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In our effort to enhance the effectiveness of enforcement conducted, DOE have reexamine its objectives, strategies and plan of actions to ensure we are current, forward looking, effective, efficient and able to meet the demands of the time and public.
Among the initiatives introduced for enhancement of effective enforcement includes:
(i) Self regulatory approach
(ii) Applications of enhanced technology
(iii) Application of management & Information Technology (IT) tools (e.g. CEMS, MDMR, ECN)
The self regulatory approach has been consulted with the Environmental Quality Council (EQC) who then advice the Minister of Natural Resources and Environment on the practicality of taking such approach to fulfill the needs of environmental protection with the current limited resources.
“Self regulation” is introduced as a preferred approach to the control of environmental pollution. Self regulation translate the requirements into several regulatory provisions such as the provisions on notification, competent person, performance monitoring, training, monthly discharge monitoring report (MDMR) submission, record keeping, etc. These same approaches are now used in the formulating the upcoming new and newly revised regulations.
The advantages of self regulation initiatives implemented includes:
(i) lowering the cost of on the ground enforcement to the government;
(ii) self regulation approach develops internal commitment and skills in the industrial sector, hence
regulatory compliance is self ensured.
(iii) self regulation leads towards increased compliance which in turn improves industries’ image resulting
in better access of our products to the international markets.
The introduction of more stringent standards as well as new parameter of pollutants in the allowable discharges standards will automatically force the industries to apply new enhanced technology in the effluent treatment as well as in the processes to successfully meet the new requirements or facing risks of stringent enforcement actions by the department.
As for DOE, environmental forensics is a new form of study which enables DOE to trace the environmental culprits. Pollution sources survey and complete spatial database of both pollution sources either subjected or not to the EQA 1974 will enable DOE to trace the potential polluters whenever there is any pollution incident. With the help of information technology, a database of scheduled waste generated, stored and disposed by the premises can be regularly checked and potential illegal disposal of scheduled waste can be identified by using the system (Electronic Consignment Note (ECN)).
Information Technology (IT) tools have also been introduced in the application of Continuous Emission Monitoring System (CEMS) in eight types of industries which includes palm oil mill, heat & power generation plant, iron & steel mills, waste incineration plant, non-metallic industry, chemical industries and oil and gas industry.
Special modules have also been developed for submission of MDMR and E-Consignment Note (ECN) in the existing Electronic Environmental Pollution Control (E-KAS) system where it is monitored by the officers in the States Offices as well as officers in the Enforcement Division in the Headquarters.
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Performance monitoring is considered unique initiative in the sense that it is an upstream activity, ingredients and processes focused that will gives an early warning information about the performance of the unit processes or unit operations of the components of the waste water treatments system, compared to the previous approach i.e compliance monitoring, which is a downstream activity, product and result focused that will give “too late” information, the performance monitoring enable the operator to be in control of the processes in the treatment system.
It address the compliance problem in a new way as conducting performance monitoring will benefit and ensures the following:
(i) ensures that the industrial effluent treatment system (IETS) components are in optimum operation at
all times
(ii) helps prevent IETS failure, hence avoid costly IETS recovery work
(iii) helps to maintain continued compliance, hence improving corporate image and avoid embarrassing
enforcement action
(iv) maintains record of IETS performance which facilitates optimization of IETS and analysis of
performance.
The creative and innovative approaches that allowed for its success includes:
(i) the formulation of guidance documents to guide the industries as well as the officers in developing
the IETS and conducting performance monitoring.
(ii) certification courses for competent person requirement conducted for both industries and DOE
officers
(iii) monitoring special parameters via rapid testing & analysis to determine the performance of each unit
processes and unit operations in the treatment system
(iv) support from DOE IT division in developing special module for online reporting
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