Gyeonggi Industrial Complex Environmental Management Office
•Background: Company A would like to file a report on alteration after it has completed construction of new factory building and its new waste water treatment facility.
•Major issues: According to the analysis on the waste water, items and components of water-quality pollutants met the legal standard level. Regarding the newly detected substance, the approval will be granted when their raw materials are identified. However Company A finds it difficult to disclose the raw material since it is the company’s trade secret.
•Requested matter: Wanted to know the second opinion of the related organization on whether it was appropriate for the competent authority to reject a report on alteration even if the items and components of water-quality pollutants met the standard level, and requested support for resolution.
Resoultion and Results
‣(Jul 22, 2013) Filing company, relevant organization, and home doctor’s visit to the competent authority
※ Competent authority: The amount of waste water discharged from Company A is little and the process is simple. It is also understandable that provision of relevant data from partner company (large business) is not easy. However, considering that Company A is exempted from building a damage prevention facility, if a particular substance is detected beyond a certain level, Company A must build a damage prevention facility.
※ Agreed conclusion: The newly added substance is suspected to be released from raw materials of clay. If Company A submits a written statement promising to take legal measures such as identifying the substance when it is detected beyond a certain level and establishing a damage prevention facility, the report on alteration will be accepted.
•Result: Disclosing the raw material is trade secret of Company A, and collecting data from partner company is not easy. In consideration of this, the written statement will be accepted as the report on alteration.