Mohalla Clinics have democratised healthcare but their unregulated biomedical waste is potentially an ecological time bomb

India’s push to democratise healthcare through decentralised models like Mohalla Clinics is a welcome step toward achieving equity in health access. 

Conceived in 2015, these clinics now number over 500 in Delhi alone, serving nearly 10,000 patients on a daily basis. Their expansion across several states is set to transform how primary care is delivered: localised, affordable and inclusive. 

However, as the Comptroller and Auditor General (CAG) of India’s audit report has shown deficiencies in clinic infrastructure, staffing and compliance plague the initiative. 

What remains under-examined is a critical blind spot: biomedical waste (BMW) management. 

This is because the Central Pollution Control Board (CPCB) reports show a nationwide surge in BMW generation from 559 metric tonnes per day in 2017 to 775 metric tonnes per day in 2021. 

Nonetheless, more than 60 per cent of secondary and nearly 80 per cent of primary health facilities lack appropriate BMW infrastructure. 

Despite growing volumes, with each Mohalla Clinic generating 2–5 kg of waste daily, effective handling of BMW remains weakly institutionalised in India’s linear policy framework. 

This policy void is not just an operational oversight - it is a potential ecological time bomb. In cities where waste logistics are already stretched thin, biomedical waste risks leaching into water bodies, contaminating groundwater, and releasing toxins through unchecked incineration. 

Without a shift from disposal-oriented strategies to regenerative, circular practices, such initiatives, however well-intentioned, risk becoming environmentally unsustainable. 

Circular economy (CE) principles, if embedded in healthcare infrastructure from the outset, can address both access and sustainability. However, does India’s policy architecture support this vision?

A policy shortcoming

We recently published new research on India's circular economy in the scholarly journal Resources, Conservation & Recycling (2025) based on a comprehensive quantitative analysis of 41 central policy instruments that govern India's biomedical waste management. 

Using a state-of-the-art integrated coding framework based on 82 circularity indicators aligned with the 6Rs of circular economy (Reduce, Reuse, Recycle, Reclaim, Recover, Restore) and the BS8001:2017 principles (System Thinking, Innovation, Collaboration, Value Optimisation, Transparency, Stewardship), we evaluated 3,362 potential instances where circular economy principles could have been encoded in these policy instruments. 

Our results are unequivocal: only 274 out of these 3,362 instances, a mere 8.15 per cent, demonstrate any alignment with circular economy principles. Conversely, this also means that over 91 per cent of India's healthcare waste management policy infrastructure reflects linear, end-of-pipe thinking.

Waste is viewed as a liability to be discarded, not a resource to be regenerated. Only one of the 41 policy instruments — the Comprehensive Mission Document of the National Water Mission (2008)—included more than 50 per cent of the 82 circularity indicators mentioned earlier. 

This instrument has a score of 67.07 per cent alignment, standing in stark contrast to five other policy instruments — including pandemic-era biomedical waste guidelines from 2020 — that showed 0% alignment with circularity. 

These five instruments are Bio-Medical Waste Management (Second Amendment) Rules, 2019 Guidelines for Barcode System for BMW Management, 2018 COVID-19 BMW Disposal Guidelines (March 18 & 25, 2020 versions) and Guidelines for Incineration Chamber Verification, 2019. Even the flagship Bio-Medical Waste Management Rules (2016), usually considered India's most comprehensive BMW legislation, showed only 3.66 per cent circularity alignment and referenced merely 2 of the 6Rs and 3 of the 6 BS8001 principles. When assessed against the six BS8001:2017 operational principles, the picture remains dismal. 

While ‘Value Optimisation’ had the highest number of coded references (61 mentions under various 6R combinations), ‘Transparency’ — essential for accountability and public trust — appeared in only 14 out of 3362 instances, or 0.4 per cent. 

In addition, the failure to implement Extended Producer Responsibility (EPR) frameworks is a key structural gap. Countries like Germany and Japan have made EPR legally binding for pharmaceutical packaging and medical devices, mandating producers to take back, repurpose, or recycle post-use medical materials.

India's 2016 BMW rules do not include any EPR mandates, potentially a glaring policy oversight in an era of rising pharmaceutical consumption and device usage. 

Another significant gap is wastewater management. Our study shows that policy instruments almost entirely ignore wastewater originating from healthcare systems, even though wastewater often contains pharmaceutical residues, endocrine-disrupting chemicals (EDCs), pathogens, and heavy metals.

For example, only four instruments out of forty-one discuss water-related circularity indicators. Even the National Policy on Faecal Sludge and Septage Management (2017), widely seen as a milestone in sanitation planning, scored just 13.41 per cent on circularity alignment. 

This is despite growing scientific evidence that links hospital effluents to antibiotic resistance, hormonal imbalances, reproductive disorders and aquatic toxicity. Climate change will intensify such effects as pathogen survival and dispersal increase in warmer and wetter conditions. 

There is also scope for improvement in the technology aspects of circularity. Globally, alternatives to incineration, such as autoclaving, pyrolysis, gasification, constructed wetlands and anaerobic digestion, are being scaled up. 

However, India’s policy landscape remains heavily skewed toward centralised, high-temperature incineration, which emits an average of 1074 kg CO₂e per ton of waste, compared to 65 kg CO₂e/ton for recycling. 

There is also a chronic underinvestment in data-driven waste monitoring systems. Innovations such as blockchain-based waste traceability, smart biohazard bags, AI-based segregation, and IoT-enabled incinerator tracking are almost entirely absent from regulatory vocabulary. The lack of real-time monitoring severely hampers enforcement in a country where over 1.5 lakh healthcare facilities generate biomedical waste.

Embedding circularity into India’s development vision

India’s aspiration to become a developed nation by 2047 under the Viksit Bharat agenda cannot rest on service delivery alone. 

It must embed climate resilience and circular economy thinking into every layer of national planning, particularly healthcare management, which produces five per cent of India’s total greenhouse gas emissions. A development model that continues treating waste as an externality is not just environmentally negligent but economically shortsighted. 

Waste is not merely a byproduct of development; it is a potential source of income that, if harnessed, can generate jobs, reduce emissions, and build localised resilience. 

Policy reform must, therefore, start by legislating circularity, particularly in healthcare.

One possible pathway to do this is via codifying EPR frameworks for pharmaceutical and medical devices, incentivising decentralised waste treatment technologies at the local level, investing in circular innovation ecosystems (e.g., startups working on biodegradable alternatives, waste-to-energy models), mandating climate-resilient wastewater systems using hybrid nature-based infrastructure like constructed wetlands, enabling behavioral change through public awareness campaigns and civil service capacity-building.

Views expressed are the authors’ own and don’t necessarily reflect those of Down To Earth