POSITION PAPER: On the proposed House Bill 2286; an Act Repealing the “PHILIPPINE CLEAN AIR ACT OF 1999” and Amend Pertinent Provisions of Republic Act 9003, Otherwise Known as the Solid Waste Management Act of 2000

20 September 2017



Committee on Ecology

House of Representatives


Dear Honorable Suansing,

Health Care Without Harm Asia is an international environmental health group that is working to promote ecologically sustainable health care practices in order to protect environmental and public health.

We thank you for giving us the opportunity to participate in today's public hearing regarding the proposed House Bill No. 2286, “AN ACT REPEALING SECTION 20 REPUBLIC ACT 8749, OTHERWISE KNOWN AS THE “PHILIPPINE CLEAN AIR ACT OF 1999” AND AMEND PERTINENT PROVISIONS OF REPUBLIC ACT 9003, OTHERWISE KNOWN AS THE SOLID WASTE MANAGEMENT ACT OF 2000.

As an organization that works directly with the health sector in order to protect the environment and people’s health, we are deeply concerned about the health and environmental hazards of bringing back incineration technologies, including waste-to-energy facilities, in dealing with municipal wastes, which include medical and infectious wastes. We have been working with the health care industry in the region for more than 12 years and have seen hospitals successfully transition from incineration technologies to safer alternative waste treatments systems. We believe resurrecting incineration in the guise of waste-to-energy technology will undermine the progress we have made in advocating sustainable waste management measures.

We reiterate therefore our earlier position to oppose any form of incineration including that of medical waste.  Below please find for your consideration the following comments on HB 2286:

  1. There are viable non-burn, environmentally–friendly technologies that can treat waste without resorting to burning or incineration, or WTE.

The World Health Organization (WHO) estimates that of the total waste generated by health care facilities, only 15 to 25 % can be considered infectious. This estimate is supported by locally generated data in the Philippines. In a health care waste assessment conducted by Health Care Without Harm among Baguio City hospitals in 2008-2009, it was found that 25 % of the wastes generated were infectious. With better segregation and more careful classification of waste generated, the proportion of infectious waste can further be brought down.

Among currently available technologies that can be used to treat bio-medical waste, the more popular are autoclave and microwave technologies. These technologies, especially autoclave, are currently being utilized in the Philippines. Autoclave technology has the advantage that hospital personnel are already familiar about how its mechanics as it is regularly used for sterilization of surgical instruments.

  1. The burning or incineration of bio-medical or infectious medical waste produces as by- products, among other emissions, highly toxic dioxins and furans.

Because of the danger of transmission of diseases and infection, most devices in health care facilities are necessarily single-use and disposable. Health care facilities, therefore, heavily rely on the use of polyvinyl chloride (PVC) plastics, which when burned or incinerated produce dioxins and furans.

Exposure to dioxins and furans is harmful because they are, for one, powerfully carcinogenic. They are also known to lead to the impairment of the immune system, the impairment of the development of the nervous system, the endocrine system and the reproductive functions.

Instead of pushing for dirty energy technologies, including WTE, that will negatively affect Filipinos’ health, we should be promoting the transition to viable, clean, and healthy energy options such as renewables.

  1. Republic Act No. 8749 or the Philippine Clean Air Act of 1999 promulgates emission standards that will be very hard for medical waste incinerators to meet, including WTE technology.

Rule XXVIII, Section 3, of the Implementing Rules and Regulations of the Philippine Clean Air Act of 1999 established emission standards (daily average values and half-hourly average values) for pollutants generated by non-burn technologies. If these same standards were to be applied to medical waste incinerators, it would be very costly to operate them. In order to meet them, sophisticated pollution control equipment is required. And even with the presence of such sophisticated pollution control equipment, meeting the standards set by the Philippine Clean Air Act is not guaranteed.

Given these, we believe the bill is a huge step backwards from our common goal of protecting Filipinos’ wellbeing.




Executive Director

Health Care Without Harm Asia