LEE Jong-Wook
Director General
World Health Organization
Avenue Appia 20
1211 Geneva 27
Switzerland
Dear LEE Jong-Wook:
We, the undersigned representatives of non-governmental
organizations and community-based organizations
working on environmental health and justice
issues throughout Asia are writing about WHO’s
position on medical waste incineration. We are
members of GAIA, an international alliance with
more than 450 members in 71 countries dedicated
to promoting safe and just alternatives to incineration.
Specifically we write to congratulate WHO on
its recent recognition of the environmental
health dangers associated with medical waste
incineration and its recognition of the need
for safer, non-incineration alternatives.
However, we also write to share our concern
that at the same time, WHO continues to promote
incineration for medical wastes. WHO’s
Guiding Policy Principles for handing medical
waste are articulated in the recent “Health-Care
Waste Management Policy Paper.” While
the principles include support for the Stockholm
Convention and other “global efforts to
reduce the amount of noxious emissions released
in to the atmosphere,” the paper also,
incredulously, supports “promotion of
appropriate practices (sic) for high temperature
incineration.”
With the well documented dangers of burning
medical waste and the availability of safer
economical alternatives, there is simply no
justification for continuing to burn medical
waste, either in small-scale or high temperature
incinerators.
We are concerned because incineration releases
heavy metals and other toxic pollutants that
are within the waste stream as well as creates
new toxic compounds during the combustion process.
Incineration also creates a toxic ash residue
that adds to the burdens of the host community.
Incineration is increasingly discredited around
the world and is being replaced with a variety
of safer non-burn solutions for medical waste
from large and small hospitals, rural and urban
clinics and recently from immunization drives.
Recently in the Philippines, all used needles
from a month-long mass immunization campaign
involving 18 million vaccinations were safely
disposed without incineration. We call on WHO
to promote models such as this which address
the critical need for safe medical waste management
without promoting an obsolete technology which
pollutes the environment and jeopardizes public
health.
Incineration and open burning not only threaten
the environment and public health in Asia and
elsewhere, but also contradict recent WHO policy
and the United Nations Stockholm Convention.
The Stockholm Convention calls for the elimination
of activities that lead to dioxin production
and specifically identifies medical waste incineration
as a source of dioxin emission. Over 50 countries
have ratified this treaty that went into effect
last month.
We find WHO’s continued promotion of
incineration fundamentally inconsistent with
WHO’s other work to promote international
public health. We also find WHO’s promotion
of incineration in the global South, while it
is being increasingly phased out in the U.S.,
to be an alarming case of global double standards
in which communities in the North are afforded
greater protection and safer technologies than
those in the South.
We recognize that WHO has identified “scaled-up
promotion of non-incineration technologies for
the final disposal of health-case wastes”
as a component of its health care waste strategy.
However, we are discouraged that this component
of the strategy is classified as “long-term”
and we urge WHO to prioritize this project within
its health care waste work program.
We look forward to WHO’s response and
we offer our assistance and support for WHO
in transitioning away from incineration and,
instead, promoting safer alternatives.
We look forward to hearing from you.
Sincerely,
