Frequently Asked Questions on Kerala

This part of our web site is aimed at answering your specific questions concerning the operation of our business in India. You may choose to scroll through all of the documents or click on a subject from the list below to be taken straight to that subject. Any item underlined is also a link that will either take you to a definition of a term or to the relevant evidence for the point we are making. You may also choose to format the page for printing either this entire document or print the selected sections but choosing the ‘print this’ option. You will need to format the page for printing to ensure photographs, graphs etc appear correctly.

Water usage
Water Quality
Bio-solids
Product Quality
BBC Radio reports
Christian Aid report
Business ownership


Water Usage

Are you depleting the aquifer that supplies your plant in Kerala?

No.

We conducted an environmental due diligence study as per our international corporate policy of good environmental practice before setting up the plant and conducted scientific tests before we located our plant in this part of Kerala. These included a satellite imagery study to determine the extent and nature of the aquifer and a pumping test to establish the sustainable yield of water from the bore wells. The plant has consistently operated the bore wells below these safe limits.

In addition to this, in September 2003 the Central Ground Water Authority confirmed that that there were no abnormal changes in groundwater levels around the plant that can be attributed to our operations.

We have also employed rainwater harvesting technology in our plant that collects rain water over the entire plant area. The system collects rain water, both from ground surface and rooftop and channels it into perColation ponds to augment recharge of the aquifer. Besides this, we are sharing this technology with the local community and have extended it to cover nearly 40 acres spread over five farms and a school in the surrounding area which have the capacity to recharge the aquifer with an average 500 cubic meters of water a day with normal rainfall.

We estimate a harvest of 50,000 cubic meters of rain water in 2002 and this more than doubled to 125,000 cubic meters in 2003, which is equivalent to approximately 50% of our annual water usage.


How does rainwater harvesting work?

In areas of low rainfall, an additional problem occurs which means that because of dried land, much of the rain that does fall does not penetrate deep into the ground and instead runs as surface water back to the ocean where it rendered unusable as drinking water. Rainwater harvesting effectively traps rainwater and directs it deep under ground into large areas of porous rock (known as aquifers).

Have you introduced rainwater harvesting technology in reaction to recent criticism?

No. We have been operating this system since June 2002.

We have been waiting for permission to build a pipeline at our own cost to source water from the Moolathara Dam (5kms away) for more than four years now. Alternatively, a check dam can be built (at our own cost) at Kunnamkattupathy (1.5kms away) but again, we have not been given permission.

If either of these projects is allowed, we can then provide a more consistent and greater supply of water (at our own cost) free to the surrounding villages.

What else have you done?

We have deployed the 3-R principles of Reduce, Re-use & Recycle since we commenced plant operations in March 2000. With these principles we achieved a reduction of about 25% in water usage and our actual average daily usage in 2003 was about 400 cubic meters.

We also provide free water to the local community. These tankers daily carry 24,000 liters of water to the villages of Plachimada, Vijayanagar and Rajeev Nagar villages and a Government School at Nellimedu.

Then why is there a scarcity of water in the area?

Government and Independent tests have confirmed that this plant is not adversely affecting ground water supply.

The main reason is poor rainfall during last three years. In 2001, the average annual rainfall for the area was only 58% of the average normal rainfall during the 1997 to 2001 period which, in 2002, further dropped to just 34% of the average normal rainfall between 1997-2001. The rainfall in 2003 was much better than the previous years but still fell short at 87% of the 1997-2001 average.

There are more than 27 other water reliant industries in the district which also use ground water for their manufacturing operations. While we have pioneered water conservation and rain water harvesting in the area, we believe that similar efforts need to be replicated by all other water-based industries.

Moreover, there are nearly 150 bore wells within five kilometers of our plant, while we use no more than three bore wells at any one time.

Why locate a plant with such a heavy requirement for water in a well known rain shadow area? How can you justify keeping the plant open in a time of low rainfall?

There are nearly 150 bore wells and 200 open wells within five kilometers of our plant and we use no more than three bore wells at any one time.

The prevailing agriculture in the area requires approximately twice as much water as our plant needs (on a per acre basis) and the rainwater harvesting technology we have introduced has the potential to not only recharge more water than we use but also ensures there is an increased supply of water available for the needs of the local farming community.

Is it true that you take groundwater and process it into bottled water for re-selling at a profit to the local community?

No. Bottled water is not produced at this plant.

Is it true that you ship water to local villagers by tanker from other villages? Wouldn't it be easier to allow villagers access to their own water?

The water shortage problem is not limited to the area around our plant. Therefore we provide water to multiple locations.

We provide water through tankers twice daily to Plachimada, Vijayanagar and Rajeev Nagar villages as well as to the Government LP School at Nellimedu.

We will continue to distribute water from our plant to the local people as needed.

By your own admission, there is a water shortage in the area. Is this a problem just around your plant or throughout the State?

The Central Ground Water Board has identified the water stressed areas in Kerala and has placed them in three categories; 'over exploited' (Chirayinkeezh, Kasaragod and Kodungaloor), 'critical' (Parassala, Athiyannur, Muhkhathala, Anchalumood, Thalasseri & Balusseri) and 'semi critical' (Nemom, Pamakkuda, Paravoor, Mulamthuruthi, Mala and Kozhikode). Given the State wide nature of the problem it is important that local industries work with Government to follow our lead in the area of rainwater harvesting.

Water Quality

Is it true that your waste water has been allowed into the earth via shallow tube wells contaminating local water supplies?

No. The Central and State Ground Water authorities have confirmed that our operations have not adversely affected the quality of groundwater around our plant.

We actively monitor the quality of water around our plant. The central ground water authorities have tested 33 wells in and around the plant in February 2003 and have concluded that the plant operations has not adversely affected the quality of groundwater.

In addition to this, State ground water authorities tested 20 well water samples in and around the plant and concluded that the problem, if any, cannot be attributed to the plant discharge

As part of our operations, we also monitor the wells within our plant for water quality and find no adverse impact on quality.

The State Pollution Control Board has renewed our license in January 2002 and this remains valid until December 2004.

Is it true that several people have been affected with skin diseases as a result of decreasing water quality in the area?

Medical Practitioner, Dr. Ramesh Chandran has provided a clean 'chit' to the plant stating clearly that there are no cases of skin disease or chronic skin ailments amongst workers in the plant. In addition, the Palakkad District Medical Office has denied this and has given a clean 'chit' to the Company's operation in Kerala.


Bio-solids

The following answers are taken from the United States Environmental Protection Agency web site

What are Bio-solids?

They are nutrient-rich organic materials resulting from the treatment of domestic sewage in a treatment facility. When treated and processed, these residuals can be recycled and applied as soil conditioner to improve and maintain productive soils and stimulate plant growth.

What is the difference between bio-solids and sludge?

Bio-solids are treated sewage sludge. Bio-solids are carefully treated and monitored and must be used in accordance with regulatory requirements.

Why do we have bio-solids?

We have bio-solids as a result of the wastewater treatment process. Water treatment technology has made our water safer for recreation and seafood harvesting. Thirty years ago, thousands of American cities dumped their raw sewage directly into the nation's rivers, lakes, and bays. Through regulation of this dumping, local governments now required to treat wastewater and to make the decision whether to recycle bio-solids as fertilizer, incinerate it, or bury it in a landfill.

How are biosolids generated and processed?

Biosolids are created through the treatment of domestic wastewater generated from sewage treatment facilities. The treatment of biosolids can actually begin before the wastewater reaches the sewage treatment plant. In many larger wastewater treatment systems, pre-treatment regulations require that industrial facilities pre-treat their wastewater to remove many hazardous contaminants before it is sent to a wastewater treatment plant. Wastewater treatment facilities monitor incoming wastewater streams to ensure their recyclability and compatibility with the treatment plant process.Once the wastewater reaches the plant, the sewage goes through physical, chemical and biological processes which clean the wastewater and remove the solids. If necessary, the solids are then treated with lime to raise the pH level to eliminate objectionable odors. The wastewater treatment processes sanitize wastewater solids to control pathogens (disease-causing organisms, such as certain bacteria, viruses and parasites) and other organisms capable of transporting disease.

How are biosolids used?

After treatment and processing, biosolids can be recycled and applied as fertilizer to improve and maintain productive soils and stimulate plant growth. The controlled land application of biosolids completes a natural cycle in the environment. By treating sewage sludge, it becomes biosolids which can be used as valuable fertilizer, instead of taking up space in a landfill or other disposal facility.

Where are biosolids used?

Farmers and gardeners have been recycling biosolids for ages. Biosolids recycling is the process of beneficially using treated the treated residuals from wastewater treatment to promote the growth of agricultural crops, fertilize gardens and parks and reclaim mining sites. Land application of biosolids takes place in all 50 states.

Why are biosolids used on farms?

The application of biosolids reduces the need for chemical fertilizers. As more wastewater plants become capable of producing high quality biosolids, there is an even greater opportunity to make use of this valuable resource.

What percentage of biosolids are recycled and how many farms use biosolids?

About 50% of all biosolids are being recycled to land. These biosolids are used on less than one percent of the nation's agricultural land.

Are biosolids safe?

The National Academy of Sciences has reviewed current practices, public health concerns and regulator standards, and has concluded that "the use of these materials in the production of crops for human consumption when practiced in accordance with existing federal guidelines and regulations, presents negligible risk to the consumer, to crop production and to the environment."

Do biosolids smell?

Biosolids may have their own distinctive odor depending on the type of treatment it has been through. Some biosolids may have only a slight musty, ammonia odor. Others have a stronger odor that may be offensive to some people. Much of the odor is caused by compounds containing sulfur and ammonia, both of which are plant nutrients.

Are there regulations for the land application of biosolids?

The federal biosolids rule is contained in 40 CFR Part 503. Biosolids that are to be land applied must meet these strict regulations and quality standards. The Part 503 rule governing the use and disposal of biosolids contain numerical limits, for metals in biosolids, pathogen reduction standards, site restriction, crop harvesting restrictions and monitoring, record keeping and reporting requirements for land applied biosolids as well as similar requirements for biosolids that are surface disposed or incinerated. Most recently, standards have been proposed to include requirements in the Part 503 Rule that limit the concentration of dioxin and dioxin like compounds in biosolids to ensure safe land application.

Where can I find out more about the regulations?

The biosolids rule is described in the EPA publication, A Plan English Guide to the EPA Part 503 Biosolids Rule . This guide states and interprets the Part 503 rule for the general reader. This guide is also available in hard copy. In addition to the Plain English Guide, EPA has prepared A Guide to the Biosolids Risk Assessments for the EPA Part 503 Rule which shows the many steps followed to develop the scientifically defensible, safe set of rules (also available from EPA in hard copy.)

How are biosolids used for agriculture?

Biosolids are used to fertilize fields for raising crops. Agricultural use of biosolids, that meet strict quality criteria and application rates, have been shown to produce significant improvements in crop growth and yield. Nutrients found in biosolids, such as nitrogen, phosphorus and potassium and trace elements such as calcium, copper, iron, magnesium, manganese, sulfur and zinc, are necessary for crop production and growth. The use of biosolids reduces the farmer's production costs and replenishes the organic matter that has been depleted over time. The organic matter improves soil structure by increasing the soil's ability to absorb and store moisture. The organic nitrogen and phosphorous found in biosolids are used very efficiently by crops because these plant nutrients are released slowly throughout the growing season. This enables the crop to absorb these nutrients as the crop grows. This efficiency lessens the likelihood of groundwater pollution of nitrogen and phosphorous.

Can biosolids be used for mine reclamation?

Biosolids have been used successfully at mine sites to establish sustainable vegetation. Not only does the organic matter, inorganic matrix and nutrients present in the biosolids reduce the bioavailability of toxic substances often found in highly disturbed mine soils, but also regenerate the soil layer. This regeneration is very important for reclaiming abandoned mine sites with little or no topsoil. The biosolids application rate for mine reclamation is generally higher than the agronomic rate which cannot be exceeded for use of agricultural soils.

Can biosolids be used for composting?

Yes, biosolids may be composted and sold or distributed for use on lawns and home gardens. Most biosolids composts, are highly desirable products that are easy to store, transport and use.

Are there rules about where biosolids can be applied?

To determine whether biosolids can be applied to a particular farm site, an evaluation of the site's suitability is generally performed by the land applier. The evaluation examines water supplies, soil characteristics, slopes, vegetation, crop needs and the distances to surface and groundwater. There are different rules for different classes of biosolids. Class A biosolids contain no detectible levels of pathogens. Class A biosolids that meet strict vector attraction reduction requirements and low levels metals contents, only have to apply for permits to ensure that these very tough standards have been met. Class B biosolids are treated but still contain detectible levels of pathogens. There are buffer requirements, public access, and crop harvesting restrictions for virtually all forms of Class B biosolids.Nutrient management planning ensures that the appropriate quantity and quality of biosolids are land applied to the farmland. The biosolids application is specifically calculated to match the nutrient uptake requirements of the particular crop. Nutrient management technicians work with the farm community to assure proper land application and nutrient control.

Are there buffer requirements or restrictions on public access to sites with biosolids?

In general, exceptional quality (Class A) biosolids used in small quantities by general public have no buffer requirements, crop type, crop harvesting or site access restrictions. Exceptional Quality biosolids is the name given to treated residuals that contain low levels of metals and do not attract vectors. When used in bulk, Class A biosolids are subject to buffer requirements, but not to crop harvesting restrictions. In general, there are buffer requirements, public access, and crop harvesting restrictions for virtually all forms of Class B biosolids (treated but still containing detectible levels of pathogens).

What will it mean for a wastewater treatment plant, biosolids manager or land applier to agree to follow an Environmental Management System (EMS) for Biosolids?

A voluntary EMS is now being developed for biosolids by the National Biosolids Partnership (NBP). The NBP consists of members from the Association of Metropolitan Sewerage Agency, the Water Environment Federation, the U.S. Environmental Protection Agency (EPA) and other stakeholders including the general public. Those facilities who pledge to follow the EMS are agreeing to follow community-friendly practices in addition to being in compliance with applicable state and Federal regulations. Community friendly practices refer to the control of odor, traffic, noise, and dust as well as the management of nutrients. Those who pledge to follow the EMS will be subjected to audit by impartial independent third parties.

End of US EPA material


Why does Coca-Cola produce bio-solids?

Our plant passes the waste water through an effective Effluent Treatment Plant (ETP), which has been approved and is regulated by the State Pollution Control Board. This digests the organic substances aerobically and produces bio solids.

If these bio-solids are so contaminated, why were you giving it out to the local farming community as fertiliser?

Numerous reports since the commissioning of the plant, and as recently as December 2003, have confirmed that the levels of heavy metal traces are within the Pollution Control Board (PCB) norms for classification as non-hazardous.

We gave bio-solids to four farmers as per their request. However, despite the fact that the official tests showed that these bio-solids are within the PCB norms for classification as non-hazardous, as soon as we became aware of these concerns, in July 2003, as a matter of utmost caution, we stopped distributing the treated waste to farmers. We went a step further and in Aug 2003, recovered all unused bio-solids from the farmers given earlier. These bio solids are stored within our plant pending agreement with the local authorities on their disposal.

The BBC has reported on three occasions that when they visited your plant in Kerala samples were taken of this bio-solid and tests proved conclusively that they contained dangerous levels of toxic materials. How do you respond to this?

The BBC's evidence of pollution in bio-solids is scientifically questionable since only 3 samples were taken and two of them had levels of heavy metal traces within the prescribed limits. The BBC samples were taken from farmland (not from our plant) and their make up could have been influenced by a host of other factors. Sampling techniques need to be representative to draw scientific conclusions.

If these bio-solids are so safe, why have you been ordered to store them as hazardous waste?

Even though the PCB confirmed that the bio-solids are within the norms for classification as non-hazardous, as soon as we became aware of these concerns, in July 2003, as a matter of utmost caution, we stopped distributing the treated waste to farmers. We went a step further and in Aug 2003, recovered all unused bio-solids from the farmers given earlier. These bio solids are stored within our plant pending agreement with the local authorities on their disposal.

How will you dispose of the bio-solids?

We have a number of options which we are pursuing with the scientific community and will have a definitive process in place. However the disposal process of the bio-solids would be dependent on the directions issued by the respective State Pollution Control Board who are regulating such disposal activity. Our options include scientifically validated options for bio solids proved to be non-hazardous. We are working closely with the Indian Institute of Technology also.

Product Quality

Is there any truth in the stories that Coca-Cola and other soft drinks made by the Company in India contain dangerous levels of pesticides?

No. Our products manufactured in India are safe as they adhere to the rigorous and global quality processes of The Coca-Cola Company. We follow one quality system across the world and the treated water used to make our beverages across all our plants in the country meet the highest international standards, as well as the guidelines recently issues by the JPC. This has been repeatedly established through tests conducted by the Government of India and independent laboratories.

Moreover, multiple independent testing of our products by accredited and internationally renowned laboratories like TNO Nutrition and Food Research, of the Netherlands, Central Science Laboratory, York, UK and the ISO 17025 certified Vimta Labs, has confirmed that they meet international norms and standards.

Did your sales suffer in India as a result of the scare?

Our sales did suffer a short term decline but consumers now realize that our products are safe in India.

There was an allegation that your product may also contain heavy metals such as Cadmium. Is this true?

Atomic absorption spectrometer methods were used by the Kerala Health Department and Health Director Dr V. K. Rajan confirmed this allegation was not true. Our own testing done at accredited, independent labs confirm that all heavy metal traces are within safety norms.

BBC Reports

The BBC radio reports on your plant in Kerala were very convincing. If you have nothing to hide, why didn't you allow them access to your plant?

Our plant has received three visits from the BBC and two of these visits have been from the BBC Radio 4 programme: Face The Facts. On both occasions they gave us no notice of their intentions to visit the plant. This BBC team was, in fact, given permission to enter the plant. Contrary to what was said in their report, the offer was extended for them to visit the plant the next day. This offer was declined and not mentioned in their programme.

The third visit was from BBC Television News who provided the appropriate notice to us and we were happy to allow them and a film crew full and unrestricted access to the plant.

We have written to the BBC Board of Governors and the BBC will shortly begin an investigation into the conduct of this programme.

The BBC has reported on three occasions that when they visited your plant in Kerala samples were taken of this bio-solid and tests proved conclusively that they contained dangerous levels of toxic materials. How do you respond to this?

The BBC's evidence of pollution in bio-solids is scientifically questionable since only 3 samples were taken and two of them had levels of heavy metal traces within the prescribed limits. The BBC samples were taken from farmland (not from our plant) and their make up could have been influenced by a host of other factors. Sampling techniques need to be representative to draw scientific conclusions.

The Board of Governors of the BBC is currently investigating the conduct of this programme.

What do you say in response to the concerns raised by the leader of the National Farmers Protection Committee, Ravi Kumar, who talked to the BBC about the impact you were having on the local farming community?

Ravi Kumar was talking broadly about the lives of the farming community in Kerala and this was edited to sound as if he was saying that this was a direct result of the presence of the Coca-Cola plant. The BBC chose to ignore a letter to John Waite from Ravi Kumar, National Farmers Protection Committee he subsequently wrote to them in which he stated that none of the charges against the company could withstand serious scrutiny.

Is it true that the plant is taking water from the aquifer, bottling it and selling it back to the villagers for a profit?

No. Again, the BBC radio report has been inaccurate. Bottled water is not made and this plant and never has been. In a further indication of inaccuracy the programme stated that the plant produces Mirinda. This is a brand of our competitor in India!

The BBC report contained a disturbing interview with an old lady who is said to walk for miles each day to fetch fresh water. If water is available to her, why does she walk this distance each day?

We were also disturbed to hear such reports. Clearly, fresh water is available to this individual via our own free daily delivery system. Our four hundred staff at the plant who are all members of the same community have tried to identify this woman without success. We are eager to trace her to provide her with details of how we can provide her with purified water each day in her own village.

Christian Aid report

Christian Aid has published a report repeating the allegations made by the BBC. What is your response?

We have already responded to Christian Aid on Jan 20th strongly protesting against the biased report that is not based on any on ground study and contains several inaccuracies.

More importantly, the report fails to give credit to the considerable efforts of this plant for setting the standards of water use in the State of Kerala, if not the entire country.

It is disappointing that Christian Aid has chosen to highlight an operation that has arguably done more than any other industrial unit in the State in order to publicize its agenda.

The door remains open for Christian Aid and others to visit this plant to see the real story for themselves.


Business ownership

Whilst saying that Coca-Cola in India is a local company, isn't it true that it is merely a branch of an American multinational employing local low wage earners whilst all the decisions about the business are made outside of India?

Hindustan Coca-Cola Bottling Private Limited is a company operated from top to bottom by Indians. There is only one foreign national on its pay-roll of approx. 6,000 and its strategic direction is managed by an Indian.

In addition to the direct employment of approx 6,000 Indians, The Coca-Cola Company's system creates an enormous multiplier effect in India. The Company insists that all ingredients and packaging are sourced locally providing valuable income and job creation for local industry. In addition, the Company provides a product that is sold by over one million retailers throughout the country generating profit and further jobs for small businesses throughout the country.

 
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