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The Ministry of Environmental Protection's Industry Reporting Requirements Policy

13.12.20 | 10:00  

Attached for your perusal is a memorandum on the subject of "The Ministry of Environmental Protection's Industry Reporting Requirements Policy" which we hope you will find to be of interest. You are welcome to contact our firm should you have any question or require any clarification regarding the contents of this circular.  

We considered it appropriate to draw to your attention the publication of a policy document for determining industry reporting requirements of the Industries Cluster in the Ministry of Environmental Protection (attached herewith), which is carried out within the framework of the regulation improvement procedures involved in preparing and submitting reports on behalf of industry.

The document deals with the reports which industrial plants are obliged to submit, in accordance with the provisions of the law, the regulations, and the various permits and licenses. The purpose of the document is to prescribe uniform reporting principles for industrial plants, in order to avoid contradictory requirements, avoidance of duplications, avoidance of demands for unused information, consolidation of dates, clarity and organization.

The policy document sets out guidelines regarding four types of reports which are required, as follows:

  1. Immediate report - Criteria have been prescribed which helps to classify incidents involving dangerous substances or other hazards and anomalies and the reporting of them which is required immediately (within 15 minutes). According to these criteria, the reporting obligation was confined to certain events and the policy grants the plant manager a degree of discretion regarding the need to report the event and its classification. With regard to the reporting of situations which are not hazardous material events, the policy specifies various types of incidents and prescribes the reporting period for each of them.
  2. Periodic report - Periodic reporting shall be confined to test results of data examined or measured by the plant, such as: the results of monitoring, sampling and control of emissions, movements of waste, etc., which are required for supervision purposes. Also, a number of periodic reporting requirements which existed until now have been annulled.
  3. Annual report - 31st March was prescribed as the uniform date for submission of the annual report. It was also stipulated that this report shall only contain a summary and analysis of data concerning emissions, transfers, hazards, risks, and the plant's compliance during the past reporting year, needed in order to assess the degree to which the plant is complying with the statutory requirements.
  4. Additional reports -  Notice before undertaking activities and additional reports when demanded, as specified in the document. The new policy has already been assimilated in the broad formats of permits and licenses. Details of the amendments which have been made can be found in the appendix to the policy document. It should be emphasized that the policy does not transcend the statutory requirements, including those applying to licenses and permits, and the relevant regulator may adopt a stringent or lenient approach in relation to the requirements of the policy document, while giving its reasons. The policy shall only apply to a permit or license issued by the Ministry of Environmental Protection only from the moment the policy is assimilated in them, when they are issued or renewed. However, a factory or business may ask for its permit or license to be amended in accordance with the principles of the policy document even before the date of its renewal.

*** The information contained in the above review is provided for informative purposes in an abridged format and under no circumstances does it constitute a substitute for legal advice***