Dear Rahul
The Advisory Note on Septage Management in Urban India by the Ministry of Urban Development Government of India also quotes the same criteria of USEPA and WHO. It also mentions that till there is standard from the CPCB, criteria of USEPA / WHO should be followed. There is no such standard from the CPCB yet.
FCO norm may be for the compost prepared from municipal solid wastes where chance of pathogens is minimum in comparison to septage.
Thanks

pawan

Dear Dr. Jha & other Experts,

Apologies for the delayed response.

What is meant by pathogen free ? Does it mean pathogen limit as ‘Nil’. What indicators are to be used officially for monitoring pathogen reduction ?

The USEPA Biosolids regulations state all sewage sludges that are to be sold or given away in a bag or other container for application to the land, or applied to lawns or home gardens must meet Class A pathogen requirements.

Class A sewage sludge must meet one of the following criteria at the time of use or disposal, when prepared for sale or give away and passes on to the user for land application or producing other products:
1) A Fecal coliform density less than 1,000 Most Probable Number (MPN) per gram of total dry solids (1,000 MPN/g TS)
OR
2) A Salmonella sp. density less than 3 Most Probably Number (MPN) per 4 grams of total dry solids (3 MPN/4g TS).
In Addition: Other requirements (viz. Time / Temperature or Alkaline Treatment, etc.) should be met.

The WHO guidelines for excreta and faecal sludge for use in agriculture mention the helminth eggs concentration <1/g total solids and E.Coli concentration should be <1000/g total solids.

With this context, my humble submission is, in India if FCO norms are to be applied to organic manure sourced from treated / stabilized ‘human excreta’ then what indicators (viz. E.Coli, faecal coliform, etc.) should be used for pathogen monitoring / reduction should be clearly stated. The USEPA & WHO do not have the pathogen limit as ‘Nil’. Should we reconsider this.

Thanks.
Rahul

Dear Rahul

It is difficult but not impracticable to make compost from septage pathogen free.



thanks
pawan

Dear Dr. Jha,

Thanks for the reply.

The National Policy on Faecal Sludge and Septage Management, 2017 (Government of India, MoUD) states ‘the Solid Waste Management Rules 2016 will also apply for disposal and treatment of faecal sludge and septage, before or after processing, at landfills and for use as compost’.

The SWM Rules, 2016 states ‘The end product compost shall meet the standards prescribed under Fertilizer Control Order notified from time to time’.

The Fertiliser (Control) Order 1985 states organic fertilizer means ‘substances made up of one or more unprocessed materials of a biological nature (plant/animal) and may include unprocessed mineral materials that have been altered through microbiological decomposition process’. The Fertiliser (Control) Third Amendment Order, 2013 states ‘The source of organic manure is any of the plant biomass / animal biomass/ animal Excreta’. The pathogen limit should be ‘Nil’ as per FCO norm.

With this context, my questions are
1. Is FCO also applicable to organic manure sourced from treated / stabilized ‘human excreta’ ?
2. If yes, then the pathogen limit should be ‘Nil’ for organic manure as per the FCO norms. Which all indicators viz. faecal coliform, salmonella spp., Helminth eggs (Ascaris lumbricoides) , E coli, etc. are applicable for the compliance to the FCO norms (Nil pathogen limit) ?
3. Is it practical to have the pathogen limit as ‘Nil’ as mentioned in FCO norms for use of treated septage / sludge as organic manure ?

Thanks.
Rahul

Dear Rahul

Quality of compost in India should be as per the standard of Ferliliser Control Order 2013, Government of India . Same is mentioned in the Solid Wastes Management Rule 2016, Government of India.
Cost of FSM is mostly higher than the sewerage system due to several reasons. In India there are only a few such systems implemented in some states. Kindly check the cost vrs quantity of septage of those plants.

Pawan

Dear Dr. Jha,

Thanks for your reply.

I agree with you that the treated sludge from the STPs in India is not suitable for use in agriculture purpose due to the presence of heavy metals / toxic elements. In my white paper, I have raised the question ‘Are the right standards in place in India for safe reuse of treated septage for agriculture ?’ During the various events (conferences / workshops / discussion, etc.) on FSM we hear very often that the treated septage/sludge is being reused in agriculture in some parts of India (eg. Bengaluru) & also encourage the reuse of treated septage/sludge for agriculture. I have not come across any comprehensive standards for safe reuse of sludge for agriculture in India. Should we encourage the reuse of treated septage for agriculture without having clear & comprehensive standards for the same ? I understand ‘reuse of sludge for agriculture’ is a topic to scientific research for the country but is being sometimes used (unintentionally) very loosely in the sanitation sector. Many aspects related to the reuse of septage for agriculture (eg. crop species suitable for reuse of treated sludge, land application rate of sludge / cumulative pollutant loading rate, safe pathogen limits for reuse, compliance mechanisms for standards, etc.) are still to be discussed / addressed for achieving the desired sustainable progress in the sanitation sector in India.

I fully second your statement ‘FSM coupled with appropriate decentralized wastewater management may be a complete sanitation solution’. This is something I feel is not discussed very often during the events (conference / workshops / discussions, etc.) on FSM which unintentionally gives an incomplete picture to the listeners. I strongly believe that the statement you made here should be the first statement during any discourse (most importantly when the discussion is with government decision makers) on FSM. As a professional & moral responsibility, during any such discussion on FSM, I always try to convey this statement (without fail) to give a complete picture of the sanitation solution.

While interacting with various government officials, I have noticed that they are of the opinion that the cost of FSM is very less compared to the underground sewerage system because they generally associate only FSTPs with FSM & compare it with the ‘underground sewerage networks & STPs’. My humble submission here is this is not correct, because FSM is beyond FSTPs i.e. it includes septic tanks & also septage emptying & transportation. Still, cost of FSM cannot be compared to the underground sewerage system because FSM does not include the safe management of grey water & effluent from septic tanks. Hence my simple argument is if one wants to compare the cost of underground sewerage system with FSM then he should include all the key components of FSM & add to it the cost of decentralized sanitation systems for managing grey water & effluent from septic tanks. I understand one of the main reasons for choosing FSM as an appropriate solution for the town / area is the cost without really having the complete understanding of end to end costs. My only request is, the decision makers should plan the complete sanitation solutions for the entire town in one go and can implement (construct) them incrementally.

Thank you once again for your reply.

Dear Elisabeth,

I am glad to receive your reply. Thanks for appreciating the format of the white paper.

I have intentionally not covered the issues related to the management side in the white paper, because the Govt. of India has been trying to highlight this aspect through various means (eg. National Policy on Faecal Sludge and Septage Management, 2017). The main idea of writing this white paper was to focus only on that aspects of FSM which have not been generally covered / discussed (especially in India) and are crucial for the advancement of sanitation sector.

You have mentioned the web link for the thematic discussion rightly. Apologies for missing to add the link to the paper.

As per Census 2011, Septic tank is the most common form (38 % of urban households) of sanitation system in urban India followed by piped sewered systems (33%), pit latrines (7%) & other latrines (2%). As per Guidelines for Clean India Mission Urban (2014), single pit latrines are considered insanitary and shall be converted to sanitary latrines. Theoretically, the digested sludge from properly designed, constructed & maintained twin pit latrines does not require vacuum trucks for desludging. Hence, it may not be incorrect to say, that it is inappropriate to discuss FSM for pit latrines in urban India. Due to the above reasons, I have intentionally used the word septage generated in septic tanks to distinguish it from the word faecal sludge. Hence, I intend to limit the discussion to septic tanks only.

Thanks for seconding the thought that FSM is not a complete sanitation solution & an additional sanitation system for safe management of grey water & effluent from septic tanks is required. This is something, I felt that has been missing in the events (conference / workshops / discussions / etc.) related to FSM in India. It would not be incorrect to say that in the absence of proper management of effluent from septic tanks & grey water from households, septage management (alone) helps in achieving cleaner environment without directly contributing to cleaner towns. I believe, even after 100% successful commissioning of FSM projects in a town, the town would still have the existing open drains (contaminated with grey water & effluent from septic tanks) flowing all across the town to the nearest water bodies leading to public health risks. Most importantly, after interacting with many government officials I have noticed they are not informed on this aspect & think that FSM would solve all of their environment & health issues related to sanitation. This experience prompted me to put this point in the white paper.

I am not sure if my white paper has caused any ripple. However, it was appreciated by few senior sanitation experts in India. My main audience for the paper is the government decision makers in India. The FSM sector experts in India are also my audience. I have been able to communicate my perspective in few events but the discussion is maybe yet not started. The main objective of the white paper is given that a lot of money is being invested in the sanitation sector in India & I simply want the government officials & the sanitation sector to be mindful of the choices they make while selecting the most appropriate sanitation solutions.

Thank you once again for your reply & thanks to SuSanA for giving me this platform for presenting my view.

Dear Rahul and All
Centralized Sewerage Treatment Plants (STPs) and Septage / FSTPs have slightly different objectives and applicability. Former takes care of total waste water while later is concerned only with black water. Before one compares cost of the two systems, one should look into applicability, advantages / limitations of the systems;
Centralized STPs
i. Centralized STPs is suitable for metros and class I cities where population density is sufficiently enough to have minimum flow velocity of sewage.
ii. However, as per the report (2015) by the Central Pollution Control Board, Government of India, there are only 522 decentralized and centralized Sewage Treatment Plants (STPs) in operation in India, (Delhi alone has 34 such STPs). Majority of the centralized STPs are not functioning properly due to various reasons. Under such conditions, semi treated sewage is allowed to flow into low land areas and nearby water bodies causing severe atmospheric, ground water pollution and public health risk.
iii. Effluent and sludge from centralized STPs contain heavy metals and toxic elements, due to mixing of industrial wastes, and their adverse synergistic affects on soil and crops can’t be predicted and regulated. Therefore, it is not suitable for use in agriculture purpose.
iv. Centralized STPs are not suitable for small towns due to unaffordable cost to the local government and required flow velocity of sewage is generally not met due to low population density.
v. It is not feasible for peripheral areas of the metros and class I cities due to low population density; not suitable for rural areas.
Septage / FSTPs
 FSTPs are suitable for small towns, rural areas and peripheral parts of metros and Class I cities.
 It can be implemented for any topography. There is complete recycling and reuse of treated effluent and dried sludge as manure for agricultural purposes.
STPs are implemented with capacities in MLDs where as FSTPs are normally in the range of 5- 50 m3. Therefore, unit cost of the former is always lower. However, life time cost (say 20 years) and outputs with the FSTPs should be much better than the STPs.
FSTPs coupled with appropriate decentralised waste water treatment may be a complete sanitation solution for smaller towns.

Best
Pawan

Dear Rahul,

Thanks for sharing this publication here, entitled: Septage Management in Urban India – Providing Conceptual Clarity - White Paper
www.susana.org/en/knowledge-hub/resource...library/details/3216

I like the format and you seem to have addressed many of the important issues. (one thing that might be missing is perhaps the management side, i.e. the role of utilities, local government, private sector and NGOs - who is responsible for what, who are the main stakeholders).

If the paper was based on a thematic online discussion on Faecal sludge management organized in 2017 by India Sanitation Coalition then I think you should have added the link to the paper. Is this the thematic discussion you meant?: forum.susana.org/component/kunena/275-fa...usana-indian-chapter

About terminology: I am always baffled why people in India now seem to use "faecal sludge and septage" rather than just "faecal sludge" - given that faecal sludge is the overarching term.

You wrote:

There appears to be a very thin line between septage
and faecal sludge. Septage is limited to septic tank
contents where as faecal sludge includes contents
from other on-site systems including the septic tank.
In other words, faecal sludge from septic tanks is
known as septage, but faecal sludge and septage are
interchangeably used in India.

Why in the paper are you mainly using the term "septage"? Is it because you want to limit the discussion to septic tanks and not include pit latrines? Or is it because septage rolls more easily from the tongue, and is more "popular", than faecal sludge? (a bit like why people like to speak of "composting toilets" even if they are really UDDTs sometimes...)

And I agree with you that FSM is not a complete solution if greywater management is not included. To make it "complete" sanitation (from a technology viewpoint) you'd need to also address greywater management, and also solid waste and stormwater management.

Has your White Paper caused a bit of a ripple? Who is your target audience and have you been able to get is read and discussed?
Again, thanks for sharing and engaging!

Regards,
Elisabeth

Dear Waste-water Experts,

As you all must be knowing since few years faecal sludge management / septage management is getting a lot of attention globally in the waste-water sector. So is the case in India. The Government of India has included Faecal sludge management as one of the thrust areas in the funding programmes (Atal Mission for Rejuvenation & Urban Transformation) for waste-water management i.e. funding is available from the Central and State Government for implementing projects related to septage management. Due to this funding, many state governments and municipalities in India have started showing interest in septage management.

Septage management is relatively a new concept (for the Government officials especially at State level & municipal level in India) compared to the conventional underground sewerage system. Many states / cities in India have started planning projects related to septage management.

With this context, we felt it would be good if this unfamiliar concept called ‘Fecal sludge management / Septage management’ could be explained to the decision makers through a short & quick module. Hence, a white paper* was prepared as an attempt to provide fundamental conceptual clarity on the subject of septage management in India. This white paper titled ‘Septage Management in Urban India – Providing Conceptual Clarity’ was prepared based on our real experience in the FSM sector in urban India. The format used for writing the paper is the use of few basic ‘guiding questions’. The format and the language used in the paper has been kept very simple for the ease of understanding by any reader. Few of the guiding questions discussed in the paper are India specific, but some of the other questions are also applicable outside India.

I would be glad to receive any type of inputs on the white paper. As an example, I would like to receive your inputs on one of the questions in the white paper ‘Is septage management a complete sanitation solution ?’.

If this paper can contribute to bringing even some clarity (new perspectives) on the subject of septage management to even a handful of decision makers / experts in the sector, the objective of the paper would be achieved. This would be our success.

Wish you Happy reading.



*This paper is based on a thematic online discussion on Faecal sludge management organized in 2017 by India Sanitation Coalition on the SuSanA discussion forum.

*Link for downloading the white paper ‘Septage Management in Urban India – Providing Conceptual Clarity’
www.susana.org/en/knowledge-hub/resource...library/details/3216