Managing Hazardous Wastes

Consultant Report: Bangladesh: Managing Hazardous Waste - Final ReportTechnical Assistance Consultant’s Report
This consultant’s report does not necessarily reflect the views of ADB or the Government concerned, and ADB and the Government cannot be held liable for its contents.
Final Report Project Number: 38401 December 2010
Managing Hazardous Wastes (Financed by the Asian Development Bank Technical Assistance Funding Program)
Prepared by Dr. David W.J. Green
Hong Kong, China
ABBREVIATIONS
ADB – Asian Development Bank BBIN – Bangladesh, Bhutan, India, and Nepal CPCB Central Pollution Control Board DMC – developing member country DOE – Department of Environment GOD Government of Denmark HCRW Health Care Risk Waste HM Hazardous raw materials / chemicals HW Hazardous Waste HWM Hazardous Waste Management HWM
rules 2008 Hazardous Waste (Management, Handling and Transboundary
Movement) Rules, 2008 (India) MOEF – Ministry of Environment and Forest (India) MOE Ministry of Environment (previously MOEST (Nepal) MOH Ministry of Health (Nepal) MOSTE – Ministry of Science, Technology, and Environment (Bangladesh) NEC National Environment Commission (Bhutan) NEP National Environment Policy, 2006 (India) POP – persistent organic pollutant PPC Pollution Control Committee PPP – Public-private partnership RCSP – regional cooperation strategy and program RETA – regional technical assistance SASEC – South Asia Subregional Economic Cooperation SPCB State Pollution Control Board TSDF Treatment, storage and disposal facilities UNEP – United Nations Environment Programme
NOTE In this report “$” refers to US dollars
Units of Measurement
Kg – Kilogram tonne(s) – 1000kg also known as metric tonne or M/T m3 – cubic meter
Contents Page
EXECUTIVE SUMMARY iv I. INTRODUCTION 1
A. Overview 1 B. Key Activities 3 C. Implementation Arrangements 5 D. Report Structure 5
II. HAZARDOUS WASTE MANAGEMENT IN NEPAL 5 A. Nepal Overview 5 B. Inventory of Hazardous Waste in Nepal 8 C. Development of Policy on Hazardous Waste Management in Nepal 9 D. Development of Guidelines for Hazardous Waste Management in Nepal 12
III. HAZARDOUS WASTE MANAGEMENT IN BHUTAN 13 A. Bhutan Overview 13 B. Inventory of Hazardous Waste in Bhutan 16 C. Development of Policy on Hazardous Waste Management in Bhutan 17 D. Development of Guidelines for Hazardous Waste Management in Bhutan 19
IV. HAZARDOUS WASTE MANAGEMENT IN BANGLADESH 20 A. Bangladesh Overview 20 B. Inventory of Hazardous Waste in Bangladesh 21 C. Development of Policy on Hazardous Waste Management in Bangladesh 23 D. Development of Rules for Hazardous Waste Management in Bangladesh 24
V. HAZARDOUS WASTE MANAGEMENT IN INDIA 24 A. India Overview 24 B. Inventories of Hazardous Waste in India 25 C. Current Practices for Recovery, Reuse, Recycling and Disposal 27 D. Policy and Strategy on Hazardous Waste Management in India 27 E. Revised Regulation for Hazardous Waste Management in India 28 F. Workshops for Disseminating Revised Regulations 28 G. Training Modules and Manual for Updating Inventories for HW in India 29
VI. OUTCOMES OF THE TECHNICAL ASSISTANCE 29 A. Outcome in Response to Design Framework Outputs 29
VII. RECOMMENDATIONS AND NEXT STEPS 31 A. Bangladesh 31 B. Bhutan 31 C. Nepal 31 D. India 32 E. Further Workshops and Training 33 F. Regional Future Steps 33
VIII. CONCLUSIONS 36
IX. Appendixes
1. Design and Monitoring Framework 38 2. Status of India’s sites for Treatment Storage and Disposal Facilities 40
Supplementary Appendixes (available upon request)
A. Nepal Hazardous Wastes Inventory Report B. Nepal Hazardous Wastes Policy Report C. Nepal Draft Guidelines D. Bhutan Hazardous Wastes Inventory Report E. Bhutan Hazardous Wastes Policy Report F. Bhutan Draft Guidelines G. Bangladesh Hazardous Wastes Inventory Report H. Bangladesh Hazardous Wastes Policy Report I. Bangladesh Rules J. India Final Report K. India National Rules on Hazardous Wastes
EXECUTIVE SUMMARY 1. Regional technical assistance (RETA) on Managing Hazardous Wastes (ADB TA 6361- REG) in Bangladesh, Bhutan, Nepal and India, was completed in 2009. The concept was originally developed by the Environmental Working Group of South Asia Subregional Economic Cooperation. The program for the RETA was in two stages. Inventories for Bangladesh, Bhutan, and Nepal; and revising the regulations for India were carried out in stage 1. The second stage focused on drafting of policy frameworks, rules and guidelines for Bangladesh, Bhutan, and Nepal and developing training modules for the revising of inventories for India. The Inception Phase of Stage 1 commenced September 2007. The Midterm Review was in July 2008. The national consultants for Bangladesh, Bhutan, India, and Nepal all presented their final reports in 2009. The inventory reports were printed for Bangladesh, Bhutan, and Nepal in 2010. The review of hazardous wastes management regulation and preparation of training module on inventory of hazardous wastes for India was printed in December 2010. 2. In many developing countries, including Bangladesh, Bhutan, India, and Nepal, the negative impacts of increased economic activity on the environment are associated with industry, agriculture, health services, and other service sectors that generate chemical and hazardous wastes. If left unmanaged these impacts lead to serious environmental problems that threaten public health and economic sustainability. 3. The objectives of the RETA included: (i) assisting the RETA governments conduct inventories of hazardous wastes, (ii) drafting policies, rules, and technical guidelines to manage hazardous wastes, (iii) assisting the Government of India to review the current regulations, (iv) developing a training module for inventory of hazardous wastes, and (v) exploring involvement of private sector in hazardous wastes management. The RETA was also expected assist member countries to harmonize their rules and policies to enable exchange of wastes for treatment or recycling. 4. In Bangladesh, pollution associated with industrial activities has been identified as a major environmental concern. Many rivers are severely polluted. Hazardous and non-hazardous wastes from industrial activities are increasing and are disposed into the environment without controls. During the course of the RETA, Bangladesh has compiled inventories in key sectors and developed draft policy and strategy and rules have been drafted. Practical guidelines for hazardous waste management are in development. 5. In Bhutan, problems associated with hazardous waste are emerging slowly. During the course of the RETA, significant steps (including new laws, a draft policy framework and draft guidelines for two key problem waste streams) have been taken towards better hazardous waste management. 6. In Nepal, the environment is under great stress, especially in and around the growing urban centers. During the course of the RETA, Nepal has compiled and published inventories in key sectors and developed draft policy that covers proposals for hazardous waste registration, segregation, collection, transportation, and disposal. Significant progress has also been made with draft guidelines to avoid significant threats to the environment and public health. 7. India’s comprehensive regulatory and institutional framework required updating to respond to increasing industrial activities. During the course of the RETA, India has revised the Rules with emphasis on recycle, reuse and recovery, conducted awareness workshops, and
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drafted a National Hazardous Waste Management Strategy. India also developed a training manual on inventory of hazardous wastes, which will be useful to other countries. 8. The RETA has consolidated the awareness and developed the mechanisms for hazardous waste management in each individual country and provides a solid platform for future work. The RETA has fostered cooperation and knowledge sharing on hazardous wastes and initiated a mechanism for information sharing, including the training manual. 9. The RETA has supported governments in Bangladesh, Bhutan, and Nepal to draft and progress the enactment of policies, rules, and technical guidelines to manage hazardous wastes based on the results of inventories. 10. The RETA has been the catalyst for the member countries to progress towards formulating harmonized rules and policies to enable them in the future to exchange recyclable wastes for treatment in one or other of the member countries. 11. The next steps in hazardous waste management for the region are open for discussion. This may be at a regional, bilateral or national level. Participating countries have expressed keen interests in further workshops and meetings to share future developments and exchange experience.
I. INTRODUCTION
A. Overview
1. This is the Final Report of the Regional technical assistance (RETA) on Managing Hazardous Wastes (ADB TA 6361-REG) project funded by the Asian Development Bank (ADB) undertaken by national consultants in Bangladesh, Bhutan, Nepal and India with support and guidance from the international consultant. The RETA was approved on 12 December 2006 and completed in December 2010. 2. The concept of regional technical assistance (RETA) for Managing Hazardous Wastes1 was originally developed by the Environmental Working Group of South Asia Subregional Economic Cooperation (SASEC) at its special meeting in 2002, and endorsed at the Country Advisors Meeting in 2005. The proposed RETA was included in the regional cooperation strategy and program (RCSP) for 2006–2008.2
3. In many developing countries, including Bhutan, Bangladesh, Nepal, and India, increased economic activity is having negative impacts on the environment. Activities associated with industry, agriculture, health services, and other service sectors generate chemical and hazardous wastes, which if left unmanaged, can lead to serious environmental problems that threaten public health and endanger economic sustainability. 4. The objectives of the RETA included: (i) assisting the governments of Bangladesh, Bhutan, and Nepal to conduct inventories of hazardous wastes; (ii) drafting policies, rules, and technical guidelines to manage hazardous wastes based on the results of inventories; (iii) assisting the Government of India to review the current hazardous waste regulations; (iv) developing a training module for updating the inventory of hazardous wastes; and (v) exploring potential involvement of private sector in managing hazardous wastes. It was also expected that the RETA would be able to assist the member countries to formulate harmonized rules and policies to enable them in the future to exchange wastes for treatment in one or other of the member countries, or to treat hazardous wastes in their common treatment plants. 5. Prior to the RETA the problems associated with the management of waste, especially hazardous waste, were different in the four RETA member countries. The governments had taken steps to minimize pollution associated with chemical and hazardous wastes, not only at the country level, but also internationally, as parties of the parties of the Rotterdam Convention on the Prior Informed Consent Procedure for Certain Hazardous Chemicals and Pesticides in International Trade, Basel Convention on the Control of Transboundary Movement of Hazardous Wastes and Their Disposal and the Stockholm Convention on Persistent Organic Pollutants3
. As parties of these conventions, Bhutan, Nepal, and Bangladesh had benefited from training and seminars. In addition, Bhutan was able to export obsolete pesticides to Switzerland for treatment and safe disposal. However, while these conventions extend invaluable assistance to their parties, they also impose strict obligations. Such obligations include undertaking real efforts at the country level to handle chemical and hazardous wastes prior to ratification. The goal of the RETA was to combine their efforts to reduce pollution associated with chemical and hazardous wastes.
1 The RETA first appeared in ADB Business Opportunities on 10 August 2006. 2 ADB. South Asia Regional Cooperation Strategy and Program (2006–2008). Manila.. 3 Out of the four RETA member countries, only India has ratified these three international conventions.
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6. The five main steps in managing hazardous wastes at the national level 4
are (i) identifying the problems, (ii) designating a lead agency, (iii) promulgating rules and regulations, (iv) developing treatment and disposal facilities, and (v) creating compliance and enforcement programs. The approach to the RETA clearly identified that each of the RETA member countries required different levels of intervention to institutionalize the management of hazardous wastes. Bhutan needed to (i) complete a national inventory of the types and quantities of hazardous wastes, (ii) draft policy to cover the institutional and regulatory framework to manage hazardous wastes, (iii) develop appropriate technical guidelines for hazardous waste management, and (iv) develop a mechanism for institutional strengthening and capacity development. Bangladesh and Nepal needed to (i) update their hazardous waste inventories as a basis for promulgating rules and regulations; and (ii) develop technical guidelines on handling, treating, transporting, and disposing hazardous wastes as a basis to identify the potential amount and type of wastes that need special treatment and disposal facilities. Meanwhile, India needed to (i) review the capacity of its hazardous waste treatment facilities, including facilities involving public-private partnerships; (ii) review the existing institutional and regulatory framework to create effective compliance programs by taking into account that some hazardous wastes have economic value; and (iii) build capacity by organizing training.
7. In Bhutan, where the environment is still largely intact and pristine, problems associated with hazardous waste are emerging slowly but steadily.5
Bhutan is still in the preliminary stage with regard to hazardous waste management. A proper system for hazardous waste registration, segregation, collection, transportation, and disposal needs to be put in place in order to avoid significant threats to the environment and public health. Some sectoral studies had been carried out to assess the improper management of hazardous wastes but Bhutan had not established institutional and legal frameworks to effectively address the problem. During the course of the RETA significant steps (including new laws, a draft policy framework and draft guidelines for two key problem waste streams) have been taken towards better hazardous waste management.
8. In Nepal, the environment is under great stress, especially in and around the growing urban centres. Several studies and workshops on managing hazardous wastes had been carried out, prior to the RETA, and the key hazardous, polluting industries and activities had been identified;6
however, there were no detailed inventories of hazardous waste of all key sectors. During the course of the RETA, Nepal has compiled and published inventories in key sectors and developed draft policy that covers proposals for hazardous waste registration, segregation, collection, transportation, and disposal. Significant progress has been made with draft guidelines for two major waste streams and control measures to avoid significant threats to the environment and public health have been identified.
9. In Bangladesh, pollution associated with industrial activities has been identified as a major environmental concern.7
Many rivers are severely polluted, and hazardous and other wastes from industrial activities are increasing and are disposed into the environment without controls. The Bangladesh Environmental Conservation Act and Rules put in place measures to address pollution problems. During the course of the RETA Bangladesh has compiled inventories in key sectors and developed draft policy and strategy and rules have been drafted. Practical guidelines for the management of hazardous waste are in development.
4 Center for Risk Management. 1999. The Evolution of Hazardous Waste Programs: Lessons from Eight Countries.
Washington, DC. 5 National Environment Commission, 1999. Environmental Assessment of Existing Industry in Bhutan. Bhutan. 6 Ministry of Population and Environment. 2004. Initial Inventory of Hazardous and Toxic Wastes. Nepal. 7 United Nations Environment Programme. 2001. State of the Environment.
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10. India has a comprehensive regulatory and institutional framework, as well as technical guidelines to handle various types of hazardous wastes. However, increasing industrial activities have brought about significant challenges in hazardous waste disposal, requiring revisions to the existing system. During the course of the RETA India has revised the Rules with emphasis on recycle, reuse and recovery, conducted workshops to inform industry of the changes and drafted a National Hazardous Waste Management Strategy. A training manual on inventory of hazardous waste was prepared and training was given to the officials of the Central Pollution Control Board (CPCB) and State Pollution Control Boards (SPCBs) and Pollution Control Committees (PCCs). B. Key Activities
11. Considering the range of issues, problems, degrees of effort, and the immediate needs for managing hazardous wastes, the RETA was designed to serve as a basis for strengthening cooperation among the four countries through the sharing of knowledge and also through the identification of ways to use common facilities for safely treating, transporting, and disposing hazardous wastes. It was envisaged that Bhutan, Bangladesh, and Nepal would benefit from India’s lessons in regulating the management of hazardous wastes and that ultimately these four countries should have compatible rules and guidelines on managing hazardous wastes. It was anticipated that in terms of using common facilities, that the steps that India had already taken, to explore the participation of the private sector in facilitating the disposal of hazardous wastes, would be advantageous and that by India knowing which hazardous wastes are potentially being generated by its neighboring countries future investment in common treatment facilities for hazardous wastes could be planned and streamlined with a regional rather than a local focus. The concept of public private partnership for setting up of common TSDF for hazardous waste was shared with the other countries based on the experience gained by India and the activities developed under this RETA are therefore consistent with the program and objectives of the regional cooperation strategy and program (RCSP 2006–08). 12. The RETA was approved in 2006, after fact-finding missions were carried out in 2005 in Bhutan and Nepal and in early 2006 in Bangladesh and India, to reach agreement with the governments on the impact, outcome, outputs, implementation arrangements, cost, financing arrangements, and outline terms of reference of the RETA. The approved design and monitoring framework is presented in Appendix 1. 13. The program for the RETA was divided into two main stages. The first stage focused on inventories for Bangladesh, Bhutan, and Nepal; and revising the regulations for India. The second stage focused on drafting of policy frameworks, rules and guidelines for Bangladesh, Bhutan, and Nepal and developing training modules for the revising of inventories for India. At the request of the governments of Bangladesh, Bhutan, and Nepal the resources applied to the inventories were increased due mainly to the additional time resources needed to complete the inventories and workshops. At the request of the Government of India the resources applied to the workshops on training activities for India were increased in response to greater need. All RETA governments requested that consultants from the same companies that conducted inventories should be retained for drafting policy and guidelines. In India the public-private partnership (PPP) consultant was not retained. The planned review of PPP for HWM was postponed as this sector was already well developed. 14. The Inception Phase of Stage 1 commenced September 2007, delayed due to difficulties in identifying national consultants suitable for the assignment. The Inception Phase included the workshop held in Bangkok (30 October–2 November 2007) to allow study of Thailand’s relatively well established national system for managing hazardous wastes firsthand and permit
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relatively easier travel from all four RETA countries than to ADB Headquarters in Manila. The objectives of the inception workshop were (i) to review the consultants’ work-plans and progress, (ii) to identify future milestones and targets to be achieved, and (iii) to learn from each other in designing the work plans and also from Government of Thailand as well as from the Basel Secretariat for South East Asia on the inventory and management of hazardous wastes. Study sessions and field activities were also organized to visit active hazardous waste management facilities in and around Bangkok.8
15. The Midterm Review Workshop was rescheduled to accommodate the commitments of all the consultants and counterparties and was held in Bangkok on 17–18 July 2008. The workshop established clear goals for the progress of the RETA under the guidance of the Principal Regional Cooperation Specialist and the Project Officer, Senior Environment Specialist, SATC. There were several sessions. These included sessions from each participating country. India’s progress with (i) re-visiting of hazardous waste rules 2008 (ii) drafting hazardous waste management strategy (iii) preparing a framework for the training module (iv) conducting a training programme for the CPCB/SPCBs/PCC and (v) conducting a workshop on the provision of the new hazardous waste rules, 2008. The progress of the inventories by Bhutan, Bangladesh and Nepal was summarized by reviewing the work of the consultants, including (i) sectors chosen for the inventor…