Toxics Link has welcomed the draft guidelines on electronic waste management announced by the Central Pollution Control Board, Ministry of Environment and Forests, but added its reservations over the lack of focus on creating systems and institution for management of waste.
In a letter to the Secretary, Ministry of Environment & Forests, Ms. Meena Gupta, the environmental group highlight these concerns.
Following are excerpts from the letter:
"While the guidelines have very detailed technical recommendations, which of course is very important, we feel that it requires an additional layer of systems oriented approach for the problem to be solved. It is such a framework which we find lacking in the guidelines.
As we have learnt from the experience of lead acid battery rules, the problem is the less of technology but more of institutional arrangements for waste to be collected, recycled, finally treated or disposed off. In India this is further complicated by the existence of informal sector mechanism of recycling.
It is important that proper waste management systems be put up for E-waste. However the issue of collection (as is in the case of lead acid battery) is key. Proper recycling facilities with appropriate technologies can only be set up if they are ensured that the collected waste will reach them. Its for this purpose that we need systemic approach which we have also proposed in a model (also enclosed herein) which we have earlier shared with the Ministry as well as with other important stakeholders like industry associations and potential recyclers.
Very briefly we would like to suggest that:
a) A collective collection system (PRO – Producer Responsibility Organization) be set up in each city. Such a PRO will have industry participation as well as participation from existing informal sector collectors, as well as other stakeholders.
b) The PRO should have tie-ups with recycling units which are either existing or are new which ensure that e-waste is properly channelised.
c) The system will be that the PRO collects the material in association with the municipality and existing informal sector, channelise this to a dismantling unit and further diverts separate components to appropriate designated recyclers.
d) Such recycling units should have mandated ESM procedures. We believe that such an arrangement will ensure that e-waste is properly channelised to the appropriate recycling units.
e) There be a complete ban on the import of e-waste as is also being followed under Basel Convention.
f) Separate set of guidelines be set up on the lines of the European ROHS directives.
Finally we would like to add that it may not be sufficient to bring the issue of e-waste under all the provisions of the existing Hazardous Waste and Municipal Waste Rules but needs separate set of rules should be set up for this purpose. The reasons for this are as follow:
a) E-waste has scattered generation from households, businesses, govt. etc. (similar to Bio-medical waste generation) and Hazardous Waste rules are intended to cover only registered waste generations, such as industry.
b) Municipal Waste rules largely deal with municipal functioning but are quite silent on the recycling activity. This activity is most critical part of E-waste handling. If anything the situation of e-waste is more akin to Bio-medical waste and set of rules geared to this will enable an adequate solution which of course is the intention of such exercise."