Environmental audit Report of EMI 1

Environmental Protection Authority

Environmental Audit Report on Ethiopian

Marble Processing Enterprise

January 2004

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Environmental audit Report of EMI 2

Table of Contents

1. Executive Summary……………………………………………………………..4
2. Introduction……………………………………………………………………….6
3. Industry description……………………………………………………………...8
4. Audit Objective, scope and criteria…………………………………………….9
5. Audit process/ Audit Methodology…………………………………………….10
6. The audit team ………………………………………………………………….10

7. Initial Review/ Review of current environmental management and

mitigation practices in the factory……………………………………………….11

7.1 Water Quality Management…………………………………….11

7.2 Air pollution control………………………………………………12
7.3 Solid waste Management ………………………………………13
7.4 Control of Noise emission ……………………………………...13
7.5 Occupational Health and Safety Management………………13
7.6 Storage, Handling and Transportation………………………...14
7.7 Disaster Management…………………………………………..14
7.8 Energy Conservation…………………………………………….15

8. Compliance Audit………………………………………………………………...15
8.1 Environmental Performance and Comparison of Air, Water
and Sound quality with standards………………………………………...15
8.2 Audit Findings / Audit results………………………………………………17

9. Due-diligence audit……………………………………………………………....20
10. Conclusion and Recommendations ……………………………………………21
Annexes ………………………………………………………………………….23

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Executive Summary
1. Background
he Ethiopian Marble processing enterprise mainly produces various types of
polished marble products that are used for building and construction purposes.
In addition the factories also produce tiles and marble chips of different sizes
and qualities from its by-products. The enterprise consists of three factories.
These factories are located at three different sites in Addis Ababa city. The
largest of the three is Gulele, and Bole is the second largest branch. The
factory at Nefas silk, where the head office of Ethiopian marble processing
enterprise is situated, is the third branch. All the three factories were
established during the late 1950s and early 1960s by Italian investors. The
factories had been in operation for more than three to five decades now and
they represent among the foremost industries in Ethiopia.

2. Objective of the audit

The principal objectives of the environmental audit were to assess the extent
of compliance of the enterprise with national legislations pertaining to
pollution, public health, occupational safety and water resources utilization.

3. Audit methodologies

The methodology adopted by the audit team was multi layered. Initially, a
quick review of the environmental management practices of the enterprise
was undertaken. Detailed site visits in all three factories were conducted at
different days to physically observe and inspect the environmental
performance as well as health and safety aspects of the factories. Key
personnel of the factories were also interviewed. An audit questionnaire was
developed and filled for each branch by the enterprise. Effluent discharged
from factories were sampled and analysed for suspected parameters. Noise
level at the factory sites were measured

4. The nature of the enterprises

The nature of marble industry as a whole is that the major inputs used for
production does not present high environmental risk in terms of posing
persistent contamination or pollution to land or water bodies. The main raw

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materials are natural marble blocks and cooling water. Electrical energy is
consumed to process the marble, but it is produced some where else. Water
pollution, that could have been created in the Kebena and Akaki rivers by the
release of wastewater from the Gulele and Bole factories in the past and
which can continue to exist in the future unless the enterprise takes
appropriate measures, is the only environmental aspect that needs careful
consideration interms of environmental liability. The stress to the aquatic
environment from the marble slurry arises not from some persistent toxic
constituents, but from its physical suspension property in the river water which
disturb the aquatic environment. The stress put on the rivers can be eliminated
once discharging the wastewater into them is stopped. Therefore, the audit
team concluded that the three site holdings as defined by the official site map
of the enterprise were entirely used for marble production through out the
whole period, implying the absence of any serious environmental liability to the
enterprise

5. Technology used

Some of the machines on use in the enterprise are old, but the enterprise is on
process to rehabilitate the factories by equipping with modern machineries.

6. Content and amount of pollutants

Effluent discharged from the factories was measured in the laboratory for
specific parameters. The result for total suspended solids before and after
treatment were as follows; for bole 13.81gm/L &0.5 gm/L, for Gulele branch
2.48gm/L & 0.005gm/L, for Nefas silk 24.6 gm/L & 0.065 gm/L. Noise level of
the factories were also measured at 75 m. and 66.4, 64.5 &64 dB was
recorded for Gulele, Bole& Nefas silk branches respectively at day time.

7. Contingency plan in case of accidents

The factory has insurance for industrial Accident and occupational safety of
the workers.

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8. Reaction of Auditee

The management body of the enterprise accepted the non compliance area
and promised to improve the environmental Conditions of the factories.

9. Next step

Bilateral signing of an agreement between the enterprise and Environmental

Protection Authority (EPA) is required in order to implement Environmental
management system with in the enterprise.

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2. Introduction

Following the economic liberalisation measures taken by the Government in the past
decade, Ethiopia has been engaged in the privatization process of public enterprises.
The Ethiopian Privatization Agency, a public organization with a sole responsibility of
executing the transfer of enterprises into the private sector through various
arrangements, was preparing twenty enterprises grouped under tranch-V for
privatization. The privatization preparation of the twenty enterprises in Tranch -V was
financially assisted by the African Development Bank through a Privatization
Technical Assistance (PTA). A measure component of the PTA project was to
undertake the Environmental Audit of the enterprises in Tranch -V. The
Environmental Protection Authority of Ethiopia (EPA) was assigned to carry out the
Environmental Audit of the enterprises as per the agreement entered in the contract.
EPA engaged resources and mobilized several teams of experts for carrying out the
task.

The Ethiopian Marble processing enterprise was one of the tranch - v enterprises that
were to be audited. In order to accomplish the auditing task a team of three auditors
was constituted by EPA that consists of one chemical engineer and two chemists.
Despite the absence of any form of environment management systems in the
factories, which in effect was complemented by the absence of comprehensive
pollution control legislation until recently, the audit team has performed initial review,
compliance and due diligence audits of the factories to reflect the existing
environmental reality. This report presents the work of the audit team.

The essence of compliance audit is basically to show the level of conformity of

industries against the national environmental standards and legislations.
Environmental legislations were promulgated in Ethiopia only very recently. Moreover
environmental standards are being introduced. Their enforcement is underway, but

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not yet at full-fledged. Therefore, since the present report is the first environmental
audit report for the enterprise it will focus on identifying the

areas of potential non-compliances and objectively reflect it with the aim of showing
opportunities for improvement by the enterprise. In the process of monitoring future
improvements to be made by the enterprise, the initial review and compliance audit
components of this report could also be used as a bench marking information to
measure progresses made.

The first 6 chapters of this report presents a brief description of the Ethiopian Marble
Processing Enterprise and continues to outline the audit objectives, criteria’s and
methodologies adopted to perform the audit. Chapter 7 deals with the initial review
audit details. The section mainly describes the fundamental observations made
during the initial review exercise. The next chapter makes a comparison of the
important environmental aspects as well as other issues with the draft national
environmental standards and legislative requirements to indicate areas of compliance
and non-compliances. The issues of preaquisition audit are dealt with in chapter 9.
Finally the report concludes by forwarding recommendations that are helpful to the
enterprise.

3. Industry Description

The Ethiopian marble processing enterprise consists of three factories. These

factories are located at three different sites in Addis Ababa city. The largest of the
three is Gulele branch, and it is found in Gulele area in woreda 25 Kebelle 02 and in
woreda 8 kebelle 06. A river flows through the middle of the factory premises
dissecting it in to two so as to lay in both woredas. The second biggest factory of the
enterprise is the Bole branch which is situated along the Kebena River bank in
woreda18 Kebelle 36. The factory at Nifas silk area, where the head office of
Ethiopian marble processing enterprise is situated, is the third branch. All the three
factories were established during the late 1950s and early 1960s by Italian investors.
The factories had been in operation for more than five decades now and they
represent among the foremost industries in Ethiopia. With the emergence of the

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previous regime and its socialist economic policies, the factories were nationalized
during mid 1970s and were organised under one institution named Ethio-marble
Industry. Later in 2001/02, the industry was re-established by proclamation number
166/1993 as an enterprise with its present name. With the assistance of UNIDO
major expansion and renovation work was carried out in the Gulele branch during
1975-86, which resulted in boosting up the production capacity of the branch.

The Ethiopian Marble processing enterprise mainly produces various types of

polished marble products that are used for building and construction purposes. In
addition the factories also produce tiles and marble chips of different sizes and
qualities from its by-products. The daily finished marble production capacity of
Gulele, Bole and Nefas silk branches are estimated to be 120, 45 and 40 square
meters respectively. The 2002/03 annual production of the factories in the enterprise
is shown in table-1 below. The total number of employees of the enterprise is around
660, out of which more than 300 employees are on temporary basis.
Table 1: Quantity of Production for the year 2002/03

No. Type of product Producing Branch Unit Annual Quantity

Produced during
2002/03
1 Marble (Harar Limestone, and Gulele m2 31041
Gojam)
2 Marble (Harar Limestone, and Nefas silk m2 12345
Gojam)
3 Marble (Harar Limestone, and Bole m2 10,000
Gojam)
4 Granilia Tiles Gulele m2 84822
5 Granilia tiles (Zocolo) Gulele m2 67157
6 Marble chips Gulele m2 5925
7. Marble chips Bole m2 ( )

4. Audit Objective, Scope and Criteria

The principal objectives of the environmental audit are:

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 To assess existing practices and identify information gaps

 To assess the extent of compliance of the enterprise with national legislations
pertaining to pollution, public health, occupational safety and water resources
utilization

In order to achieve the above stated objectives, audit criteria were set based on the
pertinent national legislations and standards of the country. The appropriate
provisions and requirements of the following national legislations and standards were
considered as the main criteria during the audit.
 Environnemental Pollution Control Proclamation No.300/2002
 Public Health Proclamation No.200/2000
 Ethiopian Water Resources Management Proclamation 197/2000
 Labour Proclamation No. 42/1993
 Provisional Standards for Industrial Pollution Control in Ethiopia

The scope of the audit covers all factory sites, production processes and other
operational units associated with the audit criteria. Prior to the commencement of the
audit its objectives and criteria were communicated to the enterprise management.

5. Audit Methodology /Audit process

The methodology adopted by the audit team was multi layered. Initially an opening
meeting was held with the enterprise’s management at the head office on 4/9/95 E.C.
Following that immediately a quick review of the environmental management
practices of the enterprise was undertaken and important environmental aspects
were identified. Detailed site visits in all three factories were conducted at different
days to physically observe and inspect the environmental performance as well as
health and safety aspects of the factories. Key personnel of the factories were also
interviewed. An audit questionnaire was developed and filled for each branch by the
enterprise.

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The audit team have convened meetings, among others, with Ato Tsegaye Belete
and Ato Asefa Terefe who are Acting General Manager and Production and technical
managers of the enterprise respectively.

6. The audit team

The audit team has the following members.

Name Profession Role in the team

1. Zereu Ghirmay Chemist Lead Auditor
2. Said Abdella Chemical Engineer Auditor
3. Habtamu Wodajo Chemist Auditor

7. Initial Review /Review of environmental aspects and current

environmental management practices in the factory/.

7.1 Water Quality Management

a) Gulele branch

The production operations of the enterprise as a whole utilize large volume of water.
The Gulele branch utilizes municipal water supply and water harvested from a bore
hole found within the factory as the main sources of its cooling water used in block
cutting, polishing and size cutting operations. Daily cooling water consumption of the
Gulele factory is not quantified. Wastewaters from production lines are channelled
through open ditches to the settling ponds. The branch owns one modern wastewater
treatment plant, which consists of a series of systematically partitioned ponds to
allow settling of the suspended particles. This treatment plant was installed together
with the modern production facilities by the expansion project conducted in 1986.
There is also another settling pond that was part of the old section of the factory.
Both treatment plants were not observed to operate at the time of visit. Operational
controls of the treatment plant and the settling pond are not in place. Wastewater
from the processing lines of the factory is discharged into the Akaki River. Since the

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river passes through the middle of the factory premises, the discharge points are
observed to be within the compound of the factory. A typical such discharge point is
found nearby the bridge joining the two parts of the factory.

b) Bole branch

In addition to municipal water supply, the bole branch pumps up the gorge water from
the River Kebena for use in its production process. The factory estimate of daily
cooling water consumption is 39m3, whereas the daily total process water
consumption is 66 m3. Wastewater from the process lines is collected through an
open ditch to the settling pond at the back of the factory. The settling pond is situated
just at the bank of the Kebena River. The wastewater flow across the ponds down
into the river with most of its suspended slurry. The operation of the ponds is not well
Managed and controlled on a continuous and periodic basis.

c) Nefas Silk branch

Unlike the other two branches, in the Nefas Silk branch, municipal water supply is the
main source of process and cooling water used in Block cutting, polishing and size
cutting operations. Daily cooling water consumption is not quantified. Wastewater
from cooling operation is discharged to shop floor from each unit and is directed
towards a small pond with out a bund. There is a very small pond (settling pond) that
receive the wastewater discharge. The pond is meant to recycle the wastewater, but
its size, location and current mode of operation makes it unsuitable for the purpose.
The pond does not have an outlet and is very closely surrounded by residential
houses on the back side of it. Sludge settled in the pond is collected by labourers
manually. There is apparent lack of consistent and proper wastewater management
scheme in the factory.

7.2 Air Pollution Control

Air pollution as environmentally significant aspect is common to three of them. The

main sources of air pollutants in all the three factories are the crushing operation and
marble powder dust arising from the dry sludge left unattended in the factory

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premises. Marble by products salvaged from the main process lines are down sized
to gravel by the crusher machines. The crushers operate in the open air and have no
installations to control dust release. Crushing of scrape marble stones is mainly
conducted in the Gulele and Bole branches resulting in proportionally higher dust
release, though the problem in Nefas Silk branch need not be undermined. On the
other hand in all the branches dry marble powder dust is also left open and spread
on the grounds, and thus is carried by wind.

7.3 Solid Waste Management

The practice of process solid waste management in Gulele and Bole branches is
similar. Solid sludge excavated from the bed of the settling ponds is one of the major
process solid wastes. The settling ponds in Gulele and Bole factories are manually
cleaned and the resulting sludge deposited on the nearby places at the river banks of
Akaki and Kebena respectively. As a matter of fact, in the Gulele branch, the sludge
is poured into the River Akaki. Similarly, at the Nefas Silk branch, the sludge from the
small pond is collected just outside it. At later stages, when dried, it is dispersed on
the nearby grounds of the factory. Other process solid wastes of the three factories is
scrapes of marble stones, but the enterprise claims that it is a raw material for other
products like marble chips and do not want to consider it as process solid waste.
However, the premises of all the factories are invariably covered by scrape marble
stones and dried sludge powder. They all present a great aesthetic loss to their
respective surrounding.

7.4 Control of Noise Pollution

Noise pollution is another most significant environmental aspect of the enterprise as

a whole. High level noise is created whenever the crushers, block cutters, and size
cutter machines operate in the factories. The factory at Nefas Silk, in particular, is
situated amidst residential areas in close distance. Records show that, already

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several complaints were made by the neighbourhood against the noise pollution. The
machines in the factories operate in open workshops and because of their
obsolescence release high level noise. Exceptions to this are the latest machineries
installed by the 1986 expansion project at Gulele branch. Noise pollution control
mechanisms are only practiced in the enterprise by limiting working hours to day time
only.

7.5 Occupational Health and Safety Management

The important factors that cause occupational health and safety hazards within the
enterprise factories which affects workers in production lines are noise, dust and
mechanical accidents. In all the three high decibels noise are created whenever the
crushers, block cutters, and size cutter machines operate. The enterprise provides
personal protection equipments to the workers. These include dust protection masks,
sound dumper masks, rubber gloves and helmets. Records also show that the
enterprise had been inspected at the end of 1994 E.C by occupational safety and
health inspectors of the Addis Ababa labour and social affairs bureau. The workers,
however, were not observed to use the personal protection equipments while on duty
in neither of the factories. There were no records found in the enterprise that indicate
regular training on occupational safety and hazard prevention given to workers.
At the Bole branch an additional occupational health hazard is posed to the workers
that come into physical contact with the cooling water of the size cutting & polishing
machines. The water pumped from the Kebena River is obviously highly
contaminated by domestic wastes including sewage.

7.6 Storage, Handling and Transportation

Handling and storage of raw material blocks is not well organized in all three factories
of the enterprise. Finished marble products of marble are also stored unorganized in
spaces with light fencing. The improper spread of scrape marble stones within the
production areas of the factories is common in all of them and indicates bad
housekeeping. Scrape marble stones are also found piled up in places that are not
suitable for the purpose (e.g. along side the main access road into Bole branch).

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Open grounds in the production premises are full of fragmented marble stones and
presents a great aesthetics loss to the area.

7.7 Disaster Management

The likely occurrence of fire hazard event due to use of processing inputs (e.g. use of
explosive or inflammable chemicals) is minimal. This is attributed to the nature of the
industry itself. However, in case of the Nefas Silk branch, the location of the factory is
such that it is not easily accessible to fire fighting brigades in case of fire emergency
situation that could be induced from the surrounding areas.

On the side, huge marble blocks (raw materials) are lifted down from vehicles with
the help of electromechanical cranes. The same marble blocks are also transported
into the production lines using the same overhead cranes. Even though the audit
team didn’t find any documented case of accident, this operation remains to be an
area of high risk for workers. Moreover, lax operational procedures can lead to
disasters within the factory’s crane operation area and block cutting areas.

6.8 Energy Conservation

Electrical energy is the mover of the production machines in the enterprise. Cranes,
Block cutters, sizing and polishing machines, and pumping motors all consume
electric energy. There were no attempts that were made to increase the efficiency of
energy use by these machineries in the enterprise. In times of power black outs, an
alternative diesel engine is used to supply power.

8. Compliance Audit

8.1 Environmental Performance and Comparison of Water and Sound quality

with standards.

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The audit team have taken measurements to elucidate the water and sound quality
management performance of the factories in the enterprise and compared them
with the values in the draft National standards. Standards for the Marble Industry
sub-sector are not treated as the other industrial sub-sectors in the draft National
industrial emission standards. However, the draft emission standards have
contained general standards which can be used for industrial sub-sectors not
treated separately. For this reason, relevant parameters from the draft general
emission standards and ambient quality standards are used for comparison. It is
worth to mention at this stage that, the draft standards for industrial emission and
ambient environmental quality standards were introduced by EPA while this audit
exercise was in progress. Therefore, factories are not yet fully required to comply
with the standards immediately.
Table 2: Comparison of factory wastewater quality with general emission standard
Factory effluent quality
Para Draft (mg/l)
meter emissio Gulele Bole Nefas silk Comments

type n
G1 G2 B1 B2 N1 N2
quality
standar
d (mg/l)
1 PH 6-9 8.4 7.9 8.4 7.8 8.7 8.4 Acceptable
2 SS 100 2480 5.0 13810 500 24600 65 Non acceptable for bole
case
3 TDS 3000 121 106 238 236 471 454 Acceptable
4 Mg 100 4.4 2.4 17.1 8.3 14.6 10.2 Acceptable
5 Ca 100 12 11.2 32 29.6 56.8 48 Acceptable
Note: All units are in mg/l except for PH

Effluent discharged from the three branches were sampled and analysed for P H, Total
dissolved solids, Total suspended solids, Calcium and magnesium before and after
treatment. After treatment all parameters Except total suspended solids are below
the permitted limit of discharge.
Total suspended solids for all of the factories is very high before treatment of the
effluent and in the permissible limit of discharge for Nefas silk & Gulele branches.
Total suspended solids for bole branch is high after treatment. The reason in the

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cause of bole branch is during the time of sampling the wells were filled with slurry
and not cleaned, the untreated effluent mixed up with the treated once.
Comment:-
 all the wells need to be cleaned at appropriate time to enable the settling of
slurry
 all the existing wells needs maintenance at appropriate time
 additional well is required for nefas silk branch
 the slurry collected from cleaning operation of the wells must be disposed in
appropriate disposal sites.

Table 3: Comparison of factory noise quality performance with ambient noise standards.
Level of Sound Ambient Noise Standard
No. Type of measurements ( dB ) (dB)
commerc Residenti Industri Remark
ial area al area al area
Gulele

Nefas
Bole

Silk

1 Inside the factory 66.4 64.5 64 65 55 75

(75meter)
2 Outside the factory 65 55 75
(150meter)
Note: All measurements and standards are for day time.

Noise generated by the three factories were measured in side the factory at 75
meters. All results are in the range of the limit for commercial area.
All the factories are located in semi Commercial and Slightly residential areas,
specially the Nefas silk branch factory is located 30 meters from the residential area.
Since there is high car & air traffic noise, welding machine noise etc in the
surrounding of the factories it was not convenient to measure the noise of the
factories out side the campus.

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Comment the factory, specially nefas silk branch is recommended to find a means of
controlling system to interrupt the transmission path ways for the noise generated to
bring in to the permit level for the residential area.

8.2 Audit Findings/ Audit results

The overall environmental performance of the enterprise was evaluated against the
relevant and pertinent articles in the criteria legislations and the main audit findings
were identified. The resulting audit findings are summarized in tabulated form as
follows (see table 4).

Table 4: Summary of audit results.

Main Compliance
No. Environnemental Criteria Provisions in legislation Comments
and other
Gulele

Nefas
Bole

aspects

a) Environnemental Pollution
1 Prevention of control proclamation

Pollution No.300/2002, Part 2, Art.3

(1), Part 3, Art. 6(a to e)
and the Draft
emission/ambient
standard.
b) Public Health
Proclamation
No.200/2000, Part 4,
Art.10 (3), 11(2), 12(1)
and 12(2).

Wastewater treatment ponds

1.1 Water quality in Gulele and Bole branches
management
x x x are not fully operational and
not monitored. Process

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wastewater is directly
discharged into rivers. The
“ “
location, size and operation of
the settling pond in Nefas Silk
branch is inconvenient for the
work.

1.2 Air pollution Dust is released from the

control “ “ x x x operation of the crusher at
large quantity in all the three
branches. Dust from the
unattended dry powder of
sludge is also dispersed into
ambient air by wind.
Waste sludge is not properly
1.3 Solid waste collected and disposed. It is
Management “ “
x x x deposited within the premises
in Nefas Silk branch. Also
sludge is spread in the rear
parts of the Gulele and Bole
factories. Other marble
scrape stones are spread all
over the grounds in all
factories. All of the
unmanaged process solid
wastes in the factories
present a huge aesthetic loss.
The noise released during the
1.4 Control of Noise operation of production
emission “ “ x x x machines is quiet high and it
is nuisance for the
surrounding households.
Domestic solid waste is
1.5 Sanitary Waste √ √ √ collected properly and
Management “ “ sanitation facilities are
available in all three factories.
However, the unsanitary river
water used in Bole branch for
cooling machineries is an

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exception to this
generalization.
1.6 Permit to Ethiopian Water Resources According to the proclamation
discharge Management Proclamation any person discharging
wastewater into No.197/2000, Part 4; Art.11(1d) x x _ wastewater into inland water
water bodies bodies should obtain permit
from the ministry of water
resources. The enterprise
was unaware of its
requirement for having such
permit to be able to discharge
wastewater into the rivers. It
has never applied to obtain
the permit.

2 Occupational Labour Proclamation

Health and No.42/1993, Part 2 section 3,
Safety Art.12(4), 14(1e), 14(2e), Part 7
Management chapter 1, Art.92(2), 92(3),
92(4), 92( 6)
2.1 Provision of The enterprise provides to
personal workers the required personal
protection Part 7 chapter 1, Art.92(3) √ √ √ protection equipments.
equipments to However, workers were not
workers observed to use it in all
factories.
2.2 Provision of Workers are not trained on
training on occupational safety
occupational Part 7 chapter 1, Art.92(2) x x x procedures and hazard
safety protection prevention. No record
to workers available on training delivery
in the enterprise.
2.3 No documented record was
found that communicate
Disaster standard operational
Management Part 7 chapter 1, Art.92(6) x x x procedures to workers for
Crane operations, which can
cause a disaster if failed.
Also, in the Nefas Silk factory
access to fire brigade is

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limited due to narrowness of

access road which can
obstruct fire disaster
prevention.
Note: The symbol (X) stands for non-compliance, whereas (√) stands for Compliance.

9. Due diligence audit results

An initial investigation on the history of the three factory sites were made by conducting an
interview with the top management of the enterprise, whom were also assisted by workers
with a deeper historical knowledge of the factories. Site investigation was conducted in the
sites after the interview. The audit team was able to understand that the factories were
established at different years starting in the 1930s to the 1960s by Italian individuals who
happen to come into Ethiopia during the Italian invasion. Before the establishment of the
marble factories in their current sites, the places were not used for any other industrial
activity. The Gulele site was among the scarcely populated residential areas during that
time. It was turned gradually into marble factory site when it expanded its operations from
simple chiselled stone production to marble production by installing machineries. Similarly,
the site at Bole was known to be an area covered by vegetation before the factory was
established there. The advancement of residence houses towards the site of the Bole
marble factory was a phenomenon that took place during the last decade. The area was
scarcely used for residence and other industrial activities in the remote past. The site at
Nefas silk was established in 1962 E.C and used as marble factory site there after.

As explained above the back history of the sites have revealed that they were only used for
industrial activities since and when the marble factories were established. The nature of
marble industry as a whole is that the major inputs used for production does not present
high environmental risk in terms of posing persistent contamination or pollution to land or
water bodies. The main raw materials are natural marble blocks and cooling water.
Electrical energy is consumed to process the marble, but it is produced some where else.
Water pollution, that could have been created in the Kebena and Akaki rivers by the release
of wastewater from the Gulele and Bole factories in the past and which can continue to exist
in the future unless the enterprise takes appropriate measures, is the only environmental
aspect that needs careful consideration interms of environmental liability. Here again,

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wastewater from the marble industry is known to contain marble slurry which essentially is
composed of Calcium carbonate, Calcium oxide and some trace metals like Iron. Therefore,
the stress to the aquatic environment from the marble slurry arises not from some persistent
toxic constituents, but from the physical suspension property in the river water which disturb
the aquatic environment. This stress to the aquatic environment in the rivers should be
avoided by introducing appropriate mitigation mechanisms, but at the moment, the situation
does not lend itself for interpretations into past liabilities for the enterprise. The stress put on
the rivers can be eliminated once discharging the wastewater into them is stopped.
Therefore, the audit team concluded that the three site holdings as defined by the official
site map of the enterprise were entirely used for marble production through out the whole
period, implying the absence of any serious environmental liability to the enterprise.

10. Conclusion and Recommendations

The following recommendations are forwarded to the enterprise to enable it improve its
environmental performance.

1. The enterprise should fully recognise and assume its responsibility for the
environment. It should also build its understanding of the legislative environmental
requirements affecting its activity by compiling a register of legislations,
regulations and standards.
2. The enterprise should take appropriate measures to avoid the discharge of
process wastewater and/or cooling water into the adjacent rivers with out
adequate treatment.
3. The enterprise should investigate for appropriate techniques to minimize the
release of dust and noise to reasonably acceptable levels and to achieve
progressively in the course of time the environmental quality levels indicated in
the draft national emission and ambient quality standards.
4. The enterprise should start good house keeping practises in each of the factory
premises to improve the orderly storage and handling of the raw blocks, scrape

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marble stones, marble chips and finished products. An orderly arrangement in

storage and handling of the above will have a tremendous positive impact on the
aesthetic values of each factory.
5. The enterprise should find ways to avoid dumping dried marble powder/sludge
waste at the backyards of its factory premises. It should dispose of this solid
waste in appropriate landfill.
6. The enterprise should provide training for its workers on occupational safety and
hazard prevention, with emphasis on overhead crane operations. It should also
improve its follow up on continuous use of personal protection equipments by the
workers.
7. The enterprise should start to work towards establishing a proper and adequate
environment management system. This will enable it to get committed and
maintain a better performance in health, safety and environment aspects in its
operations. The enterprise needs to periodically provide training to the workers on
these aspects and will keep associated documentation which can be presented
during future auditing by environmental auditors.

As it stands now, the enterprise is away from compliance to many of the environmental and
related requirements. The non - compliance areas include Noise and air pollution
management as well as wastewater and solid waste managements. However, there are
also opportunities for the enterprise to make improvements in those areas with out entailing
excess costs on itself. Such opportunities include putting back its waste water treatment
facilities in Gulele and Bole branch to continuous operation and doing their monitoring.
Good house keeping is also among the low cost opportunities for the enterprise.

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Annexes

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Environmental audit Report of EMI 24

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