Conclusions and Recommendations from the First Western Galilee Report

This report analyzes data on 24 factories and one hospital. It surveys compliance with air pollution regulation standards stipulated in their business permits, methods of control and information collected by the authorities, and the extent of compliance with standards set by the Ministry of Environmental Protection.

Compliance with Standards

Our findings show that a substantial number of factories surveyed do not meet air pollution or water pollution prevention standards. Sometimes the problem is clearly related to factories exceeding their emission standards. At other times it is the result of poor testing or sampling performance [1], and sometimes, the problems documented are related to insufficient delivery of information to the supervising agency. Concerning the issue of air pollution control, most of the standards are outdated and are no longer compatible with worldwide standards. [2]

Violating standards directly impacts environmental pollution. Even when industries take action to improve their level of adherence to standards, they do not pay for the environmental pollution they have already created. Most industries still carry on with the same practices, conducting their business in the same polluting manner. Some of the pollutants documented are extremely toxic residual substances, and some are carcinogenic. They will continue to harm the surrounding population for many years even after violations are executed.

Adaptation to Standards

Regarding sewage standards, local Israeli business licensing requirements analyzed were found to be compatible with current international standards.  However, this was not the case with regard to air pollution prevention standards. The values examined were not on par with worldwide requirements today, for a great share of the factories surveyed. This means that a considerable proportion of industries studied enjoy substantial economic benefits at the expense of public health. Such was also the ruling of Judge Daniel Fish in the case of Oil Refineries, Ltd.

"… There was also a provision of substantial financial benefit to the factory due to its failure to apply clear, accurate, and unequivocal standards, which enabled it to extend the costs of environmental risks entailed in its activity onto the general population.”[3]

 Supervision, Control, and Public Accessibility to Information

· Supervision and control by the regulatory agencies is undertaken loosely and not always in accordance with conditions stated in business permit licenses. This negligence backfires on the authorities, making it even harder for them to supervise, and it impedes systematic collection of information about industries by the authorities.[4] Citizens wishing to get information about a factory in the vicinity of their residence have nowhere to turn to. In most cases they would have to approach several authorities, wait for at least a few months until information is received, which in the end often turns out to be only partial, if acquired at all.[5]

· Most of the information collected by the Ministry of Environmental Protection and other authorities is not available on their computers or websites.

· The Ministry of Environmental Protection does not follow up on the execution of terms it set for the factories studied, as stipulated in their business licenses, and is not in possession of a large part of the data describing the industrial practices of these factories. This fact poses a major obstacle for the Ministry in conducting legal proceedings against polluting industries, when the need arises.


For the Ministry of Environmental Protection and its Local Supervisory Units

Since the responsibility and authority for supervision and enforcement over industry lies mainly with the Ministry of Environmental Protection, it is imperative to revise and improve the entire system of monitoring and enforcement such that the authority invested in it, both old and new, is executed efficiently, as stipulated by law.

· The Ministry must substantially increase the number of personnel and recruit additional professionals to its district's environmental units [6] so that they could implement supervision and control efficiently. The State of Israel is commitment to the health of its residents, and this must be a priority above all other Ministry activities.

· It must improve work procedures relating to enforcement mechanisms, and execute the process of collecting evidence in a more comprehensive and professional manner[7], so that down the road, if necessary, violators could be indicted as soon as possible after apprehension. This would ensure efficient implementation of legislation against violating industries; prevent foot dragging and ongoing harm to the environment.

· It must define a supervisory and enforcement plan based on set guidelines, and have them publicized to the authorities and the public.[8]

· It must define organized procedures and conditions for data gathering, and it must efficiently allocate issues and supervisory responsibilities between the Ministry, the regional environmental units, and the local authorities. The resultant procedures must be published, so that different industries know who their supervising agencies are, and for the public to know who they should approach with claims.

· It must stop "negotiating" with the polluting industries about terms and conditions stated in their business licenses, and it must adapt conditions to internationally accepted standards.

· It must impose regulations obliging factories to disclose information on their websites regarding the implementation of Best Available Technologies (BAT), and also obligate them to publish the results of periodic sampling. These regulations should be clearly stated in the business permits issued to industries.

For Local Authorities

· Local authorities must play a more substantial role in supervising industrial facilities within their jurisdictions.[9]

· They must without delay implement the Local Authorities Law (Environmental Enforcement—authorities invested in local inspectors), 2008.

· They must impose regulations obliging factories to disclose information on their websites regarding the implementation of Best Available Technologies (BAT), and also obligate them to publish the results of periodic sampling. These regulations should be clearly stated in the business permits issued to industries.

For Factories

· Factories should implement BAT on their own initiative without waiting to be obligated by regulation. It had already been proven worldwide that although requiring investment, the implementation of pollution reducing technologies is economical in the long run.[10]

· They 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.

· They should publish information on the implementation of BAT and the results of periodic sampling, on their websites. The public no longer believes general statements, such as the kind that are usually found in publications by industries who claim that they are "environmentally and socially committed". Industry must support such statements with reliable information and full transparency.

For Employees in Factories

· Employees in factories must be protected from exposure to 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.

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

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

· They must get tested periodically—as 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 Residents and the Public

· The public should be alert and proactive in detecting information on industrial practices in their residential environment. Well kept areas and green lawns in industrial employment zones could sometimes also include dangerous facilities.

· They must request additional information about the environmental conduct of industries, from the authorities and directly from the factories.

· They must act for civil enforcement against polluting factories in their residential areas.[11]

For the Knesset

· The Knesset must initiate legislation to authorize the publication of business licensing terms regarding industrial sewage on the website of the Ministry of Environmental Protection.[12]

[1] Some of the test results obtained were based on only partial and superficially conducted tests.

[2] See list of pollutants and their effects on health and the environment.

[3] See verdict in case 4128/04, State of Israel vs Oil Refineries Ltd., Haifa District Court, item 121.

[4] See table showing lack of consistency in reporting by industries to authorities.

[5] See table comparing testing requirements as compared to actual testing conducted.

[6] And augment its personnel by hiring additional professionals in areas such as air pollution, water pollution, sewage and hazardous materials.

[7] More and varied types of evidence should be collected, regarding sampling as well as documenting residents’ reports.

[8] The EU requires that member states reveal their supervisory regulations, for enhanced transparency and public monitoring.

[9] An example in point is the Environmental Unit in the Misgav Regional Council, which keeps records about all of the industries within its municipal jurisdiction.

[10] Corporate responsibility is a business management tool that offers a structured methodology for implementing environmental protection.

[11] CFE may be approached for assistance and guidance with civil enforcement.

[12] The obligation to publish special conditions with regard to air pollution was already addressed by the Clean Air Law.






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אתם כאן: דף הבית Conclusions and Recommendations