot project in
2006, will contribute $25 million in the next five years for 15 new projects in the country.
The innovative technology that is being used to replace the existing 150-year-old system will
simply make the brick making industry so efficient that when this is replicated across
Bangladesh we will have huge benefits for both the people and the global environment
(anonymous, 2010). The cleaner alternative coming on stream is called green bricks. Under
the project, 31 energy efficient brick kilns will be set up in different parts of the country
(UNDP, 2009). The new technology can be used in making green brick would be two types:
Vertical Shaft Brick Kiln (VSBK) and another is Hybrid Hoffman Kiln (HHK). VSBK is low
scale brick making technology; successfully demonstrated in Vietnam, Nepal and India and
its success and acceptance will be much higher in divisional cities and small towns. On the
other hand, HHK is high tech based and continue to proliferate in metro cities of Dhaka and
Chittagong which is developed in China (Anonymous, n.d).

Existing Brick Technology

Bangladesh uses four main types of kiln technologies, as presented in following table-2. The
Fixed Chimney Kilns (FCKs) and the Bull‘s Trench Kilns (BTKs), which form more than 90
percent of kilns, are very polluting and relatively inefficient. The gas-based Hoffmann kilns
and the coal-based Zigzag kilns are substantially cleaner, but represent just a few percent of
the total. The following sections discuss the characteristics of all these technologies, except
for the BTK, which is now banned.
Table-2: Existing brick kiln technology in Bangladesh (Source: Iqbal M. A., Financial Feasibility of
Environment Friendly Brick Manufacturing in the Context of Bangladesh, 2016)
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Percent of total Brick production Percent of total

Kiln type Number
kilns (%) (billion bricks) production (%)

FCK 4,500 92 15.8 91.4

BTK n.a. n.a. n.a. n.a.
Zigzag 150 3 0.6 0.0
Hoffmann (gas) 20 0.4 0.2 3.5
HHK 10 0.2 0.2 1.4
Others 200 4.0 0.5 0.9
Total 4,880 100 17.2 100

Fixed Chimney Kiln

FCK is the mainstay technology for the brick sector in Bangladesh. It is very polluting,
energy intensive and requires relatively low-cost investment. FCK dominates the northern
Dhaka kiln cluster, are located on lowlands and operate for 5-6 months a year.
An FCK under operation emitting black smoke because of incomplete combustion of coal.
The FCK is based on the traditional BTK technology, which dates back to the 19th
century. While the BTK uses two 30 feet (ft) high moveable chimneys, the FCK has a
fixed chimney of about 120-130 ft height. The tall chimney provides a faster and better
dispersion of the flue gas and its pollutants, compared to the BTK. The FCK has an
elliptical shape and measures about 250 ft long and 60 ft wide. It is constructed mostly in
open fields either over ground or partially underground. The bottom and the sidewalls are
lined with bricks. The FCK uses green bricks that are manually produced from mud
processed in pug mills. The wet green bricks are sun dried and loaded in the kiln in a
standard way developed over time with provisions for airflow and coal stoking. Once the
green bricks have been loaded in the kiln, the top is covered with two layers of bricks and
dirt for insulation.

Zigzag Kiln

A Zigzag kiln is rectangular and typically measures about 250 ft long and 80 ft wide. It has
a 55 ft high fixed chimney located on one side of the kiln. An induced draft fan located at
the bottom of the chimney draws the flue gas from the kiln and discharges it into the
atmosphere. The induced draft fan ensures a well-controlled airflow through the kiln. The
kiln is divided into 44 to 52 chambers, separated from each other by green bricks in a way
that the hot gas moves in a zigzag path through small openings. The long travel path of
bricks in a zigzag pattern and the contact of hot gas from the firing zone with bricks in the
preheating zone contribute to the transfer of more heat in the preheating zone. Thus, the
flue gas - rather than the fuel - heats up the bricks. In addition, the waste heat in the flue
gas helps to better drying and reducing the moisture content in bricks. These effects
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promote reduced fuel consumption, greater efficiency and higher brick quality compared
to the FCK‘s.
The flue gas’ repeated changes in direction and impinging on the walls and stacked bricks
lead to the deposition of significant amounts of particulate matter mostly on the green
brick surface. The deposition of particulates implies that the flue gas has much less
particulate load. This could be the reason for reduced Zigzag emissions compared to FCKs
emissions.
The Zigzag kilns in Bangladesh have been implemented with the help of artisans without
expert supervision. Thus, it has not been possible to ensure proper construction according
to certified design, which is important in reducing the level of particulate emissions. To
achieve this goal, it is essential to: (1) try out the technology with expert professional
input; (2) develop certified design specifications for construction and standard operating
procedures; (3) establish good operational practices and management. In the absence of
such a systematic approach, not only there may not be significant reductions in emission
levels, but the local pollution may actually increase due to reduced chimney height.

Hoffman Kiln
Natural gas fired Hoffman kilns were introduced in Bangladesh during the 1980s. A
Hoffman kiln is rectangular and measures 300-400 ft long and 60 ft wide. HK have
excellent insulation provided by the thick kiln walls thus heat loss is greatly reduced. The
emissions are also very low due to the use of natural gas as fuel.
Building this type of kiln requires special engineering expertise. The main difference
between Hoffman and the traditional kilns is that HK is built on high land, which does not
get flooded and hence can produce throughout the year. In addition, the HK has a roof
which makes it possible for the plant to operate even during the rainy season. The inside
roof of the kiln is arched and has a firebrick lining on the inside surface. The thick walls
provide good insulation that minimizes heat loss.
The chimney is about 80-100 ft high with an induced draft fan at the bottom. The flue gas
is conveyed towards the chimney through a network of channels just below the kiln. The
fire is controlled by merely adjusting the gas flow rate and by opening and closing the
dampers located at selected points in the flue gas network.
Hybrid Hoffman Kiln (HHK)
Developed in China, the HHK represents a hybrid version of the Hoffmann kiln
technology developed in Germany in the mid-19th century. Unlike the gas-based
Hoffmann kiln, the HHK uses coal as fuel. The HHK combines fuel injection and external
firing in highly insulated kilns, leading to lower energy use, high-quality bricks, and
reduced pollution. It was introduced in Bangladesh in 2006 under a GEF supported project
(UNDP–GEF, 2006). Eight HHKs are operating in Bangladesh, and another eight are in
the pipeline.
The HHK design combines a highly efficient kiln technology, known as Forced Draft
Tunnel Kiln (FDTK), with a unique technique of forming green bricks: Granulated coal is
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injected for internal combustion. Nearly 80 percent of the total energy required is injected
into the bricks, while the remainder is fed externally into the firing chamber. Most of the
fuel injected into the green bricks is completely burned during firing. This technology
improves energy efficiency in two ways: (i) internal combustion of injected fuel in green
bricks and (ii) application of heat optimization techniques in a minimum heat-loss chamber
in the kiln‘s combustion zone to capture waste heat for recirculation in the drying tunnel.
The HHK, like traditional technologies, does not require a tall chimney (IIDFC 2009).
HHK bricks are stronger and their price more competitive than those of FCK. The World
Bank has signed an Emission Reduction Purchase Agreement (ERPA) for buying Certified
Emissions Reductions (CERs) from the operating 8 kilns. The HHK initiative promises to be
successful in the marketplace; however, there are barriers to adopting the technology. First,
HHK implementation requires a substantially higher capital (about TK60 million per kiln)
compared to FCK (TK5 million). Second, HHK needs higher land (above the monsoon flood
level), which is scarce and expensive in the area surrounding the city of Dhaka and other
major urban centers.
Tunnel Kiln
In a tunnel kiln, which is a horizontal moving ware kiln, bricks to be fired are passed on
cars through a long horizontal tunnel. The firing zone remains stationary near the center of
the tunnel, while the bricks and air move in counter-current paths. Cold air is drawn from
the car exit end of the kiln, cooling the fired bricks. The combustion gases travel towards
the car entrance, transferring part of their heat to the incoming green bricks. The cars can
be pushed either continuously or intermittently at fixed time intervals. The tunnel kilns
have provisions for air extraction and supply at several points along the length of the kiln.
Tunnel kilns are the preferred technology for firing bricks in developed countries. The
advantages of tunnel kiln technology lie in its ability to fire a variety of products; good
control over the firing process; ease of mechanization, thus reducing the labor requirement;
and large production volume. Typically the capacity of a single tunnel kiln ranges from
60,000 to 200,000 bricks per day. While there are fewer than 10 tunnel kilns operating in
South Asia for brick firing, the technology has become very popular in Vietnam, where
roughly 700 tunnel kilns are in operation.

Comparison of Different Technology

Below table summarizes the different technologies for brick manufacturing and their impact
on environment:
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Table-3: Brick manufacturing technology (Source: Iqbal M. A., Financial Feasibility of Environment
Friendly Brick Manufacturing in the Context of Bangladesh, 2016)

From the above table it can be inferred that, tunnel kiln technology is the most suitable when
the environment is concerned.
Revenue Assumption of Tunnel Kiln

 Capacity Utilization: To estimate the revenue over the life of the project requires the
projection of capacity utilization. It this case, though a typical tunnel kiln project can
run for 30-40 years, I am considering only 10 years for hypothetical purpose which is
given in following:
Table-4: Estimated capacity utilization (Source: Iqbal M. A., Financial Feasibility of Environment
Friendly Brick Manufacturing in the Context of Bangladesh, 2016)

Estimated
Year Year Year Year Year Year Year Year Year Year
Capacity Average
Utilization 1 2 3 4 5 6 7 8 9 10

Capacity
Utilization
(% of yearly 75% 60% 65% 70% 75% 80% 80% 80% 80% 80% 80%
production
capacity)

 Estimated Revenue: Considering the price of brick as BDT 9.07 per brick in the base year
and inflation rate of 6.8% per year and rated capacity of 100,000 brick per day, the estimated
revenue from the project stands as follows:

Table-5: Estimated yearly revenue (Source: Iqbal M. A., Financial Feasibility of Environment Friendly
Brick Manufacturing in the Context of Bangladesh, 2016)
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Revenue Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Year 7 Year 8 Year 9 Year 10

Total Revenue (in 161.32 186.58 214.52 245.38 279.43 298.32 318.49 340.02 363.00 387.54
BDT million)

Economic Analysis of Brick Kiln Technologies

In Bangladesh, use of the traditional FCK is profitable for the entrepreneur, but highly
polluting for society. Experience in other South and East Asian countries, including India,
Nepal, and Vietnam, indicates that the IFCK, VSBK, Zigzag, and HHK are substantially
cleaner: they consume less energy and emit lower levels of conventional pollutants and CO 2
emissions. Adopting these technologies would be made easier if they were more socially
and financially profitable than the FCK. This chapter assesses the social (public) and private
(financial) net benefits of the FCK, IFCK, VSBK and HHK.
It should be noted that the analysis is subject to some limitations. First, it covers only a set
of technologies for which data could be made available. Other technologies, though
successful throughout the region, could not be included, either because of lack of well-
documented information (e.g. Zigzag) or because of their unlikely viability in the
Bangladesh context (e.g. technologies based on non-fired brick). Therefore, the implications
of this analysis refer only to the technologies covered by this report.
Second, despite capturing a large portion of the impacts caused by brick kilns, the analysis
does not include some effects, such as the impacts of air pollution on the value of real
estate, on recreational areas, and on agricultural productivity. In addition, the negative
effects of pollutants other than PM (e.g., SO2 and NOx) and of the hard physical labor on
workers’ health could not be estimated. Because of these limitations, present estimates
should be regarded only as orders of magnitude.
Cost-benefit Analyzing
Estimating the net returns from each technology is based on the Cost-Benefit Analysis (CBA)
approach. The analysis measures the net returns from the private and social perspectives,
defined in Table-6.
The private (financial) CBA—analysis from the entrepreneur’s viewpoint—includes all costs
and benefits for the entrepreneur. Costs include investments (e.g., cost of buildings and kiln
chimney, land, other inputs, and taxes), while benefits comprise the value of brick
production. The costs and benefits are estimated at market prices. The analysis assumes that
the entrepreneur pays all of the above costs and receives all the benefits linked to brick
production.
The social (public) CBA—analysis from the social viewpoint—includes costs and benefits
from the private CBA, as well as the environmental and social impacts of brick kilns,
including the cost of GHG emissions and the health impact of air pollution. The costs and
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benefits from the previous step are estimated at real (economic) prices, while taxes are
eliminated.

Table-6: Valuation methods to estimate costs and benefits

Analysis
Costs and benefits Valuation method
type

Costs: Investment, land, buildings,

Market prices
Private operating costs, taxes

Benefits: Value of bricks Market prices

Costs:
Investment, land, buildings, operating Real prices
costs Disability Adjusted Life Years
Health impact of air pollution (DALYs)
Social
CO2 emissions International prices in carbon
Benefits markets

Value of bricks Real prices

Private Cost-benefit Analysis

The private cost-benefit analysis considers the direct costs and benefits for the entrepreneur,
estimated at market prices for 2009 (Table-7).
Table-7: Private Cost-benefit analysis (Sources: 2009 field survey, UNDP 2010, World Bank, 2011a)

Cost/benefit FCK IFCK VSBK HHK

Annual production (million bricks) 4.0 4.0 4.8 15

Area occupied by the kiln (bigha) 15 15 4 12
Costs (million TK/kiln) 119 109 106 386
Investment 4.4 7.4 6.4 55.7
Land 1.3 1.3 0.6 2.7
Buildings 0.0 0.0 0.7 9.1
Operations 108.7 95.3 91.5 300.0
Taxes and VAT 5.1 5.1 6.4 18.7
Benefits (million TK/kiln) 198 200 214 746
Net benefit (benefits minus costs) 79 91 109 360
Net benefit (TK/thousand bricks) 103 107 108 116
Payback period (no. years) 1.8 1.9 1.8 2.2
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This analysis does not capture the potential benefits from financing carbon emission
reductions obtained from adopting cleaner technologies, such as VSBK and HHK. World
Bank (2011a) estimated that an HHK provides emission reductions of 5,582t CO2 per year,
which corresponds to a financial annual benefit of TK75 million. If these values were added
to the private CBA analysis, the net benefit of an HHK would attain TK340 per thousand
bricks.
Social cost-benefit analysis
The social cost-benefit analysis includes (i) the direct costs and benefits, (ii) the health
impacts from PM-related pollution (PM2.5, PM10) and (iii) the cost of CO2 emissions from the
brick sector.
Direct costs and benefits. The market prices used for estimating the direct costs and benefits
are not distorted (e.g., subsidized), thus they can be considered economic or real prices.
Therefore, the social CBA includes all of the direct costs and benefits, as estimated for the
private cost-benefit analysis, excluding taxes and the VAT.
Health impacts from air pollution. Estimating the health impacts from pollution is a
complex task. The brick sector is one contributor to air pollution, along with transport and
other industries. Separating out the brick kilns contribution to pollution requires data on
pollutant emissions and dispersion patterns, which are not always available. Moreover, since
the North Dhaka brick cluster consists mainly of FCKs, such an exercise would estimate only
the FCK’s impact on health. Valuing the health impacts of the IFCK, VSBK, and HHK
requires even more precise data. In the absence such information, the most realistic
assumptions have been made for the purpose of this analysis.
The kilns’ contribution to the average PM ambient concentration depends primarily on their
particulate emissions and the brick production for each kiln type. Table-8 summarizes the
estimated impacts in annual and present value terms. The FCK is the most polluting
technology, causing annual health damages estimated at about TK0.9 per brick. By contrast,
the VSBK is the cleanest technology, with TK0.3 per brick.
Table 8: Summary of estimated health-damage cost from air pollution caused by brick kilns
Annual health damages Present value of health damages
Damage Damage
Kiln type Min Max Average Min Max Average
cost cost
(million
bricks) (million TK/kiln) (TK/brick) ( million TK/kiln) (TK/brick)
FCK (4) 2.5 14.0 8.2 2.1 20.6 117.1 69 0.9
IFCK (4) 1.3 7.1 4.2 1.1 10.5 59.8 35 0.5
VSBK (4.8) 0.9 5.7 3.3 0.7 8.3 47.4 28 0.3
HHK (15) 4.7 26.7 15.7 1.0 39.3 223.6 131 0.5

The Bangladesh Country Environmental Analysis reports that poor air quality in Dhaka city
(due to all polluting sources, including brick kilns, transport, road dust, metal smelters, and
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other causes) contributes to an estimated 3,500 premature deaths per year (World Bank
2006). While the 1,200 brick kilns north of Dhaka are an important contributor to air
pollution, their overall health impact has not been quantified. This analysis is limited to
estimating the health impacts of the North Dhaka cluster (530 kilns) in terms of PM 10 and
PM2.5 pollution only. Despite these limitations, the analysis shows that PM 10 and PM2.5
pollution from these 530 kilns currently leads to 750 premature deaths per year, accounting
for 20 percent of total premature deaths due to poor air quality.
It is interesting to estimate the avoided mortality and morbidity that could be achieved by
adopting alternative kiln types. Use of the VSBK would reduce current mortality by 63
percent, followed by 45 percent for the HHK and the IFCK (Table-9).
Table-9: Avoided mortality and morbidity by adopting alternative kiln types
IFCK VSBK HHK
Factor
(4 mill.) (4.8 mill.) (15 mill.)
336 cases 469 cases 336 cases
Mortality no. cases (percent)
(45%) (63 percent) (45 percent)
Morbidity
Chronic bronchitis (PM10) (no. cases) 0 0 0
Hospital admissions (PM10) (thousands of cases) 2 2 2
Emergency room visits (PM10) (thousands of cases) 32 44 32
Restricted activity days (PM10) (millions of cases) 3 4 3
Lower respiratory illness in children (PM10) (thousands) 145 200 145
Respiratory symptoms (PM10) (millions of cases) 9 12 9

Cost of CO2 emissions. This cost is based on the CO2 quantity emitted annually by each type
of kiln and the average price on the carbon market. The FCK has the highest unit cost per
brick (TK4.2), primarily because it has the greatest specific coal consumption among the
selected technologies. By contrast, low coal consumption (TK2.5 per brick) makes the
VSBK and the HHK the cleanest technologies in terms of CO2 emissions (Table-10).
Table-10: Estimated annual cost of CO2 emissions by kiln type and brick (2009)
FCK IFCK VSBK HHK
Factor
(4 mill.) (4 mill.) (4.8 mill.) (15 mill.)
Total brick production (thousand kg-bricks) 11,600 11,600 13,860 104,580
Coal per 100,000 bricks (t) 22 15 13 13
Specific energy consumption (TJ/kg-brick) 0.0019 0.0013 0.0012 0.0009
Carbon emission factor (tC/TJ) 25.8 25.8 25.8 25.8
Carbon to CO2 conversion factor 3.66 3.66 3.66
CO2 per kiln per season (t) 2,134 1,507 4,710
CO2 per100,000 bricks per season (t/100,000
53 36 35 31
bricks)
Price CO2 (US$/t) 13.5 13.5 13.5
Cost of CO2 emissions (thousand TK/kiln/year) 2,017 1424 4,451
Cost of CO2 emissions (TK/brick/year) 0.50 0.34 0.30 0.30
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Cost of CO2 emissions (TK/brick, present value) 4.2 2.9 2.5 2.5

Results of the social CBA. Table-11 presents the social CBA and expresses the results in
terms of net benefits per thousand bricks. The analysis shows that VSBK and HHK are the
most socially profitable technologies, with net benefits of TK68-75 per thousand bricks. In
contrast, the high costs of air pollution and CO2 emissions make the FCK socially
unprofitable.
Table-11: Social cost-benefit analysis, 2009 (Sources: 2009 field survey, UNDP 2010, World Bank, 2011a)
Costs/benefits FCK IFCK VSBK HHK
Annual production (million bricks) 4.0 4.0 4.8 15
Area occupied by the kiln (bigha)* 15 15 4 12
Costs (million TK/kiln) 200 151 139 536
Investment cost 4.4 7.4 6.4 55.7
Cost of land 1.3 1.3 0.6 2.7
Cost of buildings 0.0 0.0 0.7 9.1
Operating costs 108.7 95.3 91.5 300.0
Health impacts of pollution 68.8 35.1 27.8 131.5
CO2 emissions 16.9 11.5 11.9 37.2
Benefits (million TK/kiln) 198 200 214 746
Net benefits (million TK/kiln) -2 49 76 210
Net benefits (TK/thousand bricks) -3 43 75 68
Economic IRR (%) 30 84 123 59

Relevant National Environmental Laws

Brick Burning Act

Till 1988, brick making was an unregulated industry in Bangladesh. The government has
introduced some measures of control by legislating the “Brick Burning (Control) Act 1989
(Act #8 of 1989) on February 12, 1989. The main goal of the Act was to eliminate the
unrestricted and rampant use of wood fuel in brick kilns. As a first step, it was necessary to
bring brick kilns within the purview of the law and greater scrutiny. This was done by
introducing registration and permitting requirements. The Act was amended in 1992 and
again in 2001. Each amendment sought to tighten the regulations and introduce a greater
measure of emissions restrictions. The Act forbade establishing a kiln within 3 km from an
upazila headquarter (smallest administrative unit) boundary limit or clusters of homesteads
numbering more than 50 homes or fruit garden having 50 trees. The Table-12 provides
chronological evolution over the last two decades.
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Table-12: Evolution of laws in the brick sector

Year Description
1989 Brick Burning Act, 1989 - without brick burning license none can burn bricks.
Amendment of Brick Burning Act- banning of wood burning in brick kiln, licensing
authority to District Commissioner instead of Upazila Chairman, inspection authority
1992
without prior notice, banning of bricks and firewood (if firewood used), BDT. 50,000
fine instead of BDT. 10,000.
Circular regarding postponement of license for brick kiln due to huge sulfur deposition
1999
from coal burning in brick kilns.
Amendment of Brick Burning Act-defines inspection committee, expands definition of
firewood, brick kiln location (no brick kiln within 3km range from the periphery of
2001
Upazila main town, forest (area having at least 50 trees), city town, municipality,
residential area).

2002 Circular- Mandatory requirement of 37 meter (120 feet) high chimney in brick field

Circular- Banned the operation of Bull’s Trench Kilns (BTK) and Moveable Chimney
2004
Kiln (MCK)
Circular- After December 31, 2010 renewal of clearance of existing FCK will be
2006
stopped – owners are requested to switch over other clean technology

According to the act, the Deputy Commissioner is responsible for issuing a license for brick
burning after receiving a local committee (Additional Deputy Commissioner, Upazilla Health
Administrator, Environment/Forest Official and Union Parishad Chairman) report. The
license is issued for three years and the Deputy Commissioner can cancel a license if any
violation of act is noticed. However, the brick owner is given opportunity to justify his/her
position. This act provides authority to the Deputy Commissioner or his/her representative to
inspect the brick fields without prior notice and seize all bricks, equipment’s etc. if the
brickfield uses firewood or operates without license. The act also has provision of
imprisonment up to one year, or with a fine up to BDT. 50,000, or with both punishments.
All the brick entrepreneurs requires license from the Deputy Commissioner for setting-up and
continuing brick production and have to ensure there is no use of firewood in brick burning.
Old technologies like BTK and FCK cannot be used anymore and there is an urgency to
move towards cleaner technologies.

Bangladesh Environmental Conservation Act (ECA), 1995

The Environmental Conservation Act (ECA) of 1995 is the main legislative framework
document relating to environmental protection in Bangladesh. This umbrella Act includes
laws for conservation of the environment, improvement of environmental standards, and
control and mitigation of environmental pollution. This Act established the Department of
Environment, and empowers its Director General to take measures as he considers necessary
which includes conducting inquiries, preventing probable accidents, advising the
Government, coordinating with other authorities or agencies, and collecting & publishing
information about environmental pollution. According to this act, no industrial unit or project
shall be established or undertaken without obtaining, in a manner prescribed by the
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accompanying Rules, an Environmental Clearance Certificate from the Director General.

This procedural requirement needs to be followed.
Bangladesh Environmental Conservation Rules (ECR), 1997
The Environment Conservation Rules, 1997 were issued by the Government of Bangladesh
in exercise of the power conferred under the Environment Conservation Act, 1995. Under
these Rules, the following aspects, among others, are covered:

 Declaration of ecologically critical areas;

 Classification of industries and projects into 4 categories.
 Procedures for issuing the Environmental Clearance Certificate, (iv) Procedures for
issuing the Pollution-Under-Control Certificate (v) Determination of environmental
standards.
The Environmental Conservation Rules (ECR) contains the procedures for obtaining
Environmental Clearance Certificates (ECC) from the Department of Environment for
different types of proposed projects. As per Schedule-I of ECR 1997, brick making projects
have been classified as Amber–B category and require Initial Environmental Examination
(IEE). ECR also explains the environmental clearance process.

World’s Banks Environmental Safeguards

OP 4.01 Environmental Assessment

The Bank requires environmental assessment (EA) of projects proposed for Bank support to
ensure that they are environmentally sound and sustainable, and thus to improve decision
making. EA is a process whose breadth, depth, and type of analysis depend on the nature,
scale, and potential environmental impact of the proposed project. EA evaluates a project’s
potential environmental risks and impacts in its area of influence; examines project
alternatives; identifies ways of improving project selection, siting, planning, design, and
implementation by preventing, minimizing, mitigating, or compensating for adverse
environmental impacts and enhancing positive impacts; and includes the process of mitigating
and managing adverse environmental impacts throughout project implementation.

OP 4.04 on Natural Habitats

The conservation of natural habitats, like other measures that protect and enhance the
environment, is essential for long-term sustainable development. The Bank therefore supports
the protection, maintenance, and rehabilitation of natural habitats and their functions in its
economic and sector work, project financing, and policy dialogue. The Bank supports, and
expects borrowers to apply, a precautionary approach to natural resource management to
ensure opportunities for environmentally sustainable development. The Bank promotes and
supports natural habitat conservation and improved land use by financing projects designed to
integrate into national and regional development the conservation of natural habitats and the
maintenance of ecological functions. Furthermore, the Bank promotes the rehabilitation of
 P a g e | 16

degraded natural habitats. The Bank does not support projects that involve the significant
conversion or degradation of critical natural habitats.
Of the two environmental safeguard policies that are relevant to this project, only OP 4.01 on
Environmental Assessment is triggered. From the initial assessment, it has been confirmed
that kiln will be set-up around pre-urban areas, which will not involve any impact on critical
natural habitats.

Barriers facing the brick sector in Bangladesh

The barriers that have contributed to the current state of the country’s brick sector and its
inability to bring about changes include

 Lack of supporting regulations, fiscal incentives and standards to encourage more

energy efficient practices and technologies. Except for some efforts to regulate the
sector, the government has made little effort to establish effective boundary limit
emission standards;
 Little and no governmental activity to assist the brick sector to undertake
comprehensive programs so as it to make it cleaner and more profitable. Brick owners
usually were left to bring in changes of their own which they have often failed to do,
because of the vicious cycle of low efficiency – low income.
 Lack of knowledge and access to energy efficient technology, which can lower
production costs at the same time. Comprehensive dissemination programs that
demonstrate the potential economic benefits of energy efficient technologies have yet
to be carried out.
 Lack of access to liquidity to finance modernization of brick making operations. As
traditional brick kilns have seasonal employment, they have not been included in the
list of recognized SMEs and thus, are not eligible for concessional SME loan
windows.
 Lack of capacity in terms of technical and business skills at the enterprise level that
could bring changes towards improved efficiency and reduced pollution.
 Limited experience of commercial lending institutions with SMEs and in particular,
brick SMEs.
(Source: UNDP, 2010)

Conclusion
Bangladesh’s brick sector is characterized by outdated technologies with low energy
efficiency and high emissions, low mechanization rate, dominance of small-scale brick
industries with limited financial capacity, and dominance of single raw material (clay) and
product (solid clay brick). Adopting gas-based cleaner technologies is hampered by serious
energy shortage and land scarcity.
How long can the country afford making bricks in this way? The current status is by no
means sustainable. Bangladesh has every reason to upgrade its brick sector in order to save
valuable natural resources, reduce air pollution, and increase energy efficiency. The
 P a g e | 17

government has already established regulations that ban the use of fuel wood and FCKs and
has reconsidered the location and height of brick kiln chimneys. However, transformative
development of the brick industry has yet to occur.
The development of the brick industry in Bangladesh over the next 20 years should aim at: (i)
moving from traditional brick-making technologies (e.g. FCK) to cleaner ones (e.g. HHK,
VSBK); (ii) diversifying products (e.g. hollow and perforated bricks) and finding alternative
raw materials that are locally available; (iii) increasing the proportion of large-scale
enterprises with higher capacity to adapt to cleaner technologies.

Recommendation
Short Term
 Recognize brick kilns as a formal industry. This would enable easier access to
financial resources (which in turn will enable investment in cleaner technologies and
access flood free land) and improved working conditions.
 Create a Brick Technology Center to raise awareness about the benefits of cleaner
technologies. The center should: (a) disseminate information on the social benefits
provided by cleaner technologies, new wall materials (e.g. perforated and hollow
bricks) and alternative raw materials; (b) promote pilot projects of new technologies
with improved provisions (e.g., mechanized, higher labor productivity and larger
product lines); (c) improve use of existing dissemination channels (e.g., field visits to
pilot plants, video demonstrations of the technologies, use of the Bangla language)
and introduce new channels (e.g., newsletters, industry journals, conferences, and
Internet blogs).
 Support research and development aiming at: (a) exploring alternative raw materials
that are locally available, brick diversification, and use of higher level of
mechanization; (b) conducting new studies such as energy consumption studies, land
surveys, and brick technology surveys.
 Facilitate the availability of subsidized credit lines to account for reduced health
impacts from pollution and of other economic incentives supporting the production
of new wall materials and use of alternative raw materials (e.g. via specific funds and
preferential tax policies, as in China).
 Provide access to carbon markets, on account of the carbon emission reductions
provided by cleaner technologies.
 Train several stakeholders with regard to the benefits of adopting cleaner technologies
(e.g. brick owners, workers and the financial sector).
Medium Term

 Enforce the existing regulations and policies, such as the ban of traditional high
polluting kilns (e.g. FCK, BTK), particularly those located close to large population
centers, upstream of the wind (north) in the dry season (November to April).
 Introduce regulations and policies that encourage adoption of cleaner technologies,
such as: (a) revise emissions standards for brick kilns under ECR97 to make them
 P a g e | 18

technology independent and to encourage brick diversification (e.g., perforated or

hollow bricks for partition walls); (b) establish proper emission monitoring for brick
kilns; (c) impose an emission levy based on “polluter-pay principle”; (d) design rules
and standards for the entire brick value chain: from raw materials to production
processes and equipment and final products to building designs and construction
processes.
 Develop industrial parks to accommodate a large number of industries on flood-free
land. These parks would mean less cost for kiln owners, due to the economy of scale
achieved by providing the basic infrastructure for all kilns (e.g. roads, electricity,
water) and other facilities (e.g. schools for the employees’ children). They would also
require less land for kilns establishment compared to the current situation.
 Improve working conditions by introducing higher levels of mechanization, social
programs to reduce child labor, occupational safety and health measures in kilns.

Reference
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 Bayron, R.K. (2009, December 13). Brick kilns going green. The Daily Star.
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brick-technique helps-build-a-cleaner-bangladesh.html.
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 UNDP. (2011, June 20). Eco-friendly brick technique helps build a cleaner
Bangladesh. Retrieved from
http://www.beta.undp.org/undp/en/home/presscenter/articles/2011/06/20/ecofriendly-
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