According to the MEP order 22, the environmental risk assessment (ERA) report should be submitted when the HCPEC companies apply for the environmental management registration and the report should be compiled by the third party evaluating agencies recommended by the MEP. The agencies will assess the environmental risk of the HCPECs and the environmental management level of the companies, based on the outcome of which the supervision level of the HCPEC companies will be determined by the MEP.
On 22 March 3013, the MEP published a supporting document for ERA, the “Guidance for Compiling the Environmental Risk Assessment Report for HCPECs (Trial)”. As indicated from the guidance, some of the possible requirements for potential evaluating agencies would be:
The evaluating agencies should be qualified in terms of capital asset, registered capital, and workplace space, etc.;
The evaluating agencies are asked to introduce sound QA system into their inner management and the computerized management of the document and data are required;
As for professional staff, the evaluating agencies should have over 10 technical personnel with education background in Biology, Chemical Engineering, Environmental Science and Engineering, Public Health and Preventive Medicine. Furthermore, these personnel would have at least 3 years’ experience of safety or environmental management on hazardous chemicals, ecotoxicology and toxicology review, and exposure and process control. MEP will host training workshop for the personnel from the evaluating agencies and the technicians should pass the qualification examination organized by the MEP;
The evaluating agencies should be experienced in conducting the environmental risk assessment of chemical and chemical projects and finish the ERA report on its own. Capability to conduct the hazard assessment of the chemical, exposure, and risk characteristic of the HCPECs and assess the environmental risk for the HC manufacturer and users is required. They should also be able to analyze and review the technical reports, monitor data form the cooperative association and other parties;
MEP will regularly recommend competent social agencies for environmental risk assessment and publish the names of the agencies and it is said that inner opinion has been consulted.
