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BIOMEDICAL WASTE MANAGEMENT RULES- 1998 VERSUS ( DRAFT)2015 DIFFERENCES, CHALLENGES, AND ACTIONABLES DR. SUMI NANDWANI PROFESSOR CUM/OR CHIEF CONSULTANT & HOD, MICROBIOLOGY, SUBDEAN SUPERSPECIALITY PAEDIATRIC HOSPITAL AND POSTGRADUATE TEACHING INSTITUTE,NOIDA

BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

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Page 1: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

BIOMEDICAL WASTE

MANAGEMENT RULES- 1998 VERSUS ( DRAFT)2015

DIFFERENCES, CHALLENGES, AND ACTIONABLES

DR.  SUMI  NANDWANI  PROFESSOR-­‐  CUM/OR  CHIEF  CONSULTANT  &  HOD,  MICROBIOLOGY,  SUB-­‐DEAN  SUPERSPECIALITY  PAEDIATRIC  HOSPITAL  AND  POSTGRADUATE  TEACHING  INSTITUTE,NOIDA    

Page 2: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

POINTS TO BE DISCUSSED ………… ! Available Guidelines ! BMWM Rules (1998) ! BMWM Rules( Draft 2015) ! Differences ! Challenges ! Actionables

Page 3: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

( PROPOSED) THE BIO-MEDICAL WASTE (MANAGEMENT

AND HANDLING) RULES, 2015

WHAT ARE THE AVAILABLE GUIDELINES ?

Page 4: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

ENVIRONMENTAL LEGISLATIONS 1974   Water Act (mentions sewage but not pollution by garbage) 1981   Air Act (no mention of smoke pollution from burning waste) 1986   Environment Protection Act (no mention of urban solid waste) 1989 Hazardous Chemical Waste Rules

1998 Biomedical Waste (M & H) Rules

1999 Rules for Recycled Plastics,

1999 Fly Ash Notification

2000 Municipal Solid Waste Rules

2001 Lead Acid Battery (M & H) Rules 1991   Coastal Regulation Zones 2002 Eco-Fragile Zones for Hill Stations

Page 5: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

BIOMEDICAL WASTE (MANAGEMENT & HANDLING) RULES, BY GOVT. OF INDIA To  enable  hospitals  to  develop  comprehensive  plan  for  BMWM:  

Biomedical Waste (Management & Handling) Rules, 1998 were Notified  under  Environment  Protection  Act,  1986  by  MoEF,  Govt.  of  India  -­‐  28th  July  1998      (Amended in 2000,2003)  

However these 1998 Rules had few shortcomings and so Revised rules, namely, the Bio-Medical Waste (Management and Handling) Rules, 2011 were drafted but could not be finalised pending consensus on certain issues relating to categorisation of Bio-medical waste and emission standards for incinerators.

Rules being revised again–

Govt. has notified again the revised version of the said draft rules To be called BMW (Management and Handling) Rules 2015 Draft rules were circulated and posted on website(MOEF) on 3rd

June 2015 for information of the masses. Objections/suggestions for modifications were invited within 60 days.

These are being discussed by MOEF for finalization.

Page 6: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

APPLICATION : 1998 RULES

Page 7: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

APPLICATION : DRAFT 2015 RULES

Page 8: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

CHALLENGES These ( a to g) waste eg. Home based Care and

Outreach facilities constitute a huge bulk of HCW and should be addressed , instead of saying the BMW Rules do not apply to such waste. Separate guidelines to handle such waste should be formulated and We should emphasise that separate rules exist to handle such waste with a link to these

A statewise list of authorized dealers, recyclers (e.g. for Mercury Waste, E -waste) and Treatment facilities (e.g. Hazardous Waste Treatment Facilty)is needed

DIFFERENCES IN APPLICATION

!

Draft 2015 Rules 1998 Rules

Application Makes a mention of other hazardous Health care waste which are not a part of BMW

No mention of these other hazardous Healthcare waste

Page 9: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

DEFINITIONS: 1998 RULES

Page 10: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

DEFINITIONS: DRAFT 2015 RULES

Page 11: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

DIFFERENCES IN DEFINITIONS

!

Point Draft 2015 Rules 1998 Rules

3.Definitions 1.Mentions “ Biomedical Waste Treatment and Disposal Facility” 2. “Occupier”: Defined as Person having Administrative Control over Institutes who generate BMW 3.Includes “ all systems of Medicine”

1.Only “ Biomedical Waste Treatment Facility” 2. “ Occupier”: Defined as Institutes generating BMW 3. Other systems of Medicine not mentioned

Page 12: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

DUTIES OF OCCUPIER :1998 RULES

Page 13: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

DUTIES OF OCCUPIER : DRAFT 2015 RULES

Page 14: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

DIFFERENCES IN : DUTIES OF OCCUPIER

!

Point Draft 2015 Rules 1998 Rules

Duties of Occupier

Have been detailed including: 1. Immunization, training, ensuring

Occupational Safety, Providing PPE to HCWS.

2. Record keeping,Accident Reporting,Reporting delay in pick up , ensuring segregation of BMW.

3. Formulating a BMW Management Committee

Have not been detailed

Page 15: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

CHALLENGES (DUTIES OF OCCUPIER ) IN DRAFT 2015 RULES •  Specific ‘Do’s and Don’ts are needed to make these steps

specific

•  Specifying the training module, duration and type will ensure uniformity and compliance by all levels of Health care workers

•  The frequent turnover of housekeeping, nursing or other contractual staff should be addressed and discouraged

•  Including all cases/ incidents of Sharp Injuries at all steps during patient care may become laborious and difficult

•  The PPE may not be available to the HCWs unless specified

•  Unless people from Administration, Finance and other departments are not included in the Committee most of the Compliance monitoring is left to Nodal Officers making it difficult for them to implement/comply

•  A team with above specified composition would ensure regular monitoring

Page 16: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

DUTIES OF OPERATOR OF CBMWTFS- DRAFT 2015 RULES

Page 17: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

DIFFERENCES : (DUTIES OF OPERATOR OF CBMWTFS)1998 RULES VS DRAFT 2015 RULES

!

Point Draft 2015 Rules 1998 Rules

Duties of the operator of CWTF

All duties listed Operator duties absent

Page 18: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

CHALLENGES(DUTIES OF OPERATOR OF CWTFS) IN DRAFT 2015 RULES •  Non compliance to all/ any of the above should be punitive •  The PPE may not be made available to the HCWs unless

specified •  Pick up usually is not timely because of a single operator

collecting from multiple sites with limited number of vehicles & limited capacity

•  Some states don’t have any authorized CWTF operator •  If one CWTF operator loses his license, timely handover to

another operator for collecting & treatment of waste •  Currently rates for these operators are on per bed basis

which makes it difficult to calculate or fix the rates for HCFs with no inpatients. Therefore, both the options(beds/ weight) should be available

Page 19: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

DUTIES OF AUTHORITIES- DRAFT 2015 RULES

Page 20: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi
Page 21: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

!

Point Draft 2015 Rules 1998 Rules

Duties of the Authorities

All duties listed Duties of Authorities absent

DIFFERENCES : (DUTIES OF THE AUTHORITIES)1998 RULES VS DRAFT 2015 RULES

CHALLENGES(DUTIES OF THE AUTHORITIES) IN DRAFT 2015 RULES

Actions which can be taken by authorities in case of non compliances should also be specified

Page 22: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

TREATMENT AND DISPOSAL :1998 RULES

Page 23: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

TREATMENT AND DISPOSAL Color Coding Type of Container Waste

Category Treatment options

Yellow Plastic bag Cat.1, 2,3,6 Incineration/deep burial Red

Disinfected container/Plastic bag

Cat 3,6,7 Autoclave/Microwave/ Chemical Treatment

Blue/White translucent

Puncture proof container

Cat.4,7

Autoclave/Microwave/ Chemical Treatment & destruction/shredding

Black Plastic bag

Cat 5,9,10 Disposal in secured landfill

Own requisite BMW treatment facilities or at a CWTF Chemicals treatment using at least 1% hypochlorite solution No chemical pretreatment before incineration. Chlorinated plastics should not be incinerated. Liquid waste: 1 part bleach to 9 parts contaminated liquid – let stand for 20 to 30 minutes. After treating, dispose down drain with lots of H2O best is own ETP

Page 24: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

TREATMENT AND DISPOSAL :DRAFT 2015 RULES

Page 25: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

DIFFERENCES : (TREATMENT AND DISPOSAL)1998 RULES VS DRAFT 2015 RULES

!

Point Draft 2015 Rules 1998 Rules

Treatment and Disposal

Are more comprehensive including: 1. An option for adopting new

technology provided. 2. Option for Occupiers>500 beds to

install their own incinerator if needed depending on recipient environment, location & availability of CWTF nearby/not.

3. Mandatory for operators of CWTFs to install reqd. equipments eg. Shredder, incinerator, autoclave/microwave, ETP e.t.c before commencing operation.

4. Use of chlorinated bags & incineration of chlorinated plastics prohibited

5. Mandatory for occupiers/operators of CWTFs to dispose recyclable BMW i.e. Plastics and Glass through authorized Recyclers after treatment(autoclaving/microwaving &shredding/ mutilation)

6. Maintainence of Record of such recyclable waste sold & submission of this to authorities mandatory

7. Mercury Waste Disposal emphasized.

Very brief –Only mentions about Occupiers to adhere to Schedule I( categories), Schedule V( standards for treatment) and schedule VI( Time frame) for Treatment and Disposal of BMW

Page 26: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

CHALLENGES(TREATMENT AND DISPOSAL) IN DRAFT 2015 RULES •  A lot of states do not have authorized CWTFs. •  The availability( nearest distance) of CWTF and

distance from Residential areas for deciding permission to install incinerators need to be specified.

•  Currently a lot of states do not have authorized recyclers for Plastic and Glass waste.

•  Most of the manufacturers of Plastic Bags /Plastic items donot have nonchlorinated Plastics and if so, do not have certification for the same

•  A lot of states do not have authorized Hazardous Waste Treatment Facilities.

Page 27: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

SEGREGATION , PACKING, TRANSPORT &STORAGE: 1998 BMW RULES

Page 28: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

CATEGORIES OF BMW(1998 RULES)

Page 29: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi
Page 30: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

CATEGORIES OF BIO-MEDICAL WASTE(1998 RULES) Category

Waste type

Colour coding

Treatment & Disposal

1. Human anatomical

Yellow Incineration / deep burial

2. Animal waste

Yellow Incineration / deep burial

3 Microbiology & Biotechnology Waste

Yellow/ Red Autoclaving/microwaving/ Incineration

4 Waste Sharps

White / blue / Translucent puncture proof containers

D i s i n f e c t i o n b y c h e m i c a l t r e a t m e n t / a u t o c l a v i n g / Mic rowav ing & mut i la t ion /shredding

5 Discarded medicines and Cytotoxic drugs

Black Destruction/ neutralization & disposal in secured landfills

Page 31: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

Category

Waste type

Colour coding

Treatment & Disposal

6 Soiled waste

Yellow/red Incineration / autoclaving/ microwaving

7 Solid ( plastic)

Blue/ White/ Red Disinfection by chemical

treatment/autoclaving/ Microwaving & mutilation/shredding

8 Liquid waste

------- Disinfection by chemical treatment and discharge into drains

9 Incineration Ash

Black Disposal in municipal landfill

10 Chemical

Black Chemical treatment and discharge into drains for liquids and secured landfill for solids

Page 32: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

SEGREGATION OF HCW BEING FOLLOWED CURRENTLY AT HOSPITALS

Page 33: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

TRANSPORT Intramural: By wheeled trolleys Wheelbarrows/containers /carts authorized only for the purpose

Easy to load and unload, No sharp edges, Easy to clean, Disinfect daily

Waste routes must be designated.

Separate time should be earmarked

Extramural: only  in  such  vehicles  as  may  be  authorized  for  the  purpose    

Container  apart  from  the  label  prescribed  in  Schedule  III,  should  also  carry  information  prescribed  in  Schedule  IV.    

Page 34: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

STORAGE •  In  an  area  away  from  general  

traffic  and  accessible  only  to  authorized  personnel  

•  DO  NOT  store  for  more  than  48  hours    

•  If  for  any  reason  it  becomes  necessary  to  store  the  waste  beyond  such  period  take  measures  to  ensure  that  the  waste  does  not  adversely  affect  human  health  and  environment    

Page 35: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

CATEGORIES OF BMW(DRAFT 2015 RULES)

Page 36: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

CATEGORIES OF BMW (DRAFT 2015 RULES) CONT..

Page 37: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

CATEGORIES OF BMW (DRAFT 2015 RULES) SCHEDULE I CONT..

Page 38: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

SEGREGATION , PACKING, TRANSPORT &STORAGE: DRAFT 2015 BMW RULES

Page 39: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

DIFFERENCES( CATEGORIES AND COLOUR CODING OF BMW) 1998 VS 2015 DRAFT RULES

!

Point Draft 2015 Rules 1998 Rules

Categories of BMW

Categories of Biomedical Waste according to colour

Biomedical waste divided in ten categories according to type of waste

Colour option for waste Segregation

1. Only one colour option to ensure uniformity and clarity

2. Glass and Metal Sharps in different colour categories

1. Multiple options for colour creating nonuniformity and confusion

2. Glass and Metal Sharps in same category

DIFFERENCES : (SEGREGATION , PACKING, TRANSPORT &STORAGE)1998 RULES VS DRAFT 2015 RULES

!

Point Draft 2015 Rules 1998 Rules

Storage Sharps and Solid Waste exempted from 48 hrs time limit for storage

All type of waste cannot be stored beyond 48 hours

Page 40: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

CHALLENGES( CATEGORIES AND COLOUR CODING OF BMW) IN DRAFT 2015 RULES

•  Microbiology, Biotechnology and other clinical Laboratory Waste, Blood Bags and Gloves should be elaborated and shifted from yellow to Red Category as autoclavable waste

•  Treatment of Microbiology, Biotechnology and other clinical Laboratory Waste should be modified with inclusion of Autoclaving as onsite treament and deletion of incineration and chemical disinfection

•  If infected linen has to be discarded then Linen and beddings should not be incinerated but can be autoclaved followed by washing or can be shredded and recycled after washing in 1% hypochlorite

Page 41: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

CONTD… •  Treatment to be modified with deletion of

“Chemical disinfection” and “ Incineration” •  Plastic Containers are not biodegradable. This

can be resolved by using biodegradable materials for sharp containers

•  Liquid waste should include liquid patient samples and method of disposal should be specified especially in absence of a functional ETP Plant

•  Standards for ETP Plant and Shredder should be provided

Page 42: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

CHALLENGES: (SEGREGATION , PACKING, TRANSPORT &STORAGE) DRAFT 2015 RULES •  All waste segregated at collection sites is

dumped together in a single compartment vehicle.

•  Usually the same vehicle is used to pick up waste from multiple Hospitals leading to either delay in pickup and sometimes overloading of vehicles.

•  An option of storing this waste beyond 48 hours should not be available as it may lead to noncompliance

•  Bio- medical waste should not be handed over to municipal bodies

Page 43: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

LABELS 1998 RULES 2015 DRAFT RULES

LABEL FOR RADIOACTIVE WASTE ( NOT A PART OF BMWM RULES)

Page 44: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

LABEL FOR TRANSPORT DRAFT 2015 RULES 1998 RULES

!

Point Draft 2015 Rules 1998 Rules

Label for transport

Waste category no. & quantity to be mentioned

Waste category no., class & description to be mentioned

CHALLENGE: DRAFT 2015 RULES: Category No. cannot be given as it is accdg. to colour

Page 45: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

PRESCRIBED AUTHORITY (1998 RULES)

Page 46: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

PRESCRIBED AUTHORITY (DRAFT 2015 RULES)

Page 47: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

AUTHORIZATION (1998 RULES)

Page 48: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

AUTHORIZATION (DRAFT 2015 RULES)

Page 49: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

DIFFERENCES : (AUTHORIZATION)1998 RULES VS DRAFT 2015 RULES

Page 50: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

ADVISORY COMMITTEE(1998 BMW RULES)

Page 51: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

ADVISORY COMMITTEE(DRAFT 2015 BMW RULES)

Page 52: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi
Page 53: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

DIFFERENCES : (ADVISORY COMMITTEE)1998 RULES VS DRAFT 2015 RULES

!

Point Draft 2015 Rules 1998 Rules

Advisory Committee

1.Has to meet every 6 months 2. The defence advisory committee should have a member from AFMC and MOHFW 3.Seperate Detailed Mention of monitoring of rules in Armed Forces Health Care Facilities

1.No period/ frequency of meeting specified 2. The defence advisory committee should have a member from ISHWM & MOEF 3. The Defence Advisory committee will be supervised by CPCB

Page 54: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

CHALLENGES(ADVISORY COMMITTEE) DRAFT 2015 RULES:

•  Certain National Organisations working in fields of Infection Control e.g. ISHWM & Hospital Infection Society India( HISI) and in Healthcare Waste Management should form a part of advisory Committee.

•  Clinical/Medical Microbiologist(s) should form a part of the Advisory Committee and Authority

Page 55: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

ANNUAL REPORT, RECORD MAINTENANCE &ACCIDENT REPORTNG (1998 RULES)

Page 56: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

Annual/Monthly report   Every   occupier/operator-­‐  submit   an   annual   report   to  the   prescribed   authority   in  Form   II   by   31st     January   :  categories   and   quantities   of  BMW  

The  prescribed  authority  shall  send   this   information   to   the  CPCB   by   31st     March   every  year.  

Monthly   report   to   DPCC   by  first  week  of  next  month  

Page 57: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

Maintenance of Records

•  Maintain  records  related  to  BMW.  

•  All   records   shall   be   subjected   to  inspection   and   verification   by   the  prescribed  authority  at  any  time.  

SITE%OF%WASTE%GENERATION:_____________________________________%%

%% % Quantity%%%%%%%%%%%%(%No.%of%Bags/%Boxes)%DATE%OF%WASTE%GENERATION%

DATE%OF%WASTE%PICK%UP%

BLUE%BAGS%%

YELLOW%BAGS%%

SHARPS%BOXES%%

DISCARDED%MEDICINES%%

% % % % % %% % % % % %% % % % % %% % % % % %%

Page 58: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

ANNUAL REPORT, RECORD MAINTENANCE &ACCIDENT REPORTNG (DRAFT 2015 RULES)

Page 59: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

DIFFERENCES(ANNUAL REPORT, RECORD MAINTENANCE & ACCIDENT REPORTNG) 1998 VS DRAFT 2015 RULES

!

Point Draft 2015 Rules 1998 Rules

Annual Report

CPCB required to forward the annual Report to MOEF by 30th June every year

No requirement of CPCB to file annual return

Accident Reporting

An accident should be reported within One Month of the incident and have to be a part of Annual Report

No time frame for reporting and not a part of Annual Report

Page 60: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

CHALLENGES(ANNUAL REPORT, RECORD MAINTENANCE &ACCIDENT REPORTNG (DRAFT 2015 RULES):

•  The format of Records to be maintained and points of record maintainence should be specified

•  Accident reporting especially Sharp injuries should be specified as to occurring in which step during Waste handling

Page 61: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

APPEAL, SITE FOR CWTFS,LIABILITY OF OCCUPIER/ OPERATOR (1998 BMW RULES)

Page 62: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi
Page 63: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

DIFFERENCES (APPEAL, SITE FOR CWTFS,LIABILITY OF OCCUPIER/ OPERATOR) 1998 VS DRAFT 2015 RULES

!

Point Draft 2015 Rules 1998 Rules

Appeal Any appeal filed has to be disposed off within 90 days

No such timeframe specified

Liability of occupier/ operator of cwtf

Detailed including: 1. Liability for damages to environment 2. Paying user fees to Municipal

authorities for solid waste 3. Liability under act 5

Not mentioned

Page 64: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

CHALLENGES(APPEAL, SITE FOR CWTFS,LIABILITY OF OCCUPIER/ OPERATOR) DRAFT 2015 RULES •  Punitive Measures should be specified •  Sites for these CWTFs should be away

from residential areas and distance from residential areas should be specified .

Page 65: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

STANDARDS OF INCINERATORS(1998 RULES)

Page 66: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

STANDARDS OF INCINERATOR DRAFT 2015 RULES

Page 67: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

DIFFERENCES IN STANDARDS FOR INCINERATION( DRAFT 2015 VERSUS 1998 RULES)

!

Point Draft 2015 Rules 1998 Rules

1. Secondary chamber Temperature &gas residence time

1050 Deg C 2 Second

1050+/- 50 deg C 1 Second

2. Monitoring value correction factor

11% Oxygen on dry basis 3% Oxygen on dry basis 12% Carbon Dioxide on dry basis

3. Emission Standard

Particulate matter 100 mg/Nm3 Nitrogen oxide 400 mg/Nm3 HCl 50 mg/Nm3 Dioxins & Furans 0.1 ng TEQ/Nm3 Hg & its compound 0.05 mg/Nm3

Particulate matter 150 mg/Nm3 Nitrogen Oxide 450 mg/Nm3 HCl 50 mg/Nm3

4. Sampling duration

Mentioned Not Mentioned

5. Dioxans and Furans Emission limits

Mentioned & to be achieved within 2 years of application of Rules

Not Mentioned

6. Combustion Gas Analyser

Mandatory to be installed Not mandatory

7. Stack gas emission monitoring

Must and to be done once every 3 months by authorized agency and report to be submitted

Not mandatory

Page 68: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

CHALLENGES( STANDARDS FOR INCINERATION IN DRAFT 2015 RULES

•  Currently not all incinerators able to maintain secondary chamber temperature

•  Dioxan and Furan Emission Controls require special Retrofittings which are costly and may take time

•  Stack Emission Monitoring Authorized agencies are limited

Page 69: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

STANDARDS FOR AUTOCLAVING (1998 RULES)

Page 70: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

STANDARDS FOR AUTOCLAVING (DRAFT 2015 RULES)

Page 71: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

DIFFERENCES IN STANDARDS FOR AUTOCLAVING( DRAFT 2015 VERSUS 1998 RULES)

!

Point Draft 2015 Rules 1998 Rules

Standards for Autoclaving

Frequency of Validation Spore Testing( once in 3 months) and Routine Tesing ( every batch) mentioned

Frequency of testing not mentioned

CHALLENGES( STANDARDS FOR AUTOCLAVING IN DRAFT 2015 RULES

Frequency of spore tesing for Autoclaving i.e once in 3 months is less

Page 72: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

STANDARDS FOR LIQUID WASTE, DRAFT 2015 1998 RULES

Page 73: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

STANDARDS FOR MICROWAVING DRAFT 2015 1998 RULES

!

Point Draft 2015 Rules 1998 Rules

Standards for Microwaving

Biological Indicators: Bacillus atrophaeus spores

Biological Indicators: Bacillus subtilis spores

DIFFERENCES

Page 74: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

STANDARDS FOR DEEP BURIAL DRAFT 2015 VS 1998 RULES

Page 75: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

SCHEDULE V LIST OF AUTHORITIES & DUTIES ( DRAFT 2015 RULES)

Page 76: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

DIFFERENCES IN DRAFT 2015 AND 1998 BMW (M&H)RULES)

Page 77: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

Point Draft 2015 Rules 1998 Rules

Treatment and Disposal

Are more comprehensive including: 1. An option for adopting new

technology provided. 2. Option for Occupiers>500 beds

to install their own incinerator if needed depending on recipient environment, location & availability of CWTF nearby/not.

3. Mandatory for operators of CWTFs to install reqd. equipments eg. Shredder, incinerator, autoclave/microwave, ETP e.t.c before commencing operation.

4. Use of chlorinated bags & incineration of chlorinated plastics prohibited

5. Mandatory for occupiers/operators of CWTFs to dispose recyclable BMW i.e. Plastics and Glass through authorized Recyclers after treatment(autoclaving/microwaving &shredding/ mutilation)

6. Maintainence of Record of such recyclable waste sold & submission of this to authorities mandatory

7. Mercury Waste Disposal emphasized.

Very brief –Only mentions about Occupiers to adhere to Schedule I( categories), Schedule V( standards for treatment) and schedule VI( Time frame) for Treatment and Disposal of BMW

Storage Sharps and Solid Waste exempted from 48 hrs time limit for storage

All type of waste cannot be stored beyond 48 hours

Authorization Every occupier generating BMW, irrespective of the quantum of wastes comes under the BMW Rules and requires to obtain authorization

Only Occupiers with more than 1000 patients per month required to obtain authorization

Advisory Committee

1.Has to meet every 6 months 2. The defence advisory committee should have a member from AFMC and MOHFW 3. Seperate Detailed Mention of monitoring of rules in Armed Forces Health Care Facilities

1.No period/ frequency of meeting specified 2. The defence advisory committee should have a member from ISHWM & MOEF 3. The Defence Advisory committee will be supervised by CPCB

Annual Report CPCB required to forward the annual Report to MOEF by 30th June every year

No requirement of CPCB to file annual return

DIFFERENCES IN DRAFT 2015 AND 1998 BMW (M&H)RULES) CONT….

Page 78: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

!

Point Draft 2015 Rules 1998 Rules

Accident Reporting

An accident should be reported within One Month of the incident and have to be a part of Annual Report

No time frame for reporting and not a part of Annual Report

Appeal Any appeal filed has to be disposed off within 90 days

No such timeframe specified

Liability of occupier/ operator of cwtf

Detailed including: 1. Liability for damages to

environment 2. Paying user fees to Municipal

authorities for solid waste 3. Liability under act 5

Not mentioned

Categories of BMW

Categories of Biomedical Waste according to colour

Biomedical waste divided in ten categories according to type of waste

Colour option for waste Segregation

1. Only one colour option to ensure uniformity and clarity

2. Glass and Metal Sharps in different colour categories

1. Multiple options for colour creating nonuniformity and confusion

2. Glass and Metal Sharps in same category

Label for transport

Waste category no. & quantity to be mentioned

Waste category no., class & description to be mentioned

DIFFERENCES IN DRAFT 2015 AND 1998 BMW (M&H)RULES) CONT….

Page 79: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

Point Draft 2015 Rules 1998 Rules

Standards for Incineration

1. Secondary chamber Temperature &gas residence time

1050 Deg C 2 Second

1050+/- 50 deg C 1 Second

2. Monitoring value correction factor

11% Oxygen on dry basis 3% Oxygen on dry basis 12% Carbon Dioxide on dry basis

3. Emission Standard

Particulate matter 100 mg/Nm3 Nitrogen oxide 400 mg/Nm3 HCl 50 mg/Nm3 Dioxins & Furans 0.1 ng TEQ/Nm3 Hg & its compound 0.05 mg/Nm3

Particulate matter 150 mg/Nm3 Nitrogen Oxide 450 mg/Nm3 HCl 50 mg/Nm3

4. Sampling duration

Mentioned Not Mentioned

5. Dioxans and Furans Emission limits

Mentioned & to be achieved within 2 years of application of Rules

Not Mentioned

6. Combustion Gas Analyser

Mandatory to be installed Not mandatory

7. Stack gas emission monitoring

Must and to be done once every 3 months by authorized agency and report to be submitted

Not mandatory

Standards for Autoclaving

Frequency of Validation Spore Testing( once in 3 months) and Routine Tesing ( every batch) mentioned

Frequency of testing not mentioned

Standards for Microwaving

Biological Indicators: Bacillus atrophaeus spores

Biological Indicators: Bacillus subtilis spores

List of Authorities and Corresponding Duties

Enlisted in schedule V No such List

DIFFERENCES IN DRAFT 2015 AND 1998 BMW (M&H)RULES) CONT….

Page 80: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

ACTIONABLES FOR ALL STAKEHOLDERS

(IF 2015 RULES BECOME EFFECTIVE) HEALTH CARE FACILITIES •  Every occupier generating BMW, irrespective of the quantum of waste generated will come

under the BMW 2015 Rules and requires to obtain authorization to collect, segregate and/ or treat and dispose BMW from SPCB or SPCC unlike earlier(1998 rules) when only Occupiers with more than 1000 patients per month required to obtain authorization. However HCFs with less than 1000 patients per month need it only one time.

•  Categorization of Waste is according to colour code under new (2015) Rules with only one colour option unlike earlier ( 1998)Rule which had ten categories and some categories had multiple options of colour and disposal.So Hospitals may have to add/ modify coloured containers and bags for segregation as :

1.  Yellow Bag (all non plastic , non sharp, soiled incinerable waste),

2.  Red Bag ( all plastic infected waste)

3.  White Translucent Puncture Proof Container( for all metal sharps)

4.  Blue Puncture Proof Container( for infected / broken/ discarded Glass)- New Addition

5.  Yellow Bag with Cytotoxic Label ( for cytotoxic waste)

Hence New/ Modified Posters and Training Modules and Procurement specifications for containers/ Trolleys/ Bags will have to be made

Page 81: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

CONTINUED…. •  Under new Rules “Sharps and Glass” can be stored beyond 48

hours and have been exempted from this time limit of storage unlike earlier rules( 1998)whereany category of BMW could not be stored beyond 48 hours so now the Hospitals can increase the sizes of Containers and reduce the required number and recurring cost for these containers which is very high currently .However Big sized containers for Glass if all Laboratory glassware needs to be given as BMW will be difficult.

•  An Effluent Treatment Plant needs to be installed in the HCF if not existing for treating all Liquid Waste

•  A facility having more than 500 beds can install its own incinerator provided there is no CWTF in the vicinity( exact distance still to be specified)and it is not near any residential accomodation.

•  An Autoclave/ Microwave for treating and A shredder for shredding Plastic Waste before selling it to the recycler needs to be installed in the Hospital if this waste is not being given to CWTFS

Page 82: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

ACTIONABLES FOR CWTF OPERATORS •  Duties of CWTF Operators have been clearly listed in the 2015

rules unlike 1998 rules in which there was no separate mention of their duties.

•  Any noncompliance by them will be considered as an offence and a punit ive action ( could amount to cancellat ion of authorization)can be taken against them by authorities.

•  All Waste Pick up vehicles will now have to be compartmentalized for segregated waste.

•  All incinerators will now need to install pollution control devices including Retro fittings to adhere to pollution control emission standards (detailed)in the new2015 rules.

•  The incinerators will have to comply to emission standards especially for dioxans and furans within two years of commencement of these rules.

•  They will have to tie up with authorized recyclers for plastic and glass waste for resale after treatment and shredding.

Page 83: BioMedical Waste Management & Handling Rules (1998 vs draft 2015) dr sumi

Dr.  SUMI  NANDWANI  PROFESSOR-­‐  cum/or  CHIEF  CONSULTANT,  HOD,  Microbiology,  Sub  -­‐  Dean  Superspeciality  Paediatric  Hospital  and  Post  Graduate  Teaching  Institute,Noida  E  Mail:  [email protected]  

THANK YOU