Meet Subba Rao, Chief Executive at Chola MS Risk Services in India, to learn about the latest Indian EHS regulations, biggest opportunities to improve EHS performance in his geography, and more.

Antea Group is a founding member of the Inogen Environmental Alliance—a global network of EHS&S consultancies that work together to provide environmental, health and safety solutions to multinational clients around the world. Our Inogen Member Spotlight series highlights the deep experience and localized knowledge from our fellow Inogen Associates in their respective geographies.


Subba Rao

Where Do You Live?

I live in Chennai, which is the capital of Tamil Nadu, one of the 29 states in India. 

What Is Your Area Known For?

Chennai, known as the Gateway of South India, is a 400-year-old city located in the southern part of India. Chennai is known for its rich cultural heritage and its peoples’ passion for music. (It has produced Oscar award-winning musicians in the last ten years!)

What Is Your Role?

I work as Chief Executive of Chola MS Risk Services. I have been associated with the company for the past 23 years, and represent Chola MS Risk Services on the Inogen board.

What Do You Do?

As Chief Executive, I am responsible for implementing the strategy outlined by the board. I am involved in every facet of the business, from marketing, to project execution, to hiring new engineers. With Inogen, I am actively engaged in the digital initiatives of the group.

What are the biggest opportunities to improve EHS performance in your geography?

Many companies are benchmarking their EHS performance with the best-in-class. EHS is no longer seen as statutory compliance, but as a value differentiator. For example, the latest Indian regulations on extracting groundwater demand that for every m3 of groundwater extracted, you need to replenish twice that amount.

India is the first country in the world to have made Corporate Social Responsibility (CSR) mandatory for every organization that has a net profit of US $75 million or more. In the last two years, US $2 billion was spent on CSR activities. EHS personnel have a unique opportunity to work with communities and improve social governance.

Similarly, India witnessed new regulations on the disposal of e-waste, solid waste management, emission regulations, water consumption standards, and more. It introduced new guidelines by way of the National Building Code and National Electrical Code. Other emerging opportunities include soil remediation, source vulnerability assessments (SVAs) for water, and hydrogeology. Adapting to these new regulations and guidelines presents a tremendous opportunity for EHS personnel to improve their performance.

Any advice for EHS managers?

Unlike earlier years, EHS managers must cope with many workplace challenges, especially in a developing country like India. The modern workplace has robots, automated systems, and sophisticated material-handling equipment. The size and complexity of operations have increased manifold. They are expected to have in-depth knowledge of fire safety, electrical engineering, construction, IT, instrumentation, chemical handling, environmental engineering, et cetera.

Besides all of the above, EHS managers also have to contend with ever-changing regulatory requirements and prepare their organizations to face emerging challenges. EHS managers are expected to contribute and work tirelessly to address the organizational goals like zero harm/accidents sustainability goals and add value aggressively to the bottom line. They are likely to work with every employee of the organization and be the change agent to achieve the stated goals. In addition to this, they are expected to stay current on emerging issues and trends, which is a big challenge by itself.

What are Some Key Emerging Regulations in Your Area?

  • One Step Environmental Clearance (EC)

For industries requiring Environmental Clearance (EC), issuing of consent by State Pollution Control Board (SPCB) shall be a one-step process and EC will be deemed as Consent to Operate (CTE) in such cases. SPCB shall be involved in the process of granting EC. In this regard, CPCB has already requested that the Ministry of Environment Forest and Climate Change (MoEF&CC) lay down a methodology for involving SPCBs in the process of granting EC.

  • Standardization of Environment Clearance Conditions

The Ministry of Environment, Forest and Climate Change (MoEF&CC) has modified the Environmental Impact Assessment (EIA) Notification 2006, under the provisions of the Environment (Protection) Act 1986, which regulates the development and expansion/ modernization of 39 sectors/activities listed in the Schedule to the EIA Notification 2006.

There are two categories of projects: Category 'A' projects that are handled at the level of MoEF&CC and Category 'B' projects that are handled by the respective State Environment Impact Assessment Authority (SEIAA).

All projects or activities included as Category 'A' in the schedule, including expansion and modernization of existing projects or activities and change in product mix, shall require prior environmental clearance from the Central Government in the MoEF&CC on the recommendations of an Expert Appraisal Committee (EAC) constituted by the central government for the purposes of this notification.

This is applicable to the following sectors and activities:


  • 7(a) Airports
  • 7(d) Common hazardous waste treatment, storage and disposal facilities (TSDFs)
  • 7(da) Bio-medical waste treatment facilities
  • 7(e) Port, harbor, break water, and dredging
  • 7(g) Aerial ropeways
  • 7(h) Common effluent treatment plants
  • 7(i) Common municipal solid waste management facilities

Building/construction projects, area development projects

  • 8 (a) Building and construction projects
  • 8(b) Township and area development projects
  • Implementation of Zero Liquid Discharge (ZLD) for water-polluting industries (Jan. 2015)

Implementation of the Zero Liquid Discharge (ZLD) rule is an important issue. In many sectors, technology can make it possible to achieve ZLD. Courts are seeking opinion from regulators about the feasibility and possibility of total implementation. In many parts of the country and in many sectors, it is being demonstrated successfully, though the economic aspects remain in question.

This is applicable to the following facility types: distilleries, tanneries, pulp & paper, sugar, pharmaceuticals, textile, refineries, fertilizers, and dye and dye intermediate facilities.

  • Mangroves Protection Act (State of Maharashtra)

All mangroves in Maharashtra have been declared to be protected forests or reserved forests, including mangroves located in City and Industrial Development Corporation (CIDCO) and Mumbai Metropolitan Regional Development Authority (MMRDA) land.

All mangroves are to be treated as Coastal Regulation Zone (CRZ) I. If the area of the mangrove patch is more than 1,000 square meters, the 50-meter buffer zone is also to be treated as CRZ I. No construction or dumping will be allowed. Satellite mapping will be carried out every six months. 

  • New CRZ Rules (Jan. 21 2019)

The proposed draft rules allow “public utilities,” like sewage treatment plants, link roads, coastal roads, and ecotourism projects in CRZ I. Also, any permits that apply to existing town and country planning rules for building construction in CRZ II areas are frozen under the current regulation.

Draft rules distinguish between the CRZ III A and CRZ III B, where the former has a higher density population. The No Development Zone (NDZ) in CRZ III A areas is now 50 meters from the high tide line, reduced from 200 meters under current regulations, but remains 200 meters for CRZ III B areas.

The proposed rules allow for temporary tourism facilities in NDZ areas. In cases where a national or state highway cuts through an NDZ in a CRZ III area, temporary facilities will be allowed on the seaward side. On the landward side, construction of hotels, resorts, and related tourism facilities will be permitted.

  • Guidelines to Regulate and Control Ground Water Extraction in India (In effect from Jan. 6 2019) 

A No Objection Certificate (NOC) for industries shall be granted only for such cases where government agencies are not able to supply the desired quantity of water. Industries shall minimize the use of fresh groundwater through recycling and reuse of wastewater.

All industries extracting groundwater to the tune of 500 meters3 or more per day in safe and semi-critical assessment units, and 200 meters3 or more per day in critical and over-exploited assessment units, shall be required to undertake a water audit via CII, FICCI, or NPC certified auditors and submit a report within three months of completion to CGWA through the web portal. The first audit shall be completed within a year of when the NOC was granted. Subsequent audits shall be conducted once every three years for safe/semi-critical assessment units and once every two years for critical/over-exploited assessment units.

The NOC shall be valid for a period of three years in safe and semi-critical areas and two years in critical and over-exploited areas.

Other new regulations introduced or amended in the recent past are:

Want to know more? Contact Subba:


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