The “National Hazardous Waste Management (NHWM) Policy, 2022” aims to ensure compliance with Multilateral Environmental Agreements (MEAs) concerning hazardous waste. It is therefore essential to critically examine this policy to identify various regulatory, infrastructural, technological, financial, and ethical issues that may prevent its effective implementation.
Scott explains institutions as comprising regulative, normative, and cultural-cognitive elements that, together with associated activities and resources, provide stability and meaning to social life. The regulative pillar focuses on rules and regulations. The normative pillar directs the behaviour and values of the people responsible for implementation. The cultural-cognitive pillar then addresses the culture of the organisation and individuals responsible for implementation.
Regulatory: Absence of Proper Life Cycle Management of HW
Prior to the NHWM Policy’s formulation, Pakistan lacked any comprehensive legal document to cover the lifecycle management of hazardous waste (HW) in an environmentally sound manner. Although the Pakistan Environmental Protection Act (PEPA) was introduced in 1997, it still fails to accurately predict HW generation rates in Pakistan. Accurate HW rates require information about first-level generation inventory and a robust classification system for HW. Pakistan Custom Tariff (PCT) codes for hazardous waste are not yet properly designed. The country is reported as the third-largest importer of hazardous waste globally, after China and India. This waste is mostly imported for chemical and metal recovery. At present, no proper regulation requires the compilation of a list of these chemicals. Usually, for containers containing waste, no specific codes are available, and thus, they are often cleared by the Customs Department. The NHWM Policy can also contribute to compiling a list of banned chemicals that should not be allowed to enter Pakistan.
Pakistan is reported as the third-largest importer of hazardous waste globally, after China and India.
Current Status: The Ministry of Climate Change & Environmental Coordination (MoCC & EC) shared the Policy as well as its Action Plan with relevant stakeholders, including ministries, federal, and provincial departments. However, no substantial progress has been made. The Government of Punjab has initiated work on a Provincial Hazardous Waste Management Policy and Action Plan. Other provinces can also develop similar regulations as per their requirements.
Infrastructural: Lack of Storage, Recycling, and Reclamation Facilities
Pakistan lacks the standard physical infrastructure required to recycle and treat waste and then dispose of it efficiently. It is therefore important that infrastructure facilities handling HW meet all basic requirements and commit to continual improvement in their operations.
For this purpose, the proximity principle can play a key role; its adoption can result in treating HW as close to the point of production as possible. Moreover, there is incomplete incineration of hospital infectious waste. Discussions with relevant officials indicate that every hospital and laboratory is legally required to completely incinerate infectious waste. In Pakistan, only a few large hospitals possess incineration facilities. Even hospitals with incinerator facilities often do not meet the temperature requirement of 1300 ?C for safe disposal of infectious waste, which is consequently disseminated into the environment. Basic health units, small clinics, and laboratories located in far-flung areas also lack proper facilities to dispose of infectious waste.
Current Status: Two common treatment and disposal facilities for tannery waste are being operated at Kasur and Karachi under a public-private partnership model. A feasibility study was also conducted by the Basel Convention Secretariat to establish common treatment, storage, and disposal facilities for the ship dismantling industry and other allied industries at Gaddani, Balochistan. Stockpiles of POPs (Persistent Organic Pollutants) pesticides, which were banned through the Stockholm Convention, were incinerated at Best Way Cement Plant located at Kallar Kahar, on Motorway M2. To manage hospital waste containing infectious agents, incineration is carried out in some private and government-owned incinerators located in various parts of the country. However, a problem associated with current incinerators is that they do not meet the recommended temperature of 1300 ?C and above, thus not completely converting hazardous infectious waste into ash and leaving behind dangerous residues.
Technological: Prevention is not the Panacea.
Prevention is not the sole solution to problems associated with Hazardous Waste Management (HWM). Some waste will inevitably be generated. Hence, it is important to adopt reuse, treatment, recycling, and recovery techniques that result in better environmental outcomes and are compatible with the principles of best available techniques and best environmental practices. These techniques can prevent environmental hazards, protect limited natural resources, promote clean technologies, and curtail the nation’s dependence on raw materials and energy.
Current Status: A few types of hazardous waste, such as lead-acid batteries, plastic waste, and used engine oil, are being recycled in an environmentally sound manner in the country with the approval of the Federal/Provincial EPAs. Some industrial hazardous waste, including paints, chemicals, pesticides, and expired medicines, is being disposed of by private sector-owned incinerators. In addition, Hospital Waste Management Rules are being implemented by the Federal and Provincial EPAs.
However, there is a lack of data regarding infectious and non-infectious hospital waste. Furthermore, Pakistan has ratified the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships. Ratification of this Convention will enhance the capacity of the shipbreaking industry at Gaddani, Balochistan. Two Cleaner Production Centres are working at Sialkot and Rawalpindi. Single-use Plastics (Prohibition) Regulations 2023 are being implemented in ICT, including the provision of Extended Producer Responsibility (EPR).
Financial: Fiscal and Financial Incentives
Fiscal and financial incentives and initiatives play an important role in the effective and efficient management of HW. These incentives are critical to attract investment in process innovation and the development of treatment, storage, and disposal facilities in the country. Both the national and provincial governments, as well as international organisations, need to allocate financial resources for the implementation of the NHWM Policy measures.
Current Status: Unfortunately, funding is scarce. There is no sustainable financial mechanism in place for implementing the guidelines provided in the NHWM Policy. Scarcity is one issue, but proper homework is often not done by concerned environmental officials before raising the matter with the Ministry of Finance/Departments or potential local and international donors. The current government can take the initiative and provide financial resources to relevant stakeholders to ensure the smooth implementation of international conventions and promote sustainable development.
Cultural & Cognitive: Promoting Sustainable Development
The NHWM Policy will contribute to promoting the sustainable development agenda and improving people’s quality of life by taking socially responsible and environmentally sustainable measures. This domain aims at the prevention, minimisation, and control of HW generation with the support and cooperation of the public. It will restrict the import, export, and transit of HW into the country.
The reuse of disposable syringes is a serious problem prevalent among people unaware of its adverse health hazards. This also reflects problems of culture and cognition. Ignoring the harmful consequences of reuse, some antisocial elements are also engaged in the trade of these syringes without understanding the implications. Similarly, people collect and sell plastic waste from municipal waste as well as from dumping sites for their livelihoods. Given these cultural and cognitive practices, the role of enforcement agencies and civil society is extremely important in checking these practices to minimise the dissemination of HW.
Current Status: Currently, there is no proper and organised system for waste collection and storage. Some large cities have hired international companies for the management of HW. However, at present, the bulk of HW is segregated and collected by the informal sector in the country. The informal sector, comprising mostly children and women, does not use any personal protective equipment (PPE) during the segregation and collection of hazardous waste due to a lack of knowledge and education. These practices pose serious health risks to these individuals.
Despite these limitations, the NHWM Policy 2022 is a strong initiative and a step in the right direction to address the issue of HW management in Pakistan. It is a timely intervention and provides a launching pad for the provinces to build on it and further consolidate the work of implementing international conventions on HW management. Non-compliance with these conventions runs the risk of further eroding our national credibility. It is the task of the men at the helm of affairs, both at the national and provincial levels, to ensure that further steps are taken collaboratively to realise the aims and objectives of the policy, which should benefit all stakeholders of society.
(Concluded)
Alizar Sajjad is law student at University of London. Saud Bin Ahsen works at public policy think tank.
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