SANITARY WASTE

MANAGEMENT IN INDIA
CHALLENGES AND AGENDA
 SANITARY WASTE
MANAGEMENT IN INDIA
CHALLENGES AND AGENDA
 Research direction: Atin Biswas

Author: Shailshree Tewari

Editor: Archana Shankar

Cover: Ajit Bajaj

Layout: Kirpal Singh

Production: Rakesh Shrivastava and Gundhar Das

We are grateful to the Norwegian Ministry of Foreign Affairs for its support.

© 2022 Centre for Science and Environment

Material from this publication can be used, but with acknowledgement.

Citation: Atin Biswas and Shailshree Tewari 2022, Sanitary Waste Management in India: Challenges and Agenda,
Centre for Science and Environment, New Delhi

Published by
Centre for Science and Environment
41, Tughlakabad Institutional Area
New Delhi 110 062
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Website: www.cseindia.org
Contents

1. INTRODUCTION 7

2. CURRENT LEGISLATIVE FRAMEWORK FOR SANITARY WASTE

MANAGEMENT IN INDIA 11.
2.1 SOLID WASTE MANAGEMENT RULES, 2016 11
2.2 CPCB GUIDELINES FOR MANAGEMENT OF SANITARY WASTE 11
2.3 MENSTRUAL HYGIENE MANAGEMENT NATIONAL GUIDELINES 12.
2.4 DISPOSAL OF MENSTRUAL WASTE UNDER THE GUIDELINES
FOR SWACHH BHARAT MISSION (SBM)-URBAN AND SBM-GRAMIN 13

3. SANITARY WASTE MANAGEMENT IN INDIA 15

4. DISPOSAL OF SANITARY WASTE THROUGH INCINERATION 18

4.1 CENTRALIZED INCINERATORS FOR DISPOSING OF SANITARY WASTE 23
4.1.1. Key challenges of centralized management of sanitary waste 24
4.2 DECENTRALIZED INCINERATORS FOR DISPOSING OF SANITARY WASTE 26
4.2.1. Key challenges of decentralized management of sanitary waste 28

5. CENTRALIZED INCINERATORS 31

6. ALTERNATIVE SANITARY PRODUCTS AND METHODS OR DISPOSAL 34

6.1 DISPOSAL IN LATRINE PITS 40
6.2 DEEP BURIAL 40
6.3 COMPOSTING 41
6.4 CLAY-POT OR MATKA BURNING 41

7. RECOMMENDATIONS 44

REFERENCES 53

5
 List of tables
Table 1: Technical specifications and standards as per CPCB Guidelines, 2018 20
Table 2: Emission standards as per SWM Rules, 2016 21
Table 3: Compliance of small-scale incinerator options as per SWM Rules, 2016 22
Table 4: Decentralized incinerator market landscape in India 28
Table 5: Advantages and disadvantages of various sanitary products 35
Table 6: Current alternative sanitary products and their lifespan 35
Table 7: Current methods of disposal for alternative sanitary products 39
Table 8: Recommended disposal options as per CPCB Guidelines for Sanitary
Waste Management 39
Table 9: Overview of different sanitary waste disposal options 42
Table 10: Roles and responsibility of various stakeholders 47

List of graphs
Graph 1: Growing usage of sanitary napkins in India 9
Graph 2: Estimated percentage of sanitary waste in municipal solid waste in India 10
Graph 3: Major concerns related to menstrual waste 18
Graph 4: State-wise status of common biomedical waste treatment facilities 24
Graph 5: Sanitary waste generation in Karad 32

List of figures
Figure 1: Estimated usage of sanitary napkins in India 7
Figure 2: Components of a sanitary napkin 8
Figure 3: Components of a diaper 9
Figure 4: Sanitary waste management in India 15
Figure 5: Sanitary disposal practices in India as per MHM Guidelines, 2015 16
Figure 6: Sanitary waste disposal practices in India 17
Figure 7: Impact of incomplete burning of disposable sanitary napkins 22
Figure 8: Strategy for the IEC campaign. 31
Figure 9: Sanitary waste management in Karad 32
Figure 10: Comparative analysis of waste generated by three different types of
sanitary products 36
Figure 11: Deep burial pit 40
Figure 12: Process flow diagram of sanitary waste management 46
Figure 13: Cross-sectional view of disposable eco-friendly sanitary napkin 51

6
1. Introduction

According to the Solid Waste Management Rules (SWM) Rules, 2016, used
sanitary napkins, diapers, condoms, tampons, incontinence sheets and any other
similar waste are classified as sanitary waste, and should be disposed of properly
with dry waste.1

Sanitary waste management has had limited attention due to societal and cultural
taboos. Even though it fits squarely within the scope of waste management, it must
be treated with adequate importance, with policy and implementation mandates.

According to advocacy group Menstrual Hygiene Alliance India (MHAI),2

assuming 36 per cent of women or girls in India use disposable sanitary napkins
regularly at an average rate of eight sanitary napkins per month, 336 million
menstruating women and girls use about 1 billion sanitary napkins per month,
or 12.3 billion sanitary napkins annually. This works out to 33 million disposable
sanitary napkins per day. Assuming the average weight of a soiled napkin is 11.3 g,
with the average blood and other fluid loss per day during menstruation 8 ml and
average weight of a sanitary napkin 10.5 g,3 India generates approximately 137,483
tonne of used sanitary napkins annually, or 377 tonne daily.

Figure 1: Estimated usage of sanitary napkins in India

1 billion
sanitary napkins

8
36% per month

64% per 12 billion

cycle sanitary napkins
annually

336 million Use other materials 121 million

menstruating Use sanitary pads women and girls
women and girls use
in India sanitary pads

Source: MHAI. Graphic prepared by CSE

7
SANITARY WASTE MANAGEMENT IN INDIA

Figure 2: Components of a sanitary napkin

Layers of conventional sanitary napkin

Top layer: Perforated plastic

sheet (polypropylene [PP] and
polyethylene [PE])

Synthetic chemicals: Artificial perfumes,

heavy metal dyes

Transfer layer: Synthetic fibres or

cellulose-based pulp

Absorbent layer: Sodium

polyacrylate (SAP)

Adhesive: Polyurethane (PUR)-based

hot melt glue

Bottom layer: Petrochemical-based

polyethylene (PE)

Release paper: Silicone-coated paper

Source: Ingredients Used in Conventional Sanitary Pads, Sparkleuser, 2020; graphic prepared by CSE.

As per the National Family Health Survey (NHFS-4), a country-wide survey

conducted by the Ministry of Health and Family Welfare, Government of India, with
the International Institute for Population Sciences serving as the nodal agency,4
around 41.8 per cent of women in the age group 15–24 use disposable sanitary napkins
while 16.4 per cent use locally produced napkins. According to recent government
statistics, use of disposable sanitary pads is continually increasing among women
aged 15–24. In Bihar, for example, 58.8 per cent of girls and women in this age group
used such products, an increase of nearly 90 per cent in just four years, i.e. 2016–19.
Their use increased to 85.1 per cent in 2019–20 in Andhra Pradesh, up from 67.5 per
cent in 2015–16. A similar trend is seen in most Indian states.5

In the context of baby diapers, a one-month-old infant typically has three to four
bowel movements a day and wets at least six or more diapers a day, adding up
to six to 12 disposable diapers a day.6, 7 Assuming a one-month-old infant uses
10 diapers a day—or 300 diapers per month—a single one-month-old baby
could generate around 3,600 used diapers every year. According to the United
Nation Children’s Fund (UNICEF), 25 million children are born in India each
year8 and the average weight of the soiled diaper is 800 g.9 India thus generates
approximately 548 tonne of baby diaper waste daily, or 200,000 tonne annually.

8
 CHALLENGES AND AGENDA

Graph 1: Growing usage of sanitary napkins in India

Percentage of women using napkins

90 84.8% 85.1%
83%
80
70 66.3% 66.1% 67.5%
60 58.8%
54.9%
50 44.8%
40
31%
30
20
10
0
Bihar Assam West Bengal Maharashtra Andhra Pradesh

2015–16 2019–20

Source: National Family Health Survey, 2020

Figure 3: Components of a diaper

Elastic Back tape Fastening hook
Fastening tape

Absorbent core Top sheet

Frontal tape Backer sheet

Source: Review on convenience and pollution caused by baby diapers, Aishwariya-Sachidhanandham, Research Gate, 2020. Graphic
prepared by CSE.

According to Ministry of Housing and Urban Affairs (MoHUA) data, India

generates around 141,000 tonne of solid waste per day. CSE estimates that
India’s consolidated daily generation of sanitary napkins and baby diaper waste
(excluding adult diapers, tampons, condoms, incontinence sheets, and similar
waste) is approximately 925 tonne, which accounts for 0.65 per cent of total solid
waste.

Given the increasing volume of sanitary waste, including sanitary napkins, diapers,
tampons, condoms, incontinence sheets and similar items, the total percentage of
sanitary waste in municipal solid waste could reach approximately up to 3–4 per
cent. The percentage may not seem much, but sanitary waste is voluminous and

9
SANITARY WASTE MANAGEMENT IN INDIA

Graph 2: Estimated percentage of sanitary waste in municipal solid waste in India

0.65%

Sanitary waste
Municipal solid waste

99.35%

Source: CSE 2022.

Note: Only disposable sanitary napkins and baby diapers have been considered.

infectious in nature, and plastic is a primary material used in the manufacture of

disposable sanitary products, underlining the need for sanitary waste management
in India.10 Due to unorganized sanitary waste management in cities and villages,
poor source segregation, and inadequate collection, transportation and disposal
networks, most sanitary waste ends up in landfills mixed with solid waste or
dumped openly, posing significant health and environmental hazards.

Over the past few years in India, many government bodies such as the Central
Pollution Control Board (CPCB), Ministry of Health and Family Welfare
(MoHFW) and Ministry of Jal Shakti, Department of Drinking Water and
Sanitation (DDWS) have promoted policies on sanitary waste management and
menstruation hygiene management (MHM). The government initiatives are
primarily aimed at disposing of sanitary napkins. There have been hardly any
documented measures for collecting and disposing of other sanitary waste such as
tampons, condoms, incontinence sheets, and other similar waste in the country.

There are no comprehensive statistics on sanitary waste management in

India. Sanitary waste is likely to have long-term impact on health and adverse
environmental consequences unless a science-based solution is found.

This report highlights the key concerns regarding the increasing quantity of
sanitary waste. It identifies the critical challenges associated with current sanitary
waste disposal practices in India with evidence-based learning and policy measures
to be considered going forward.

10
2. Current legislative
framework for sanitary waste
management in India

There are two major legal frameworks for sanitary waste management: the Solid
Waste Management (SWM) Rules, 201611 and the Central Pollution Control Board
(CPCB) Guidelines for Management of Sanitary Waste, issued in 2018.12 The CPCB
guidelines cover a wide range of sanitary waste disposal alternatives, including
the types of waste that each option can handle, where they can be adopted and
implemented, and the technical specifications or pollution control standards that
may apply to their manufacturing process and usage. The SWM Rules, 2016 also
discuss the role of various stakeholders in the process. Apart from the SWM Rules,
2016, other government initiatives address sanitary waste treatment and disposal
methods.

2.1 Solid Waste Management Rules, 2016

According to the Solid Waste Management Rules, 2016:
• Sanitary waste includes used sanitary napkins, diapers, condoms, tampons,
incontinence sheets and other similar waste. Sanitary napkins and diapers are
also included in the definition of dry waste in the SWM Rules, 2016.
• Every waste generator must collect and segregate all waste into three categories:
biodegradable, non-biodegradable and domestic hazardous waste. In the case
of sanitary waste, the waste generator must wrap the used product in the
manufacturer’s pouches or any other suitable wrapping material as directed
by the local authorities and collect it with other non-biodegradable waste.
• Sanitary waste manufacturers must consider using recyclable materials or
provide covers, wrappers or bags for disposal after use. They must also raise
public awareness on adequately collecting and disposing of sanitary waste.
• Local authorities must use information, education,and communication (IEC)
initiatives to raise awareness on the various provisions under the SWM Rules,
including the handling and disposal of sanitary waste.

2.2 CPCB Guidelines for Management of Sanitary Waste

According to the CPCB Guidelines for Management of Sanitary Waste:
• A user must dispose of sanitary waste in the wrapper or pouch provided by the

11
SANITARY WASTE MANAGEMENT IN INDIA

manufacturer. If not provided, the sanitary waste should be wrapped in an old

newspaper and disposed of it with other non-biodegradable waste.
• A sanitary waste producer or manufacturer must provide packing material
that can be utilized for disposal and help local agencies achieve segregated
sanitary waste collection and disposal.
• Authorized waste pickers may undertake incineration as a commercial service.
If a nearby centralized biomedical waste treatment facility has sufficient
capacity, these waste pickers may also collect sanitary waste and dispose of it
in such treatment facilities.
• Where standard incinerators are unavailable, state pollution control
boards (SPCBs) may allow the sale of small, decentralized incinerators.
Any small incinerator unit manufactured or marketed must meet emission
standards prescribed under lawor by the SPCBs. The SPCBs are also responsible
for coordinating awareness campaigns with other ministries and government
entities, identifying resources for implementation and organizing orientation
training for various officers and staff across departments and ministries.
• Urban local bodies (ULBs) shall ensure that all collected waste is disposed
of through sanitary waste disposal alternatives—incinerated in treatment,
sent to storage or disposal facilities or centralized biomedical waste treatment
facilities, or fed into waste-to-energy treatment plants. ULBs may also establish
small community-incinerators in their areas.
• ULBs may receive assistance from women in the design and construction of
menstrual hygiene management (MHM) infrastructure and private entities
and commercial or industrial groups for improved product design and more
environmentally friendly usage and disposal methods. They should ensure that
the MHM requirements are followed, and they should also conduct training
sessions in schools and communities.
• Homemade and biodegradable sanitary products can be disposed of in a burial
pit at least 50 cm deep in rural areas and at the panchayat level. Commercially
manufactured sanitary products can be burned at low-cost incinerators such
as matka incinerators.

2.3 Menstrual Hygiene Management National Guidelines

• The Menstrual Hygiene Management (MHM) Guidelines were published in
2015 by the Ministry of Drinking Water and Sanitation in collaboration with
UNICEF India.13 The Guidelines are an essential aspect of the Swachh Bharat
Mission (SBM). As per the Guidelines, all MHM budgetary requirements can
be met from the SBM budget. Any Information, Education and Communication
(IEC) programmes on MHM can be undertaken from the SBM’s IEC campaigns
budget. Incinerators can also be purchased for school use.

12
• The guidelines are divided into three categories. The first category of guidelines
focuses on the MHM framework and covers the ways in which adolescent girls
and women can be offered MHM options, MHM infrastructure in schools,
and safe menstrual waste disposal methods. The second category details
the role and responsibility of various government organizations and other
relevant stakeholders. The third category addresses the technical details of
various disposal methods.
• To collect sanitary waste, separate bins should be used, with a designated
schedule for disposing of and properly transporting such waste.
• The available budget, amount and type of material are the significant factors
while selecting the appropriate disposal solution for menstrual waste. In
addition, sociocultural attitudes may also determine the method’s selection
and implementation.
• The disposal and treatment solution chosen must ensure minimal human
involvement and no adverse environmental impact. If a hospital with a
hazardous waste treatment facility is located nearby, the disposal option can
be incorporated into the procedure.

2.4 Disposal of menstrual waste under the Guidelines for

Swachh Bharat Mission (SBM)-Urban and SBM-Gramin
The Guidelines for Swachh Bharat Mission (SBM) (Urban)14 and SBM
(Gramin)15 outline the following:
• Disposal of menstrual waste, emphasizing the segregation and collection of
sanitary waste. Sanitary napkins and diapers must be separated, specially
marked and sent to a biomedical waste for incineration.
• One of the essential specifications for constructing community toilets is
installing small-scale incinerators in toilets with more than ten 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.

The aforementioned legislative is either available as guidelines or advisory issued

by various government bodies. However, they are not mandatory, and non-
compliance with these guidelines imposes no penalty or legal offence on anyone.
Further, each of these policies has a different approach for treating and disposing
of sanitary waste, which can cause problems with implementation.

Further, the categorization of sanitary waste, whether biomedical or plastic waste,

has been a significant issue. Sanitary napkins, diapers and condoms are classified

13
SANITARY WASTE MANAGEMENT IN INDIA

as household wastes and should be disposed of along with dry waste as per CPCB
Guidelines and SWM Rules, 2016.16 However, waste contaminated with blood or
other bodily fluids is classified as biomedical waste under Category 6, Schedule I
of the Bio-Medical Waste Management Rules 2016.17 Under the same schedule,
Category 2, biomedical waste includes organs, body parts, tissues and bleeding parts
of animals. This addresses why sanitary waste, especially menstruation waste, is
not classified as biomedical waste. According to the Bio-medical Rules 2016, such
biomedical wastes should be microwaved or autoclaved to kill pathogens rather
than burying them in landfills as potent viruses like Hepatitis B and C can survive
even in a drop of blood or any other fluid, posing a threat to the environment
and humankind. Similarly, sanitary items include hazardous germs that can cause
diseases in those who work in landfills, and harm the environment by eroding
lands, soil, and waterbodies.

The lack of synergy between the government authorities and differences in

capacities make it challenging to resolve inconsistencies between the laws with
regard to the existing legal framework of sanitary waste management. The
multiplicity of laws causes ambiguity in the actual process to be adopted. There
are no comprehensive statistics on this subject that reflects our country’s concern
for sanitary waste management in India. These guidelines and policies are only on
paper and have not translated into action on the ground.

14
3. SANITARY WASTE
MANAGEMENT IN INDIA
Waste management is an end-to-end process that includes waste generation,
segregation at source, collection, treatment and disposal. Efficient disposal of
menstrual waste necessitates source segregation at the level of waste generation
(see Figure 4: Sanitary waste management in India).

Figure 4: Sanitary waste management in India

Generation of sanitary waste

Disposed of with mixed waste Disposed of segregated sanitary waste

Dumped in open Thrown Wrapped in

spaces and in dustbin Buried pouch or paper
waterbodies or with (rural) and thrown in
flushed in drains mixed dustbin along
and toilets waste with dry waste

Mixed waste Segregated

collected by sanitary waste
sanitation collected by
workers sanitation workers

Secondary segregation Secondary segregation

not practised practised

Small-scale Composting Disposed

Disposed Centralized Common decentralized (for of by open
Treatment in landfill incineration biomedical incinerator compostable burning
and facility facility (manually or material-
disposal (urban) (urban) electrically based
operated) sanitary
products)
Source: CSE

In India, where separate collection of sanitary waste is practised in only a few

cities, sanitary waste from residences or other public spaces is typically collected
alongside dry waste or mixed waste. As a result, sanitary waste is mixed with
other types of waste and disposed of in landfills or dumpsites unscientific and

15
SANITARY WASTE MANAGEMENT IN INDIA

indiscreet manner. Further, in each city the local authorities manage solid waste
management activities; therefore, different methods of sanitary waste disposal
have been adopted in different cities.

At the household level—except in a few cities such as Karad, Jamshedpur, Panaji

and Pune, where segregation systems have been implemented for sanitary waste—
sanitary waste is primarily collected with dry or mixed waste in most cities.
Further, disposal techniques differ between rural and urban areas. In rural areas,
where waste collection is less common, sanitary waste is disposed of by burning
or shallow burial, which pollutes the waterbodies and air and potentially impacts
both the environment and human health. In urban areas, where a waste collection
system is in place, sanitary waste is disposed of in a landfill or, if segregated,
disposed of by means of a centralized incinerators or decentralized incinerators.

At the community level, menstrual waste may be segregated in the case of

community users and public washrooms, depending on management. If the waste
is segregated, it is disposed of by means of decentralized incinerators or dumped in
a landfill. Due to the emerging focus on sanitary waste management and menstrual
hygiene management in India, educational institutes and government departments
in a few states such as Goa, Maharashtra and Tamil Nadu have formalized the
installation of decentralized incinerators in educational institutes and offices for
on-site disposal of menstrual waste.18, 19 According to the MHM Guidelines, 2015,
the following are the most common sanitary waste disposal practices (see Figure
5: Sanitary disposal practices in India as per MHM Guidelines, 2015).

Figure 5: Sanitary disposal practices in India as per MHM Guidelines, 2015

Common practice
UNSAFE
Throwing sanitary waste unwrapped into fields or rooftops

Wrapping sanitary waste in a paper or plastic bag and throwing it outside

Drying or wrapping sanitary waste in a plastic or paper bag and throwing it in a

dustbin (mostly in urban and peri-urban)
Burying sanitary waste for decomposing

Throwing sanitary waste in latrines or toilets

Burning sanitary waste (in rural and peri-urban areas)

Using small-scale incinerators (at the community or school levels)

Managed under municipal solid waste management system or burning in health clinics
SAFE (in urban areas)

16
 CHALLENGES AND AGENDA

It is evident that there is a dearth of awareness and organized sanitary waste

disposal infrastructure and disposal practices in rural and urban locations vary
greatly (see Figure 5: Sanitary disposal practices in India as per MHM Guidelines,
2015). In parts of India, women dispose of the sanitary napkins or cloth in drains
and potholes; some who are uncomfortable disposing of sanitary napkins in public
flush them in toilets. Many women do not use dustbins because they think it might
bring them disgrace as waste collectors might think poorly of them if they notice
soiled napkins.

Figure 6: Sanitary waste disposal practices in India

45 % 23% 15 % 25 % 9%
Use routine Throw away in Dispose of Dispose of Throw in toilets
waste disposal open spaces, drains, by burning by burying (flushing or
methods or rivers, wells, lakes, or pit latrine)
dustbins roadside

Source: Menstrual Hygiene Management, WaterAid, 2019. Graphic prepared by CSE.

Sociocultural constraints such as myths and taboos play a major limiting factor
and aggravate the problem. Community-specific beliefs have a significant impact
in determining proper disposal options. In India, some communities believe that
burning menstrual waste might harm family members, and any sanitary waste
disposal practice that involves burning is unlikely to be accepted.

To manage sanitary waste effectively, it is critical to consider other aspects

of waste management, starting with continuous Information, Education and
Communication (IEC) and followed by source segregation, proper waste
collection and transportation, and sanitary waste handling and disposal. The
MHM Guidelines and CPCB Guidelines have accelerated incineration utilization
to dispose of and treat sanitary waste. Many states have installed decentralized
incinerators at the community and institutional levels.

17
 4. Disposal of sanitary waste
through incineration

Incineration involves burning waste at a high temperature and converting it to

ash. It has gained popularity for disposing of sanitary waste and is a favoured
technique of eradicating hazardous microorganisms in sanitary waste.

Sanitary waste takes long to decompose and is thus harmful to the environment. In
a survey conducted by New Delhi-based NGO Toxics Link,20 487 consumers were
asked if they considered sanitary waste to be a problem and if so what difficulties
they connected it with. Around 42 per cent of the respondents considered sanitary
waste a problem for the environment, health and hygiene. When environment,
health and hygiene were considered separately, an overwhelming majority—
around 92 per cent—identified sanitary waste as an environmental concern,
while 59 per cent identified it as a hygiene issue and 48 per cent of those polled
classified it as a health issue. A small percentage of respondents considered it an
occupational hazard for waste workers as well.21

Graph 3: Major concerns related to menstrual waste

Environment Health

H-1%
EH-5%
HyH-
HyHE- Hygiene
1%
E-35% 42%

HyE-
10% Hy-6%

E: Environment; EH: Environment Health; HyHE: Hygiene Health Environment; HyE: Hygiene Environment; H: Health;
HyH: Hygiene Health; Hy: Hygiene
Source: Menstrual products and their disposal, Toxics Link, 2021.

18
 CHALLENGES AND AGENDA

Currently, incinerators have been considered the most convenient means of

disposal since they allow for on-site treatment and disposal. However, most
incinerators are not certified to meet the Central Pollution Control Board
(CPCB) regulations. Low-cost incinerators often burn at low temperatures and
lack control over harmful pollutants released (i.e. they are carcinogenic). Girls,
students, school employees and workers who use or live near these incinerators
are at risk of developing health problems. Problems from smoke and smell from
incinerators installed in school along with concerns about the emissions released
from incinerators have also been reported.22

This chapter highlights the various government guidelines about the technical
specification and emission standards for incinerators to dispose of sanitary waste.
The CPCB Guidelines are intended to outline broad standards with which small-
scale incinerators must adhere. The CPCB Guidelines also include the technical
aspects of a biomedical waste incinerator, which are covered in detail under
Biomedical Waste Management Rules, 2016 (see Table 1: Technical specifications
and standards).

The Menstrual Hygiene Management (MHM) Guidelines issued by Ministry

of Drinking Water and Sanitation in India provides further technical guidance
for incinerators. They include a set of technical protocols for incinerators and
other disposal methods developed by UNICEF (United Nations Children’s Fund)
India. The guidelines, however, do not delve into many technical parameters
and only give information on available incinerator models. It may be that the
technical specifications and standards specified in the guidelines are prescriptive
and therefore not enforceable. The classification of incinerators and potential
specifications vary between the two sets of guidelines mentioned above.

The manual fire-based incinerator addressed in the MHM Guidelines is similar

to the low-cost, locally built incinerator under the Central Pollution Control
Board (CPCB) Guidelines on Sanitary Waste. In both the guidelines, however,
the prescribed standards for incinerators are different. The MHM Guidelines
focuses on electric incinerators. However, instead of offering a set of technical
elements for small-scale electric incinerators, it addresses other factors such as a
list of products available in the market, cost and potential application (see Table 1:
Technical specifications and standards as per CPCB Guideline, 2018 and Table 2:
Emission standards as per SWM, 2016).

19
SANITARY WASTE MANAGEMENT IN INDIA

Table 1: Technical specifications and standards as per CPCB Guidelines, 2018

Options Type of waste Where to use Specifications/pollution control norms

Low cost, Napkins and Rural girls- • Manually operated

locally made other wastes. schools, • Minimum size: 3 foot x 3 foot x 3 foot
incinerator Best for pads colleges, • Design: As per MHM Guidelines, technical guide
with high institutions, • Capacity: 200 napkins per day
cellulose hostels etc. • Comprises twin chambers
content, not • An emission control system with a door for firing.
those that have • Made of brick masonry
superabsorbent • The opacity of the smoke shall not exceed 20 per cent
polymers (SAP) • All the emissions to air other than water vapour or steam to be
odourless and free from mist, fumes, and droplets
• Operation temperature reaches up to 300 degrees Celsius
• Assures 100 per cent burning effectiveness
• The incineration chamber to be designed to use a supplementary
gas or oil burner as necessary to maintain the prescribed minimum
combustion temperatures.
• If diesel is used as fuel in the incinerator, low-sulphur diesel shall be
used.
• Shall comply with general emission standards for air pollutants
notified under E (P) Act, 1986 or as may be prescribed by state
pollution control boards (SPCBs) or Pollution Control Committees
(PCCs).
Electrically The bulk amount Ladies’ toilets, • Ensures complete burning of napkin.
operated of napkin wasters community • Ensures instant disposal in a scientific, hygienic way.
incinerators toilets, • Burns 150–200 napkins/day, programmed for multiple cycles.
shopping malls, • Self-disposal with sanitary waste placed directly into the incinerator.
society complex • Ash generation shall not exceed 5 per cent per napkin.
etc. • Ash should be collected in a separate tray and stacked on that tray.
• Auto power, thermal cut-off and automatic temperature maintenance
to be ensured for the safety of the user.
• Excellent heat retention ensured inside refractory lining to avoid
thermal loss.
• The residence time for gaseous products in the combustion chamber
will be designed to be at least two seconds to ensure complete
combustion.
• The emission from incinerators shall adhere to the General Emission
Standards mentioned under the section “Standards for incineration”
in SWM Rules, 2016.
High- Incinerate all Waste burned • Incinerator designed for a capacity of more than 50 kg/hour.
temperature types of pads at central/ • The dual-chamber Incinerator shall preferably be designed on the
incinerators and all types combined “controlled-air” incineration principle. Minimum 100 per cent excess
for biomedical of biomedical incinerator air shall be used for the overall design.
waste wastes facility • Incinerator shall not be allowed to operate unless equipped with Air
Pollution Control Device (APCD).
• The incineration ash shall be stored in a closely sturdy container in a
masonry room to avoid pilferage. Finally, the ash shall be disposed of
in a secured landfill.
• As per Schedule 11 of the Bio-Medical Waste Management Rules
2016, emission control measures must be followed, notified under the
Environment (Protection) Act 1986.
• The location, structural design, of the Incinerator shall be as per the
guidelines of Bio-Medical Waste Rules, 2016.
• A skilled person shall be assigned to operate and maintain the
incinerator.

Source: CPCB Guidelines 2018.

20
 CHALLENGES AND AGENDA

Table 2: Emission standards as per SWM Rules, 2016

Parameter Emission standard

Particulates 50 mg/Nm3 • Standard refer to half-hourly average

HCl 50 mg/Nm3 • Standard refer to half-hourly average

SO2 200 mg/Nm3 • Standard refer to half-hourly average

CO 100 mg/Nm3 • Standard refer to half-hourly average

50 mg/Nm3 • Standard refer to half-hourly average
Total organic carbon 20 mg/Nm3 • Standard refer to half-hourly average
HF 4mg/Nm3 • Standard refer to half-hourly average
NOX (NO and NO2 expressed 400 mg/Nm3 • Standard refer to half-hourly average
as NO2)
Total dioxins and furans 0.1 ng TEQ/Nm3 • Standard refers to six to eight hours of sampling.
Please refer to guidelines for 17 concerning
congeners for toxic equivalence values to arrive at
total toxic equivalence.
Cd+ Th+ their compounds 0.05 mg/Nm3 • Standard refers to sampling time anywhere
between 30 minutes and 8 hours.
Hg and its compounds 0.05 mg/Nm3 • Standard refers to sampling time anywhere
between 30 minutes and 8 hours.
Antimony (Sb+), arsenic (As+), 0.05 mg/Nm3 • Standard refers to sampling time of 30 minutes to
lead (Pb+), chromium (Cr+), eight hours.
cobalt (Co+), copper (Cu+),
manganese ( Mn+), nickel
(Ni+), vanadium (V+) and their
compounds
Note: All values corrected to 11 per cent oxygen on a dry basis.

Source: SWM Rules 2016.

Notes:
1. The appropriate pollution control equipment should be installed or connected with the incinerator to achieve the above emission
requirements.
2. Incinerated waste should not be treated chemically with chlorinated disinfectants.
4. The ash should be transported to hazardous waste treatment, storage and disposal facility if the concentration of harmful metals in
incineration ash exceeds the limitations provided in the Hazardous Waste Rules, 2016.
5. The incinerator should only burn low-sulphur fuels such as LDO (light diesel oil), LSHS (low-sulphur heavy stock), diesel, biomass, coal,
LNG (liquefied natural gas), CNG (compressed natural gas), RDF (refuse-derived fuel), and biogas.
6. The concentration of carbon dioxide in the exhaust gas should be less than 7 per cent.
7. All facilities with a dual-chamber incinerator should be engineered to achieve a minimum temperature of 950°C in the secondary
combustion chamber and gas residence time not less than 2 seconds in the secondary combustion chamber.
8. Incineration plants (combustion chambers) should be operated at a temperature, retention time and turbulence so total organic
carbon concentration in slag and bottom ash is less than 3 per cent, or a loss on combustion is less than 5 per cent of the dry weight.
9. Site odours should be controlled as per CPCB guidelines.

21
SANITARY WASTE MANAGEMENT IN INDIA

Figure 7: Impact of incomplete burning of disposable sanitary napkins

Disposable sanitary Incomplete burning of chlorine HIGHLY TOXIC AND

napkins contain and plastic results in release of CAUSES CANCER
CHLORINE noxious gases
AND PLASTIC DIOXINS AND FURANS

Non-compliance with these emission standards can release noxious gases such as
dioxins and furans. At present, most small- and medium-scale incinerator options
available in the market do not meet the minimum requirements and have limited
compliance with existing guidelines. Most incinerators are not certified to meet
the Central Pollution Control Board (CPCB) regulations. There are also reports
about smoke and smell from incinerators installed in school and concerns about
emissions released from incinerators.23 As is evident, decentralized small-scale
incinerators can cause detrimental effects on human health and the environment.

Table 3: Compliance of small-scale incinerator options as per SWM Rules, 2016

S. Type of incinerator >800 degrees Ash disposal guideline Emission control
no. Celsius provided? standards
1. Earthen pot (matka) No No, usually mixed with soil Non-compliant
incinerator
2. Low-cost locally made No No, usually mixed with soil Non-compliant
incinerator
3. Electrically operated Yes No, usually mixed with soil Most of the available
incinerator incinerators do not
comply with these
standards
Source: Compiled by CSE, 2022.

The incinerators available in the market adhere to only a few components of the
standards. Further, unlike other consumer electronic items, incinerators made in
India are not subject to any testing to confirm standard certification.

The authorities must therefore ensure the following critical requirements before
adopting any incinerator for disposing of sanitary waste. First, the incinerator
must burn waste at a temperature of at least 800 degrees Celsius to minimize

22
 CHALLENGES AND AGENDA

smoke and odour in accordance with WHO’s 2014 publication Safe Management
of Wastes from Health-care Activities.24 The CPCB Guidelines, however, prescribe
a burning temperature of only 300 degrees Celsius, which causes incomplete
burning of sanitary waste and releases highly toxic gases such as dioxins and furans.
Second, emission control standards stipulated by the Solid Waste Management
(SWM) Rules, 2016 must be followed. Third, after testing, ash generated from the
incineration process must be disposed of in a secure or sanitary landfill to have
limited contact with the environment.

4.1 Centralized incinerators for disposing of sanitary waste

In India, large-scale or centralized incinerators are present largely in urban
and semi-urban areas and used to treat biomedical waste or a combination of
biomedical waste and sanitary waste. Standards have been prescribed under the
Bio-Medical Waste Management Rules, 2016, and regulations and guidelines
framed under it. Incinerators at biomedical waste treatment facilities that can
incinerate more than 1,400 sanitary napkins a day come under the category of
large-scale or centralized incinerators.25

Centralized incinerator at a common biomedical waste treatment facility (CBWTF) in Agra

Source: CSE, 2022

One of the critical factors affecting the operation of any centralized incinerator
is source segregation. According to the Guidelines for Swachh Bharat Mission
(SBM) 2.0, waste generators must segregate all waste into four categories, namely,
biodegradable, non-biodegradable, sanitary waste, and domestic hazardous waste.
Source segregation in four fractions is still a significant challenge in many cities
in India. Most authorities collect waste only into two fractions—dry and wet.
Sanitary waste is collected along with dry fraction, which eventually ends up in
landfills, leading to air, soil and water pollution.

23
SANITARY WASTE MANAGEMENT IN INDIA

Several cities such as Karad, Jamshedpur and Pune, however, have made concerted
efforts over the last decade to address the issue of segregation at the ULB level
through the combined efforts of the municipal local body and citizens.

There are 207 operational common biomedical waste treatment facilities

(CBWTFs) in India, with a total incineration capacity of 621 tonne per day.26
Assuming the per day generation of sanitary napkins and baby diapers (excluding
adult diapers, tampons, condoms, incontinence sheets and other similar waste)
is 925 tonne, with the per day total incineration capacity of common biomedical
treatment units 621 tonne, there is a capacity constraint to treat sanitary waste
alongside biomedical waste. Failing this centralized arrangement, the majority of
sanitary waste ends up in landfills or dumpsites. CBWTFs need to stretch beyond
their capacity to run this ecosystem successfully as the volume of sanitary waste
continues to increase.

Graph 4: State-wise status of common biomedical waste treatment facilities

35 31
30 27
No of CBWTFs

25
20
20 18
14
15 12 11 11 11
10 8
5 5 5 6
4
5 2 2 3 3 1 2
0 0 1 1 0 0 1 0 1 1 0 0 1 0
0
Andaman and Nicobar
Andhra Pradesh
Arunachal Pradesh
Assam
Bihar
Chandigarh
Chattisgarh
Daman & Diu
Delhi
Goa
Gujarat
Haryana
Himachal
Jharkhand

Karnataka
Kerala
Lakshdweep
Madhya Pradesh
Maharastra
Manipur
Meghalaya
Mizoram
Nagaland
Orissa
Puducherry
Punjab
Rajasthan
Sikkim
Tamil Nadu
Telangana
Tripura
Uttarakhand
Uttar Pradesh
West Bengal
J&K

States

Source: Annual Bio-Medical Report CPCB, 2019–20 and SOE (State of Environment), CSE 2022.

4.1.1 Key challenges of centralized management of sanitary waste

Given the increasing quantum of sanitary waste and challenges associated with
their management, the following set of critical challenges must be addressed to
ensure the long-term viability of centralized incinerators.
• Lack of source segregation: One of the most significant challenges faced by
centralized incinerators is inadequate source segregation. The overall waste
management system is weakened due to a lack of source segregation. Except
for a few cities such as Karad and Pune, most cities segregate waste at source
only into two streams—biodegradable and non-biodegradable waste. Waste
should be separated at source into a minimum into four fractions—wet, dry,

24
 CHALLENGES AND AGENDA

domestic hazardous waste and sanitary waste—to avoid adverse health and
environmental impact due to improperly handled sanitary waste. In 2002, the
Panaji Municipal Corporation launched an initiative to segregate sanitary waste
at the household level and dispose of it at the Goa Medical College’s biomedical
incinerator. While this example was frequently recognized as a best practice
in the Indian context, Panaji eventually encountered difficulties maintaining
this sanitary waste disposal strategy since many houses discontinued
source segregation due to a lack of regular inspections and enforcement.27

• Inadequate infrastructure and services: Appropriate infrastructure and

services play a significant role in sustaining the overall waste management
system. A separate container or bag for storage of segregated sanitary waste
at source, collection vehicles with a minimum of four compartments, and
appropriate treatment and disposal facilities that use the right technology for
sanitary waste are required to make sanitary waste management efficient.

Collection vehicles in South Delhi Municipal Corporation (SDMC). The vehicles do not have a separate
container or compartment for sanitary waste

Source: CSE, 2022.

In India, sanitary waste is either disposed of with mixed or dry waste due to
which centralized facilities are sometimes hesitant to receive sanitary waste
from households. Waste management with insufficient infrastructure and
services affects systematic collection, transportation, treatment and disposal
of sanitary waste.

• Handling issues: In India, manual sorting is the most widely used and
accepted method of waste segregation. Most waste management steps such
as waste collection at source, waste transportation and even secondary
segregation require human contact. Sanitation workers at each step (door-to-

25
SANITARY WASTE MANAGEMENT IN INDIA

door collection to treatment facilities) must be informed about proper handling

of sanitary waste to ensure that sanitary waste does not come in direct contact
with sanitation workers, is not mixed with the other waste and is disposed of
scientifically.

• Capacity constraint: The capacity of an in incinerator at a centralizedbiomedical

waste treatment facility can dispose of only a limited amount of sanitary waste
at a time, posing a capacity constraint for sanitary waste disposal and resulting
in a large amount of sanitary waste left untreated or unprocessed This can
fail the city’s integrated sanitary waste disposal. In 2002, Panaji Municipal
Corporation launched an initiative to segregate sanitary waste at the household
level and dispose of it at Goa Medical College’s biomedical incinerator. While
this example is frequently recognized as a best practice in the Indian context,
Panaji eventually encountered difficulties in maintaining this sanitary waste
disposal due to the capacity constraint of the facility.

Goa Medical College’s common biomedical waste incinerator can only burn
40 kg of sanitary waste at a time. A huge quantum of sanitary waste is left
untreated and stored in a material recovery facility. The limited capacity of
the common biomedical incinerator has resulted in failure of Panaji’s sanitary
waste disposal ecosystem as their facilities have been stretched beyond capacity
while the volume of waste continues to increase.28

• Financial constraint: To dispose of sanitary waste, a few cities utilize existing

centralized biomedical facilities. However, there are no incentives for these
biomedical treatment facilities to collaborate with urban local bodies (ULBs)
in sanitary waste disposal, frequently managed by private entities. Lack
of financial support is a significant factor in forcing local authorities to pay
commercial rates for sanitary waste treatment. In addition, distance to the
nearest common biomedical waste treatment facility (CBWTF) increases
transportation cost, which imposes a financial burden on municipalities that
may already be struggling to develop sanitary systems due to lack of resources.

4.2 Decentralized incinerators for disposing of sanitary waste

Decentralized incineration for sanitary waste disposal has emerged in India
for promoting and improving menstrual hygiene management. Waste disposal
systems should to be installed near the source, need little human invention,
and should be used directly by the waste generator. Decentralized incinerators

26
 CHALLENGES AND AGENDA

are commonly installed at educational institutions, public spaces and offices.

Centralized incinerators on the other hand are large-scale biomedical waste or
sanitary waste treatment facilities that require a significant amount of land to put
up and are installed by local authorities. Small- and medium-scale incinerators are
two types of decentralized incinerators.

Types of decentralized electric incinerators

Size: Small-scale incinerator Size: Medium-scale incinerator

Capacity: Approx. 100–300 pads a day Capacity: Approx. 400–900 pads a day
Cost: Rs 10,000–25,000 Cost: Rs 30,000–70,000

Source: GeM Portal, Government of India

Note: Image for representational purposes only

Many states have issued tenders for decentralized incinerators to be installed

in various locations such as educational institutions, government offices and
hostels. Such incinerators are purchased either through a tendering process or
directly from an e-marketplace. Several states, such as Goa and Maharashtra, have
installed incinerators in educational institutions through financial assistance from
Rotaract Clubs or the corporate sector.

As per a 2019 study by the US-based initiative Sanitation Technology Platform

(STeP) and the Bill and Melinda Gates Foundation (BMGF), Menstrual Hygiene
Market (MHM) Landscape, the market opportunity for decentralized incinerators
in India has grown significantly.29 The statistics show that the market opportunity
for MHM incinerators in India is expected to grow at 3.84 per cent compounded
annual growth rate (CAGR), and the government is now the largest consumer
of decentralized incinerators (see Table 4: The decentralized incinerator market
landscape in India). That market is, however, expected to shift to the private sector
as more private organizations and educational institutes have begun procuring
decentralized incinerators to create awareness on menstrual hygiene management.

27
SANITARY WASTE MANAGEMENT IN INDIA

Table 4: Decentralized incinerator market landscape in India

• The market opportunity of decentralized incinerators in India is 1,371,890 units (in 2020)
Market size for and is expected to grow at a 3.84 per cent compounded annual growth rate (CAGR).
decentralized • The government is projected as the leading buyer (54 per cent) in 2020, but this is
incinerators projected to flip to the private sector (54 per cent) by 2030 as the private sector is
growing faster than the government sector (in aggregate across segments analysed).
• Combining quantitative and qualitative factors, private sector-controlled schools and
Key market
higher educational institutions (HEIs) (2.59 per cent CAGR) and offices (5.64 per cent
segments for
CAGR) are the most promising market segments for decentralized incinerators.
decentralized
• Incumbents primarily focused on schools and HEIs, making private offices an
incinerators
interesting target market segment for new decentralized incinerator developers.
Source: Compiled from Sanitation Technology Platform (STeP) and Bill and Melinda Gates Foundation (BMGF), Menstrual Hygiene
Market (MHM) Landscape, 2019.

4.2.1 Key challenges of decentralized management of sanitary

waste
Given the growing demand and market for decentralized incinerators for sanitary
waste disposal, the following set of significant challenges must be addressed before
their use is expanded.
• Standards for decentralized incinerators: Items such as APCD (Air Pollution
Control Device), combustion chambers, emission outlet pipe stack, detachable
ashtray used to manufacture the decentralized incinerators available on the
Government e-Marketplace (GeM) portal—or any other e-marketplace—are
inconsistent. Some of the incinerators do not meet CPCB’s emission standards.30
While CPCB’s guidelines are legally enforceable, a lack of standards for small-
scale incinerators attracts no penalty. Tenders for the purpose of procurement
of decentralized incinerators that are publicly available also reflect the same
concern.31

• Self-certification: As a result of self-certification of compliance, several

decentralized incinerators are available in the market that claims to be
environmentally sustainable. In the absence of regular monitoring and
inspection from the State Pollution Control Board, many state governments are
procuring decentralized incinerators that do not meet technical specifications
prescribed under CPCB Guidelines 2018. The possible consequences of
insufficient emission control or poor thermal treatment are hazardous to the
environment and human health.

• Lack of technical guidance: Many decentralized incinerators have fallen into

disuse due to users’ limited technical understanding of the machines and their
hesitation to use the machines. According to a 2012 comparative study in a
school in Nepal, 46 per cent of girls thought using the incinerator was simple,

28
 CHALLENGES AND AGENDA

5 per cent were hesitant, and 49 per cent had never used an incinerator due to
lack of technical guidance.32 Users should receive sufficient technical assistance
from the authorities before decentralized incineration units are installed.

• Taboo and myths associated with sanitary disposal: Women in Tamil Nadu
who used a community toilet were hesitant to put sanitary waste in common
bins and instead used latrine pits as a disposal technique because they did
not want to burn their sanitary waste. Burning sanitary waste is forbidden in
some cultures on the basis of the belief that doing so will jeopardize a woman’s
reproductive ability, making it more challenging to utilize decentralized
electric or clay pot incinerators.33

• Inappropriate placement of incinerator: Occupational hazards might arise

from improper installation of the decentralized incinerator. While incinerators
are convenient and allow for on-site disposal, there have been reports of broken
school incinerators not being utilized, issues with smoke and odour from
decentralized incinerators in schools, and concerns raised regarding emissions.34

There is a high risk of emissions entering the room if decentralized incinerators

are installed in confined rooms or toilet blocks and the vent stack/outlet
pipe is not long enough to reach a suitable height outside the room. In some
instances, privacy has often been overlooked for the design and placement
of incinerators.35 A straight duct should run from the toilet room to the
incinerator to ensure privacy; this design has been implemented in Tamil
Nadu.36 According to the Central Pollution Control Board (CPCB) guidelines,
the stack height must be at least 2 metre above the roof or the nearest building
or as determined by the State Pollution Control Board (SPCB). As can be seen
in the following image, the incinerator machine installed in a public toilet in
a park in Gurugram does not comply with this, which can have deleterious
effects on human health and the environment.

Decentralized incinerator installed in a public toilet in a park in Gurugram

Source: CSE,, 2022

29
SANITARY WASTE MANAGEMENT IN INDIA

• Disposal of ash: Most decentralized incinerators have a cut-off temperature

below 800 degrees Celsius. If sanitary waste is not burnt at the correct
temperature, the ash will likely contain residues of heavy metals and
chlorinated organic chemicals, such as dioxins, arsenic, lead and nickel,
which could affect human health and the environment. There is currently no
standardized protocol for ash disposal for decentralized incinerators, because
of which ash is disposed of indiscriminately.

• Functioning of incinerators: Every decentralized incinerator has an overall

capacity and run time for each incineration cycle. Further, specific models with
a higher capacity have a feed-in rate, which is the number of sanitary napkins
that may be placed in the burning chamber at a given frequency during the
run-time. Overloading might affect the quality of the burning process, causing
incomplete incineration and irregularities in the burning cycle in the long
term, putting the machine’s overall functioning at risk if the feed rate is not
rigorously monitored.

30
5. Centralized incinerators

Case study—Karad city

Karad city, in the state of Maharashtra, spreads over 10.51 sq. km and is divided
into two zones, North and South, with 14 wards and an estimated population of
86,000 in 2021. In 2001, the Karad Hospital Association was given a one-acre
stretch of land to build and commission a 600 kg/day biomedical treatment
facility. As a result, the Karad Municipal Corporation signed an agreement with
Karad Hospital Association to allow sanitary waste collected by urban local bodies
(ULBs) to be processed at the existing biomedical facility at no expense to the
ULB. However, the corporation had difficulties managing sanitary waste due to a
lack of awareness and source segregation.

In August 2021, the Municipal Council adopted a communication strategy and

began a comprehensive campaign to raise awareness among the citizens. IEC
activities and capacity-building programmes educated people about the health
and environmental consequences of improper sanitary waste management and
mixing it with the rest of municipal solid waste.

Figure 8: Strategy for the IEC campaign

Administration-elected
representative
Problem statement
and troubleshooting

Capacity building

Awareness Schoolgirls passing Schoolgirls forming groups

1. GREEN team
programme for school on the information in to create awareness in
2. Local volunteers
girls in classes 7–9 their locality other areas

Capacity
building Collateral distribution

Spreading awareness
1. Waste collectors Continuous 100 per cent sanitary waste
during door-to-door
2. Housekeepers monitoring separation achieved
collection

Source: Karad Municipal Council

31
SANITARY WASTE MANAGEMENT IN INDIA

In June 2021, the council introduced waste segregation into four fractions—
biodegradable, non-biodegradable, domestic hazardous and sanitary. Adequate
infrastructure and services to improve sanitary waste management was set up.
The facility was located on the same plot where biodegradable waste was brought
in for windrow composting and non-biodegradable waste for recycling at the
material recovery facility. The plot also houses a material recovery facility, so
integration of the whole system came at no extra transport cost.

Graph 5: Sanitary waste generation in Karad

3500
3086
3000

2500 2200
Quantity in Kg

2104
2000

1500

1000

500

0
Dec-20 Jan-21 Feb-21
Source: Karad Municipal Council

Figure 9: Sanitary waste management in Karad

Sanitary waste Removal of
compartment compartment

Incineration Weighing
sanitary waste

Source: Karad Municipal Council

32
 CHALLENGES AND AGENDA

By spending a small amount of money on IEC and modification of waste

collection vehicles, the city administration has been able to achieve the feat of
separate collection and scientific processing of sanitary waste. According to Karad
Municipal Council, a total of 11.919 tonne of sanitary waste was treated in October
2020–March 2021.37

The Karad Hospital Association handles the operation and maintenance of an

integrated centralized biomedical and sanitary waste facility. It is a one-of-a-kind
project in which a hospital organization has stepped up, partnered with an urban
local body (ULB), and demonstrated how to properly handle sanitary waste.

33
 6. Alternative sanitary
products and methods of
disposal

Regulations, guidelines, waste management practices and sanitary products

are continually updated. In India, 50 per cent of females use cloth sanitary
napkins; 45 per cent use commercial napkins; 13 per cent use both cloth remaining
6 per cent “don’t use anything” during menstruation.38

Sanitary waste is largely disposable commercial products like pads and tampons.
Polythene, cotton, rayon, polyester, cellulose and superabsorbent polymers
(SAPs) are used in commercial disposable sanitary napkins. It takes at least six
months for compostable materials to decay; plastics take hundreds of years. Most
commercial sanitary products are bleached and scented, and contain chlorine
and other chemicals that if not disposed of properly can have a negative impact
on the environment. Many women also opt for menstruation cups and reusable
cotton pads, which have little or no environmental impact. Many others choose
“biodegradable” sanitary napkins to switch to sustainable periods. There has,
however, been some debate regarding how sustainable these biodegradable
napkins are.39

Examples of eco-friendly sanitary products used by Indian women

Reusable cloth napkins Menstrual cup Compostable napkins

Layers of natural absorbent materials, such Menstrual cups are made of silicone or rubber Bamboo, banana tree fibre and water
as fabric and hemp plant fibre, are used to of medical quality. They must be cleaned and hyacinth are used to create layers of natural
make reusable cloth napkins. Some reusable sterilized after each cycle and stored in a dry absorbent materials that are compostable.
cotton pads contain a leak-proof lining place. They can last for up to five to ten years. They are single-use and can be used for
made of synthetic materials like polyester. They have a longer lifespan and produce less three to four hours.
They can be used for three to four hours waste than commercial disposable napkins.
after which they must be washed and dried.
They can last for a year or two. They have
a longer lifespan than commercial sanitary
pads and produce less waste.

34
 CHALLENGES AND AGENDA

Personal preference, culture, economic status, and availability in the local market
influence selection of sanitary product (see Table 5: Advantages and disadvantages
of various sanitary products). The pros and cons are dependent on social and
economic factors and vary with the local context. For example, in rural areas,
reusable cloth napkins are the most common sanitary product. However, urban
women prefer commercial napkins, and women and girls in a few metropolitan
cities have shifted to tampons or menstrual cups.

Table 5: Advantages and disadvantages of various sanitary products

Amount of waste Cultural
Sanitary product Affordability Accessibility
generated acceptance
Cloth-based napkins
Commercial disposable
napkins
Tampons

Commercial reusable napkins

Biodegradable disposable
napkins
Menstrual cups

Advantage Disadvantage
Source: Compiled from WaterAid 2012, Menstrual Hygiene Management.

Before discussing how environmentally friendly our biodegradable sanitary

napkins are, it is essential to understand why disposable pads are environmentally
damaging. Aside from waste generation from treatment and disposal techniques,
carbon emissions are generated during the manufacturing process and the
product’s active lifespan. When we use a reusable product, on the other hand, we
may optimize the value of the emissions by utilizing it for an extended period due
to its prolonged active lifespan. We produce less trash, emit less CO2, and spend
less on products like menstruation cups, reusable cloth pads and period panties.

Table 6: Current alternative sanitary products and their lifespan

Product Material Usage

Sanitary napkins Contains superabsorbent polymers (SAPs) and plastics One time
and tampons
Cloth-based Cloth and hemp (plant material) Reusable for one to two years
sanitary napkins
Menstrual cups Medical grade silicone Reusable for five to ten years

Biodegradable • Natural ingredients such as cotton, wood pulp, banana One time
sanitary napkins fibre, sugar cane
• Organic cotton with bio-plastic layer in some cases
Source: Compiled from WaterAid and MHAI (Menstrual Hygiene Alliance of India).

35
SANITARY WASTE MANAGEMENT IN INDIA

Figure 10: Comparative analysis of waste generated by three different types of

sanitary products
BASED ON THE FOLLOWING ESTIMATES

6 Number of days per cycle

12 Cycles per year
40 Number of years spent menstruating

Disposable sanitary
products—compostable Reusable sanitary Menstrual
and non-compostable napkins cups

THE AVERAGE LIFE OF THE AVERAGE LIFE OF THE AVERAGE LIFE OF

THE PRODUCT THE PRODUCT THE PRODUCT

Five
One One years
time year
USAGE USAGE USAGE

Four Six
napkins pads per One per
per day cycle cycle

WASTE GENERATION IN A LIFETIME WASTE GENERATION IN A LIFETIME WASTE GENERATION IN A LIFETIME

OF A PRODUCT (BASED ON THE OF A PRODUCT (BASED ON THE OF A PRODUCT (BASED ON THE
ABOVE ESTIMATES) ABOVE ESTIMATES) ABOVE ESTIMATES)
4 x 6 x 12 x 40 = 6 x 40 / 1 = 1 x 40 / 5 =

11,520 240 8

Source: CSE, 2022

36
 CHALLENGES AND AGENDA

These alternative sanitary products are either reusable or compostable products

that reduce waste generation. Reusable items, such as cloth napkins and menstrual
cups, can be used numerous times before being discarded, resulting in waste
reduction. Reusable menstrual cups and reusable napkins have a longer lifespan
than disposable sanitary napkins, which directly affects the quantum of waste
these products generate over time (see Figure 10: Comparative analysis of waste
generated by three different types of sanitary products).

Further, we must understand that biodegradable is not the same as com-

postable. While all compostable material is biodegradable, not all biode-
gradable material is compostable. Although biodegradable materials return
to nature and gradually disappear completely, they can sometimes leave res-
idues. On the other hand, compostable materials produce compost, which is
nutrient-rich and beneficial to plants. To summarize, compostable materials
are biodegradable, with compost the added benefit, i.e. as they decompose,
they release vital nutrients into the soil, helping plant growth.

Most of these “biodegradable” pads claim to be chemical-free and compostable.

Many of them eliminate superabsorbent polymers (SAPs) and wood pulp, but
some plastic is still retained for waterproofing. How is it better than disposable
napkins if the biodegradable, organic-tagged pads have bleached white cotton and
plastic liners? It would not be incorrect therefore to say that most pads that
claim to be “biodegradable” sanitary napkins are not entirely compostable,
and the term can be misleading.

According to a study conducted by Green the Red, a volunteer-led community

of healthcare professionals and activists who aim to spread awareness about
sustainable menstruation alternatives, some sanitary napkins that claimed to be
eco-friendly and compostable were composted. The results were the following:40

Sanitary napkin sample 1: These pads were not bleached and claimed to comprise
banana fibre. Two pads were composted, one used and the other unused. At high
room temperature, the one with blood dissolved and composted in seven and a
half months, while the one without blood took roughly five and a half months (see
following image of napkins after two and six months in compost).

37
SANITARY WASTE MANAGEMENT IN INDIA

Sanitary napkin after two and six months in compost

Source: Green the Red

Sanitary napkin sample 2: This pad appeared to be bleached white. It took

more than six months to dissolve when a used pad was composted. It had a non-
shredding plastic coating. It was finally removed from the compost pile. (Corn
starch, bamboo fibre and corn-based bio-plastic were among the ingredients.) (see
following image for the napkins after two and six months in compost).

Sanitary napkin after two and six months in compost

Source: Green the Red

The results suggest that these sanitary napkins may be biodegradable and may
degrade in years due to some plastic coating, but they are not compostable.
However, it remains unclear whether they are genuinely an eco-friendly and
sustainable option. The components used to make a napkin determine whether
it is a green or a conventional napkin. Perforated polyethylene or non-woven
polypropylene, utilized as the top sheet, is frequently mistaken for cotton due
to its texture and appearance. However, it is not compostable. In addition, the
polyethylene back layer and the top layer together make up about 25–30 per cent
of the total weight of a sanitary napkin. Non-compostable materials are typically

38
 CHALLENGES AND AGENDA

utilized for the top permeable layer—usually non-woven—the barrier plastic layer
underneath—superabsorbent polymer (SAP)—and hot-melt glue in disposable
sanitary napkins.41 Apart from the glue, which is utilized in small amounts, the
remaining components must be replaced.

Alternative sanitary products that are reusable or partially compostable products

reduce waste generation (see Table7: Current methods of disposal of alternative
sanitary products).

Table 7: Current methods of disposal for alternative sanitary products

Product Material Disposal method

Sanitary napkins and tampons Contains superabsorbent polymers (SAPs) Electric incineration
and plastics
Cloth-based sanitary napkins Cloth and hemp (plant material) Incineration, deep burial or
composting
Menstrual cups Medical-grade silicone Incineration

Biodegradable sanitary • Natural ingredients like cotton, wood Deep burial or composting if
napkins pulp, banana fibre, sugar cane made up from only plant-based
• Organic cotton with bio-plastic layer in material
some cases
Source: Compiled from WaterAid and MHAI (Menstrual Hygiene Alliance of India)

Reusable items, such as cotton pads and menstrual cups, can be used numerous
times before being discarded, resulting in reduced waste (see Table 8: Recommended
disposal options as per CPCB Guidelines for Sanitary Waste Management).

Table 8: Recommended disposal options as per CPCB Guidelines for Sanitary

Waste Management
Sanitary waste Disposal into a Deep burial Composting Pit burning Incinerator
pit latrine
Low-cost
Used tissue, paper, Less
√ √ √ or electric
cloth, cotton recommended
incinerator
Cotton napkins
Less Electric
(reusable or √ √ Less
recommended incinerator
commercial) recommended
Commercial
Less Less Biomedical
napkins with √ Not possible
recommended recommended incinerator
plastics and liners

39
SANITARY WASTE MANAGEMENT IN INDIA

6.1 Disposal in latrine pits

Flushing in latrine pits is a method of sanitary waste disposal. CPCB recommends
this disposal method for tissue paper, cotton and cloth-based sanitary napkins but
less for commercial plastic-based sanitary napkins. As per the MHM Guidelines,
however, commercial sanitary napkins should not be disposed of in latrine pits.
The multiple methods of disposal recommended by various organizations create
ambiguity in the implementation process. Lack of coordination between different
government entities is a significant concern with regard to existing sanitary waste
disposal options, making resolving inconsistencies in legislation a challenge.

According to a study done by international non-profit WaterAid, 9 per cent of

women flushed their sanitary waste in toilets or latrine pits as they considered this
a more discreet option.42 Non-biodegradable pads made of synthetic materials
were disposed of in latrine pits and toilets, jeopardizing the biological processes
that break down faeces in the pit. Disposable sanitary pads using superabsorbent
polymers (SAP) pose a challenge since SAP absorbs liquids, causing pads to
expand and clog sewer pipes. This has ramifications for sanitation workers and
cleaners who clear blockages from sewers and clean septic tanks and their health
and social status.

6.2 Deep burial

Deep burial is a low-cost method of sanitary waste disposal that can be used in
rural areas. According to the CPCB guidelines, once the sanitary material has
been placed inside the burial pit, it is covered with soil to avoid foul smell and
exposure to the open air. The pit should be built at least 5–7 metre away from any
drinking water sources. At the village and panchayat levels, homemade cotton or
cloth-based sanitary waste can be disposed of in burial pits of at least 50 cm depth.
Deep burial is not the best disposal option in areas with a low groundwater table
or frequent rains.

Figure 11: Deep burial pit

Wire mesh
Fence around
covering pit
the pit
contents

Backfill the pit with Earth mound to keep

at least 0.5m of soil surface water out of
cover the pit
0.1m layer of soil

Source: CPCB Guidelines, 2018

40
 CHALLENGES AND AGENDA

Deep burial may cause women embarrassment and privacy concerns along with
the inconvenience of collecting and taking sanitary waste to a burial site. Further,
sanitary products made of plastic should not be considered for deep burial.

6.3 Composting
Composting is a viable alternative for compostable sanitary waste (such as those
composed of natural fibres), not bleached cellulose, SAP or plastic liners. According
to CPCB, compostable sanitary waste should be covered with biodegradable
materials such as leaves or dried plants. After the pit is filled, it should be covered
with soil to avoid foul odours. Many sanitary products composed of synthetic fibre
rayon with antibacterial compounds such as organochlorines are now available
in the market. When composted, these partially biodegradable sanitary napkins
destroy the soil microflora and slow the decomposition process due to their
chemical composition.

A study by Green the Red suggests that these sanitary napkins may be
biodegradable—they could degrade over several years due to the plastic coating—
but they are not compostable. It however remains unclear whether composting
of sanitary napkins is really an eco-friendly and sustainable disposal option as we
envisage.43

6.4 Clay-pot or matka burning

Pit burning is a viable option in remote areas where no other options are available.
Cotton-based sanitary products can be disposed of by burning in a clay-pit.
According to CPCB guidelines, the burning should be done at a depth of around
1 metre. At villages and panchayat levels, low-cost incinerators like clay-pot
incinerators can also be utilized to dispose of only cotton-based sanitary waste.

Clay-pot or matka incinerator

Source: Vatsalya Foundation

41
SANITARY WASTE MANAGEMENT IN INDIA

Table 9: Overview of different sanitary waste disposal options

Disposal option Type of use Advantages Disadvantages Examples of use

Deep burial Households • Low cost • Feasible option only for sanitary • Households in
(rural) • Easy to use pads made of plant-based material Uttarakhand
or cotton or cloth
• Not a good option for areas
with low groundwater table and
frequent rains
Composting Households • Low cost Composting a feasible option only • Households in Tamil
(rural and • Easy to use for compostable sanitary pads, e.g. Nadu
urban) • Generates made of natural fibres), not pads
additional made of bleached cellulose, SAP, and
resources, i.e. plastic covering.
compost
Incineration— Household • Low cost • No emission controls • Households in Papna
clay pots (Rural) • Easily • Burn at low temperature, hence Mau village, Uttar
(matka) available waste may not burn efficiently Pradesh
• Easy to use • May not work for pads with high
• Uses locally moisture content and high content
available fuel of superabsorbent polymers
(SAPs)
• Ash might not be safe to use for
gardening
• Design not standardized and
highly variable
• Feasible option only for home-
made cotton or cloth-based
sanitary napkins
Low-cost Institutional/ • Low cost • No emission controls • Schools in Nepal
locally made public • Easy to install • Burn at low temperature, hence • Schools in Uttar
incinerators settings, • Built from waste may not burn efficiently. Pradesh
households locally • May not work for pads with high • Rural schools in Tamil
(rural/urban) available moisture content and high content Nadu
materials of superabsorbent polymers • Households in Tamil
• Easy to use • Ash might not be safe to use for Nadu
and maintain gardening. • Communal EcoSan
• Uses locally • Design is highly variable and not toilets, Tamil Nadu
available fuel standardized
Electric Institutional/ • More • Dependent on electric supply • Public toilet, Chennai
incinerators public expensive and • High cost Central Railway Station
settings some models • May release toxic gases if • Public toilet, Dindigul
(Urban) have emission temperature below 800 degrees Bus Stand, Tamil Nadu
control Celsius • Schools in Tamil
features such • Unclear if they can efficiently burn Nadu, Kerala, Delhi,
as filters pads with high moisture content Rajasthan, Madhya
• No need for • Variation in design Pradesh, Maharashtra
fuel • No standard quality certification and West Bengal
• Some models • Ash might not be safe to use for
have quality gardening
certification
Source: Compiled from PATH (2017) and Menstrual Waste Disposal in Low- and Middle-Income Countries, 2018.

42
 CHALLENGES AND AGENDA

In the case of burning plastic-coated sanitary products, the ash is likely to contain
residues of toxic chemicals that should not be mixed with soil or water because
they can be detrimental to individuals who come into touch with them. The matka
or clay-pot incinerator must be kept in open places, such as the backyard or terrace
of the house, and may not be used to dispose of commercial sanitary waste.

There are a variety of disposal options available, ranging from deep burial to
incineration systems, each with its advantages and disadvantages (see Table 9:
Overview of different sanitary waste disposal options).

According to findings from an Indian systematic review and meta-analysis study,

unsafe disposal practises such as throwing absorbents in open spaces and burning
(open burning, not incineration) were significantly higher in community-based
(especially in rural and slum settings) than in school-based settings. According
to the study—which also highlighted that in the school-based study girls were
observed to discard soiled napkins in latrines, particularly when they did not have
access to dustbins—sanitary waste disposal may be more difficult in community
settings than in institutional settings because facilities are not as well managed.44

Cultural norms, personal preferences, economic position and socioeconomic

pressures influence sanitary waste disposal habits. Menstrual attitudes, knowledge
and behaviours are all intertwined, and these conventions might act as roadblocks
to proper waste disposal. As a result, regular awareness and capacity building on
sanitary waste management should be carried out at all levels, including producers,
consumers and decision-makers.

43
 7. Recommendations

This chapter addresses recommendations for policy considerations, effective

coordination among stakeholders, implementation protocol and waste governance
by local governments to institute a sustainable system for sanitary waste
management.
 Comprehensive assessment: One of the largest hurdles towards scientific
sanitary waste management is the absence of data and lack of comprehensive
statistics on the subject, and lack of statistics and measures for collecting and
disposing of other sanitary wastes in the country. There should be a clear policy
mandate for a comprehensive study to quantify and characterize sanitary
waste generation, and local authorities should include correct estimated
data—instead of zero—under the column “sanitary waste” in the Swachh
Bharat Mission (SBM) Management Information Systems (MIS). City- and/or
panchayat-level data can be collated at the district and/or state level to arrive at
the national scale to institute a scientific monitoring and management system.

Snapshot of SBM-MIS portal

Source: Ministry of Housing and Urban Affairs (MoHUA), Government of India.

 Inventory of sanitary products: In March 2022, the Central Pollution

Control Board (CPCB) launched the EPR (Extended Producers Responsibility)
portal for PIBOs (Producers, Importers, and Brand Owners) to ease the EPR
implementation process and ensure processing of their plastic packaging.

44
 CHALLENGES AND AGENDA

EPR portal

Source: CPCB

CPCB should similarly develop a separate portal where every sanitary product
brand owner and manufacturer is required to share their production and sales
data for all sanitary products to estimate and assess the quantity of sanitary
waste generation and accordingly compute the treatment facility design
capacity.

 Strengthening existing rules and guidelines: Non-compliance with

SWM Rules, 2016 and the provisions of the Guidelines for Sanitary Waste
Management, 2018 currently has no consequences. Considering the hazardous
potential of sanitary waste—along with magnitude and quantity—and need
for an established scientific protocol to deal with it, there must be a dedicated
policy for sanitary waste management. Such a policy should provide a legal
instrument to local bodies to adopt and enforce by-laws exclusively on sanitary
waste management.

 Address inconsistency in terminology: According to the SWM Rules,

2016, domestic hazardous waste and sanitary waste are considered separate
categories of waste and treated differently. According to the Ministry of
Housing and Urban Affairs (MoHUA) Swachh Survekshan Toolkit 2022,
however, sanitary waste and domestic hazardous waste have been consistently
classified in a common waste category.

To reduce inconsistency and confusion among waste management practitioners

and authorities, the standard definition of sanitary waste prescribed under
SWM Rules, 2016 should be standardized across policies, guidelines and
management protocols for its uniform understanding and management.

45
SANITARY WASTE MANAGEMENT IN INDIA

 Redesign infrastructure and services for sanitary waste management:

Appropriate infrastructure and services play a significant role in sustaining
waste management operations. Segregation of sanitary waste at source must
be enforced as mandatory. Collection vehicles, tricycles and/or pushcarts
must have a dedicated compartment for collection and storage of sanitary
waste, with a specific colour code. Currently, SBM 2.0 has recommended
four-way segregation of waste at source, including segregation of sanitary
waste. Similarly, the treatment and disposal system must be made uniform
and mandatory regardless of the scale and level of interventions so that the
hazardous potential in sanitary waste could be mitigated without harming the
environment and public health.

Figure 12: Process flow diagram of sanitary waste management

Source segregation
Sanitary waste appropriately wrapped Compartmentalized
in a newspaper or pouch and put vehicle for collection
Waste generation separately in a bag or bin and handed of segregated
over to the waste collector sanitary waste

Decentralized incinerator for Incineration of Transported sanitary

disposal of sanitary waste sanitary waste waste to CBMWTFs
generated at community level;
cut-off temperature minimum
of 800 degrees Celsius

Testing of ash Disposal of ash or

from EPA- or NABL- residue at a secured/
accredited lab sanitary landfill

Source: CSE, 2022

46
 CHALLENGES AND AGENDA

To check for the presence of heavy metals before disposal in a landfill, ash
produced by incinerators should be tested in any EPA (Environmental
Protection Agency)- or NABL (National Accreditation Board for Testing
and Calibration Laboratories)-accredited laboratory. Penalty clauses should
be considered for non-compliance to improve enforcement mechanisms and
streamline implementation.

 Reinforce instructional arrangement to strengthen sanitary waste

management: The policy document should clearly specify the roles and
responsibilities of every stakeholder for sanitary waste management (see Table
10: Roles and responsibility of various stakeholders).

Table 10: Roles and responsibility of various stakeholders

Stakeholder Role and responsibility

State-level officials • A dedicated inventory of sanitary waste generation should be created at the state level,
with breakup of sources. Compliance should be monitored at state-level review meetings
along with reviews of regular municipal solid waste management performance. Competent
state authorities must frame relevant state policies to complement financial allocation,
with special focus on sanitary waste management.
Local authority • Enact by-laws for four-way segregation at source, with a clear mandate to include sanitary
waste in the segregated streams of waste.
• Providing adequate infrastructure and services for separate collection, transportation and
treatment of segregated sanitary waste.
• Collaborating with existing common biomedical facilities and waste-to-energy facilities to
treat sanitary waste at the required scale.
• Getting technical specifications of decentralized incinerators mandatorily vetted by
State Pollution Control Boards before any procurement. The procedure may involve the
city governments receiving and forwarding applications for installation of decentralized
incinerators.
• Instituting a stringent system for regular monitoring of installed incinerators with regard
to measures to safeguard against pollution and protect the environment and public health.
• Ensuring that all vendors submit an NOC (no objection certificate) from the State Pollution
Control Board in compliance with the emissions standards as per SWM Rules and CPCB
Guidelines prior to any procurement of decentralized incinerators.
State Pollution • Ensuring that the site is inspected to ensure all possible safety standards and
Control Board environmental parameters have been complied with ahead of installing decentralized
incinerators in educational institutes and public places.
• Creating a mechanism so that the city government officials inspect installed incinerators at
least once every year to monitor the ash disposal and emission control system.

47
SANITARY WASTE MANAGEMENT IN INDIA

State Health • Providing knowledge and healthcare support to women and adolescent girls through IEC
Department campaigns.
• Issuing directives to hospitals to allow urban local bodies (ULBs) to send their sanitary
waste to their captive incineration facilities until the ULBs are connected to a sustainable
sanitary waste treatment and disposal system.
• Periodically reviewing the rates for collection, transportation and treatment of sanitary
waste so that it remains an interesting proposition for service providers.
• Promoting eco-friendly alternative sanitary products to reduce the carbon footprint in the
environment.
• Creating an enabling environment to encourage women self-help groups (SHGs) to initiate
small-scale businesses to make eco-friendly sanitary products using programmes such as
the National Urban Livelihoods Mission (NULM).
Educational • Implementing age-appropriate curricula for adolescent girls to educate them on scientific
Department management of sanitary waste in schools and at home. Students must be considered
as amplifiers to receive the message for sanitary waste management and educate their
family, friends and neighbourhood.
• Issuing directives to all the schools on the minimum mandatory standards for installing
decentralized incinerators.
• Issuing directives to all the schools for scientific disposal of sanitary waste through an
authorized vendor deployed by the ULB or entering into an agreement with the common
biomedical waste treatment facility, subject to its availability.

 IEC (Information, Education and Communication): Considering the

scale of sanitary waste generation and current practices on sanitary waste
management, it is imperative to initiate an IEC drive with a proper roadmap at
the national scale. The absence of education contributes to the stigma and lack
of awareness of sanitary waste management. Not just women using menstrual
products but also administration are often unaware of the science behind the
menstrual products and their disposal. One of our long-term priorities in India
should be IEC (information, communication, and education) programmes
around alternative sanitary products that are more environmentally friendly,
with a budget assigned especially for IEC. The IEC initiative should be part of
the policy mandate, and the same should reflect as a programme mandate for
SBM (Swachh Bharat Mission).

• Concerned state officials

• Health officials
State • State urban department

• Local authorities
• City engineers
City • Frontline sanitation workers

• Self-help groups
• Civil societies
Communities • Rotaract clubs

• Head teachers
• Teaching and non-teaching staff
Educational • Students
institutes

48
 CHALLENGES AND AGENDA

 Collaborate with other organizations: Urban local body shall join hands with
civil society, private organizations and self-help groups involved in sanitary
waste management in their jurisdiction to conduct extensive IEC to promote
source segregation and create awareness about eco-friendly sanitary products.

SWaCH, in collaboration with the Kagad Kach Patra Kastakari Panchayat

(KKPKP), a waste pickers’ trade organization, and the Pune Municipal
Corporation, launched in 2017 the Red Dot Campaign to promote awareness
about proper sanitary waste disposal at the household level.45

A poster from the Red Dot campaign

Source: SWaCH Pune

 Promote eco-friendly products: Looking at the current ecosystem of available

sanitary products available in the market and materials used in the process of
manufacturing them, there is a clear need to invest on promoting eco-friendly
alternatives with health, economic and environmental benefits. To promote
environmentally friendly sanitary products, local authorities can partner with
non-profit organizations such as Eco Femme, a women-led social enterprise
in Tamil Nadu that manufactures and sells reusable, washable cloth sanitary
napkins.

 Disclosure of composition and testing of disposable eco-friendly sanitary

product: Manufacturers must also disclose information on the chemical
composition of sanitary products so that appropriate technologies for disposal
and treatment can be devised. Consumers need to be given choice of what they
are purchasing. Instead of looking for the term “biodegradable”, they should
look for the term “compostable”. A compostable sanitary pad usually takes
90–180 days to decompose. Compostable napkins made up of natural and
plant-based material can decompose in the soil within the specified timeframe,

49
SANITARY WASTE MANAGEMENT IN INDIA

INDIAN STANDARDS

IS 5405:2019: Sanitary napkins are absorbent materials used to absorb fluid discharged during
menstruation. As compared to cloth and other materials (husks, ashes, etc.) used during menstruation,
they provide better hygiene and protection against leakage. This standard was originally published
in 1969 and subsequently revised in 1980. The current revision was made in the light of experience
gained since its last revision and to incorporate the following major changes:
• Material and sizes
• Types of sanitary napkin
• The procedure and requirement of ability to withstand pressure after absorption
• The optional requirement of disposability
• Hygiene testing requirement
• Good manufacturing practice guidelines for hygiene requirement
• Bio-compatibility evaluation requirement
• Optional requirement of biodegradability and compostability
Manufacturers that claim that their product is biodegradable or compostable shall perform
the above testing for the final product. The product shall be considered biodegradable or
compostable when tested as per IS/ISO 17088. The information regarding whether the product
is biodegradable, compostable or oxy-degradable shall be marked on every packet of sanitary
napkin.
• Sampling and criteria for conformity
• Marking and packing clause

IS/ISO 17088:2021: These standards specify procedures and requirements for plastics and
products made from plastics that are suitable for recovery through organic recycling. The four
following aspects are addressed:
• Disintegration during composting;
• Ultimate aerobic biodegradation;
• No adverse effects of compost on terrestrial organisms; and
• Control of constituents.

These four aspects are suitable to assess the effects on the industrial composting process. This
document is intended for use as the basis for systems of labelling and claims for compostable plastics
materials and products. This specification is intended to establish the requirement for the labelling
of plastic products and material as “compostable” or “compostable in municipal and industrial
composting facilities”. The labelling, in addition, must conform to all international, regional, national,
and local regulations.

50
 CHALLENGES AND AGENDA

producing no heavy or toxic metals in the environment. Biodegradable or oxo-

degradable sanitary pads are often confused with fully compostable sanitary
pads.
Manufacturers must ensure that each eco-friendly-labelled sanitary products
must bear the label “compostable” and conform to Indian Standards: IS 5405
and IS/ISO 17088 (as amended from time to time). Their eco-friendly-labelled
sanitary products must be tested by the Central Institute of Petrochemicals
Engineering and Technology (CIPET) or any other Central Pollution Control
Board (CPCB)-recognized government laboratory with adequate testing
facilities.

Various sanitary product producers in India include the chemical composition

of their sanitary napkins on the package and label their sanitary products with
certifications to identify the product’s possible environmental impact before
releasing it on the market.46

Figure 13: Cross-sectional view of disposable eco-friendly sanitary napkin

Super-soft and comfortable

Elementary GOTs certified 100 per cent
chlorine- and organic cotton top layer
dioxin-free
absorbent airlaid

Breathable +
compostable
bio back layer
Side wall for
extra leakage
protection

ISO-certified fully
compostable, natural and
superabsorbent

Source: Anandi compostable sanitary napkins

 Prescribe standards for manufacturers: Due to increased demand for

decentralized incinerators as a primary choice for sanitary waste disposal,
various decentralized incinerator models are available in the market. As

51
 detailed in this report, many or most of these incinerators do not meet the
prescribed emission standards. Therefore, policy instruments are needed for
the industry with regard to mandatory compliance of emission standards
for materials to be used in the manufacture of incinerator unit, feed-in rate
and capacity of a given model, emission control system, ash residue disposal
process, and a standard checklist for operations and maintenance of the
machines post installation.

 Standardized procurement procedure: A standard format for tenders for

procurement of incinerators must be used by government bodies at all levels.
The tender must include manufacturing requirements to be prescribed,
compliance with CPCB guidelines, testing through an accredited laboratory,
annual maintenance contract, monitoring for a minimum of two years from the
date of installation, and training for users on how to utilize the decentralized
incinerator unit. To ensure efficient operation, annual maintenance must be
incorporated under the scope of work of the selected contractor or agency for
at least three years from the date of installation and renewed as needed.

 Monitoring of sanitary waste management: Considering the scale in the

increment of sanitary waste generation in India, every city and panchayat must
comply with the mandate to provide data on sanitary waste generation after
systematic characterization of all waste streams. The data should be compiled
at various tiers of administration and be part of the agenda-for-development
meeting.

52
 CHALLENGES AND AGENDA

References
1. Solid Waste Management Rules 2016; https://cpcb.nic.in/uploads/MSW/Salient_features_SWM_Rules.pdf (last
accessed on April 11, 2022).
2. Menstrual Hygiene Alliance of India; https://menstrualhygieneday.org/resources-on-mhm/mhh-web-
dialogues-2019-2020/ (last accessed on April 11, 2022).
3. Information provided through conversation with various gynaecologists and paediatricians.
4. Ministry of Health and Family Welfare, Government of India, “National Family Health Survey (NHFS-4) 2015-16”,
p. 98 on December 2017 (http://rchiips.org/nfhs/NFHS-4Reports/India.pdf) (last accessed on April 11, 2022).
5. Ibid.
6. How must we dispose of diapers, Deccan Herald, December 2019 available at: https://www.deccanherald.com/
opinion/panorama/how-must-we-dispose-of-diapers-786453.html (last accessed on April 11, 2022).
7. Information provided through conversation with various gynaecologists and paediatricians.
8. United Nation Children’s Fund, India, Jan 2020 available at: https://www.unicef.org/india/key-data (last accessed
on April 11, 2022).
9. Information provided through conversation with various gynaecologists and paediatricians.
10. Treatment of Absorbent Hygiene Product; file:///C:/Users/91880/Downloads/Treatment%20of%20absorbent%20
hygiene%20products%20for%20improved%20recycling%20of%20materials.pdf (last accessed on April 11, 2022).
11. Guidelines for the management of sanitary waste as per Solid Waste Management Rules, 2016 issued in May 2018
(https://kspcb.gov.in/Sanitary%20Waste%2006082018.pdf) (last accessed on April 11, 2022).
12. CPCB issued Technical Guidelines for Sanitary Waste Management https://cpcb.nic.in/uploads/MSW/Final_
Sanitary_Waste_Guidelines_15.05.2018.pdf(last accessed on April 11, 2022).
13. Ministry of Drinking Water and Sanitation, Government of India, MHM National Guidelines; (http://www.ccras.
nic.in/sites/default/files/Notices/16042018_Menstrual_Hygiene Management.pdf) (last accessed on April 11,
2022).
14. Ministry of Housing and Urban Affairs, Government of India, Guidelines for Swachh Bharat Mission—Urban,
October 5, 2017; (http://swachhbharaturban.gov.in/writereaddata/SBM_GUIDELINE.pdf) (last accessed on
April 11, 2022).
15. Ministry of Drinking Water and Sanitation, Government of India, Guidelines for Swachh Bharat Mission (Gram-
in), October 2017, (http://swachhbharatmission.gov.in/sbmcms/writereaddata/images/pdf/Guidelines/Com-
plete-set-guidelines.pdf) (last accessed on April 11, 2022).
16. Guidelines for the management of sanitary waste as per Solid Waste Management Rules, 2016 issued in May 2018
(https://kspcb.gov.in/Sanitary%20Waste%2006082018.pdf) (last accessed on April 11, 2022).
17. Bio-medical Waste Management Rules, 2016 https://dhr.gov.in/sites/default/files/Bio-medical_Waste_
Management_Rules_2016.pdf (last accessed on April 11, 2022).
18. Tamil Nadu to Set up over 4000 Sanitary Napkin Incinerators in Govt. Schools!, Raymond Engineer, March 21
2018, https://www.thebetterindia.com/135175/tamil-nadu-sanitary-napkin-incinerators-government-schools-
promoting-menstrual hygiene/ (last accessed on April 11, 2022).
19. On World Menstrual Hygiene Day, Maharashtra announces 400 toilets equipped with sanitary napkin facilities
on highways, Gopi Karelia, NDTV, May 29, 2018, https://swachhindia.ndtv.com/world-menstrual-hygiene-day-
maharashtra-toilets equipped-sanitary-napkinfacilities-20493/(last accessed on April 11, 2022).
20. Menstrual products and their disposal, ToxicsLink, 2021; http://toxicslink.org/docs/Menstrual%20Waste%20
Report.pdf (last accessed on April 11, 2022).
21. Ibid.
22. Menstrual Hygiene Management and Waste Disposal in Low- and Middle-Income Countries—A Review of the
Literature, 2018 available at: https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6266558/ (last accessed on April
11, 2022).
23. Ibid.
24. Report on Safe management of wastes from health-care activities, Second edition, World Health Organization,
2014. Available at: https://www.euro.who.int/__data/assets/pdf_file/0012/268779/Safe-management-of-wastes-
from-health-care-activities-Eng.pdf (last accessed on 26.04.2022).
25. Menstrual Waste Disposal in India. Available at: https://thequantumhub.com/wp-content/uploads/2020/05/
TQH-Report-Menstrual-Waste Disposal-Incinerators-28th-May-2020-Final.pdf. (last accessed on April 11, 2022).

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SANITARY WASTE MANAGEMENT IN INDIA

26. Biomedical Annual Report 2019 by Central Pollution Control Board. Available at: https://cpcb.nic.in/uploads/
Projects/Bio-Medical-Waste/CBWTF_Status_2019.pdf (last accessed on April 11, 2022).
27. Menstrual Waste Disposal in India. Available at: https://thequantumhub.com/wp-content/uploads/2020/05/
TQH-Report-Menstrual-Waste Disposal-Incinerators-28th-May-2020-Final.pdf. (last accessed on April 11, 2022).
28. Ibid.
29. Incinerator Market landscape, Analysis of India and South Africa, 2019, available at: https://gatesopenresearch.
org/documents/5-9 (last accessed on April 11, 2022).
30. GeM Portal available at https://mkp.gem.gov.in/search?q=sanitary%20machines(last accessed on April 11, 2022).
31. Tender docs available at: https://pmidc.punjab.gov.in/wp-content/uploads/2019/06/RFP-SanitaryNapkin.pdf
http://techeduhry.gov.in/sites/default/files/documents/Sanitary%20Napkin%20Incinerator_Tender%20docu-
ment.pdf https://cdn.s3waas.gov.in/s3ad61ab143223efbc24c7d2583be69251/uploads/2019/09/2019092627.pdf
(last accessed on April 11, 2022).
32. Elawati K.C. A Study of Menstrual Hygiene and Impact of Pad Incinerator: A Comparative Study in Bharatpur,
Guleria, Tikapur and Butwal 2012, available at: http://library.nhrc.gov.np:8080/nhrc/handle/123456789/508 (last
accessed on April 11, 2022).
33. PATH. Menstrual Management and Sanitation Systems: Findings from Two Case Studies in South Africa and
India. PATH; Seattle, WA, USA: 2013, available at: https://www.path.org/resources/menstrual-management-and-
sanitation-systems-findings-from-two-case-studies-in-south-africa-and-india/(last accessed on April 11, 2022).
34. Menstrual Hygiene Management and Waste Disposal in Low- and Middle-Income Countries—A Review of the
Literature, 2018 available at: https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6266558/ (last accessed on April
11, 2022).
35. Global Review of Sanitation System Trends and Interactions with Menstrual Management Practices 2011, available
at: https://www.susana.org/en/knowledge-hub/resources-and publications/library/details/1827?pgrid=1 (last
accessed on April 11, 2022).
36. Incinerator for School Toilet Waste Case Study: Tamil Nadu. Rajiv Gandhi National Drinking Water Supply,
Department of Drinking Water Supply, Ministry of Rural Development; Tamil Nadu, India: 2007 available at:
https://jalshakti-ddws.gov.in/sites/default/files/case_study_tamilnadu.pdf (last accessed on April 11, 2022).
37. CSE and NITI Aayog release ‘Waste-wise cities’ – compendium of best practices in municipal solid waste management
2021, available at:https://www.cseindia.org/cse-and-niti-aayog-release-waste-wise-cities-compendium-of-best-
practices-in-municipal-solid-waste-management-11074 (last accessed on April 11, 2022).
38. Menstrual Hygiene Management, WaterAid 2019, available at: https://www.wateraidindia.in/sites/g/files/
jkxoof336/files/informed-product-choice-and-disposal_1.pdf (last accessed on April 11, 2022).
39. Sanitary napkins: Why biodegradable is not the same as compostable,2021, available at:https://www.downtoearth.
org.in/blog/environment/sanitary-napkins-why-biodegradable-is-not-the-same-as-compostable-80657
40. Study on sanitary napkin by Green the Red, available at: https://www.greenthered.in/(last accessed on April 11,
2022).
41. Sanitary napkins: Why biodegradable is not the same as compostable,2021, available at:https://www.downtoearth.
org.in/blog/environment/sanitary-napkins-why-biodegradable-is-not-the-same-as-compostable-80657(last
accessed on April 11, 2022).
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jkxoof336/files/informed-product-choice-and-disposal_1.pdf. (last accessed on April 11, 2022).
43. Study on sanitary napkin by Green the Red, available at: https://www.greenthered.in/(last accessed on April 11,
2022).
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jkxoof336/files/informed-product-choice-and-disposal_1.pdf. (last accessed on April 11, 2022).
45. The campaign in Pune about sanitary waste segregation, Richa Agarwal, 2017, https://www.downtoearth.org.in/
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46. Anandi Sanitary Napkins https://anandilife.com/(last accessed on April 11, 2022).

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The Solid Waste Management (SWM) Rules, 2016
classifies used sanitary napkins, diapers, condoms,
tampons and incontinence sheets as sanitary waste.
According to the Menstrual Hygiene Alliance of India
(MHAI), 336 million girls and women of reproductive age
in India generate about 1 billion sanitary napkins per
month, or 12.3 billion sanitary napkins annually. Sanitary
waste is voluminous and infectious, and plastic is used
as a primary material in the manufacture of disposable
sanitary products, underlining the need for sanitary
waste management in India.

There are few documented measures in the country

for collecting and disposing of sanitary waste.
This report highlights the status, challenges and
government initiatives in the context of segregation,
collection, transport, treatment and disposal of sanitary
napkins in India. It addresses recommendations for
policy consideration, effective coordination among
stakeholders, implementation protocol and waste
governance by local governments to institute a
sustainable system for sanitary waste management.

Centre for Science and Environment

41, Tughlakabad Institutional Area, New Delhi 110 062
Phones: 91-11-40616000 Fax: 91-11-29955879
E-mail: cseindia@cseindia.org Website: www.cseindia.org