Auditing Plastic Waste – An Overview and Experience from SAI India-SAI India

Team at International Centre for Environment Audit and Sustainable Development (iCED), Jaipur

1. Introduction

Plastic Waste, or plastic pollution is the accumulation of plastic objects in the Earth’s environment that adversely affects wildlife, their habitat, and human beings. It also refers to the significant amount of plastic that is not recycled and ends up in landfills or thrown into unregulated dump sites¹. Plastic Waste has become ubiquitous and its rapidly increasing levels represent a serious problem on a global scale, negatively impacting the environmental, social and economic dimensions of sustainable development.

Fragile marine ecosystems are also facing the menace of plastic pollution. Because of their size, micro-plastics and nano-plastics enter the bodies of animals through ingestion and inhalation blocking the digestive tract. These can further enter the marine food chain, introducing plastic debris into higher trophic levels including humans. There are examples of coral reefs and mangrove forests that have been seriously damaged by plastic pollution². It is estimated that, by 2050, global greenhouse gas emissions associated with plastic production, use, and disposal would account for 15 percent of allowed emissions i.e., limiting global warming to 1.5°C (34.7°F) in line with the Paris Agreement on climate change³. Management of plastic waste is of urgent importance and a global risk area for sustainable development.

2. A Regulatory Paradigm for Plastic Waste Management

2.1 Global Regulations: Various efforts have been made by Governments and International Organizations across the world for curbing plastic waste in the form of Global Conventions, Regional Protocols and Collaborations, International Plans, Campaigns and Plastic Waste Alliances, as shown in Figure 1. These initiatives can be traced back from 1972 (London Convention) to 2020 (European Plastics Pact). In 2022, a resolution was adopted by the United Nations Environment Assembly held in Nairobi to end plastic pollution, and forge an legally binding international agreement by the end of 2024.

2.2 Plastic Waste and Sustainable Development Goals

In September 2015, the United Nations established the sustainable development agenda for the period until 2030. The agenda contains 17 Sustainable Development Goals (SDGs), 169 targets and 231 unique indicators⁴. There is only one indicator (14.1.1b) under Goal 14 which is specifically related to reducing impacts of plastic in the marine environment as indicated in Figure 2⁵. Plastic pollution is impacting every part of the earth’s ecosystem and impacts nearly every Sustainable Development Goal in one way or the other.

2.3 Regulatory Framework for Management of Plastic Waste in India

The Government of India has notified Acts and Rules for sustainable management of plastic waste from time to time. A timeline of important initiatives since enactment of Plastic Manufacture, Sale and Usage Rules (1999) to Plastic Waste Management Amendment Rules (2021) is shown in Figure 3. A ban on identified single-use plastic items has been notified vide the Plastic Waste Management Amendment Rules, 2021 on 12th August 2021, which is in force from 1st July, 2022.

2.4 Institutional Framework for Management of Plastic Waste in India

In India, plastic waste comes under the ambit of Municipal Solid Waste. It is treated under the “Special waste” category as it requires special handling and disposal because of its quantity, concentration, physical and chemical characteristics, and biological properties. Due to a lack of proper segregation at the source, plastic waste frequently ends up in the mixed Municipal Solid Waste stream⁶.

The roles and responsibilities of different institutions in Solid Waste Management extend to Plastic Waste Management also. The framework for Plastic Waste Management in India can be broadly divided into the following levels⁷.

• Central Government- The responsible institutions are Ministry of Environment, Forest and Climate Change, Ministry of Urban Development and Central Pollution Control Board. Their roles and responsibilities include making of laws and rules, policies and norms; guidelines, manuals and providing technical assistance, and financial support for monitoring implementation of laws and rules.
• State Government- The responsible institutions are State Urban Development Departments and State Pollution Control Boards. Their roles and responsibilities include monitoring the implementation of laws and rules, state policy and Solid Waste Management Strategy, issue of Guidelines, Manuals, and providing technical assistance and financial support. These also report on Service Level Benchmarks to the Ministry of Urban Development and grant consent for setting up waste treatment and disposal activities.
• District level- At the district level, the District Urban Development Cell looks after waste related issues. It reviews the performance of Urban Local Bodies on waste management process.
• Urban Local Bodies- These provide Municipal Solid Waste Management services, prepare Solid Waste Management plans, frame byelaws, levy and collect fees, provide finance to Solid Waste Management systems, create public awareness and involve the informal sector in Solid Waste Management. The informal sector comprises of waste recyclers, Non-Government Organisations, Community-based organizations and private partners.

Responsibility of local bodies⁸-

1. Local bodies are responsible for development and setting up of infrastructure for segregation, collection, storage, transportation, processing and disposal of plastic waste.

2. Local bodies are responsible for setting up, operationalization and co-ordination of waste management systems and for performing the associated functions, namely:-

• Ensuring segregation, collection, storage, transportation, processing and disposal of plastic waste; Ensuring that no damage is caused to the environment during this process;
• Ensuring channelization of recyclable plastic waste fraction to recyclers;
• Ensuring processing and disposal of non-recyclable fraction of plastic waste in accordance with the guidelines issued by the Central Pollution Control Board;
• Creating awareness among all stakeholders about their responsibilities;
• Engaging civil societies or groups working with waste pickers; and
• Ensuring that open burning of plastic waste does not take place.

3. Local bodies also frame bye-laws incorporating the provisions of rules.

3. Audit of Plastic Waste

3.1 INTOSAI Working Group on Environmental Auditing (WGEA) work

The INTOSAI WGEA has worked on Sustainable Development issues since 2007⁹. Under the INTOSAI WGEA working plan 2020-2022, SAI India is the leader in contributions on Work Package 2: SDG 12- Responsible Consumption and Production- Focus on Plastic waste.

3.2 Plastic Waste Audits by Supreme Audit Institutions

Some audit reports by the Supreme Audit Institutions on themes related to plastic waste are illustrated as under:

• The Netherlan Court of Audit published a report “Reducing the Use of Plastics”(2019), and noted that working in coordination and encouragement with other organisations is important for achieving the targets in relation to the use of plastics. The audit found that, since only packaging materials are recycled, plenty of potentially usable plastics still end up in incinerators and public support is required for effective waste separation by the people. Audit found that more drastic measures are required to bring about a circular economy. These should include both recycling targets and targets for the prevention and reuse of plastics.
• A comprehensive summary of audits on plastic waste -“Joint Report on Management of Plastic waste in Europe” (2022)10- was prepared by 12 Supreme Audit Institutions, viz., Albania, Bulgaria, Hungary, Malta, Moldova, North Macedonia, Poland, Portugal, Romania, Serbia, Slovakia and Turkey. It revealed that existing legislations and organisational arrangements were insufficient to reduce the generation of plastic waste and ensure its proper treatment. The report also noted that more intensive measures are required to encourage and persuade citizens to change their consumption patterns to reduce the use of plastic products and thus scale down the quantity of waste generated, and re-use plastic products as far as possible.(Source:https://nao.gov.mt/en/press-releases/4/1301/joint-report-on-management-of-plastic-waste-i)

3.3 Plastic Waste Audits by SAI India during the last five years: Selected Snap-shots

• Performance Audit Report on “Conservation of Coastal Ecosystems¹¹” (2022) indicated that the global indicators for SDG 14.1 include ‘Index of coastal eutrophication and plastic debris density’. While the national indicator Coastal Water Quality Index (CWQI) prepared by the Ministry of Earth Sciences takes into account nutrient pollution, the Ministry of Earth Sciences, was yet to prepare an indicator related to plastic debris density. Audit also found that all the stakeholders in the field of coastal management were not mapped, and Ministry of Earth Sciences was yet to prepare an indicator related to plastic debris density which was a vital part of the action to preserve the coastal and marine ecosystem. Further, the States had not localised their indicator frameworks to suit their local conditions. As such, the measures taken up by the Government towards achieving the targets under SDG 14 need further impetus.(Source: https://cag.gov.in/webroot/uploads/download_audit_report/2022/Report%20No.%204% 20of%202022_CCE_English_PDF-A-062f0f908256ef0.76318631.pdf)
• Performance Audit Report on “Waste Management in Indian Railways” (2022)¹² highlighted that the assessment of the quantity of plastic waste generated was not done at a majority of the railway stations selected for audit. It highlighted the non-installation of Plastic Bottle Crushing Machines (PBCMs) and absence of provision of ‘Plastic only Bin’ in stations and coaching depots. The audit recommended that Indian Railways needs to put in place an effective monitoring mechanism for managing plastic as well as solid waste in an environment-friendly manner.(Source: https://cag.gov.in/en/audit-report/details/116657)
• Compliance Audit of “Department of Urban Development in Karnataka” (2020)13 highlighted that the guidelines issued by the Commissioner and provisions of Indian Road Congress regarding the use of plastic waste in bitumen mixes in the construction of roads was not observed by the engineering division concerned. The works were executed without adding plastic waste during the formation of roads.(Source: https://cag.gov.in/webroot/uploads/download_audit_report/2020/Report%203%20of% 202020_English-05fd1cdd9c123c4.02129258.pdf)
• Performance Audit of “Waste Management in Rajasthan” (2018)¹⁴ revealed that the Urban Local Bodies (ULBs) did not assess the quantum of plastic waste generated and made any future projections about the composition and quantities of the plastic waste to be generated, in the urban areas. None of the test-checked ULBs had either registered any retailers/street vendors for selling/providing consumer goods in plastic sheets/packaging or ensured compliance to the extant rules. They did not frame any bye-laws for levy of user charges for plastic waste management and established no mechanism for collection, handling, storage, transportation and disposal of Plastic Waste.(Source:https://cag.gov.in/cag_old/sites/default/files/audit_report_files/Report_No_2_of_2018_-_Local_Bodies_Government_of_Rajasthan.pdf)
• The Performance Audit of “Solid Waste Management in Urban Local Bodies in Karnataka” (2018)¹⁵ revealed the failure of the Urban Local Bodies to perform the prescribed responsibilities and devise methods for utilization of plastic in roads which resulted in mismanagement of Plastic Waste.(Source:https://cag.gov.in/cag_old/sites/default/files/audit_report_files/Report_No_4_of_2018 _Performance_Audit_of_Solid_Waste_Management_in_Urban_Local_Bodies_Government_of_ Karnataka.pdf)

4. Challenges and Way Forward

Non-availability of authentic and reliable data on generation, collection, segregation and treatment of plastic waste is a major hindrance in the auditing of plastic waste issues. Many stakeholders related to plastic waste are not mapped by policy makers in their National Indicator Frameworks thereby making data collection a challenge. Therefore, efficient mechanisms and infrastructure for collection and assessment of credible and complete data regarding plastic waste is crucial for audit. This should include last-mile mapping of end-users of plastic to the institutions of local self-government at both rural and urban levels. This will also aid in framing plastic waste management policies and programmes and their outcome assessments.

Non-production of records and production of incomplete records act as significant constraint in audit scrutiny. It is also a challenge for auditors to keep themselves updated with the domain/ technical knowledge including various recycling techniques so as to comment effectively on plastic waste recycling and its alternate usage such as Bitumen mix roads, etc. SDGs indicators can be used as criteria by auditors during audits. However, there is lack of sufficient indicators on plastic waste despite its interlinkages with many SDGs.

The rules governing the treatment of plastic waste and public awareness, effective implementation of Extended Producer Responsibility measures in plastic waste generation, sorting and segregation of plastic waste from other Municipal Solid Waste can promote better management of plastic waste.

Supreme Audit Institutions play an important role in overseeing the impact of environmental policies related to plastic waste. SAIs do so by conducting independent audits of government activities. The conduct of such audits in the area of plastic waste and pollution would thus help in red-flagging crisis areas of environmental degradation, which would then assist the executive authorities to take suitable remedial action in the sphere. Plastic pollution is not only a “severe anthropogenic issue in the coastal and marine ecosystems across the world”. It is also a crucial component of the overall paradigm of degenerative climate change with its destructive effects on manifold ecosystems and consumption patterns. The need of the entire global community is to thereby acknowledge this fact; and successful auditing of plastic waste is thus of immense necessity.

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