Big problems in small incinerators for sanitary waste burning

City governments are increasingly relying on small incinerators to dispose of sanitary waste. But the evidence so far creates serious concerns.

In India alone, roughly 121 million women and girls use an average of eight disposable and non-compostable pads per month, generating 12.3 billion pads as waste annually, and 113,000 metric tons of annual menstrual waste. But there is a stark lack of awareness around the subject, and the subject is not always open to conversation, which makes the handling of this waste stream even more difficult. However, city administrators are scrambling for solutions and ordering thousands of small incinerators to tackle this problem.

Our sanitation systems are designed with urine and faeces in mind. Unable to cope with the menstrual absorption materials, they often get clogged. Sanitary products soaked with blood of an infected woman/girl may contain hepatitis and HIV viruses, which retain their infectivity and live up to six months in soil. Disposable sanitary pads, primarily made of plastic, are thus ticking time bombs – infesting landfills and finding their way to water bodies, drainage systems, soil cover and impacting the health of sanitation workers. 

Across urban local bodies, however, the most popular approach towards preventing disposable sanitary waste from reaching landfills seems to be the installation of small incinerators for in situ burning. These small scale incinerators are essentially waste burning chambers mostly used for burning sanitary waste, handling a few to hundreds of sanitary napkins per day. 

There are some rudimentary ones where waste is burnt in brick/clay chambers, using fuel like kerosene. Then, there are the more sophisticated ones where the energy source is electricity operated with a click of a button. Many such electric incinerators are being installed across the country by government and private bodies to handle the increasing volume of sanitary waste. The Maharashtra government, for example, has recently installed incinerators in all 9940 schools of the state.

Poster explaining the workings of a small scale incinerator
What are small incinerators and how do they work? Graphic courtesy: Why Burn Waste campaign

But is this really the best or most desirable way of handling disposable sanitary waste? Let us first see what the government says.

Guidelines for sanitary waste management

  • SWM Rules 2016 state that sanitary waste includes incontinence sheets, sanitary napkins, diapers, condoms and tampons which have to be collected separately. Sanitary waste manufacturers must consider using recyclable materials or provide covers, wrappers or bags for disposal after use.
  • Central Pollution Control Board (CPCB) Guidelines state that authorised waste pickers may undertake incineration as a commercial service. The Urban Local Bodies (ULBs) have to ensure that all collected waste is disposed of. It has to be sent to storage or disposal facilities or centralised biomedical waste treatment facilities or fed into waste-to-energy (WtE) treatment plants.

    ULBs may also establish small community-incinerators in their areas. Modular incinerators may have to demonstrate compliance to general emission standards for air emissions notified under the Environment (Protection) Act (EPA), 1986 or as may be prescribed by SPCBs/PCCs. In this regard, they shall produce a test certificate from an EPA recognised/accredited laboratory so as to sell their Product. (c) Considering low volume of flue gases, the cleaned flue gases after complying with standards shall be vented through stacks of height at least 2m above the roof or the nearest building or as may be decided by SPCBs. 
  • Swachh Bharat Mission (SBM) guidelines for disposal of menstrual waste state that small-scale incinerators can be installed in toilets with more than 10 seats. Ladies’ toilets shall have a vending machine for sanitary napkins.
  • SBM-Gramin guidelines for rural regions outline the deployment of adequate facilities for ensuring MHM and recommend the safe disposal of menstrual waste through incinerators.

Read more: Waste-to-energy plants face several challenges in Bengaluru

Where is the problem with small incinerators then?

One big problem is that most readily available sanitary napkins today are 90% plastic.

Each pad is equivalent to around four plastic bags and can take up to 250 years to fully decompose. They are made up of polypropylene as a top sheet to keep the pad dry. The super absorbent polymer (SAP) acts as an absorbent material along with fluffed cellulose pulp, while the back cover is made up of polythene to act as a barrier for leakage. Many sanitary napkins available nowadays contain plastic liners and gels. Over a period of time, thin polyester fibres are weaved into the pad, to help the menstrual fluid flow to the absorbent core. 

The pads also contain adhesives which hold all the layers of the pad together. These adhesives are generally made up of polyromantic/polyolefin copolymer, hydrocarbon resins and mineral oil. Therefore, sanitary pad burning can emit some highly toxic substances. 

Burning plastics generates GHG and other harmful chemicals

Burning the cotton/cellulose pulp in the pads can generate dioxins, as the cotton is mostly bleached with chlorine. Burning of chlorine with plastic at low temperatures of 200-400°C results in the release of dioxins. 

Dioxins damage the immune system, are potent carcinogens and cause hormonal imbalances. When they end up in water, they are absorbed by the aquatic life. Fishes are known to have 10,000 times more levels of dioxins compared to their surrounding water. Being fat-soluble in nature, it gets rapidly dissolved and gets biomagnified in the body, travelling up the food chain.

Furans, another very toxic substance, are also found in pesticides which are sprayed while growing cotton, therefore making burning of cotton ones equally harmful.

As per the SWM Rules 2016, small incinerators are meant to handle cloth or cotton-based sanitary wastes only. According to the Menstrual Hygiene Alliance of India, India generates nearly 12 billion disposable sanitary napkins every year, a majority of which are non-biodegradable in nature. These should be handled in biomedical waste incinerators due to the nature of the materials used. 

Why ‘small’ is an issue: The evidence so far

The small incinerators installed across the country do not have any pollution abatement measures and are impossible to monitor as lakhs are being installed all over. They do not attain high enough temperatures for complete combustion and therefore could lead to emissions of harmful dioxins and furans. 

Study 1 shows that small incinerators cause significantly more pollution (per kg of waste burnt) on almost all parameters, compared to medium and large incinerators. Incinerators generate maximum pollution when starting or shutting down with the temperature being below 800°C. A typical incinerator generates 60% of its total annual emission (of continuous, non stop operations at 800°C and above) in just one start-stop operation! As small incinerators typically stop and start multiple times a day, the US Environment Protection Association has set higher limits for them.

Study 2 investigated single chamber sanitary napkin incinerators. The two commercially available incinerators on which the study was carried out, failed to meet the standard emission norms with regard to CO and CO2 emissions.

Poster highlighting important findings from various studies on small incinerators
Several studies on small incinerators have yielded findings that are cause for serious concern. Graphic courtesy: Why Burn Waste Campaign

Study 3 revealed that the 12 small-scale incinerators installed in Pune by the city’s municipal corporation are operating at a temperature of 350-450°C. This is much less than the temperatures of 850-1100°C recommended by the World Health Organisation, which results in the incinerators releasing potentially carcinogenic emissions during the process.

In study 4, the secondary research conducted for India and South Africa reported problems from smoke and smell from incinerators installed in schools, along with concerns about the emissions released.

Study 5, a multi-stakeholder consultation, showed that the guidelines put forward by the CPCB and the MHM were not enforceable on the ground. The commercial incinerators present in the market in the small and medium-scale category, do not comply with minimum standards, thus causing incremental harm to the environment. In the absence of a monitoring mechanism, there are little to no consequences if incinerators do not comply with the emission standards. There is no provision regarding disposal of ash residue that is generated as a result of burning of sanitary products in such unmonitored incinerators.

Study 6 shows that in spite of the present market products not complying with basic norms, they are being procured in large numbers by both government and private organisations under national programmes like SBM, Sarva Siksha Abhiyaan or as part of CSR activities. 19 states in India are planning to install such incinerators in various places including schools, colleges, hostels, gram panchayats, etc.

The pushback

For all these reasons, from 14th December to 22nd February 2023, ‘whyburnwaste ran a dedicated campaign to focus on the problems associated with these small incinerator machines placed unsuspectingly in school toilets, girls hostels, offices, etc. ‘whyburnwaste’ — a campaign designed and led by Divya Tiwari, Sowmya Raghavan and myself  — addresses incineration and burn technology, more popularly known as ‘WtE’ or Waste to Energy. Through a series of data driven posters, films and talks, we hope to reach citizens, administrators and policy makers and help them make informed decisions.

Read more: “Hear us today, for life tomorrow”: Pleas against Bandhwari Waste to Energy Plant

Citizens from Pune also petitioned the National Green Tribunal (NGT) on the technical tender terms omitting twin chambers and a minimal 950°C operating temperature. In an interim order, the NGT has ruled that as per SWM Rules 2016,

  • Sanitary pad incinerators must have twin-chambers
  • Operating temperatures must be 800°C or higher

Small incinerators are getting questioned at multiple forums which demand a fool-proof plan and provision for their design, standardisation, certification, procurement and instalment in schools and colleges. The government should ensure that incinerators are scrutinised not only by the pollution control authorities but also third-party agencies.

Call to action

For the government:

Concerted efforts should be made to reduce the volume of this waste. This film on Siddipet district in Telangana shows almost 84.1% of menstruating women switched to using sustainable alternatives (cloth pads and menstrual cups) enabled by a government and NGO partnership under the leadership of MLA Harish Rao.

A gram panchayat in Mysore has shown 94% conversion with a push from the Panchayat Development Officer Shobha Rani and these models are being replicated in Rajasthan through the Anganwadis. More villages and cities should adopt this model to reduce the dependence on disposable plastic pads and the need to burn them. 

Environmental Impact Assessment (EIA) should be done on small incinerators and deeper studies commissioned to ensure that there is enough data to guide policy, manufacturing and sales around them and the materials they burn. There needs to be specific guidance on single or dual chambers, operating temperatures, emissions, safety and quality standards, etc.

Multiple emission testing facilities should be set up pan-India. The monitoring protocols and law enforcement procedures should be periodic and stringent.

A deeper focus on EPR led management of sanitary waste could help considering that our country does not have enough Common Bio-medical Waste Treatment Facilities (CBWTF) to manage the total waste generated.

The government must take proactive steps to stop vending single-use disposable pads.

For Urban Local Bodies & Gram Panchayats:

ULBs must ensure a separate collection for sanitary waste and manage it in the CBWTF run in the cities which are well operated and monitored. Increasing their capacity makes more sense than installing lakhs of these uncertified units. None of the developed nations have installed these small-scale incinerators.

In Mumbai, an NGO in partnership with Thane Municipal Corporation and Thane citizens has initiated separate sanitary waste collection from 1000 homes which is being managed in the Hazardous Waste Facility of the city.

IEC programmes should be undertaken to make young girls, parents and institutions aware about the dangers of burning sanitary waste in small, unmonitored machines running at low temperatures.

Ensure through notifications and inspections that unregulated machines are not installed which do not meet the standards set by the SWM Rules 2016.

For citizens:

Citizens must question how their sanitary waste is being disposed of by the municipality. They must insist that it should not find its way to the landfill, dumpsites or open grounds. They should ensure that there is a running CBWTF or Hazardous Waste Facility in their cities and the sanitary waste is sent for disposal to these facilities. 

Sustainable menstruation is catching up fast in urban India. There are multiple options of either using cloth pads that are reusable, menstrual cups or period underwear.

Read more: A woman’s first guide to sustainable menstruation

Citizens must write to the State Pollution Control Boards and alert their ULBs if they see unmonitored incinerators being installed without the test certificate from an EPA recognised/accredited laboratory.

The challenge is real and in the now. We need to step up action on all fronts before this problem gets out of hand and causes further damage to human health and our environment.

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