From:����������������������������� paadam pm [[email protected]]

Sent:������������������������������ Saturday, 02 July, 2011 5:59 PM

To:���������������������������������� Harsh Mander; Narendra Jadhav; aruna roy; Martin Macwan; Henri Tiphagne; Vidya Bhushan Rawat; ska; NHRC; K.Anuradha; [email protected]; [email protected]; gita ramaswamy; Mari Marcel Thekaekara; justice V.R.Krishna Iyer; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; Shiva Shankar; Mangesh Dahiwale; Priyadarshi Telang; D.Leena; S.Anand; Benjamin Kaila; NANDINI; [email protected]

Subject:������������������������� the possibility of replacing the toothless Manaul Scavenging(prohibition)1993 act.

Attachments:���������������� HC on manual scavenging amendment.pdf; manual_scavenging-NAC note may 11thminutes.pdf

 

LATEST MADRAS HIGH COURT ORDER & CRITIQUE OF NAC NOTE ON MANUAL SCAVENGING

Dear Sirs/Madam,
Greetings.
1. Attached pl find the pdf file of the latest MHC order strongly indicting the Union Govt for delay in reforming the 1993 act and setting a deadline of August 22 for bringing the neccessary amendment, going beyond which the High Court may be constrained to direct personal appearance of Dignitaries be it Home, Law & Justice or even the PMO.

2. The Govt of Tamilnadu has also agreed to move a resolution in the TN assembly in favour of an amendment and forward to the Union Govt for taking up in the parliament. We need one more state to move such a resolution., because atleast 2 states' backing is required for a bill to be placed for amendment, it seems.

3. In the meantime, there is second thought about amending the existing 1993 act and there are discussions for an altogether new, comprehensive act on this subject matter.

4. Even though NAC was originally in favour of an amendment to the 1993 act earlier, now they feel it may be pointless to amend the old act and it is better to move a new bill. Reason being, the old  (Prohibition) Act, 1993 was enacted under Entry 6 of the State List and the states took their own sweat time to even notify the act in their states and many did not even frame the rules.

5.When the old act was drafted, it was under the subject of 'Public health' whereas the intend should have been to eliminate centuries old  historical wrongs, according to NAC note. Hence, it will be prudent not to draft amendments under the same 1993 act.

6. There is another fear in the Housing Ministry circles is that if such strong amendment is carried out under the same act with Housing Ministry as the nodal agency, then all states need huge funds to modernise the sanitation mechanism and there will be clamour by the states for more funds from the centre under JNNURM or other schemes. This is because most of the municipalities in the country are already bakrupt with very little scope for raising their own funds through the state and will depend on contributions from the Centre. The centre is already overburdened with so many committments such as loan waivers, RTE, RTF such as PDS, MGNREGA, etc etc. The Total Sanitation Mission had been a mixed bag. So, the financial angle is a deterrant to enacting the new amendment. Moroever, by making the amendment stronger, there will be instances of proceeding against even Municipal commissioners under the act, which no minicipal administration offcialswill agree to. So there will be stiff resistance to the same.

7. There was a suggestion to bring the subject under Labour welfare (concurrent list) so as to improve the working conditions of those employed as Manual Scavengers. But, this will not be acceptable as Manual scavenging is not any other labour work such as construction, mining etc and there is a caste angle. So, bringing the subject under 'Labour' has been ruled out.

8.The PM recently spoke of bringing the scope of employing someone for Manual scavenging as an offence under SC/ST atrocities prevention act, but there are constraints., namely a)there are certain muslim communities engaged in manual scavenging and they cannot be covered under this SC/ST act., b)SC/ST atrocities prevention act is far more dangerous for municipal offcials and they will not agree to the same, c)there is this problem of foisting false cases against municipal officials, supervisers etc under this act by bad-scheming workers etc etc.

9. So,NAC now believes that a new strong seperate act either under concurrent list entry 23, List III (Social Security) or preferably under Union's residual powers deriving under Article 248 read with Entry 97 List I under scope of 'Social Welfare" (instead of Public health or labour welfare) may be the solution instead of amending the old 1993 act. (Please go through the attached 'Follow up note of NAC dt 11th May).  In this note, NAC defines manual scavengers as two seperate entities a)traditional manual scavenging such as manually removing human excreta from dry latrines and b)those employed in Septic tanks and sewerages to remove blocks and railway cleaning workers.

10.Under the new definition according to NAC,work under traditional catagory such as removing excreta from Dry latrines should be banned forth with and they should be rehabilitated.   Those employed under the second definition of sewer work and railway work should be liberated  within 5 years through technical changes but their livelihood itself should not be abolished. The onus of enforcing the technical and administrative changes is with the hiring authority (i.e., unscrupulous railway contractors employed by the railways through corrupt tendering process with built-in kickbacks).

While, I mostly agree with the various arguments advanced by NAC in their follow up note of May11th on the limitation of amending the existing law, I am perplexed by the lack of comprehension of the issue in its full measure by the learned members of NAC, some of whom are revered social scientists such as Harsh Mander and others.

I express my critique of NAC suggestions on the following counts:

1.While those involved in cleaning of dry latrines should be liberated forthwith by demolision of dry latines, what is the alternative, the new law will offer is not clear from the NAC's arguments. We know that most of those who are using dry latrines, either individual or community dry latrines are themselves poor backward communities living in slums or colonies and are socio-economically worse off. Two things flow from this. The demolished dry latrines will be replaced by Pour Flush Toilets or  large scale open defecation(which is the stark reality in India today) on streets, road margins, platforms, near waterbodies, railway tracks etc. So, many municipal civic workers (who in any case are from born as scavenging communities) are made to handle those human extreta on account of open defecation albeit as part of their routine civic cleaning work.

2.When dry latrines are demolished and modern community pour flush toilets are built, due to shortage of water, indequate number of toilets, lack of education in civics, overpopulation, poor qualtity of construction and plumbing etc, etc, these so-called modern toilet complexes end up in reality as virtual dry toilets. The civic workers who in any case are from the same scavenging communities  end up cleaning these complexes with bare hands or broomsticks amounting to manual scaveging. In effect, we end up replacing manual scavenging in dry toilets with manual scavenging in wet toilets.

3.Now comes the second type of manual scavengers, those working to clean septic tanks, sewers and railway workers. The NAC talks about a 5 year period for liberating(???) them from direct manual scavenging through technical changes .'Technical Change or Technology Change' is a tinkering option, an improvement in an existing devise or equipment. What India needs is a Technology revolution in the science of Sanitation, in the science of disposal or preferably use of Human excreta as a resource and to remove the caste stigma in it by making excreta processing 'Fashionable' and an 'in-thing' and not something designed or resigned for a specific community at the bottom most of our caste system.

So, NAC or anyone with a stake in this subject should talk of a 'paradigm shift to a Technology of Sustainable Sanitation and Innovation'. I have my own doubts on the sustainablity of the ongoing TSC on which crores have been spent without quantifiable outcomes.

4. India is urbanising fast, more and more the middle class and the rural migrants are moving into the urban areas and the population density is high and growing. Our sewer lines are highly polluting monsters, unscientifically concieved, pathetically executed and horribly maintained and therefore totally unsustainable. Instead of pollution through open defecation, we are polluting our waterbodies and groundwater through our sewerlines. We install sewer treatment plants, but these are not optimally designed and scientifically operated, thereby letting out semi-treated sewage along with raw sewage back into waterbodies. Yamuna is DYING GODDESS. Ganga has become IMPURE GODDESS. Same with scores of rivers with Goddess names, waterbodies across India as well as ground water getting irreversably polluted, not just due to open defecation but due to relentless pollution by monster sewers.

The erstwhile manual scavengers of dry latrines now become the neo-manual scavengers of wet sewers and railway lines. The issue is likely to become more and more complex in the near future. Technical changes as envisaged by the NAC may be inadequate. There is need for technology development, a sound national and local solid waste management policy and sanitation policy which should lay emphasis on scientific collection, processing, disposal or recyling methods and local innovative solutions. It will not out of place to point out that there is no sanitation or solidwaste management policy in any state in India.  More research needs to be carried out on designing and developing eco-friendly sanitation systems assurance for human dignity rather than on launching satellites or sending an Indian to the moon. Sadly these are really lacking in our priorities.

If we are talking about abolishing Manual scavenging and liberating them and dignifying sanitation work without having a Sound, Sustainable and Scientific Policy Framework on Salidwaste and Sanitation Management in place in this country, we are far removed from reality. Many will concur that as long as there is need for scavenging in this county, scavengers will be perpetuated in one form or other.

5. Another thing that is surprising in NAC's argument is that the sewer cleaning and railway cleaning should be improved through technical changes, but the livelihood of those imployed in sewer /septic tank cleaning or railway cleaning should not be abolished. NAC argues that the occupation should not be abolished but only the 'humiliating and unsafe aspects' should be eliminated within 5 years. We need to deliberate on the import of this line of argument. Because, through this argument, we seek to perpetuate less hazardous manual scavenging on exactly the same communites. Where is the question of liberation from caste inequity in this? NAC proposes that through 'technical changes', manual scavenging be made less humiliating and but not liberating.   When technical changes fail, they are back to 'humiliating and unsafe'manual scavenging. This line of NAC thinking is ok for China or Africa because there is no caste system there. By advocating technical changes but simultaneously proposing preservatiion of livelihood, what are we proposing to achieve? Because, for a typical middleclassman or for any other caste hindu, even the very idea of cleaning a sewer or a railway track or a septic tank even with 'safe &modern gadgets' and 'handsome salary' may be extremely humiliating and revolting. So in reality, humiliation is relative to caste and not absolute. So, what are we talking when we say 'manual scavenging without humiliating and unsafe aspects'.?

These are some of the critique points that I am raising, not with an intention to belittle NAC or any other wellmeaning thinktank groups but to throw up the issue for a healthy discussion.

Last, but not the least, dont we think this subject is tricky and needs serious but urgent broad-based discussions across the country with stakeholders. In an earlier mail, I suggested a proposal for a seminar on this subject in Chennai. If some of the public spirited persons, legal experts and activists respond positively, we may do something in this regard. Regional public consultations are key to drafting a sound bill on this vital subject matter.

Please feel free to express your views.
With warm regards

 

Regards

A.Narayanan (98403 93581)

Editor

Paadam, Monthly Magazine in Tamil for Development Politics

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Gerugambakkam

Chennai - 602 101.