TOXIC SUBSTANCES MANAGEMENT
Clearance and Permitting
Presented in Table 1 is the summarized data of the overall quantity of issuance per type of importation permit for January to June 2020, a total of nine hundred thirty eight (938) permits were issued for the importation of chemicals these includes Small Quantity Importation, Importation Clearance (Cyanide and Mercury), Chemical Control Order for Cyanide, Mercury and PCB.
Table 1. Number of Clearances and Volume of Importation for Chemicals for January to June 2020
|Small Quantity Importation (SQI)||391||816|
|Chemical Control Order (CCO)||25||30|
|Importation Clearance (IC)||50||92|
The number of registrants of CCO Importation for Cyanide and Cyanide Compounds increased in number due to a higher demand for chemicals needed in production and manufacturing. Whereas, most of the applicant for Small Quantity Importation has a big impact on registration even during the first half of the year.
For January to June 2020, a total of 314.5971 tons of Cyanide and Cyanide Compounds were registered and 468.0885 tons were imported. Major usage of the said chemicals which were imported are intended for but not limited to plating chemicals, adhesive in manufacturing of Inductor products and core bonding product, wood preservative and laboratory analysis.
On the other hand, volume of Mercury and Mercury Compounds registered is 0.05301 tons and 0.1664 tons were imported which are mainly used as standard for laboratory analysis and one company importing Mercury which are being used for the manufacturing of Lamps which will be installed and used in Laboratory Equipment for analysis as well.
It can be noted that for the first half of 2020, there were no registered firms for CCO for Asbestos, this may be associated to the limited allowable usage of such and there are numerous available materials that can be used as substitute for Asbestos.
Table 2. Number of Clearances and Volume of Importation for Chemicals.
|NUMBER OF CERTIFICATE/
|Regulated Chemicals Under CCO: Registration Certificate|
|Importer, Distributor, End-user||29|
|Regulated Chemicals Under CCO: Importation Clearance|
|Small Quantity Importation Clearance||816|
For 2018, online processing of Importation Permits and Clearances was initiated, and no manual application was allowed and accepted.
On November 2016, PICCS application was no longer accepted in this Office since permit/clearance is not needed to be secured if the chemicals are already listed in the PICCS Database based on Section II of EMB Memorandum Circular 2014-001 dated 10 January 2014 “Manufacturers and importers do not need to notify and secure clearance from this Office before they manufacture or import chemicals already included in the PICCS, provided that these chemicals are not in the Priority Chemical List (PCL) or regulated by Chemical Control Order (CCO) or chemicals which are already covered or regulated by other laws or legislation.” And under section III of EMB Memorandum Circular 2016-011 dated 10 August 2016 “Issuance of PICCS Certificate shall not be allowed”
It was in the same year that indefinite suspension of Online Hazardous Waste Manifest System and PCB Online was ordered for the upgrading of the online system as well as to address some technical issues. See figure below.
Figure 1. Announcement of indefinite suspension of online application as posted in the official website
On the other hand, Operationalization of the Online Hazardous Waste Management System (HWMS) has started effective June 1, 2020. As such all transactions with regards to hazardous wastes management shall be made through https://hwms.emb.gov.ph. The system requires prior company profile registration thru https://iis.emb.gov.ph/crs to generate company reference id.
HAZARDOUS WASTE MANAGEMENT
Industrialization resulted in generation of industrial wastes, including hazardous wastes that require management to prevent or minimize risks to the environment and public health. As such, Title III of RA 6969 was mainly designed to respond to increasing problems associated with toxic chemicals and hazardous and nuclear wastes. It provides systems and procedures for proper hazardous wastes management for regulator and regulated communities.
To effectively manage and handle hazardous wastes, the DENR requires the following:
- Waste generators to register and report the type and quality of waste generated, treated or transported outside the plant;
- Waste generators to use waste transporters and treaters duly authorized by DENR;
- Waste transporters to secure permits from DENR before transporting any quantity of hazardous wastes; and
- Waste generators, transporters, and treaters to keep records and to submit report to DENR on the transport of wastes from the point of generation to its final storage, export, treatment, and disposal points, among others.
Clearance And Permitting
Issuances of Permit to Transport (PTT) for January to June 2020 have reached to nine hundred thirty-nine (939) permits which is 112% of the target PTT issuance for this year.
During ECQ and upon issuance of MC 2020-14, 15, 16 and 20, the Region has issued 361 Special Permit to Transport (SPTT). One hundred ninety-nine (199) of issued SPTT is attributed to healthcare wastes transport majority of which are referral hospital for Covid-patients and Quarantine Facilities. The remaining one hundred sixty-two (162) SPTT were issued for hazardous wastes other than health care wastes.
For CALABARZON Region, there are five (5) TSD facilities which cater or treat healthcare infectious wastes. These are: 1&2) Integrated Waste Management Inc (IWMI) with Autoclave and Pyrolysis technology and further disposed in Metro Clark Waste Management Corporation in Region 3 and Cleanway Environmental Management Solutions Inc. (CEMSI) using the Hydroclave technology and disposed in the facility’s sanitary landfill. The remaining two (2) facilities are Green Eco Techwin and Hazchem Inc. located in Cavite and Laguna, respectively.
Table 5. Lists of Hazardous Wastes Permits issued for January to June 2020
|Permit to Transport (PTT)||837||939||112%|
|Special Permit To Transport (SPTT)||–||361||–|
In addition, a total of two hundred nineteen (219) facilities have registered as Hazardous Waste Generator this 2020 which was 125% from the target. Eleven (11) registered generators were healthcare facilities. It includes clinics, diagnostics and laboratories, hospitals, lying-in and other similar services.
Capability Building / IEC
Series of trainings on Environmental Management and Environmental Regulations were held in the first Quarter of 2020. Personnel from this Office were invited by Recognized Training Organizations as resource persons or speakers in the conduct of Pollution Control Officers (PCOs) training to discuss thoroughly the salient features of RA 6969 up to more detailed information/concept that is essential for the proper management of chemicals and hazardous wastes in the industries. However, on the second quarter of 2020, there were no to limited trainings were done since gatherings are prohibited during ECQ and GCQ.
To further disseminate information, this Office provides infographics and podcasts to further inform, circulate and share information through social media platforms.
It is apparent that implementation and monitoring of compliance of each establishment is quite challenging especially those with very minimal and outdated training on Environmental Laws.
Below are the challenges encountered in the implementation of RA6969:
- Information Dissemination (Best Available Technologies for treatment of Hazardous Waste and On-Line Applications for Hazardous Waste Generators, Transporter, TSD Facilities, SQI, CCO Application, and the likes);
- Familiarization with the new system of IIS and online HWMS for processing of HW Generators, Transporters and TSD facilities;
- Mobility and Accessibility. Monitoring of establishments in areas that are high risk due to COVID-19 Pandemic; and
- Some of the firms are still adjusting in the shift to paperless in the submission of application for permits and some of the establishments lack internet access. Also, the system is not perfect and exposed to technical glitch or error.
STRATEGIES IN THE IMPLEMENTATION OF PROGRAMS AND PROJECTS
- This Office provides infographics and podcasts to further inform, circulate and share information through social media platforms.;
- Operationalization of online Hazardous Waste Management System to provide undisrupted services relative to RA 6969;
- Online banking was made available for the payment of permits;
- Provision of mobile number which serves as hotline to assist the client with regard to Chemicals and Hazardous Waste Management concerns and
- Conduct of trainings/webinars in the use of new online system not just for EMB personnel but for firms and establishments.
PROVINCIAL ENVIRONMENTAL MANAGEMENT UNITS
The Provincial Environmental Management Units (PEMUs) are the alter-ego of the Regional Office in all provinces. Each PEMU is headed by a Provincial Environmental Management Officer (PEMO) with technical staff and the SWEET-ENMOs. Number of personnel varies in each province.
Primary functions of PEMUs are survey and monitoring of firms, investigation of complaints and assessment/monitoring of SWM facilities. Reports generated after field works are forwarded to the Regional Office for further action. They also represent the Regional Director in some meetings or conferences.
CHALLENGES (ISSUES AND CONCERNS)
- Difficulty in the conduct of monitoring and investigation:
- The technical personnel of this Office could not conduct face to face on site monitoring and investigation in some project complaints in compliance with IATF Protocol.
- Even under MGCQ, PEMUs could not yet conduct regular, actual, on site monitoring of projects/ industries to check compliance to environmental laws, rules and regulations. This is due to public transport limitations, safety requirements and strict entry regulations on private industries.
- In general, the high risks COVID 19 infection of technical personnel going out in the field could create anxieties in the performance of their work, especially to those in the vulnerable sectors (Senior citizens, pregnant women and those with pre-existing conditions).
- Clients/complainants cannot be prevented from coming to our office
- To ensure immediate conduct of on-site investigation on complaints received by the Office, the assigned EnMOS are tasked to gather data based on the technical personnel instructions. These technical personnel make the necessary coordination with the LGUs;
- Close coordination with LGU MENROS and CENROS are being done considering the proximity of the projects in their areas;
- Regular Monitoring of the ENMOS and on-line monitoring of the technical personnel to ensure the performance of their targets;
- Strict submission of investigation reports of the technical personnel within 72 hours;
- Adoption of WFH and skeleton force thru on-line attendance to ensure the continuity of service;
- All Technical Personnel and EnMOS of the Office are provided with complete PPEs to ensure their safety especially when they are on fieldwork;
- Disinfectant installed at the office entrance; and
- Have a thermal scanner in the Office. All employees/visitors are tested prior entry to PEMU Office