Who is a ‘Bulk Generator’ of solid waste?

BBMP has classified gated communities as bulk generators of waste, putting them on par with the commercial category. Here are the rules which govern them.

Bengaluru generates 6000 tons of garbage per day from various entities. BBMP as the local government and the nodal agency in charge of solid waste management, has categorised waste generators into bulk and non-bulk categories. According to estimates, over 1500 tons of waste is generated by Bulk Generators (BGs).

Classification of Bulk Generators

Bulk Generators have been classified into three categories, as per BBMP’s circular JC(SWM)/PRF/e-17410/2021-22 dated 30th Mar 2022:

Apartments, Multi dwelling units, gated communities housing greater than 100 Units.Academic institutions, government departments and undertakings, religious institutions, hospitals, hospitality industry, Corporates, etc.All commercial entities which generate on an average more than 100 kgs of waste per day and/or located in an area above 5000 sq. metres.
– This includes any commercial entity which requires a Trade Licence to operate.
– Petty retailers, street vendors, Hawkers or temporary stall
holders, small scale cottage industry, etc.

Read more: Madiwala market’s journey of managing its waste problem

Bulk Generators’ classification for residential category has been increased from 50 units and above or 10 kgs of waste per day to 100 Units. In case of commercial/institutional categories, it has been increased to 100 kgs of waste per day and/or located in an area above 5000 sq mts.

Duties of a Bulk Generator

housekeeping staff segregating waste
Housekeeping staff in an apartment collecting waste as per the 2Bin1Bag model. Pic: 2bin1bag

Under the BBMP SWM Byelaws 2020, segregation and storage guidelines have been laid down – all BGs have to segregate their solid waste into different categories at their premises/source:

  • Biodegradable/wet waste – kitchen, garden and horticulture waste – stored in green bins, without plastic liners
  • Non-biodegradable/dry waste – plastic, cartons, disposable waste (food containers to be cleaned and dried for easy recycling) and e-waste – stored in blue bins.
  • Domestic hazardous waste and sanitary Waste (wrapped in paper) – stored in a red bin.
  • Construction and Demolition (C&D) waste.

How should Bulk Generators dispose of waste?

All BGs must ensure segregation and processing of solid waste at source, as per the SWM bye-law, and failure to do so will be liable for punishment.

The options for managing waste :

When a complex/establishment goes in for in-situ compositing:
Wet waste has to be handled within the premises, at their own cost. This involves identifying a place to install the composting infrastructure, sorting, etc.
1. In exceptional cases, where there is no land/space for managing waste in-house – segregated wet waste is sent to composting sites through Authorised Waste Processors (AWPs).
2. Dry waste and other waste is to be sent to either an interim transfer point from where it is further segregated by the AWP and sent to different recyclers.
3. Rejects / Bio-waste – are sent to incinerators.
4. Inert waste – to be sent to recovery sites.
5. Mixed/uncategorised waste is sent to a private landfill.

BGs are required to engage Authorised Waste Processors (AWPs – erstwhile empanelled vendors) to dispose of dry, rejects, inert waste, etc. As an exception however, in cases where in-situ composting is not possible (due to lack of space), BGs can engage AWPs to dispose of segregated wet waste too.

BBMP Auto tippers on the road
BBMP tipper autos ferrying waste. Pic credit: Pinky Chandran

Read more :  How Bengaluru is targeting 100% segregation of waste by December 2019: BBMP’s new SWM bye-laws

How should Bulk Generators find a suitable vendor?

BGs are required to do due diligence while engaging a vendor. The list of documents to be provided by the AWP vendors are:

  1. Company Registration details
  2. BBMP Empanelment Letter
  3. BBMP Compliance Certificate for capacity
  4. Labour Compliance Certificate
  5. Authorisation letters for Interim Transfer Point, End Destination for wet waste processing, dry waste processing, etc.
  6. Transportation: Agreement for outsourced vehicles/own vehicles and related documentation
  7. 3rd Party agreements:
    • Copies of agreements with recyclers
    • Private landfill and/or scrap dealer
    • Recyclers and private landfills must produce KSPCB approval letters

Relevant forms to be submitted and fines for non-compliance are listed in the SWM Bylaws 2020.

A study by the Compost Connect Initiative by SWMRT and Bangalore Apartment Federation (BAF) shows the segregation levels in apartment complexes is as high as 90%.

One reason for such high segregation levels is because apartments are considered bulk generators (BGs) and they manage their own waste; collection is done by their housekeeping staff and disposed off either via in-situ composting or through private contractors/AWPs. However even as they manage their own solid waste, Bulk Generators still have to pay the Garbage Cess to BBMP.

Lack of clarity on Bulk Generator responsibilities

The latest notification has detailed the kind of institutions and commercial entities which are brought under the ambit of BGs. There are however, several clauses under the new circular that raise a lot more questions than answers. Here are some of the highlights of the circular:

  1. While BGs have been asked to go in for in-situ compositing, there is however no clarity whether it is mandatory or recommendatory.
  2. It is not clear whether BGs have the freedom to decide on the composting method. BBMP has put the onus on KSPCB to decide on the technology. Activists are apprehensive that 24 hour composting machines such as Organic Waste Composters (OWC) will become mandatory.
  3. BGs have been given an option of sending their biodegradable waste to piggery farms, however currently there is no clarity on either the piggeries’ capacity or the mechanism of transportation.
  4. While the circular alludes to penalisation, the how and who is not specified. Who will be in charge of the monitoring/enforcement; the Health department or SWM department?
  5. Who will determine the lack of space for in-situ compositing?
  6. The current empanelment is cumbersome, with quarterly renewals. AWP/empanelled vendors have demanded a longer (3 years), cleaner and easier empanelment process.

In the past, a self reporting mechanism called BGnet was created, which failed to take off. Currently BBMP does not have data on the number of Bulk Generators. If BBMP can iron out the issues in processes and regulations, Bengaluru’s solid waste management situation can become much better.

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