What is a solid waste ‘bulk generator’?

BBMP SWM automatic tilters. file picture

Bengaluru generates 6000 tons of waste per day from various entities. The BBMP, as the local government and nodal agency in charge of solid waste management, has classified waste generators into bulk and non-bulk categories. It is estimated that more than 1,500 tonnes of waste is generated by bulk generators (BG).

Classification of Bulk Generators

Mass generators have been classified into three categories, in accordance with BBMP circular JC(SWM)/PRF/e-17410/2021-22 dated March 30, 2022:

Residential Institutional Commercial
Apartments, multiple dwellings, gated communities housing over 100 units. Academic institutions, government departments and enterprises, religious institutions, hospitals, hospitality industry, businesses, etc. All commercial entities that generate on average more than 100 kg of waste per day and/or located in an area greater than 5,000 m².
– This includes any commercial entity that requires a commercial license to operate.
– Small retailers, street vendors, peddlers or temporary stall
farmers, small cottage industry, etc.

Read more: The journey of Madiwala market in dealing with its waste problem


The classification of bulk generators for the residential category has been increased from 50 units and above or 10 kg of waste per day to 100 units. In the case of commercial/institutional categories, it has been increased to 100 kg of waste per day and/or located in an area greater than 5,000 m².

Functions of a mass generator

maintenance staff sorting waste
Maintenance staff of an apartment collecting waste according to the 2Bin1Bag model. Photo: 2bin1bag

As part of the BBMP SWM 2020 regulations, segregation and storage guidelines have been established – all BGs must segregate their solid waste into different categories at their premises/source:

  • Biodegradable/wet waste – kitchen, garden and horticultural waste – stored in green bins, without plastic liners
  • Non-biodegradable/dry waste – plastic, cardboard, disposable waste (food containers to be cleaned and dried to facilitate recycling) and e-waste – stored in blue bins.
  • Household Hazardous Waste and Sanitary Waste (wrapped in paper) – stored in a red bin.
  • Construction and demolition (C&D) waste.

How should bulk generators dispose of waste?

All BGs must ensure the segregation and treatment of solid waste at source, in accordance with the SWM decree, and any failure to do so will be subject to penalties.

Waste management options:

Onsite/Insitu Offsite
When a complex/establishment switches to in-situ compositing:
Wet waste should be handled within the premises, at their own expense. It is a question of identifying a place to install the infrastructures of composting, sorting, etc.
1. In exceptional cases, where there is no land/space to manage the waste in-house, sorted wet waste is sent to composting sites through Approved Waste Processors (AWP ).
2. Dry waste and other waste must be sent either to an intermediate transfer point from where it is then separated by the AWP and sent to different recyclers.
3. Rejects / Bio-waste – are sent to incinerators.
4. Inert waste – to be sent to recovery sites.
5. Mixed/uncategorized waste is sent to a private landfill.

BGs are required to engage Approved Waste Processors (AWP – formerly Approved Vendors) to dispose of dry waste, scrap, inert waste, etc. However, exceptionally, in cases where on-site composting is not possible (due to lack of space), BGs can also engage AWPs to dispose of sorted wet waste.

BBMP Auto tippers on the road
BBMP tipper cars transporting waste. Photo credit: Pinky Chandran

Read more: How Bengaluru aims for 100% segregation of waste by December 2019: BBMP’s new GDS orders


How should Bulk Generators find a suitable supplier?

BGs are required to exercise due diligence when engaging a supplier. The list of documents to be provided by AWP sellers are:

  1. Company registration details
  2. BBMP Incorporation Letter
  3. BBMP compliance certificate for capacity
  4. Labor Compliance Certificate
  5. Authorization letters for intermediate transfer point, final destination for wet waste treatment, dry waste treatment, etc.
  6. Transport: agreement for subcontracted vehicles/own vehicles and related documentation
  7. Agreements with third parties:
    • Copies of agreements with recyclers
    • Private landfill and/or scrap dealer
    • Recyclers and private landfills must produce KSPCB approval letters

Relevant forms to submit and fines for non-compliance are listed in the SWM 2020 Bylaws.

A study conducted by Compost Connect Initiative by SWMRT and Bangalore Apartment Federation (BAF) shows that levels of segregation in apartment complexes are as high as 90%.

One of the reasons for these high levels of segregation is that apartments are considered bulk generators (BG) and manage their own waste; collection is carried out by their housekeeping staff and disposed of either by on-site composting or by private contractors/AWP. However, even if they manage their own solid waste, bulk generators still have to pay the garbage tax to BBMP.

Lack of clarity on the responsibilities of the mass generator

The latest notification detailed the type of institutions and business entities that come under the umbrella of the BGs. However, there are several clauses in the new circular that raise many more questions than answers. Here are some of the highlights of the flyer:

  1. Although BGs have been invited to participate in the in situ composition, however, it is not clear whether this is mandatory or recommended.
  2. It is not clear whether the BGs have the freedom to decide on the method of composting. BBMP entrusted KSPCB to decide on the technology. Campaigners fear round-the-clock composting machines such as organic waste composters (OWCs) will become mandatory.
  3. BGs have been given the option of sending their biodegradable waste to pig farms, but there is currently no clarity on the capacity of the barns or the transport mechanism.
  4. While the circular alludes to the penalty, the how and who is not specified. Who will be in charge of monitoring/enforcement? the health department or the SWM department?
  5. Who will determine the lack of space for the composition in situ?
  6. The current constitution is cumbersome, with quarterly renewals. AWP/incorporated vendors demanded a longer (3 years), cleaner and simpler incorporation process.

In the past, a self-reporting mechanism called BGnet was created, but failed to take off. Currently, BBMP does not have data on the number of mass generators. If the BBMP can iron out the process and regulatory issues, the situation for solid waste management in Bangalore can become much better.

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