To,
Dr. K Madhavi Latha
Collector and District Magistrate,
East Godavari District
Sub: Grasim, Balabhadrapuram – public hearing
Madam,
The Human Rights Forum (HRF) is a citizens’ forum established in 1998 with the objective of working for protection of Constitutionally guaranteed and internationally recognized rights of the people. HRF has been committed to documenting the violations of people’s rights. We are writing this to you to reconsider the holding of a public hearing for Grasim Industries scheduled on 28 Feb 2023 at Balabhadrapuram, Biccavolu mandal of East Godavari district.
Grasim is introducing PFOA as a raw material for PTFE production. “The previous guideline, set in 2016, set a limit of 70 parts per trillion (ppt) for both PFOS and PFOA in drinking water. The new advisories decrease that by more than a thousandfold. The new limit for PFOS is 0.02 ppt; for PFOA, it’s 0.004 ppt.” (Philippe Grandjean, adjunct professor of environmental health at Harvard T.H. Chan School of Public Health).
In some studies, higher levels of PFOA in a person’s body were associated with higher cholesterol, changes to liver function, reduced immune response, thyroid disease, and increased kidney and testicular cancer.
The companies, in their quest for profits don’t bother about public health. But you being the District Magistrate have the responsibility to direct them to follow the stipulated rules and guidelines. As this proposal is for expansion you can direct the AP Pollution Control Board to conduct a study of the local ground water to measure the presence of the PFOA before and after the commencement of the project. APPCB should have done this already but they don’t have the intent or the wherewithal.
No lab or university in AP has the ability to analyse water with a low concentration below 0.004 ppt. How do authorities ensure public safety? Latest research shows that rainwater everywhere on the globe has PFAS beyond the safe limit for drinking water. Adding to it in the East Godavari district is not a desirable development.
You have the authority/responsibility to intervene and defer the public hearing in the interest of public safety. Draft EIA report submitted is of poor quality and has left out many details. It does not say a word about PFOAs and their risks. Simple chlorine balance is not presented. If a chlorine bullet fails, the consequences are not presented in the risk assessment chapter. Companies should not take advantage of the inability of people to understand EIA reports.
Grasim should be allowed to proceed for the public hearing only after the comparative study about the presence of the PFOAs in the local ground water is conducted and the information is shared with the local public widely.
Sincerely,
Y Rajesh
HRF general secretary
21.02.2023
Rajamahendravaram