To: Dr.D.Boralkar
Member Secretary
MPCB
Kalpataru Point
Sion
Mumbai 400022 

Sub: Common Biomedical Waste Treatment Facilities in Mumbai  

In order to minimize the environmental and public health consequence of the CBWTFs, we  strongly urge that the following points be incorporated in the MPCB's protocol for biomedical waste management and development of new CBWTFs in Mumbai:  

1. No more incineration for the City of Mumbai 

As we have mentioned in previous correspondence, we believe that Mumbai already has sufficient capacity to handle Category 1 and 2 wastes. We therefore, stand against any proposals or plans that allow for incineration in Mumbai and surrounding regions. 

2. Increased monitoring and efficacy 

We believe that the City of Mumbai and surrounding regions need one or a maximum of two CBWTFs (including Taloja) to cater to the biomedical waste needs. This will facilitate monitoring and regulation of waste from hospitals to the site/s and from the site/s to landfills. The purpose of the CBWTFs is to allow for centralised monitoring and smooth functioning of the waste disposal proposal to prevent public health hazards from occurring. If MPCB is incapable of monitoring existing sites closely, we see no need to invest in new sites that will add more to MPCB’s responsibilities. It is therefore, more resource efficient and safer for our city and its citizens if MPCB has one or maximum two sites that it needs to monitor for health, safety and environmental concerns.  

3. Selection of any new site 

Keeping the above point in mind, we are united as citizens concerned with health and well-being, that none of the CBWTFs are to be located in residential areas or parks, playgrounds and recreation grounds (as designated by the development plan for that purpose)   
 
4. Site selection committee shall be constituted as follows    

The committee responsible for short-listing the sites must include representatives from citizens' groups and environmental organizations. We believe that the ultimate cost of this project will be borne by citizens of Mumbai and surrounding regions. This is because the CBWTFs are being constructed on public lands which could be used for other purposes and with the cost of disposal being incurred by hospitals, it is also a matter of time before this cost is then transferred on to patients, i.e. citizens and taxpayers. It is for this reason we strongly urge you to include citizens' groups, resident societies, alms and other interested stakeholders as an integral part of the selection and setting up of the CBWTFs.  

5. Public hearing on site selection 

The selection process must include a public hearing. The list of possible sites must be    made public at least a month before the selection process begins. The notice for the public hearing must appear in major daily newspapers, English, Hindi and Marathi, at least three times in the week before the public hearing.  The minutes of the public hearing must be recorded by representatives from MPCB as well as by representatives from local citizens' groups. The final minutes must be approved by all actors, and must be published within a week after the public hearing. The public hearing process must provide full and complete information about the CBWTF to the local communities. 

6. Monitoring of the selected site 

Once the site/s are finalized, citizens' monitoring groups must be formed as an integral part of MPCB’s and the BMC's monitoring committee for such sites. These monitoring groups (the composition of which will be decided in consultation with local civil society organizations and environmental groups) must be given complete access to the facility at all times. The groups must also have ready access to the MPCB, and systems must be set up to act on any complaint/suggestion from the monitoring group immediately. The monitoring groups must also have access to all data and documents pertaining to the functioning and operations of the facility, including details of waste procured from each healthcare establishment. 

7. Monitoring hospital performance in segregating waste correctly  

Comprehensive record keeping systems must be put in place and enforced at every healthcare establishment and the CBWTFs. This should include daily records of the category and quantities of waste generated by a particular hospital and the category and quantities received by the CBWTF from that same hospital, along with particulars of transportation (vehicle number, driver's name, time of pick-up and final disposal of the waste). 

8. Minimizing waste so that there is less to treat at the end      

An upper ceiling on the quantity of yellow bag waste generated by a hospital must be established – for instance, not more than 20% of the total waste generated by the hospital. The CBWTF operator must be required to check this every day and report any irregularities to the MPCB immediately. If a hospital crosses this limit, MPCB should do a surprise audit of the hospital in conjunction with BMC staff who have access to the hospital sites. The rationale behind this is simple, as a government agency interested in reducing pollution in our state, MPCB’s responsibilities include ensuring that there is minimum amount of waste being incinerated. 

9. MPCB’s role in waste management should include efforts to reduce waste 

If there is less waste generated by hospitals, it serves MPCB's purpose and goals to reduce pollution. All of Mumbai's problems cannot be dealt with by simply having machines at the end of the pipe disposing the waste. The key to Mumbai's medical waste problems is MPCB’s working closely with hospitals and their associations to reduce the quantity of waste generated by them. As hospitals across the country invest in newer technology for treatment of patients, they are also increasing their packaging and other non-essential product use, encouraging a culture of increased waste. We believe that reducing waste coming out of hospitals is MPCB’s primary responsibility. We therefore recommend that a special cell must be set up at the MPCB to look into all matters relating to Biomedical Waste Management (BWM). In addition to MPCB officials, the cell should include an advisory board comprising of civil society organizations and representatives from healthcare organizations. This cell will be responsible for daily monitoring of healthcare establishments, CBWTFs and BMW transporters and treatment vendors.

10. Dealing with public concerns and complaints     

All complaints/suggestions from monitoring groups, the public, from healthcare establishments and the CBWTF operator will be addressed by this cell. Regular inspections of records and surprise checks at healthcare establishments and the CBWTFs are a must. Any irregularity must be reported to the advisory board and necessary action must be taken. Stringent penalties for violation of guidelines and rules must be imposed. Feedback and reports from the cell and the advisory board will directly influence the renewal or revoking of the authorization/license of the CBWTF or healthcare establishment. The BMW cell will also enforce payments by the healthcare establishments to the CBWTF operator, will enforce proper supply of bags/sharps containers and regular collection of waste by the CBWTF operator, and will promptly look into complaints of improper segregation from the CBWTF operator and of irregular supply/collection from healthcare establishments.  We strongly recommend a financial penalty to hospitals for improper segregation practices. This is so that the public health costs (ill health of citizens, waste workers and transporters injured) incurred from their mismanagement of waste is compensated for by the hospital committing the irregularity. 

The MPCB published a report on The Status of Some Common Facilities for Collection, Treatment and Disposal of Biomedical Waste in Maharashtra, in August 2004 that notes that biomedical waste is not adequately segregated at the healthcare establishments, that collection is irregular, and that waste is regularly diverted to the scrap market, often not reaching the facility. The survey also brought out very disturbing revelations including the fact that the primary and secondary chambers of incinerators in many of the facilities rarely achieved the recommended temperature and that on line temperature recorders for the same were not provided by the operator. In addition, the survey discovered that the installed capacity of incinerators in most of the CBWTFs was much more than the actual generation of incinerable waste, thus pointing to the need to augment these facilities by allowing them to cater to additional areas in the vicinity. The report also stressed on record keeping, noting that most of the facilities did not maintain daily category wise records of BMW collection from individual generators. 

The report concluded with recommendations and a proposed action plan, which incorporated specific time frames for the various activities. Some of the recommendations and activities that were to be immediately undertaken by the MPCB included: 

Monthly inspection and monitoring of the CBWTFs

Issuance of directions to upgrade all units in the facilities to the prescribed standards, and to install on line temperature recorders for the incinerators.

Legal action against generators who are not sending waste to the facility or who are not segregating waste properly.

Establishment of a regional taskforce for monitoring and advice, comprising of representatives from the IMA, from the local body, from NGOs and the State Health Department.

Inventory of biomedical waste generating units and category-wise waste generated.

It is imperative that the MPCB act on the findings of this survey and citizen comments as addressed above to ensure that its future actions are in line with the same. 

We request that you get back to us with clarifications on the current status of the CBWTF establishment process, as well as on the status of the action plan delineated in the 2004 Report. We would also like to meet with you to discuss the MPCB's responses to our recommendations, and to collaboratively draw up a plan for safe, sustainable and effective biomedical waste management in the city of Mumbai .

Mumbai Medwaste Action Group (MMAG)  
4^th Floor, CVOD Jain School , 84 Samuel Street , Dongri, Mumbai – 400 009
Tel : (022) 23434754 / 6692  Email: mumbaimedwaste@gmail.com