Pollutant Release and Transfer Registers (PRTRs) and Toxic Release Inventory (TRI) are names of chemicals control schemes, which are quite similar to each other but are given different names depending on the country of implementation. Both names depict a public registry system that collects and disseminates information on transfer and release into the environment of pollutant and toxic chemicals. In 1992, the United Nations deemed that environmental and health protection from industrial pollution would be achieved if there would be a “list of pollutants emitted by different types of sources.” Later, a global strategic plan was formulated, requiring all industrialized countries to set up a “PRTR (Pollutant Release and Transfer Registers)” regulation including such developing countries as Thailand.

 

Pilot project of PRTR in Thailand

In 2011, Pollution Control Department, the Department of Industrial Works (DIW) and Industrial Estate Authority of Thailand, with help from Japanese International Cooperation Agency (JICA) launched a 4-year cooperation project to set up PRTR system and a related regulation structure model suitable for Thailand. Important elements of the project include:

    1. formulation of the basic design of PRTR system,
    2. development of a reporting scheme for industrial sources,
    3. estimation of pollution the amounts of release/transfer from point sources including making manual for estimation of pollution discharged from point sources,
    4. estimation of the amounts of pollution release/transfer from non-point sources, including data gathering for estimation and making manual for pollution estimation from non-point sources,
    5. utilization of data and basic risk analysis, and
    6. development of the method for risk communication of PRTR data. The project was completed in 2016 with pilot implementation conducted in two provinces, both of which are major industrial areas.

While the structure of the PRTR system piloted in Thailand is similar to that of Japan, there are two fundamental differences that should be noted. First, the number of substances to be notified in Thailand’s PRTR system is only 107. Such substances list is prepared based on actual chemicals used in Thailand, which can be grouped into: 1) toxic agricultural chemicals such as insecticide and herbicide, 2) metal compounds, 3) organic compounds, 4) criteria pollutants such as sulfur dioxide and nitrogen dioxide and 5) unintentional pollutants such as Dioxin and Furan. Second, the number of point sources included in Thailand’s PRTR system are limited to the following 7 categories of factories: chemical and petrochemical, automobile equipment, wood and furniture, metal and fabricated product, electrical machinery, plastic and rubber. The reason for the limited numbers of substances and point sources covered is  the country’s strategy to start PRTR in a small scale and later expand as the public has better understanding.

Although being a pilot project, the PRTR system in Thailand has received quite good cooperation from business operators in both provinces. For Rayong province, the number of factories that voluntarily submitted PRTR reports during the pilot phase increased steadily from 12.8 % in 2014 to 30.9% in 2016, which is believed to cover approximately 75% of industrial capacity. The survey has shown that toluene, N-hexane, xylenes, methanol and isopropyl alcohol were among top pollutants released in the province and the major polluter  was the industrial sector. Similarly, for Samutprakarn province, the number of factories that voluntarily submitted PRTR reports during the pilot phase was at 36.7% in 2016 but it is believed that the submitted reports only covered approximately 39% of the province’s industrial capacity. Similar to Rayong province, the survey in Samutprakarn has shown that toluene, isopropyl alcohol, xylenes, ethyl acetate and zinc compounds were top pollutants released and the major emitter of chemicals was also the industrial sector. In 2017, the pilot area for PRTR was expanded to Chonburi province, which was an investment promotion area designated under the EEC (Eastern Economic Corridor) policy and is an area to be developed as an “eco-industrial city.” It was hoped that by initiating the PRTR system in such area, the industrial sector and the local community would be aware of the importance of reduction of pollution and joint spatial management. For Chonburi province, there were 141 factories that submit reports. The top three substances with the highest reported released and transported amounts were toluene, N-pentane and xylene. Pentane released into the air was mostly from the plastic products industry, rubber industry and publishing industry while xylene was released into the air by automotive industry, metal industry and machinery industry. The areas that released the highest volumes of these four substances were Siracha district, Phan thong district, Ban bueng district and Mueang District respectively.

The data collected through the PRTR reporting scheme between the year 2013 to 2017, in the three major industrial provinces, has shown that the industrial sector had significantly improved in understanding and reporting capabilities. This could be observed in actual data reported: i.e., though sometimes submitted data contained many errors, the errors were corrected quickly in the subsequence year. From the collected data, we can see that major pollution occurs in the form of air pollution. Part of this comes from the fact that in the 107 substances to be notified, most of which are volatile organic compounds and are primarily released into the air. However, we can also see that the characteristics of Samut prakan province data are different from those of Rayong province, where major chemical producers and petrochemical industries are located. The chemical substance of concern is toluene. Although toluene is a solvent that is ranked first in of all three provinces, it is found that, in Rayong province, toluene was also assessed and reported as contaminating wastewater. While most industries in Samut prakan province are solvent users, especially in painting and printing processes. This leads to toluene released directly into the air without treatment as exhaust gas emission standards have not been established in the province. In such a context, the DIW has given advice on the use of paint solvents to assess total emissions into the air, if pollutants are not treated before exhaust gas is discharged outside the factory. When we see the information of Rayong province, we can found that emissions of the top 3 substances between 2015 and 2017 decreased every year. This may partially reflect the success in establishing the PRTR system that requires the industrial sector to raise awareness and voluntary reduce the emissions.

 

Growing importance of PRTR

Since PRTR system fits well with the Green Industry policy, which is a major policy implemented by the Ministry of Industry (MOI), the DIW and the Industrial Estate Authority of Thailand have requested JICA for continuous support on fine-tuning of the PRTR system, under the project “The Development of New Pollution Management Model using PRTR and Public Participation Principles for Eco-Industrial Town (PRTR Phase 2).” The project ran from 2019 – 2021.  Important elements of the second project include:

    1. development of a public audit program for Eco Industrial Town program at pilot areas;
    2. capacity development for PRTR data utilization;
    3. capacity development for risk communication and public participation mechanism; and
    4. disseminating lessons/experiences to neighboring countries.

Main output of this project can be learned from its website http://prtr.pcd.go.th/jica/

Recently industrial accidents are getting more attention from news media in Thailand. This may partly due to more accidents happened under the Covid-19 pandemic situation, which may cause less attention to safety protocol. In such events, most of the stakeholders have pointed out the need for PRTR regulation. There are some news articles that discuss on the implementation of PRTR, such as an article by The Active (https://theactive.net/data/get-to-know-prtr/) and an article by Sarakadee Magazine (https://www.sarakadee.com/2021/07/14/%E0%B8%AB%E0%B8%A1%E0%B8%B4%E0%B8%87%E0%B8%95%E0%B8%B5%E0%B9%89-prtr/) that pointed out that if PRTR system were  in place, the citizen should have been able to better handle such incidents. NGOs, led by the Ecological Restoration Foundation (EARTH) and the Environment Law Foundation (EnLaw), had also drafted the Act on Reporting on Emissions and Transfer of Pollutants or PRTR Act, based on the PRTR principles learned in the 4year cooperation project with JICA. But there has been no response from the government or relevant government agencies. Later, in early 2021, members of the House of Representatives, submitted the “Draft Act on Reporting on the Emissions and Movement of Pollutants into the Environment B.E. …” for consideration but was deemed as a regulation relating to finance. Therefore, the draft must be approved by Prime Minister. This draft regulation was later canceled due to similarity to the existing Environmental Act.

 

Latest draft on PRTR

On January 10th 2022, the DIW published its draft “Ministry of Industry Announcement on Pollution Release and Transfer Report B.E. …” in its website for public hearing until February 9th 2022. The draft regulation can be obtained from the following link: http://php.diw.go.th/rubfung/upload1/file1_139.pdf. The regulation has incorporated fundamental concepts of PRTR, which can be summarized as follows:

  • Provide definition to common terms used in PRTR system such as pollutants, chemical possession, pollution release and pollution transfer (3rd item of the concepts).
  • Stipulate that factories that use, make, store or possess chemicals (substances), release pollutions or are specifically announced by DIW must report the amounts of chemicals in possession, those of pollutants released and amounts of pollutants. The yearly report over the preceding year must be submitted before July 1st (5th and 7th item).
  • Stipulate that factories that do not possess chemicals (substances) or release pollutants also must also submit reports for confirmation of no possession and not releasing pollutions before July 1st (6th item).
  • Amounts of pollutants released and transferred can be calculated by the concentration-per-volume, engineering calculation, emission factor or mass balance method. The procedure for calculating the amounts of pollutants released and transferred can be found in the DIW’s PRTR handbook, TRI documentation by U.S. EPA, NPI Emission Estimation Technique Manual issued by Australian Government or PRTR Estimation Manuals by NITE of Japan (8th and 9th item).
  • A total of 108 substances that are included in this draft PRTR regulation are shown in the 1st annex, in which mercury and its compounds have been added.
  • A total of 19 categories of factories are covered by this draft PRTR regulation, as shown in the 2nd The list is largely expanded from experimental phase of study. The list is as shown below:
    1. Plant product industry group, i.e., factories No. 1, 2, 9 and 21
    2. Food industry and related businesses, i.e. , factory No. 4 – 8, 10 – 20, 90 and 92
    3. Textile industry group, leather production and leather products, i.e., factory No. 22–33, 93 and 98
    4. Wood processing industry and wood products such as furniture or decorations in the building made of wood, glass, rubber, i.e., factory No. 34–37
    5. Paper and paper product manufacturing industry group, i.e., factory No. 38–41
    6. Chemical and petrochemical industry groups, i.e., factory No. 42–48
    7. Refinery industry, gas separation plants and petroleum products, i.e., factories No. 49 – 50 and 89 (only natural gas separation plants)
    8. Rubber and rubber products industry groups, i.e., factory No. 51 and No. 52
    9. Plastic products industry group, i.e., factory No. 53
    10. Industry group of stone, gravel, sand or soil for use in construction, i.e., factory No. 3
    11. Non-metal product industry group or related to construction, i.e., factory No. 54–58
    12. Primary steel and metal product manufacturing industry, i.e., factory No. 59–64 and 104.
    13. Machinery and mechanical manufacturing industry group, i.e., factory No. 65–70
    14. Electrical appliance manufacturing industry, electrical and electronic equipment and parts, i.e., factory No. 71–74, 81, 94 and 107
    15. Vehicle manufacturing industry, automobile equipment and parts, i.e., factory No. 75–80 and 100
    16. Garage industry group, spraying rust proof paint, washing or grouting, i.e., factory No. 95
    17. Waste Management Industry Group, adjusting the quality of the total waste, landfill, sewage and recycling, i.e., factory No. 101, 105 and 106
    18. Electric Power Generation Industry and selling steam, i.e., factory No. 88 and 102
    19. Other manufacturing industry groups are factory No. 82, 83, 84–87, 89 (non-gas separation plants), 91, 96, 97, 99 and 103.

After this MOI’s Announcement will pass through public hearing, the draft should be modified and announced soon later. After a long wait, it seems like the year of 2022 will be the first year of actual PRTR implementation for Thailand.