Revised Solid Waste Management Rules Mandate Inclusion of Wastepickers!

The recently released Solid Waste Management Rules, 2016 are a matter of celebration. They acknowledge the contribution of wastepickers in keeping our cities clean. Prescriptions are made for the inclusion of waste pickers and informal waste workers (identified as informal waste collectors) in waste management services. There are few flaws in the given document, those need to be rectified while making policies and plans for solid waste management at the state and city level as mandated by the rules.

Clear mandate for inclusion of wastepickers in door to door collection and other waste management services

The rules define wastepickers and other informal waste collectors, respectively as follows:

“waste picker” means a person or groups of persons informally engaged in collection and recovery of reusable and recyclable solid waste from the source of waste generation the streets, bins, material recovery facilities, processing and waste disposal facilities for sale to recyclers directly or through intermediaries to earn their livelihood.

“informal waste collector” includes individuals, associations or waste traders who are involved in sorting, sale and purchase of recyclable materials.

As per our understanding of the waste economy hierarchy i.e. apart from wastepickers; itinerant (kabadiwallas) buyers, scrap dealers etc. have all been clubbed together in the definition of ‘informal waste collector’. Such a measure is welcome as it is inclusive of all relevant vocations in informal waste economy. Further, the rules propose issuance of occupational identity cards to wastepickers and informal waste collectors and their integration in door to collection as responsibility and duty of local authorities and village panchayats, rules also command setting up of material recovery facilities which enables wastepickers and waste collectors to separate recyclables from the waste, and state that incentives need to be provided to recycling initiatives by informal waste recycling sector. Local bodies have been asked to do capacity building of wastepickers and waste collectors through training. For the strengthened implementation of rules, department in charge of local bodies of all state governments have been asked to constitute state level advisory committees, which will have representative of waste pickers and informal waste recyclers.

It is worth mentioning that the representative of wastepickers: General Secretary of Kagad Kach Patra Kashtakari Panchayat- Harshad Barde was included in the committee to finalize these rules. We are grateful to all committee members including Harshad Barde for such a commendable job.

Coming to the measures which need to be rectified are:

• Source segregation: The rules prescribe source segregation in 3 categories: Dry, Wet & Hazardous Waste. Instead of streamlining sanitary waste separately, they suggest that waste generators ‘wrap securely the used sanitary waste like diapers, sanitary pads etc., in the pouches provided by the manufacturers or brand owners of these products or in a suitable wrapping material as instructed by the local authorities and shall place the same in the bin meant for dry waste or non- bio-degradable waste.’ This is unacceptable, sanitary waste should be considered a separate stream and should not be mixed up with dry waste. As we know dry waste will be sorted by wastepickers in secondary collection center or material recovery facility, in case of Bengaluru- those are termed as Kartvavya/ neighbourhood dry waste collection centers. If sanitary waste is mixed with dry waste, while sorting wastepickers will be forced to touch the human excreta and other biological waste, which is a violation of prohibition of manual scavenging act. Therefore, while framing state and city plans collection of sanitary waste should be separately streamlined as is done in Bengaluru through the enforcement of 2 bin 1 bag. 2 bins for organic waste and sanitary/reject waste respectively and bag for dry waste. Karnataka High in its order given on 16^th December, 2015 has also directed the implementation of 2 bin 1 bag concept at household level. For reference- definitions of dry, biodegradable and hazardous waste have been provided here: “dry waste” means waste other than bio-degradable waste and inert street sweepings and includes recyclable and non-recyclable waste, combustible waste and sanitary napkin and diapers, etc; “biodegradable waste ” means any organic material that can be degraded by micro-organisms into simpler stable compounds; “domestic hazardous waste” means discarded paint drums, pesticide cans, CFL bulbs, tube lights, expired medicines, broken mercury thermometers, used batteries, used needles and syringes and contaminated gauge, etc., generated at the household level.

• Removal of quantity from definition of Bulk Generator: “bulk waste generator” means and includes buildings occupied by the Central government departments or undertakings, State government departments or undertakings, local bodies, public sector undertakings or private companies, hospitals, nursing homes, schools, colleges, universities, other educational institutions, hostels, hotels, commercial establishments, markets, places of worship, stadia and sports complexes having an average waste generation rate exceeding 100kg per day. The mention of quantity makes it cumbersome to identify bulk generators as most of these institutions don’t generate uniform amount of waste every day. For example, on a day of festival a temple must be generating around 500 kilograms of waste and on a regular day it’s waste generation doesn’t exceed 50 kilograms. In such cases monitoring of average waste generated will be next to impossible. It is suggested that the definition should exclude mention of quantity of waste generation i.e. average waste generation rate exceeding 100kg per day.
• Rules command manufacturers or brand owners of sanitary napkins and diapers to ‘explore the possibility of using all recyclable materials in their products or they shall provide a pouch or wrapper for disposal of each napkin or diapers along with the packet of their sanitary products. All such manufacturers, brand owners or marketing companies shall educate the masses for wrapping and disposal of their products.’ As per the principle of Extended Producers’ Responsibility the duty of manufactures and brand owners should not be limited to providing packets for their products but also taking the charge of creating disposal facility for sanitary waste with the support of municipal authority.

While getting in the implementation mode, we will have to do course correction time to time and the list of suggestions for strengthening waste management will not be exhaustive. There are visible improvements in the standards for scientific landfill, leachate, compost and incineration/co-processing facilities. It needs a separate analysis and therefore, has not been mentioned in this post. There are many features which this post has not touched upon but we will be doing so in the coming days and weeks. To conclude, I would like to state that out of 10 demands made to the union ministry by Alliance of Indian Wastepickers, a network of wastepickers organisations from all over India, 7 have been fully or partially satisfied in the framing of rules. A lot has been stated, a lot needs to be done. It is time for some rectification and rest implementation.  implementation and implementation.

For reference demands are given below:

1. Waste-pickers and informal waste recyclers should be identified, registered, authorised and integrated into the solid waste management system by local governments. Thereby, should be recognized and identified as green collar workers.
2. Occupational Identity cards should be issued to waste-pickers by the local/Municipal governments with the involvement of waste-pickers’ collective.
3. Sorting (secondary segregation/ fine segregation) should be recognized as a crucial activity in SWM. Space for sorting and temporary storage of recyclables should be made available for waste-pickers in a decentralized manner.
4. Waste-pickers should be afforded free and easy access to recyclables at source of generation as well as at secondary storage, material recovery, transfer, processing and disposal facilities.
5. Introduce a comprehensive EPR policy under both Municipal Solid Waste and Plastic Waste Management rules to tackle difficult streams of waste such as sanitary waste, multi-layered packaging etc. and providing support to waste-pickers in collecting and diverting low value recyclables.
6. Manufacturers of sanitary products like diapers, sanitary napkins etc. should be required to provide uniquely marked leak proof bags for the safe disposal of each individual product.
7. Waste-pickers should be allowed to retain the waste collected by them.
8. State and local governments should promote integration of waste-pickers into solid waste management systems by:
   1. Incentivizing formation of membership based organisations of waste-pickers including self- help groups, cooperatives, unions and companies.
   2. Preference for integration into door-to-door collection and processing facilities
   3. Authorize waste pickers to collect user fee from the beneficiaries of their services
   4. Handing over management of material recovery and other waste processing facilities to collectives of waste-pickers.
   5. Training and capacity building of waste-pickers in fine sorting, composting, bio-methanation and scrap shops management
   6. Provision of safety equipment, social security and health benefits to waste-pickers, including inclusion in housing schemes, food and security measures (for their children) as priority.
9. National, State and Local policies/ strategies/ plans should be made in consultation with waste-pickers and their organisations.
10. Waste-pickers should be involved in monitoring and advisory committees.
11. Viability gap funding, tax concessions, credit at low rate of interest etc. should be made available to participants in the informal waste recycling sector.