Mike Posner
Jul 20, 2017 · 5 min read

Toxic Loopholes: Hazardous Waste usage by large Indian fertilizer companies for Zinc fortification

Hazardous waste is a waste that poses threats to public health or environment. Hazardous wastes can take the form of solids, liquids, sludges, etc. and they are generated primarily by manufacturing and other industrial activities.

They can cause serious damage during inadequate storage, transportation, treatment or disposal operations and such waste should not be dumped into a landfill or soil as they tend to contaminate soil / water leading to impact on public health.

How does Indian Government control Hazardous Waste?

Government has notified Hazardous Waste Management Rules (HWMR) to ensure safe collection, handling, storage, transportation, processing, treatment or disposal of Hazardous Waste. Under the rules, only authorized and controlled entities are allowed to handle such waste and they are regulated by the State Pollution Control Board (SPCB) and Central Pollution Control Board (CPCB) under the Ministry of Environment Forest and Climate Control (MoEF&CC).

How can a waste be classified as Hazardous?

Schedule I of HWMR defines processes which generate hazardous waste. Zinc production and use is defined as a process which generates hazardous waste in the form of Zinc Ash which is a yellow to brown coloured powder containing heavy metals like Lead, Cadmium, Mercury and Arsenic which are all considered poisonous.

Schedule II of HWMR defines the concentration limits of poisonous substances like Lead, Cadmium, Mercury and Arsenic in material which can classify the material as hazardous. Schedule II Class C defines the toxicity levels which will classify the material as hazardous.

HWMR have clearly classified Zinc Ash as hazardous and purchase, sale, treatment and disposal of Zinc Ash is controlled through issue of licences to recyclers and Zinc Ash can only be sold to such licence holders.

What is happening in the Fertilizer Sector?

Fertilizer companies are faced with the challenge of increasing productivity of Indian farms through balanced fertilization programme and hence they need to provide micronutrients such as Zinc along with their regular fertilizers such as NPK.

This Zinc demand is met by coating or blending Zinc containing material with the NPK fertilizers and most commonly used material is Zinc Oxide.

Zinc Oxide is manufactured by processing pure Zinc or Zinc bearing hazardous wastes like Zinc Ash. On processing the impurities fall below the specified limit and the resultant material can be classified as non-hazardous.

As there is need to reduce the cost of zinc in fertilizers to make it affordable for farmers while making reasonable profits, fertilizers companies prefer to use processed hazardous waste.

What is the problem?

There is no guideline issued on usage of Zinc raw material for manufacturing fertilizers.

Ministry of Agriculture (MoA) has notified the Fertilizer Control Order (FCO) which defines the limits of impurities in finished fertilizers. There it has kept low levels of limit on all heavy metals for direct zinc fertilizers such as Zinc Sulphate Monohydrate, Zinc Sulphate Heptahydrate, etc.

However, Zinc Oxide has not been included in the FCO and no limits of impurities have been defined thereby it is free to be used for manufacturing fertilizer without any restrictions.

What is the result?

The fertilizer companies are specifying only the Zinc Content in procuring their zinc raw material and there is no guideline or restriction on content of heavy metals like Lead, Cadmium, Arsenic, Mercury, dioxins, free zinc metal, etc. in procuring Zinc Oxide.

This is leading to Zinc containing hazardous waste, such as Zinc Ash, Zinc Residue, discarded Zinc Catalysts, etc. being sold to fertilizer companies in the name of “Zinc Oxide”.

Result is that large fertilizer companies are violating HWMR in their purchase of Zinc Oxide and using Hazardous Waste for manufacturing fertilizers thereby jeopardizing the health and safety of Indian citizens and environment.

These heavy metals are known to be persistent bio-accumulative toxins (PBTs). PBTs persist for long periods of time in the environment – some indefinitely – and they can accumulate in the tissues of humans and wildlife. They are associated with damage to nervous / immune, kidney, blood vessels, lungs, bones, etc. Some of them are known carcinogens – i.e. Cancer causing substances.

There is a statutory requirement on sellers to obtain copy of SPCB licence of the buyers of hazardous waste. Fertilizer companies logically and rightly have not been issued such licence. However, the sellers (recyclers of Hazardous Waste) are not insisting on obtaining copy of the licences. They are able to do so as the waste is being sold in the name of “Zinc Oxide” which is processed material. Also there is no check on the fertilizer companies to stop procurement without specifying limits required to classify items as Hazardous Waste.

Fertilizer companies are violating the law by closing their eyes and buying Hazardous Waste in the name of Zinc Oxide. Worst still, they are using this material to coat their NPK fertilizers and becoming a conduit for hazardous waste being applied directly (without treatment) to Indian soils making them a dump-yard of toxic wastes. In short, material which is not allowed to go untreated even to designated waste landfills, is being dispersed directly to Indian farm soils via Zincated fertilizers.

What is needed?

Ministry of Agriculture (MoA) need to take stock of the situation and immediately issue guidelines on the specification of impurity levels in Zinc Oxide to be used by fertilizer companies for Zinc fortification on urgent basis before fertilizer companies become a dumping ground of poisonous industrial waste. Considering the fertilizer consumption in India and the need for Zinc fertilization in coming years this anomaly can lead to dumping of several thousand tons of poisonous waste in Indian Soils.

What is the international approach?

In the United States Environmental Protection Agency (EPA) realized that recycling of hazardous wastes into fertilizer products does not always include the process of treatment or cleaning of hazardous waste, but rather dilution of the waste. Dilution does not reduce the toxicity of the hazardous constituents and have prohibited dilution as a form of treatment.

Additionally, Dioxin limits were put in place when some fertilizers were found to contain Dioxins which is among the most toxic and environmentally persistent chemicals known to humans. It is known to cause cancer, birth defects and developmental defects in children

Companies making commercial fertilizers from “recycled materials” or “hazardous wastes” have been asked to specify limits of heavy metals and dioxins on incoming material instead of just having limits in final fertilizer or contamination per hectare of soil.

I hope that this note is read by some responsible officers of the Government of India in Ministry of Agriculture and they take immediate action to issue guidelines on usage of Zinc Oxide in fertilizer or have Zinc Oxide incorporate in FCO with appropriate limits on heavy metal, in consultation with the industry association, MoEF&CC, zinc ash recyclers and the fertilizer companies.

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