Technical Guidelines for the

Environmentally Sound
Management (ESM) of
Mercury-Containing Medical
Devices (MCMMDs) in the
Philippines

Myline Macabuhay
Consultant, BAN Toxics
28 September 2021
Introduction
Process
1. Review of international guidelines and best
practices
• Minamata Convention on Mercury (particularly Article
4 and 11)

• Basel Convention on the Control and Transboundary

Movements of Hazardous Wastes and Their Disposal
• Framework for the ESM of Hazardous and Other Wastes
• Technical Guidelines on the ESM of Wastes Consisting of,
Containing, or Contaminated with Mercury
Process
1. Review of international guidelines and best
practices
UNDP - Guidance on the cleanup, temporary or intermediate storage and
transport of mercury waste from healthcare facilities

UNEP - Methodological guide for the undertaking of national inventories of

hazardous wastes within the framework of the Basel Convention
- Mercury: Acting Now!
- Practical sourcebook on mercury waste storage and disposal
- Manual for the implementation of the Basel Convention
- Guidance on BAT and BEP
- Guidelines on the environmentally sound interim storage of
mercury, other than waste mercury
Process
1. Review of international guidelines and best
practices
UNEP - Guide for the development of national legal frameworks to
implement the Basel Convention
- Toolkit for identification and quantification of mercury releases
- Catalogue of technologies and services on mercury waste
management
UNIDO - No time to waste: International expert group meeting on the
sustainable management of mercury waste

WHO - Replacement of mercury thermometers and sphygmomanometers in

healthcare: Technical Guidance
- Procurement process guide
- Safe management of wastes from healthcare activities
Process
1. Review of international guidelines and best
practices on the ESM of mercury
WHO - Developing national strategies for phasing out mercury-containing
thermometers and sphygmomanometers in healthcare, including in the
context of the Minamata Convention on Mercury
- Global model regulatory framework for medical devices, including in
vitro devices (IVDs)
- Strategic planning for implementation of the health-related articles of
the Minamata Convention
- Decommissioning medical devices
- Technical specifications for automated non-invasive blood pressure
measuring devices (BPMDs) with cuff
- Technical specifications for complementary medical equipment to
support COVID-19 management
Process
1. Review of international guidelines and best
practices
BAN - Policy paper on the ESM of mercury and mercury compounds in the
Toxics Philippines

EEB & - Guide and checklist for phasing out mercury-added products under
ZMWG the Minamata Convention on Mercury

HCWH - The global movement for mercury-free healthcare

- Guide for eliminating mercury from healthcare establishments

UM - An investigation of alternatives to mercury-containing products

Lowell - Eliminating mercury in healthcare: A workbook to identify safer
alternatives
Process
1. Review of international guidelines and best
practices
OECD - Guidance manual for the implementation of the OECD
recommendation C(2004)100 on ESM of waste

US EPA - Eliminating mercury in hospitals: Environmental best practices for

health care facilities
Process
2. Review of Philippine policies on the ESM of
mercury and mercury wastes
RA 6969 DAO 1992-29 Lists mercury as a priority chemical; regulates
Toxic DAO 2019-20 mercury, mercury compounds and MAPs
Substances and DAO 2013-22 through a CCO; requires the proper
Hazardous and DMC 2020- management of mercury
Nuclear Wastes 19
Control Act
RA 9003, DAO 2001-34 Focus on municipal wastes and recognizes the
Ecological Solid need to manage “special wastes” which
Waste comprise of household hazardous wastes under
Management the responsibility of LGUs
Act
Process
2. Review of Philippine policies on the ESM of
mercury and mercury wastes
RA 8749, DAO 2000-81 covers mercury emissions from stationary
Philippine Clean sources and no-burn technologies, which can
Air Act cover TSD facilities managing mercury wastes.
The maximum permissible limit of 5 mg Hg/
Ncm

RA 9275, DAO 2005-10 Mercury is part of the secondary parameters

Philippine Clean that need to be monitored as part of EIAs of
Water Act TSD facilities. Depending on the classification
of the impacted water body, values range from
0.001-0.004 mg Hg/L.
Process
2. Review of Philippine policies on the ESM of
mercury and mercury wastes
Presidential DAO 2003-30 Hospitals, healthcare facilities and
Decree 1586, TSD facilities are required to apply for an ECC
Environmental prior to operation.
Impact System

RA 9711, Food Draft circular Thermometers are included in the list of

and Drug Act for the medical devices requiring registration (i.e.,
phaseout of requiring CPR). The impending the draft
MCMMDs circular aims to ban MCMMDs, including
online retail sale
Process
2. Review of Philippine policies on the ESM of
mercury and mercury wastes
DOH AO 2008- Related policies: This is the main legislation
21 - DILG MC 2010-140 which phase out MCMMDs in
- DepEd MC 2010-160 the healthcare setting
- Philhealth benchbook
- DOH DM 2017-0302
- DOH Healthcare waste
management manual
Process
2. Review of Philippine policies on the ESM of
mercury and mercury wastes
JAO 2005-02, --- Provides guidelines for the management of
Policies and biological and hazardous wastes generated
Guidelines on from health care facilities and clarifies the
the Effective and jurisdiction, authority, and responsibilities
Proper between DENR and DOH
Handling,
Collection,
Transport,
Treatment,
Storage and
Disposal of
Healthcare
Wastes
Process
2. Review of Philippine policies on the ESM of
mercury and mercury wastes
NAP for the --- Detail the 5-year implementation plan for the
Phaseout of ESM of mercury-containing products in
MAPs and the accordance with the provisions of the
Management of Minamata and Basel Conventions
the Associated
Mercury-
Containing
Wastes
Technical Guidelines
 ESM of Mercury
Input from primary mercury
Mining to be phased out Raw materials
containing mercury

Elemental mercury

Recovered Production
mercury Mercury added
product Processing
(Collection and
Wastes
transportation)
Permanent Use Elemental
mercury
storage or Elemental mercury,
dust, sludge, ash
specially Storage
engineered Wastes
landfill (Collection and
Recovery transportation)

Stabilised/
Solidified Stabilization/ Storage
waste Solidification

Figure 1. Life Cycle Management of Mercury as recommended by the Basel Convention Technical
Guidelines
Life Cycle Stages & ESM
Elements
Life Cycle Stages Other ESM Elements
1. Waste prevention and - Monitoring
minimization - Financing
2. On-site assessment and - Stakeholders involved
inventory - Public and Workers’ Safety
3. Packaging
4. Labelling
5. Temporary storage
6. Collection
7. Off-site transportation
8. Treatment and disposal
9. Export
Waste Prevention and
Minimization
• “Ensure that the generation of hazardous and other wastes… is
reduced to a minimum” (Art 4 para 2 Basel Convention)
• Can be done through regulatory phaseouts (e.g., EU prohibition
on the sale, use, export, etc. of MCMMDs) or through voluntary
pledges (e.g., AHA and US EPA)
• The Minamata Convention prohibits the manufacture, import
and export of MCMMDs in 2020, which was made possible by
the availability of mercury-free alternatives
 Waste Prevention and
Minimization
• To address address any accuracy/ quality issues of alternatives,
WHO developed “technical specifications” which can serve as
reference in procurement programs

Figure 3. Summary flow chart of standard procurement procedures

Waste Prevention and
Minimization
• Steps for the successful replacement of MCMMDs in healthcare
settings:
1. Involving participatory stakeholders
2. Conducting an inventory
3. Evaluating the feasibility and acceptability of alternatives
4. Identifying vendors and planning the phase out of
MCMMDs and phase in of alternatives
5. Developing a budget and procurement process
6. Developing bid specifications
7. Safely removing or disposing MCMMDs
8. Preparing programs such as staff education
9. Periodically maintaining and calibrating equipment as
needed
Waste Prevention and
Minimization
• In case the generation of hazardous wastes is inevitable, waste
generators must register to the regulatory authority. This can
include other government agencies which function to confiscate
illegal products/ wastes (ESM Framework)
Onsite Assessment and
Inventory
• Inventories are an important tool for identifying, quantifying and
characterizing wastes

• First step is to define the wastes:

• Only wastes consisting of, containing of, or contaminated
with mercury in a quantity above the relevant thresholds
(Art 11 para 2 Minamata Convention)
• New draft of the Basel Convention Technical Guidelines
propose that no thresholds are needed for mercury waste
falling under Art 11 para 2 of the Minamata Convention
Onsite Assessment and
Inventory
Wastes consisting of - Excess mercury from the decommissioning of chlor-
mercury or mercury alkali facilities;
compounds - mercury recovered from:
o wastes containing mercury or mercury compounds
o wastes contaminated with mercury or mercury
compounds
o surplus stock of mercury or mercury compounds
designated as waste.
Wastes containing - Wastes of products containing mercury or mercury
mercury or mercury compounds that easily release mercury into the
compounds environment including when they are broken (e.g. mercury
thermometers, fluorescent lamps);
- Other wastes of mercury-added products (e.g. batteries);
- Wastes containing mercury or mercury compounds that
result from a treatment of mercury.
Wastes contaminated - Residues generated from mining processes, industrial
with mercury or processes or waste treatment processes
mercury compounds
 Packaging
• MCMMDs should be packed in a manner that reduces the
potential for their breakage
STEP 1 STEP 2 STEP 3

Placed in the original Wrapped in a labelled Placed in a labelled

box and sealed with plastic bag as primary secondary container
duct tape container and sealed with duct
tape

Figure 4. Storage of MAPs in San Lazaro Hospital

 Labelling
• Labelling should follow the Globally Harmonized System of
Classification and Labeling of Chemicals

GHS06- GHS06- GHS06-

Acute Toxicity Acute Toxicity Acute Toxicity

Figure 5. GHS hazard pictograms

Temporary storage
• Storage must be located in a secure, restricted area accessible to
authorized persons
• Storage and space design requirements include:
• Suitable for the projected type and volume of wastes;
• Weather and insect-resistant roof and walls;
• Sloping roof to drain water away from site;
• Floor made of smooth material impervious to mercury;
• An accessible and replaceable drain trap to capture mercury in the event of
spill;
• A ventilation system;
• Fire alarm and suppression systems;
• Temperature control (must be cool and dry; below 25oC and 40% relative
humidity);
• Personnel protective equipment (PPE), spill kit and wash areas; and
• Must have warning signs at entrance and exit doors.
Temporary storage
• General procedures to be followed:
• Provision of training to personnel
• Availability of MSDS and international chemical safety cards
• Regular (once a month) inspections
• Proper maintenance of inventory records
• Availability of site-specific procedures such as a workable emergency plan
and identification of an authorized modification of safety procedures when
necessary to allow emergency response personnel to act
Collection
• The Basel Convention Technical Guidelines enumerate the
following issues that need to be considered when establishing/
implementing collection programs:
• Advertise the programs, depot location and collection time periods to all
potential holders of mercury wastes;
• Allow enough time for the operation of collection programs;
• Make acceptable containers and safe-transport materials available to
mercury waste owners;
• Establish simple, low-cost mechanisms for collection
• Ensure the safety of all workers involved in the collection process;
• Ensure that programs and facilities meet all applicable legislative
requirements; and
• Ensure the separation of mercury wastes from other waste streams.
Collection
• Examples of collection schemes:
1. Waste collections stations or drop off depots
2. Collection at public places (e.g., town halls or other public buildings)
3. Coordinated collection (e.g., Tokyo Medical Association in Japan)
4. Prepaid shipping service

• In the Philippines, healthcare facilities are required, as waste

generators, to facilitate collection by contacting waste
transporters and TSD facilities.
Off-Site Transportation
• Mercury wastes should be transported in an environmentally
sound manner to avoid accidental spills. The following guidelines
should be considered when transporting mercury wastes:
• Transporters should be certified (permit/ license);
• Must provide proof of liability insurance of guarantee bond, emergency
preparedness and emergency response plan, contingency plans
• Personnel involved in transporting wastes must be qualified and certified
and must have undergone training on:
• Legal obligations;
• Planning, routing, handling, visual inspection, packaging, labelling,
loading/unloading, securing, placarding, manifest or consignment
forms;
• Occupational safety, hazard recognition, hazard mitigation (including
ways to minimize the possibility and the consequences of accidents);
• Use of PPE; and
• Spill response planning, use of spill kits, emergency procedures, and
accident reporting.
Off-Site Transportation
• A specially registered vehicle used to transport mercury
waste must have the following:
• A size suitable for the load to be transported;
• A bulkhead between the driver’s cabin and the body to retain the load in
case of vehicle collision;
• A secure system to load/ unload the wastes;
• Empty air-tight containers, plastic bags, PPE, spill kits, cleaning
equipment and decontaminating agents;
• Markings with the names and address of the waste transporter;
• Warning signs and placards displayed in the body of the vehicle, including
the registration number.
Off-Site Transportation
• Regulatory authority may opt to specify the maximum amount
above which a registered transporter is required (e.g., US EPA
regulations 40 CFR 261.5 and regulations 49 CFR 173.164)

• DENR MC 2020-19 also allows small quantity generators to

form a cluster so that their consolidated volume can be collected
by a EMB-registered transporter
 Storage at Storage Depot
• End-of-life MAPs from different sources can be collected and
transported to a centralized facility
• May occupy a central position for countries wishing to export
mercury wastes for disposal due to the lack of necessary
infrastructure

Figure 6. Photo of off-site storage facility of DUL Willkommen in der Umwelt

Storage at Storage Depot
• The following guidelines must be considered:
• Located at least 150 meters away from densely populated
areas, agricultural operations, bodies of water and other
environmentally sensitive areas; must not be located in areas
prone to disasters
• In a secure, restricted location to prevent theft, but must be
readily accessible to trucks and other vehicles
• Suitable for the projected type and volume of mercury waste
region/s being served
• Constructed to withstand or ameliorate the effects of natural
disasters
• Have four distinct and separate areas: (1) receiving area; (2)
inspection area; (3) storage area; and (4) administrative and
record-keeping area.
Storage at Storage Depot
• The following general procedures must be considered:
• Compliance to licensing and registration requirements;
• Periodic reporting on safety issues, storage conditions and
monitoring data
• Establishment of a hazardous waste management plan,
which includes procedures for:
• Receiving waste and internal transport;
• Waste inspection, re-labeling and repackaging;
• Supplementary containment and storage;
• Facility inspection and general cleaning (housekeeping);
• Spill control and cleanup;
• Emergency procedures;
• Worker safety (including hazard identification, hazard mitigation,
proper use of PPE, ergonomic techniques for handling waste, and
medical surveillance);
• Reporting and record-keeping; and
• Health surveillance or medical monitoring.
 Treatment and Disposal
Code Recovery Operations Code Disposal Operations
R4 Recycling/ reclamation of metals D5 Specially-engineered landfill
and met
R5 Recycling/ reclamation of other D9 Physico-chemical treatment
inorganic materials
R7 Recovery of components used for D12 Permanent storage
pollution abatement
R8 Recovery of component from D13 Blending or mixing prior to
catalysts submission to D5, D9, D12, D14
or D15
R12 Exchange of wastes for D14 Repackaging prior to submission
submission to operations R4, R5, to D5, D9, D12, D13 or D15
R8 or R13
R13 Accumulation of material D15 Storage pending any of the
intended for operations R4, R5, operations D5, D9, D12, D13 or
R8 or R12 D14
Treatment and Disposal
• Criteria for choosing among the disposal and recovery options:
1. Technological considerations
2. Legal framework
3. Public health and environmental concerns
4. Social and political acceptability
5. Financial implications
Recovery options
• Mercury wastes containing mercury or mercury compounds are
treated in dedicated facilities to extract and purify the mercury
contained in the waste for re-use or disposal operations
• Steps: (1) pre-treatment, (2) thermal treatment, (3) purification
• The Minamata Convention calls for Parties to control emissions
and releases of mercury; can be done through BAT/ BEP. For
example:
• Establishing a mass balance
• Enclosed system under negative pressure
• Any exhausted air emitted in the recovery process must pass through a
series of particulate filters and a carbon bed that absorbs the mercury
before the air is released to the environment
• Isolation of mercury in wastewater through physico-chemical treatment
• Continuous monitoring
 Recovery options

Figure 7. Process flow for the dismantling mercury sphygmomanometers at

Nomura Kohsan Co., Ltd., Japan
 Recovery options

Figure 8. Process flow for the mercury recovery system at Nomura Kohsan Co.,
Ltd., Japan
Encapsulation
• When the extracted
mercury is bound for final
disposal, they should be
treated to meet the
acceptance criteria of
disposal facilities
• Existing technologies
include:
1. Stabilization – e.g.,
conversion of mercury into
mercury sulfide (chemical)
2. Solidification – encapsulate
the waste to form a solid
material (physical) Figure 9. Process flow for the stabilization system
3. Stabilization and for mercury at Nomura Kohsan Co., Ltd., Japan
solidification (e.g., SPSS)
Encapsulation
• It is suggested to evaluate physico-chemical treatment
methods in pilot-scale tests before commercial use,
including the:
• Quality of the stabilization process by determining the
conversion rate and the mercury vapor release from the
stabilized waste;
• Leaching potential over a range of plausible disposal
conditions (especially over a range of pH values); and
• Plausible changes to the treated waste in the long-term due
to exposure to the environment and biological activity at
disposal sites.
 Disposal
1. Specially engineered landfills – waste is stored aboveground
or near the surface below ground.

Figure 10. A schematic diagram of a SEL

Disposal
1. Specially engineered landfills – guidelines to consider
include:
• Waste eligibility criteria - leachate limit values (e.g., <0.025 mg/L
mercury by TCLP testing in the US)
• Duration
• Site selection – can be based on geographical, geological and
hydrogeological properties, future use of the area, degree of urbanization,
etc.
• Safety requirements – must have a permit system; thorough EIA; have
control and oversight procedures, etc.
 Disposal
2. Permanent storage in underground facilities – potential host
rocks can include salt rock, clay formations and hard rock
formations

Figure 11. Placement of bags and drum containers in the Herfra Neurode salt mine
Disposal
2. Permanent storage in underground facilities – guidelines to
consider include:
• layout of storage facilities;
• types of containments used;
• storage location and conditions;
• monitoring;
• site access conditions;
• storage closure strategy;
• sealing and backfilling, and
• depth of storage.
Export
• A critical option for countries that do not have necessary
infrastructure or have a small volume of waste
• Must be in line with the provisions of the Minamata Convention
(Art 11 para 3) and Basel Convention
• Written documents required to facilitate transboundary
movement include:
• notification for all concerned countries (import, export, transit), which will
include the declarations and information requested in the Convention
• prior written consent from all concerned countries (import, export,
transit)
• insurance, bonds or guarantees
• confirmation of the existence of a contract specifying ESM of the wastes
between exported and the owner of the disposal facilities
Export
• Process flow:
• The State of export shall notify in writing the all concerned States of
any transboundary movement of mercury waste.
• The State of import shall respond in writing consenting or denying
permission of or requesting additional information on the movement.
• Transboundary movement will commence if:
• The notifier has received the written consent of the State of
import; AND
• The notifier has received from the State of import confirmation of
the existence of contract between the exporter and the disposal
facility specifying the ESM of the waste in question.
• Each State of transit which is a Party shall promptly acknowledge the
notifier receipt of notification, and may respond in writing, within 60
days. The State of export shall not proceed allow the movement until
receipt of the written consent from the State/s of transit.
Export
Company Location Description of Services
BATREC Wimmis, Extracted mercury from thermometers will be:
Industrie Switzerland 1. Stabilized as HgS for permanent storage in Germany
AG 2. Recovered with a purity >99.99% for recycling in
accordance with the Minamata Convention
Ecocycle Victoria, Distillation of mercury for recycling
Pty Ltd Australia
Ecologic Panama Final disposal via concrete encapsulation
SA City, Long-term storage of mercury and mercury compounds
Panama for future processing
Nomura Tokyo, Production of HgS using mechanochemical reaction,
Kohsan Japan (head which is then disposed in a leachate-controlled SEL
Co, Ltd office)
Remondis Dosten, Accepts metallic mercury for stabilization to HgsS,
QR Germany which is sent to German salt mines for long-term
storage
 Monitoring
• It is important to establish a
traceability chain to ensure that
mercury is not diverted to
illegitimate uses
• Must start from the waste
generator → transporter →
storage → recovery/ disposal
facility
• Follow required information at
the entrance and exit of each
delivery
• Philippine manifest system
(D407 wastes)

Figure 12. Traceability chain

Financing
• Article 13 of the Minamata Convention establishes a financial
mechanism with 2 components:
1. The Global Environment Facility (GEF) Trust Fund; and
2. A Specific International Programme (SIP) to support
capacity- building and technical assistance.

• The Convention also calls on Parties to provide, within its

capabilities resources for national activities that are intended to
implement its obligations, including national budgets and costs
borne by the private sector (para 1)

• The existing Philippine framework puts the burden of cost for

the ESM of MCMMDs on the waste generators.
Stakeholders Involved
Governments - Develop and enforce national policy;
- Provide incentives to foster the development of infrastructure
- Put in place measures to ensure due diligence and proper
management of wastes
- Be transparent and require transparency to the public
- Establish effective consultation mechanisms or partnerships
with key stakeholders
Waste - Responsible for integrating BAT and BEP when undertaking
generators activities that generate wastes
Waste - Should have a license/ permit to carry out the transport of
carriers/ wastes, ensuring that these are adequately packed, handled, and
transporters documented properly
Waste - Should, at the minimum, meet all basic requirements to ensure
management ESM of wastes. They should also commit to continual
facilities improvement in their operations, evolving as new BAT and BEP
are established
Public and Workers’ Safety
Public health - Include programs which prevent and minimize exposure by
and safety establishing mercury limitations from commercial and industrial
sources
- Pay particular attention to protecting populations that are
more sensitive to the effects of mercury wastes
Workers Worker health and safety measures include:
safety - Provision of employee training
- Use respirators with mercury filters and PPE
- Take urine samples from workers on a continuous basis
- A regular intake of selenium may protect against mercury
exposure
- Health, safety and emergency plans in place based on risk
assessment
- Emergency planning
- Ambient mercury monitoring (8-hour average and STEL)
Gaps and Actions
 Gaps and Actions
Area of International Philippine guidelines Identified gaps
analysis guidelines and actions
Waste Prohibits the Phaseout of 1. Finalization and
prevention manufacture, import MCMMDs in approval of draft
and and export of healthcare facilities FDA circular and
minimization MCMMDs starting (DOH AO 2008-21); DENR-DTI policy
2020 CCO on mercury to phase out retail
specified phaseout sale of MCMMDs
Promotion of schedule of MAPs by
alternatives 2022; alternatives 2. Assistance to
promoted (e.g., BOC/ FDA
Registration of waste CDRRHR policy for registration as
generators (including thermometers and waste generators
government agencies) sphygmomanometers)
3. Actions to
encourage
compliance
 Gaps and Actions
Area of International Philippine guidelines Identified gaps
analysis guidelines and actions
Inventories Definition and MCMMDs are 1. Amend DAO
categories of mercury considered hazardous 2013-22 to adopt
wastes waste and classified definition and
under D407. It does categories of
Methodologies for not distinguish mercury waste
conducting inventory between mercury
wastes

Inventory activities
done in 2008 and 2019
following the UNEP
toolkit
 Gaps and Actions
Area of International Philippine guidelines Identified gaps
analysis guidelines and actions
Packaging Best practices Compliance to GHS Compliance
and labeling Compliance to GHS and UN
and UN Recommendations on
Recommendations on the transport of
the transport of dangerous goods
dangerous goods
Handling, Best practices Healthcare facilities Programmatic
separation Schemes for waste are required, as waste approach to
and collection generators, to facilitate facilitate one-time
collection disposal collection of
MCMMDs
 Gaps and Actions
Area of International Philippine guidelines Identified gaps
analysis guidelines and actions
Storage Best practices Best practices Compliance
(temporary Technical guidelines Technical guidelines
and at depot) (DOH AO 2008-21,
DAO 2013-22)
Off-site Technical guidelines Technical guidelines Compliance.
Transportati (e.g., DAO 2013-22) Programmatic
on approach to
facilitate one-time
transportation of
MCMMDs (DENR
MC 2020-19)
Disposal Technical guidelines Evaluation of TSD No facility that can
for recovery and technologies are part process MCMMDs
disposal operations, of the ECC
including treatment application
technologies
 Gaps and Actions
Area of International Philippine guidelines Identified gaps
analysis guidelines and actions
Export Technical guidelines Technical guidelines No action
(e.g., DAO 2013-22)
Monitoring Technical guidelines Technical guidelines Streamlining of
for traceability chain for a manifest system manifest system
(e.g., DAO 2013-22) based on definition/
categories of waste
Financial GEF and SIP Cost for ESM is borne If one-time
resources National budget, by generators collection of
private sources MCMMDs will be
NAP identified budget done, explore
requirements for external sources
Convention activities
 Gaps and Actions
Area of International Philippine guidelines Identified gaps
analysis guidelines and actions
Stakeholders Government Government No further action
involved Waste generators, Waste generators,
carriers, management carriers, management
facilities facilities
NGOs and other NGOs and other
stakeholders stakeholders
Public and Best practices Best practices No further action
worker Technical guidelines Technical guidelines
safety
 Thank You!

mdmacabuhay@gmail.com

Sources/ references can be found in the draft paper (September version;

final)