Comments for Draft Municipal Waste (Management & Handling) Rules, 2013
Sent to Ministry of Environment and Forests on 29th October, 2013
A. Administrative Responsibilities
1. We think, waste is a quite big problem and a separate nodal agency or authority as ‘Central Waste Management Board’ (CWMB) similar to Central Pollution Control Board should be formulated which will act as nodal authority for collection, segregation, transportation and other developments for the disposal of municipal solid waste. CPCB should be responsible for monitoring of compliance pollution and other hazardous materials arising from the waste handling procedures and disposal. The State Level Advisory Committee (SLAC) should be nodal agency for the states under CWMB. The SLAC shall meet atleast three monthly and the compliance reports should be submitted by regional nodal officers every six months.
2. All the minutes of meetings, agenda for the forthcoming meeting and every proceeding related to the working of the
CWMB and SLAC, annual reports (as mentioned in para 11 of the draft notification), compliance reports and other documents should be made pro-actively public through a dedicated website.
3. Site inspections should be mandated to be conducted by SLAC such that four season’s (summer, monsoon, post-monsoon and winters) observations could be made. Yearly site inspection by CWMB shall be mandated. All the details of site visit and reports shall be put into public knowledge pro-actively through websites and other communication method.
4. The local RWAs, Housing Societies should be encouraged to recycle/compost their biodegradable waste. This can be done through knowledge-sharing, institutional support in the local initiatives and promotion of the products such as recycled papers and organic manure.
5. Waste-collectors (Rag pickers) play an important role in solid waste management. Hence they their contribution should be acknowledged by identifying all the Waste Collectors of the city and issuing them a license from the Municipal Authorities to collect waste.
i. In order to earn a license, a short but intensive professional-training along with a proficiency-test (which can be conducted by the Municipal Authorities) should be mandatory for obtaining a license.
ii. The training should cover aspects of Health, Bio-medical and Environmental safety along with impetus on Best-practices and Stress-Management.
iii. After qualifying the test, the qualified professionals could be issued a set of essential equipment (e.g. a set of gloves) for their job. The quality of gloves and other equipment must be approved taking into consideration the nature of work they would be undertaking and it must be approved by a Material-Engineering and Health Institute.
iv. Moreover, the qualified waste-collectors should also asked to enroll themselves in a continuing training module, which would train them on various aspects from time to time, preferably in the evenings. They should also be encouraged to take part in Adult and continuing Education programs of the govt. (E.g. Sakshar Bharat)
v. A set of Minimum support-prices can be fixed for the certain categories of waste collected by the rag pickers. (e.g. newspaper, PET Bottles)
vi. Monthly Health Check-up camps should be organized at the Municipality Offices or at any suitable place for proving health-support for the waste-collectors
B. Specification of landfill site:
1. A guideline notification on siting criteria of landfill sites should be prepared in consultation with reputed institutes and stakeholders from different parts of the country. The guideline should also consider the regional topography and it should clearly mention the procedure to assess suitability of landfill sites and which type of surroundings to be avoided. A minimum safe distance from residential areas and other regions frequented by people should be decided and mandated for all landfill sites.
2. During monsoon, the temporary soil covers may not be sufficient. The standards for texture of soil and permeability coefficient to be used for such covering should be decided and strict compliance to the standards should be monitored. The soil shall be stored in a nearby place such that during rainy seasons in non-monsoon time, the same can be used for next 15 days.
3. The climatic conditions suitable for landfills with other related factors like methane generation should be considered for landfill sites.
4. The after use plans for the landfill sites should be planned at the time of commissioning the landfill as there may be future possibility of expansion of urban areas to the proposed landfill sites.