written by: Bruce Mitchell
edited and published by: William Billeaud
Environmental Permitting Procedure
It is important during the entire process that you ask as many questions with knowledgeable people as you can find in order to get detail, different perspectives and to determine consistency from different sources. This applies to locating equipment vendors, determining utility costs, and environmental issues. Given the opportunity to interview the Environmental Coordinator from a current company in the same Industrial Park, I had many questions to ask regarding their experiences meeting the environmental regulatory requirements in China.
A meeting was arranged and he presented the following procedures that they followed to meet the environmental requirements:
1. Initially emissions and waste data were prepared and provided to an Environmental Consultant to develop the environmental assessment that is ultimately submitted to the Environmental Bureau for approval.
2. The Environmental consultant develops the table, report, etc. – i.e. Environmental Impact Assessment.
3. The report is submitted to the Environmental Bureau.
4. Within 3 months of production startup you report to the Environmental Bureau.
5. Stack tests are performed and the Environmental Bureau as applicable performs noise level measurements, etc.
6. Check and Accept Procedure – This includes a site audit and a panel review and then a report is provided to the applicant.
7. The next step is to apply for a waste emission certificate/license to the local Environmental Bureau after 6 months of completion of the check and accept report but no later than 12 months. (The bureau has a format for this application.)
8. The Bureau provides a license including metal plate with serial numbers, which must be posted visibly at the plant.
9. The license previously is good for one year so this process has to be repeated each year.
The following reports must be submitted to the Environmental Bureau:
1. Quarterly report – This is used by the Bureau to calculate the fees. It includes any changes to air emissions, solid waste disposal quantities, hazardous waste quantities and the amount of water used. (At the time of the writing of this book we had not been requested to issue a quarterly report.)
2. Semi Annual report – the Bureau for data analysis uses this. (Same comment as for the quarterly report.)
3. Annual report. (The Format is similar to Semi-annual report)
For more specifics we experienced in implementing the above procedure including the “in’s and out’s” of the process, the actual Chinese environmental emission limits and more read Chapter 5 Chinese Environmental Regulations of “13 Steps to Manufacturing in China”
As Vice President, Engineering in the Magnetics Division at Spang and Company for 13 years, Bruce Mitchell’s responsibilities included overseeing strategic business growth, production capacity maximization, plant expansions, maintenance, engineering and environmental initiatives. He managed department managers, a staff of buyers, project managers, designers, and electrical, mechanical, civil, and environmental engineers. He oversaw the Division’s global facilities and manufacturing equipment installations. Through his department equipment was identified and purchased. He was also responsible for the design and fabrication of in-house testing and automation equipment. From 2003 to 2012 he had overall responsibility for the relocation of all manufacturing to China. Potential locations were identified and selected, Chinese equipment was sourced and purchased and installed in a pilot operation in parallel with the design and construction of a new Greenfield plant and later expansion into a second facility. The Asian expansions required the creation of two wholly-owned foreign enterprise. From his experiences he wrote and had published by Palgrave MacMillan in 2012, “13 Steps to Manufacturing in China, The Definitive Guide to Opening a Plant, From Site Location to Plant Start-Up”. Purchase from Amazon. Bruce held numerous engineering supervisory and managerial roles at Honeywell Corporation from 1974-1989. Mr. Mitchell received his Bachelor and Master of Science degrees in Mechanical Engineering from Virginia Polytechnic Institute & State University (Virginia Tech), Blacksburg, Virginia and a Master of Business Administration from Virginia Commonwealth University, Richmond, Virginia.