STOP DENR!Save our Practice!

STOP DENR!Save our Practice!

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Concerned Dentist of the Philippines started this petition to Senators and

Sign our petition to elevate our concern to a national level official regarding the investigation and cessation of implementation of DENR hazardous permit requirement for Dental Clinics. We , concerned private dental practitioners , ask for clarification regarding the confusion that has ensued in the recent implementation from certain DENR groups with regards to “Department Administrative Order DAO 92-29 of the DENR AO 36 series of 2004” and the “DAO 2003-30”. We understand that DAO set the guidelines for the issuance of permits to various industrial, commercial, trade establishments which produce hazardous waste. The intent of the DAO is noble, as hazardous waste disposal should be monitored. And because these are hazardous, these must be handled with registered “transporters” of hazardous waste. This is designed for and especially true for large industries, factories and hospitals which produce large amounts of hazardous wastes. However, it seems that our dental clinics were singled out as we have been bombarded with exorbitant seminar fees, ranging from 5 thousand to 7 thousand, excluding numerous permit and ID fees similar to those of large factories, wet markets, hospitals etc, which produce significantly bigger amounts of hazwaste than us. Also, the definition of hazardous in the DAO 92-29 has no clear measure of volume or weight. For example, a busted lightbulb is an electronic waste, needles and syringes are hazardous wastes. If you are caught disposing of a single lightbulb or a single canister full of needles, you may be liable and a violation will result in a fine of 50,000 pesos! It is the same fine if a large factory violates the same law with tons of waste! There is also word going around that there is a 19,000 peso fine per day for other violations. Please refer to the attached file of the said DAO for the definition of terms and list of fines. The required disposal of hazardous wastes for industries according to the DAO is to first, register the establishment, attend a required PCO (pollution control officer training) (they ask a high fee for this), then there is a need to contract a transporter for the said hazardous waste as it is illegal to transport the waste on your own. We think this is designed for large industrial factories which have large amounts of hazardous waste to dispose of. For the registration alone, the paperworks that need to be done are extremely discouraging if not outrageous. One of which is to provide architectural plans with converted measurements to hectares! There is also a need to submit a quarterly report on the volume of hazardous waste. Our offices hardly make more waste than a regular household. A point of comparison is, hazardous medical waste such as insulin needles, diapers, and sanitary napkins are also common household waste. What if a household has to dispose of a hazardous material such as a single busted light bulb, or any of the aforementioned hazardous wastes? The answer is, if they are to strictly follow the rules, the busted light bulb should be placed in a properly labeled container and disposed through the LGU hazardous waste collection. This is called the CENRO (Community Environmental and Natural Resource Department). Given this simple point of comparison, why is there a need to register small dental clinics and ask for these small businesses to pay separate fees for permits and training where there is an obvious difference in the amounts and the type of hazardous waste between large industries and these small dental clinics. Another point is, is this not a double taxation as we already pay sanitary taxes, and garbage collection taxes to the LGU? The CENRO also offers services to collect these small amounts of hazardous materials. Not to accuse anybody, but we are also suspicious of certain groups and individuals that offer PCO training services for fees up to 7000 pesos or more. What is the basis for selecting the correct PCO training seminar? Some of our colleagues have been duped into attending invalid seminars. This should be free as seminar topics are mostly DAO guidelines which are available online. A simple manual could suffice. Aside from this, we question the exclusive registered “transporters” that collect fees, on top of the aforementioned seminar & permits. Since our hazardous wastes are minimal and hardly noticeable, it does not make any economic sense for us to be paying for additional “transporting” since our LGU have handled them quite efficiently in the past years. Just like everyone else, we are concerned with how we can improve and keep our environment in good condition. We would like to help in any way we can despite the challenge of the covid crises. May we reiterate that this pandemic has affected our income in many ways since many of our patients are hesitant for dental.appointments because of fear of contracting covid and many of us also have reduced our clinic hours for the same reason. We cannot afford to be burdened by additional fees and excessive paperwork. Therefore, in the spirit of impartiality , truthfulness & kindness, we hope for a review of its implementation. If possible, 1. amend the law to include a realistic minimum amount of hazardous waste that needs special permits for disposal in order to free dental clinics from these additional fees and permits, 2. to lessen the paperwork that may lead to clerical errors that may be used as a basis for penalties, 3. and to review the need for expensive seminars as a requirement for the permits.

0 have signed. Let’s get to 2,500!
At 2,500 signatures, this petition is more likely to get picked up by local news!