Sectoral Meeting, a gathering of Pollution Control Officers and representatives from different stakeholders of one sector, is a special seminar regularly conducted by the Pollution Control Association of the Philippines Inc. Region 4A (PCAPI Calabarzon) that aims to provide basic compliance requirements to all relevant environmental laws and to clarify issues in relation to their implementation specialized for one sector. PCAPI Calabarzon acknowledges that different business sectors have different needs and requirements and that each sector must undergo a focused and an in-depth discussion, thus the implementation of sectoral meetings.
In the span of six months before the end of the year 2018, a total of three sectoral meetings were held by PCAPI Calabarzon. These meetings focused on the following business sectors: Chemical/Pharmaceutical/Cosmetics and Warehousing/Logistics Sector; Semi-Conductor & Electronics/Electrical Sector; and Poultry and Livestock Sector.
On July 6,2018, 49 participants from different industries attended the Sectoral Meeting for Chemical/Pharmaceutical/Cosmetics and Warehousing/Logistics Sector at Silid ng Karunungan Room D, 7th Flr, Tower 1, ILCC, Insular Life Drive, Filinvest Corporate City, Alabang, Muntinlupa City.
Entitled the “Sectoral Meeting and Relevant Environmental Updates for Chemical/Pharmaceutical/Cosmetics and Warehousing/Logistics Sector”, the event is the first sectoral meeting for the two sectors.
Ms. Brefelin J. Robles, Sector Director of Chemical/Pharmaceutical/Cosmetic and Ms. Gemaika C. Trasadas, Sector Director of Warehousing/Logistics Sector, both from PCAPI Calabarzon, headed the meeting. Topics discussed during the seminar were: “Relevant Environmental Updates on General Effluent Standards (GES)” by Engr. Randy Anonuevo, Inspector, Surveillance and Monitoring Division, LLDA; “Compliance Action Plan (CAP)” by Engr. Wilfredo Billones, OIC of Ambient Air & Water Monitoring Section from EMB-R4A; “Updates on DENR-EMB Chemical Regulation and Permitting Requirements” by Ms. Emmanuelita Mendoza, Chief Chemical Management Section from EMB Central; and “Relevant Updates on Chemicals and Hazardous Wastes” by Engr. Marissa DC. Malabana, OIC, Chemical & THWMS from EMB-R4A.
To give an in-depth view of what transpired during this sectoral meeting, below is the highlights of the Minutes of Meeting.
- First speaker is Engr. Randy Añonuevo of LLDA and discussed the following highlights:
- Brief background of LLDA and their mandates including the EUF System.
- LLDA BR 523- Adoption of the EMB DAO 2016-08 effective 2nd week of February 2018. All areas covered by LLDA must comply with DAO 2016-08 Standards.
- Compliance Action Plan (CAP) must be submitted to receive the grace period and get exempted from the standards and new parameters required per industry type stated in the new DAO 2016-08. Upon submission of CAP to LLDA, it is automatically approved without any notice. But need to submit progress reports and results of analysis including the new parameters during submission of SMR.
- Format of CAP was presented. If the company wishes to get exemption on a certain parameter, they need to submit at least 10 monitoring data showing that their discharge has no traces or significant presence of the said parameter.
- Using the PSIC Code, the company shall monitor and comply with the indicated parameters in the DAO 2016-08. If the company is discharging process water and domestic water, specific PSIC Code and 37000 requirements apply. Unless, their domestic waste will go to a centralized wastewater treatment facility of a park.
- If interconnected to CWTF, but LLDA/EMB found out that sewer line has bypass and has discharge to bodies of water, LLDA will still monitor the effluents of the company.
- Manila Bay is now classified as Class SB from Class SC, so water discharge going to Manila Bay must comply with Class SB standard.
- LLDA ROLA must be submitted immediately to companies who will fail the standards and will be marked as Day 1 of the penalty. Penalty will only be stopped once the resampling analysis passed. If ROLA will not be issued to the company, this means that it passed the standard. Companies may request for copy of ROLA from LLDA.
- For cosmetics industry, there are chances of sudden change and exceedance in BOD caused by different product line mixtures. With this situation, request for Influent and Effluent Sampling and shall not be considered as Strong Waste. This usually applies to slaughter house.
- Willie Billones of EMB R4A answers questions on CAP and DAO 2016-08 inquiries.
- EMB is the one in-charge for accrediting testing laboratories. LLDA requires only EMB-accredited Labs to conduct 3rd party sampling.
- Upon submission of CAP to EMB, EMB needs to review and discuss the programs with the proponent through a Technical Conference before approving the submitted CAP. EMB does not give the maximum (5years) grace period.
3. For the updates on Chemical Permitting, Ms. Emmanuelita Mendoza of Chemical Section EMB Central Office presented the following:
- DENR mandate is to address the chemicals’ adverse effects on health and environment. Review of chemicals for regulations is through risk assessment.
- Maam Milet discussed the PICCS (Philippine Inventory of Chemicals and Chemical Substances). As of 2017, there are 47,139 registered chemicals in the Philippines excluding those covered by CBI (Confidential Business Information)
- PICCS Certificate is no longer issued by the office as already coordinated with BOC. But, if clients from abroad requests for PICCS, they may submit request letter to EMB Central.
- Latest PICCS List is available in USB for Php500
- Discussion on the difference between 2 types of PMPIN. Abbreviated PMPIN, if chemical is already registered in other countries. Detailed PMPIN would require additional information such as Occupational Exposure, Toxicological and Ecological Effects in SDS.
- SDS to be submitted must be in GHS (Globally Harmonized System) format with 16 sections.
- Notice of Commencement must be submitted with proper attachment to register the chemical/s to PICCS.
- SQI is the exemption for PMPIN for less than 1000kg. It can only be renewed 5 times.
- Polymer Exemption soon to be implemented. Currently under Public Consultation.
- Milet highlighted the use of Online Permitting and Monitoring System(OPMS)
- PCL (Priority Chemical List) – regulating those chemicals that has known adverse health effects. EMB is currently working on the revision of PCL which will (a) require additional requirements such as Chemical Management Plan and Contingency Plans and (b) additional 47 chemicals to be included in the list.
- PCL Exemption may be applied for less than 1% component or for laboratory reagent use. All importers (even if to be used for lab reagents) are not exempted.
- CCO (Chemical Control Order) must be secured prior to importation. If chemical is already in the port without the CCO Registration, BOC will notify EMB and Import Clearance will not be issued to the importer.
- Lead in paints will be phased out until 2019. Mercury due to Minamata Convention must be phased out by 2022 including those in fluorescent lamps, batteries and cosmetics.
- CCO for cyanide will have additional licensing requirements other than the registration and import clearance.
- Position letters are still accepted for those who have concerns on the 3rd PCL Revision while Public consultation is still on going.
4. Updates on Hazardous Waste Management was discussed by Engr. Marissa Malabana of EMB-R4A. Highlights are the following:
- Online HazWaste Manifest System. No hazardous waste shall be transported without going through the online HW manifest System which was implemented since December 2016.
- Online PTT was strictly implemented for CALABARZON generators last Jan 15, 2018. No more manual PTT was accepted thereafter.
- For valid manual PTT, manual manifest form will be used.
- Marissa run through the online manifest system showing some screenshots and the process flow of Generator’s ID Registration, PTT Application and Manifest application. Some of the benefits of the online system are it is real time and responsive and proponents can trace their applications.
- For Online Registration system support, you may call Mr. Lito Tanggali (02) 928-9898.
- Cost of Registration is Php1025 + Php 50 (Bank Charge) paid through Landbank. Print Order of Payment and transfer the information to ON COL Form.
- Multiple manifest can be applied for single PTT to cover the dates of transport.
- To be able apply for PTT, one must update first the generated wastes (maximize quantity) to be covered by the PTT which is valid for 6 months.
- Manifest form is to be printed by the transporter. Approval is up to EMB Evaluator.
- For data integrity, Treater/TSD can already edit the actual quantity of haz waste received and treated and reflect it on the Certificate of Treatment.
- Exempted from HW ID and PTT are untreated wastewater subject for transport (not covered by RA 6969)
- Manual issuance of PTT is applicable only for abandoned/ closed facilities and consolidated hauling (like ECOInDEX)
- Expired PNP/ PDEA Controlled chemicals that are subject for disposal are already considered hazardous wastes. PNP/PDEA may request to witness the actual disposal. PNP has a different Permit to Transport requirement.
- If company transfers to another location and has new ECC, new HW ID must be applied.
Another sectoral meeting was conducted on August 24, 2018 with title “Sectoral Meeting and Relevant Environmental Updates for Semi-Conductor & Electronics/Electrical Sector” which is the first sectoral meeting for the said business sector. Held at Silid ng Karunungan Room D, 7th Flr, Tower 1, ILCC, Insular Life Drive, Filinvest Corporate City, Alabang, Muntinlupa City, the six-hour seminar was attended by 50 participants from different stakeholders.
The sectoral meeting for electronics sector was welcomed by the PCAPI-R4A President Ms. Rasmiah “Miah” Malixi and Sector Director Mr. Rodolfo “Rudy” Rabe affiliated with American Power Conversion / Schnieder Electric Philippines.
Mr. Rudy Rabe discussed industry highlights and part of discussion is the classification of electronics industry sector comprising of nine (9) subsector which are semiconductor, consumer electronics, office equipment, control & instrumentation, electronic data processing, telecommunications, communications & radar, medical & industrial and automotive electonics. Profile of typhical electronics company including its characteristics and geographical location within the Philippines was also taken into account. It was also highligthed that the Philippine semiconductor and electronics industry is the largest contributor to the country’s manufacturing sector. Per year to date, data is showing that the electronics industry remains as the country’s top exporter with 54.38% of the total Phillipne exports.
In spite of industrys’ success, environmental management concerns has been a challenge in the operations such as :
- Permitting (Legislation, Regulatory Compliance) from various government agency such as DENR, DOLE, DOH, PEZA, PDEA
- Hazardous Wastes Management
- Waste Water Management
Ms. Miah Malixi provided updates of the organization such as PRC Accreditation, Training institution programs and services offered. Updates pertaining extention for PCO Accreditation with referrence to MC-001 highlighting temporaty deferment of PCO renewal (but still act as PCO in hold over capacity) were also discussed.
The first topic was supposedly focused on Online Manifest. Apparently, there was a recent Memorandum Circular for its immediate suspension. With this, the Guest Speaker, Ms. Marisa Malabana of EMB R4A open the floor for any Questions they have regarding RA 6969, Chemical Management and even Hazardous Waste Management. Some of the Questions raised are:
- Re: SQI, is there an alternate Signatory for the Regional Director? Our permits are being delayed because we are (most of the time) waiting for the RD’s Signature.
Ans: Apparently, there is no alternate. EMB signatories has unique numbers that cannot be transferred. The online approval can be easily accessed even outside the office. It is also recommended that they do follow up.
- Re: CCO Certificate and Importation Clearance. Do we really need to pay again if we re-apply online? Two companies raised the same concern.
Ans: No need to pay for the same permit. One company shared that they had a chance to talk to EMB Central Chemical Section and advised that they just attach the previous CCO permit. This is what they did and they did not pay.
- Re: CCO Application: We have lots of CCO, around 10 – 15 and I still have to renew my CCO Certificate every 6 months, I am being questioned by the management for the additional fees.
Ans: For companies with many CCO, it is advisable that you consolidate you CCOs. CCO Certificate does not expire. Please send a copy of the same concern to Ms. Marissa for clarification. It is possible to have additional fees for amendments.
- What office handles the CCO Application? Is it the Regional Office? To whom should we seek clarifications?
Ans: CCO Lead – EMB Central Office; PCB, Cyanide and Mercury – Regional Offices; CCO ODS – Ozone Desk in the regional office. For any clarification, we can call EMB Central Office at 9288892.
- Is there an option to pay to any Landbank for the CCO and PCL Application?
Ans: Chemical Permit Payment – Go to EMB
- Who can give the Chemical Training being required as one of the attachments for CCO and PCL Application?
Ans: UP Public Health – Chemical Safety Training; OSH Training Center for chemical safety trainings and other experts on the field.
Additional Information Motioned by the guest speaker:
- As service provider they should also apply for lead / CCO as transporter.
- For end use / product with CCO Content, no need to apply for the CCO / PCL Certificate. It only applies to all materials that will still be used in another process as raw materials / raw ingredients.
As the discussion went, there were clarifications on proper hazardous waste classification such as:
- F604 – Resinous Materials – Mold Runners
- Compressor with Used oil – Should be classified as I101.
- Oil from Oil water separator from canteen and operation H802.
- Sludge from Filter Press with Tin and Copper, should be D499 – change in SMR as necessary for Region 4A.
- Empty container of Freon – J201;
- Lithium Battery – M506
Some participants also raised concerns that scrap buyers and residual haulers are not getting gypsum boards and fiber glass because they thought that these are hazardous.
- TCLP Test can be done to confirm presence of inorganic chemicals.
- Fiber Test can be done to detect asbestos
- PCOs can also check with co-processing plants for recycling of such wastes.
- For gypsum board – Non-hazardous and be classified as Solid Waste.
- For used tires, we can look for treaters that recover crude from it.
Before presenting the next speaker, PCAPI-R4A Recognized its new 20 years institutional member from ARTESYN. A plaque of recognition was awarded by the officers of PCAPI R4A present in the event.
The second topic is on the discussion of the General Effluent Standard (GES) and Compliance Action Plan (CAP) by Engr. Randy Anonuevo of LLDA. Some of the questions raised after his presentation are:
- Our park admin is requesting us to submit CAP. Is it ok? Ans: Yes, The Park Admin if with centralized WWTP / STP will be responsible to submit the CAP to us.
- Is the Annual progress report different from the SMR? Ans: Yes. It should be submitted separately.
Other highlights mentioned by the speaker are:
- Submit CAP to LLDA so that we will not test you with the new standard.
- CAP is like a request letter of your company that you still need time to comply for the new standard. It is a commitment of the actions that your company will do in order to comply.
- Start of 5 years of CAP once you have submitted. After your 5 years has lapsed, you can still submit a catch-up plan if you still need more time. Extension is 6 months.
- Annual Progress report should be submitted too.
The last sectoral meeting of the year, the 2nd Sectoral Meeting for Poultry and Livestock Sector, was held on September 21, 2018 at NCAS Auditorium, University of the Philippines, Los Baños, Laguna and attended by 71 participants from different swine and poultry farms around Calabarzon.
As the Sector Representative for Poultry and Livestock Sector, PCAPI Calabarzon President Ms. Rasmiah Malixi headed the seminar by opening the program with her remarks and discussion about the Environmental Requirements in the Poultry and Livestock Sector. Ms. Malixi presented the 2017 Status of Poultry Production in the Philippines by region, Central Luzon having the highest production of broilers and Calabarzon for layers. She also discussed about the environmental issues being faced by Poultry and Livestock businesses such as generation of foul odors, increase population of flies that are vectors of diseases, and improper wastewater treatment that poses risks to surface water and ground water contamination. She also explained the major compliance requirements of their sector for the following Environmental Laws: Phil EIS System (PD 1586); Clean Air Act (RA 8749); Clean Water Act (RA 9275); Toxic and Hazardous Waste Management (RA 6969); Solid Waste Management Act (RA 9003); PCO Designation (DAO 26); and PCO Accreditation (DAO 2014-002).
Engr. Phoebe P. Pua of Bureau of Soils and Water Management talked about the steps and requirements on Applying for a “Certificate for Reuse of Wastewater for Irrigation and Other Agricultural Uses (DA AO 2007-06). She discussed all about the Department of Agriculture Administrative Order No. 26 (DA AO No. 26) series of 2007 or the Guidelines on the Procedures and Technical Requirements for the Issuance of a Certification Allowing the Safe Reuse of Wastewater for the Purposes of Irrigation and other Agricultural Uses. She explained that a certification issued by DA through DA-RFO is required before a person can reuse his generated wastewater for irrigation, fertilization, and aquaculture and other agricultural purposes that is for the protection of environment, human health, and animal health. That being said, she then thoroughly discussed the step by step procedures and requirements to be done to get certified, as well as the validating agencies needed per purpose of wastewater reuse.
Other topics discussed during the seminar were: Compliance Status of Poultry and Livestock Sector on General Effluent Standards (GES) and How to Write a Compliance Action Plan (CAP), discussed respectively by Engr. George S. Volante, Clearances and Permits Division, Environmental Regulations Dept from LLDA and Engr. Wilfredo Billones, OIC, Ambient Air & Water Monitoring Section from EMB-R4A.
These Sectoral Meetings were especially done as service for the PCAPI R4A members but the doors were opened to non-members as well.