The Tamil Nadu Government which did not even provide information to the Central Pollution Control Board, for the latter’s Annual Report for 2017-18, on the action taken to implement the provisions of the Plastic Waste Management Rules of 2016, has jumped into action.
The features are: ban on forms of plastic that are not easy to dispose of, punitive measures to deal with non-compliance, and charging local bodies with responsibility for collection, appropriate disposal and law enforcement.
The definition of “waste generator” includes individuals, groups, residential establishments, etc.punishable for failure to comply and “extended producer responsibility” (EPR) making producers responsible for environmentally sound management of their plastic products till the end of their life. These arrangements, presently on paper, will be put to severe test in practice.
A simplified material balance helps to uncover the dimensions of the problem and indicate areas critical for success. Plastic waste can be contained by a combination of the following measures – reduce usage by finding substitutes, recycle the waste of the rest so that fresh production is correspondingly reduced, wherever possible put waste to alternative use (in road construction and as alternate fuel/raw material (AFR) in cement units) and, failing these, burn or dump. The last one is not environmentally desirable and, hopefully, the quantity would be nil or negligible.
Collecting the plastic waste
The quantity of plastic waste to be managed in Chennai is about 430 tons per day (tpd). Collection efficiency is claimed to be 40 percent but that is considered an over-estimate. What is uncollected is what we see everywhere, including sewage and drainage lines and overflowing bins.
From the collected waste, registered recycling units in Chennai get only about 50 tpd whereas they need a minimum of 100 tpd, according to the Tamil Nadu Pondy Plastic Association. If there is as much as 430 tpd of scrap, why are the recycling units not getting all they want? Therefore, it is doubtful if collection ratio is the claimed 40 percent. It is probably much less.
The surrounding omnipresence of plastic waste also lends basis to doubt the 40 percent. The foremost challenge, therefore, is to raise the present abysmal collection efficiency to 90 per cent or more.
Reducing the quantum of waste
It is estimated that nearly 50 percent of plastic usage is for single use or disposable products – plastic bags, plates, throw-away cutlery, bottles. This presents the opportunity to reduce usage substantially, within a very short time, by switching to substitutes and repeatedly usable cotton/jute bags. The waste could come down to half of 430 tpd i.e. 215 tpd. Time taken to enforce this practice is short – say, a month or two. This is the second challenge.
Utilising the collected plastic waste
If most of the 215 tpd is collected, the recycling units could have the full 100 tpd that they have been denied all along. Recycling would be important for plastic waste management for quite some time to come and therefore, it is necessary that policies are conducive to sustain the operation of these units. They are allies in the fight against plastic, and not intruders.
The next question is whether road construction and cement units can absorb the remaining 115 tpd. Taking road construction first, 2 tons can be used for one km of road. So, to absorb, say, 100 tons, 50 km of roads in Chennai should be constructed per day. That means, in a year of 250 working days, 12,500 km of roads need to be constructed, which is outright unrealistic. Therefore, road construction alone cannot be a significant option.
Can cement units absorb the remaining 115 tpd? The remaining 115 tpd is about 42,000 tons per year of plastic scrap (115×365). Based on the successful experience of Ambuja Cements and other cement units in Gujarat, it seems possible for cement plants to take 20-30,000 tons of plastic scrap each.
In summary, recycling and cement units together could have a very useful role to play in plastic waste management.
Making recycling units viable
It is necessary to place the recycling units in a position to take 100 tpd or even more, if necessary. Recyclers and plastic article manufacturing units have greeted the new discipline on plastic use with protests. Confusion prevails on the definition of what plastic articles are allowed and what are not. They feel that indiscriminate ban on articles would adversely affect their production range and, consequently, viability.
In the GST regime, these units have been denied the advantage they had over virgin plastic raw material. Before GST, VAT was 5 per cent on recycled granules and the same on virgin granules, but the latter had to pay, additionally, an excise duty of 12.5 per cent. This differential advantage has been removed with 18 per cent GST on both and the abolition of excise duty. Although this problem is not a repercussion of the plastic war, it has affected the viability of recycling units at a time when their full operation is essential to absorb a substantial portion of the daily collection of waste.
Admittedly, it is difficult to levy different GST rates on recycled and virgin material because of risk of tax evasion – one can easily be passed off for the other but some other way must be found to restore the advantage to these units which they rightly enjoyed in the pre-GST era. One suggestion is that the price of plastic waste to recyclers should be subsidised to the extent of the 12.5 per cent advantage they enjoyed earlier.
Recycling units are already exposed to another disadvantage compared to virgin raw material. When oil prices fall, virgin material cost falls making recycled material unattractive, as, after all, plastic is derived from petroleum. Making recyclers viable enough to absorb the scrap is the third issue to be tackled in the plastic war.
While resorting to recycling and reuse of waste, the problem of the already accumulated landfill and dumps must be resolved. Experts have suggested gasification as an effective way of converting waste into energy. Such possibilities should be explored. Within the next few weeks the aim must be to avoid further accumulation at the landfill/dump.
Cost of disposal
The proposed arrangement under clause 15 of Plastic Waste Management Rules, for funding the cost of collection and disposal, provides for a minimum fee of Rs 4000 per month from registered dealers authorised to sell recycled carry bags which would be sold to customers, with the proceeds going to the local body. Rule 8(3) of Plastic Waste Management Rules 2016 says that “waste generators” shall pay a fee. These provisions are still unclear. Fee collection from thousands would add to the administrative burden of the local bodies.
A New Zealand practice, with appropriate adaptation, may be considered. In that country, local authorities make large paper bags stamped with the official logo available to retail outlets. Households and complexes buy as many bags as they need for the volume of waste they generate. The price of the bag is equivalent to the cost of collection and disposal of waste. Waste is collected only if it is in the bags carrying the official logo.
Incidentally, should we not experiment with weekly or bi-weekly collection of solid waste to make collection more thorough and effective with available staff? Till the turn comes, the material can be held by the waste generators. Effective collection methods and easy way of charging for the cost of collection and disposal is the fourth issue.
The goal, within the next twelve months, should be to attain total control on plastic disposal, create a much cleaner environment and release the capacity of clogged sewerage and storm water drains. It is in our larger interest to participate proactively in this movement and watch its progress, if the government publishes the score card of progress every month.
[This article was first published in Madras Musings, and has been republished with permission (with addition of subheads only). The original article may be read here.]