We would like to place on record our appreciation to the Ministry for being progressive and recognizing the need “for plastic waste minimization, source segregation, recycling, involving waste pickers, recyclers and waste processors in collection of plastic waste fraction either from households or any other source of its generation or intermediate material recovery facility and adopt polluter’s pay principle for the sustainability of waste management systems”. We also welcome the phasing out of multilayered packaging.
We have few suggestions for the draft Plastic Waste Rules, 2015 which we believe will further strengthen the rules and their enforcement and are given as follows:
|Section 3 (d):||Definition of “compostable plastic”||The definition is currently limited to ‘where the material goes after use; what we would like it to include is ‘where the material comes from’ and should read as given below:
Compostable Plastics mean (Where the material comes from) plastics made from a bio based origin such as corn, sugar, or starch, as opposed to a fossil-based carbon source. Bio-based plastics (compostable) are called “plant-derived” or products that are derived from “new carbon” or “organic carbon,” or “renewable carbon”, and (Where the material goes after use) plastics that biodegrade in some time frame that is relevant, meaning it will decompose in closer to a year than 1,000 years, which is a normal rate for fossil fuel-based plastics. 
The standards for compostable plastic should also be upgraded as new technologies and monitoring systems have been developed across the world.
|Section 3 (g)||Definition of “Extended Producers’ Responsibility”||should read as ‘Extended Producer Responsibility’ (EPR) means responsibility of any producer of plastic material, for their products beyond manufacturing until environmentally sound management of their end of life products, it includes setting up of effective plastic waste channelization system comprising of setting up of collection centers (like Dry Waste Collection Centers in Bengaluru) by involving Municipal authorities and scrap-dealers, waste-pickers, itinerant buyers
Dry waste collection centers are non-biodegradable waste collection units in Bengaluru initiated by Bruhat Bengaluru Mahanagara Pallike (Greater Bangalore Municipal Corporation) for streamlining dry waste collection and sale of collected, aggregated and sorted waste including plastic materials for recycling, thereby encouraging segregation at source. In these centers informal waste workers i.e. wastepickers, scrap-dealers and itinerant buyers are involved in collection, sorting and aggregation of waste which is further sold to recycling industries and units in the city. These centers are not yet supported by manufacturers of plastic materials but we envision that if it is done it will further strengthen the existing system of recycling and decrease the cost on Municipal authorities.
We strongly recommend that a national policy defining the ‘Extended Producers Responsibility’ framework for all forms of waste should be brought out after consultation with all relevant stakeholders as has been done in European Union.
|Section 3 (j):||institutional generator||It is recommended that Ministry define the definitions of waste generator or generator of waste, institutional generator and bulk consumer across the spectrum. Use of different terminologies adds to the confusion.
Again here, it is expected that multi dwelling apartments of 50 units, malls, sports complex/stadiums, place of worship, and marriage halls are added
|Section 3 (v):||“waste generator”||The waste generator may be defined as “any person, by site, whose act or process produces MSW waste , This definition contains three important terms – The first term, “by site,” refers to where the waste is generated; The definition of “person” encompasses any entity involved with a process that generates waste ; The third key component of the generator definition is the “act or process.”
The definition should also include ‘Forest Department’, as at many places including forest reserves, national parks etc. etc. forest department through tightened enforcement of ‘plastic ban’ norm requests the entrants to remove plastic material like pet drinking water bottles, chips and biscuits packets at the entrance, further the department is also engaged in removal of plastic waste in the forest areas and this makes Forest Department an important waste generator in addition to Indian Railways and Defense Cantonment. Few other stakeholders needs to be identified and recognized in the given rules as in addition to waste-pickers- they i.e. scrap dealers and itinerant buyers (kabadiwallah) are the backbone of informal plastic waste recycling systems.
Itinerant buyers or kabadiwallas purchase small quantities of scrap from households, offices, shops and other small commercial establishments and sell it to retail scrap dealers or recycling units directly.
Retail scrap dealers or small junk dealers purchase scrap commodities by weight or unit from wastepickers, itinerant buyers and directly from households, offices, shops and other commercial establishments.
Informal recycling industry refers to the recycling pyramid in which the bottom most layer consists of waste collectors, the second layer of itinerant buyers and small scrap traders, the third layer of large scrap traders and the fourth or the top most layer being the recyclers/reprocessors.
Processors/Reprocessors and Recyclers Reprocessors/processors and recyclers are largely located both in the formal and informal sector and use scrap as their raw material. They range from small scale enterprises to medium size labour intensive industries to automated multinational factories in the case of paper and glass. All enterprises need capital investment and utilize power for their operations.
Persons engaged in the recycling industry includes all persons engaged as waste collectors, outsourced or contracted municipal waste collectors, itinerant buyers, scrap traders and those employed in the trade, processing and reprocessing industry.
|Section 4 Conditions f||Sachets
sachets using plastic material shall not be used for storing, packing or selling gutkha, tobacco and pan masala;
|Must include phasing out of sachets as a means of packaging completely|
|Section-51a||Plastic waste management
Wet bio–degradable waste, dry recyclable and combustible wastes and domestic hazardous wastes shall be segregated at source in accordance with the Solid Waste Management Rules, 2015
|Our submission to MSW Rules also states the three categories as follows:
Wet waste or biodegradable waste
Dry waste or non-biodegradable waste
Sanitary waste and Hazardous waste
We believe that Sanitary waste must not be mixed with Dry waste
We also firmly demand that the rules must
Remove the word combustible waste as otherwise it means any waste that can be burnt,(which includes newspapers, magazines, books, clothes, shoes, trimmings from lawns, trees, shrubs and flower gardens, pasteboard boxes, rags, paper, straw, sawdust, packing material shavings, wooden boxes and objects and all rubbish and refuse that will incinerate)
And if the Ministry is emphazing on is on recycling, the document must clearly define combustible waste
We propose that combustible waste are limited those waste that cannot be recycled currently and CPCB must ensure through EPR impose guidelines on developing recycling technologies
|Section-51b||Plastic waste, which can be recycled, shall be channelized to registered plastic waste recycler and recycling of plastic shall conform to the Indian Standard: IS 14534:1998 titled as Guidelines for Recycling of Plastics, as amended from time to time.||“Plastic waste, which can be recycled, shall be channelized with the help of wastepickers, itinerant buyers and scrap dealers to registered waste recycler and recycling of plastic shall conform to the Indian standard: IS 14534:1998 titled as Guidelines for Recycling of Plastics, as amended from time to time.”|
|Section 5 ( 2)||Urban local bodies shall encourage the use of plastic waste by adopting suitable technology such as in road construction, for energy recovery, etc. in compliance with the standards and pollution control norms specified by the prescribed authority in this regard.
|The use of plastic waste in other technologies other than recycling , such as in road construction, for energy recovery etc, shall limit the use of plastic waste only to such plastic waste which cannot be recycled and in compliance with the standards and pollution control norms as specified by the prescribed authority in this regard.|
|Section 5 ( 3)||Processing and disposal of plastics including thermo-set plastics shall be as per the guidelines issued by the CBCB from time to time||Processing and disposal of plastics including thermo –set plastics , by energy recovery including road construction, shall be as per the guidelines issued by the CPCB from time to time, and limited to non Recyclable plastics ( Thermoset and others) like multi layer and laminated plastics, PUF, Bakelite, Polycarbonate, Melamine , Nylon etc.
Processing and recycling of recyclable plastics ( Thermoplastics) like PET, HDPD, LDPE, PP,PVC,PS etc shall be in adherance to the guidelines issued by the CPCB from time to time . Further, shall be in adherence to the Recycling targets set by the CPCB guidelines , allowing for access by waste pickers in such recycling activity.
|Section-6(1)||Responsibilities of urban local body-
Every urban local body shall be responsible for development and setting up of infrastructure for segregation, collection, storage, transportation, processing and disposal of the plastic waste either on its own or by engaging agencies or producers.
|should read as “Every urban local body shall be responsible for development and setting up of infrastructure for secondary segregation, collection, transportation, processing and disposal of plastic waste with the help of producers. Wastepickers, scrap dealers, itinerant buyers must be involved in secondary segregation, collection of plastic waste.”|
Section 7 3 a
|ensuring segregation, collection, storage, transportation, processing and disposal of plastic waste;||should read as “ensuring source segregation, collection, storage, transportation, processing and disposal of plastic waste;”|
|Section- 8(2)||Responsibilities of waste generator||should read as “All institutional generators of plastic waste, shall segregate and store the waste generated by them in accordance of Solid Waste Management Rules, 2015 and handover segregated wastes with the involvement of wastepickers, itinerant buyers and scrap dealers to authorized waste processing or disposal facilities or disposal centers either on its own or through the authorized waste collection agency.”|
|Section- 9(1)||Responsibilities of producers||should read as “The producers, within a period of six months from the date of publication of these rules, shall work out modalities for waste collection system including creation of collection centers (on the lines of Dry Waste Collection Centers in Bengaluru) based on Extended Producers Responsibility and involving State Urban Development Departments, either individually or collectively, through their own distribution channel or through the urban local bodies|
|Section- 15(4)||Explicit pricing of carry bags||should read as “The urban local body shall utilize the amount paid by the customers for the carry bags exclusively for management of dry waste collection centers- units set up for collecting and streamlining plastic waste collection and their sale to recycling units thereby increasing the sustainability of the waste management system within their jurisdiction.”|
Recognizing Multi Dwelling Generators either as a part of institutional generators or creating a separate category in definition is must and we should suggest the definition of it should read as follows:
|Multi Dwelling generator||Multi Dwelling generator means any residential multi household unit be it an Apartment , apartment complexes, gated community, residential campus or whatever name called||The Rules must recognize in the Residential segment a grouping of households as compared to a single household unit.|
There are few generic suggestions we have which are as follows:
- Bringing online retail companies (producers) under the ambit of the Plastic Waste Rules, 2015 as they use a lot of plastic material in packaging of the material. Online shopping is going to grow 200 times over the next 5-10 years and needs to be reformed at the earliest before it expands at a massive scale. Packaging material like thermocal should be completely phased and be replaced by honey comb paper packaging.
- Polyester which is polyethylene terephthalate (a plastic material product) is completely left out and should be addressed in Plastic Waste Management Rules, 2015 and producers of polyester should be brought under the ambit of Plastic Waste Rules, 2015
- Explicitly mentioning sanitary pads, diapers in the document is must to bring their producers under Plastic Waste Rules, 2015. Used sanitary pads and diapers are a major nuisance and promise a considerable health risk, Municipal body alone cannot manage them. Stringent enforcement of EPR forcing producers to take the used product back is important to mitigate public health risks.
We have emphasized a lot on replication of ‘Dry Waste Collection Centers’ model initiated by Bruhat Bengaluru Mahanagara Pallike (Greater Bangalore Municipal Corporation) across India as we believe that it is one of the best practices which if extended further can streamline the collection of dry waste including plastic waste in the most sustainable manner and also will pursue local bodies for inclusion of informal waste workers i.e. wastepickers, scrap-dealers and itinerant buyers.
Kabir Arora, Coordinator, Hasiru Dala; Nalini Shekar, Executive Director, Hasiru Dala; Pinky Chandran, Trustee, Hasiru Dala; Sandya Narayanan, Member, Solid Waste Management Round Table; Kuttikrishnan P.C, Founder, Bumberry; Venugopalan C., Founder, Bumberry.
Address: Hasiru Dala C/O Radio Active, #1/1-1, Atria Towers, Palace road, Bengaluru-560001
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