Hazardous Waste Recycling Plant Setup

Various industrial processes generates hazardous waste in plants and factories. This waste generally has chemical, reactive and toxic characteristics. Due to this reason, it may cause danger to the environment. Hence, the Hazardous Waste Management Rules of 2016 classify them as hazardous waste and regulate for safe and sound management. These rules prescribe the ways we can adapt to transport, store, recycle and dispose of or utilise this hazardous waste. If such measures are taken and rules implemented efficiently then we can save the environment from the harmful effects of these hazardous substances by setting up Hazardous Waste Recycling Plants.

What is Hazardous Waste?

Hazardous Waste is defined under sub-rule 17 of rule 3 of the Hazardous Waste Management Rules of 2016. It prescribes,

“Hazardous Waste means any waste which by reason of characteristics such as physical, chemical, biological, reactive, toxic, flammable, explosive or corrosive, cause’s danger or is likely to cause danger to health or the environment, whether alone or in contact with other wastes or substances.”

These wastes are further classified and mentioned in Schedule I, Schedule II and Schedule III of these rules. Schedule I specifies the waste and the processes from where they are generated, Schedule II specifies the waste constituents and their concentration, and Schedule III defines the characteristics of hazardous waste.

Classification of Hazardous Waste

The sources of hazardous waste are the industrial processes that generate it as a by-product. There are 128 listed hazardous wastes and these are divided into thirty-eight categories based on the source process. These categories include petrochemical processes, natural gas production, production of resources like lead, zinc and copper, production of acids, metal processing, production of textiles, leather tanneries, electronic industry, pulp and paper industry, chemical processing, hazardous waste processing etc. The hazardous waste mostly includes sludge’s, chemicals, residues and other harmful substances originating from these processes.

The Hazardous Waste Management Rules are now in practice but industries were generating hazardous waste even before the existence of these rules. Hazardous waste came into existence from the very inception of the industries in the nineteenth century and these producers were dumping this waste into the ocean, landfills and underground disposals. All these methods were drastic for the environment and not sustainable for the industries growing at a record pace. Considering the gravity of this issue, the Central Government of India made rules for the management of hazardous waste generated from these industries. The Ministry of Environment, Forest and Climate Change notified these rules in the official Gazette of India. The Pollution Control Boards took responsibility for the implementation of these rules and started monitoring these industries. Now businesses handle hazardous waste without getting registration.

Hazardous Waste Management Practices

The rules prescribe the following methods to deal with the rising quantities of hazardous waste-

• Prevention
• Minimisation
• Reuse
• Recycling
• Recovery and Utilisation
• Safe Disposal

The owners of waste generators should take the issue of hazardous waste management very seriously and start the prevention of hazardous waste generation from their respective plants and factories. If prevention is not possible, you can at least minimize the waste generation and reuse it wherever possible. Then comes the recycling, recovery, utilization and disposal of the generated hazardous waste. The TSDF facilities are designated to treat, dispose or process hazardous waste for any other purpose.

Treatment, Storage, and Disposal Facility (TSDF)

The Occupier term is used for the responsible person of a factory that is generating hazardous waste and the Operator is used for the controller of a treatment storage and disposal facility. The occupier cannot keep the waste for more than ninety days in his factory. He needs to sell, transfer, recycle or process this waste within this time period. Once the hazardous waste is transferred to a Treatment, Storage, and Disposal Facility, the operator starts processing the waste either to extract useful materials or completely dispose of it in an environmentally safe and sound manner. These facilities are commonly abbreviated as TSDF and require waste management registration for disposing of hazardous waste.

We witness several positive outcomes if we treat hazardous waste as prescribed by the waste management rules by following the standard operating procedure drafted by the Central Pollution Control Board. Some of the major benefits of hazardous waste recycling are as follows-

• Pollution Control
• Protection of Habitat
• Climate Change
• Cost Efficiency
• Resource Saving
• Business Reputation

Pollution Control

Recycling Hazardous Waste prevents the effluents to mix up with the air, soil and water. Instead of going to landfills, the hazardous waste goes to the Treatment, Storage and Disposal Facility where the operator treats and makes it harmless to whatever extent possible then we recycle it for reuse or safely dispose of it. As a result, we get a safe, clean and healthy environment that is free from hazardous effluents.

Protection of Habitat

In the absence of a recycling mechanism, industries dispose of hazardous waste in an improper way and expose it to the flora and fauna of the environment. It contaminates the soil and causes harm to nearby living beings. But when the government regulates these industries with Hazardous Waste Management Rules, it saves the natural habitat of the country from such toxic effluents.

Climate Change

Unmanned and unregulated open composting of this hazardous waste releases toxic pollutants into the atmosphere. When businesses practise this method on a large scale, the concentrated greenhouse gases affect the ozone layer and cause climate change. The proper regulated treatment of these hazardous substances can only prevent such a drastic loss to our environment and pave the way for sustainable development.

Cost Efficiency

The TSDF facility converts hazardous materials into raw materials after proper treatment of this waste and segregates the harmful elements. The manufacturing units can use this cheaper recycled raw material instead of costlier fresh material which costs multifold. This alternative saves costs for the production of new products.

Resource Efficiency

Hazardous waste recycling does not only save costs for businesses but also resources. When industries utilise recycled materials, it lowers the demand for fresh resources and they continue the manufacturing process with the recycled raw materials. Apart from the resource savings in terms of raw materials, these recycling plants also save resources in terms of fuel. The energy required to obtain reusable recycled raw materials is lower than the energy required to process fresh raw materials and make them usable in the manufacturing process.

Indirect Benefits

Businesses that comply with environment-friendly policies earn a soft influence over the consumers and build a market reputation. Their customers appreciate their efforts to support sustainable development. Such compliance also avoids any potential legal hurdles. The State Pollution Control Board and Central Pollution Control Board may put financial penalties on the entities in case of non-compliance with these Hazardous Waste Management Rules.

There are some requirements that the business entity should fulfil before establishing a Hazardous Waste Recycling Plant. He must obtain authorization from their respective State Pollution Control Board to manage the hazardous waste. It provides them with the certification to handle hazardous waste. The authorization is mandatory for both the occupier and the controller who handles, generates, collects, stores, packs, transports, uses, treats, processes, recycles, recovers, utilises, offers to sell, transfers or disposes of any kind of hazardous waste. He should also acquire consent to establish and consent to operate from the State Pollution Control Board and in case of a union territory, from the Pollution Control Committee.

The State Pollution Control Board needs to make sure that the entity seeking the authorisation to manage hazardous waste or indulging in any activity that generates the hazardous waste is capable of what it is trying to do and is legally eligible for such permission. For this purpose, it requires such an entity to furnish some hazardous waste management certification that verifies the legality of the business. These documents are as follows-

• Aadhar & PAN of Responsible Person
• Business Registration (MSME, Partnership, CIN etc.)
• PAN Card of the Company
• GST Registration of the Company
• An application under Form I
• Emergency Response Plan
• Consent Order from SPCB
• Pollution Control Equipment Proof
• Layout Plan of the Facility
• Compliance Report of Previous Year
• Environment Clearance
• Process Flow Chart

Now that you are aware of the basic requirements for the establishment of a Hazardous Waste Recycling Plant, we can move forward to look into the process to get all the formalities done in this regard. The process comprises the following steps-

Consents For Hazardous Waste Management

• You must acquire a site for the establishment of your plant. It can be through a purchase, rent or lease deed or it can be your existing property.
• This site should not be in a prohibited area hence make sure to choose an industrial area for Hazardous Waste Management Plant Setup.
• You should make a plan for the layout and operations of your plant.
• You need to collect the required certificate as needed for the grant of consent for the establishment as well as operate the Hazardous Waste Recycling Plant.
• Once you are ready with the necessary documents, you can move the application for consent online through the SPCB portal of your state.
• After reviewing your application, the State Pollution Control Board may grant consent if your application satisfies the necessary requirements.

Authorisation For Hazardous Waste Management

• The Occupier or the operator needs to obtain authorisation from the State Pollution Control Board.
• For this purpose, you need to prepare the above-mentioned documents.
• You need to submit the application under Form I for the grant of authorisation. It works as a licence to deal with the hazardous waste.
• In case you are submitting the application for renewal of the authorisation then you also need to attach the latest compliance report of the previous year along with the application.
• You have to submit the renewal application at least three months prior to the expiry of your license.
• The State Pollution Control Board goes through the submitted application and reviews the details mentioned therein and the documents submitted along with it.
• If they find the application and the submitted documents in a good position then they accept it and grant the authorisation to the applicant.
• This authorisation allows businesses to deal in hazardous waste management including generation, storage, collection, processing, recycling etc.

SOP For Hazardous Waste Recycling Plant

• As the authorisation provides you permission to set up a Hazardous Waste Recycling Plant, now you can set it up and start operating but with the Standard Operating Procedure (SOP) as prescribed by the Central Pollution Control Board.
• You should assess the environmental soundness of the recycling process to ensure that it does not cause undue harm to the environment. You should also take all the necessary preventive measures accordingly.
• The emissions released from the plant should be as low as possible. You should assess the potential pollution, these emissions may cause to the environment.
• You should minimise or eliminate the use of hazardous and toxic substances in the process of recycling to whichever extent possible.
• Tracking the resources used in the recycling plant, utilities paid, and residues generated by it can be very helpful in decision-making. You should maintain the data in this regard and if the efficiency is not impressive then it will be better to shift to an alternative process.
• The quality of resources recovered and the residues generated also matters a lot. If the quality of resources recovered is not good enough for the purpose of reuse then also you need to look for an alternative process.
• Fugitive emissions are unintentional and undesirable emissions that may take place anytime and you need to be prompt to deal with any such situation. You should avoid recycling processes that have a higher chance of fugitive emissions.
• You should take care of any potential exposure to human resource dealing with hazardous substances. They should wear preventive gear at all times to stay safe in such a dangerous work environment.
• Manual handling of hazardous substances involved in a recycling process is an important matter of consideration. You should prefer and promote the use of unmanned processes whenever and wherever available and discourage manual handling.
• Other potential environmental, health and safety matters should be considered when selecting a recycling process. You should use an eco-friendly and safe process for recycling that provides quality resources, uses low energy and generates recyclable residues in minimum amounts.

Compliance For Hazardous Waste Management Plant

• To utilise the processed hazardous waste after pre-processing for co-processing even within the premises of the occupier, requires obtaining authorisation from the State Pollution Control Board.
• The occupier must ensure that the hazardous waste is packed in a suitable manner as prescribed by CPCB for safe handling, storage and transport.
• The occupier should label the packaging and any other container containing hazardous waste as per Hazardous Waste Management Rules. This label should include category, characteristic, incompatibility, quantity, date of storage and physical state of the waste.
• The labelling should be non-washable material, weatherproof and clearly visible.
• When transporting hazardous waste from one state to another, the occupier should obtain a non-objection certificate (NOC) from the State Pollution Control Board of both the sending and receiving state.
• The occupiers and operators should maintain records of all operations done on the handling and disposal of hazardous wastes. They should also file annual returns to the SPCB.
• There are some wastes under the category of hazardous waste that fall under the ambit of EPR. If any producer sends this kind of waste then being a recycler you need to issue EPR Certificates to these producers with respect to the quantum of their submitted waste.

We, at Corpseed, have a team having years of experience and extensive knowledge relating to various horizons of Waste Management Laws and Compliances applicable in India as well as the processes involved to get the permissions required for the establishment of waste recycling plants. We perform desk-based research, documentation, and coordination to provide consultation to clients in establishing their businesses and fulfilling the compliance as prescribed by the applicable rules. For all your business needs, Corpseed acts as a one-stop solution.