My views on Guided Self-Regulation (GSR)
On previous meeting with Jabatan Alam Sekitar Labuan, we were asked on our views regarding GSR. My answer is simple in one sentence, " we have follow all the mainstreaming tools in GSR and we are good". Probably this is not the answer that everybody want to hear and raised a lot of question.
This fellow must be bluffing and don't know what he's talking about.
The fact is, every companies that being awarded the "Jadual Pematuhan Lesen" for "Off-Site Storage" by Jabatan Alam Sekitar were so lucky. Obviously because they were granted with that "Jadual Pematuhan Lesen", which only a handful can obtain it.
I see it differently.
For me, "JP" what we always call, is my main reference for day to day work. I do read every word on it because I'm the one that going to submit it every quarterly. Not just "JP", we also need to abide with Environmental Quality (Scheduled Wastes) Regulation 2005. As long as we comply with both "JP" and EQ(SW)R2005, we already fulfill more than 50% of GSR requirement. That will be half "Good".
No need to tell everybody that we had submitted GSR report, we already did this, did that and so on. Wake up !!! It's in the GSR report !!!
Let's take a look a the latest GSR Environmental Mainstreaming Tools (previously 8 tools but now has been reduced or combined into 7 tools):
- Environmental Policy (EP)
- Environmental Budgeting (EB)
- Environmental Monitoring Committee (EMC)
- Environmental Facility (EF)
- Environmental Competency (EC)
- Environmental Reporting And Communication (ERC)
- Environmental Transparency (ET)
With "JP", at least we have fulfill no. 2 , 4, 5 and 6.
To operate any businesses, we do need budgeting. This will include Environmental Budgeting because as an "Off Site Storage" for Scheduled Waste, we are actually involved directly with Environmental.
As for Environmental Facility, not all industries has to have in house facility such as laboratory or monitoring equipment. It depends on the nature of that business, type of scheduled waste produced, discharge, treatment required, etc. At least they should have a proper place to store their scheduled waste. For us, a third party accredited laboratory should be sufficient because we do not produced large amount of scheduled wastes. Most of our scheduled waste came from used PPEs, transportation maintenance activity and used office equipment such as printer cartridges, used fluorescent tubes and some e-waste. We only need to monitor air, water and noise quality every quarterly.
Environmental Competency is a must in "JP", and we need at least two person that are competent in CePSWaM. This is a compulsory requirement for an "Off-Site Storage". Unless you want to have other activity (with license) such as water treatment, you need other type of competency such as CePIETSO(BP) or CePIETSO(PCP) or both, depends on the process involved. So, if my calculation is right, for a company that runs "Off Site Storage" and doing a water treatment (chemical and biological process), they need 2 CePSWaM, 2 CePIETSO(BP) and 2 CePIETSO(PCP). That will be 6 competent person. To save cost, hire 2 person that has all 3 competency in their hands. This requirement is a blessing to me as a competent person. At least the burden is not solely on my shoulder and now I can have a long vacation which been postponed for so many years.
As for other personnel, it already mention in regulation 15 of Environmental Quality (Scheduled Wastes) Regulation 2005, "Training Programme : Every waste generator shall ensure that all his employees involved in the identification, handling, labeling, transportation, storage and spill response of scheduled wastes, attend training programme".
In any industries or business, Reporting and Communication is always a critical aspect. Reporting and communication can be done through meetings, phone calls, notice board, tool box meeting, email, whatsapp, form submission and so on which every company should have had established.
Coupled "JP" with Environmental Management System (EMS), especially ISO 14001:2015, will increase the percentage to more than 90%.
We have been accredited ISO 14001:2004 in 2012 and now we already done with the transition to new standard of ISO 14001:2015 and just being accredited.
The first Environmental Tool, Environmental Policy is one of the element required by ISO 14001:2015, in fact all the tools except the new Environmental Transparency already covered by EMS. ISO 14001:2015.
Environmental Monitoring Committee is something familiar with company that has Health, Safety and Environment in place. Our company has HSE department from the beginning of operation. What is different between those two is the term used. The function almost the same. In HSE, Environment Performance Monitoring Committee(EPMC) is known as HSE Employee Representative Committee and Environmental Regulatory Compliance Monitoring Commitee(ERCMC) is known as HSE Employer Representative Committee.
With EMS, it will refine all the GSR requirement in an organized manner. You can just simply extract any documents needed by GSR from EMS document.
The Environmental Transparency can easily be achieved. That is why this website was created in the first place. CSR (Corporate Social Responsibilities) is part of Environmental Transparency now. The easiest way to be involved in CSR is by asking you employee to become "Rakan Alam Sekitar" and join any activity endorsed by Jabatan Alam Sekitar. Without being "Rakan Alam Sekitar", we did joined activity by Jabatan Alam Sekitar.
Now we are "Good".
My conclusion :
GSR in my opinion, is an interpretation of Environmental Management System (EMS) by Jabatan Alam Sekitar for industries to implement. At least there is some sort of EMS in the backbone of industries in Malaysia.
If a company has both "JP" and ISO 14001 in place, they actualy don't need GSR, but of course Jabatan Alam Sekitar need a uniform type of environmental reporting from industries.