Getting the permit is half the work. Keeping it means telling EMB, on schedule, how your facility performed: the Self-Monitoring Report every quarter, and for projects with an ECC, the Compliance Monitoring Report every six months. This article explains what each report covers, who signs it, when it is due, and the mistakes that turn a routine filing into a notice of violation.
Two reports, two laws
- The Self-Monitoring Report (SMR) reports compliance with the environmental standards under each law that applies to your facility: RA 9275 for water, RA 8749 for air, RA 6969 for chemicals and hazardous waste, RA 9003 for solid waste. It is filed quarterly.
- The Compliance Monitoring Report (CMR) reports compliance with the conditions of your ECC and the commitments in your Environmental Management Plan under PD 1586 and DAO 2003-30. It is filed semi-annually.
The two are linked: the Revised Procedural Manual for DAO 2003-30 provides that the semi-annual CMR is submitted as Module 5 of the second and fourth quarter SMRs.
The Self-Monitoring Report: legal basis and frequency
What the rules require.
- DAO 2003-27 established the SMR system and its modular format, and requires the report to be submitted quarterly, within 15 calendar days after the end of each quarter, signed by the accredited PCO and the owner or managing head and notarized. Permits and ECCs issued by EMB Region XII repeat the 15-day wording in their conditions; check your own document.
- DAO 2014-02 Section 12 requires all accredited PCOs to submit the SMR to the EMB Regional Office quarterly. ISO 14001-certified companies may apply to the EMB Central Office for semi-annual submission, and establishments in the Industrial EcoWatch and Philippine Environmental Partnership Programs may avail of reporting incentives.
- DAO 2000-81 Rule XIX Section 14 requires the owner or PCO to keep operational data and control test records for permitted air sources and furnish them to EMB quarterly.
- DAO 2013-22 requires registered hazardous waste generators to submit online the hazardous waste management portion of the SMR, with the type and quantity of waste generated and transported off-site. Its Table 3.2 sets the generator's own reporting frequency by category: quarterly for large, semi-annual for medium and annual for small quantity generators.
- DAO 1992-29, the RA 6969 rules, Section 26 requires generators to report the type and quantity of hazardous waste quarterly.
How. Submission is through EMB's online reporting system, with the acknowledgment or received copy retained as proof. Confirm the current portal and procedure with EMB Region XII.
What goes into each SMR module
The SMR is modular. Each establishment fills in the modules that apply to it; confirm the current module list and form version on the EMB online system before filing:
- General information: company profile, PCO and managing head, permits held with numbers and expiry dates, production and operating data for the quarter, raw materials and water use.
- Chemicals and hazardous waste (RA 6969): Priority Chemical List chemicals used or stored; hazardous waste generated by type and quantity, stored on site, and transported off-site, with manifest numbers, transporter and TSD facility, and Certificates of Treatment.
- Air (RA 8749): each permitted source with operating hours, fuel type and consumption, control device operation and maintenance, stack test results or emission estimates against the standards, and breakdowns.
- Water (RA 9275): wastewater generated and discharged in m³/day, treatment facility operation, chemical dosing and sludge disposal, laboratory results for the parameters in your Discharge Permit against DAO 2016-08 Table 9 as amended by DAO 2021-19, and exceedances with corrective action.
- Solid waste (RA 9003): quantities generated, segregated, recycled, composted and disposed, and the disposal facility used.
- ECC compliance (Module 5): the CMR, in the second and fourth quarter SMRs, for projects with an ECC.
Laboratory reports, manifests, Certificates of Treatment, calibration records and photographs are attached as supporting documents.
The Compliance Monitoring Report: legal basis and frequency
What the rules require.
- DAO 2003-30 Section 9.2 requires the proponent to conduct regular self-monitoring of the parameters in the EMP through its environmental unit and to submit a semi-annual monitoring report within January and July of each year.
- The Revised Procedural Manual standardizes this as the semi-annual ECC Compliance Monitoring Report (Annex 3-1), submitted by the proponent's environmental unit or environmental officer to the designated monitoring EMB office. The first CMR is due mid-year after the start of project implementation, and the proponent must notify EMB of the start-up date. Your ECC conditions state the exact wording that applies to you.
- For Category A projects, DAO 2003-30 Section 9.1 requires a Multipartite Monitoring Team (MMT), funded by an Environmental Monitoring Fund, which submits its own semi-annual monitoring report. The manual's Compliance Monitoring and Validation Report attaches the proponent's CMR and SMR.
What goes into the CMR
The manual requires the CMR to report performance at three levels, at the minimum:
- Performance against the ECC conditions, condition by condition, with status and evidence.
- Performance against the Environmental Management Plan: each mitigation and enhancement measure, whether implemented, and the results.
- Performance against actual impacts: monitoring of actual impacts, including residual impacts, compared with the impacts predicted in the EIA report, in relation to current operations.
The second CMR of each year must include a simple trend analysis of the environmental standards and a summary of cumulative annual and historical performance: for example, total areas replanted, local jobs generated, population covered by information campaigns, exceedances of standards and violations.
Signatures, notarization and filing
DAO 2014-02 Section 10 requires CMRs and SMRs to be accomplished and signed by the PCO, approved and certified correct by the managing head, and notarized. The same section requires the PCO to report breakdowns, releases and exceedances to EMB in writing within 24 hours; the SMR is not the place to disclose them for the first time. The Annex 4 incident report notes that corrective actions, repair costs and completion dates are reported in the next SMR.
Keep the received copy or the online acknowledgment for every submission. Establishments with a pending case must also submit a copy of the SMR, duly received by EMB, to the Pollution Adjudication Board (Section 10, item 16).
Common mistakes
- Filing the SMR late, or not at all, during quarters when "nothing happened". A quarter with no discharge is still reported.
- Reporting laboratory results from a laboratory without DENR recognition, or for the wrong parameters; DAO 2016-08 Table 8 lists the significant parameters per sector.
- Discharge volumes that do not match the Discharge Permit or the water bills.
- Hazardous waste quantities that do not reconcile: generated minus transported minus stored should balance, and every transport needs a manifest and a Certificate of Treatment.
- Forgetting Module 5 in the second and fourth quarter, so the CMR is never filed.
- CMRs that restate the ECC conditions without evidence: photographs, receipts, laboratory reports and MMT minutes are what evaluators look for.
- Signed by the PCO but not certified by the managing head, or not notarized.
- Expired PCO accreditation, which EMB notices on the first page. See what the PCO role involves.
Region XII examples
- Tuna cannery, General Santos City: quarterly SMR with water and air modules, effluent sampling for temperature, pH, BOD, TSS, nitrate and oil and grease (the PSIC 1020 list), boiler stack results, hazardous waste manifests for used oil and laboratory chemicals, and Module 5 twice a year against its ECC.
- Beach resort, Glan, Sarangani: quarterly SMR with the water module for its sewage treatment plant (BOD, fecal coliform, ammonia, nitrate, phosphate, oil and grease, surfactants) and the air module for standby gensets; CMR against an IEE Checklist-based ECC.
- Subdivision with a communal treatment facility, Koronadal City: SMR water module reporting flow and Class C compliance for discharge toward the Marbel River; CMR reporting drainage, tree-planting and community commitments in the ECC.
- Limestone quarry and cement plant, Sarangani or South Cotabato: an Environmentally Critical Project with an MMT, so its CMR feeds the MMT's validation report as well.
How EnviSoul helps
EnviSoul in General Santos City prepares the technical documents your PCO's reports rest on: Discharge Permit and Permit to Operate applications, ECC documentation, Engineer's Reports, CAD drawings of treatment and control facilities, and GIS maps of monitoring stations and outfalls.
Within an agreed scope we also provide reporting support: a data-request checklist and tracker so the right records reach the report on time, preparation support for the quarterly Self-Monitoring Report from the data and monitoring results you supply, preparation support for the semi-annual Compliance Monitoring Report against your ECC conditions and commitments, organisation of the supporting records, and coordination of the online submission where you authorise the access. Your establishment remains the reporting party: the PCO and management approve the data before anything is filed, and EMB decides whether a report is accepted. When permit conditions, laboratory results and operating data no longer agree, we help you reconcile them before the next filing. See our services or the Discharge Permit guide, or send us your permits and last report: consultant@envisoul.com, +63 950 191 8850, or the form at envisoul.com/#contact.
FAQ
How often is the SMR submitted?
Quarterly, under DAO 2003-27 and DAO 2014-02 Section 12, within 15 calendar days after the end of each quarter. ISO 14001-certified companies may apply to the EMB Central Office for semi-annual submission.
How often is the CMR submitted?
Semi-annually. DAO 2003-30 Section 9.2 requires the report within January and July each year, and the Revised Procedural Manual places it as Module 5 of the second and fourth quarter SMRs. Your ECC conditions give the wording that applies to your project.
Who signs the SMR and CMR?
The accredited PCO signs, the managing head approves and certifies correct, and the report is notarized (DAO 2014-02 Section 10).
Do I still file an SMR if I have no ECC?
Yes, if you hold a Discharge Permit, Permit to Operate or hazardous waste registration, or otherwise have an accredited PCO. The CMR module applies only to projects with an ECC.
What if my laboratory results exceed the standard?
Report the exceedance to EMB in writing within 24 hours of receiving the results (DAO 2014-02 Section 10, item 15), state the cause and interim measures, and report the corrective action in the next SMR. Do not wait for the quarterly report.
Sources
- DENR Administrative Order No. 2003-27, Self-Monitoring Report System — DENR
- DENR Administrative Order No. 2014-02, Revised Guidelines for Pollution Control Officer Accreditation — DENR
- DENR Administrative Order No. 2003-30, Implementing Rules and Regulations for the Philippine EIS System — DENR
- Revised Procedural Manual for DAO 2003-30 — DENR-EMB
- DENR Administrative Order No. 2000-81, Implementing Rules and Regulations of RA 8749 — DENR
- DENR Administrative Order No. 2013-22, Revised Procedures and Standards for the Management of Hazardous Wastes — DENR
- DENR Administrative Order No. 1992-29, Implementing Rules and Regulations of RA 6969 — DENR
- DENR Administrative Order No. 2016-08, Water Quality Guidelines and General Effluent Standards of 2016 — DENR
Disclaimer
This article is general information for business owners in the Philippines, not legal advice. Requirements, fees and processing times vary by project category, location, EMB regional office and technical review; confirm the current rules with EMB Region XII or the applicable issuance before relying on them. EnviSoul prepares and coordinates applications; approval decisions are made by DENR-EMB.