General waste generated from kitchen, packaging material for groceries, food material, waste papers, waste plastics, floor cleaning dust, etc, must be handed over to the municipal solid waste collector identified by Urban Local Bodies or as per the prevailing local method of disposing general solid waste. Likewise, the bio-medical waste contaminated with blood/body fluids of Covid-19 patients must be collected in a yellow bag and handed over to authorised waste collectors at door steps, engaged by local bodies or the waste collector engaged by CBWTF operator at the doorstep or can be deposited at designated deposition Centers established by ULBs.
Did you recently come across any used Personal Protective Equipment (PPE) like mask, glove lying on the road? Well, if you did not, you are lucky to be residing in an area where people are aware of the proper disposal mechanism of the protective equipment. How do you dispose of your one-time use mask? Do you throw it in the common bin of your neighborhood? If yes, then are you aware of the threat it poses to the environment and the health of the people? Do you know how largely does the proper disposal of such waste contributes in limiting the spread of the ghastly virus?
With India topping the list of the most recorded COVID-19 cases in a day (near about 90,000), the concerns regarding the management of the bio-medical waste, produced by the hospitals, nursing homes, health centers and households, used for the purpose of self-quarantine, are exponentially increasing. Though the threat of contracting the virus is spine-chilling, however what appears to be more alarming is the aftereffect of the pandemic i.e. the stacking up of the waste, generated during the diagnosis, treatment and immunization of people.
Through this column, the authors aim at apprising its readers with the measures taken by the government and the judiciary to contain the spread of the ghastly virus via mediums such as used PPEs, testing equipments, solid and liquid waste.
UNPACKING THE MEASURES
It is not an unknown fact that improper disposal of the waste certainly poses risk to the lives of sanitation workers who quite often work without being trained for handling such hazardous materials. India, since time immemorial has been struggling with the issue of poor waste management and with the coming in of the novel corona virus in the country there was a pre-emption that this issue would be taking a turn for the worst. The daily numbers certainly do suggest the same.
Government of India through Ministry of Health and Family Welfare (MoH&FW) anticipated the excessive amount of waste that would be generated as a consequence of all the measures which would be adopted to prevent, diagnose and treat the virus. In its bit to prevent the spread of the novel coronavirus, the MoH&FW, released the guidelines on use of masks by public. It prescribed the manner of disposal of masks and stated that used masks must be disinfected using ordinary bleach solution (5%) or sodium hypochlorite solution (1%) and then disposed of either by burning or deep burial. This guideline was subsequently complemented with pictorial representations in order to create awareness amongst the general public. The municipal bodies would do well to sensitize the public at large and not just make repeated and stale announcements of social distancing.
Notably, the Central Pollution Control Board (CPCB) also took the initiative of enacting Guidelines for handling, treatment and disposal of Covid-19 waste at Healthcare Facilities, Quarantine Camps/ Quarantinehomes/Home-care, Sample Collection Centres, Laboratories, SPCBs, Urban Local Bodies (ULBs) and common biomedical waste treatment and disposal facilities (CBWTFs). These guidelines are to be read with the existing Bio-medical Waste Management Rules, 2016.
It may be advisable to impose stricter implication of these guidelines under the Disaster Management Act, 2005 (the 2005 Act). As we understand, the only threat thus far of the 2005 Act has only been witnessed by migrant labors and remotely by private companies for keeping their employees on their pay role. Its high time we impose stricter guidelines within the ambit of 2005 Act upon everyone that may have a defining role in management of COVID-19 Biomedical waste. If not, we can segregate the petty yet damaging offences to steep fine if not curtailment of personal liberty under the 2005 Act.
Undernoted provides a short gist of the duties imposed upon the above-mentioned stakeholders for the systematic disposal of COVID-19 biomedical waste:
Are you taking care of a COVID-19 patient at Home?
Recently, when one of the authors was at the supermarket for grocery shopping, he happened to meet a friend who shared the unfortunate news of his wife being tested positive for COVID-19. During the conversation, the author was brimmed with a rather very shocking and unsettling news; the husband of the infected wife, was disposing his wife’s bio-medical waste with the general household waste, without any segregation.
Do you know the repercussions of the above act? Are you aware of the risk it poses to the sanitation worker who is responsible for collecting the general waste? Do you know that any person who comes in contact with this particular sanitation worker is also at a risk of contracting the virus? Then, what is the correct way of disposal? Look into this section to understand your duties as a care-taker for disposal of Bio-medical waste.
It is to be noted that a COVID-19 patient’s waste such as discarded masks and gloves can be disposed of as a general waste only when the same has been stored in a paper bag for a minimum of 72 hours.
General waste generated from kitchen, packaging material for groceries, food material, waste papers, waste plastics, floor cleaning dust, etc. must be handedover to the municipal solid waste collector identified by Urban Local Bodies or as per the prevailing local method of disposing general solid waste, whereas the bio-medical waste contaminated with blood / body fluids of COVID-19 patients must be collected in a yellow bag and handed over to authorized waste collectors at door steps, engaged by local bodies or the waste collector engaged by CBWTF operator at the doorstep or can be deposited at designated deposition Centers established by ULBs.
Pertinently, it must be ensured that general waste and COVID-19 bio-medical waste must not be mixed – SHOULD BE SEGREGATED CAREFULLY.
Are you an operator of an Isolation Ward? How do you dispose of the COVID-19 bio-medical waste?
If you are an operator, the you must look at this space to get well versed with the compliances required to be fulfilled by you to ensure safe handling of the biomedical waste. The key duty of an operator is to maintain separate color coded and labelled [COVID-19 Waste] bins (with foot operated lids)/bags/containers in the wards. Red colored bags must be used to collect goggles, face-shield, splash proof apron, Plastic Coverall, Hazmet suit, nitrile gloves and yellow for the collection of used mask (including Triple layer mask, N95 mask etc.), head cover/ cap, shoe-cover, disposable linen Gown, non-plastic or semi-plastic coverall. Additionally, the use of double layered bio-medical waste bag must be encouraged to ensure that the liquid contents of the waste do not spill out.
Most importantly, utmost care must be undertaken to ensure that the equipments such as containers/bins/ trolleys are disinfected with 1% sodium hypochlorite solution daily. Proper training must be provided to waste handlers in terms of the preventive measures via videos and demonstration in local language. Training shall be provided by designated nodal officer trained by Health Departments / professional agencies in association with SPCB of the States/ UTs.
It must be ensured that separate records of waste generated from COVID-19 isolation wards are maintained and registered on the CPCB mobile application namely ‘COVID19BWM’.
Do you collect samples of suspected patients or operate Collection Centers/Laboratories? If yes, then watch out the undernoted directions issued by the CPCB.
As soon as a lab/collection center is opened, it is incumbent upon the operator to inform about the same to the SPCB. Disposal mechanism as listed above for an isolation ward operator is to be followed.
Is transmission to an operator of a Healthcare Facility, during the treatment of wastewater, possible? If yes, then what precautions can one take?
As of now, there is no evidence of such a transmission taking place, however, since prevention is better than cure, safety measures as provided by CPCB must be complied with, such as operators must ensure that treated wastewater is disinfected as per prevailing standard operating procedure to inactivate corona virus. Furthermore, as much as possible, the use of treated wastewater in utilities within Healthcare Facilities may be avoided. Pertinently, proper care must be undertaken to ensure that the operators associated with the handling of the discharge from healthcare facilities practice basic hygiene precautions and wear PPE kit.
Role of Regulatory Bodies
CBWTFs are essentially required to collect waste from COVID-19 isolation wards/ Quarantine Camps/Homes/ Testing Centers and report the same to the SPCBs. It is incumbent that COVID-19 waste be disposed-off immediately upon receipt at facility and the dedicated vehicle bringing the same, must be sanitized with appropriate chemical disinfectant.
Urban Local Bodies are bounden to ensure proper and careful collection and disposal of biomedical waste generated from Quarantine Camps/ Quarantine Homes/ Home Care for COVID-19 suspected persons. To further the abovementioned duty, the ULBs must identify CBWTFs, who would be responsible for directly collecting waste from quarantine camps. Yellow colored bags must be made available to the operators of the camps/ homes, either directly or through the CBWTFs. For the protection of the workers handling the waste, PPE kits must be provided and it shall also be ensured that the aforementioned bags are disinfected. Additionally, careless handling of the waste i.e. mixing up of the COVID-19 waste with the general waste must be strictly avoided and awareness regarding segregation of waste be spread by the ULB.
The SPCBs are primarily required to maintain the records of the COVID-19 treatment wards/self-care facilities. The SPCBs also ensure that bio-medical waste is properly disposed in light of the prevailing Rules and SoPs, the same is carried out through the coordination between the CBWTFs and ULBs.
Use of deep burial pits for disposal of yellow category waste as per standards prescribed in Schedule II of Biomedical Waste Management Rules, 2016 may be permitted in the scenario a particular State does not have CBTWFs. Additionally, the usage of HW incinerators may also be allowed if an exponentially large amount of yellow color coded waste is generated. Most importantly, every SPCB is mandated to upload the COVID-19 biomedical waste on the COVID19BWM web-portal developed by CPCB.
The authors understand that activities undertaken by the local municipal bodies must remain free from fetters due to the usage of word good faith under Section 73 of the Disaster Management Act. But there has to be some accountability. Maybe introduction of defined and wellarticulated rules under the Act regarding the disposal of bio-medical waste may be an answer to this issue.
TACKLING EFFICIENTLY OR GRAPPLING: A REALITY CHECK
Though various guidelines have been put in place to fortify a smooth mechanism for disposal of COVID-19 biomedical waste, however the concern regarding its effective implementation is still very prominent. Recently, in a report dated 27.07.2020, submitted by the Environment and Pollution (Prevention and Control) Authority to the Hon’ble Supreme Court, a very depressing picture was brought to light – manifold increase in the quantum of COVID-19 biomedical waste in Delhi (near about 14 times more generation of waste in July as compared to May). This sorry state of affair clearly leads to the conclusion that despite having the best of rules/guidelines, we as a country are lacking somewhere. What are these implementation roadblocks? How do we address them?
Pertinently, the EPCA, recommended certain best practices which identified these roadblocks and provided a solution to demystify the same. Notably, some of these recommendations were conceded by the Supreme Court and subsequently directions were issued to ensure the compliance of the same.
The EPCA while identifying the key problem which has led to the increase in the amount of waste in the country, stated that, “While the system for collection of biomedical waste from healthcare facilities and registered laboratories is well established, in the case of COVID-19, the biomedical waste is being generated in homes and quarantine centers. This is where the key complication arises, as urban local bodies have to track the patients on a real-time basis and then set up systems for collection of biomedical waste from individual households located in different parts of the city.”
The Apex Court vide its order dated 31.07.2020, issued a mandate regarding uploading of data on the COVID19BWM APP, which provides the statistics of the biomedical waste sent to a CBWTF. This direction will essentially help the CPCB to keep a track on the treatment of the collected waste. Earlier, the uploading of data was not mandatory, however, now all the civic bodies are under a mandate to be in compliance of the same.
Additionally, the Apex Court also directed the municipal corporations to send the waste to CBWTF and not WTE, considering the fact that WTEs are not well equipped to dispose of the bio-medical waste, which requires a double incineration chamber for its proper disposal. A need for having a national barcode portal for monitoring the biomedical waste was also highlighted and in light of the same, the Union Ministry of Environment and Forests and Climate Change and CPCB were directed to design a draft model.
The above directions indeed hint towards a flickering light at the end of the tunnel, which is effective disposal of COVID-19 biomedical waste. Moreover, the readers must also take note of the fact that India has taken measures at par with countries like Germany, China, France in laying down guidelines for disposal of waste. The basic practices such as (i) segregation of waste – proper labelling (ii) disinfection of transport that brings the waste(iii) phased incineration, are universal. Problem here is not lack of rules on the subject but the implementation, it is time that we follow the guidelines at institutional as well as individual levels.
With the spurt in the number of Covid-19 cases, it is implied that the waste will multiply manifold in the future, however it is in our hands to reduce the piling of waste by disposing it of properly, as they say it: We are all in this, together.