INFORMATION
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?
HS-TECH ENGINEERING Co., Ltd. will outline the procedures and lots of remaining issues concerning about the amendments of Hazardous Substance Act 1992 in line with the following items.
1. Understanding of amendment processes for the Hazardous Substance Act 1992, based on specific Thai culture.
2. Development of existing chemicals inventory
3. New chemicals management system
Amendment on Hazardous Substance Act 1992.pdf (0.27MB)
Who knows which product would be hazardous in line with list 5.6 except for officers in Hazardous Substance Control Bureau (HSCB), Department of Industrial Works (DIW), the Ministry of Industry Thailand?
We only knew that there are 10 characteristics of chemicals / products which meet the criteria for the list 5.6.
http://hstecheng.com/info/1172622
Consultation system on the judgement of hazardous substances / product by HSCB was not clear and no documents on criteria have been disclosed to the public by HSCB.
HS-TECH ENGINEERING Co., Ltd will track the history of list 5.6 on the next information, including impossible for manufacturers to secure confidential business information (CBI).
- Chemical Companies, icluding Global Top 50 Chemical Companies
- Think Tanks
- Environment Safety and Health Consulting Firms
- Trading Companies
Note: Some clients allowed to disclose business relationships with HS-TECH ENGINEERING. Please get in touch with us when you want to know our client's name.
Hashimoto Shinya
President
shinya_hstecheng.com
Mobile +66915454896 (English and Japanese)