Can you believe it? The waste management sector in not officially recognized as an Industry by the government of India! As astonishing as this sounds, it is also alarming, specially for a country that desperately needs private sector participation to workable provide solutions along with much needed investment. The Swachh Bharat Abhiyan has mostly focused on building toilets to counter the challenge of open defecation in cities and villages. Waste Management under the Swachh Bharat Abhiyan has been dismal failure of mega propositions. Besides photo opts and some localized cluster success stories that are far from scalable, the program has not been able to achieve the intent that it was created for. Changing the minds of Individuals and cleaning the towns and cities of India.

As a private organization working in the field of waste management for the last decade, we have faced an uphill battle trying to get simple permissions to collect, transport, segregate and dispose municipal solid waste. This after the government itself has mandated in MSW rules 2016 that the private sector, ragpickers and the unorganized sector must be encouraged to partake and help rid the country of monumental crisis that it is staring at. No industry status means the sector is always looked upon from a social angle, there is little or no interest shown by private or public-sector banks to fund projects in this field and the sector as a whole has no voice when it comes to voicing its concerns or demands. 

Try going to any government municipal body and ask for the following: 

1.     Permission to collect non-hazardous waste 

2.     Permission to dispose non-hazardous waste at the authorized dump site 

3.     Permission to set up a dry waste collection and sorting center for recyclables 

The answers range from, it cannot be given too we have already contracted the entire cities garbage contract to a private company, if we give it to you we will have to give It to everyone, and finally the golden question, what will we get in return? 

What we are proposing: 

1.     Provide permissions to private players small and large to 

a.     Collect municipal waste 

b.     Set up waste segregation and stocking facilities 

c.     Tip waste at authorized government sites and pay the government a tipping fee 

d.      Bring about changes in the MSW rules(Attached Document with Suggestions) 

e.      Permissions to collect non-hazardous, industrial and commercial waste

Not only will these steps help in promoting the sector as whole, it will also bring in much needed competition which in term will lead to setting of best practices and additional generation of revenue for the government. Privatization of waste collection, transportation, segregation/storage facilities is key to insuring a thriving waste management sector. Numerous other benefits can be derived by allowing easy access to private companies or individuals to start operating in this sector: Some of these benefits are:

1.     Create Employment: With lacs of young individuals flooding the market every year, the waste management industry if allowed to thrive will act as a sponge to provide much needed avenues for these individuals to apply them selves 

2.     Add to the GDP of our country. According to an independent study done by us, the waste management industry as off now stands organized and unorganized stands at about $45 billion in India. This includes Municipal waste, hazardous waste, E-waste and the recycling industry. This figure does not account other support industries such as truck and equipment manufacturing, IT, petroleum and many others that will directly benefit for this growth. 

3.     Added revenues for the government and in terms of fines and tipping fee, along with reduction in collection, transportation costs as local companies will be able to do the same tasks more efficiently.

4.     Provide the private bulk waste generators an option to select the best possible vendor at the lowest price to meet their waste management needs, where by reducing their costs.

5.     Help create a data base of what types of waste is being generated from industries, commercial establishments, residential establishments across the country. Data is the key to making the best possible decisions in terms of changing tactics, utilizing the correct technology and predicting the future generation of waste with educated estimates.

A full policy change document has been attached along with article that we have submitted to various state governments. 

The Below Policy Note is protected by the Copyright Act, 1957 and all rights in respect of the same are reserved by Mr. Manik Thapar (the “Author”). The reader of this Policy Note shall not copy, reproduce, distribute, publish, republish, download, display, post or transmit in any form or by any means (“Use” or “Used”), without the prior written consent of the Author. ”

Concept Note: Authorization for Waste Collection, Transportation, Storage,  Segregation & Disposal

The ministry of forest and environment recently updated and formulated MSW rules 2016, outlining the responsibilities of municipal authorities, waste generators, bulk waste generators, waste collectors and the role and inclusion of rag pickers in the process of waste collection and disposal. The guide lines are mandatory and are to be followed by all municipal authorities on a national basis.

The purpose of this document is to bring about policy change, so that private companies large and small wanting to enter the waste, collection, transportation, segregation, treatment and disposal business are provided with clarity on regulations and permissions required in order for them to enter this sector. With rapid urbanization, increase in earnings and consumption, generation of waste is an ever-growing concern. As of now there is no policy to include private participation in this sector, other than the tendering route, which caters only to large companies and requires mega investments. There lies a huge opportunity to regulate and open up the waste collection, transportation, segregation, treatment and disposal business to private enterprise. 

MSW Rules 2016 mention and dictate local authorities and municipal corporations to involve the private sector along with the informal sector in the entire process of managing waste, specifically in collection, segregation and resource recovery. Yet, there is no clarity on policy available to private organizations wanting to invest in the collection, segregation, treatment and disposal side of the business as a whole or individually. There is dire need of investment in the waste management sector, and private companies and the informal sector should be tapped not only for investment purpose, but also for their knowledge and expertise in the field of waste collection resource recovery and treatment. Further the concerned state governments can generate tremendous revenue from charging tipping fees to private companies or individuals who use government owned and operated landfill sites for the purpose of waste disposal. 

Globally, waste management as a sector has been given Industry status, but here in India, the sector still does not have any official recognition nor is it considered an industry. As a result, it becomes tough for the few organized, and vast number of unorganized players to get financing through banks, for regulators to regulate the sector due to no clear policy. In most developed and some developing nations, waste management is as a sector is completely privatized and monitored through tough regulations. In all of these countries, the government and local authorities have understood that a handful of companies cannot manage the waste of the entire country, they need small and large players to partake in different parts of the waste management process, from collection, segregation, treatment and final disposal. Guided by a strong policy and enforcement mechanism and the understanding that competition is good for the industry, these countries have been able to not only manage their waste effectively, but also create a booming industry that employee’s lacs of people and supports the growth of other supporting industries, such as truck manufacturing, equipment manufacturing, IT services and host of other small and large businesses that provide support to this sector. 

Details of Policy Intervention needed: MSW rules 2016 provide a guide line to central and state pollution control boards, along with providing instructions with defined time lines to local authorities and municipalities. The rules apply to every local body, outgrowths in urban agglomerations, census towns as declared by the registrar general and census commissioner of India, notified areas, notified industrial townships, areas under the control of Indian Railways, airports ports and harbors, defense establishments, special economic zones, state and central government establishments, place of pilgrims, religious and historical importance as may be notified by respective state government from time to time and to every domestic, institutional, commercial and any other nonresidential solid waste generator situated in the areas except industrial waste, hazardous waste, hazardous chemicals, bio medical waste, e-waste. Lead acid batteries, and radioactive waste, that are covered under separate rules framed under the environment protection act of 1986. 

Workings: The suggestions made in the following document can be implemented in the current system, to increase efficiencies, promote private investment and competition within the prevailing waste management system. Currently there are many cities in the state of Uttar Pradesh that have either tendered the waste collection system to private enterprises or are looking to tender the waste collection, transportation, segregation, treatment and disposal system as a whole or in parts to private companies. As you may be aware the current system in place is unable to cope with the tremendous amounts of waste that is being generated, in urban areas and the challenge will spread to rural areas sooner than later. The current process leaves a lot of room for SME’s and the unorganized sector to actively partake in managing waste, weather through collection, material recovery, treatment or disposal, while providing the local bodies with much needed revenue in terms of disposal fees charged to these private companies. 

The system suggested will not interfere with the current process, as there will be no liability no contractual liability on the government to provide work to such entities. Through structured policies the government will only provide permissions to these entities to enter specific or all aspects of the waste management business, based on pre-determined criteria’s that must be met before granting of permissions to such entities. Households, commercial and industrial establishments who require specialized services or have specific needs that are not being met by the specified government contractor will have options to hire a private contractor to undertake such jobs. This will not only provide much needed boost to the sector by giving it industry status, but will also insure that best practices are implemented at a micro and macro level.  

Policy intervention as per MSW rules 2016: 

Point 4 – Duties of waste generator – (1) Every Waste Generator Shall-

Sub point (a) – sub point (a) states the following: segregate and store the waste generated by them in three separate streams, namely, bio-degradable, non-biodegradable and domestic hazardous waste in suitable bins and handover segregated wastes to authorized waste pickers or waste collectors as per the direction or notification by the local authorities from time to time

The point above clearly mentions that the waste must be handed over to the authorized waste picker or waste collector, but there is no policy in place for private companies, waste pickers or the unauthorized vendors to apply for such permissions. Most authorities and municipalities are clueless about how authorization can be given and in absence of proper clarity simply refuse to provide such permissions. The business of collection, transportation, open segregation and dumping continues in all cities in India and a major reason for this is the lack of participation from private players in absence of a clear policy mandate. The government needs to urgently take the following steps in order to facilitate the inclusion of the unorganized sector and to attract investment in the sector from private enterprises looking to invest in certain or all parts of the waste management eco system: 

1.    Promote private participation in collection, transportation, segregation, treatment, and disposal of municipal solid waste. 

a.    Collection of MSW: Private companies should be allowed to collect waste from industries, commercial establishments and residential establishments based on the following criteria’s:

      i.     Collection must be done in trucks or vehicles that are equipped to be covered and by only those vehicles that can be registered with the local RTO. 

      ii.     The local authority or municipal authority will not be liable to pay the private agency undertaking such activity, and the private agency must charge the generator of waste a fee it so deems fit.

     iii.     The private collection agency must register itself with the local authority/municipal corporation and the state pollution control office of the region for the purpose of verification and validity of the said organization or person.

     iv.     The local state pollution control board, in conjunction with the local authority/municipality can levy fines and cancel the registration of private companies and individuals who do not abide by the rules along with imposing fines for non-adherence of rules. 

      v.     Workers involved in the process of collection should be insured under ESI/PF or through private insurance. Third party insurance must be made mandatory so that any damage to public or private property is covered to up to a minimum of  

b.    Transportation: Private companies and individuals should be allowed to transport the collected waste to either a MRF for segregation, composting unit, waste to energy unit, bio gasification unit or to the local landfill/dump site for disposal purposes depending on the type of waste collected and transported. The following criteria should be applied to private companies or individuals looking to transport waste:

      i.     Waste must be transported in a manner so that it is not visible to the public

      ii.     Waste must be covered in a manner that it does not fly off or drop from the truck during the transportation process.

      iii.     The collector and transporter must ensure that all waste that is recyclable is segregated and sent to associated recycling units and all waste that is bio degradable is sent to the composting, bio gasification or waste to energy plants. If the said vendor does not have processing unit of his own, he must be liable to pay the operator of such a unit a fee as deemed necessary by the operator of such a unit. This fee must be based on a per ton/per kilogram basis.

       iv.     Only waste that has no value and cannot be recycled, up-cycled or converted to useful forms should be disposed of in the landfill site. 

       v.     All waste disposed at the government landfill site must be weighed and the local authority must be paid in accordance to the rates decided by them on a per ton/per kilogram basis.

      vi.     Vehicles transporting waste must have all valid permits to ply on the road. List of these vehicles must be provided to the concerned authorities, including the concerned local pollution control office and local authority and municipality to ensure that only these vehicles are used for the purpose of collection or transportation of waste to the concerned sites. It is also imperative that only those vehicles registered with the competent authorities be allowed to enter and tip their waste at the landfill or dump site. This will insure that no illegal dumping takes place at the concerned site by individuals or companies that are not authorized to do so. 

c.    Segregation: Private companies and or individuals must be allowed to segregate the waste to recover valuable recyclables to minimize the amount of waste ending up in landfills. The following criteria must be followed to insure safe and secure recovery of recyclables: 

      i.     The private agency or individual must undertake the activity of waste segregation in an enclosed compound that is covered and has cemented flooring. 

      ii.     All waste that is segregated for the purpose of further reprocessing must be sent to authorized recyclers of the said product.

      iii.     In case of manual segregation of waste, special care must be given to the health and wellbeing of the employees evolved. The MRF can and should also be allowed to except waste from outside vendors. In this case collection and transportations is done by third party vendors and the operator of the MRF procures this waste at a given rate from the collector. Site such as these can and should be promoted for decentralized sorting of MSW from homes, industries and commercial establishments.

      iv.     Dumping of recyclables and mix garbage in open fields or open ware houses on bare ground should be prohibited, as it not only promotes unhealthy waste segregation practices, but also encourages the concept of open dumping.

     v.     Only waste that cannot be recycled or treated should be dumped at the authorized landfill or dump site. The vendor must pay the concerned authorities a tipping fee as determined by the operator of the landfill/dump site. 

Sub point (c) Store separately construction and demolition waste, as and when generated, in his own premises and shall dispose off as per the construction and demolition waste management rules 2016

Construction waste is one of the most pressing issues the waste management sector faces today. With growing amounts of commercial, industrial and residential construction happening around the country, and the lack of treatment facilities for such kind of waste, construction and demolition waste is mostly dumped in an unauthorized and unregulated manner in open dumps, or in empty tracks of land. The ministry of forest and environment has formulated the construction and demolition waste management rules 2016. 

Promotion and participation of private companies is a must in the collection, treatment and final disposal of C&D waste, as this will bring in much needed investments in the treatment collection and storage side of the business, along with generating tremendous amounts of revenues for the local authorities in the way of tipping fees. The following criteria must be applied to private companies or individuals looking to enter the C&D collection, transportation, Treatment and Disposal business. 

       i. C&D Collection: The collection of C&D waste by private companies and individuals must be based on the following criteria, which also include the roles and responsibilities of the generator of C&D waste:

a.    The Waste Generator must segregate the recyclables from the C&D waste and store all such waste in a clearly marked skip. 

b.    The construction debris must be filled in sacks and then stored in skips that are easily accessible via small, medium or large trucks. 

c.    Depending on the project size, specialized bins must be placed for large projects that generate five tons or more of C&D waste on a daily basis. These can be roll on roll off bins if such equipment is available by the collector/transporter or the waste must be filled in sacks and then stocked in one large bin or in multiple bins for the purpose of collection. The bins must be accessible via, small, medium and large trucks and should be placed at a height so that the content in the bins can be easily emptied into the truck without too much manual lifting involved. 

d.    The generator and the collector must have the contents weighed at an authorized government weigh bridge or on a calibrated weigh scale at the generators location for the purpose of record keeping.

e.    The generator must pay the collector/transporter a fixed fee based on a per kilogram rate.

f.     The collector/transporter must insure that all recyclable waste is sent for the purpose of recycling after recording all such waste in presence of the generator. The generator can demand a rebate in the collection fee amount based upon the value of recyclables recovered 

g.    The collector/transporter must insure that all C&D waste collected must be transported to the closest C&D treatment facility and pay the operator of such a facility a tipping fee as determined by the operator of the facility. In absence of such a facility, the collector/transporter must insure that the waste is disposed off in accordance and in guidance of the local bodies.

h.    All efforts must be made to utilize the waste for filling purposes and only and only after exhausting all alternatives the waste must be disposed off in the authorized landfill/dump site belonging to the government.

i.      The collector/transporter must pay a tipping fee to the local bodies to such an amount as decided by the local bodies. The fee must be charge on a per kilogram basis. The tipping fee for C&D waste must be charged at a higher rate than that of general waste. This will put pressure on companies and individuals to minimize the amount of waste that they generate and look at alternative and new methods of contractions that limit or reduce wastage. 

j.      The collector/transporter must during the process of transporting the C&D waste insure that the vehicle used is covered and not overloaded. 

k.    The vehicle must have tipping mechanism so that unloading of the waste does not require labor 

l.      All sacks in which the construction debris is filled must be recovered by the waste collector and reused for the purpose of filling debris. These sacks where ever possible must be returned to the client for the purpose of filling and stocking the construction debris.

Sub point (d) Store horticulture waste and garden waste generated from his/their premises separately in their own premises and dispose as per direction of the local body from time to time. As of now local bodies have no policy in place for disposal of horticulture waste most of this waste is dumped in open dumpsites and some of it is used as kindly wood used for cooking purposes. Private companies or individuals should be allowed to collect, transport, treat and dispose all such waste, generated from residential, commercial and industrial establishments. The collection of horticulture waste by private companies and individuals must be based on the following criteria: 

a.    The collection of waste must happen in vehicles that can cater to transport such waste in a manner that the waste does not fly off the trucks. 

b.    The collection agency must either transport such waste to the closest composting, waste to energy or brisket manufacturer for the purpose of treatment.

c.    The private agency or individual must pay a fee as determined by the facility operator tip the waste at their facility. The tipping fee charges must be on a per kilogram basis.

d.    In the absence of any such facility present, the collector/transporter must tip the waste at the authorized landfill/dump ground and pay the government a fee for tipping such waste. The fee should be charged on a per kilogram basis as deemed necessary by the local authorities or operator of the landfill.  

Duties of waste generator point (4): No person shall organize an event or gathering of more than one hundred persons at an unlicensed place without intimidating the local body, at least three working days in advance and such person or the organizer of such event shall ensure segregation of waste at source and handing over the of segregated waste to waste collector or agency as specified by the local body. 

Numerous such functions take place throughout the country on a daily basis, post completion of such functions waste is found to be littered in and around the event venue. Private organizations or individuals should be allowed to collect, segregate, treat and dispose waste from such functions based on the following criteria:

a.    Collection of waste from unlicensed venues must take place in accordance to the rules mentioned in MSW rules 2016. The generator or organizer of the waste must insure that all waste generated be segregated and then disposed of in a segregated manner in different dustbins. 

b.    Collection of such waste must happen on a daily basis for the duration of the event. 

c.    The event organizers must pay a collection fee to the waste collection agency 

d.    The collection agency must insure that all waste collected is transported in covered trucks so that no waste flies off or falls from the truck during the transportation process. 

e.    All waste collected must be segregated at the collection agencies facility or at the closest MRF. In absence of such facilities, the waste must be segregated at the authorized landfill or dump site belonging to the local authorities. The recyclables recovered from the waste must be sent for recycling and the organic waste to closest composting or waste to energy plant. The collection agency is liable to pay a tipping fee to the operator of all such facilities as decided by the facility operator. 

f.     Waste that cannot be treated or recycled must be dumped in the landfill or dumpsite and a tipping fee must be paid to the appropriate government authorities. The fee should be charged on a per kilogram basis.

Duties of Generator Point (6): all residential welfare and market associations shall, within one year of the date of notification of these rules and in partnership with local bodies insure segregation of waste at source by the generator as prescribed in these rules, facilitate collection of segregated waste in separate streams, handover recyclable waste to either the authorized waste picker or authorized recycler. The bio degradable waste must be processed, treated and disposed off through composting or bio methanation within the premises as far as possible. The residual waste shall be given to the waste collectors or agency as directed by the local body. 

Door – Door collection of waste in most residential societies or homes can be broken down into three different categories: 

1.    Collection from High Income Neighborhoods 

a.    Collection from high income neighborhoods are done by private contracts in most cases. Over ninety five percent of these contractor’s function in the unorganized sector and collection is done using a cycle rickshaw in most cases. After the collection of waste is done from houses/flats located within a community or area the waste is taken to either an empty field or the contractors’ warehouse which in most cases is in the open and unregistered or to local community bins. The contractor proceeds to segregate the waste here to recover the recyclable waste for the purpose of selling it. The inert and organic waste is either left at the community bin or disposed of in unauthorized sites/empty plots. The segregated recyclable waste is transported to open warehouses in empty plots of land, mostly in villages where this waste is stored in the open and then sold to various scrap traders. Some of these unauthorized vendors collect the waste and then bring it directly to their warehouse, where the waste is segregated into different categories. Post the recovery of recyclables, the inert and organic waste is dumped illegally in open tracks. 

2.    Collection from Middle Income Neighborhoods 

a.    Collection from middle income neighborhoods are done by private contracts in most cases. Over ninety five percent of these contractor’s function in the unorganized sector and collection is done using a cycle rickshaw in most cases. After the collection of waste is done from houses/flats located within a community or area the waste is taken to either an empty field or the contractors’ warehouse which in most cases is in the open and unregistered or to local community bins. The contractor proceeds to segregate the waste here to recover the recyclable waste for the purpose of selling it. The inert and organic waste is either left at the community bin or disposed of in unauthorized sites/empty plots. The segregated recyclable waste is transported to open warehouses in empty plots of land, mostly in villages where this waste is stored in the open and then sold to various scrap traders. Some of these unauthorized vendors collect the waste and then bring it directly to their warehouse, where the waste is segregated into different categories. Post the recovery of recyclables, the inert and organic waste is dumped illegally in open tracks. 

3.    Collection from Low Income and Slum Areas:

a.    Collection from low income neighborhoods and slum areas poses specific challenges. In low income neighborhoods collection becomes a task as accessibility is a huge issue. Most if not all of these colonies are either unauthorized or constructed in such a manner that it becomes tough for trucks or small or large to enter the area for collection purposes. In most of these colonies as off now waste is just dumped in open collection points or thrown out of one’s house onto open areas. In some instances, waste is collected using cycle rickshaws or wheel barrows and then dumped in open dumpsites located in the vicinity or within the area itself. Waste from these dumps is then collected by the government agencies and transported without segregation to the landfill or dumpsites. According to our study, some neighborhoods pay a nominal fee of rupees twenty per month per house to local vendors/unorganized sector for removal of waste from their houses, but the majority do not pay a fee and simply dump the waste where suitable. Private agencies should be encouraged to collect from slum areas and from low income housing societies by the concerned authorities. 

4.    Collection, Transportation, Segregation and Treatment Process & Criteria for Residential Establishments: 

a.    Collection Process: The collection of waste from residential colonies must be done in three halves, the first being collection of dry recyclable waste, second being the collection of organic waste and the third being the collection of inert waste. Horticulture and household hazardous waste should be collected separately. The process of collection, transportation, treatment and disposal of horticulture waste has been defined in this document, and the process of household hazardous waste will be defined separately as part of this document. As defined in MSW rules 2016 individual houses are responsible for segregation of their own waste into recyclables and wet waste. All gated communities of more than 5000 sqm area must ensure segregation of waste at source, collection of segregated waste in separate streams, and hand over the material to authorized waste pickers, private companies or authorized recyclers. The bio degradable waste must be treated and converted into compost within the premises as far as possible.  To facilitate this entire process private participation is of utmost importance, and will help in insuring that the waste collected is optimized to its fullest. 

b.    Transportation Process: The waste collected must be transported in a cover truck to ensure that no waste flies off the truck littering the streets that the tuck is travelling on. 

c.    Segregation Process: MSW rules 2016 clearly mention that all waste generated at residential level must be segregated and then handed over to the authorized waste collector or recycling agency. All segregated waste such as recyclables must be sent directly to the recycling facility. If the collection agency so decides to stock the goods at their facility, they must do so according to the following criteria:

i.     The stocking facility must be covered and in an industrial area 

ii.     The facility must have flooring made of cement 

iii.     The facility must be open to the public, for them to tip their clean recyclable waste 

iv.     The facility should only deal with non-hazardous recyclable waste, unless specified otherwise by the local government bodies.

v.     There might be instances where the mixed garbage is being provided to the waste collector by the residential society. In such cases the collector of waste must insure that the waste is either segregated at a MRF facility operated by him or a second party. If the facility of operated by a second party, the collector must abide by the payment terms of the operator of such facilities.  If it is found that the mix waste contains organics or inert waste the collector must pay a fixed fee to the operator of such facilities. If the collector is operating his or her own facility he must insure that waste is segregated properly, the inert waste is dumped in the authorized landfill/dump site, for which the operator must pay a tipping fee to the government. The operator can also outsource the disposal of all such waste to an authorized third-party vendor to whom the operator must pay a fee for tipping such waste based on a per kilogram basis. The collector intern would pay the local government body a fee for tipping all such waste in the landfill/dumpsite. 

d.    Treatment: recyclables must be treated according to their characteristics, and the organic waste must be converted into compost within the housing societies if the area is above 5000sqm. if for whatever reason the housing society is unable to treat their organic waste, all such waste must be transported and tipped at the closest composting/waste to energy/bio metheneisation facility for which the collector/transported must pay a tipping fee to the operator of such facilities. The government must subsidize and provide state GST concessions to all such units small or large to promote private investment and competition in this field, specially in the case of treating organic waste and sale of recyclables. 

5.    Duties of waste generator – (1) Every Waste Generator Shall: Sub Point (8): all hotels and restaurants shall, within one year from the date of notification of these rules and in partnership with local bodies ensure segregation of waste at source as prescribed in these rules, facilitate collection of segregated waste in separate streams, handover recyclable materials to either the authorizes waste pickers or the authorized recyclers. The bio degradable waste shall be processed, treated and disposed off through composting or bio methanation within the premises as far as possible. The residual waste shall be given to the waste collectors or agency as directed by the local body.

a.     Current methods of handling waste: Hotels, Restaurants, Commercial Mall & office Buildings: Commercial Malls generate various types of waste, ranging from wet organic waste, horticulture waste, recyclable waste, e-waste, sludge, construction debris, and other hazardous waste such as oil from generators etc. Majority of the Mall in India sell or tender their waste management so lutions out to the highest bidding vendor. These are fixed rate contracts that where the vendor pays a fixed sum to the mall management on a monthly basis to collect their waste. The vendor has to collect, organic, recyclable, hazardous, construction debris, horticulture waste. Mall management are not concerned about what happens to this waste, as their main concern is that they receive the highest value for their scarp waste. Again, reasons for this have been elaborated above. As per the hazardous waste such as oil is concerned, this is sold off too in a dubious manner, using a third-party vendor to provide fraudulent certificates of collection and then proper disposal. Within the malls large retail outlets dispose of their waste, but have their recyclables segregated and then sell these off separately to local scrap dealers for cash. Again, little or no thought is given to how the waste is handled. It is also surprising to know that large multinational organizations providing facility management services to malls are also engaging in these malpractices, whereby they charge the mall for services and then tender out certain services that they do not do, specifically waste management services. Large commercial office building also follows the same practices, where by the facility management company is responsible for waste management services. 

Policy intervention and Implementation required:

There is clear direction been given in MSW rules 2016 in regards with waste segregation, and then handing over the waste to authorized waste collectors or authorized waste recyclers, yet there is no clarity at the municipal and authority level for granting such permissions to private organizations or individuals. State government and the pollution control board should bring about amendment in their policies to allow for collection, transportation, treatment and disposal of MSW from commercial establishments such as malls, restaurants, hotels and office buildings. The criteria for granting permission to private companies and or individuals has already been detailed in this document.            

6.    Duties of the secretary – in – charge, urban development in the sates and union territories: 

a.    Sub Point (b): while preparing state policies and strategies on solid waste management, lay emphasis on waste reduction, reuse, recycling, recovery and optimum utilization of various components of solid waste to ensure minimization of waste going to the landfill and minimize impact of solid waste on human health and the environment.

i.     MSW rules 2016 clearly states that the emphasis should be laid on reduction of waste through reuse, recycling and recovery. Private companies and the unorganized sector consisting of rag pickers and local scrap dealers are a vital part of this equation, but do not have any legal recognition for doing this work from the government. Policy intervention is required to encourage investment in MRF and new methods of recycling and this can only happen the legal frame work encourages competition in this field. As of now there is no clarity at the municipal and authority level and tendering of entire cities is the preferred method when it comes to managing municipal solid waste. Permissions must be given to private companies, individuals to collect, transport, recover, store and recycle all such waste. The criteria for engaging in such activates have been shared in this document already. 

7.    duties and responsibilities of local authorities and village panchayats of census towns and urban agglomerations: 

a.    Sub Point (b) (c) (d) & (h) The following document and the suggestions made in it will help local bodies meet the requirements mentioned in the sub points mentioned above. From arranging door-door waste collection from households, commercial establishments, malls to setting up material recovery facilities and engaging with the informal sector to make them a part and parcel by bringing them officially into the ambit of organized waste management, will require the mass participation from SME in terms of bringing in investment and new ways of handling waste.

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