85andbelow's blog

No one can be this stupid so you have to consider if they spend most of their time in government offices planning ways to screw things up and make things nearly impossible, perhaps to "create jobs" for fixers and consultants.

Point in case, we have an employee that has been working on getting her NSO since June of 2015.   Born as a twin with a sister, only one birth certificate was made showing a single birth, so it has been impossible to get a NSO for this 30 year old woman.  Beyond financial possibility to hire a lawyer for these poor people but a late registration was possible, literally creating a new identity out of thin air by changing their name and getting some locals to vouch that they were born with that name.

So nearly two years later she has the NSO and it is time to get her a TIN number.  Google "Philippines TIN number application" and you find articles with the link to the eReg, the online BIR registration website.   Easy sailing, right?

Nope, your browser won't open the website, despite using the recommended Firefox browser.  That's right, most of the official websites make you use a particular browser in order for them to work and it isn't usually the most recent version of that browser.  The problem is that the SSL certificate is using an obsolete encryption process that leaves your connection and their server open to attack because the "encryption" is easily cracked and read.   Here is the error message you will get:

An error occurred during a connection to SSL received a weak ephemeral Diffie-Hellman key in Server Key Exchange handshake message. (Error code: ssl_error_weak_server_ephemeral_dh_key)

So at this point you can't access this part of the BIR website to even learn about how to register an employee TIN number.   You can access the self employed version of filing for a TIN but not the most common TIN registration process.  After trying four browsers, none of which can access the page past the error message you start researching the error message and find this fix, albeit a dangerous one as you are disabling browser security:

Open up a new tab, and type in about:config in the address bar, accept the risk warning to proceed.  You will find a list of features, in the search box above the list type in or past security.ssl3.dhe_rsa_aes_128_sha, wait for the system to find that particular item and double click on it turning the seting from "true" to "false" Search  again for this item and double click on it too:  security.ssl3.dhe_rsa_aes_256_sha

Now go back and reload the page you couldn't access, in the same browser but a different tab.  It should now work.

All that to access a single part of the BIR website, no warnings that you might have problems accessing or how to get around it.   Now if you are registering as an employer on something like Philhealth you might get a five page document emailed to you explaining the hoops you have to jump through to thread your way into their system, Philhealth set up took me the better part of an hour to set up the bypasses required by their antiquated online system.  And they are encrypting nothing critical, employee wage data, old filing and report info, not credit card numbers or banking access info.  And even better news?  You get to do it again in a year as you have to re-register annually.

Now once you are finally inside the BIR eReg you find out that no, an employee cannot file their own TIN application!   First time this has ever been told despite a dozen online articles on doing this process telling you how easy it is and how anyone can register their own TIN.  So you register for an employer account with BIR for this particular process, adding it to the other bakers dozen of employer accounts with BIR, all with different web addresses, user names and passwords.  Not one central BIR account that can access everything, hell no, that would make sense.

Simple shit like warning you that there are password requirements, over eight characters in this case, are missing from the page.   The only way is to try and try again till you get a password accepted and no it doesn't say why the system failed to accept the password.

So the solution to an idiot filling out a birth certificate thirty years ago?  Just change one of the twin's names and change her identity.  Imagine what this would do if this person wanted to go to college, no school records would match.  Imagine the danger if a terrorist could simply change their identity to bypass terror watch lists.

Welcome to doing business in the Philippines.

My God, I gave this imbecile the benefit of the doubt when he was first elected but this latest blunder pretty much removes any reason to think Duterte is fit to run a country.


I mean the chi coms have massively disrespected this fool and no one in the Philippines has had the sense to remove this guy from office?

This dumb fuck said he would spend "double the money" for new equipment?  Hell the U.S. is giving the fucking retard this equipment, double what money?

Some bitching about missile systems taken out of some of the old patrol boats but this land of 85 and below IQ citizens couldn't keep modern systems operating and would probably sink more U.S. ships than Chinese ships if they ever had to use the damned missile systems.Duterte to refuse refurbished arms

This might be old news to some but as I just started getting involved in the Philippines in late 2012 and didn't visit till early 2013 I either missed the eruption or wasn't interested enough to follow it.

It seems a Canadian comedian made a joke about that time on a British TV show that caused a firestorm of condemnation from the Filipinos.  The show has two teams of comedians competing, doing some ad lib stuff, and the subject for the ad lib was "Things that a Cosmetic Company will Never Say" or something to that effect.  Now the title alone is a clue to take any answer given with a sense of humor IF you have the cranial capacity to understand irony.

So the woman, Kathrine Ryan, said something to the effect of "We never use animals for our product testing.  We use Filipino children instead."

Twitter war erupts, death threats against the woman, her family, even her very young daughter ensue.  And whether it is a joke or one of life's ironies the woman's sister was said to have been engaged to a Filipino and they visited the Philippines and got some rough treatment.

Old or not, I just found it while watching one of her specials on Netflix and thought it was both hilarious and a teaching moment for those new to the Philippines ore thinking of visiting.


I'd been lurking since the new site was put up, too busy to do anything other than read but after coming back from a one week trip to the shit hole I needed to blow off some steam and hopefully warn others that might be thinking about opening up a business in the Philippines if you are of the white persuasion. The trip was needed because Phil Post had delayed delivering a signed contract that was needed for a PEZA renewal, four days to get from the East Coast of the U.S. To Manila, sixteen days to get from Manila to the Subic area. Below when I talk about the things that can and will go wrong this is the kind of crap that normal people from normal countries never worry about.

Now keep in mind that I know little of everything that is needed and that as the years go by things always turn out more complicated than I had initially thought.  I don't think anyone understands the totality of what is facing foreign businessmen that are crazy enough to try to build a business here much less build a factory.

In an earlier story I stated that I had read that the average Philippines PEZA locator deals with 156 separate licenses or permits to open the average foreign owned business and this story talks about the 162 permits and 102 licenses required to open an electrical generating plant so I suppose one shouldn't complain. Then this story relates that it takes eight months to get the approval done for a cell phone tower site which needs 25 separate permits to construct the foundations, install the tower, and wire the damned thing. So I wasn't exaggerating on the complexity and cost of complying with Filipino rules and regulations if you have a white skin.

Now as you read down through this process keep in mind that the simplest thing can go horribly wrong in the Philippines. Perhaps you need to submit a report from the local BIR, one signed by all eight department heads stating that you have zero problems with the BIR, all taxes paid, all reports filed. But when you file the report with the national BIR office as required by the permit process requirements you find that the report is rejected due to missing payments and tax returns, all of which were accounted for before the local BIR department heads signed off on your report. You see, the local BIR and national BIR haven't had a working data link in over a year so the records are out of sync but the local BIR didn't bother to tell you this before you drove to Manila to file the needed report. It might take you three months to get Certified True Copies of all the missing payment receipts and filings, if the local BIR can even find the original documents and no, those Certified True Copies that you obtained right after you file the original tax reports and payments will not be accepted by either BIR office. You need new ones as you are suspected of being a tax cheat by the national BIR at this point.

Here is an example of what an office building and parking lot had to deal with when constructing inside an existing industrial park. And this is only one of the permits and licenses. Every single one of those dozens of other permits and licenses is going to be nearly as complex and time consuming to obtain. And Filipinos love acronyms that you will have to research to understand the terminology used,

First they applied for a EIA, Environmental Impact Assessment. That is a report written by experts hired by the building owner that attempts to predict anything that might go wrong and cause an environmental impact of any sort. The EMB gets to evaluate and approve or disprove the plan. They are evaluating water discharges, an noise that might be created by the business, pesticides, herbicides, and potential accidental release of chemicals. Then the indirect impacts such as farm land loss, erosion, turbidity of any local waters, silt in any local water reservoir, any potential damage to fish and wildlife, oxygen levels, nutrient loss, or nutrients in any run off water.

The company will set up a series of funds for EMB, Environmental Revolving fund, Review Support Fund, Environmental Monitoring Fund, and Environmental Guarantee Fund. The amount of money deposited by the building owner into these funds depends upon the size of the project but they are large, very large, as this is literally a lifetime endowment of money to provide constant monitoring of this land and building from that day forward in time.

Keep in mind that there will be dozens of requirements and documents similar to those needed for the Permit to Operate. The process is so long that you are given five years as the maximum time to acquire everything.

Then once you have this EIA program approved and all of the bank accounts funded you have provided a road map for the IEEC, Initial Environment Evaluation Checklist Report. You want to build a house, a pond, set up a piggery or chicken house, food manufacturing building, small factory, a road or bridge or any of dozens of items, you need the IEEC before you get to the ECC which is the next step in the environmental permit process. The list of requirements will be much the same as for the Permit to Operate, a collection of other government documents, reports from experts, detailed description of how and what will be done in the project, along with pictures or drawings and maps of the completed project. Every single possible use for that building or land must be added to the permit application, additional uses are not allowed unless the permit process is repeated for any changes in use. The project cannot be expanded either without going through the entire process again.

So you have your ECC now, next the company had to construct an IEC program that educates all contractors, workers, and local residents on the environmental and safety plans for the project, a program that never ends and is renewed on an annual basis. That's right, this report will be filed in perpetuity and anyone that buys the building will report the purchase to DENR EMB and remain compliant. Again you have a list of requirements including some of the same documents that you provided several times already.

Create a SDP, a Comprehensive Social Development Program for the area and report every six months through a CRM, Compliance Monitoring Report, another unending report. Ditto on the requirements, more of the same documents as you provided in previous submissions.

If any trees are cut a tree cutting permit must be secured from DENR CENRO or each tree must be transplanted in an earth ball to another location approved by CENRO. The requirements for such a permit are a letter asking for the permit, duly notarized and signed by top officials of the owner of the project, letters of endorsement or no objection from the local LGU and barangay, a copy of the land title, photographs of the trees to be removed or transplanted, a Site Development plan drawn by a draftsman to their specifications, and of course the separate ECC for the cutting or transplanting.

The STCP, Special Tree Cutting Permit, must be approved by the DENR central office, not by the local DENR. Certifications must be submitted to any LGU or barangay that has jurisdiction where hearings and public consultations will be held. Before cutting or transplanting trees a separate ECC, Environmental Compliance Certificate must be procured for the tree transplanting or cutting, in addition to the ECC for building the building or piggery or small factory. The trees must be assessed for biodiversity, carbon sequestration potential, water storage capacity, and identify mitigation measures to fix any negative impact of the removal of the trees. Of course any LGU or barangay can object and cancel the transplanting or tree cutting project. Once the permit is approved a billboard is installed to inform the public of the removal along with how many trees are affected.

During the removal or cutting the local DENR CENRO (Community Environment and Natural Resources) group and the local LGUs have to supervise the operation and any wood gets turned over to DENR for disposal. As this operation is covered by a separate ECC there will be thousands of indigenous seedlings that will be planted and maintained for three years with an 80% survival rate required prior to the cutting of the trees. If the trees are transplanted the permit owner must maintain the transplanted trees for three years. Should one of the trees fail to survive the permit owner has to plant one hundred trees for every transplanted tree that dies in the three year period.

Draconian? Ya think? Here is the actual flow chart for one of the STCP permits:

Issue Order/Instruction to conduct inventory/inspection and forward to Chief, FMS CENRO, Assign Inspecting Officer to conduct inventory/inspection Chief, FMS, Prepare Order of Payment CENRO Cashier, Sign Order of Payment CENRO, Receive Order of Payment, Release Order of Payment Clerk, Pay inventory fee for planted and naturally growing trees but no payment required for less than 20 trees or if inventory will be used, Accept payment and issue Official Receipt CENRO Cashier, Official Receipt conducted by the customer, Conduct 100% inventory or inspection of the area and prepare Inspection Report with geo-tagged photos to be submitted to Chief, FMS, except those with Certificate of Tree Plantation Ownership (CTPO) (Inspection requires three personal), If Inventory undertaken by customer: Plant 1,200 Php /hectare Inventory Fee (100% inventory), Timber Inventory/Inspection Report with Tally Sheet/Stand and Stock Table, and Pictures, Tree Charting Map, Review Inspection Report and submit recommendation to CENRO Chief, FMS, Review and approve Inspection Report and sign endorsement to PENRO and CENRO, PENRO Level, Receive documents and forward to Chief, FMS Receiving Clerk, Review and evaluate and endorse to PENRO Chief, FMS, Review and approve CENRO recommendation and sign endorsement to RD PENRO, Regional Level, Receive documents and forward to ARD for Technical Services Receiving Clerk, Forward to Chief, FRCD for review and evaluation ARD for Technical Services, Review documents and prepare endorsement to ARD for Technical Services Chief, FRCD, Review and sign endorsement to the RD ARD for Technical Services, Review and approve endorsement to Forest Management Bureau indicating that copy to be furnished to the USEC for Field Operations RD, Release endorsement to FMB, copy furnished USEC for Field Operations Records Section, Regional Office, Central Office Level, Receive and forward documents to Director, FMB Records Unit Chief, Review and assign to NFMD Division Chief FMB Director, Review and assign to Section Chief NFMD Division Chief, Review and assign to Action Man/Forest Management Specialist Section Chief, Review, evaluate and conduct data analysis and prepare Memorandum Endorsement to USEC for Field Operations with draft clearance to RD to issue tree cutting permit and forward to Section Chief Action Man/Forest Management Specialist, Review and forward to Division Chief Section Chief, Review and forward to Assistant Director Division Chief, Review and forward to Director Assistant Director, Review and sign Memorandum Endorsement to USEC for Staff Bureaus Director, Release to USEC for Staff Bureaus Records Unit, FMB, Receive and forward to USEC for Staff Bureaus Receiving Clerk, Review and forward to USEC for Field Operations USEC for Staff Bureaus, Receive and forward to Chief of Staff for ASEC for Field Operations Receiving Clerk, Refer to Technical Staff for review and processing Chief of Staff, Review documents and prepare and initial Memorandum with attached Clearance to Issue Permit to Cut and forward to Chief of Staff Technical Staff, Review and initial Memorandum and Clearance, to Issue Permit to Cut and forward to ASEC for Field Operations Chief of Staff, Review and sign Memorandum and initial Clearance to Issue Permit to Cut and forward to USEC for Field Operations ASEC for Field Operations, Review and approve/sign Clearance to Issue Permit to Cut USEC for Field Operations, Release Clearance to Issue Permit to Cut to Records, FMB Releasing Clerk, USEC for Field Operations, Receive Clearance to Issue Permit to Cut and transmit to Regional Office concerned Records Unit, FMB, Regional Level, Receive Clearance to Issue Permit to Cut and forward to RD Records Section, Regional Office, Assign to ARD for Technical Services for preparation of Tree Cutting Permit RD, Assign to Forest Resources Conservation Division ARD for Technical Services, Prepare Tree Cutting Permit and forward to RD for approval ARD for Technical Services, Sign Tree Cutting Permit RD, Release Tree Cutting Permit to Customer copy furnished CENRO concerned Records Section, Regional Office.

The company must establish a reforestation and carbon sink program using indigenous species to mitigate the greenhouse gas emissions of the project. This particular project required establishing a tree nursery that would produce 4,735 new trees and done six months before the project actually starts, going through EMB RO. A CENRO Certification must be made and submitted to prove that the tree production has been done and handed off to EMB.

A MRF, Material Recovery Facility has to be established on the property, basically a composting facility along with separate recyclable material areas for things like electronic waste, batteries, hazardous wastes, busted light bulbs, paper, plastics, metals, and basically trash. A zero waste management scheme must be adopted to limit the amount of garbage going through the local government unit's landfill.

Next is to create EU, an Environmental Unit within the company that is charged with handling all environmental issues. This is separate from the required EMP/EMoP plan. The EU is charged with monitoring the actual impacts versus the predicted impacts and report on the management measures to comply with the IEEC and to revise the EMP/EMoP after submitting those revisions to the EMB RO. Ensure that the data gathered during the monitoring are documented, assessed, evaluated, and reported to the EMB in standard formats and to ensure that the monitoring and submission of reports to EMB are done.

Before a project starts billboards must be erected stating the name of the project and the ECC, Environmental Compliance Certificate, with a billboard at each entrance and exit of the project. A copy of the ECC certificate must be posted at the barangay hall, with a separate report and pictures of the posting submitted to EMB for the barangay posting and the individual billboards.

The ECC certificate has to be furnished to national DENR, PENRO, the local DENR, CENRO, and all local governments in the area.

A WTF, (how appropriate) Waste Water Treatment Facility must be set up with zero discharge and any wastewater must be reused or recycled including a cistern tank for rainwater to prevent any storm water run off from flowing onto roads or canals. The rain collected must be used for toilet flushing or watering plants.

Now, keep in mind the number of processes and permits outlined above with each one almost as detailed as the earlier Permit to Operate article or the STCP permit for cutting trees. An estimated 130 billion pesos a year are wasted on the cost of applying for all of this crap or the lost business due to the time frame required to comply with all of this crap.

Are you beginning to understand why there are so few jobs in the Philippines and the incredible amount of paperwork and cost for a simple project? Churning paper, making jobs for bureaucrats, engineers, accountants, experts of all sorts, but fewer jobs for the working class and middle class.



In the U.S. there are plenty of regulation especially on the West Coast but generally you are going to find the most troublesome regulations enforced only when the company is large enough to pay the huge fines for non compliance.  As an example OSHA is rarely seen in shops employing a few dozen workers, the state version of OSHA generally will harrass those shops and OSHA will work over the big shops.  Even then the largest fines and most common gotcha's are paperwork related, not shop hazards.

But in da felippines this is reversed with shops over 100 workers being able to self inspect and set their own "safety" programs while the smaller shops are harassed by DENR and DOLE, the Department of Envirnoment and Natural Resources, and the Department of Labor and Employment.   However they do share one aspect with the U.S., they tend to target the shops that can pay the fines and have the ability to conform with their voluminous and idiotic paperwork and permitting process. 

There is a modicum of commonsense at least at the legislature as they passed a law that exempts small shops of less than 21 tons of output per year from the environmental legislation.     Basically if you aren't using hazardous chemicals, are below 21 tons of finished product per year, and aren't in an environmentally vulnerable area you get the Certificate of Non Compliance if you apply for it.   Yet the DENR simply ignores the quite plain command to exempt small producers from "All" DENR requirements if they pass the fairly simple online interview process.   If you show them a copy of the legislation and your completed exemption certificate they say "But sir, there are six laws that we operate under.  This exempts you from only one."  Which is not true but bucking the system is guaranteed to get you shut down.

The result is that it will cost you several thousand dollars per year if you wish to install and operate the simplest of equipment such as woodworking saws, spray booths, or other fume producing machinery such as a large grinder or a welding booth.  Or a generator if used in your business.

First is the application process for the PCO or Pollution Control Officer.  Who needs a PCO?  Any business that uses hazardous chemicals or wastes, even batteries in a flashlight, flourescent tube lights, or ink for a small printer.  Who do you have to hire for the position?   A dedicated employee, a college graduate in most cases unless you can fit one of the exemptions, that watches over the facility to prevent pollution and to fill out the quarterly reports and of course makes sure you have legal recycling storage areas.  Now with other DOLE programs you can hire a company to do this for you but PCOs can only do one company, not multiple companies.

You send the applicant to a four day school operated by someone's brother in law and fork over 10,000 pesos plus another 5,000 pesos for their room and board.  The penalties for a PCO screwing up are enormous so the online job board for the Philippines are full of ads for PCO candidates because no one in their right mind would volunteer for the position.  If you went to one of the schools you would see mostly executives and a few peons taking the course if the peons can be coerced into it.

The PCO application lists a page of hazardous chemicals, the bad stuff that probably does need regulation in the land of 85 average IQ.  Then the glues, adhesive (scotch tape anyone?), paint, printer ink, and yes, miscellaneous waste AKA trash.  This includes food waste and broken light bulbs.   You will report the amount of water you purchase from the water company, list all the machines in the business along with the wattage and fuel type, and all of the various items in the business that might contain chemicals including glue, ink, or other sort of safe, stable, everyday use products.  Don't forget the notarized letter authorizing the PCO candidate, you never know when someone might just sneak into one of those schools and apply for your company I guess.  About two months later you will receive the PCO accreditation, after many trips down to the local DENR EMB to see if they have completed the process.  No, they won't call or email you when it is done.

Next is the "Permit to Operate".   This will take you about four months to get in our experience despite the stated time frame on their website as demanded by Filipino law.  The application is three pages, kind of materials you use, list the machines that produce any sort of particulate, fume, or dust such as a drill press, grinder, paper drill, sander, or spindle.  Those are called APSI, Air Pollution Source Installation.  Doesn't matter if the drill press dust and chips fall to the floor, you have to have a dust collector, called an APCF, an Air Pollution Control Facility.

Next is a series of eleven different documents:

1)Engineer’s Report prepared by the Pollution Control Officer and approved by the President/General Manager with at least containing the following:
  • Company profile

  • Amount of raw materials and finished products

  • Material balance

  • Process flow diagram indicating all sources of air emission or possible air emission

  • Brief description of process.

  • List of APSI and corresponding air pollution control facility (APCF) with complete specifications

  • Discussion of each APSI & APCF showing the process/mode of operation, design criteria & efficiencies of the APCF, the quantities & types of pollutants in the final emissions.

  • Discussion of mitigating measures undertaken if APSI is not provided with APCF

  • Pollution loading of the regulated air pollutants in tons/year.

2)  Drawing requirements in 50cm x 90 cm paper signed by the President/General Manager and duly signed by PME/ChE or any from the two.

  • Vicinity Map;

  • Plant & Machinery Layout showing the connection of the APSI to APCF;

  • Plan & elevation drawings of each APSI & APCF.

  • Sectional drawings of the APCF.

3)Copy of the Certificate of Accreditation of the Pollution Control Officer, or appointment/designation as such by the Managing Head.

4)    Environmental Compliance Certificate (ECC) or Certificate of Non-Coverage (CNC) copy.

5)      Source Emission Test Requirement (if required).

6)     Copy of Recent “Permit to Operate” issued by the Office.

7)      Copy of Discharge Permit, if applicable.

8)     Copy of Hazardous Waste Generator Registration ID, if applicable.

9)    Copy of SEC Registration Certificate & Articles of Incorporation.

10)    Copy of DTI Registration Certificate

11)     Proof of compliance to permit conditions.

Now look at the #1  and #2requirements.  You are going to hire an engineer and a draftsman to produce the drawings and report.  Doesn't matter that they say the plant owner and PCO can make the report.   The details are going to largely be written by you and rubber stamped by the hired engineer including the "testing" results.   Your butt is going to Manila to find both professionals and to pick up the finished drawings and reports.  This is going to cost you around 50K in all.

#3, you have already paid around 20K to get this done and waited six weeks as you can't start any of the paperwork with the PCO being certified.

#4, that certificate that says you aren't really required to do any of this.  But it does exempt you from ANOTHER round of environmental certificates and processes that are damned expensive and troublesome including posting a bond to clean up the area should you ever shut down and payments to any locals that might be impacted by you opening up a small factory, you know, increased competition for housing or a few more trucks on the road.

#5, source emission testing, for anything that produces fumes, dust, particulate, or odors.  Generator, wood planer, paper drill, spray booth, grinder.... hire an expert and get the bullshit readings properly stamped and sealed.  Cheap for a generator, a trip to Manila for the others where you basically pay some guy with a degree to lie about what the results of the testing were.

6),   well good luck with that  as you don't have one yet.

7),  the dreaded discharge permit.  No, you aren't pumping chemical sludge into Manila Bay, you are flushing a toilet.  Get ready to prove you have sewage treatment and enjoy getting the water/sewer company to give you a letter showing compliance and no your water/sewer bill won't do.  Yes, you are in a long established industrial park.  Just shut up and get to work.

8), another process not quite as expensive and time consuming as this one.  Done online where you pay a fee and provide much of the same information to the same agency.

9), head to the nearest regional SEC for a recent Certified True Copy of your SEC certificate, bylaws, and throw in the GIS too.  Photo copies won't do, need the stamps, seals, and pay for the privilege.  Why in the hell do they need this?  Are they in charge of ensuring SEC regulations?

10), DTI registration, same shit, different day.   You don't have it because you are a corporation or partnership, so a bullshit affidavit that is notarized will get you past the monkey in charge.

11), proof of compliance to permit conditions.  How in the hell do you prove compliance to something that you are applying for?  You can't, notarized affidavit to the rescue, then next time you get to re submit  all the quarterly reports and annual reports from the last year.

Now six to eight weeks later it might be done and it might not.   Drive the  100 kilometers to the nearest DENR EMB office and inquire if they have seen fit to finish the process.  No need to email or call, ass in the seat and drive down to ask in person.   In our case we got it in April after filing it in October.  Of course they completed it in November and just now saw fit to give it to us.   Meanwhile the PEZA organization that forced us to go through the process had long since given us a certificate of accomplishment for completing most of the process as they knew how long it  would take to get an actual permit.  What really mattered was the brother in law packing in over 400 people into a "school" that raked in 10 to 15K per attendee plus the week's wages and travel costs for the 400 people who get to do it again in less than three years.

And yeah, you do all this again the very next year.   Got it in April, it expires in November, due to renew in October, six months from now.   Your Source Sampling testing must be done within three months of the renewal date, you fill out the quarterly and annual reports, make sure you have a wind direction device installed on your facility so the neighboring communities can easily see it, make sure your PCO records the wind direction each week and  puts that info in the 18 page SMR, Self Monitoring Report that is due each quarter.  You submit photos of the recyclable storage areas with separate spaces for recyclables, electronic wastes, BFLs (flourescent lamps), batteries, and special wastes.  Pictures of your backyard composting facility along with proof that the compost was disposed of by a licensed sanitary landfill along with the contract that covers your waste disposal, along with a copy of the Certificate of Disposal from your local waste hauler, accredited sanitary landfill, and waste water treatment company.

All because you wanted to take raw materials, paper, wood, steel, and cardboard and turn them into consumer products inside a decades old industrial park.   Along the way expect to be scammed, lied to, and subjected to a constant barrage for bribes to facilitate the process.

And this is just one of the nearly 150 permits, processes, or licenses needed to operate in the Philippines if you want to keep your white skin from getting you in trouble.  Plan on having one dedicated person, an accountant on retainer, and a healthy list of engineers, draftsmen, and other professionals.   You as the business owner or major stockholder will spend dozens of hours each month dealing with the crap even if you don't live in the Philippines.  Hire someone knowledgeable to do it all?  Dream on in the land of 85 average IQ.

Its certainly more fun in the Philippines.


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