OCCUPATIONAL HEALTH AND SAFETY IN FSSM

FSSM is necessary for maintaining the health of the on-site containment and disposal units such as a Septic Tank and Soak pit or Dispersion Trench. The figure above depicts a typical sanitation service chain involved in FSSM and consists of emptying, transport, treatment and reuse/disposal of the faecal sludge and septage. Unlike sewered sanitation, where liquid waste is conveyed using pipes with minimal human intervention, non sewered sanitation involves human interventions to manage liquid waste. Hence, Occupational Health and Safety (OHS) should be prioritized in FSSM.

OHS is a subject which ideally should be prioritized by the employee more than the employer itself. After-all, implementing OHS results into increase in the cost to the employer. The Prohibition of Employment of Manual Scavengers and their Rehabilitation (PEMSR) Act and Rules of 2013 is currently the only law in India which governs OHS in sanitation sector. However, the biggest challenge of any law is its awareness and enforcement. On one hand, the workforce engaged in the sanitation sector is not aware about their rights (insurance, medical support and access to safety and protective equipment etc.) while carrying out the work; and on the other hand, the regulators lack in enforcing the law on the employers. Result of this, the employer forces the labour to undertake hazardous cleaning of septic tanks and enter the confined space without any safety and protective equipment. On an average in India, every week there is at least one death of the person while cleaning septic tank or sewer appurtenances.

Monetary profits are always prioritized over safety and human life in unregulated - ill monitored service sectors.

The root cause analysis of these accidents suggests that, unlike manufacturing and producing industries, the culture of safety is yet to be developed in the service industry. Calculated risks are taken by the employers and planned-inappropriate operations are carried out, which in most of the cases do not result into immediate accident but affects the employees’ health in the long term.

The IS Code 11972, 1987 recommends appointment of workers in sanitation sector after medical examination based on 14 checks by the employer and a regular medical checkup depending on the age and job of the worker. However, in practice this is not done. Moreover, the workers are not provided adequate training to carry out the job using safety and protective equipment leading to carrying out of unsafe acts. The picture above depicts the Swiss Cheese Model which perfectly summarizes that failure at different stages leads to an accident.

The safety and protective equipment are only as good and effective as the knowledge of the user and provides protection only to the person using it.

Common understanding is that, OHS is limited to safety and protective equipment only. However, the Personal Protective Equipment (PPE) are considered as the last line of defense in OHS framework. The figure below illustrates the hierarchy of controls for OHS. These hierarchy of controls help to mitigate the hazards in the occupation while carrying out a specific task.

Inherently safe design: The phrase is self-explanatory. Although it is the most effective and cost-effective control measure, the ugly truth is that this is the most neglected among all the measures. For example, if the design of the septic tank is safe as described in IS Code 2470 (Part I), 1985 then the chemical hazard of poisonous gases such as methane and hydrogen sulfide is reduced and biological hazard from manual cleaning of septic tank will be eliminated. However, bye laws for enforcing these codes are either not passed or enforced by the local government body to reduce the onus and their liability.

Engineering controls: It refers to use of tools and equipment either to carry out the job or in the path of the hazard. This has been widely adopted in FSSM. For example, the suction vehicle is used for desludging the septic tank and the worker does not come in direct contact with the waste or the poisonous gases. However, the assembly of these trucks is mostly done by the local fabricators who are not aware about the IS Code 13496, 1992. Thus, in most cases, the trucks are not based on safe design criteria given in the codes, making workers vulnerable to physical hazards.

Safe work practice: This entails following of SOP for carrying out specific tasks involved across the sanitation service chain by the employees. The PEMSR Rules attempts to describe the procedure for cleaning of septic tank; however, it does not provide a detailed step by step approach to complete the task safely. This fallacy has been carried forward in the advisory and manuals prepared by CPHEEO and issued by MoHUA. Hence, a critical piece of information is missed even after investing into preparing and dissemination of these documents.

Administrative controls:  It consists of preparing and enforcing the regulations, SOP of carrying out key steps in the process such as – selection of the employees, monitoring of the services and last but not the least training of employees in the SOPs, in use of safety and protective equipment, in emergency response, etc. This control measure plays a significant role in the increasing the efficacy of the other control measures.

Personal protective equipment: By this point, it is clear why PPE is considered to be the last line of defense. Selection of PPE depends on the Hazard Identification and Risk Analysis. This takes into account the probability of the person being exposed to the hazard and the severity of the hazard. Accordingly, a choice of combination of PPE from head to toe (8 categories) needs to be made.

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Last but not the least, it is to be noted that OHS in the sanitation sector will contribute to raising the socioeconomic profile of the workers in a significant way. Although, environmental services provided by the sanitation workers are essential to maintain balance between the built and natural environment, there is a social stigma around the profession. Integrating OHS in FSSM will not only save lives, but also make the profession adequately motivating for the unemployed to become sanitation professionals.