An environmental ultrasound

Today we have the privilege of observing, through an ultrasound, the development of a life in gestation. Ultrasound is not only a magical window to the invisible world of the womb, but it also allows us to verify the baby’s development or identify possible complications or ailments. The doctor not only relies on his clinical knowledge, but also on images that allow him to detect more easily what could happen in order to make the right decisions.

During the conception of a company, it is also important to have prospective tools to make decisions and efficiently manage resources. The tool used to make decisions regarding potential environmental impacts and risks is called environmental impact assessment (EIA). It is an exercise that is done before starting a project and, depending on its complexity, will involve a greater or lesser number of experts in social, archaeological, geological, biological, and engineering issues.

The EIA is an environmental ultrasound from which decisions are made about possible risks that could occur during the construction or operation of a project. It allows to anticipate. Prevent surprises.

Modification of regulations

Any serious developer knows that it is better to be safe than sorry. He knows that his stakeholders, financiers, clients, and the community, increasingly demand that the environmental risks of the project are well controlled. It also understands that if it wants to develop a project in a country like Costa Rica, which presents itself as environmentally friendly, it must act accordingly.

Unfortunately, the Costa Rican government has confused the EIA with excessive red tape and modified the environmental impact assessment (EIA) regulations last April. As a result of this modification, certain high environmental risk industries, such as the manufacture of pharmaceuticals, textiles, paper and cardboard, are not required to receive approval from the government authority, the Secretaría Técnica Ambiental (SETENA), in order to begin operating.

What environmental risks might be present in these types of industries and why should we be concerned that they are not subject to approval by SETENA? To answer these questions, let’s imagine a pharmaceutical project being established in an industrial park in Costa Rica.

Impacts of an imaginary project

Let’s imagine that the pharmaceutical company Pills Inc. sets up a research and development center and a manufacturing plant for tablets, ovules and dissolutions in Costa Rica. The company uses flammable compounds, such as alcohols and solvents, to synthesize or extract some of the raw materials. Mishandling of these substances could lead to fire or explosion and serious damage to people and infrastructure.

On the other hand, Pills Inc needs a lot of water to wash the tanks in which the components are synthesized. As a result, wastewater containing active ingredients and antibiotics is generated. When discharged into rivers, this water could generate reproductive problems in aquatic species and antimicrobial resistance, which is a major global public health concern, according to UN Environment. These are just two potential environmental impacts of this imaginary project. Now let’s look at what happens in reality.

Reality and Costa Rican legislation

Last May 8, there was an explosion at a pharmaceutical plant in Massachusetts, USA, that sent a steel tank through the roof, killing one worker and injuring four others. This is not an isolated incident. Research published in 2020, in the Journal of Loss Prevention in Process Industries, identified 73 incidents in the pharmaceutical industry globally, resulting in 108 fatalities between 1985 and 2019. Several of these incidents have occurred in countries with robust legislation, such as the United States.

Our legislation does not provide clear guidelines for the management of hazardous chemicals, including flammable substances. This deficiency was pointed out by the Organization for Economic Cooperation and Development (OECD), as stated in the 2021 roadmap of the Ministry of Foreign Trade. By the end of 2023, Costa Rica committed to comply with a Chemicals Management Plan, which includes the development of a decree on good chemical management practices in industry. This decree has not yet been published.

It is very ambitious to think that, in the short term, we will have regulations in Costa Rica for all possible industrial scenarios. This has been a hard work of some Latin American countries such as Mexico and Brazil. For this reason, it is essential that those who advise potential investors in the country, recommend the development of an EIA that incorporates international best practices.

Let us not confuse EIA with bureaucracy, paperwork or obstacles. On the contrary, it is important to remember that this environmental ultrasound is a key part of any project that wants to be oriented towards business succes.