The governance of Household Hazardous Waste (HHW): A literature review of HHW-related regulation in Southeast Asian developing countries

Growing cities of developing countries followed by human activities brings challenge on how to manage the massive solid waste production. Pile of solid waste in the collecting or dumping sites produce methane gas that threaten earths’ climate change, whereas leachate with organic, inorganic, and hazardous contaminants resulted in soil and groundwater pollution. Furthermore, untreated solid wastes are aesthetically disturbing and environmentally polluting as they enter the water bodies. More than 40% of the Municipal Solid Waste are generated by household activities and approximately 1% of it contains hazardous materials, such as heavy metals and inert materials. Unprocessed Household Hazardous Waste (HHW) carries substantial ecological impacts. However, issues on HHW considered to have less attention either by community or government due to the requirement of specific treatment and the cost of final disposal. The role of regulation or guidelines are critical to manage the HHW handling. This review aims to explore the availability of national as well as local regulation related to HHW management in Southeast Asian developing countries and to analyze the correlation between GNI level and the government concern on HHW issues. Despite the main solution, the availability of HHW regulation is required to govern the management and minimize the contamination to the environment. The analysis is based on literature from journals as well as official websites from each country which studied. The result of the study can give an alternate perspective on the governance of HHW in developing countries.


Introduction
Developing countries in Southeast Asia are experiencing rapid economic growth and development within the last few decades.Based on data by The World Bank in 2022, eight developing countries in Southeast Asia, namely Indonesia, the Philippines, Thailand, Vietnam, Malaysia, Lao, Myanmar, and Cambodia, experienced an increase of GDP until more than 2%.Only Timor-Leste experienced a 1314 (2024) 012124 IOP Publishing doi:10.1088/1755-1315/1314/1/012124 2 degression of GDP growth in 2022 up to -17,5%.The increase of economic growth and GDP aligns with the increase of rapid globalization that consequently boost massive development of infrastructures and facilities.This development has brought implications on the emergence of numerous activities, such as new settlement areas, commercial areas, and industrial areas.Inevitably, rapid urbanization at city center, huge variety of human activities, high level consumptions of goods and services eventually increase the production of municipal solid waste that become a global challenge [1][2][3][4][5][6][7][8].
In many studies, it is known that more than 40% of the Municipal Solid Waste (MSW) are generated from the domestic or household activities, and approximately 1% of household waste is categorized as Household Hazardous Waste (HHW), because it contains hazardous materials.Even though the amount of household hazardous waste is not as significant as other types of waste, HHW can cause adverse impacts that are harmful for the living organisms and the environment.Furthermore, it can harm human health because the toxic materials that contains in the waste can cause skin and eye irritation, overdose, harmful for embryo, mutation of genes, and death.Toxic material from HHW can be accumulated inside living organisms and it can cause mutation of genes, cancer, and attack the central nerves system if accumulated in a long period [2,[9][10][11].
The effect of HHW to the environment can be in many forms.Mainly, the hazardous and toxic materials or substances can cause in air, surface and ground water, and soil pollution.The pollution of hazardous contamination may cause several ecological disasters due to the characteristic of the hazardous waste if it is not treated properly.For example, hazardous waste that contain chlorinated organic hydrocarbon can cause air pollution by producing noxious or dioxin gases and odor if it is being burnt [7,11].Dioxins according to the WHO is categorized as persistent organic pollutants (POPs) and it can accumulate in body and attack skin, liver, immune system, nervous system, endocrine system, and reproductive functions.The untreated hazardous waste also may produce methane gas (CH4), one of the greenhouse gases, that can damage the ozone system in the atmosphere and cause the global warming [12].
Because the effect of hazardous waste is extremely harmful for the living organisms and the environment, hence the hazardous waste must be managed properly including hazardous waste generated from household.Based on the study conducted by Manggali and Susanna [8], the absence of HHW-related regulation and its enforcement leads to the improper handling of HHW.Establishing HHW-related regulation is one of the instruments to control the generation, movement, and handling of this type of waste [13].This paper aims to explore the availability of national and/or local regulation related to HHW issue focusing on developing countries in Southeast Asia, and to analyze the correlation between the Gross National Income (GNI) level and the governments' concern on HHW issue.This approach carried out because as studied in many literatures, good practices of HHW management system commonly occur in developed countries.For example, the United State of America has United States Environmental Protection Agency or US EPA that govern the HHW generated from household in the USA.The US government provides several public collection facilities for HHW which equipped with guideline as can be seen in the manual book for HHW called "Household Hazardous Waste Management, A Manual for One-Day Community Collection Program which regulate the utilization and preservation of hazardous products.They also have a system to minimize the generation of hazardous waste from households.US EPA sets the guidelines for each state in the United Stated so that each state are able to have their own regulation for HHW management [14].In Europe, HHW handling are based on the Directive (EU) 2018/851 of the European Parliament and of the Council of 30 May 2018 that amending the Directive 2008/98/EC on Waste [15].Europe also has the guideline for HHW collection that is regulated in the European Commission of 2020/C 375/01 about the Commission Notice on Separate Collection of Household Hazardous Waste [16].Finally, the outcome expected from this study is to find out the perspective on the governance of household hazardous waste in the developing countries in Southeast Asia Region.

Materials and Methods
This study relies on literature review by analyzing the regulations that related to HHW in each developing country in the Southeast Asia.The data consists of regulations obtained from official websites of government agencies or other official website of national and or international organizations as well as from journals, report books, and articles [17].[13], [14], [15], [16], [18], [19], [33] Moreover, this study applies the Comparative method as part qualitative analysis.This method enables to compare the content of HHW-related regulation.The focus is to see the similarity and difference of variables or scope of arrangement from each regulation from each studied location [32].Determining variables to be analyzed from each regulation is the next step of analysis.These variables are waste types and sources, waste management system, actors which involved or regulated object, source of funding, and penalties.The objective is to be able to understand to what extent the Governments' concern about HHW issue within their jurisdiction.In addition, to understand the transferability of a particular regulation from one place to be implemented in other places, it is important to learn the actual implementation from literatures, such as journals or report books, and then draw some lessons to see the degree of the lesson that can be applied.

Country classification
Discussion on hazardous waste that are generated from household activities or Household Hazardous Waste (HHW) receives less attention globally compared to the discussion on the hazardous waste generated from industry in almost all countries in the world as well as the discussion on Municipal Solid Waste in general.commonly developed countries, which already have a better waste management, already consider HHW is that kind of waste that need to be given attention as much as other type of waste, especially considering the negative impacts that can be generated by this type of waste [18].According to the International Monetary Fund's (IMF), of all 11 countries in the Southeast Asia Region, there are only 2 countries that categorized as developed country, namely Brunei Darussalam and Singapore.The remaining 9 countries are categorized as developing country.Brunei Darussalam received its developed status from the IMF before year 1980 while Singapore received its developed status by the World Bank during period of 1980 -1999 [19].The classification of developed or developing countries used to be defined according to the level of Gross National Income or GNI per capita of a country by the World Bank.The World Bank divides countries based on the income of the country, in which developing countries are characterized as a country with low-or middle-income group while the country with high level of GNI per capita considered as developed country.
Nowadays, the World Bank or other international institution rarely use the term developing or developed country because it is no longer relevant.Countries in the world are being classified based in their income level by the World Bank.Income per capita can be affected by the location of a country, their income per capita (Gross National Income (GNI) per capita), income group, IDA status, and services of infrastructure such as electric power consumption (kwh per capita), improved water source (% of population with access), improved sanitation facilities (% of population with access), telephone subscribers per 100 inhabitants, and mobile cellular subscriptions per 100 inhabitants.The income classification is based on Atlas GNI owned by the World Bank, which has thresholds to determine the classification of a country.
The classification of a country is based on the GNI per capita of each country.There are four classifications based on the GNI level of a country that applicated from July 1 st 2023 to June 30 th 2024, which are Low Income with GNI per capita is at least US$1,135, Lower-middle Income with GNI per capita is between US$1,136 -US$4,465, Upper-middle Income with GNI per Capita is between US$4,466 -US$13,845, and high income with GNI per capita is more than US$13,845.The threshold of these classifications may vary each year.
Based on the explanation above, the classification of countries in South-East Asia based on their level on income in year 2023 can be seen in table below.Based on the table above, there are three main classifications of the countries in the Southeast Asia Region, the high income which are Singapore and Brunei, also classified as developed country, the upper-middle income which are Indonesia, Thailand, and Malaysia, and the lower-middle income which are Philippines, Vietnam, Myanmar, Cambodia, Lao PDR, and Timor-Leste.
Since the study will mainly discuss about the regulation for household hazardous waste for developing countries in the Southeast Asia Region, then the country that will be discuss in Indonesia, Philippines, Vietnam, Thailand, Myanmar, Malaysia, Cambodia, Lao PDR, and Timor-Leste.

Household hazardous waste related regulation in developing countries in Southeast Asia
Currently, it is known that not all of the developing countries in Southeast Asia have established HHWrelated regulation, either as a specific regulation or as part of hazardous waste or MSW regulation in general.Based on the study towards regulations owned by some of these countries, it is clear that there are no specific standard or guidelines to regulate HHW among developing countries.The result of the analysis is explained below.
Indonesia does not have a particular regulation on HHW, but it has a national directive that regulates the waste from specific sources with specific characteristics which is called as specific waste, namely the Government Regulation Number 27 Year 2020 about Specific Waste Management.In this regulation, there are two goals of the specific waste management, which are to reduce and to handle it properly by separation, collection, transportation, treatment, and final disposal.In this regulation, HHW become part of solid waste which contain hazardous materials or hazardous waste which resulted from household activities.This regulation also gives the overview for the authority of the government, which mention that the Minister of Environment and Forestry has full authority on national scale and must give the mandate for household hazardous waste management to the governor in each province in Indonesia.The governors themselves have the authority to manage each of the regional heads for be responsible in the management of household hazardous waste that generated in their regional [20].
Philippines has The Republic Act No. 6969 known as the "Toxic Substances and Hazardous and Nuclear Waste Control Act of 1990".This legal act regulates the hazardous waste, but does not include the HHW [21].Instead, hazardous wastes which are generated from residential and commercial facilities, called specific waste, is mentioned in the Republic Act No. 9003 or also known as the "Ecological Solid Waste Management Act of 2020" in which initially regulate solid waste management.This household hazardous waste should be managed separately from other solid waste, and this regulation regulates the Department of Environment and Local Government Units in the Philippines to be able to issue some guidelines for the characterization of HHW based on the Republic Act No. 6969.The Local Government Units also have the responsibility to handle and dispose the HHW within their area of authority under the assist of the National Ecology Centre.The Republic Act No. 6969 and Republic Act No. 9003 are in the national level [22].
Furthermore, Thailand has the Ministerial Regulation B.E. 2563 (2020) about Toxic or Hazardous Waste Management from the Community.Despite indirectly state or regulate HHW, the term of 'community' in this regulation may also refer to people or society or building, which can be assumed that the regulation may also regulates the hazardous waste from household activities.This regulation mainly discusses the waste which contain hazardous substances as well as the authority of government and their role as the provider of hazardous waste facility and infrastructure.The management system stated within this regulation are divided into collection, transportation, treatment, and disposal of hazardous waste [23].
According to the Law No. 08/2022/ND-CP about the detailing number of the Law on Environmental Protection by the Socialist Republic of Vietnam, the hazardous waste is defined as the hazardous waste that generated from the industrial sector and being part of industrial waste [24].But Vietnam has a decree of the Ministry of Natural Resources and Environment No. 36/2015/TT-BTNMT about the Management of Hazardous Waste.This decree can be applied for those whose activities are related to the generation of hazardous waste, including the state management agencies and domestic or foreign organizations and individuals' activities.This regulation contains the list of hazardous waste and the technical requirements for hazardous waste processes.This regulation also contains the management of hazardous waste processes, which include the registration order for hazardous waste source owner, the grand and re-grant of hazardous waste, and the licenses and certificates for hazardous waste disposal and management industry [25].
Malaysia has Peraturan-peraturan Kualiti Alam Sekeliling P.U.(A) 294/2005 under the Environmental Quality (Scheduled Waste) Regulation 2005, which amended became P.U.(A) 158/2007, the Environmental Quality (Scheduled Waste) (Amendment) Regulation 2007.This stipulation regulates the hazardous waste within the list of scheduled waste in the First Schedule and the list of incompatible scheduled waste in the Fourth Schedule that can be found in the annex of this regulation.The First Schedule waste contains of five different types of waste with the total of 77 types of waste in the list.The Fourth Schedule waste contains seven group of waste which potentially incompatible and produce harmful materials if it is mixed with other waste categories.This regulation manages the waste generated from any person who generates scheduled wastes which include household.It also governs the treatment and disposal of scheduled waste including the recovery process of material or product of scheduled waste.This regulation mentions the responsibility of the waste generators, waste contractors, and waste occupiers [26].
Lao has the Environmental Protection Law of 2012 which stated that the person who generates hazardous waste has the responsibility to manage the hazardous waste according to the applicable standards and regulations.But there is lack of information about the management of household hazardous waste [27].Lao also has the Ministerial Instructions on Hazardous Waste Management which stated that the Government of Lao PDR is most likely will focus on the handling of plastic waste and the management of hazardous waste based on Basel Convention [28].
Other developing countries; Myanmar, Cambodia, and Timor-Leste, are currently do not have any regulations related to HHW management.The regulations available in those countries are only regulate the hazardous waste generated from industries.Myanmar has the National Waste Management Strategy and Master Plan for Myanmar for 2018 to 2030 that only discusses about the waste management plan for two types of waste, which are domestic and industrial waste.Hazardous waste discussed in this document only those produced in the industrial sector [29].
In Cambodia, the regulation for the environmental protection which include the policy to reduce and control the hazardous waste in the Law of Environmental Protection and Natural Resources Management.Hazardous waste is included in the solid waste category called Hazardous Solid Waste (HSW).Despite the HSW that being defined is include the hazardous waste from the dwelling house, but up until today there are no specific rules for HHW in Cambodia [30].Timor-Leste has a Decree Law or Decreto-Lei No.2 Year 2017 about the Basic Law on the Environment.This regulation stated that hazardous waste as a part of Urban Solid Waste (USW) that can be generated from household, but there no specific explanation about the urban solid waste and the regulation regarding HHW in specific [31].As mentioned earlier, from 11 countries in Southeast Asia, 9 countries are classified as developing countries with the GNI index range from lower-middle to upper middle income based on the data from World Bank and International Monetary Fund (IMF), namely Indonesia, the Philippines, Thailand, Vietnam, Malaysia, Lao, Myanmar, Cambodia, and Timor-Leste, while the other 2 which are Singapore and Brunei Darussalam are both develop countries with high income classification.
From 9 developing countries, 6 of them already have regulation related to hazardous substances, which are 5 countries already stated that household activities as one of the sources of hazardous waste, together with other industrial, commercial, and public activities, namely Indonesia, Philippines, Thailand, Vietnam, and Lao; while Malaysia only stated commercial and industrial as the source of hazardous waste.The other 3 developing countries namely, Myanmar, Cambodia, and Timor-Leste do not have a specific regulation about household hazardous waste.
In general, developing countries in South-East Asia already have national regulation on Hazardous Waste including those resulted from household activities both from upper-middle and lower-middle income countries, namely Indonesia, the Philippines, Thailand, Vietnam, Malaysia, and Lao.The absence of HHW-related regulation mainly occurs in developing countries with lower-middle income, which are Myanmar, Cambodia, and Timor-Leste.This HHW-related regulations issued at the national level which arrange some variables including waste types, waste sources, management system, and actors related.Furthermore, there are some parameters that are not regulated in some countries, such as financial sources and fines or penalties; this probably because not all regulations are issued at the level that enables them to arrange those variables.
Based on the year issued it can be seen that only recently these countries acknowledge the potential harm of household hazardous waste towards the environment, like in Indonesia, Thailand, and Vietnam

Table 1 .
Research Data Sources

Table 2 .
Country classification in the Southeast Asia according to the IMF

Table 3 .
Country classification in the Southeast Asia based on GNI per capita by the World Bank

Table 4 .
Comparation of HHW-Related Regulation Among Southeast Asian Developing Countries