Review of Building Regulations from Indian States on FSM

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Review of Building Regulations from Indian States on FSM

Dear members,

In the Scaling City Institutions for India: Sanitation (SCI-FI) programme at the Centre for Policy Research (CPR), we conduct policy research and analysis to support non-sewered sanitation in India. *

As part of the SCI-FI initiative, we have been trying to understand the enabling legal and regulatory frameworks for faecal sludge management (FSM) operations in India. There is emerging formal recognition for FSM: in 2017 the national government issued a National Policy for Faecal Sludge and Septage Management, and there is funding under the national AMRUT scheme for FSM facilities in eligible cities. At least 4-5 states have FSM policies in place, and several others have policies and guidelines in various stages of preparation. At this stage there is a need to establish new rules of the game, and to create the conditions for investments, and for the development of new facilities and capabilities. These laws and rules will need to cover public institutions, private companies and private individuals and their relations with each other. For this we need to see what existing legal powers, rules and regulations do exist, and where the gaps are.

As we know, having appropriate on-site containment facilities is an essential part of the FSM chain. We also understand that building owners (and building managers for larger buildings) should be principally responsible for having on-site facilities. However, it is not so clear that this is actually a legal responsibility for owners and managers of buildings. We reviewed a number of building regulations recently to see what these regulations say about on-site containment for buildings on sites which cannot be connected to sewer networks. We found in this review that most (but not all) building regulations mandate some form of on-site containment. Most of the regulations however fail to back this up with adequate information or detail. It also becomes increasingly clear, as we read the regulations, that planning cells in the various state planning authorities have a limited understanding of FSM, and the role of on-site containment facilities in FSM. Our draft report based on this review is attached with this message.

In this regard, we are seeking the following inputs from members:

• What are the basic principles, standards and requirements for on-site containment in urban areas that could be included in a new regulation? Some of the issues to be considered are: (i) basic health and safety conditions in terms of location and construction standards, (ii) access for mechanised de-sludging operations, (iii) need for location specific standards for areas near water bodies, and in densely built up, congested areas.

• To address these issues, what kind of standards and specifications can we suggest?

We are also seeking comments and inputs on the report to further strengthen the same. Your inputs will be very valuable in strengthening our understanding and work on building by-laws and the provisions relating to FSM. We look forward to your contributions.

Arkaja Singh
Centre for Policy Research, New Delhi

* See here for more information about this project: (added by moderator)

SCI-FI (Scaling City Institutions for India) program at the Centre for Policy Research is currently working on urban sanitation.

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  • hajo
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Re: Review of Building Regulations from Indian States on FSM

Dear Arkaja,

the Lusaka City Council (LCC) in Zambia is currently in the process developing an on-site sanitation Bye-Law trying to promote better OSS solutions and application in which process I try to support them. In the process we also learned that existing sanitation regulations in Zambia relate mostly either to sewers or to septic tanks.

Additionally we have the problem in Lusaka that areas which depend on OSS (i.e. are not or cannot be sewered) are all located on an underground which prohibits any kind of percolation due to high ground water levels, little to no soil cover on top of karstic rock. But of course the Bye-Laws are meant to cover the whole of Lusaka, not only the peri-urban, informal, low-income areas.

We found it necessary that OSS Bye-Laws should elaborate on the following:

1. Define and describe possible OSS facilities (interface, containment). This should not be too restrictive as we never know what new technology may be developed and not be too open so that not too many different emptying / treatment technologies may become necessary.

2. Define areas of town in which what type of sanitation is permissible, i.e. in sewered areas no OSS can be permitted, further we have percolation and non-percolation areas for OSS. This serves the LCC for the approval of sanitation technologies within building permits and for the enforcement of sanitation in informal areas.

3. All sanitation facilities have to be constructed in conformity with approved standards and using approved materials especially where typical OSS materials are used such as SATO pan or urine diversion (UD) interfaces or specific containers collecting faeces or urine.

4. OSS requires service chains for emptying, transport, treatment and re-use/disposal as we have done away with sewers and WWTP for that purpose. LCC is responsible to regulate and enforce these service chains, while the local utility, Lusaka Water and Sewerage(!) Company (LWSC) is responsible for the safe and sustainable operation of the service chain which will include delegating certain steps of the service chain to parastatal or private service providers.

5. We defined two major parts of the service chain, i.e. ‘emptying and transport’ and ‘treatment and re-use/disposal’.

6. The Bye-Laws require the service chains aiming at re-use of the FS and urine either as fertilizer / soil-improver in agriculture or as bio-fuel in industry (cement kilns) or in households (replacing char-coal).

7. In all steps of the service chain the safety of processes is of utmost importance aiming at reducing the percentage of unsafe managed FS in the shit flow diagram (SFD).

8. The Bye-Laws have to spell out the roles and responsibility of all public stakeholders regarding OSS governance.

9. The Bye-Laws shall outline how these OSS regulations are enforced and what penalties are applied if not followed.

10. The By-laws have to regulate the construction and O&M of decentralized sanitation systems in large institutions or housing estates.

11. Miscellaneous topics in the By-laws should cover temporary toilets (at building sites and functions), MHM management in public toilets, hand-washing facilities and training and protection of sanitation personnel.

12. With regard to your last question: standards and specifications are in the process of development by relevant Zambian authorities.

The above are so far the ideas by the LCC and have not yet been agreed upon with other stakeholders such as LWSC and the regulators for the protection of the customers, the environment, and the water resources. LCC expects quite some objections especially from LWSC which does not see OSS as a business case.

But it must be observed that about 80-85% of the Lusaka population depends on OSS (including septic tanks) and more than 60% of the water supply in Lusaka comes from groundwater which is contaminated by the current unsafe management of faecal sludge. And the 80% OSS users have as much human right asking for public (support) services as the customers on sewer systems.

We hope that this helps you a bit in your further developments and we look forward to questions which will help us in our developments.

We can't solve problems by using the same kind of thinking we used when we created them.
Albert Einstein
Any intelligent fool can make things bigger and more complex... It takes a touch of a genius - and a lot of courage to move in the opposite direction.
E.F. Schumacher
Everything should be made as simple as possible, but not simpler. :-)
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  • arkaja
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Re: Review of Building Regulations from Indian States on FSM

Thank you Hajo for this post. It is immensely useful and informative, and will help us in our future discussions in India. We've exactly the same issues, and our formal specifications for septic tanks are almost impossible to follow for most of the OSS users. The planning agencies probably implicitly know this, but we've been mostly unable to get a new set of specifications accepted.

I am a lawyer by training and I am currently responsible for managing a programme on sanitation (SCI FI, or 'Scaling City Institutions for India') at the Centre for Policy Research. My current work is focused on the role of law and regulation for inclusive water and sanitation. I lead and manage research on various aspects of non-network sanitation, informal service provision, and its institutional and socio-economic dimensions.

My other interests and areas of work include: urban governance and policy, land, urban poverty, low-income informal settlements, environment law and water resources....
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