A memorandum by the Environmental Management Bureau of the Department of Environment and Natural Resources allowing the incineration for all CoViD-related healthcare wastes violates the law, undercuts safer and cheaper options, and poses a threat to public health and the environment.
The memo, which purports to ensure continuity of operations in public health and safety, will only make the situation worse.
Issued by OIC Engr. William Cuñado, the memo directs all EMB regional directors to use thermal treatment by incineration as a mode of disposal, with total disregard for Sec. 20 of RA 8749 or the Philippine Clean Air Act which bans incineration.
Disinfection through chlorination and sterilization using an autoclave or hydroclave are all in the Department of Health Healthcare Waste Management Manual (2004) that hospitals have been using. The 2012 version of the manual also includes microwave treatment, disinfection by hydrogen peroxide, and methods of encapsulation and burial — which are not even listed in the EMB memo.
The only thing new in the memo is permitting incineration and the use of crematoria.
It appears that the EMB memo intends to bypass the Clean Air Act by allowing a process which emits poisonous and toxic fumes, while introducing the use of crematoria for healthcare waste disposal.
Despite its high transmissibility and case fatality rate, the virus responsible for CoViD-19 is easily-destroyed by decontamination. The coronavirus belongs to a group of viruses called ‘enveloped viruses’ that are among the most sensitive to chemicals and heat. It is readily- inactivated by such disinfectants as 0.1 percent sodium hypochlorite (the active ingredient in Zonrox, Winrox, and other bleach products), 70 percent ethyl alcohol, 50 percent isopropyl alcohol, and 0.5 percent hydrogen peroxide. The World Health Organization recommends these and other disinfectants for clinical laboratory waste.
The WHO also recommends disinfecting CoViD-contaminated linen in a diluted bleach solution of 0.05 percent hypochlorite for 30 minutes. The DOH Manual calls for the decontamination of infectious waste by 5 percent hypochlorite, a safe concentration since it is 10 times higher than what is needed to inactivate the CoViD.
Coronaviruses are also easily destroyed by simple soap and water, because of the nature of enveloped viruses. Soap molecules act as chisels that break open these ‘enveloped viruses’ and trap their fragments in structures called micelles that are formed by soap. The WHO, DOH, and other health agencies keep emphasizing washing hands with soap for 20 seconds and rinsing with water as a simple but effective method to stop the transmission of the CoViD-19 virus.
Studies have also found that other coronaviruses are destroyed by hot water at only 56°C (133°F) for about 45 minutes. It is likely that the CoViD-19 will also be destroyed at 56°C, the temperature of hot water setting of many commercial washing machines.
The WHO adds a safety factor by recommending washing contaminated clothes, beddings, and towels used by CoViD patients in hot water with detergent at 60-90°C. Boiling in water would destroy the virus even faster.
Microwave units used for infectious waste require enough water to produce steam, and operate around 100ºC to achieve high levels of disinfection in about 30 minutes. Autoclaves, which are basically pressure cookers operating at temperatures between 121-134ºC, reach sterilization levels (used to sterilize surgical instruments), and are far more than adequate to handle CoViD-19 wastes.
Since coronaviruses can be destroyed at temperatures even below the boiling point of 100°C, incinerating infectious wastes at 850 to 1200°C is overkill, and completely unnecessary, especially since cheaper methods are readily available on-site.
Opposing incineration goes beyond the legal requirement, and has everything to do with health.
Much of healthcare wastes are single-use materials such as disposable gloves, gowns, face masks, and IV bags — which are mostly plastics made from fossil fuels. When burned, they release toxic substances, including respirable fine particles, heavy metals, carbon monoxide, and acid gases, all of which adversely impact the respiratory system.
CoViD-19 is a severe acute respiratory disease that will be exacerbated by respiratory pollutants. Many of the pollutants from incinerators are also known to suppress the immune system. Thus, creating air pollutants by incinerating infectious wastes will further compromise CoViD-19 patients in healthcare facilities and communities.
The Clean Air Act prohibits the burning or incineration of medical wastes in part because it creates the most toxic chemicals known to science, dioxins, and furans, which remain in the environment for decades to hundreds of years.
Dioxins and furans are linked to various types of cancers, reproductive disorders, birth defects, endocrine disruption, suppression of the immune system, and other health problems.
The Philippines does not have the capacity to continuously monitor incinerator emissions of dioxins and furans. This means it is unlikely that emission limits for dioxins and furans will be enforced even without a pandemic.
Large amounts of dioxins and furans are also found in incinerator ash. This is why the ash must be safely transported and disposed of in hazardous waste landfills, according to the Stockholm Convention for Persistent Organic Pollutants, to which the Philippines is a party.
The guidelines of the Convention even recommend catalytic treatment of ash, solidification prior to landfilling, or use of double-walled containers.
Since the Philippines does not even have enough hazardous waste landfills, toxic incinerator ash will probably end up in dumpsites or rivers.
The EMB’s role should not be to negate the protection of public health and the environment by undermining the Clean Air Act and the DOH Healthcare Waste Management Manual. What hospitals and other healthcare facilities can do is to ensure compliance with the DOH Manual and where possible, strengthen their waste management systems.
Rigorous waste segregation and proper handling, storage, and transport of healthcare waste should be strictly followed. The CoViD-19 pandemic should not be an excuse to return to outdated and polluting disposal methods like burning and incineration. The continued use of safe and environmentally-sound treatment methods is more protective of public health.
Merci Ferrer
[email protected]
Convener, War-on-Waste/Break-free from Plastic-Negros Oriental
Manager, Zero-Waste Cities Project-Dumaguete