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Short Communication

Biomedical waste and solid waste management

draft rules, 2015: Acomment
Sandeep Sachdeva
Department of Community Medicine, North DMC Medical College and Hindu Rao Hospital, NewDelhi, India

Waste management is increasingly being given focus
and attention throughout the globe in view of its diverse
and adverse consequence to human and environmental
health. Recently government has released draft
biomedical waste and solid waste management rules,
2015 and invited comments from stakeholders. This
brief provides update on bio medical waste, solid waste
management especially community disposal of sanitary
waste and highlights some of the concerns.

Key words: Color coded bags, disposal, human,

incinerator, legislation, program, segregation, sharp


Biomedical waste(BMW) means any waste that is generated
during the diagnosis, treatment, or immunization of human
beings or animals or in research activities pertaining
thereto or in the production or testing of biological. From
management perspective, activities involved in BMW
management include(1) waste generation, (2) segregation,
(3) collection,(4) reception, (5) transportation, (6) storage,
(7) treatment, and (8) final disposal including any other
form of handling. It is estimated that 85% of hospital wastes
are actually nonhazardous(general waste) while remaining
15% are infectious, hazardous, or toxic waste.[1] If we can
manage this 15% waste effectively, our 85% of the basic and
Address for correspondence: Dr.Sandeep Sachdeva,
Department of Community Medicine, North DMC Medical
College and Hindu Rao Hospital, NewDelhi110007, India.

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consequential problems will be solved. However, this has

not been achieved even today. Highincome countries on an
average generate 0.5kg while lowincome countries generate
0.2kg of hazardous waste per hospital bed per day.[2]
The waste management hierarchy is largely based
on the principle of 3Rs, namely, reduce, reuse, and
recycle. However, broader concept of waste management
includes most preferred practice of preventing waste
to least preferred but essential practice of dispose.
Mismanagement of BMW generated in health care and
allied facilities is a global concern with far reaching
consequence on human health, animal, flora, fauna, and
environmental issues. In spite of regulatory framework in
many countries, the ground realities remain grim across
the world.
India has taken many steps over the past few decades to
address issues related to healthcare waste; however, it is
estimated that only just over50% of the countrys 84,809
hospitals and healthcare facilities in India properly treat
and segregate infected waste from noninfected waste.[3]
Another recent study conducted in 25 districts of 20 states
on situational analysis of BMW management reflects poor
practices/mismanagement in 82% of primary, 60% of
secondary, and 54% of tertiary care health facilities.[4] It
was not uncommon until few years back to notice burning
of plastic BMW in an uncontrolled manner even in
metropolitan city like Delhi,[5] what to talk of other
cities or rural areas. We may have definitively evolved
overtime yet the existing challenges of diverse and variable
awareness, casual attitude of staffmembers, governance
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How to cite this article: Sachdeva S. Biomedical waste and solid

waste management draft rules, 2015: A comment. Int J Health Allied Sci

2016 International Journal of Health & Allied Sciences | Published by Wolters Kluwer - Medknow


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Sachdeva: Waste Management

issue, poor accountability, media attention, social pressure,

advancement of safe technologies, legislation, logistics,
research, and funding have had many positive impacts in
country but critical gaps are evidently visible.
For the 1sttime in the country, the Government of India
notified BMW(management and handling) rules 1998
under environment protection act of 1986 to provide a
framework for management of BMW generated in the
country in line with global call. The said rules were framed
in the erstwhile Ministry of Environment and Forest that
were amended from time to time. The last amendment took
place in 2011 but could not be finalized due to nonconsensus
on categorization of BMW and emission standards for
incinerator. A set of new draft rules BMW(management
and handling) rules 2015has been released in public
domain by Ministry of Environment, Forest, and Climate
Change[Schedule I].[6]
The new BMW draft rules 2015 notification details about:
Title of notification, scope; definitions; duties of
occupier and operator of common biomedical
treatment facilities, prescribed authorities, composition
of advisory committee, institutional waste management
committee; treatment and disposal options; guidelines
and procedure for authorization for generation,
collection, transportation, storage, treating and disposal;
accident reporting; site for common BMW management
facility; liability of occupier or operator of facility;
maintenance of records and reports; and monitoring
and grievance mechanism. In continuation of previous
notifications, there is mention of awareness generation
activities, training, immunization and use of personal
protective equipment and consultative/directive roles
of various stakeholders; quantum of waste generated,
treated, transported, disposed off, recycled, etc.
The rules also prescribe biohazard/cytotoxic hazard
labeling symbol, standards for treatment and disposal
of BMW, i.e.,operating, emission, autoclaving,
microwaving, liquid waste, and deep burial
Annexure provides list of form/applications.



Authors perspective


In the 1998 notification, there were ten categories

of BMW including typographical error which were
reduced to eight in the 2011 amendment. In this
notification, there is no mention of separate but
reclassified categories of BMW according to Arabic
Many new entities were introduced in the last
amendment and had been retained in the present
notification. As in previous notification, the rules

shall not apply to radioactive waste covered under

the manufacture, storage and import of hazardous
chemical rules 1989; the municipal waste covered
under the municipal solid waste(management and
handling) rules 2000; the lead acid batteries waste
covered under the batteries(management and
handling) rules 2001; the hazardous waste covered
the hazardous waste(management, handling and
transboundary movement) rules 2008; waste covered
under the Ewaste(management and handling) rules
2011 and the hazardous microorganisms, genetically
engineered microorganism and cells covered under
the manufacture, use, import, export and storage of
hazardous microorganism, genetically engineered
microorganisms or cell rules 1989
Every occupier or operator involved in BMW
irrespective of quantum of waste shall seek grant of
authorization in a prescribed application
Every occupier shall either set up his own requisite
BMW treatment equipment such as autoclave,
microwave, or shredder in his premises as a part of
onsite treatment or ensure requisite treatment through
an authorized common BMW treatment facility
There is no overlapping or confusion with regard to
color coding bags and segregation of waste which existed
in previous rules. Some new points and/or deviation
from current practices may be a cause of concern.

Sanitary waste means waste comprising of used infant

and adult diapers, sanitary towels, napkins/pads,
tampons, condoms, incontinence sheets, menstrual
cups, or any other similar waste generated. The
Government of India has issued guidelines for
community disposal of sanitary waste under solid
waste management rules 2015 under environment
protection act 1986 and in supersession of municipal
solid waste(management and handling) rules 2000[7]
The sanitary waste is to be wrapped securely as
and when generated in a newspaper or suitable
biodegradable wrapping material and to be placed in
the domestic bin meant for nonbiodegradable waste
or dry waste. It is to be then transported to respective
processing facility or material recovery facilities or
secondary storage facility or sanitary land fill facility
along with other nonbiodegradable(dry) waste
A survey conducted in 2011 among 1000women sample
showed that at 12%, India has one of the lowest sanitary
napkin usage figures in the world. Rest 88% of women
use unsanitized cloth, ashes, and husk sand. There

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Schedule I: Biomedical wastes categories, treatment and disposal options, draft rule 2015

Type of waste


Human anatomical waste

Human tissues, organs and body parts
Animal anatomical waste
Experimental animal carcasses, body
parts, organs, tissues, including the
waste generated from animals used
in experiments or testing in veterinary
hospitals or colleges or animal houses
Soiled waste
Items contaminated with blood, body
fluids like gloves, dressings, plaster casts,
cotton swabs and bags containing residual
or discarded blood and blood components
Expired or discarded medicines
Including all items contaminated with
cytotoxic drugs
Chemical waste
Chemicals used in production of
biologicals and used/discarded
Discarded linen, beddings contaminated
with blood body fluid




Type of bag/container
tobe used

Treatment and disposal options

Yellow colored
nonchlorinated plastic


Yellow colored
nonchlorinated plastic
bags or containers


Yellow colored containers

or nonchlorinated plastic

After treatment liquid waste shall be

discharged into drains complying to the
discharge norms. Solids shall be disposed
of in secured landfills or by incineration
Incineration or chemical disinfection
followed by disposal in municipal sanitary

Nonchlorinated or yellow
plastic bags or suitable
packing material

Microbiology, biotechnology and other

clinical laboratory waste
Laboratory cultures, stocks or specimens
of micro-organisms, live or attenuated
vaccines, human and animal cell cultures
used in research, industrial laboratories,
production of biologicals, residual toxins,
dishes and devices used for cultures

Yellow colored
nonchlorinated plastic
bags or containers

hydroclaving/chemical disinfection followed
by shredding/mutilation or combination
of shredding and sterilization. After the
treatment final disposal in secured landfill
or disposal through registered or authorized
recyclers, whichever is applicable

Contaminated waste (recyclable)

Wastes generated from disposable items
such as tubings, bottles, intravenous tubes
and sets, catheters, urine bags, syringes
(without needles)

Red colored
nonchlorinated plastic
bags or containers

chemical disinfection followed by
shredding/mutilation or combination
of shredding and sterilization. After the
treatment final disposal in secured/sanitary
landfill or disposal through registered
or waste to energy plant or authorized
recyclers, whichever is applicable. In case
the occupier does not wish to opt for
recycling, the incineration may be opted

Puncture proof

Chemical disinfection/autoclaving followed

by shredding/mutilation/sterilization by
encapsulation in metal container or cement
concrete; combination of shredding cum
autoclaving; destruction by needle and tip
cutters; whichever is applicable and final
disposal through registered or authorized
recyclers or secured/sanitary landfill or
designated concrete waste sharp pit

Waste sharps including metals

Needles, syringes with fixed needles,
scalpels, blades, or any other
contaminated sharp object that may cause
puncture and cuts. This includes both
used, discarded and contaminated sharps
Broken or discarded and contaminated

are though reservations amongst certain section of

researchers with regard to small sample size to throw
light on sanitary napkin usage amongst women in India.
The figure is 100% in Japan and Singapore, 96% in the

USA, 88% in Indonesia, and 64% in China. Estimating

that 300 million women in India are of 1554years
of age, a sanitary napkin usage of 12% implies that 36
million women use sanitary napkins every month. At

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Sachdeva: Waste Management


an average usage of 12 napkins per woman per month,

this would add up to 432 million soiled pads, weighing a
staggering 9000 mega tonnes, enough to cover a landfill
spread over24 hectares. The sheer number of ladies
soiled sanitary napkins discarded with general household
waste every day adds to the burden of the environment.
More than 90% of a sanitary napkin is made of crude
oil plastic; the rest is made of chlorinebleached wood
or cotton pulp. Soiled napkins are considered part of
nonrecyclable household waste and are to be incinerated
as an interim solution. The informal practice of burning
soiled napkins in the open releases toxic gases like
dioxins and furans. However, most napkins end up
in landfills. Significant percent of women flush used
napkins in toilets which often choke and block sewage
lines. None of the methods are a safe or sustainable way
to dispose soiled napkins.[8,9] As a contradiction, foreign
organizations are promoting sanitary napkin in India as
they see it as a big business while trying to discourage
traditional environmental friendly methods.[10] The
debate between personal choice, comfort, hygiene,
cost, sustainability, disposal method, and environment
protection continues
Recently, Council of Scientific and Industrial Research
has developed biodegradable sanitary napkin which is
being made available to industry for mass production.[11]
The Government of India is providing subsidized
sanitary pads to adolescent girls in the country since
2011, and this technology transfer may give a timely
boost to reach all adolescent girls for ensuring universal
safe personal/menstrual hygiene with collateral
protection to environment
Ministry has invited comments and suggestions
from experts, nongovernmental organization, public,
and lay persons on both draft rules and would also
provide a larger platform for discussion and debate to
accommodate any additional concerns and issues.

Financial support and sponsorship


Conflicts of interest
There are no conflicts of interest.


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