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Analysis of CPCB circular Dt.Feb-2025'

 Central Pollution Control Board (CPCB) circular dated February 25, which reclassifies hospitals with up to 50 beds from the Orange category to the Green category under the pollution control framework.

1.Context of CPCB Categorization*:

   - The CPCB categorizes industries into Red, Orange, Green, and White based on their Pollution Index (PI), which considers emissions, effluents, hazardous waste, and resource consumption . Hospitals are typically classified under Orange due to bio-medical waste (BMW) and liquid waste generation, requiring Consent to Establish (CTE) and Consent to Operate (CTO) under the Water (Prevention and Control of Pollution) Act, 1974, and Air (Prevention and Control of Pollution) Act, 1981 (

   - Green category industries have a lower pollution index (PI < 40) and face less stringent compliance requirements, such as longer CTO validity (up to 15 years) compared to Orange (5 years) (). If hospitals with up to 50 beds are reclassified as Green, it would imply a lower perceived environmental impact, potentially simplifying regulatory processes

2. Impact on Medical Establishments*:

   - Simplified CTE/CTO Process*: By Reclassification,  hospitals with up to 50 beds would benefit from easier CTE/CTO processes and longer validity periods (15 years for Green vs. 5 years for Orange) . This reduces administrative burdens and costs for small hospitals, clinics, and healthcare facilities, aligning with the government’s Ease of Doing Business initiative    

-Sewage Treatment Plant (STP) Requirement*: The news claims that Green category hospitals may not need STPs. However, the CPCB’s guidelines on liquid waste management, particularly under Schedule II, Section 8 of the Bio-Medical Waste Management Rules, 2016, mandate compliance with effluent discharge parameters (e.g., pH, BOD, COD, TSS, and bioassay tests) regardless of category . Even without an STP, hospitals must treat liquid waste to meet these standards, possibly through alternative methods like chemical disinfection or outsourcing to Common Effluent Treatment Plants (CETPs

   - No Relief from Liquid Waste Parameters*: The Green category status does not exempt hospitals from complying with liquid waste management parameters under Schedule II, Section 8. These parameters ensure that treated effluents are safe for discharge into water bodies or sewers . 

Without changes to these standards, the reclassification offers limited practical relief for liquid waste management compliance .

 -Advocacy for Parameter Modification: The IMA’s push to modify or abolish liquid waste parameters for Green category hospitals suggests a desire to further reduce compliance costs. However, this would require significant CPCB policy changes, as liquid waste from healthcare facilities can contain pathogens, pharmaceuticals, and chemicals, posing risks to public health and the environment

3.Impact on Bio-Medical Waste Management Compliance*:

   - No Change in BMW Rules**: The reclassification does not appear to affect the Bio-Medical Waste Management Rules, 2016, which mandate segregation, treatment, and disposal of BMW through authorized Common Bio-Medical Waste Treatment Facilities (CBWTFs). 

-Hospitals, regardless of category, must comply with these rules, including obtaining authorization and maintaining records.

   - Potential Financial Relief*: Smaller hospitals (up to 50 beds) may benefit from reduced consent fees and less frequent renewals under the Green category.  However, BMW handling costs, such as CBWTF membership fees, remain unchanged

   - Operational Continuity: The longer CTO validity (15 years) could provide operational stability for small hospitals, reducing the frequency of compliance audits and renewals. However, they must still adhere to regular monitoring and reporting requirements for BMW and liquid waste.

4. Critical Considerations:

   - Environmental Impact*: Reclassifying hospitals as Green without relaxing liquid waste parameters maintains environmental safeguards, as untreated effluents can pollute water bodies . However, if the IMA succeeds in modifying these parameters, it could risk weakening protections unless alternative treatment methods are robust .

  - Regulatory Burden vs. Public Health: Simplifying compliance for small hospitals could encourage more healthcare facilities to operate legally, especially in rural or underserved areas. However, lax enforcement of waste management standards could lead to public health risks, particularly if liquid waste treatment is inadequate.

   - IMA Advocacy*: The IMA’s efforts to influence CPCB policy reflect a broader push to balance regulatory compliance with the operational challenges faced by small healthcare facilities. National-level advocacy could lead to standardized changes across states, but progress depends on CPCB’s response and scientific justification for altering parameters.

 

In Conclusion, the reported CPCB circular of February 25, 2025, reclassifying hospitals with up to 50 beds as Green,  would simplify CTE/CTO processes and extend consent validity to 15 years, reducing administrative burdens for small hospitals. However, compliance with liquid waste parameters under Schedule II, Section 8 remains mandatory, meaning the absence of an STP does not exempt hospitals from treating effluents to meet standards. 

The IMA’s advocacy for modifying these parameters could further ease compliance but raises concerns about environmental and public health impacts.  

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