pollution control association of the philippines region · pdf filepollution control...

POLLUTION CONTROL ASSOCIATION

OF THE PHILIPPINES REGION 4A CHAPTER, INC.Room 409 4th Floor Vega Centre, College, Los Baños, Laguna 4030

Mobile #: 0917-8144751 / 0998-5347850

E-mail Address: [email protected] / [email protected]

ROUND TABLE DISCUSSION

Team: Nante, Jelo, Luz, Junnel, Lowell



Mobile #: 0917-8144751 / 0998-5347850


OBJECTIVE:To promote two-way communication between the community of PCOs and the regulators. This will serve as a venue for regulators to report updates and raise compliance issues that they deemed necessary for the regulated community to improve on. On the other hand, this is also a venue for the PCOs to raise their concerns and issues in terms of actual compliance on the ground.



Mobile #: 0917-8144751 / 0998-5347850


Discussion:• DAO 2014-02 PCO Accreditation

• DAO 2013-22 (Hazardous Waste On-line Filing)

• DAO 2000-18 (PTO)

•DAO 2005-10 (Discharge Permit)

• PNP Permitting



Mobile #: 0917-8144751 / 0998-5347850


DAO 2014-02

PCO Accreditation



Mobile #: 0917-8144751 / 0998-5347850


DAO 2014-02 PCO Accreditation

FREQUENTLY ASKD QUESTIONS (FAQs) ANSWER

Since DAO 2014-02 has beenimplemented in 2014 andaccreditation is only valid for three (3)years, are we going to requirerenewal of his/her accreditation forthose who are accredited last 2012and 2013?

Yes. All PCOs are required to renewtheir accreditation on or before 21February 2015.

Does the managing head need to beaccredited also or the 8-hrs trainingEnough?

The Managing Head will not beaccredited as PCO (but will need toundergo the 8-hour training) but will actas interim PCO in the event that thePCO resigns or is terminated.



Mobile #: 0917-8144751 / 0998-5347850




In Sec. 7.1 “PCO for Companies Installations”, are packing plants, gasoline stations and schools covered?

Yes, packing plants, gasoline stations and schools are covered but are notconsidered as “installations” but as “establishments”.

Is it allowed for either Category A or B establishments to have onlyone person acting as Managing Head and PCO at the same time?

Section 8 of DAO 2014-02 states that there should be aManaging Head and at least one (1) PCO per establishment.



Mobile #: 0917-8144751 / 0998-5347850




Can establishments have multiple accreditedPCOs?

An establishment can have more than one (1) accredited PCO. However, the focal PCO who will liaise with the EMB should be clearly identified with the concerned EMB Regional Office.

Can the corporate Vice President or Managersubstitute for the managing head especially for off site projects?

Yes, an “appointment letter as Managing Head” should be issued by the CEO to the VP or Manager.



Mobile #: 0917-8144751 / 0998-5347850




What if the appointed PCO has been with the company only for less than a year although in a supervisory position, will he/she still qualify for accreditation?

Sec. 6-2a Qualification Requirements for PCOs•Graduate of any related technical course; OR•Had reached 3rd year in tertiary level education; OR• Had been with the establishment for at least 3 years in a supervisory position or in a responsible position or equivalentexperience



Mobile #: 0917-8144751 / 0998-5347850




What are the list of technical courses in which you can be considered as a Category A PCO?

Examples would include Electronics, Machine Shop Practice, Motor Control, Mechatronics, and Industrial Automation, among others.

Does the statement "had reached third year intertiary level education" refer to the technicalcourse or for any course for that matter?

This refers to any course, whether college or technical course.



Mobile #: 0917-8144751 / 0998-5347850




For category B establishments, what shall be proofs that the PCOs have experience in environmental management?

Experience on environmental management refers to actual work experience or training on environmentalmanagement or pollution control. Proof may include Certificate of Employmentand/or Training.

What will happen to existing PCOswho have not met the minimumcompetency requirement?

Existing PCO’s current accreditation cannot be renewed anymore if theycannot meet the minimum competency requirement.



Mobile #: 0917-8144751 / 0998-5347850




In Section 11 of the DAO, can you expound further on what the "20 hours training as a trainer/subject matter expert“ mean?

If you are a PCO, an expert on environmental management and acts as a resource speaker on topics/subjects such as environmental laws and management, pollution control, and other relevant subjects which accumulated to 20 hours, then saidhours can be considered for your renewal for PCO accreditation. However, said lectures in training or seminars should be validated by EMB.



Mobile #: 0917-8144751 / 0998-5347850




What are the sanctions for stablishments/LGUs who refuse to designate PCOs?

LGUs are also covered in Sec. 27 (n) of RA 9275 (Prohibited Acts). Sec. 28 (Fines, Damages and Penalties) stated a fine of not less than P10,000 nor more than P200,000 for refusal or failure to designate a PCO whenever required by DENR.



Mobile #: 0917-8144751 / 0998-5347850




If the Managing Head stands as a PCO for his company, would he be required to secure a Certificate of Training for eight (8) hours on environmental management on top of the 40 hour Basic PCO training? (please refer to the PCO accreditation application form under other requirements)

If the Managing Head is the PCO, he is required to undergo 40 hours of training only. However, ideally, the PCO should not be the Managing Head. In an establishment, there should be a 1)Managing Head and 2) PCO. The PCO and the Managing Head shall be held jointly and severally liable for any violation of environmental laws.



Mobile #: 0917-8144751 / 0998-5347850




Is the Managing Head allowed to be a PCO for his company? If not or how long will he be allowed to act as an interim PCO?

Sec. 9 states that a new PCO should seek accreditation within 30 calendar days from the date of resignation or termination of the previous PCO.

If there is a change in the Managing Head, do we have to resubmit a new Affidavit of Joint Undertaking signed by the new MH?



Mobile #: 0917-8144751 / 0998-5347850


DAO 2013-22

Hazardous Waste On-line Filing



Mobile #: 0917-8144751 / 0998-5347850


DAO 2013-22 Hazardous Waste On-Line Filing

FREQUENTLY ASKD QUESTIONS (FAQs)

ANSWER

How do we dispose electronic wastes which is not included in the DENR prescribed list.

Make a letter of request and list down all theelectronic wastes that are not included in theprescribed DENR list and submit to DENR Hazwaste div. Provide analysis.

Is their any deadline for online registration of haz waste? Generators ID?

None



Mobile #: 0917-8144751 / 0998-5347850


DAO 2013-22 Hazardous Waste On-Line Filing

ISSUES AND CONCERNS COMMENTS AND SUGGESTION

Difficulty in on-line HW registration due to lack of information campaign or awareness training on the system for the PCOs

Long time to release the online HW ID from the date of online submission

How are we going to characterize e-waste for effective management and handling? (maximize recycling option and proper disposal of hazardous component of e-waste)



Mobile #: 0917-8144751 / 0998-5347850


DAO 2000-18

Permit To Operate



Mobile #: 0917-8144751 / 0998-5347850


DAO 2000-18 Permit To Operate


Particulate Matter ( PM) – is this included in the parameters of air emission?

Yes this must be included in the parameters of air emission testing.



Mobile #: 0917-8144751 / 0998-5347850


DAO 2000-18 Permit to Operate

Issues and Concerns Comments and Suggestion



Mobile #: 0917-8144751 / 0998-5347850


DAO 2005-10

Discharge Permit



Mobile #: 0917-8144751 / 0998-5347850


DAO 2015-10 Discharge Permit


ANSWER

Is it compulsory for a firm interconnected to the centralized treatment facility of LISP to apply for a Discharge Permit Exemption?

No. LLDA Memorandum Circular No. 03, Series of 2008 states that “those individual locators which are interconnected to operational CWTF and those locators with no industrial wastewater discharge interconnected to the CSTP are exempted from securing Discharge Permit from the Authority”. Since, LISP can treat both industrial and domestic wastes, all locators of LISP interconnected to their treatment system are exempted from DP. It is not compulsory for the locators to secure for a Discharge Permit Exemption. However, if a locator wants to have a proof of exemption, they can request for DP exemption from LLDA for free.



Mobile #: 0917-8144751 / 0998-5347850




ANSWER

What are requirements in securing Discharge Permit Exemption?

For a locator interconnected to the centralized WTF, the requirements are: a letter requesting for exemption and a proof of interconnection from an industrial park. While for dry process industries, a request letter, short project description and water bills for the past 3 months.

For firms exempted from Discharge Permit (DP), do they still need to submit SMR to LLDA and to have an accredited PCO?

They are no longer required to submit SMR to LLDA and to have an LLDA accredited PCO



Mobile #: 0917-8144751 / 0998-5347850




ANSWER

For firms exempted from DP, are they still subject to LLDA inspection?

Yes. All industries/establishments within LLDA jurisdiction are subject to LLDA inspection to ensure their compliance with environmental rules and regulations. But those exempted, are on the least priority.



Mobile #: 0917-8144751 / 0998-5347850



Issues and Concerns Comments and Suggestion



Mobile #: 0917-8144751 / 0998-5347850


PNP Permitting



Mobile #: 0917-8144751 / 0998-5347850


PNP Permiting


What is the turn-around time for processing of permits and licenses?

24 working days for new application, 3-5 working days for renewal. To recommend photocopying of documents to be due to PNP.

Is an escort required for chemicals of very dilute concentrations? (i.e. <5%, for preservation purposes)

Certain chemicals are now allowed with no escort. MSDS is the basis for the concentrate. If the chemical is part of the mixture, categorization may be streamlined.



Mobile #: 0917-8144751 / 0998-5347850


PNP Permiting


Can escort fee be included in the permit fee? If this is intended for honorarium, shouldn’t it be charged under PNP’s OPEX?

Fees vary according to site location and escort period. You pay to the office and not to the police escort. TR is issued. Fee is P2,500 within MM, and P15,000 outside MM. Option to fetch escort.

Are guidelines available for the processing of permits? Is it possible to collaborate with other agencies to streamline the process?

Process flow is posted outside of the office.Right now system can not support a separate web site for a specific office.



Mobile #: 0917-8144751 / 0998-5347850


PNP Permiting


How can the processing time be shortened?

If permit is allowed not to pass through the Director’s office, we can cut 35 signatories.

What is the magazine’s maximum capacity? Can we store different chemicals in one magazine?

This is your warehouse’s maximum storage capacity. There will be an MC for a separate magazine for chemical and mining industry. Storage is the outlook of the Safety officer.



Mobile #: 0917-8144751 / 0998-5347850


PNP Permiting


Why is NaCl, a table salt, included in the list?

NaCl is identified in locally-manufactured explosives. Local manufacturers are the one regulated, they will be treated as purchaser.

Nitric acid reacts violently with metal, need to revise guidelines on magazine material?

Already part of guidelines drafted. PCO/SO to submit standard criteria for storage.

What is the acceptable unit of measure?

Liter or kg is acceptable. Must be specified in the request.



Mobile #: 0917-8144751 / 0998-5347850


PNP Permiting


As per the guidelines before, only chemists are allowed to be the chemical custodian, are there any changes?

Not necessarily chemist, as long as appointed/recognized by company

Is there a process for extension for lapse permits?

No extension. Get permit during time of usage considering 60 days permit validity.

Can another person process application apart from the PCO?

Yes. Include all possible authorized representative in the BOD Resolution. Also indicate/identify all possible transactions with PNP.

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