Hazardous wastes, bulk of which is generated by industries, can pollute and adversely affect human health if managed poorly. The effective management of such wastes with an emphasis on minimisation of generation and reuse, taking into account economic aspects, is therefore essential. India urgently needs an appropriate strategy for regulatory bodies, generators of wastes, recyclers and operators of the facilities to treat and dispose hazardous wastes in an environmentally sound manner.

Various interventions for environmentally sound management of hazardous wastes in the country - establishing regulatory and institutional framework, preparation of technical guidelines, development of individual and common facilities for recycle-recovery-reuse, treatment and disposal of hazardous wastes, inventory of hazardous wastes generation, identification and assessment of dump sites for the purpose of preparing remediation plans, and creating awareness amongst various stakeholders, have been undertaken. However, these activities need to be expanded, reinforced and strengthened. India needs to achieve ‘zero disposal of hazardous wastes’ through an infusion of cost effective innovative technologies, processes and practices. Further, the management of ‘end of life’ consumer products, containing hazardous constituents, such as used lead acid batteries, waste electrical and electronic equipment etc., must give primacy to recycle-recovery-reuse. Wastes not amenable to the aforementioned methods, needs to be subjected to physico-chemical or biological treatment, incineration or disposal in secured landfill.

A recent ‘National Hazardous Waste Management Strategy’ (NHWMS) by the Ministry of Environment and Forests (MoEF), incorporates the essence of the National Environmental Policy 2006 and relevant multilateral environmental agreements like Basel Convention and the National Regulations. The Strategy reiterates that import of hazardous wastes from any country to India for disposal shall not be permitted. (see box)

Hazardous Wastes Generation The inventory of hazardous wastes generating industries and hazardous wastes generated, prepared by the State Pollution Control Boards (SPCBs) in the states and Pollution Control Committees (PCCs) in the respective union territories (UTs) state that currently about 8 million tons of hazardous wastes are being generated per annum by the 30,000 odd hazardous wastes generating industries in India. The inventory has also brought out detailed information on quantum of wastes in terms of recyclable, reusable, landfillable and incinerable components. Such information facilitates better planning of common facilities for treatment and disposal.

Experiences of industrially developed nations indicate that 1 per cent increase in the gross domestic product (GDP) leads to a 1 to 3 per cent increase in generation of hazardous wastes. In such a situation, given the fact that the GDP growth in India is rapidly accelerating, it can be reasonably projected that the hazardous waste generation in the country would increase. Since industries change their products, processes, or capacity of production and as new industries get established, there is a need to periodically update inventories by the SPCBs and PCCs. Besides, it should be made mandatory on the part of industries to report changes and additions in hazardous waste generation and the steps taken by them to reduce generation of waste per unit of production. As per the Hazardous Wastes (Management, Handling and Transboundary Movement) Rules 2008, industries have to store hazardous wastes properly, and in accordance with authorisation issued by SPCBs and PCCs. The waste recycled either has to be reused or disposed in captive or common treatment, storage and disposal facility (TSDF) if available in the state, or incinerated in a captive incinerator of its own - based on type of waste. So far as the ‘end of life’ consumer products are concerned, no detailed inventory has been prepared, except for some rough estimates in respect of the e-waste. These are bound to increase in volume as the economy grows. 

Components of NHWMS

Waste Avoidance and Minimisation at Source In the hierarchy of waste management, waste avoidance and waste minimisation have to be attempted at the outset. This requires a close look at the processes generating hazardous wastes to incorporate feasible modification in processes, technologies and plant practices. Dissemination of information on technological options for such practices should, therefore, be a continuing exercise. Whenever switch over to cleaner processes involves substantial investments and import of machinery and technology, suitable financial incentives in the form of rebate in customs duty, etc., need to be considered :-

In the chemical industry, in particular, assessment of cleaner technologies needs to be taken up in major segments such as pesticides, dyes and bulk drugs, and their intermediates. In all such industries, wherever laboratory scale trials have been completed, setting up of pilot/demonstration plants needs to be encouraged through suitable incentives. This would enable speedier adoption of cleaner technologies by the industry.

In cases, where techno economic feasibility of cleaner production process has been well established and have been adopted by few industrial units, such as cyanide free electroplating, a dialogue should be initiated by governmental agencies to encourage the remaining set of industries to switch over to cleaner production options within a specified time period. In petrochemicals, bulk drug, pesticides and dye sectors, product wise opportunities available for recovery of resources, such as solvents, other reagents and byproducts as well as regeneration of spent catalysts have been well documented and need to be implemented urgently.  

Reuse-Recover-Recycle Hazardous

Wastes Second in the hierarchy of waste management is reuse-recover-recycle useful resources from wastes. To promote such options establishment of financially assisted, waste exchange banks and centres should be encouraged jointly and severally by MoEF and State Governments, which would provide information on waste technologies and up cycle the quality of resource recovery rather than down cycle it. For example, recycling of non ferrous metal wastes (zinc and brass dross, used lead acid batteries, copper oxide mill scale etc.) offers attractive options for resource recovery. The current gap between demand and supply of lead, zinc and copper as well as the projected widening of the gap due to rapid increase in demand arising from growth in the various sectors, serves as incentive for recycling of such wastes. As compared to primary production of metals, recycling is energy efficient and environment friendly. The recycling of used lubricating oil is another example of resource conservation.  At present, there are about 800 recyclers of non ferrous metal wastes, used oil and waste oil registered under the Hazardous Wastes Rules, 2008. The capacity registered for re-refining and recycling of used oil and waste oil is about 1.2 million KLA; that for non ferrous metal wastes other than lead is 1.3 million tons per annum; and for lead based waste it is about 0.75 million tons per annum. Barring a few large facilities, recycling is essentially handled by the small scale sector. As such, there are limitations on technology upgradation necessary to ensure reprocessing in an efficient manner. To promote technology upgradation, it would be necessary to offer incentives with up to date facilities which not only meet the CPCB guidelines but go beyond. One such incentive could be the preferential access to imports of nonferrous metal wastes and other wastes requiring MoEF permission to only those recyclers employing state of the art facilities.

Despite the registration scheme for recyclers, recycling in the unorganised sector with all its attendant environmental and health hazards is reported to continue. This underscores the importance of channelisation of wastes. While the Battery (Management and Handling) Rules 2001, mandate return of used lead acid batteries, compliance remains unsatisfactory. It would be necessary to extend the corporate responsibility concept to the producers, for instance, in the form of a buyback scheme.

At present, there are no environmentally sound reprocessing facilities in the country to recover toxic metals such as mercury from thermometers, fluorescent tube lights etc., and cadmium from batteries. Considering the potential for serious health impacts posed by codisposal of such hazardous wastes with municipal solid wastes, setting up of facilities for their reprocessing deserves to be accorded high priority.

E-waste, Electrical and Electronic

Equipments Recycling of e-waste such as components of waste electrical and electronic assemblies comprising accumulators and other batteries, mercury switches, activated glass cullets from cathode ray tubes and other activated glass and PCB capacitors etc., needs to be regulated as they possess hazardous constituents. The producers of electronic equipment will need to have a centralised facility as extended producer responsibility. In case of a facility created for indigenous e-waste, a minimum scale of operation for environmentally sound processing technology is essential thereby requiring sufficient e-waste for processing. For such facilities, import of e-waste may be considered. The export of e-waste may be allowed in the event of non availability of environmentally sound recycling facilities.  

Safe Disposal of Hazardous Wastes

Wastes which cannot be reused or recycled have to be disposed. Depending on the waste category, secured land disposal, incineration or any other mode of safe and environmentally sound disposal system should be adopted. Design and operational norms of such facilities, either captive or common should strictly adhere to the guidelines framed by CPCB. Post closure monitoring of the disposal facilities would also be necessary. Common facilities invariably need to be equipped with laboratory facilities to verify waste characteristics so as to decide upon treatment and disposal options including secured land filling or incineration. 

Common Hazardous Waste TSDF

Currently there are 23 common hazardous waste TSDFs in operation in 12 states. In addition, 64 sites have been identified and 35 sites have been notified for setting up of the disposal facilities. The notified sites are at different stages of development. The annual capacities of the TSDFs range from 10,000 tons per annum to 1.2 lakhs tons per annum with an operating life span of 15 to 30 years. Common facilities including integrated facilities have to be planned following the polluter pays principle, although at the initial stages, a certain level of assistance from the state governments could significantly accelerate the process of setting up of these facilities and also ensure their initial viability. Considering the urgency to set up common facilities, scientific planning backed by sound economic rationale is called for. Transportation could account for a significant portion of disposal cost in the case of landfillable wastes and as such the location of TSDFs should be close to the source of generation, within industrial estates. 

Interstate Transportation of Hazardous

Wastes Interstate movement of hazardous wastes will be required when the landfillable waste generated by a state is less than 10,000 tons per annum (TPA) and companies with units located in several states propose to incinerate wastes at one facility. In case of some states and UTs, particularly in the North-East, combined facilities with neighbouring states involving interstate movement appears to be a preferable option due to factors such as land availability and the amount of waste generated in each state for landfilling or incineration.  

Cement Kilns Incinerating Hazardous

wastes Incineration of high calorific value hazardous wastes in cement kilns is one of the safe alternatives to conventional incineration – with the implementation of suitable safeguards. The spread of cement industry in the country across the states makes this option particularly attractive. Sludge from petrochemical industry, oil refinery and paint industry as well as spent solvents from pesticide and bulk drug industries are particularly suitable for this purpose in view of their high calorific value. In cement kilns, high flame temperature of around 2000^oC, high material temperature of around 1400^oC and large residence time of around 4 to 5 seconds ensure complete combustion of all organic compounds. Acid gases formed during combustion are neutralised by the alkaline raw material. The non combustible residue including heavy metals is embedded into the clinker in an irreversible manner. However, it may become necessary to blend and process the wastes before they are suitable for use in the cement kiln.

The Central Pollution Control Board has conducted field trials for different waste categories and also arranged to carry out monitoring of all hazardous air pollutants. As field trials indicate, compliance of notified emission norms for hazardous waste incinerators, use of hazardous wastes, such as ETP sludge from dyes, tyre chips, paint sludge, tar residue and refinery sludge, as supplementary fuels in cement kilns need to be promoted. In fact paint sludge may be successfully used after reconditioning as a primer coating and has been in practice in some of the automobile manufacturing industries. Such reuse of hazardous wastes is a preferable option over coincineration and should be encouraged. 

Illegal Dump Sites and Remediation

In the absence of common facilities, illegal and clandestine dumping of hazardous wastes is reported in several states. Even after waste disposal facilities have become operational in many states the problem persists. Surveillance, both by enforcement agencies and the industry needs to be stepped up to avoid illegal dumping. Remediation of dumpsites based on scientific assessment of soil and groundwater contamination and modelling the projected future damage should be undertaken. The approach for site remediation would vary from site to site depending on the nature of pollutants, future damage potential, remediation cost etc.  

Strengthening of Infrastructure of

Regulatory Bodies The mantle of hazardous waste management regulation is primarily on SPCBs at the field level. For effective discharge of their responsibility, the boards have to be strengthened in terms of manpower, equipment, instruments and other infrastructure facilities. Apart from the board, customs department too plays an important role in regulating import of hazardous wastes into the country. Cases of illegal imports of hazardous wastes indicate the need to plug existing loopholes. Priority areas for action include harmonisation of EXIM Regulations with the provisions of Hazardous Waste Rules, training of customs department personnel engaged in inspection and sampling and also upgradation of customs department laboratories. Difficulties faced by customs authorities in distinguishing between used oil and waste oil serves as a case in point. 

Regulatory Framework In order to manage the hazardous wastes generated within the country as well as its export and import, the Hazardous Wastes (Management and Handling) Rules, 1989 were notified under the Environment (Protection) Act, 1986. Any waste, which by virtue of any of its physical, chemical, reactive, toxic, flammable, explosive or corrosive characteristics causes danger or is likely to cause danger to health or environment, whether alone or when in contact with other wastes or substances has been defined as hazardous. These rules were amended in 2008 to bring greater clarity to classification of hazardous wastes by linking generation of waste streams to specific industrial processes.   Simultaneously, threshold levels for concentration of specified hazardous constituents in wastes were laid down to distinguish between hazardous and other wastes. For regulating imports and exports, wastes had been classified as either ‘banned’ or ‘restricted’. The new Rules titled ‘Hazardous Waste (Management, Handling and Transboundary Movement) Rules, 2008’ have been notified superseding the earlier regulation. Recycling of e-waste has also been addressed under these Rules. The management and handling of bio-medical wastes as well as used lead acid batteries are regulated under separate Rules made for the purpose.   Categories of Hazardous Wastes • Industrial wastes (hazardous) generated during production such as rejects or process residues, spent chemicals and solvents, spent catalysts, hazardous dust collected from air pollution control devices, sludge arising from waste water treatment plants etc.; • Date-expired products such as obsolete pesticides and medicines; • Discarded products such as fluorescent bulbs and tubes containing mercury, used batteries etc.; • E-waste; • Hazardous wastes from demolition including ship breaking activities; • Used oil or waste oil, and • Used Lead Acid Batteries; • Other types of hazardous wastes are radioactive wastes and biomedical or infectious wastes which are covered under separate relevant regulations; • The high volume low effect wastes such as fly ash, phosphogypsum, red mud, slags from pyrometallurgical operations, mine tailings and ore beneficiation rejects are excluded from the category of hazardous wastes. However, management of these wastes should be as per the guidelines issued by regulatory authorities, which emphasise utilisation to the maximum extent possible.

Disposal of Date-Expired Drugs and Pesticides There are significant quantities of date expired drugs and pesticides lying unused in various states. To dispose such wastes the options available are to either have these reprocessed wherever possible by the industry which supplied them or to appropriately incinerate them through individual industries or through TSDF incinerators. In order to deal with such hazardous wastes, interstate transportation may also be permitted. 

Ship Dismantling Various materials and wastes containing hazardous constituents are handled during ship dismantling. These include used oil, waste oil, asbestos, paint chips and unused chemicals and more. Some of these materials can be used directly such as asbestos panels - others however need to be disposed. Adequate safety systems and procedures need to be adopted during dismantling and handling of these wastes. This activity is required to be regulated through state maritime boards, SPCBs and factory inspectorates.

—Inputs from National Hazardous Waste Management Strategy, Ministry of Environment and Forest, Government of India.