Managing India’s Hazardous Wastes

By: Sulagna Chattopadhyay
The growing economy along with emerging industries generates hazardous waste which if not managed can pose to be a serious health hazard. Various strategies put forward by the Ministry of Environment and Forests in terms of regulatory and institutional framework, technical guidelines, identification, treatment and disposal to manage such waste are in place, but they require effective implementations.
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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 is therefore essential. India urgently needs an appropriate strategy for generators of wastes and recyclers; regulatory bodies and operators of the facilities to treat and dispose hazardous wastes in an environmentally sound manner.

Various interventions such as regulatory and institutional framework, technical guidelines, development of individual and common facilities for recycle-recovery-reuse, inventory, treatment and disposal of hazardous wastes, identification and assessment of dump sites for the purpose of preparing remediation plans and awareness creation amongst various stakeholders are in place. However, these activities need to be expanded, reinforced and strengthened. India needs to achieve ‘zero disposals of hazardous wastes’ through cost effective innovative technologies 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 model. Wastes not amenable to the treatments mentioned so far need to be subjected to physico-chemical or biological treatment, incineration or disposal in secured landfill.

The rules

Hazardous Waste Management Rules are notified to ensure safe handling, generation, processing, treatment, package, storage, transportation, use, reprocessing, collection, conversion and offering for sale, destruction and disposal of hazardous waste. These Rules came into effect in the year 1989 and have been amended later in the years 2000, 2003 and with final notification of the Hazardous Wastes (Management, Handling and Transboundary Movement) Rules 2008, in supersession of former notifications. In the latest addition, the Ministry of Environment and Forests (MoEF) notified the Hazardous Waste Substances (Classification, Packaging and Labelling) Rules in August 2011. The Rules incorporate the essence of the National Environmental Policy of 2006 and relevant multilateral environmental agreements such as the Basel Convention and the National Regulations; and, reiterate that import of hazardous wastes from any country to India for disposal shall not be permitted.

New projects

In a recent move MoEF has initiated a project on remediation of hazardous waste contaminated areas in the country with Central Pollution Control Board (CPCB) as the implementing agency under the National Clean Energy Fund (NCEF). Dr J S Kamyotra, Member Secretary, CPCB threw light on initiatives taken first-time-ever in the country for remediation of 12 hazardous waste contaminated sites selected on priority by proposing “to build broad based strategies and guidelines for implementation of remediation works at national level from the lessons learnt from remediation of 12 priority contaminated sites across the country. Remediation of the sites will minimise the environment and health risks by containing the migration of the chemicals and pollutants from contaminated soil and groundwater to acceptable and safe levels.”

Structured under a World Bank aid, a policy framework towards a management strategy for hazardous waste is also being developed by the MoEF in association with CPCB, under three broad components under ‘Capacity Building for Industrial Pollution Management Project’ (CBIPMP) which is designed to provide a comprehensive framework for investments in remediation of contaminated orphan sites and solid waste dumpsites which pose significant hazards to human health and the environment. “The development of the National Programme for Rehabilitation of Polluted Sites (NPRPS) will require the development of a national methodological framework for site assessment, prioritisation, clean up/remediation standards and financing modalities for implementation. The three components currently underway are inventorisation and mapping of contaminated sites, development of methodologies for remediation and creation of a national programme,” informed Dr Kamyotra.

“Under the CBIPMP project, pilot studies for remediation of two contaminated sites in Andhra Pradesh (Noor Mohammed Kunta in Hyderabad and municipal dumpsite in Kadapa) and two sites in West Bengal (Dhapa municipal dump site in Kolkata and chromium dumpsites in Hooghly district), have been identified for remediation on pilot basis,” informed B V Babu, Sr. Environmental Engineer, Hazardous Waste Management Division, CPCB. “Numerous remediation works have been taken up in western developed countries over the past two decades, these first ever attempts at remediation of hazardous waste on-site is going to be a leap forward for the nation”, added Dr Kamyotra.

Existing Scenario of Hazardous Waste Management in India

Based on the information obtained from SPCBs/PCCs, it is estimated that there are about 40,000 hazardous waste generating industries in India producing about 7.90 million tonnes of hazardous waste per annum. These wastes can be categorised into three components, recyclable, landfillable and incinerable (Fig 1).

Maharashtra (22.84 per cent), Gujarat (22.68 per cent) and Andhra Pradesh (13.75 per cent) are the top three hazardous waste generating states in the country. Thereafter Rajasthan, Tamil Nadu, Madhya Pradesh and Chhattisgarh fall in the second category generating more than 2.5 lakh tonnes per annum. These seven States together, are generating about 82 per cent of country’s total hazardous waste (CPCB 2009) (Table 1).

Table 1: Statewise Status of Hazardous Waste Generation

Table 1: Statewise Status of Hazardous Waste Generation

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 the generation of hazardous wastes. 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. In view of fast changing industrial profiles in terms of products, capacity of production and new industries getting established, there is a need to periodically update inventories by the SPCBs and PCCs. Besides, it should be mandatory on the part of industries to report hazardous waste generation and the mitigating steps taken by them. 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.



Waste Avoidance and Minimisation at Source

Waste avoidance and waste minimisation have to be hierarchically placed. This requires a close look at the processes that generate hazardous wastes so that feasible modification in processes, technologies and plant practices can be attempted. Dissemination of information on technological options for such practices should, therefore, be a continuing exercise. If the switch over to cleaner processes involves substantial investments and import of machinery and technology, suitable financial incentives may be offered. The chemical industry requires cleaner technologies in major segments of its production 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 to enable speedier adoption of cleaner technologies.

Fig 1. Percentage component of Hazardous Waste Generation
Fig 1. Percentage component of Hazardous Waste Generation

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 priority are the ‘reuse-recover-recycle’ useful resources from wastes. To promote such options establishment of financially assisted, waste exchange banks and centres should be encouraged jointly 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 because of growth in the various sectors serves as incentive for recycling of such wastes. The recycling of used lubricating oil is another example of resource conservation. There are more than 1000 registered recyclers of non ferrous metal wastes, used oil and waste oil registered under the Hazardous Wastes Rules, 2008. Recycling at present 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. 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 environmental and health hazards is reported to be continuing. 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 co-disposal 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

The E-Waste (Management & Handling) Rules, 2011 have been notified in May 2011 and have become effective from May 1, 2012. These rules were notified in advance to give the various stakeholders adequate time to prepare themselves and also to place the required infrastructure for the effective implementation of these rules. The objective of the rules is to ensure environmentally sound management of e-waste. The rules are based on the concept of extended producers responsibility and is meant for every producer, consumer or bulk consumer, involved in the manufacture, sale and purchase and processing of electrical and electronic equipment or components as specified in schedule I of the said rules and also to collection centres, dismantlers and recyclers of e-waste.

There are about 77 registered recyclers/dismantlers of e-waste in the country to whom the e-waste can be channelised for environmentally safe recycling. The degree of recycling the e-waste depends on type of recovery technologies adopted. Most of the registered recyclers in the country are engaged in dismantling operations, who are also engaged in exporting part of the e-waste (especially the PCBs) to large scale recovery facilities located in western countries (Europe) for recovery of precious metals. The capacity of registered recyclers in the country is limited in terms of number of precious metals that can be recovered by them and the degree of recovery of precious metals from e-waste. E-waste may be exported to other countries as long as those countries accept the same and is economically viable to the Indian entrepreneur or till such integrated facility is set-up in the country.



Wastes which cannot be reused or recycled have to be disposed in an environmentally sound system. 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 landfilling or incineration. There are 36 common hazardous waste treatment, storage and disposal facilities (TSDFs) in the country of which 16 are integrated, 6 are common incinerators and 14 are common secured landfill (SLFs). There are 6 TSDFs under construction at present. (CPCB, December 2011) The States where there are no TSDFs have limited or inadequate options for disposal of hazardous waste due to inadequate captive facilities, hindrances in interstate movement and permissions. The existing TSDFs have a cumulative capacity of about 32 million metric tonnes for secure landfill of hazardous waste and about 0.18 million tonnes/annum for incinerable hazardous waste. There is acute problem of disposal in the states generating moderately high quantity of hazardous waste but not having a TSDFs such as Chhattisgarh, Jharkhand, J&K, Goa, Assam, and Puducherry.

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.

Cement Kilns Incinerating Hazardous Wastes

Utilisation of hazardous waste either as co-processing in cement kilns or in other applications as a supplementary resource or for energy recovery after processing have been initiated in the country. There is an increasing trend of co-processing of hazardous wastes in cement plants over the past 3 years and in 2011 about 45,000 tonnes of hazardous wastes was being co-processed in cement plants annually. Incineration of high calorific value hazardous wastes in cement kilns is one of the safe alternatives – with the implementation of suitable safeguards. In cement kilns, high flame temperatures ensure complete combustion of all organic compounds. There are 98 hazardous waste incinerators including 22 common facilities available in the country among which 18 are in the northern, 31 are in the central and 49 are in the southern region. Further, there are 157 bio-medical waste incineration facilities (National Implementation Plan, MoEF, April 2011). There are several cement production facilities that are allowed to co-incinerate hazardous wastes. The common hazardous waste incinerators can be utilised for destruction and disposal of toxic organic wastes such as date expired pesticides, pesticide intermediates/residues, expired medicines, persistent organic pollutants in an environmentally safe manner.

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

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 the customs authorities in distinguishing between used oil and waste oil serves as a case in point.

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.


There are several hazardous waste contaminated dump sites in various parts of India where hazardous wastes were dumped by several industrial units during their industrial operations resulting in contamination of soil and ground/surface water. In some instances, industries responsible for contamination have been either closed down or the cost of remediation is beyond the capacity of the polluter – the sites however, remain contaminated. Sites were also created illegally and clandestinely for dumping and disposal of industrial waste. These contaminated dump sites need to be remediated on priority and restored in an environmentally sound manner through appropriate remediation technologies to safeguard human health and environment.

*Inputs from Hazardous Waste Management Division, Central Pollution Control Board, New Delhi

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