Letter from Ann Leonard, Multinationals Resource Center,
to Andrew Steer, Environment Department Director at the World Bank.
Leonard never received a response from Steer.

February 14, 1997

Andrew Steer
The World Bank
1818 H St., NW
Washington, DC 20433

Dear Mr. Steer:

I am writing to inquire about an inconsistency in the environmental categorization of some World Bank projects involving a medical waste component.

Concern about the environmental and health risks of medical waste incineration has increased in recent years as a number of studies have identified such incinerators as among the primary sources of extremely toxic dioxin into the environment. In both industrialized and less-industrialized countries, growing movements of health workers, labor and environmental advocates, and concerned citizens call for the replacement of medical waste incinerators with cleaner, safer, and less expensive alternatives which are already commercially available and widely in use.

At the same time as medical waste incineration is being discredited and in many places phased out in Northern countries, it is alarming to find that the World Bank is funding new medical waste incinerators throughout the third world.

A cursory review of World Bank projects has uncovered the following projects which involve a medical waste component. I have spoken with World Bank staff involved in these projects who verified that the projects potentially involve either funding, facilitating infrastructure, or recommendations for medical waste incineration, yet the projects' environmental classifications are inconsistent and do not reflect an understanding of the very severe risks associated with medical waste incineration.

Brazil: Health Sector Reform Project; Category B
India: State Health Systems Development Project II; Category C
Morocco: Environmental Protection II, Category B
Pakistan: Pakistan-Punjab Urban Environment Project, Category A
Turkey: Antalya Solid Waste Management Project, Category B Senegal: Population and Health Services, Category C

I am especially concerned about the State Health Systems Development Project II in India which potentially includes funding for up to hundreds of incinerators in three states in India. The Staff Appraisal Report, dated February 1996 states:

Karnataka: "All hospitals with 50 beds and above will be installed with incinerators."

Punjab: "With Project Assistance incinerators of various capacities would be provided to all hospitals based on their bed strength and the amount of waste likely to be generated..."

West Bengal: "Incinerators will be made available for district hospitals and some sub-divisional hospitals, where the number of beds are larger than 300."

In another apparent inconsistency, the World Bank's own South Asia office, just one month prior to the SAR date above, recommended against incineration for medical waste in India. The January 1996 report "India's Environment - Taking Stock of Plans, Programs and Priorities" states:

"Long-term environmental policies, guideline, and statutes should be linked with immediate requirements to segregate and decontaminate medical waste at its source. This linkage should include appropriate technology for sustainable environmental and public health protection, rather than imported high-technology incinerators that are expensive to purchase and difficult to maintain."

I do not understand why the World Bank is funding medical waste incinerators at all, and I especially do not understand why the environmental classifications for these projects are so varied. I look forward to your response and explanation for this disturbing situation.

I have enclosed additional information about the dangers of medical waste incineration, the advantages of alternative non-incineration medical waste treatment technologies, and both the U.S. and Indian campaigns against medical waste incineration. I am happy to provide further information upon request.

Sincerely,

Ann Leonard
Multinationals Resource Center
(A Project of Essential Information)
Phone: (202) 387-8030

cc. Ismael Serageldin
Indian Campaign Against Medical Waste Incineration

Enc.