Bio-Medical Waste (BM waste) is generated during diagnosis, treatment or immunization of human beings or animals or research activities. The Government of India framed Bio-Medical Waste (Management and Handling) Rules, 1998 (BMW Rules) to streamline the procedure for collecting, handling, transporting and disposing of biomedical (BM) waste. The recently-released “Report of the Comptroller and Auditor General (CAG) of India on General and Social Sector” has revealed that the Gujarat government has been negligent in implementing most of the provisions of the BMW Rules. A counterview.org report:
The CAG has found that the implementation of BMW Rules was deficient, as only 19 out of 80 government HCEs test-checked had authorisation under BMW Rules.” Further, “in 56 Government HCEs, segregation of BM waste in colour-coded containers had not been done and BM waste was mixed-up with municipal waste. The common BM waste treatment facilities were not created as per norms and were not functioning properly.” Worse, “Feeding of BM waste in incinerators and autoclaving was found to be done manually. In some cases, BM waste was disposed of by burning/dumping. Deep burial of BM waste as per the rules was not ensured.”
The BMW Rules provide that every occupier of an institution generating, collecting, receiving, storing, transporting, treating, disposing and/or handling BM waste in any manner was required to obtain authorisation from the Gujarat Pollution Control Board (GPCB) and occupier/operator to maintain records in respect of BM waste handled during the year and has to submit an annual report to the prescribed authority. In order to take stock of the quantum of BM waste generated in the state, health Care Establishments (HCEs) were to be listed.
“However, Gujarat’s health department was registering only government HCEs and no authority was designated with the task to take stock regarding the non-Government HCEs. Hence, the information regarding non-Government HCEs was not available with the Department”, CAG says.
In fact, CAG’s scrutiny of the annual reports submitted by the GPCB to the Central Pollution Control Board (CPCB) reveals that a large number of HCEs were running without authorisation. Out of the test checked 80 HCEs, only 19 had authorization, as required under the rules. “In rest of the HCEs, either the information regarding authorisation was not available or the HCEs were operating without obtaining the same from GPCB”, CAG points out.
Non-segregation of biomedical waste
Segregation is the first step in the entire process of BM waste management and its improper segregation results in mixing of other wastes with BM waste, rendering the other wastes also toxic and hazardous. As about 15 per cent of hospital waste is hazardous, proper segregation could considerably reduce the quantity of waste as well as cost of treatment and disposal. Rule 6(2) of BMW Rules provide that the waste shall be segregated at the point of generation and collected into appropriate colour coded bags.
However, CAG says, “Test check of the records in the 80 HCEs revealed that in 56 HCEs segregation was not done as per requirement. This resulted in improper segregation and consequential improper treatment posing health hazards.” Worse, there was “mixing up of BM waste with municipal solid waste”, which is against the rules. The BM waste has to be kept separate from other wastes. “However, out of 80 HCEs test checked, BM waste was found mixed up with municipal solid waste (MSW) in 58 HCEs (73 per cent). This waste was disposed off in open landfill site, which was in contravention to the BMW Rules”, says CAG, adding, “In addition, the waste could cause infectious diseases to those human/animal/birds arriving at the landfill sites, including the employees of ULBs, rag pickers, etc.”
CAG finds delay in the collection of BM waste as a major health hazard. The BMW Rules provide that no untreated BM waste shall be kept stored beyond a period of 48 hours. When it becomes necessary to store the waste beyond 48 hours, prior permission of the prescribed authority was necessary. “Joint visit at the hospitals with GPCB officials revealed non-collection of the BM waste (for two or more days) by the Common Bio-Medical Treatment Facilities (CBMWTF) operators beyond 48 hours”, CAG says.
The Health and Family Welfare Department installed (between 1999 and 2009) 41 incinerators for treatment of BM Waste in different taluka and district hospitals across the state at a cost of Rs 1.99 crore. These incinerators remained inoperative for a period ranging from four to 10 years due to repeated breakdowns and operational problems. “The incinerators were not got repaired; instead, the hospitals obtained membership of CBWTFs operating in their areas for treatment of the BM waste generated”, CAG says.
Coming to the operation of individual incinerators by HCEs, out of 80 HCEs test checked by CAG, 59 HCEs were members of CBWTFs, 18 were adopting deep burial method disposal and the remaining three HCEs (Motibanugar, Navi Pardi and Sarbhon) were neither member of CBWTF nor having deep burial facility. Out of 80 test checked HCEs, only three HCEs (Ahmedabad, Surat and Vadodara) had their own incinerators.
According to the BMW Rules, while operating incinerators, the temperature of the primary chamber was to be maintained at 800±50º C and the secondary chambers resistance time was to be kept at 1050± 50º C for at least one second. CAG found that:
- Temperature of primary chamber ranged between 490-430ºC and temperature meter of secondary chamber was not in operation.
- Water used for cleaning site of incinerator was discharged into the drain of Surat Municipal Corporation (SMC) without any treatment.
- The incinerator did not have any mechanical device (such as belt conveyer etc.) for conveyance and the waste was being fed manually.
CAG comments, “When improper functioning of incinerators was brought to notice, hospital authorities outsourced (April 2012) the disposal of BMW. However, the fact remained that infrastructure remained unutilised and expenditure incurred thereon remained unfruitful.”
A study of the Sir Sayyajirao Civil Hospital, Vadodara revealed the hospital had not obtained Consolidated Consent and Authorisation (CCA) from GPCB under the provisions of Hazardous Waste (Management and Handling) Rules, 1989 to operate the same and were being utilised without GPCB’s authorization. There were no recordings of the temperatures of the chambers, in the absence of which maintenance of operational parameters could not be ascertained. There was no graphic or computer recording devices to automatically and continuously monitor and record dates, time of day, load identification number and operating parameters throughout the entire length of the incineration cycle. A diesel incinerator was lying idle in inoperative condition.
Common BMW treatment facilities
A Common Bio-medical Waste Treatment Facility (CBWTF) is set up and operated by private players with the consent of GPCB, where BMW generated from a number of HCEs is treated. The CBWTF should be submitting quarterly and annual reports to the GPCB. Accoording to CAG, in all, 13 CBWTFs were operating across the state. In its joint visit of five CBWTFs with GPCB officials, CAG noticed —
- As per CPCB guidelines only one CBWTF was allowed to cater the need of up to 10,000 beds in a radius of 150 km. Scrutiny of the quarterly statements furnished by the operators of the CBWTF to the Regional Offices (Surat and Vadodara) revealed that two CBWTF had exceeded the limit of 10,000 beds and were covering more beds in the absence of facility in the area.
- During scrutiny of the records of two CBWTF, it was also found that some of the hospitals were sending waste in blue bags or in yellow bags only, which reflected improper segregation of the BM waste. None of the hospitals sent potentially infectious plastic waste in red bags, which led to improper handling of waste. Mixed-up waste was being disposed of by the CBWTF according to the colour of the container bag.
- According to the operating standards in respect of the incinerators the combustion efficiency should be at least 99 per cent; however, the GPCB did not carry out the test till date as the facility for the same was not available with them.
- Out of these five incinerators, two were having mechanical devices for waste feeding; however, at other three sites of CBWTF, waste feeding was being done manually. CBWTF, quantum had hydraulic device for waste feeding; however, at the time of visit, the same was not functional and the waste was being fed manually. The bigger incinerator was equipped with mechanical device for waste feeding; however, the smaller one, which was operational at the time of visit, was not having any such device and the waste was fed manually.
- Out of 43, 12 hospitals/clinics were not giving their BM waste to the CBWTF for disposal though they have obtained the membership; however, the reasons for the same were not available on record.
- Autoclaving (steam sterilization) is prescribed for disinfecting and treating micro-biology and bio-technology waste, sharp waste and soiled waste. As per BMW Rules, each autoclave should have graphic or computer recording devices which will automatically and continuously monitor and record dates, time, load identification number and operating parameters throughout the autoclave cycle. Graphic/computer recording devices were available with three CBWTFs. However, in respect of Samvedana and Care CBWTFs the same was being done manually.
Burning of BMW in the HCEs
The treatment/disposal of BM waste by incineration/deep burial, autoclaving shredding etc. depends on the type of the waste. Burning of BM waste is nowhere prescribed as a mode of treatment in the Rules. However, joint inspection of 80 HCEs revealed that in 48 HCEs the BM waste was being disposed by burning.
The BMW Rules provide for deep burial of Category-1 and Categorty-2 of BM waste in towns having a population of less than five lakh and in rural areas. The location of the site of the deep burial was to be identified in consultation with the GPCB. In the test checked HCEs, 18 PHCs resorted to deep burial method for waste treatment without adding any layer of lime and soil. In addition to this, following deviations from BMW Rules were also observed:
(a) In PHC, Samlaya (Vadodara), the site of deep burial was not being utilised for the last two years. On opening the pit during joint visit, it was found that the same was one metre in depth and did not have any trace of BM waste having been buried there. Instead, the BM waste was being disposed of by burning and mixing with solid waste handled by civil body. In PHC Sandhasal (Vadodara), the deep burial site was found uncovered.
(b) The PHC, Motibanugar (Jamnagar) was neither a member of common treatment facility nor it had any deep burial system for disposal of the BM Waste. Only one sharp pit was available in the PHC which was not in use for a long time. Hence, all the waste generated was being disposed unscientifically in an open kutcha pit, flouting all Rules.
(c) PHC, Chanod (Vadodara) used deep burial method for disposal of BM waste generated by it. However, the pit was destroyed and was not being utilised for last two-three years. Since then the hospital was throwing all its waste in an open well (adjacent to the tank through which water was supplied in the village) which was located in the middle of the village. However, no steps were taken by hospital authorities or the health department or by GPCB in the matter.
(d) PHC Bhatia (Jamnagar) used an open site for dumping the BM waste. The location of the site was adjacent to the Staff quarters constructed for the hospitals staff which was one kilometre away from Hospital.
(e) Despite being a member of CBWTF, the Community Health Centre, Savli (Vadodara), was dumping its BM waste in a pond and in an open well.
Poor GPCB monitoring
A task force (advisory group) also constituted (March 2005) by the GPCB for effective implementation of the BMW Rules with member-secretary, GPCB as its chairman and 14 other members. The first meeting of the task force was held in March 2005. In the first meeting of the task force, an Action Plan for BM Waste Management was prepared. Following activities were identified for better implementation of the BMW Rules in the State:
(i) GPCB would explore the possibility of grading/categorisation of health care as ‘Green Hospital’ based on their compliance of BMW Rules. However, no progress has been made in this matter. The GPCB stated that grading of the Hospitals based on their compliance to BMW Rules was not easy so there was no progress.
(ii) It was decided to set up at least one pilot plant on ‘Deep burial’ per region for study/demonstration to create awareness. However, the same did not materialise.
(iii) It was also decided to carry out a study for ‘Normative assessment of waste generation in different specialty of Health Care Units in Gujarat’.
Says CAG, “However, the GPCB has not conducted any such study. In reply, the GPCB stated that standard thumb rule for calculation of generation of BMW is adopted. GPCB stated that grading of hospitals, based on their compliance to BMW Rules required manpower and that due to staff crunch, no progress had been made. GPCB also stated that deep burial was not much encouraged and hence the recommendation of task force could not be implemented.”
As per the Environment (Protection) Act, 1986, failure to comply with or contravention of any of the provisions of the Act, would entail imprisonment and/or fine. According to CAG, “However, it was observed that though the GPCB issued 2,864 notices for violation of BMW Rules (2007-12), no penalty was imposed as there was no follow up action after issue of notices.”
CAG adds, “The GPCB replied (July 2012) that, according to the provisions of the Environment (Protection) Act for violation/non-compliance of the Rules, cases under Section 15 of Environment (Protection) Act are required to be filed before the court of law and that no court has till date imposed any fine and/or penalty to any HCE. Records revealed that as no court case has been filed by GPCB for such violation, no further penal action could be taken against the erring HCEs, which reflected laxity on the part of the GPCB in enforcement of the Rules.”