A Policy Framework Derived from Lessons Learned in Khulna, Rajshahi, and Rangpur

Executive Summary
Bangladesh's sanitation sector has achieved over 99% latrinecoverage, but the workers who sustain this achievement remain structurally invisible. Field evidence from three city corporations - Khulna, Rajshahi, and Rangpur - shows a workforce that is 97–99% informally employed, earns as little as USD 30–80 per month, has no access to health insurance or compensation, and continues to die inside septic tanks. Between 2018 and 2021 alone, at least seventeen sanitation workers died in containment-emptying incidents across Bangladesh.This article distils six lessons learned from the three-city case study and translates them into a seven-pillar policy framework for the
protection of sanitation workers in Bangladesh. The framework is anchored in the Bangladesh Labour Act 2006 and aligns with the Citywide Inclusive Sanitation (CWIS) agenda, Sustainable Development Goals 6.2 and 8.8, and the International Labour Organization's Just Transition guidelines. It covers formalisation, climate-adaptive occupational safety and health, a just transition for manual emptiers displaced by mechanisation, a national compensation fund, accountability and inspection, dignity and public awareness,
and a data and worker-voice mechanism. Each pillar maps to specific responsible actors and to a phased implementation roadmap of zero to twelve months, one to three years, and three to five years. The framework is not a wish list. It is a structured responseto documented failures, designed to be operationalised within Bangladesh's existing institutional architecture.

1. Introduction and Context
Bangladesh's sanitation success is globally recognised. TheWHO/UNICEF Joint Monitoring Programme reports that over 99% of the population now has access to some form of latrine or toilet, and open defecation has been largely eliminated. Behind that achievement, however, lies an invisible and unprotected workforce whose occupational risks are paid for in lives.Pit and septic tank emptying is one of Bangladesh's most dangerous professions. The inhalation of methane, hydrogen sulphide, and ammonia that accumulate inside confined sewers and septic tanks is the prevalent cause of occupational death. Documented fatalities include three cleaners who died in Tangi, Dhaka in 2018 (Patwary et al., 2021); six workers who died at once in Jaypurhat and two more in Faridpur in 2019 while cleaning a
single septic tank; and six more who died during containment emptying across Dhaka, Tangail, and Kushtia in 2021. At least seventeen deaths in four years - and these are only the documented cases. The Bangladesh Labour Act 2006 recognises occupational safetyand health (OSH) as a key indicator of labour standards, but its provisions are broadly ignored for sanitation workers because the vast majority are informally employed. Sectoral initiatives - the FSM Convention hosted by the FSM Network Bangladesh in Dhaka in 2016, SNV Bangladesh's City Cleaners: Stories of Those Left Behind (Karim, 2017), and the SNV OSH manual for pit-emptiers (Repon et
al., 2015) - have raised the issue but have not yet translated into structural reform.This article presents a policy framework derived from field evidence across three Bangladeshi cities. Its objective is to give the Government of Bangladesh, city corporations, and WASH sector partners a structured, costed, and phased agenda for the protection of sanitation workers.

2. Methodology and Evidence Base
The framework presented in this article is drawn from the author's field research between April 2023 and August 2026 across three city corporations: Khulna City Corporation (KCC) in the southwest, Rajshahi City Corporation (RCC) in the northwest, and Rangpur City Corporation (RpCC) in the north. In each city, the author conducted focus group discussions with both manual emptiers (who use rope-and-bucket methods and physically enter pits and septic tanks) and mechanical emptiers (who operate vacuum tanker trucks), as well as key informant interviews with the city corporation Conservancy Officer. The findings have been published as five SuSanA forum case studies by the author and synthesised in two prior articles (a policy brief and a forum article). This article translates that evidence base into a structured policy framework. All worker quotations in this article are drawn verbatim from the focus group discussions, with consent for publication. Names are included at the workers' own request.

3. Lessons Learned from Three Cities
The three-city evidence base yields six interlocking lessons. Each lesson is documented across at least two of the three cities, and most are
documented in all three.

Lesson 1. Near-universalin formality is structural, not incidental
In Khulna, 97% of sanitation workers are informal; in Rajshahi, 98%; in Rangpur, 99%. The uniformity across three geographically and
administratively distinct cities demonstrates that informality is the standard employment model for sanitation work in Bangladesh, not an anomaly of one city or one mayor. The “muster roll” arrangement - paid per work-day, no contract, no benefits - is the default. Without formalisation, every other OSH intervention is non-binding.

Lesson 2. PPE without climate-adaptive design is wasted expenditure
Workers in Rangpur and Khulna have received PPE and OHStraining in 2018, 2020, and during the COVID-19 pandemic. By conventional
project metrics, they are “covered”. In practice, the gear is rarely worn because standard heavy-duty coveralls, gloves, and masks are designed for temperate industrial environments and cause profuse sweating and restricted movement in Bangladesh's 35°C-plus tropical heat. Abdul Malek, a vacuum tanker operator in Rangpur, put it directly: “I will use PPE if these are manufactured with comfortable design and materials.” Pranto Das in Khulna said the same. Distributing unusable PPE is not a successful intervention; it is a wasted one.

Lesson 3. “No work, no payment” nullifies the Bangladesh Labour Act 2006
The muster roll rule means that if a worker falls ill, isinjured, or stays home for a family emergency, the day's pay is deducted or stopped. Mosal Basfor, a manual emptier in Rangpur who began this work at the age of thirteen, asked: “If we are injured at work, we will not be compensated for our injuries, and no one will take responsibility. We maintain a healthy environment in the city, but what do we get?” The OSH provisions of the Labour Act are effectively unenforceable against informal workers who have no contractual standing. The Act exists on paper; the muster roll nullifies it in practice.

Lesson 4. Mechanisation without a transition policy creates new harms
The CWIS agenda promotes vacuum tanker trucks as a safer alternative to manual bucket-and-rope emptying. From an OSH perspective,
mechanisation is the right direction. From a livelihoods perspective, however, it has been catastrophic for traditional manual emptier communities. In Khulna, the introduction of vacuum tanker services displaced the existing manual emptier workforce without absorbing them into the new system. Gopal Das, a manual emptier with twenty-five years in the profession, reported that his fourteen-year-old son now accompanies him to work because the family can no longer survive on his USD 50 monthly income. Mechanisation without a Just
Transition policy produces child labour.

Lesson 5. Social stigma compounds regulatory failure
Sanitation work in Bangladesh is historically performed by low-caste Dalit Hindu communities, commonly called “horijon” or “sweepers”, and treated as “untouchable”. The stigma is operational, not just attitudinal. Abdul Malek in Rangpur hides his profession from his neighbours and works at night to avoid public teasing. Shamsul Islam in Rajshahi travels a long distance from home so that no one in his neighbourhood knows his occupation. The stigma suppresses worker voice, blocks collective bargaining, and prevents
the public recognition that would sustain regulatory reform.

Lesson 6. Fatalities continue without accountability or compensation
Despite seventeen documented deaths between 2018 and 2021, nocity corporation has been held accountable for failing to enforce confined-space entry protocols, and no family of a deceased sanitation worker has received statutory compensation. Shamsul Islam in Rajshahi, who has never received OHS training in fourteen years of operating a vacuum tanker, summarised the absence of accountability: “We just used once and through like waste.” Nitto Ranjan Hela, a sixty-three-year-old manual emptier in Rajshahi with twenty-eight years in the profession, said the same: “Where occupational health and safety supports are dream for us.” The continued fatalities are not
accidents; they are the predictable consequence of an unenforced regulatory regime.

4. The Policy Framework: Seven Pillars for Bangladesh
The seven pillars below translate the six lessons into a structured policy framework for Bangladesh. Table 1 maps each lesson to its corresponding pillar(s) and to the actors responsible for implementation.

Pillar 7 (Data, Monitoring, and Worker Voice) is foundational and cross-cuts all six lessons: without granular data and institutionalised worker voice, none of the other pillars can be monitored or sustained.  Pillar 1. Formalisation and Decent Work
Abolish the muster roll in every city corporation and formalise all sanitation workers with written contracts, wages aligned to the
national minimum wage, paid sick and annual leave, and enrollment in the government health insurance and pension schemes. Formalisation is the precondition on which every other pillar depends; without it, the Bangladesh Labour Act 2006 remains unenforceable for the workers who need it most.

Pillar 2. Climate-Adaptive OHS Standards
Develop and promulgate a Bangladesh Standard (BDS) for climate-adaptive PPE suitable for tropical sanitation work, including
breathable coveralls, moisture-wicking gloves, and lightweight respirators. Procure and replace PPE at no cost to the worker. Mandate gas-detector checks, confined-space entry permits, and the presence of a trained safety supervisor before every septic tank or sewer cleaning operation. The Bangladesh Standards and Testing Institution (BSTI) should lead the standard-setting, in consultation with the Department of Inspection for Factories and Establishments (DIFE) and INGOs experienced in tropical-climate PPE design.

Pillar 3. Just Transition Mechanism
Require every city corporation introducing vacuum tanker services to adopt a written Just Transition policy for displaced manual
emptiers. The policy must include apprenticeships as drivers, helpers, or maintenance staff; a one-year transitional allowance; and education stipends for the children of manual emptier families. This pillar operationalises the ILO Just Transition guidelines (2015) in the sanitation sub-sector and prevents mechanisation from creating the next generation of child labour.

Pillar 4. Compensation and Social Protection Fund
Establish a national Sanitation Workers' Compensation Fund, financed jointly by city corporations and the central government, to provide
statutory compensation to workers injured or killed on duty and to support their families. The fund should be administered by an independent statutory body, not by the city corporations themselves, to avoid conflicts of interest. Eligibility should extend to both formal and informal workers, recognising that the vast majority of the workforce is currently informal.

Pillar 5. Accountability, Inspection, and Enforcement
Issue a Sanitation Workers' OSH Rule under the Bangladesh Labour Act 2006, with inspection powers for the Department of Inspection for
Factories and Establishments (DIFE) and financial penalties for non-compliant city corporations. Require city corporations to publish annual OSH compliance reports, including fatality and injury statistics, PPE distribution and replacement records, gas-detector use logs, and inspection outcomes. Without inspection powers and public reporting, the OSH Rule will remain a paper instrument.

Pillar 6. Dignity, Awareness, and Public Education
Launch a national dignity campaign to recognise sanitation workers as essential public health professionals. Integrate modules on
sanitation work and caste-based discrimination into secondary school curricula. Use state and private media to publicly acknowledge sanitation workers, particularly on national occasions. Regulatory reform alone cannot change a culture that treats sanitation workers as untouchable; the cultural shift must be explicitly funded and led.

Pillar 7. Data, Monitoring, and Worker Voice
Establish a national Sanitation Worker Registry under the Local Government Division, capturing every formal and informal sanitation
worker by city, age, gender, caste, employment status, and OSH training history. Conduct an annual independent occupational health survey. Create a grievance redressal mechanism accessible to informal workers, with whistleblower protections. Worker voice must be institutionalised, not extracted during research, and then ignored.

5. Implementation Roadmap
The framework should be implemented in three phases.
Short-term (0–12 months): Foundation
In the first twelve months, the Government of Bangladesh should:
(i) issue an official circular abolishing the muster roll and requiring city corporations to issue written contracts to all sanitation workers within twelve months;
(ii) constitute the Sanitation Workers' Compensation Fund by gazette notification, with initial seed funding from the central government;
(iii) commission the Bangladesh Standards and Testing Institution (BSTI) to develop the Bangladesh Standard for climate-adaptive PPE;
(iv) require every city corporation operating vacuum tanker services to publish a Just Transition plan within six months; and
(v) launch the national dignity campaign through a partnership between the Ministry of Local Government, Rural Development and
Cooperatives, the Ministry of Information, and civil society organisations. INGOs should reorient their existing WASH programming to support formalisation and Just Transition planning, not only infrastructure delivery.

Medium-term (1–3 years): Operationalisation
In years one through three, the government should:
(i) issue the Sanitation Workers' OSH Rule under the Bangladesh Labour Act 2006;
(ii)extend DIFE inspection powers to city corporation conservancy departments, with a dedicated sanitation-work inspection unit;
(iii) complete the national Sanitation Worker Registry and publish the first annual occupational health survey;
(iv) operationalise the Compensation Fund with the first compensation disbursements to families of deceased workers;
(v) achieve 100% formalisation of sanitation workers in KCC, RCC, RpCC, and at least ten additional city corporations; and
(vi) integrate dignity modules into secondary school curricula in pilot districts. Donor financing for sanitation should be explicitly conditioned on formalisation, Just Transition plans, and compliance with the new OSH Rule.

Long-term (3–5 years): Consolidation
In years three through five, the government should:
(i) extend formalisation and OSH Rule compliance to all city corporations and pourashavas (municipalities);
(ii) achieve full operational coverage of the Compensation Fund and Sanitation Worker Registry;
(iii) complete the rollout of climate-adaptive PPE nationwide, with periodic replacement cycles institutionalised;
(iv) achieve a measurable reduction in confined-space fatalities, with public annual reporting; and
(v) conduct the first independent national evaluation of the framework, with results published and recommendations integrated into the next five-year plan.

6. Conclusion
Bangladesh's sanitation success is real, but it is being subsidised by the lives, lungs, and dignity of the workers at the bottom of the
chain. The evidence from Khulna, Rajshahi, and Rangpur shows that the problem is not localised or accidental; it is structural. The seven-pillar framework presented here is not technically complex, financially extravagant, or novel. It requires only the political will to treat sanitation workers as workers - with the rights, protection, and dignity that the rest of the labour force takes for granted. The lessons have been learned in three cities. The framework is ready. What remains is the decision to implement it.

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