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Executive Summary and Recommendations – Report No. 4

Executive Summary and Recommendations –  Report No. 4


This is the fourth in a series of reports on "Industrial Silence" published by the Citizens for the Environment (CFE) (hereinafter: "the Organization"), which aims to promote sustainable industrial practices in Israel.

In its reports, the Organization examines two central issues:

One, do the industries meet environmental standards as stipulated by law and are the requirements and standards set for them up to par with internationally accepted regulations?

Two, do the authorities monitor the industries' environmental practices regularly as determined by law?

The first report related to 25 factories in the Western Galilee.

The second report related to 22 factories in the Western Galilee.

The third report related to 30 factories in the Lower and Western Galilee.

The current report relates to 10 factories in the Migdal Tefen Industrial Zone

Executive Summary

Locating and Compiling the Information

The process of locating and compiling the information is very similar to those applied in the previous reports and, unfortunately, most of the required information remains undisclosed to the public and is even difficult to obtain after filing a request for it.

It shall be noted that this report examined the results of factory sampling in 2010 and 2011, but toward the end of its preparation, we looked into 2012 results published in the Tefen Industrial Council website and considered them as well.

Obtaining information from the Tefen Industrial Council

In the past year, we have witnessed a revolutionary shift in the manner in which the Tefen Industrial Council considers the issue of information and its disclosure to the public.  This shift is evident in the manner by which the Council handles requests submitted under the Freedom of Information Law and through the publications on its website pursuant to the Freedom of Information Regulations (Provision of Information on Environmental Quality to the Public) 5769-2009 (hereinafter: Environmental Information Regulations).

The Organization’s attempts to obtain information regarding fa[i].  Since then and until early 2012, most of the requests for information about Tefen factories were left unanswered or were only addressed after a drawn out struggle.[ii]

The ongoing attempts eventually led to the initiative to amend the Freedom of Information Law in 2003, resulting in the addition of Article 6A, which requires state authorities to post environmental information in their possession on the following websites [iii].  The said amendment was followed by the Environmental Information Regulations, which apply to all state authorities, including the industrial councils.

Even attempts to obtain information for preparing this report were initially met with the refusal of the Council’s legal advisor.  Later, following correspondence and a meeting with the new Council Head, we managed to obtain the required information.

Furthermore, the Council kept its commitment and began publishing information on its website, as required by the Environmental Information Regulations, as of their applicability to the Council in March 2012.

The Tefen Industrial Council is one of the only authorities to publish environmental information on its website, according to the regulations.

Obtaining Information from the Ministry of Environmental Protection

2011 and 2012 marked a substantial decline in the Ministry of Environmental Protection’s publication of information, although it began posting some of the information following the introduction of the Environmental Information Regulations in September 2010.

The rate at which requests submitted under the Freedom of Information Law are answered is still very slow and a request for business licensing terms applying to factories, for example, was met only after 6 months.

In addition, the information appearing on the Ministry of Environmental Protection’s website revealed that, over the last three years, the Ministry did not conduct any surprise inspections at Tefen, except for one at Vulcan in 2012.

Industrial Supervision by Authorities

Tefen Industrial Council

Although the Industrial Council is responsible for handling and supervising factories, it is not involved with acts of education, welfare, etc.  The Council composition has been found inefficient as a mechanism for supervision and enforcement.  Indeed, the Council and its employees maintain direct contacts with the factories, but we found no evidence of their implementing an ordered mechanism of supervision and control.  The opposite is true; it represents and defends them in all situations.

Read more about the problematic nature of the Council composition and the method for appointing its members in the chapter on the Migdal Tefen Industrial Council.

In October 2012, the Industrial Council measured a concentration of Suspended Particulate Matter (SPM) in 10 locations within the Council district and its surroundings and found them to be standard.  However, as stated, the measurement was a one-time endeavor, performed in the winter, rendering it insufficient, failing to reflect the year-round situation and failing to replace ongoing or regular sampling throughout the year.

Western Galilee Cities Association

Upon preparing this report, we found that the Association is nearly the sole entity to continuously monitor the factories at Tefen.  Association employees maintain ongoing and direct contact with the factories, ensure the performance of periodic testing, send the factories alerts regarding result deviations, and more.

Nevertheless, we did not find any legal proceedings taken due to the discovery of deviations from the set standards or other alleged offenses under the Business Licensing Law.

Ministry of Environmental Protection

Minimal supervision.  The Ministry hardly performs surprise inspections and does not take legal measures, even after receiving information from the Cities Association regarding alleged factory deviations/offenses.

In this regard, one major instance is that of the Tefen Water Treatment Center, whose water has been flooding the mountain for years, polluting the ground and the groundwater.  In the past, the Ministry of Environmental Protection took several measures against the Council, but nothing has been done recently, despite the fact that the situation remains the same.


Standard Suitability

The report demonstrates that nearly half of the factories have not yet adjusted their standards to the Israeli standard for air quality (Clean Air Law and related regulations or other laws, respectively).  By nature, the standards applied by the said factories do not comply with internationally accepted standards.

Only 3 of the factories fully adjusted their standards to the internationally accepted standards on air quality.

The recommendations set forth by Dr. Bernanda Flicstein in her opinion dated 20 September 2009, were only partially implemented.

See: Follow-Up Chapter – Implementation of Recommendations by Dr. Bernanda Flicstein

Also regarding sewage, the standards in most factories comply only partially with the international standards.

Factory Compliance with Legal Requirements
Based on our review, none of the factories have fulfilled all of the testing and standard compliance requirements.

Failure to comply with the required inspection frequency is especially apparent regarding air quality.  Most factories do not monitor the chimneys at the required frequency and do not perform air quality measurements as required.

Our inspections found multiple deviations.  For example:

Air: Deviations relating to lead (up to 100% of the standard), chlorine compounds (up to 650%), volatile organic compounds (up to 12,860%) and particles (up to 740%).

Sewage: Deviations relating to sulfates (up to 10,500%), lead (up to 135%), oils, metals and suspended solids at hundreds of percentage points from the standards.

Sewage Treatment Facility Effluents: Large deviations of BOD, nitrogen, COD, cobalt, ammonia, suspended solids, fluoride and others, as well as extensive coliform deviations (up to 2,700,000%).

Sewage Treatment Facility:

The sewage treatment facility for the Tefen factories continues to flood the mountain with its water!

Our inspection demonstrates that the quality of effluents from the sewage treatment facility continues to be very poor and it is evident that the facility does not fulfill the objective for which it was established.  The sewage treatment facility receives all factory sewage without testing or stopping the flow of polluting sewage from factories whose sewage treatment was insufficient.

Exceptional metal concentrations were recently measured in the sewage treatment facility sludge, leading the Western Galilee Cities Association to conduct an inspection of major industrial sewage sources.

For details, see the chapter on Sewage Problems in Tefen.

Factory Cooperation

When beginning to collect information for the current report, we contacted the factories ourselves in an attempt to obtain information.

Comparing to the cooperation from the previously reported factories, only two of ten cooperated with us:

Vulcan – The factory manager fully cooperated with us, including a tour of the factory and a meeting.

Redimix – The factory sent us a copy of its business license terms.

Many factories expressed an initial willingness to cooperate and even began scheduling appointments.  However, at a certain point, they surprisingly turned back on their commitments and cancelled the meetings.

Conclusions and Recommendations

The report demonstrates a certain improvement in updating the standards set for the factories, as well as a major improvement in information disclosure by the Industrial Council.

However, most factories still do not perform the tests required of them and the public cannot be updated as to the substances emitted into the environment and the quantity thereof.

Thus, our recommendations are as follows:

The Tefen Industrial Council and the Ministry of Environmental Protection must immediately implement the recommendations brought forth by Dr. Bernanda Flicstein, including:

1. Requiring the obligated factories to prepare process and emission surveys, to conduct ongoing chimney monitoring while reducing the metal detection threshold,

2. Examining the impact that all Tefen factories have on the environment, while implementing an integrative approach, using an environmental impact assessment.

This requires the preparation of a model for entering all emission, meteorological and topographical figures relating to regional factories.  The model will predict the concentration of environmental pollutants in order to determine whether they meet the standards and where the highest concentrations are.

3. Extending environmental monitoring efforts and establishing several monitoring stations for ongoing air quality measurement, based on the environmental impact assessment.

For the Tefen Industrial Council:

4. Immediately connect its sewage treatment facility to the facility operating in Acco, pursuant to the rulings set forth by the court, the County Planning and Construction Committee and the Ministry of Environmental Protection.

5. In addition, the Council must establish a sewage monitoring array and discontinue production in plants that cause exceptional pollution of the sewage treatment facility and disrupt its operation.  It is important to understand that polluting sewage can disrupt the entire treatment facility, both the one in Tefen and definitely the sewage treatment facility in Acco in the future.  Therefore, a monitoring and work stoppage system is essential for polluting factories in the industrial zone and especially within a council whose entire essence is industry.

For the Ministry of Environmental Protection:

6. Increase supervision of factories, especially as related to air emissions, and take measures against deviant factories.

7. In addition, it must complete the adjustment of business licensing terms for all factories to internationally accepted standards, both as related to the prevention of air pollution and standards relating to sewage.

For Factories:

1. Factories should implement Best Available Technology (BAT) on their own initiative and not wait for regulations to be imposed. It has already been proven universally that while investment is required, the implementation of pollution reduction technologies (Corporate Responsibility) is economically worthwhile in the long-term.

2. Factories should improve their wastewater treatment systems immediately.  Large industries must examine the possibility of establishing a wastewatertreatment system within their factory complexes, so as not to contaminate themunicipal sewage systems.

3. Factories using large quantities of water should reuse water in order to reduce the quantity of sewage filled with hazardous materials and metals, flowing to the treatment center and greatly burdening its operations.

4. Factories should hold periodic tests in the employees’ environment, as determined by law, including the entire range of toxic substances held by the factory and used in the production process.

5. They should publish information on the implementation of Best AvailableTechnologies (BAT), and on the results of their periodic sampling. Thisinformation should be made available on company websites. The public nolonger believes in generalizations, such as the type that ordinarily appear inthe publications of different industries with references to “environmental andsocial commitment”. Industries are required to compile trustworthy informationand make statements that are fully reliable and transparent

For Employees in Factories:

1. Employees in factories must avoid exposure to hazardous materials: If their workplace uses toxic substances, they could be harmed by breathing them and through contact.  Toxic substances are also absorbed by clothes and the skin. Employees must meticulously adhere to safety instructions, be equipped and use safety gear.

2. They must demand periodic testing and sampling of their work environments bytheir employers, including the entire range of toxic substances they come in contact with.

3. They must demand that their employers implement BAT to prevent leakage of toxic materials.

4. They must get tested periodically – blood tests can detect the presence of toxins in the bloodstream. Tests must include the majority of substances that employees come into contact with on a daily basis.

For the Residents and the public:

1. The public must locate information on industrialpractices in their environment and be alert – even well-kept areas and green lawns may include dangerous facilities.

2. They must request additional information about the environmental conduct ofindustries, from the authorities and directly from the factories.

3. They must act for civil enforcement [iv] of the law against polluting factories in their residential areas.

For the Knesset:

Building on our longstanding experience with the Industrial Council, we have concluded that it is a mechanism that does not allow for a proper balance between the public and private interest.  CFE has contacted several Knesset members in order to obtain their recommendation or secure their intention to remedy the situation [the report was sent to representatives of the Labor Party, HaTnua, Hadash and Meretz several days prior to the elections.  We asked what they intend to do about the problems and flaws presented in the report.  Thus far, we have received just one response from Dov Khenin].

MK Dov Khenin (Hadash), Chairman of the Outgoing Knesset Joint Committee on Environment and Health: “The report demonstrates an embedded failure within the Industrial Council supervision and control mechanisms.  The Industrial Council, by nature, operates in favor of industry.  The result: economic interests surpass interests relating to the environment and health of people residing near the factories.  This being the case, it is no surprise that air and sewage tests are not conducted at the frequency set forth by law and that the factories fail to fully comply with the standards.  I call upon the Ministry of Environmental Protection to address the issue of industrial supervision and to adopt the report recommendations in full.  In the new Knesset, I will continue to promote the law for disbanding the Tefen Industrial Council and for transferring supervisory responsibility, as well as municipal property tax gains, to the local authorities in the region".

[i]  At the time, the Organization requested information about one of the factories and the operations of the sewage treatment facility.  The Council Head and its legal advisor at the time, refused to provide the information despite repetitive requests in writing and by phone.  It was only after legal measures were taken that information was received, presenting very concerning data regarding ongoing water and ground pollution, and mainly of the lack of adequate monitoring and control on behalf of the Council and the Environmental Protection Agencies.  As time went by, the Organization found that this mode of operation reflects a pattern – unwillingness to provide information and creating obstacles to the obtainment of information requested by residents and the Organization representing them, a pattern that went on for nearly the entire period.

    [ii]  For more information on past Organization attempts to obtain information, visit the Organization website.

[iii] For more information, visit the Organization website.

    [iv]  Contact the Organization for guidance and advice


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