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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,	
  
SUB-­‐DEAN	
  
SUPERSPECIALITY	
  PAEDIATRIC	
  HOSPITAL	
  AND	
  
POSTGRADUATE	
  TEACHING	
  INSTITUTE,NOIDA	
  
	
  
POINTS TO BE DISCUSSED …………
! Available Guidelines
! BMWM Rules (1998)
! BMWM Rules( Draft 2015)
! Differences
! Challenges
! Actionables
( PROPOSED) THE BIO-MEDICAL WASTE (MANAGEMENT
AND HANDLING) RULES, 2015
WHAT ARE THE AVAILABLE GUIDELINES ?
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
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
Notied	
  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.
APPLICATION : 1998 RULES
APPLICATION : DRAFT 2015 RULES
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
DEFINITIONS:
1998 RULES
DEFINITIONS: DRAFT 2015 RULES
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
DUTIES OF OCCUPIER :1998
RULES
DUTIES OF OCCUPIER : DRAFT 2015 RULES
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
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
DUTIES OF OPERATOR OF
CBMWTFS- DRAFT 2015 RULES
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
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
DUTIES OF AUTHORITIES- DRAFT 2015
RULES
!
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
TREATMENT AND DISPOSAL :
1998 RULES
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
TREATMENT AND DISPOSAL :DRAFT
2015 RULES
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
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.
SEGREGATION , PACKING, TRANSPORT
&STORAGE: 1998 BMW RULES
CATEGORIES OF BMW(1998 RULES)
CATEGORIES OF BIO-MEDICALWASTE(1998 RULES)
Cat
ego
ry
Waste
type
Colour
coding
Treatment & Disposal
1. Human
anatomical
Yellow Incineration / deep burial
2. Animal
waste
Yellow Incineration / deep burial
3 Microbiolog
y &
Biotechnolo
gy 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 /
Microwaving & mutilation/
shredding
5 Discarded
medicines
and
Cytotoxic
drugs
Black Destruction/ neutralization &
disposal in secured landfills
Cate
gory
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 Incinerat
ion Ash
Black Disposal in municipal landfill
10 Chemica
l
Black Chemical treatment and
discharge into drains for liquids
and secured landfill for solids
SEGREGATION OF HCW BEING FOLLOWED CURRENTLY
AT HOSPITALS
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.	
  	
  
STORAGE
•  In	
  an	
  area	
  away	
  from	
  general	
  
trac	
  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	
  	
  
CATEGORIES OF BMW(DRAFT 2015 RULES)
CATEGORIES OF BMW (DRAFT 2015 RULES) CONT..
CATEGORIES OF BMW (DRAFT 2015 RULES)
SCHEDULE I CONT..
SEGREGATION , PACKING, TRANSPORT
&STORAGE: DRAFT 2015 BMW RULES
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
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
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
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
LABELS
1998 RULES 2015 DRAFT RULES
LABEL FOR RADIOACTIVE WASTE
( NOT A PART OF BMWM RULES)
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
PRESCRIBED AUTHORITY (1998 RULES)
PRESCRIBED AUTHORITY (DRAFT
2015 RULES)
AUTHORIZATION (1998 RULES)
AUTHORIZATION (DRAFT 2015 RULES)
DIFFERENCES :
(AUTHORIZATION)1998 RULES VS
DRAFT 2015 RULES
ADVISORY COMMITTEE(1998
BMW RULES)
ADVISORY COMMITTEE(DRAFT
2015 BMW RULES)
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
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
ANNUAL REPORT, RECORD
MAINTENANCE &ACCIDENT REPORTNG
(1998 RULES)
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	
  
rst	
  week	
  of	
  next	
  month	
  
Maintenance of Records
•  Maintain	
  records	
  related	
  to	
  BMW.	
  
•  All	
   records	
   shall	
   be	
   subjected	
   to	
  
inspection	
   and	
   verication	
   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%%
% % % % % %
% % % % % %
% % % % % %
% % % % % %
%
ANNUAL REPORT, RECORD
MAINTENANCE &ACCIDENT REPORTNG
(DRAFT 2015 RULES)
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
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
APPEAL, SITE FOR CWTFS,LIABILITY
OF OCCUPIER/ OPERATOR (1998
BMW RULES)
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
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 .
STANDARDS OF INCINERATORS(1998 RULES)
STANDARDS OF INCINERATOR
DRAFT 2015 RULES
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
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
STANDARDS FOR AUTOCLAVING
(1998 RULES)
STANDARDS FOR AUTOCLAVING
(DRAFT 2015 RULES)
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
STANDARDS FOR LIQUID WASTE,
DRAFT 2015 1998 RULES
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
STANDARDS FOR DEEP BURIAL
DRAFT 2015 VS 1998 RULES
SCHEDULE V LIST OF AUTHORITIES & DUTIES ( DRAFT
2015 RULES)
DIFFERENCES IN DRAFT 2015 AND 1998 BMW
(M&H)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/microwa
ving &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….
!
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….
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….
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
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
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 punitive action ( could amount to cancellation 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.
Dr.	
  SUMI	
  NANDWANI	
  
PROFESSOR-­‐	
  cum/or	
  CHIEF	
  CONSULTANT,	
  
HOD,	
  Microbiology,	
  
Sub	
  -­‐	
  Dean	
  
Superspeciality	
  Paediatric	
  Hospital	
  and	
  Post	
  
Graduate	
  Teaching	
  Institute,Noida	
  
E	
  Mail:	
  suminandwani@gmail.com	
  
THANK YOU

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

  • 1. 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    
  • 2. POINTS TO BE DISCUSSED ………… ! Available Guidelines ! BMWM Rules (1998) ! BMWM Rules( Draft 2015) ! Differences ! Challenges ! Actionables
  • 3. ( PROPOSED) THE BIO-MEDICAL WASTE (MANAGEMENT AND HANDLING) RULES, 2015 WHAT ARE THE AVAILABLE GUIDELINES ?
  • 4. 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
  • 5. 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 Notied  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.
  • 7. APPLICATION : DRAFT 2015 RULES
  • 8. 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
  • 11. 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
  • 12. DUTIES OF OCCUPIER :1998 RULES
  • 13. DUTIES OF OCCUPIER : DRAFT 2015 RULES
  • 14. 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
  • 15. 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
  • 16. DUTIES OF OPERATOR OF CBMWTFS- DRAFT 2015 RULES
  • 17. 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
  • 18. 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
  • 19. DUTIES OF AUTHORITIES- DRAFT 2015 RULES
  • 20.
  • 21. ! 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
  • 22. TREATMENT AND DISPOSAL : 1998 RULES
  • 23. 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
  • 24. TREATMENT AND DISPOSAL :DRAFT 2015 RULES
  • 25. 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
  • 26. 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.
  • 27. SEGREGATION , PACKING, TRANSPORT &STORAGE: 1998 BMW RULES
  • 29.
  • 30. CATEGORIES OF BIO-MEDICALWASTE(1998 RULES) Cat ego ry Waste type Colour coding Treatment & Disposal 1. Human anatomical Yellow Incineration / deep burial 2. Animal waste Yellow Incineration / deep burial 3 Microbiolog y & Biotechnolo gy 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 / Microwaving & mutilation/ shredding 5 Discarded medicines and Cytotoxic drugs Black Destruction/ neutralization & disposal in secured landfills
  • 31. Cate gory 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 Incinerat ion Ash Black Disposal in municipal landfill 10 Chemica l Black Chemical treatment and discharge into drains for liquids and secured landfill for solids
  • 32. SEGREGATION OF HCW BEING FOLLOWED CURRENTLY AT HOSPITALS
  • 33. 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.    
  • 34. STORAGE •  In  an  area  away  from  general   trac  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    
  • 35. CATEGORIES OF BMW(DRAFT 2015 RULES)
  • 36. CATEGORIES OF BMW (DRAFT 2015 RULES) CONT..
  • 37. CATEGORIES OF BMW (DRAFT 2015 RULES) SCHEDULE I CONT..
  • 38. SEGREGATION , PACKING, TRANSPORT &STORAGE: DRAFT 2015 BMW RULES
  • 39. 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
  • 40. 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
  • 41. 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
  • 42. 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
  • 43. LABELS 1998 RULES 2015 DRAFT RULES LABEL FOR RADIOACTIVE WASTE ( NOT A PART OF BMWM RULES)
  • 44. 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
  • 52.
  • 53. 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
  • 54. 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
  • 55. ANNUAL REPORT, RECORD MAINTENANCE &ACCIDENT REPORTNG (1998 RULES)
  • 56. 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   rst  week  of  next  month  
  • 57. Maintenance of Records •  Maintain  records  related  to  BMW.   •  All   records   shall   be   subjected   to   inspection   and   verication   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%% % % % % % % % % % % % % % % % % % % % % % % % % %
  • 58. ANNUAL REPORT, RECORD MAINTENANCE &ACCIDENT REPORTNG (DRAFT 2015 RULES)
  • 59. 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
  • 60. 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
  • 61. APPEAL, SITE FOR CWTFS,LIABILITY OF OCCUPIER/ OPERATOR (1998 BMW RULES)
  • 62.
  • 63. 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
  • 64. 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 .
  • 67. 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
  • 68. 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
  • 71. 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
  • 72. STANDARDS FOR LIQUID WASTE, DRAFT 2015 1998 RULES
  • 73. 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
  • 74. STANDARDS FOR DEEP BURIAL DRAFT 2015 VS 1998 RULES
  • 75. SCHEDULE V LIST OF AUTHORITIES & DUTIES ( DRAFT 2015 RULES)
  • 76. DIFFERENCES IN DRAFT 2015 AND 1998 BMW (M&H)RULES)
  • 77. 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/microwa ving &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….
  • 78. ! 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….
  • 79. 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….
  • 80. 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
  • 81. 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
  • 82. 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 punitive action ( could amount to cancellation 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.
  • 83. Dr.  SUMI  NANDWANI   PROFESSOR-­‐  cum/or  CHIEF  CONSULTANT,   HOD,  Microbiology,   Sub  -­‐  Dean   Superspeciality  Paediatric  Hospital  and  Post   Graduate  Teaching  Institute,Noida   E  Mail:  suminandwani@gmail.com   THANK YOU