I believe it is rarely known that the concept of “environmental personnel” at factories in Thailand has its root in Japan. In 1971, the Japanese government enacted the Law Concerning the Improvement of Pollution Prevention Systems in Specific Factories, which required specified factories to set up a pollution control manager system composed of a pollution control supervisor who oversees pollution prevention duties, pollution control chief managers who support the pollution control supervisor, and pollution control managers who have technical and professional knowledge and skills in topics of air, water, noise, vibration and dioxin pollution. Such an organizational system has allowed target factories to develop personnel responsible for pollution control who are capable of performing daily tasks and maintaining a good relation with authorities and local residents. This policy played a significant role to improve the compliance rate in terms of environmental regulations among factories in Japan during 1970s–1980s.
In Thailand, such experiences in Japan had been well recorded, presented and demonstrated in various occasions and the Ministry of Industry of Thailand has adopted the similar pollution control manager system since the year 2002. To date, eight regulations have been released and such a pollution control system has become one of the most important environmental regulations that all factories must observe. This article will discuss each of the eight regulations in the chronological order of legislation.
1. Ministry of Industry Notification on Designation of Factory Types and Sizes, Procedure for the Control of Discharges of Wastes, Pollutants, or Any Substances that Cause Adverse Effects on the Environment, Qualifications of Supervisors and Operators, and Criteria for Registration of the Supervisors of Pollution Prevention Systems B.E. 2545 (2002).
- This regulation establishes principles for environmental personnel in factories composed of
- “Pollution control supervisor” which is classified as: “environmental manager” “water pollution supervisor” “air pollution supervisor” and “waste management supervisor”
- “Pollution control system operator”
- “Consultant” who is a service provision contractor permitted to serve as a supervisor
- Factories that fall under the following conditions must have environmental personnel
- Factories having 500 cubic meters per day or more of wastewater (excluding cooling water) or having BOD load of influent 100 kilograms per day or more.
- Factories using heavy metals such as zinc, cyanide, lead, chromium or compounds thereof in production processes and having 50 cubic meters per day or more of wastewater.
- Factories generating high pollution such as a thermal power plant with a capacity of more than 10 MW, petrochemical, oil refinery, natural gas separation, pesticide, and chemical fertilizer industries, central waste treatment plant, sugar-related industry, waste management facility, iron-steel, chlor-alkaline, cement, smelting, and pulp industries.
- This regulation designates duties of environmental personnel as followed,
- “Environmental manager” is responsible for environmental management of the factory, including preparation of environmental implementation plans and management manuals. Environmental manager is the one who sign on environmental report submit to the government.
- “Water pollution supervisor” “air pollution supervisor” “waste management supervisor” and “consultant” are responsible for assessment and inspection of pollutants’ characteristics and the efficiency of pollution prevention system and prevent pollutants from being discharged into the environment without passing through the pollution prevention system as well as to prepare pollutant analysis reports.
- “operator” is responsible for the operation of machines under the pollution prevention system.
- The factory shall control of discharges of wastes, pollutants or any substances that cause adverse effects on the environment by employing environmental personnel and submit application for permission to have environmental personnel according to the criteria defined by the Department of Industrial Works.
- This regulation also gives criteria for registration of environmental personnel, renewal of license, revocation of license and format of application form.
2. Ministry of Industry Notification on Designation of Factory Types and Sizes, Procedure for the Control of Discharges of Wastes, Pollutants, or Any Substances that Cause Adverse Effects on the Environment, Qualifications of Supervisors and Operators, and Criteria for Registration of the Supervisors of Pollution Prevention Systems No. 2 B.E. 2554 (2011).
- This regulation updates the definitions and structure of environmental personnel in factories who are composed of:
- “Pollution control supervisor” which is classified as: “environmental manager” “water pollution supervisor or consultant” “air pollution supervisor or consultant” and “waste management supervisor or consultant”
- “Pollution control system operator” which is classified as: “water pollution control system operator” “air pollution control system operator” and “waste management system operator”
- Expanding types of factories that must have environmental personnel to 18 groups namely,
- Factories having 500 cubic meters per day or more of wastewater (excluding cooling water) or having BOD load of influent 100 kilograms per day or more
- Factories using hazardous substances or compounds thereof including cadmium, cyanide, lead, chromium, arsenic and mercury in production processes and having 50 cubic meters per day or more of wastewater.
- Factory engaging in any of the following activities: 3.1 Production of raw sugar or white sugar or refined sugar, all sizes 3.2 Production of glucose, dextrose, fructose, or other similar products with a production capacity of 20 tons/day or higher
- Factory engaging in production of liquor, alcohol with a production capacity of 40,000 liter/month or higher (at 24% alcohol) or production of wine, with a capacity of 600,000 liter/month 4.3 Production of beer, with a capacity of 600,000 liter/month
- Pulp production from wood or other materials, having a capacity of 50 tons/day or higher
- Petrochemical factory having chemical processes and having a capacity of 100 tons/day e
- Chlor-Alkaline Industry using Sodium Chloride as raw material for a production of Sodium Carbonate, Sodium Hydroxide, Hydrochloric Acid, Chlorine, Sodium Hypochlorite and Bleaching powders with a production capacity of each or combined product(s) of 100 tons/day or more
- Factory producing active ingredients or pesticide, insecticide by chemical processes of all sizes or chemical fertilizer using chemical processes, all sizes
- Production of rubber, synthetic resin, elastomer rubber, plastic, or synthetic fiber which is not optical fiber having capacity from 100 tons/day
- Petroleum refinery, all sizes
- Cement factory, all sizes
- Iron and steel factory, capacity from 100 tons/day
- Non-ferrous smelting factory, having capacity from 50 tons/day
- Thermal Power Plant with a capacity from10 MW
- Natural gas separation or processing plant, all sizes
- Central waste treatment factory
- Waste separation or landfill
- Recycling of industrial waste or industrial hazardous waste as raw materials or new products, all sizes.
- The regulation updates e duties of “pollution control supervisor” and “pollution control system operator” and criteria for renewal of license, revocation of license and format of application form.
3. Department of Industrial Works Notification on Qualification, Training and Standard Examination of Environmental Personnel in Factory B.E. 2554 (2011).
- Stipulates matters on the qualification of environmental personnel in factories. For example, “environmental manager” must be an employee at a factory in managing level who have completed an environmental manager training course and “pollution supervisor” must have at least bachelor degree in a related field and passed a qualification examination and be registered with Department of Industrial Works.
- Stipulates qualification requirements for training agencies which must be a legal personnel under Thailand laws and regulations with an experience on industrial environment and pollution training for at least 2 years with personnel qualified to be trainers.
- Stipulates the registration procedure, structure of training courses and duties of the training agency.
- Stipulates matters on qualification of examination agency which must not be agency that conduct training under this regulation.
- Designate registration procedure, examination procedure and duty of examination agency.
4. Department of Industrial Works Notification on Registration of Water pollution Supervisor, Air Pollution Supervisor and Waste Management Supervisor B.E. 2556 (2013).
- Stipulates the procedure for registration of individuals who have passed a qualification examination as a pollution supervisor using the internet system. Each registration will valid for 3 years and extension of registration can be done upon a request within 30 days before the expiration date as well as consulting company.
- Allowing those individuals to be registered as a pollution supervisor to work with no more than 5 factories.
5. Department of Industrial Works Notification on Notification and Receipt of Notification on the Presence of Environmental Personnel in the Factory B.E. 2556 (2013).
- Stipulates a notification form to be used by factories to nominate qualified employee as environmental personnel to Department of Industrial Works. The notification will be valid for 3 years and need to renew in 90 days before expiration.
- Designates a receipt notification form to be used by the Department of Industrial Works to reply to the notification from companies.
6. Ministry of Industry Notification on Preparation of Report on Type and Amount of Pollutants Discharged From a Factory B.E. 2558 (2015).
- Adds 5 more types of factories that must have environmental personnel, namely:
- Factory related to the production of papers, paperboards, or papers made from fiber pulp or fiber paper for the construction works, having the production capacity from 50 tons/day.
- Factory related to the production of iron or steel having each or total production capacity from 100 tons/day,
- Factory related to the production of glasses, fiberglass, or glass products having melting furnace.
- Factory using boilers with steam-producing capacity from 10 ton/hr per one boiler in case liquid or solid fuel is used; or with steam-producing capacity from 20 ton/hr per one boiler in case gas is used as fuel.
- Factory having or using VOCs in production processes from 36 tons/year.
- Uses a regulatory concept taken from PRTR to estimate the amount of pollution to be reported by environmental personnel in the report. Type and amount of pollutants can be estimated and reported by two methods: “Group M” (Measurement) which refers to data of type and amount of pollutants retrieved from measurements and analyzed with a reference standard method; and “Group C” (Calculation) which refers to data of type and amount of pollutants retrieved using an internationally-accepted calculation method, namely one of the following: a) emission factors of such pollutants b) engineering calculation; or c) mass balance.
- Designates pollutants that should be analyzed in terms of factory effluent and emission. For example, in most cases, factories should analyze for BOD, COD, pH, and suspended solids of their effluent; and in some cases, they should analyze heavy metals and other parameters. They also should analyze for oxide of nitrogen, sulfur dioxide and total suspended particulate in emission gases, with carbon monoxide in some cases.
- Stipulates a format for report on type and amount of pollutants compilation which must be done by environmental personnel and that the report should be submitted to the Department of Industrial Works online. The first report, comprising the data from January to June, shall be submitted by September 1st of the reporting year; and the second report, comprising the data from July to December, shall be submitted by March 1st of the following year.
7. Department of Industrial Works Notification on Report Form of Type and Amount of Pollutants Discharged From a Factory B.E. 2559 (2016).
This regulation designate form for emission report namely
- RoWo.1 Form: for factory general information
- RoWo.2 Form: for water pollution report
- RoWo. 3 Form: for air pollution report
8. Department of Industrial Works Notification on Registration of Water pollution Supervisor, Air Pollution Supervisor and Waste Management Supervisor No.2 B.E. 2564 (2021). This regulation modifies Department of Industrial Works Notification on Registration of Water pollution Supervisor, Air Pollution Supervisor and Waste Management Supervisor B.E. 2556 (2013) such that registration of pollution supervisor can be done online.
Currently there are 12 institutes registered as a qualified training agency and 2 institutes registered as an examination agency. In 19 years from the beginning, regulations on environmental personnel in Thailand’s factories have evolved. Currently, most of individuals who major in environmental sciences are encouraged to take the pollution supervisor qualification examination before their graduation since such certificate will increase a chance of getting job in factory.