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COVID-19 Exposes Vulnerabilities In Tamil Nadu‘s Bio-Medical Waste Management

Tamil Nadu’s bio-medical waste management system is struggling as tons of pandemic-related waste gets generated from healthcare facilities, households, commercial establishments and other organizations. According to the Central Pollution Control Board (CPCB) and other reports, the state generated more than six thousand tonnes of Covid-19 biomedical waste between March 2020 and May 2021.

Even before the pandemic, inadequate bio-medical waste management infrastructure and gaps in compliance monitoring were major causes of concern for the state as with only 8 biomedical waste treatment units in place to meet barely one-fifth of its requirements. The pandemic has further exposed these vulnerabilities in an already overburdened system with PPE equipment being discarded all along Chennai’s coastline.

“Single-use plastic masks can be seen floating on the ocean surface and also littered in beaches,” says Chennai-based scuba instructor and ecologist Siddharth Ramachandran. The pervasive pollution, he points out, is harmful to both public health and the environment.

Discarded Plastic Masks/Youth Ki Awaaz

Infrastructure Inadequacies

One of the major challenges in bio-medical waste management in Tamil Nadu is that the existing limited infrastructure has to handle both COVID-19 related bio-medical waste in addition to regular bio-medical waste. In Tamil Nadu, all bio-medical waste is disposed of through the Common Bio-Medical Waste Treatment and Disposal Facility (CBWTF) and the State currently only has 8 fully functional CBWTFs. This is not enough.

According to the Tamil Nadu Pollution Control Board’s (TNPCB) 2019 annual report, the combined installed capacity of Tamil Nadu’s 8 CBWTF facilities is only an average of 49 Tons of bio-medical waste per day. In 2020, the state was producing around 70 Tons of bio-medical waste per day, which is greater than the CBWTF’s installed capacity of 49 Tons per day. The amount of biomedical waste generated in Tamil Nadu has nearly doubled since 2016, where it was around 48.26 tonnes per day.

The state pollution control board, TNPCB, and the Central Pollution Control Board (CPCB) are responsible for preventing pollution of the environment and they also advise governments regarding prevention and control of pollution.

In November 2020, a Joint Committee report was submitted before the National Green Tribunal (NGT) after the tribunal took Suo Motu cognizance regarding reports of illegal dumping of bio-medical waste in Tamil Nadu. This committee consisted of a senior scientist from the Central Pollution Control Board’s regional office in Chennai, the District Collector of Chennai, three senior officer’s from the Greater Chennai Corporation and two senior officer’s from the Tamil Nadu State Pollution Control Board.

The report by this Joint Committee states that the 8 fully functional CBWTF’s in Tamil Nadu are extending their operating hours to handle around 70 Tons of bio-medical waste per day.

Medicines discarded on Roads. Photo by the author.

Even before the pandemic, infrastructure inadequacies were straining the system. TNPCB’s 2019 annual report states that the three CBWTFs located in Coimbatore, Ooty, and Ramanathapuram were closed by TNPCB due to non-compliance of the BMWM Rules, 2016 further stressing the already overburdened bio-medical waste management system in the state.

The construction of four new plants – meant to be started in Tiruvallur, Cuddalore, and Tirapur, is yet to be completed. These have been listed as under establishment in TNPCB’s annual reports, from 2016 till 2019, but there is little clarity on when they will become operational. It is also not clear if these really will be situated at the said districts because the 2020 Joint Committee report states that 3 new CBWTFs are under establishment in Gummidipoondi, Hosur, and Tirupur districts.

TNPCB officials and the Tamil Nadu Environment Department did not respond to YKA’s email requests on March 1, 2021, and March 2, 2021, to comment on this. The report will be updated if they respond.

According to CPCB’s ‘Revised Guidelines for Common Bio-medical Waste Treatment and Disposal Facilities, 2016′, a CBWTF can only cater to healthcare facilities situated at a radial distance of 75 Km. If this coverage area does not have at least 10,000 beds, an existing CBWTF in the locality may be allowed to cater to healthcare facilities situated up to a 150 Km radius, provided the biomedical waste can be treated in it within 48 hours as specified by the BMWM Rules, 2016. However, in 2018, TNPCB issued orders stating that bio-medical wastes generated from healthcare facilities situated anywhere in Tamil Nadu can be taken for treatment and disposal within 48 hrs to a CBWTF situated anywhere in Tamil Nadu and there is no restriction for the establishment of another CBWTF within a radial distance of 75 Km.

Even with the establishment of the facilities, experts say the state may still not be equipped to handle bio-medical waste generated effectively. At present, due to the availability of only 8 fully functional CBWTFs for all 38 districts in the state and the consequent transportation challenges, biomedical waste from remote areas are at risk of being illegally dumped into the environment.

“Every district in Tamil Nadu should have 1 or 2 CBWTFs depending on the number of healthcare facilities in that district for effective bio-medical waste management,” says Jawaharlal Shanmugham, a social activist who files public interest litigations on biomedical waste management in Tamil Nadu. “The number of lorries transporting BMW should also be increased,” he says.

For comparison, Maharashtra – a state with 36 districts and a population of 12.6 crores has 29 operational treatment facilities, and Karnataka ( with a population of nearly 7 crores) has 26 fully functional treatment facilities.

Data Discrepancies

It is also not clear just how much bio-medical waste Tamil Nadu generates. A 2017 CPCB report noted that the state generated 8.39% of the total bio-medical waste in the country, but experts say the percentage isn’t proportional to the state’s population(nearly 7.8 crores). The report had stated that this discrepancy in data was due to an incomplete inventory of all the healthcare facilities in the state (both bedded and non-bedded) and it had recommended TNPCB to complete the inventory to ensure effective treatment and disposal of bio-medical waste. Within a year, the number of healthcare facilities that were added to the inventory doubled. The inventory process, however, still remains unfinished. While TNPCB’s 2019 annual report pegged the number of facilities at 10,294, the 2020 Joint Committee report states that the state has 24, 573 facilities (as of September 2020).

The 2020 Joint Committee report also states that so far 63 healthcare facilities have been issued with closure direction and disconnection of power supply for operating without consent and 24 healthcare facilities including Government Hospitals have been identified as violators.

Environmental activists say this poses a grave threat to public health and the environment.“There exists a huge gap between the realistic figures of bio-medical waste which is being generated and the official figures that are being conveyed. This bio-medical waste is going into the environment, into dump yards and it is also being dumped along with regular waste in municipal corporation bins,” says Shanmugam.

According to studies, improper bio-medical waste management can cause severe air, water, and soil pollution and transmission of diseases like typhoid, cholera, and hepatitis through injuries from sharps contaminated with blood. Incinerating bio-medical waste causes the emission of fly ash and toxic metals which affects air quality.

Mixed with general solid waste or when dumped in corporation bins or landfills, it also poses severe health risks to sanitation workers and the general public. “During interviews with sanitary workers I gathered that they routinely come in contact with used syringes and needles, sometimes even human waste with bare hands,” says Kripa Kishore Ramachandran, a waste policy researcher in Tamil Nadu.

Kovalam Beach, Chennai. The pandemic exposed these vulnerabilities in an already overburdened system with PPE equipment being discarded all along Chennai’s coastline. Photo by the author.

Segregation Issues in Healthcare Facilities

In addition to the BMWM Rules, 2016, the CPCB also provides multiple revised guidelines for managing bio-medical waste. The latest guidelines were released in July 2020 and they lay out proper segregation procedures for disbursal of COVID-19 bio-medical waste. This includes disposing of bio-medical waste in colour-coded and labelled double-layered bags, bins, and containers; separate temporary storage of bio-medical waste before handing them over to the CBWTFs; maintenance of separate records of bio-medical waste from isolation wards, quarantine camps, quarantine homes, testing centres and providing dedicated sanitation workers for the same who do so in adequate protective gear and dedicated vehicles for transport.

But according to experts, many of these rules are not being followed. “The major challenges are the lack of knowledge, awareness, and lack of proper training. The country also lacked a preparedness plan to deal with a pandemic of this nature, and major guidelines were prepared last minute,” says Dr Aakanksha Mehrotra, Programme Coordinator at Toxics Link.

“During the early months of the pandemic, all waste (food waste and general waste) related to COVID-19 patients was disposed of in yellow bags to be incinerated. This impacted the efficiency of CBWTFs as they are not designed to handle all kinds of waste. It also increased their load, causing an increase in the release of particulate matter and other components. Guidelines were issued only later to segregate recyclable plastic waste and dispose of them in red bags,” she added.

A senior management official at a private hospital in Chennai who declined to be named for this report said that CPCB’s COVID-19 protocols resulted in an increase in the generation of biomedical waste, but many healthcare facilities in Tamil Nadu lacked adequate facilities and human power to segregate bio-medical waste according to the CPCB guidelines..” Tier 1 and Tier 2 cities also do not have approved collection centres for bio-medical waste. Proper monitoring and system education is required.” he said.

A doctor working at a COVID-19 ward at Raja Muthiah Medical College which has been designated as an exclusive COVID-19 hospital for Cuddalore district in Tamil Nadu by the government said that proper segregation of biomedical waste was not always practised both before and during the pandemic. “There are only two bins. One bin for sharp waste like needles and syringes, and all other biomedical waste ends up in a single bin without proper segregation. PPE kits used by doctors were also not segregated properly,” she said.

She said between July and August 2020, which were the peak months of the pandemic in this area, 4- 5 big bins of biomedical waste were generated per day in the COVID ward. “Improper segregation of biomedical waste puts sanitation workers at risk of needlestick injuries and other infections. Even though doctors and nurses are trained to handle biomedical waste, many do not practice it and even if they do want to, adequate resources are not available. More resources, awareness, and strict enforcement are required,” said this doctor. A private medical practitioner in Madurai also says that they also use only two bins in their hospital without any segregation.

In February 2020, TNPCB observed that many healthcare facilities were yet to obtain authorization, did not pre-treat bio-medical waste as per World Health Organization (WHO) guidelines, establish a bar code system for bags containing bio-medical waste before sending them to CBWTFs and they also did not upload annual reports to their websites which were all serious violations of the BMWM Rules, 2016.

Discarded Plastic Gloves /Youth Ki Awaaz

Increase In Number of COVID-19 Bio-Medical Waste Generators

According to the 2020 Joint Committee report, around 339 healthcare facilities, 12 sample collection centres, 84 Laboratories and 148 Quarantine homes/camps operated by Urban Local Bodies (ULB’s) are involved in handling COVID-19 bio-medical waste.

COVID-19 related bio-medical waste is also being generated from sources other than healthcare settings. Since the pandemic started, there has been a widespread increase in the usage of single-use personal protective equipment.

In the case of home care of COVID-19 patients, CPCB guidelines state that bio-medical waste should be placed in yellow bags and urban local bodies should engage with the CBWTF to pick up the waste either directly from homes or from designated collection points. Masks and gloves used by people who are not COVID-19 positive are required to be stored separately for a minimum of 72 hours for disposal along with the solid waste. After cutting or shredding, they can be collected as dry solid waste by urban local bodies.

“Guidelines were issued by the Greater Chennai Corporation specific to COVID-19 waste disposal but it was never followed in spirit. They were to hand out a yellow bag specifically to discard waste generated from quarantined households but when our ward had many COVID-19 cases, we never received any such imposition. Source segregation of waste is also still an elusive thing,” says Ramachandran.

Managing Bio-Medical Waste from Sources other than Healthcare Settings

“Household bio-medical waste is often an overlooked area. Though urban local bodies were mandated to comply with the guidelines and work in association with the CBWTFs, complete segregation and disposal of such waste could not be achieved,” Mehrotra told YKA.

General guidelines for managing household bio-medical waste is not part of the BMWM rules, 2016 and household bio-medical waste like expired medicines, sanitary napkins, condoms, adult/baby diapers, needles, bloodstained cotton buds, insulin pens, band-aids, pregnancy, and blood sugar test strips regularly end up being dumped along with the general solid waste.

Commercial establishments like shops, beauty salons, and restaurants also generate huge volumes of single-use personal protective equipment like plastic masks and gloves due to the pandemic.
“A mass vaccination program, unlike anything, ever witnessed is in play, and any guidelines to tackle this waste are not yet in sight,” Mehrotra told YKA.

Another area that requires intervention is liquid bio-medical waste management. “Strict compliance monitoring, complete inventory of all healthcare facilities in Tamil Nadu and focus on biostatistics is the need of the hour for effective bio-medical waste management in Tamil Nadu,” says Shanmugam.

Featured image credit: Author
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