India’s sanitation workers are nobody’s priority

Source: Quartz India

The loss of life should be a wake-up call for all of us. Going by the number of deaths of sakai karmachari-
sanitation workers, the government appears to remains blind on such issues. Death of worker/s is always
labelled as ‘accident due to negligence’ but Supreme Court judge has termed it as ‘Conscious crime’ by
those who force workers to enter the manholes.

Definitions

‘Sewage’ means, raw sewage, sewage sludge, or septic tank waste.

‘Raw sewage’ is mainly water containing excrement, industrial effluent and debris etc. Excrement is the
major source of harmful micro-organisms, including bacteria, viruses and parasites.

‘Sewage system’ or ‘Sewer system’ centralized sewer systems, comprises of various components
including pipes, chambers, manholes, sewer main etc., while, ‘Septic tank’ are sewage handling facility,
commonly used for private, remote, rural areas where no centralized sewer systems exist. A septic tank
is an underground chamber made of either concrete, fiberglass or plastic through which domestic
wastewater (sewage) flows for basic treatment.

‘Manual scavenging’ is the act of manually cleaning, carrying, disposing of, or handling human excreta in
any manner, in an insanitary latrine or in an open drain or pit into which the human excreta from the
insanitary latrines is disposed of. Thus, any act of making a person coming into physical contact with
human excreta is banned legally and rightly so. Any physical contact with excreta is banned.

‘Safai karmachari’ or ‘sanitary workers’ means any person engaged in or employed for any sanitation
other than domestic work that may be necessary for the specific nature of work to be carried out. It
includes all inspection and maintenance work sewer system, septic tank etc.; construction workers
(who repair or replace live sewers); sludge tanker drivers/operators and associated maintenance staff
etc. in addition to employees who clean and maintain the underside of railway carriages and empty
aircraft sewage compartments and other types of portable lavatories etc…

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Past Incidents
There is no exact data available related to the deaths in associated with this occupation, as The National
Crime Records Bureau (NCRB) figures do not reflect the exact numbers, as the NCRB, records them as
asphyxiation (it includes non-occupational death as well), rather than listing them occupation specific.
The various state/union territory governments have failed to notice and document even those sewer
deaths that get reported in the local and regional news. This raises serious questions on their willingness
and commitment to prevent occupation related fatalities. In many cases, occupational deaths of worker/s
do not get registered properly. The occupational health hazards of are also, numerous (described
separately), most of the workers die a premature death due to the deteriorated health conditions. It is
estimated that the lifespan of a sanitation workers is 45-50 years.

Specified below are some of the newspaper reports published related to the occupational fatalities;

 5 men die from toxic fumes while cleaning septic tank at luxury Delhi apartment block, Monday 10
September 2018, Independent.
 3 died, sent to clean septic tank without safety gear, three manual scavengers die after inhaling toxic
fumes in Thane, May 11, 2019, Times of India.
 3 sanitation workers lost their lives after inhaling toxic gases while cleaning a septic tank in
Nallasopara on Friday, May 4, 2019, The Hindu, Mumbai.
 3 sanitation workers have died due to asphyxiation while cleaning a drain in southeast Delhi’s Lajpat
Nagar, near the Kabir Ram temple, August 7, 2017, PTI reports.
 2 choke to death while cleaning septic tank in Delhi's Rohini, 3 hospitalized, All the five labourers fell
unconscious after entering the septic tank, May 7, 2019, India Today.
 4 Assamese workers choked to death while cleaning septic tanks in Tamil Nadu’s die while cleaning
septic tank, Apr 15, 2019, Hindustan Times.
 4 labourers died after they were exposed to poisonous gas inside a septic tank in Bihar's Siwan, , Sept
9, 2019, First spot.
 7 men have suffocated to death while cleaning a hotel septic tank in western India without safety
gear, June 15, 2019.

Note: Information mentioned above is limited but not all, the intention to provide the information is
to present the graveness of the issue.

Legislative Provisions
One big obstacle before evolving policies for the welfare of safai karmachari is the lack of credible data.
There are no official numbers available on those employed in sewer and septic tank cleaning as most of
those employed to do the cleaning of septic tanks are hired on a casual basis. In majority of the cases,
the cleaning activity of sewers & septic tanks are carried out by private contractors with minimal or no
knowledge about the systems and work methods to be adopted.

The law severely restricts the entry into manholes or septic tanks and only permits the same in extreme
circumstances with the prior permission of the Commissioner and on using protective gear and safety
devices. This is termed as “hazardous cleaning” and is a RARE exception. Failure to comply with this law
has very serious consequences and any person who engages such workers, either directly or indirectly,
would be punishable with imprisonment up to two years or fine or both.

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i) Prohibition of Employment as Manual Scavengers and Their Rehabilitation Act, 2013

It describes “hazardous cleaning” by an employee, in relation to a sewer system or septic tank etc., means
its manual cleaning by such employee without the employer fulfilling his obligations to provide protective
gear and other cleaning devices and ensuring observance of safety precautions, as may be prescribed or
provided in any other law, for the time being in force or rules made thereunder.

ii) Prohibition of Employment as Manual Scavengers and their Rehabilitation Rules, 2013 (PEMSR Rule)

The Rules has been notified by Ministry of Social Justice and Empowerment under the provisions of
Prohibition of Employment as Manual Scavengers and their Rehabilitation Act, 2013. As per the Rules, no
person shall be allowed to clean a sewer manually, with the protective gear and safety devices in
exceptional condition prescribed in the rules.

Manual entry for hazardous cleaning of sewers is completely banned as per the Prohibition of
Employment as Manual Scavengers and their Rehabilitation Rules, 2013 & Rules, 2013.

Swatch Bharat Mission

Standard Operating Procedure (SOP) for cleaning of sewers and septic tanks developed under Ministry
of Housing and Urban Affairs - Government of India, Swatch Bharat mission to impart the knowledge into
the stakeholders about the inspection & maintenance of sewer and septic system. The SOP developed
are useful by all Urban Local Bodies, Public Health Engineering Departments, other agencies and also
applicable to the contractors and the individuals who hire person(s) for maintenance of their septic
system at their premises across the country. States, Union Territories require to publish this SOP in local
language for better understanding of the concerned agencies and individual, as per the necessity.

National Safai Karamcharis Finance and Development Corporation (NSKFDC)

Wholly owned Govt. of India Undertaking, under the Ministry of Social Justice & Empowerment (M/o
SJ&E) was set up on January 24, 1997 as a Company “Not for Profit” under Section 25 of the Companies
Act, 1956. NSKFDC is in operation since October, 1997, as an Apex Corporation for the all-round socio-
economic uplift of the Safai Karamcharis and their dependants throughout India, through various loan
and non-loan based schemes.

Human Right Organization

Safai Karmachari Andolan, an Indian human rights organization engaged campaigning to end the practice
of manual scavenging, the construction, operation and employment and help those engaged in it find
dignified work.

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Understand the Sewer system
Common to municipalities around the world is the need to maintain a clean and sanitary environment
suitable for humans to live and work. This responsibility includes providing a system for efficiently moving
both wastewater (sewage) and storm water along with the solid materials through a collection system
from the source to an environmentally safe place of treatment and disposal.

(Graphic Source: Norristown Municipal Waste Authority)

A wastewater collection system is typically a network of pipes, manholes, cleanouts, traps, siphons, lift
stations and other required structures to collect all the wastewater from an area and transport it to a
treatment plant or disposal system. Partial or complete interruption of the flow may result from an
obstruction in a sewer. Human health is threatened with unsanitary conditions and the spread of
diseases. The best way to keep a sewer or storm system working properly is to perform routine inspection
and cleaning.

Understand the Septic Tank

The septic system is constructed for single households, villages, and the area not covered by Municipal
sewer system. Indeed, the onsite wastewater treatment system including a septic tank and soil
absorption field is the most common domestic wastewater treatment system in rural homes.

(Graphic Source: https://www.canr.msu.edu MSU Extension)

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The basic construction and operation of a single cell septic tank. If the depth of the sludge layer or scum
layer reaches the outlet pipes solids will fill plug the soil causing absorption failure. Keeping the sludge
pumped regularly can prevent failure and increase the life of your onsite waste water treatment system.

The Septic tank required to be inspected every 3 years, while the average recommended pumping
frequency is between 3 and 5 years, depending on the tank size and number of occupants, failure to
neglect inspection and pumping will shorten its lifespan.

Sewers System and Septic Tank Inspection and Maintenance Methods are mentioned below;

Methods of sewer and septic system Inspection

Direct Method inspection by the inspector- when sewer is not in service

Indirect Methods
 Light and Mirror Method
 Closed Conduit Camera Method
 Sonar System A robot is sent through the sewer and it emits high frequency sound waves, which
impinge on the pipe surfaces and returns to the emitter as a reflection etc.

Methods of sewer and septic tank maintenance

Manual Methods
 Manila Rope and Cloth Ball
 Sectional Sewer Rods- Used for cleaning small sewers.
 Scraper as similar to pigging operation- the scraped debris are removed manually

Mechanical Methods
 Sewer Cleaning Bucket Machine-Power bucket machine setup
 Rodding Machine with Flexible Sewer Rods- Power rodding operation
 Hydraulically propelled Devices- Flush Bags, Sewer Balls and Sewer Scooters,
 Velocity Cleaners (Jetting Machines) including mini jetting machine, hydraulic jet
 Dredger (Clam-shell) - for manhole cleaning
 Gully Emptier (Suction Units) etc.

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Understanding the risks to health and safety of workers associated with the occupation

Most of the fatalities reported are caused by Asphyxiation. All hazards expected in a regular workplace
are associated with sanitation worker’s activities. However, they can be even more hazardous in a
confined space than in a regular worksite.

A ‘confined space’ is a fully or partially enclosed space, it is not primarily designed or intended for
continuous human occupancy, has limited or restricted entrance or exit, or a configuration that can
complicate rescue, evacuation, or other emergency response activities. Also, it can represent a risk for
the for the health and safety of anyone who enters, due to one or more of the factors,

a. its design, construction, location or inside atmosphere,

b. the materials or substances in it,
c. work activities being carried out in it,
d. the mechanical, process and safety hazards present

Confined space hazards to which sanitary workers are exposed includes;

i. Poor air quality (Oxygen deficient atmosphere) for the worker to breathe.
ii. Hazards from an asphyxiants: They are classified as either simple or chemical on the basis of the
mechanism of toxicity.

a. Simple Asphyxiants are gases like methane, carbon dioxide displaces oxygen in inspired air, results
in hypoxemia. That can cause unconsciousness or death by suffocation (Asphyxiation). Note that
carbon dioxide interferes with the body’s regulation of breathing and is hazardous at lower
concentrations than simple asphyxiants. Other examples of Simple Asphyxiants are nitrogen, argon,
helium etc.

b. Chemical Asphyxiants interfere with oxygen transport system and cellular respiration and thereby
cause tissue hypoxia. Chemical asphyxiants which interfere with the transportation or absorption of
oxygen in the body, include hydrogen sulphide. Other examples of Chemical asphyxiants are carbon
monoxide, hydrogen cyanide etc.

iii. Fire & explosion hazard: There may be an explosive/flammable atmosphere due to flammable liquids
and gases and combustible dusts which if ignited would lead to fire or explosion, it affects all the workers,
whether they work inside the confined space or outside.

iv. Other hazards to which the workers may be exposed while they are working inside the confined space
or performing the task outside;

Physical hazards such as noise, heat/cold, radiation, vibration, electrical (in case of exposure to live
electrical system/ underground utilities etc.), inadequate lighting, pressurized hoses, high pressure
jetting, slip trip & falls are common hazards.

Biological hazards –viruses, bacteria from fecal matter and sludge, fungi or moulds, insect/animal stings
or bites.

Hazard which rarely considered or controlled is vehicular and pedestrian traffic etc. collapse risk is
common in areas of unstable soils or areas of commonly built systems.

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Blog writer’s views
Why the incidents are getting repeated?
Based on the Prohibition of Employment as Manual Scavengers and Rehabilitation Rules, District level
survey committee and State level survey committee are responsible for monitor & oversee the survey
process, distribute material for awareness campaign to designated place, arrange publicity through
local newspapers etc. about the survey, distribute translate survey material to designate place under
its jurisdiction, approve and publish final list of consolidated manual scavengers for all towns, cities and
villages in the district. State as well as District Survey committee has responsibilities to carry out survey
as per the sampling pattern specified in the law (Every local authority has responsibility to carryout
survey of insanitary latrines, Survey of Manual Scavengers within its jurisdiction, as per Chapter II & III
respectively PEMSR Rules). Also, has responsibility to connect with community, but authorities are
lacking to meet the requirements. Even though the legislative provisions are existing but their
implementation has open the avenue for further exploration.

Lapses from local authorities to inforce the law is clearly visible from the incident trend over the years
and no improvements marked to pull the trend downwards, as incidents of sanitary worker/s death
getting regularly reported. It may be due to any reasons but taking appropriate action is prime
responsibility of the authorities at all levels. No records available related to exact number of sanitation
workers engaged in manual scavenging. Reason may be, worker associated with the occupation are
mostly casual labourers. Local authorities might have initiated awareness program but it appears to
remain on rather than practice, as no evidences are noted in the public domain.

Under the law, provision do exist for compensation in case of death of sanitation worker and it is the
responsibility of employer to ensure his worker are covered with life insurance of ten lakh rupees.
Minimal legislative provision exists related to occupational health of the workers engaged in this
occupation. No provisions exist in the law addressing the occupation related chronic diseases except
provision for vaccination. Also, provisions for acute disease are not elaborated in detail, apart from
regular medical check-up (period is not specified). Priority should have been given to Health and Safety
of workers. Law is having provision for compensation based on risk of losing the life, then why this
occupation is not notified as high risk one?

It is the responsibility of employer to provide protective gears and safety devices and ensure post task
measures (as listed in the Chapter II- Obligation of employer towards employees PEMSR Rule). Local
authority has responsibility to ensure that cleaning devices are used by persons engaged in inspection,
maintenance, cleaning etc. of sewer system, septic tank (Rule 5- PEMSR Rule). Still, we come across
regular reports of deaths of sanitation workers, till the date, no one from the local authorities has faced
disciplinary action/s for their failure and for the fatalities resulted in their jurisdiction. In very few cases,
convictions to employers were noted but most of them were released from detention, due to many
loop holes in the system.

Illiteracy and unemployment are the major concern and has pushed many unemployed illiterate as well
as literates to opt sanitation work as their profession. Most of the worker engaged in this occupation are
casual labours, either they work with private contractors or in many cases as an individual. Also,
contractors seldom bother to follow safety norms.

The law demands necessary steps to reduce the Risk to persons by taking safety precautions, the
mandates, display of written operating and rescue procedure at the entry site, CCTV monitoring is
mandatory throughout the operation period if person entering manhole or sewer line, first aider, basket
stretcher or similar means onsite are mandatory requirements...., but reality is known to everyone. Local

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administration has appeared to be unsuccessful to enforce the law and meet the legislative
requirements. This is one of the major cause of repeated incidents.

Provisions exist but with no clarity, as law prescribes, all employees present on-site during cleaning
work must be provided with necessary training and training shall be conducted every two years, but
who shall provide the training? what topics it should cover and how? who is supposed to certify the
competency level of the participants and so on, the entire process loops around competency of workers
including the site supervisor. Who should be held responsible for incompetency of the workers? Lack
of training, knowledge and awareness about the confined spaces and associated hazards are factors
responsible for worker’s deaths. The workers carry out their job is miserable conditions; not even basic
personal protection is available or provided to them. For example, law mandate provision of full body
suit or partial fishing wader body suit depends on depth and also other safety gears, but who shall take
the lead, we need to change our attitude.

As per the law, District level survey committee and State level survey committee are oblige to carry out
survey of manual scavengers within its jurisdiction, complete their registration process, ensure they
are rehabilitate them. Let us consider as, local authorities are very serious in their task, then the
question arises as usual, why we are not able to curtail the rate of incidents?

As we know, it is essential to carry out the sanitation work on periodic bases and even though high risk
nature of the activity, this occupation haven’t gained necessary attention and the respect due to the
nature of the work. No one appears to be concerned about worker’s health & safety.

Local authorities were supposed to create awareness amongst the members of society in their
jurisdiction but no such measures are visible, as a result of it, housing societies, private facility owners
etc. hire private contractors, individuals, those who claim themselves as private safai contractor/workers
to get work contracts. In such cases, neither the private safai kamgar is listed in the final state list nor
does they are equipped with necessary safety devices and the capacity to meet the legal requirements.
Also, housing societies, private facility owner etc. always look for cheaper and easier options and in some
cases to avoid to face typical government officials and the formalities.

Even though it may sound strange but it is the reality that the workers adopt tool to gauge risk levels at
the site is a box of safety matches. “A match stick is lit at the mouth of the sewer to find out the presence
of flammable gases (methane) and to confirm the oxygen deficient air inside the confine spaces and
perform the entry. Such malpractices should not be adopted.

How to prevent the reoccurrence of incident?

Working on the directions of the law, the final list of manual scavengers- safai kamgar to be created and
updated timely. Local authority has to ensure that every individual worker under goes the mandatory
training and they understand the hazards associated with the activity, minimum requirements while
onsite, safety measures to be in place, use of the equipment’s, training on emergency response,
respiratory protection equipment’s- their use, maintenance & care etc… Training shall be conducted
every two years. At least one member of the work group is undergone the training as Authorized Gas
Tester and retrained periodically.

Local authorities need to list out authorized the training provider, oversee the content of the training
with respect to the requirements and suggest necessary changes. Ensure, employer including private
contractor arrange the mandatory trainings for their employees.

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It is suggested that, the local authorities need to create list of authorized private sanitation work
contractors with in their jurisdiction based on the capabilities & other standards. Also, convey the
message through awareness campaign to take help of registered private safai work contractors only.

Law need to clearly propose the prerequisite to adopt Risk Assessment approach while planning
sanitation activity, especially for “hazardous cleaning” and in case of RARE exceptions wherein confined
space entry is necessary. As stated on the page three, entry into manholes or septic tanks only permitted
in extreme circumstances with the prior permission of the Commissioner. All the documents including
Standard Operating Procedure, Emergency Response procedure, Risk Assessment, valid training records,
Insurance documents, equipment fitness certificate etc. proposed to be certified by officials from
commissioner office prior to commencement of actual work. The Risk Assessment documents, shall be
signed by employer, site supervisor and the site owner or authorised signatory prior to submission for
the approval. How much it is feasible, is different topic and can be discussed separately, as we are
concerned about the life safety as priority. Process must take help of technology, by adopting online
submission, acceptance and approval/rejection (with reasons clearly stated) approach which remains
time bound. For every work application submission shall have unique identification number, which can
use to track the submission online. Adopting this method, shall help in prompt & effective tracking of the
activities.

Proper risk assessment, (excluding, analysis of sewage for micro-organisms as they can constantly
change), Ensure that team performing the sewage cleaning activity understand the risks through proper
instruction, training and supervision.

Proper ventilation must be provided for sewer, septic system confined spaces, prior to the entry into
confined space, atmospheric test must be conducted by Authorised Gas Tester having valid authorization,
and also provision for continuous atmosphere monitoring and note the result accordingly. Employer,
contractor, facility owner etc. must provide all mandatory protective gears and safety devices for the
purpose (as prescribed in the Rule-5 and according to Rule 7-PEMSR Rule), including Respiratory
Protective Equipment as appropriate for the task and identified in risk assessment. Also, employer,
contractor, facility owner etc. must ensure, all the precautions are in place prior to begin the activity.

Standardised procedures and legislative guidelines must be followed prior to permit confined spaces,
atmospheric test must be conducted by authorized gas tester for the confined spaces covering the test
area from side-to-side and top to bottom. Approach of continuous monitoring of the confined spaces
must be adopted.

The Inspectors required to carry out the site audits, verify the requirements are meet, including display
of standard operating procedure, emergency procedures on site and discuss with workers onsite to
ensure they understand the content of procedures. Verify the minimum requirements as per the
provisions in the law i.e. minimum three employees at site one of them shall be supervisor, traffic and
pedestrian barricades, flagman, ventilation means, safety devices including tripod and harness or other
methods ensuring manoeuvring in case needed, warning signs, flash lights and means of
communication (two-way radio into sewer and confined spaces), law empower the inspector to stop
the cleaning activity if any gaps are observed and pose immediate threat to the life and report the same
to local authority. Reality is far more different, isn’t it?

Effective use of the social media by connecting with all workers, creating awareness by sharing useful
information, health & safety AV. For the success of the program, local authorities need to circulate the
pamphlets printed primarily in local language. Use of media in effective manner as similar to swatch
bharat mission.

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Stringent measures, should be adopted to punish the offender, in case of any incidents gets reported and
investigation concludes that the short fall is result of unprofessional conduct & practices, rather than
tagging the incidents as negligence or tragedy. It is very easy for politicians to be active in declaring the
compensation for the life’s lost rather the adopting proactive approach to administer the local authorities
with its functioning.

Until now, the occupational health of sanitation workers, haven’t received the necessary attention and
always overlooked. For workers, exposure to sewage or its products may result in gastroenteritis,
cramping stomach pains, diarrhoea and vomiting; Weil’s disease (Leptospirosis); hepatitis, characterised
by inflammation of the liver, and jaundice; occupational asthma, resulting in attacks of breathlessness,
chest tightness and wheezing, and produced by the inhalation of living or dead organisms; infection of
skin or eyes; and/or rarely, allergic alveolitis (inflammation of the lung) with fever, breathlessness, dry
cough, and aching muscles and joints as also common among workers. Indian human rights organization-
Safai Karmachari Andolan, need to take up this issue and not just limiting their movement to the
compensation to the families of deceased person. Occupational health of worker must receive prime
importance and there is lot of scope for overall improvement.

Worker health and safety risks are likely to vary among specific locations, local authorities may consult a
trained health and safety professional not only to create site specific worker health and safety plans but
also to propose changes in the existing law framework. Also the authorities as all level to put more efforts
to close the gaps noted in specific time frame, record the findings & actions and sharing with local and
state bodies.

Additional Safety and Health measures to prevent incidents

Direct exposure to sewage should be eliminate, use of Remote-Controlled Robotic Cameras and similar
devices to perform sewer system or septic tank inspections; drying sludge before disposal; injection of
sewage into land (post treatment) rather than spreading; blocking and bypass pumping of sewer sections
prior to reconstruction. Activity based, specialized Remotely Operated Vehicles (ROV) need to be
developed further.

Provision of adequate personal protective equipment’s and Respiratory Protective Equipment’s to

workers. Respirator selection shall be based on an evaluation of respiratory hazards and risk assessment;
however, during entry for maintenance repair and cleaning inside a large sewage tank, it is recommended
that workers wear full-face, supplied-air respirators with an escape set. Trained confined space hole
watch, breather apparatus record keeper are additional requirements must be meet.

Along with Decontamination facility, provision of adequate welfare facilities, including shower facility or
portable shower facility (especially for remote site) with clean water, soap, sanitizer, etc. portable welfare
facilities should be provided. Areas for storage of clean and contaminated equipment should be
segregated and separate from eating facilities. It may sound difficult but not impossible.

Vaccinations must be completed as stipulated by the law, occupational health practitioner to advise on
Diphtheria-Tetanus vaccinations, typhoid fever, hepatitis vaccinations.

Workers should be trained to report potentially work-related illnesses or symptoms to the appropriate
supervisory or health care staff. This may aid in the early detection of work-related health effects.

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Reference:

 Ministry of Social Justices and Empowerment

http://164.100.228.143:8080/sbm/content/writereaddata/AMRUT%20SOP%20Book%20Final.pdf
 Prohibition of Employment as Manual Scavengers and Their Rehabilitation Act, 2013- Raj Patra -
https://ncsk.nic.in/sites/default/files/manualsca-act19913635738516382444610.pdf
 http://swachhbharatmission.gov.in/sbmcms/writereaddata/images/pdf/Guidelines/Complete-set-
guidelines.pdf
 National Safai Karamcharis Finance & Development Corporation- https://nskfdc.nic.in/
 https://www.canr.msu.edu/

Disclaimer:

All the views expressed in the blog are my own and do not represent the opinions of any entity whatsoever
with which I have been, am now or will be affiliated. This document may provide guidance to Health and
Safety Professionals, representatives of local authorities and interested parties. Nothing herein, however,
is intended to replace, amend, supersede or otherwise depart from any other legal requirements. Blogger
has no intention for held any individuals or the authority representatives, responsible for the past
incidents.

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