Amend MSW Rules 2015 for proper management of absorbent hygiene product waste

We petition that the proposed Draft Municipal Solid Wastes (Management and Handling) Rules, 2015  referred to as MSW Rules 2015 above clearly state that all absorbent hygiene product waste (which includes menstrual hygiene waste) is:

  1. Categorized and segregated at source as a third separate stream of waste as reject waste
  2. Wrapped in an identifiable, leak-proof bag for collection
  3. Not incinerated if the product contains chlorinated wood pulp and plastic
  4. Never flushed down the toilets

We further demand the following amendments to the Draft Plastic Waste (Management and Handling) Rules, 2015:

  1. Clearly state that all absorbent hygiene products that contain plastic polymers come under the purview of this law
  2. Clearly extend the Extended Producer’s Responsibility (EPR) clause of this law to include manufacturers all absorbent hygiene products containing plastic polymers so that they provide the required finance for identifiable, leak-proof bags for collection of absorbent hygiene product waste; for establishing centres for waste collection and processing (that is sterilizing by autoclaving/microwaving, followed by recycling and composting of the various layers) for dealing with such waste
  3. Ensure that the collection of the funds under EPR is rigorously enforced by the municipal government with support from the state government

Why are the above amendments to the laws important?

In India, absorbent hygiene product waste (which includes menstrual hygiene waste) is flushed down the toilet or thrown into the trash, or burnt. All these methods of disposing sanitary waste lead to social and environmental injustice:

Disposal by flushing:

Absorbent hygiene product waste flushed down toilets cause huge problems as they clog up sewers. Most sewerage system are meant to carry only water and excreta. Besides the huge costs in maintenance of sewerage systems worldwide, in India the problem is exacerbated by the fact that, in contravention to existing laws, conservancy workers, with no protection whatsoever, have to go down the manholes to manually clean the blockages. The occupational hazards of conservancy workers are such that they risk their lives at work and are subject to infectious diseases such as leptospirosis, viral hepatitis, and typhoid. Because of the nature of their work, conservancy workers are subject to alcoholism and have a life-span of only 45 years.

Disposal by throwing it away as unsegregated trash:

When absorbent hygiene product waste is thrown away as unsegregated trash either in the open or into trash cans, waste pickers, who do not have protective gear, have to handle them with their bare hands. Handling this waste with their bare hands is particularly degrading and against the legal right to dignity of labour.

Additionally as this form of waste contains bodily fluids, this form of waste may contain life-threatening pathogens, which severely compromises the life and health of waste pickers and against the constitutional right to life.

Disposal by burning in open fires or incinerators:

In recent years, incineration is being promoted in India as a safe way of disposing absorbent hygiene product waste (particularly menstrual hygiene waste) and single-chamber or electric incinerators are widely being installed in public places for burning menstrual hygiene waste.

Yet a closer study reveals that none of the incinerators in India, reach the necessary temperature of 800 degrees Celsius, recommended by World Health Organization, to allow for the safe incineration of health-related waste. Disposable absorbent hygiene products are made of multiple layers comprising cellulose or wood-pulp, LDPE plastic polymers and polyacrylate. When such complex plastic polymer products are burned at lower temperatures they typically release asphyxiant and irritant gases into the atmosphere. Further, the biodegradable components, such as cellulose or wood-pulp in absorbent hygiene products often contain furans (due to use of pesticides) and dioxins (due to a chlorine-bleach process).

Dioxins and furans are among the most deadly toxins known to science, being highly carcinogenic even in trace quantities. When absorbent hygiene products are burnt these toxins are released into the atmosphere and can travel a long way from the point of emission. Dioxins are additionally hormone disruptors that cause reproductive and developmental problem, damage the immune system, and can be transmitted by mothers directly to their unborn babies.

Additionally, there is just not enough scientific knowledge about the individual and combined effects of the hundred different kinds of chemicals present in the waste or formed during incineration. Incinerators also operate at temperatures lower than 800 degrees Celsius during the start-up and cool-down phase. Thus waste disposal experts advise on adopting the precautionary principle and refraining from incinerating plastic waste. By choosing to burn napkins rather than flushing then down the toilet, we merely shift the problem from affecting individual lives to affecting entire populations including future generations.

Therefore it is important to amend both Draft Municipal Solid Wastes (Management and Handling) Rules, 2015 and The Plastic Waste (Management and Handling) Rules, 2015 for proper management and handling of  absorbent hygiene product waste as described above.

NB: The Ministry of Environment, Forest and Climate Change have just released their latest draft on Municipal Solid Wastes (Management and Handling) Rules, 2015 the public can give feedback till June 6. So please sign the petition.

Other objections or suggestions on the proposals contained in the draft notification, if any may be addressed, within the period so specified, electronically at e-mail

This petition is part of the #periodofchange campaign.

We are grateful

  • To Harshad Barde and Malati Gadgil of SWaCH for helping Bindu Mohanty to fine-tune the text
  • To Brooks Anderson for the use of his photo
  • To waste workers in India for humbling us with the work they do
  • To all of you all over the world who care about environmental and social justice

Thank you for your support!

Bindu Mohanty (Earth&us)

Minhaj Ameen (Earth&us)

Arpita Bhagat (The Kachra Project)

Malati Gadgil (SWaCH)

Harshad Barde

Chitra Mukherjee (Chintan Environmental Research and Action Group)

Ashish Malani (MediAceso Healthcare Pvt Ltd)

Shibu Nair (Thanal)

Harshini Mugandan (Eco Femme)

Ribhu Vohra (WasteLess Auroville)

Chandrah Nusselein (WasteLess Auroville)

Angad Vohra (Mantra)

Sign the petition!