Seminar on Hazardous Substance Single Submission (HSSS) was held at Department of Industrial Works (DIW), Thailand on August 24th, inviting around two hundreds of Audiences who were working for industrial sectors.

The seminar was hosted by DIW to introduce a web based application system which will enable importers and manufactures to submit substances information which were classified as hazardous substance type 2 and type 3. An officers in DIW explained the details of the system.

                              A part of material for HSSS

On the other hand no announcement was made on the date of services commencement for the HSSS.

Just a reference in understanding amendment procedures on regulations in Thailand.

Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ) GmbH, on behalf of the German Federal Ministry of Economic Affairs and Energy (BMWi), published a position paper entitled’ PV ROOFTOP DEVELOPMENT IN THAILAND Analysis of Regulations and Challenges in March 2015.

They pointed out issues of the Factory Act 1992, managed by the Department of Industrial Works, the Ministry of Industry, which was a barrier to prevent from installation of solar power system.

The report strongly claimed that it is advised to define clear requirements, procedures and deadlines for obtaining the factory operation license. The information should be made publically available and equally known to all involved stakeholders. In addition, procedures, requirements and deadlines should be applied transparently and uniformly by the competent authorities.

You are able to download the report at;

http://www.thai-german-cooperation.info/download/20140408_pdp_th_report_pv_regulations.pdf

Some remarkable improvements have been made thanks to the position paper.

It seems to me that procedures of amendment for Hazardous Substance Act should be followed the successful path of the Factory Act.

                            Figure  Notification procedure on hazardous substances information

 HSCB; Hazardous Substance Control Bureau, DIW: the Department of Industrial Works

cbi july 31.pdf (0.33MB)

• Importers in Thailand have still been key players in the notification on hazardous substance to HSCB, DIW Thailand.

• Most of the notifications on existing chemicals have been made by importers of the products, reflecting upon direction by HSCB.

• On the other hand, some importers have had tough time in getting CBI from manufacturers and are not able to apply useful products for importation to Thailand. 

• Some Manufacturers, located on the outside of Thailand, strongly claimed that confidential business information (CBI) would not be secured in this notification procedure.

• Absolutely, the notification procedures do not prevent CBI leak from importers to other manufacturers.

• Copy of original products might be released all over the world.

• We reallize that almost all legal processes in Hazardous Substance Act were absolutely not clear.

• How to address it?