CIVIC, a non-governmental organisation in Bengaluru has registered its concerns regarding new garbage tenders published in June 2015 by the BBMP. Here is the summary of the letter sent by CIVIC to the BBMP Administrator T M Vijayabhaskar.

Overall concerns

1.     Outsourcing of garbage disposal to contractors needs to be discontinued and contract PKs regularised

CIVIC feels that outsourcing of garbage disposal by BBMP to contractors should be discontinued as garbage disposal is a “core” and “perennial” activity of BBMP which cannot be outsourced as per the Contract Labour (Abolition & Regulation) Act. CIVIC suggests that the current contract workers be absorbed as regular workers of BBMP and BBMP take over the complete task. This has been suggested in view of the observed violations of laws, rules, tender conditions, etc., indulged in by the contractors and their unholy nexus with elected representatives, officials and others, where the workers are exploited.

The Karnataka Commission for Safai Karmacharis too has recommended to the State government to abolish the contract system for municipal workers  and has has expressed its assurance that this would be implemented by the State Cabinet in the immediate future.

CIVIC believes that the move to issue fresh contracts for garbage is likely to be a futile exercise, as the Bombay Industrial Court has also ruled that outsourcing garbage disposal to contractors is illegal.

2.     Integration of informal workers in the dry garbage recycling  system

CIVIC notes that the new tender guidelines have no mention of how informal sector workers, such as rag-pickers, will be integrated in the collection, sorting, recycling and disposal of dry garbage. There are around 30,000 rag-pickers engaged in collecting and recycling a good amount of dry waste in the city. They will be deprived of their livelihood if contractors are given the right to collect all the dry waste and sort and recycle it at DWCCs.

CIVIC suggests that the BBMP can form self-help groups of informal sector waste-pickers (rag-pickers) and permit them to collect all dry waste, from individual as well as bulk generators, and sort and recycle them at the Dry Waste Collection Centres (DWCCs) to generate employment and make entrepreneurs out of rag pickers.

3.     Garbage being a resource, a “Business Model’ should be devised to generate revenue out of it.

Garbage being a resource when properly segregated, BBMP need not pay hundreds of crores for the disposal but should actually earn some revenue out of it, says CIVIC. If the contract system is to be continued, BBMP should auction the right to collect and process garbage to the highest bidder, as is being done with coal, spectrum, etc. and pay only the salaries of the workers and provide assets, such as push-carts, autos, bins, etc. BBMP can also stop the outsourcing system, devise its own ‘Business Model’ to generate revenue out of garbage by ensuring segregation at source and processing it or selling the waste to processors.

A BBMP Executive Engineer in charge of SWM demonstrated that Rs 300 crores can be generated as revenue from BBMP’s garbage. He presented it at one of the consultations organised by CIVIC at the time the last tenders were issued. This means the Rs 400 crores being spent on transportation can also be saved. Hence the assumption that costs for garbage disposal need to be increased to Rs 600 crore or so appear to be misconceived and miscalculated.

4.     Formation of self-help groups of PKs and informal sector waste-pickers

Since BBMP is providing the assets, such as push-carts, autos, land and infrastructure for processing waste, it can ask existing PKs to form self-help groups and hand-over the collection and processing of wet waste to them and let them keep the profits from the bio-methanation or compost generated. Such self-help groups of PKs and rag-pickers can be linked to the National Urban Livelihood Mission (NULM). This way, the waste-collectors themselves are incentivised to demand garbage segregation at source. This will also enthuse residents to segregate their waste as there will not be mixing of waste by the collectors, as is happening now.

5.     Why should bulk generators process their own waste?

Since all property owners are paying solid waste management cess along with their property tax, why should they process their own waste at their own cost? Garbage disposal is an obligatory function of the BBMP

Since apartment complexes also consist of individual households, it is creating inequality before the law as households living in individual bungalows are spared from having to process their own waste. Moreover, more and more apartments are built in Bengaluru and all of them may generate more than 10 KG waste per day, which is the limit for bulk generator. In such cases, if almost everyone is to process their waste at their own cost, will BBMP not be abdicating its obligatory function to collect and dispose garbage?

There is a case for BBMP itself to organise separate streams of collection for bulk generators such as hotels and Kalyan Mantaps, etc, and perhaps, charge a higher SWM cess for such commercial units. Or at least, those processing their own waste should be exempted from payment of the SWM cess or given a rebate on property tax.

Specific concerns

6. Bins to be supplied or sold by BBMP to householders

The manner in which garbage has to be received by the waste-collectors from households needs to be specified in the tender. Currently, most residents are being asked to give loose garbage to avoid the use of plastic bags. But rules in cities across the world prohibit giving of loose garbage, its exposure to the workers and environment and its littering on roadsides.

Garbage has to be always given and collected in closed condition in those countries. Each household is given a bin with a lid by the municipality with a unique number indicated on the bin which links the number to the address of the householder, which will identify whose garbage it is in case of any violations of rules regarding garbage disposal. Efforts have been made by some organisations in Bengaluru to adopt the 2-bin and 1 bag method, which can be made the rule in the tender itself.

7. Mechanical lifting of individual/apartment household bin

Most countries require householders to put out their garbage bins at the kerbside after specified times at night and take back their bins before specified times in the mornings, to give the households a flexibility and a period of over ten hours during which the householder can put out his garbage at any time convenient to him. He need not be there at the exact fixed time everyday when the pick-up van comes to hand-over his bin. This is the reason why many who miss giving their waste to the waste-collector/auto throw their garbage later at the collection point.

8.  Minimum specifications for infrastructure for collection of wastes in Schedule 3A to be expanded

There is a need to specify more accurately the kind of infrastructure that needs to be deployed by the contractors. There are often no bins in the currently-used push-carts for collecting garbage or street waste. A torn sheet or broken mat is slung across the push-cart to hold the garbage. There is no means of collecting segregated garbage with such infrastructure.

 Push-carts with no bins. Pic: Kathyayini Chamaraj

The Tender says:

“Comply with Applicable Laws at all times during the period of this Agreement and in particular ensure conformity to all the laws relevant to contract labourers/ employees, with respect to their work environment, health and safety aspects.”  But the pourakarmika has to suffer the stink and often handle the garbage manually with such infrastructure. The push-carts are in such a condition that they can hardly be pushed as they have not been renewed since 2000. Also the MoEF Rules say that household waste should not be mixed with street waste. Hence it is required to specify in the tender that PKs shall collect only street waste and autos shall collect household waste.

To fulfil the conditions placed by these Rules, it would be required to specify in the tender that the infrastructure should consist of push-carts/tricycles/trolleys with lidded containers for Pourakarmikas to collect only street waste.

It should be specified that door-to-door collection should be done only with autos that have containers, with lids or flaps. Autos with tippers that are currently specified in the tender will result in garbage being exposed to the environment and later tipped to the ground as it is usually difficult to coordinate the arrival of the tipper with that of the compactor at the collection point.

Containerised trolleys for street waste and containerised autos for door-to-door collection of garbage will ensure that garbage is collected in a closed condition always, so as not to expose the garbage to the environment, or make it visible to the public, and cause stench, breed insects, feed rodents and stray animals, and hence become health hazards.

9. Secondary storage of municipal solid wastes  

Though the Tender says:

“Ensure that all aspects of the Assignment shall conform to the laws pertaining to environment, health and safety aspects including Municipal Solid Waste (Management & Handling) Rules 2000, policies and guidelines related thereto;” there is no provision in the Tender to install secondary garbage storage bins at collection points which is a requirement under the existing and proposed MoEF Rules.

Currently, direct transfer from push-cart or auto-tipper to lorry is not happening. Garbage is being first dumped on the ground and then lifted manually, violating all rules. Without secondary waste containers, this situation is likely to continue.

Garbage dumped on a streetside, due to the lack of secondary storage. Pic: Kathyayini Chamraj

It is not only a violation of MoEF Rules but also impractical to believe that one can effectively manage waste without installing hygienic bins/containers for secondary storage of waste, especially in market areas. Aesthetic fibre bins are available (as shown below) which should be placed on a cement platform and people should be educated to use them properly.  The colour-coded  bins should then be either towed away to processing sites or lifted mechanically and emptied by compactors without manual handling.

Colour-coded street bins. Pic courtesy: wikipedia.org

Containerised street trolleys. Pic courtesy: biocycle.net

Containerised auto. Pic courtesy: ipwtgroupindia.com

10.  Land for DPF

The tender says: “Subject to availability of land, develop a ‘Decentralized Processing Facility’( DPF”) for Wet Waste and Service Provider shall endeavour to set up a DPF within the Package within 12 months of the CoSD…”

With such a vague formulation which is not binding on the BBMP or the contractor, local DPFs will not become a reality everywhere. BBMP should mandatorily either purchase directly from sellers or acquire the necessary land to set up DPFs, at least one in every ward.

11. Performance standards and liquidated damages

Performance standards should be set for segregated collection of different wastes with different streams of collection; the amount of garbage processed locally; the amount earned on the products (gas or compost); the amount of recyclables recycled and the least amount send to landfill.

12.  Collection of bulk and other wastes

• Bulk waste such as mattresses, rugs, broken commodes, etc should be collected only on a monthly basis by fixing and announcing the dates of collection. Anyone dumping them on any other day should be penalised.
• Hazardous waste such as batteries or tube lights should be collected separately on monthly basis from households or delivered by citizens to drop-off centre at DWCCs. They should not reach the landfills.
• Separate weekly trip should be made for collecting household garden waste. All leaves should be bagged. The tenders do not mention collection of garden waste from households.
• It is not clear how construction debris will be picked up from source. There should be a telephone number to which citizens can make calls when they have debris to be collected. They can be made to pay as per weight or volume.

13.  Stand-by staff

Along with 1/7th additional staff at least 20% stand-by staff should be recruited for those taking leave/ absent. The tender states that additional number of staff shall be recruited by the bidder only ‘if required’.

Manual handling of garbage. Pic: Kathyayini Chamaraj

14.  Cleaning of tools

In the tender, the service provider is made responsible to make arrangements to clean all the tools, equipments and vehicles once in several days, but not daily. However, to avoid communicable diseases to workers, the equipment, tools and vehicles should be cleaned on daily basis to maintain hygiene. Vehicles and equipment should be cleaned by bio-sanitizers and not phenyl, to avoid killing the bacteria which help in composting.

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