With permission from Dr. Jorge Emmanuel, we are publishing his statement during the Philippine House of Representatives Committee on Ecology’s meeting on Caloocan Representative Edgar Erice’s House Bill 3161, which proposes to lift the ban on incineration to burn municipal, bio-medical, and hazardous waste.
Health Care Without Harm Asia is one of the groups in the Philippines strongly opposing the passage of this bill, which greatly neglects the environment and public health.
Statement of Dr. Jorge Emmanuel to the House Committee on Ecology, Philippine House of Representatives, 9 June 2015
Mr. Chair and honorable members of the House of Representatives, I thank you for the opportunity to present my expert testimony regarding the proposed Erice bill.
By way of introduction, I am here as a private citizen not representing any organization and not receiving funds from any organization to present at this hearing. From 2003 to May 2015, I was the chief technical advisor of the United Nations Development Program on global healthcare waste projects involving 17 countries. Before that, I was a consultant to the World Health Organization, World Bank, Swiss Red Cross, USAID, US National Institutes of Health, and other organizations, providing assistance to about 40 countries on incineration, non-incineration technologies, and waste management. I am presently the President of the Environmental & Engineering Research Group in California. I hold degrees and certificates in chemistry from North Carolina State University, environmental management from the University of California-Berkeley, public health from the University of Iowa, renewable energy technologies from Stanford University, and a PhD in chemical engineering from the University of Michigan, with additional training in environmental engineering from Rensselaer Polytechnic Institute and infection control from APIC.
I respectfully oppose the Erice bill for the following reasons:
1 – The Erice bill is a serious step backwards from the standpoint of the protection of public health.
Incinerators produce the most toxic compound known in science, namely, 2,3,7,8-tetrachloro-dibenzo-p-dioxin and other similar compounds which I will simply call “dioxins.” Dioxins are toxic at very low levels and are known to cause cancers (specifically chronic lymphocytic leukemia, soft tissue sarcoma, non-Hodgkin’s lymphoma, prostate cancer, as well as cancers of the lungs, larynx and trachea). They also cause birth defects, alter the reproductive systems of fetuses, impact the IQ of children, suppress the immune system, decrease fertility, cause ovarian dysfunction, and reduce the sizes of male genitalia. They are highly persistent in the environment, so any dioxins produced today will remain for up to 150 years if on top of the soil, more than 500 years if in bodies of water, and up to 1000 years if the dioxins are covered by a few centimeters of soil surface.
The Philippines is a party to the Stockholm Convention on Persistent Organic Pollutants. Under this treaty, the Philippines is obligated to reduce and, where feasible, eliminate releases of dioxins to the environment.
Studies presented to the House Committee on Ecology that may underestimate the health effects of dioxins are problematic. I speak in particular on the cost-benefit studies of so-called Clean Incineration, reviewed and presumably approved by DENR/EMB and DOH. A health risk assessment by the World Health Organization published the very same year shows a more appropriate method of estimation of health risk. The so-called Clean Incineration study conducted an inhalation exposure assessment while admitting that inhalation was only a small fraction of total exposure, so they used 1997 data from the EPA to estimate total dioxin exposures. The WHO study showed a more appropriate method which was to use relative ingestion intake rates and compare them to relative body burdens for dioxins. The WHO study, which was global, gave much more pessimistic results on the health impacts of incinerators than the Clean Incineration study and led to the WHO Policy in 2004 calling for the shift to non-incineration technologies.
I should add that there is no such thing as “clean incineration.” All incinerators release toxic particulates, carbon monoxide, hydrogen chloride, toxic metals, etc. in addition to dioxins and greenhouse gas CO2. Air pollution control devices are needed to limit the releases to the air, but most of these pollution control devices such as filters and electrostatic precipitators merely move the pollutants from one environmental medium (the air) into another (solid filters or wastewater). The toxic pollutants do not disappear; they are concentrated into other media that have to be treated as hazardous waste. Importantly, ash from incinerators is toxic, heavily contaminated with dioxins and leachable metals, and under the Stockholm Convention BAT/BEP guidelines, ash requires special land disposal as hazardous waste. Often, these added costs are not included in economic analyses but they should be.
The dioxin limits continue to be revised as new data come out. The current Philippine limit is 0.1 ng I-TEQ/Nm3 which remains the international standard, but a few years ago the US EPA lowered its dioxin limits even further to 0.0099 to 0.027 ng TEQ/m3. This suggests that in coming years, the internationally acceptable dioxin limit will go down further as new data compel us to promulgate more stringent limits to protect public health from a pollutant that will remain in our environment for hundreds of years.
Is DENR/EMB prepared to enforce an even stricter dioxin limit in the future?
2 – The second reason I oppose the Erice bill is because DENR/EMB may not be able to enforce the current dioxin limit, much less a more stringent dioxin limit to protect public health in the future.
The Philippines does not have the technical in-country capacity to analyze for dioxins from incinerators. In the 1990s, the US limited the number of approved US laboratories capable of testing for dioxins under the Contracts Lab Program since it is a very difficult test to conduct. There are no labs in DENR/EMB, DOST or DOH that can analyze for dioxins. Samples have to be sent to the US, Japan or other countries to undergo these expensive tests.
Many industrialized countries require testing for dioxin emissions every 6 months or every year. Some countries conduct frequent spot checks of dioxin emissions, since high levels of dioxins are formed during transient conditions in incinerators waste-to-energy plants and many manufacturers submit dioxin results under ideal conditions. Spot tests are how many incinerator facilities in the US and elsewhere have been shut down or heavily penalized for violations.
Given that the Philippines does not have the in-country capability to conduct regular testing for dioxins of incinerators, much less frequent independent spot checks by regulatory bodies, I fear that Philippine dioxin limits may just be limits in paper and not in reality thereby threatening public health.
3 – The third reason for my opposition to the Erice bill has to do with costs.
In 2012, I wrote a book entitled “Compendium of Technologies for the Treatment and Destruction of Healthcare Waste” published by the United Nations Environment Program. For the research, I signed non-disclosure agreements with companies and obtained their actual capital and operating costs. The results are published in a series of graphs in Chapter 11 of my book. They show comparisons of incinerators that really meet the international dioxin standard (not just as claimed by the manufacturer—because many make that claim but are not able to prove it—but as shown by actual test results and by their ability to meet the Stockholm Convention BAT/BEP guidelines’ secondary measures) compared to non-incineration technologies. For the same throughput rate (capacity), the costs of the high tech incinerators meeting dioxin limits are two to three times higher than non-incineration technologies, with operating costs are as much as 20 times higher than non-incineration technologies.
In the late 1980s, when I began work on incineration, there were more than 6,000 medical waste incinerators in the United States; today there are about 30 or less in the whole country. When I was part of the advisory group on the US regulation for medical waste incineration, one of my contributions to the EPA was a computer program that projected the costs of incineration versus non-incineration. My calculations then showed that non-incineration would be cheaper. History has proven me right – the drastic decline in medical waste incinerators from 6000+ to 30 was driven primarily by economics as facilities realized that non-incineration technologies were cheaper to purchase, install, and operate.
4 – The fourth reason I opposed the Erice bill is because it is a move away from environmentally sound best practices of segregation, waste minimization, and environmental protection.
By their very nature, incinerators are technologies that need waste as an input to operate. Therefore, they encourage generation of more waste in order for the operators to make a profit. There are case studies worldwide that have shown that when communities decide to reduce waste, increase recycling, improve composting, etc., incinerators and waste-to-energy plants end up losing money and have to shut down.
Bringing back incinerators will do the opposite – discourage less segregation and produce more waste so that incinerator operators can make more profits. Moreover, investing in incineration and waste-to-energy plants commit communities to these dirtier technologies for the long term, commitments that require communities to generate more waste for incinerators to operate profitably. We should be moving in the opposite direction: encouraging less consumption of materials, greater demand side management, minimization of waste, and more protection of the environment and public health.
5 – Finally, I want to mention the issue of Ebola which has been used as an excuse to bring back incineration. I spent late October 2014 until April 2015 as chief technical advisor of the United Nations Development Program’s Global Ebola Response project. Because of complaints about incinerators from WHO and local communities, I was sent by the UN to West Africa to install non-incineration technologies to replace the incinerators. The new non-incineration technologies kill the Ebola virus in a matter of seconds. Seeing the operation of incinerators and non-incineration technologies side by side, the Ebola Command Center officials of Liberia now want to replace all their incinerators with non-incineration technologies. Sierra Leone has developed a plan to do the same nationwide. I received an email this morning from Guinea wanting to install more non-incineration technologies. So why bring back incineration under the fear of Ebola? The African countries affected by Ebola are doing the exact opposite, having seen the adverse environmental and health impacts and costs of the imported incinerators compared to the environmental and public health benefits of the non-incineration technologies.
In summary, the Erice bill is a grave step backwards, from the standpoint of environmental protection, public health, and cost. Incinerators generate highly toxic pollutants that will remain in our environment for hundreds of years and cause cancers, developmental and reproductive disorders. The country does not have in-house technical capacity and hence lacks the ability to enforce existing dioxin limits. The capital and operating costs of non-incineration technologies are lower and do not commit communities to long-term generation of waste to feed the treatment systems. Instead, more effort and funding need to go to improving segregation, recycling, source reduction, reuse, composting, and waste minimization, and the promotion of truly cleaner technologies.