Reproducing here  Dr Tiwari's article published in the MAHIMA of IMA Mah. State. in its Monsoon Issue 2009


Impractical Attitude of Authorities towards small clinics in smaller cities.


Dr. Subhash R. Tiwari. Akola.

Member, Editorial Board, MAHIMA


Present status.


During last few days, the Maharashtra Pollution Control Board, through its Regional Officers has issued notices to Doctors all over the state, asking them to show cause regarding

i) failure to get authorization with MPCB,

ii) for not joining a common facility for Bio Waste Disposal,

iii) and for not submitting Affidavits claiming immunity from authorization due to having less than 1000 patients per month.

We all know, that the Bio Medical Waste Rules 1998 ( amended 2000) are enforced by the State Government Pollution Control Board through its regional and sub regional officers. The Government’s attitude up till now has been impractical towards the actual problem, because its officers are not following the rules in “true spirit”, and mostly sticking to the law in “word” only.


Bio Waste Problem- “Reality versus Hoopla.”


Lately there have been numerous news insertions in news papers pointing fingers towards the medical community being responsible for not disposing bio waste in prescribed manner. Such items are generally planted by the vested interests who want to be benefited by the action which follows this by the MPCB. The facility operator is invariably behind such news item so that he can enlarge the scope of its coverage and earn more. No doctor would endanger his own health and that of his patients by unscientific disposal of bio waste in any way, but the hue and cry raised by certain ill informed and medically illiterate persons creates an impression as if the whole world were to be doomed due to bio waste only.  Let the wisdom  prevail upon the misinformed people that there are hundred more dangerous modes of getting deadly infections than the bio waste alone, which most often comes out of a totally aseptic environment and is handled by people who understand the importance of infections better than anyone else.


The plight of small out patient consultation clinics.


The Medical Practitioners having purely “Examination and Consultation Practice”, who are not administering medicines or dressing any wounds in their clinics, are being threatened with legal action if they do not join a common facility by paying huge recurring charges unnecessarily. Why?






Adamancy to deny deep burial.


While the Rules put the responsibility of taking all necessary steps for safe disposal of the Bio Waste on the Occupier who generates such waste, it also provides specifications about how to do it.


The Bio Waste Rules clearly mention that the cities having population below 5 Lakh will have a legitimate option to dispose off the Category I and II waste by Deep Burial, but the Pollution Control Board is adamant, in not allowing such disposal in most of the Municipal Corporations (D type) and the Municipal Councils, which are eligible to use that option. The Board should go through the Population Data of 2001 census and verify for itself the municipal areas eligible for deep burial. It will be found that most of the areas in the country below the C level of Municipal Corporations are eligible for the provision of Deep Burial. Deep burial is a safe, cost effective and productive method for safe disposal of Category I and II Bio Waste. Why should the authorities then, insist upon the use of Incinerators, which are not only costly but are also a potential source of pollution if the emission norms are not monitored properly? With the given efficiency of the Government machinery, the remedy poses a greater risk than the disease itself.

In smaller places having population below 5 Lakh, for Bio Waste category I and II the Board must encourage Deep Burial and not the Incinerators which have been discarded in most parts of the world.


The Rules clearly mention that the site for disposal within the Municipal Area will be provided by the Local Self Government, it has not been done and Medical Associations are either asked to develop such disposal site out of the Municipal Area or join a common facility operated by some third party suggested by the MPCB authorities. Why?



Bio waste from Domestic Source

The incidence of Insulin Dependant Diabetes Mellitus (IDDM) in children below 15 years of age is about 10/1,00,000 in India. Extrapolating this incidence to all higher ages, we may say that at least about 5,00,000 IDDM patients are there in Indian population.   

(Source: Source: 1: Diabetes Res Clin Pract. 1996 Oct;34(2):79-82.)



Majority of  these Type I insulin dependant diabetics are daily injecting themselves at home and disposing their syringes and needles in the municipal dustbins. Does that not amount to production of Bio Waste?


Soiled dressings and pads.


About 250 million women in the reproductive age group are throwing menstrual pads in open every month that is 8 million per day. That is hundreds of times more, compared with the amount of soiled waste from small clinics.


Thousands of patients having injuries and weeping ulcers are dressing themselves at home discarding their soiled dressings in open. Does the MPCB have a control over them?


Open Shaving Blades (The Sharps in bio waste rules)


As per census 1991 breakup 62.7 % part of population is above 15 years of age. (There should be the same proportion in 2001 census too). This means about 627 million persons are above 15 years. With the given sex ratio it means there are 350 million males who must be shaving themselves with varying frequency of once a day to once a week. That means an average of 200 million persons shave each day. Out of these only a few millions in urban areas are using Cartridge Shavers and the rest are using open blade shavers, which means about 20 to 25 million blades are disposed daily in the roadside by the people at large. This may be verified from the sales statements of leading blade manufacturers in India. A cut during shave makes them a sharp soiled with blood and attracts the provisions of bio waste rules just like the blade of a surgeon’s knife. Even if these are not contaminated by human blood during shaving, these are sharp edged wastes potentially hazardous to the rag pickers or handlers.


If disinfected needles, even though properly shredded and mutilated after use by the doctors, are considered to be potential hazards to the public at large, how come the open shaving blades thrown in dustbins are not? Will it be wise to take any statutory action against the common people? If not why should the authorities target the Doctors only with such rigorous and draconian provisions of law having penalty in Lakhs of rupees and imprisonment up to 7 years.


In fact, the medical workers are working with utmost caution, maintaining aseptic environs to prevent causation of injury and infection, not only to patients but to themselves too. The hoopla created by the so called NGOs is utterly misguiding the lay people, and the government is acting impractically on their pressure. What is needed is, to have a practical approach, rationalizing the application of methods of disposal in such a way that they are made simple and acceptable by most of the producers of bio waste to achieve the desired objectives of these rules.


For small clinics, having less than 1000 patients per month, simple measures can be taken up by the doctors themselves. Sharps and soiled material after mutilation and disinfecting in the prescribed manner can be disposed as routine solid waste by Municipal Authorities as usual, as provided in Bio Medical Waste Rules. Periodic checks by the competent authorities regarding satisfactory compliance of the requirements of law should be carried out.

Only establishments like Big Surgical Homes which generate Tissue waste should be required to take all steps themselves or join a transport and treatment facility.




Role of IMA.  


Indian Medical Association must take this matter with the government to ensure that the legitimate options of the rules are made available to the all the medical practitioners, and the major chunk of its membership is not flogged in the name of enforcement of law by its word and not in spirit.



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