[Background]
Currently, under the Act on the Integrated Control of Environment-Polluting Facilities, if an integrated environmental manager is unable to perform their duties due to travel, illness, or other temporary reasons, a substitute can be designated to act on their behalf; however, there is no upper limit set for this substitution period.
To prevent prolonged vacancies of integrated environmental managers, the maximum substitution period has been internally managed at 5 months. There is now a need to formally legislate this to clearly inform the subject entities.
An amendment to the Act was promulgated (June 9, 2026) to allow integrated permit proxy agencies that meet specific criteria to act as proxies in drafting the annual reports submitted by workplaces.
To fulfill the purpose of the amended Act, it is necessary to establish specific regulations in the subordinate statutes regarding the additional items required in the annual reports and the requirements for proxy drafting.
[Main Points]
A. Designating a maximum substitution period of 5 months for individuals acting on behalf of an integrated environmental manager.
B.
- Establishing new obligations for integrated permit proxy agencies to retain basic data for 5 years and proxy contracts for 3 years when drafting annual reports on behalf of clients.
- Mandating that annual reports include necessary environmental management details considering the workplace's specific conditions. When drafted by a proxy, the integrated permit proxy agency must also attach the results of a self-inspection verifying whether the workplace has complied with permitted emission standards and permit conditions.
- Stipulating the criteria for integrated permit proxy agencies eligible to draft annual reports as those possessing at least two dedicated personnel for annual report drafting.
- Granting the authority to conduct ad-hoc inspections of a workplace if the contents of an annual report drafted by a proxy agency require verification.
-Establishing disciplinary measures for integrated permit proxy agencies if they draft annual reports falsely or inadequately (False drafting: 6-month business suspension → cancellation of registration; Inadequate drafting: Warning → 3-month business suspension → 6-month business suspension → cancellation of registration).