A few weeks ago we were travelling from Bangalore to Hyderabad by train. While waiting in the lissom corridor for the toilet to be free, the bogey door suddenly swung open and we saw a mother carrying her child and holding what seemed to be a soiled diaper wrapped in newspaper at first sight. In unison, we all looked at the tiny space meant to be a rubbish bin under the sink, spilling from the brim. Within microseconds, the soiled packet was flying out of the train. Shell shocked, we felt compelled to ask her why she couldn’t have gone to the next bogey and thrown her trash in the space allocated there!
The woman glowered and scowled and told us indignantly that it was her sanitary napkin and she couldn’t be bothered to walk around the train to dispose it.
“How long could I have held on to that thing”, she said with a grimace.
It is safe to say that this instance is probably not the only time someone has thrown out personal trash. The very act of menstruation is shrouded in secrecy. Sanitary pad and tampon producers have been focusing awareness campaigns on using their products for a healthy, confident, and sugar overdosed woman who will necessarily wear white pants on her period day. Unfortunately, there has not even been a ‘whisper’ of waste management related to these products once used by women to ‘Stayfree’.
India has nearly 355 million women in the menstruating age bracket and on an average, each woman spends 3500 plus days of her life menstruating. The AC Nielsen’s study places the current sanitary napkin usage at about 12% of this 355 million which in itself is generating around 9000 tons of menstrual waste per month. It doesn’t take a genius to do the math to comprehend the waste implications of 355 million women using commercially made plastic sanitary napkins which take about 500 years to decompose.
Government policies to improve menstrual hygiene and health have been minimal at best. These interventions have focused largely on the distribution of low cost sanitary napkins in schools and rural areas. Like with most things, it is not in the nature of a welfare state to think through their next step. There is little or no follow through on what to do after using these napkins.
Does it go into trash cans that are picked up by the municipal corporation? Where is it taken after? The landfill? Seems logical so far. What happens once it reaches the landfill? No clue? We’re pretty stumped too. (But if you know, please email us!)
The entire use to disposal cycle of the sanitary napkin has gaping holes. At the face of it, menstrual waste seems to resemble discovering a new species in 2016; the kind one is unable to classify as either amphibian or reptile.
At the core of how to dispose of something is to know what the something is classified as. According to wen.uk, the materials used in sanitary napkins, tampons, and panty-liners often use a mixture of cotton and rayon, plastic polymers, bleached wood pulp, and super-absorbent gel (polyacrylate). The organic material (wood pulp and any cotton present) often contain dioxins and furans, a highly toxic environmental pollutant. The contents of the menstrual hygiene products are what makes the laws extremely dubious. Strangely, these products have no clear method of disposal because they fit into multiple brackets of waste.
While the list of classifications menstrual waste could fall under would be exhaustive, it has perhaps in each law been referred to as something different. Central Pollution Control Board (CPCB) has classified sanitary napkins as municipal solid waste. According to the Municipal Solid Waste (Management and Handling) Rules, 2000, menstrual waste is considered household waste. As per the Bio-Medical Waste (Management and Handling) Rules, 199 it is bio-medical waste.
A recent campaign by Change.org addresses these questions and calls for the amendment of the currently vague Draft Municipal Solid Wastes (Management and Handling) Rules, 2015 and The Plastic Waste (Management and Handling) Rules, 2015 towards the adequate handling of absorbent hygiene product waste. The limited upside is that the disposal of sanitary towels finds mention in the Draft Municipal Solid Wastes (Management and Handling) Rules, 2015, which recognizes that a category of wastes known as “sanitary waste” (which includes sanitary towels or napkins, condoms) exists. The Rules specify that as the duty of a waste generator, one should securely wrap the used sanitary waste in a newspaper and place it as non-biodegradable waste. The Rules also specify the transport of wrapped sanitary waste to the respective processing facility or material recovery facilities (MRF) or secondary storage facility.
Once we move past the mystery of what sanitary menstrual waste is classified as, we enter the magical world of disposal. The law lacks clarity on two accounts – the segregation of sanitary waste, and its subsequent disposal. In respect of the first account, it is immediately obvious that wrapping sanitary waste in a newspaper does not lead to automatic segregation of sanitary waste from other waste material. This has led to the problem of rag pickers or waste segregators not being able to differentiate sanitary waste from other kinds of waste. In fact, to know what is inside a wrapped newspaper ball, a segregator will need to open the wrapping, which in itself renders the wrapping-up of the waste pointless. Since contact with such waste by segregators remains, this also has the potential to lead to spread of infections and disease amongst waste pickers/segregators.
So what does a waste collector/ segregator do in this situation? Probably let the trash remain until a mountain is formed out of a molehill.

Karnal Byepass Dumping Ground
Ah, the scenic view of rolling hills, where your olfactory senses are cued into its existence before your eyes lay sight on the filth, plastic bottles, wrappers, the rest of that mango you ate yesterday.
What happens once it reaches the landfill? How is it segregated? Are sanitary napkins put together with other plastics? Or are they put with the bio-waste?
The lack of clarity when trying to answer these questions is what makes this a unique research opportunity. It is unfortunately not a surprise that India’s waste management infrastructure is inadequate to deal with processes that are core to dealing with general waste, let alone non-biodegradable plastic sanitary napkins - products that are rapidly entering the rural market as well. The associated environmental health costs of using commercial menstrual hygiene products without proper disposal could be staggering.
According to the Centers for Disease Control and Prevention (USA), “...both Hepatitis B and C can thrive in blood-soaked materials and in residue on restroom fixtures left behind by infected individuals. The virus is extremely hardy and it can survive in a drop of blood or bodily fluid or even on a dry surface for weeks and still be capable of causing infection. Hepatitis C may survive on environmental surfaces at room temperature for up to four days. The viruses can enter the body through direct contact with broken skin. ... (I)t must be assumed that any and all soiled feminine care products may contain blood-borne pathogens.”
While this issue is being extensively advocated against by various NGOs including SWaCH, it is important to focus on what policy initiatives can be taken to begin understanding and then dealing with the problem at hand.
That brings us to the second account, which is the disposal of sanitary waste after segregation. The Rules simply state that “respective processing facility or material recovery facilities (MRF) or secondary storage facility” is where such waste will be transported, without providing for, or even mentioning, the next stage in the process, that is, the manner of disposal of such waste once segregated. A possible out is to adopt the best practices in other countries. For example in the UK, to change the rhetoric of sanitation in the menstrual health space, it has been held vital to first understand that it is not just the provision of products and services that makes a difference, but also what happens to these products at the point of disposal. The UK laws stress on ‘Duty of Care’. ​​
The Duty of Care Regulations 1991 & The Environmental Protection Act 1990, Section 34 provides that sanitary waste should be managed to the point of disposal. It is a necessity that waste is carried by a licensed carrier with a valid carrier’s certificate and a complete audit trail of documentation must be available for viewing at all times. Failure to comply with these laws can lead to a large fine or imprisonment. These laws act as one way of ensuring that a suitable and hygienic method of sanitary waste disposal is available at all times to every female.
Although this may fix the first problem of proper segregation, however, world over policy makers are grappling with the issue of end disposal. Currently, in most countries, sanitary waste is being sent to landfills. This brings us back to the problem of sanitary waste taking hundreds of years to degenerate.
Incineration has also been considered as a means of sanitary waste disposal but it leads to release of harmful toxins into air. While practices that work in different countries may exist, they need to be fleshed out and contextualised for India.
The regulatory and infrastructural framework of waste management in India is at a relatively nascent stage. Improving the environmental soundness of industry standards to record-keeping, personnel safety and disposal systems are at the core of this framework. However, while attempts have been made to address the overarching needs of environment protection, the lack of a clear national policy that looks at waste management can exasperate the current situation. Also, like most laws in India, simply enacting a legislation does not necessarily mean the implementation of such laws. Judging by the current state of our waste disposal system, it is the equivalent of millions of women on trains throwing out their used sanitary napkins/tampons.
What is important to remember is that everything that our government does, does not need to be a knee-jerk reaction. Good governance is also about anticipating the effects of every possible intervention and having the corrective measures in place so that in 2020, we are not in a situation where all our cities are a popular destination for toxicity and our villages are dumping grounds.