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Archives of Business Research – Vol. 10, No. 8
Publication Date: August 25, 2022
DOI:10.14738/abr.108.12858. Hien, T. T., Hieu, N. K., Duong, T. D., Hanh, N. T. H., & La, N. T. T. (2022). Auditing of Environmental Management in Industrial Zones
of Vietnam Case Study of Industrial Zones in Lao Cai Province. Archives of Business Research, 10(8). 74-98.
Services for Science and Education – United Kingdom
Auditing of Environmental Management in Industrial Zones of
Vietnam Case Study of Industrial Zones in Lao Cai Province
Tran Thi Hien
Academy of Finance, Hanoi, Vietnam
Nguyen Khac Hieu
State Audit of Vietnam
Tran Dinh Duong
State Audit of Vietnam
Nguyen Thi Hong Hanh
Academy of Finance, Hanoi, Vietnam
Ngo Thi Thuy La
Thai Binh University
ABSTRACT
Vietnam is a developing country with an economic growth rate among the top in
Asia, therefore facing pressures from industrialization, urbanization, and
population growth means that the amount of waste also increases. In the face of
current environmental issues, an environmental audit is considered a tool to
provide information about the environment, and a basis for assessing the
possibility of environmental risks caused by enterprises, the environmental
obligations of the business, as well as the degree of satisfaction with environmental
standards or regulations. Besides, an environmental audit is also one of the
supporting tools for harmoniously solving the relationship between economic
development and environmental protection, contributing to raising the awareness
of individuals and production organizations in sustainable environmental
protection. The article focuses on analyzing and evaluating the current status of
environmental management in industrial zones in Lao Cai province based on
content and audit criteria for the period 2017-2020. From there, it proposes some
recommendations to improve the efficiency of environmental management and
protection in Lao Cai in the coming time.
Keywords: environmental audit, environmental protection, industrial park, Lao Cai
INTRODUCTION
Lao Cai is a mountainous province, bordering the Northwest region of Vietnam, however,
thanks to its favorable geographical position, inter-regional transportation system, rich and
abundant natural resources, etc., it has created potential and advantages for Lao Cai to attract
investment for comprehensive socio-economic development. In the first six months of 2021,
the highlight among them was industrial development because statistics of the Department of
Industry and Trade of Lao Cai province (2021) showed that the industrial production value
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Hien, T. T., Hieu, N. K., Duong, T. D., Hanh, N. T. H., & La, N. T. T. (2022). Auditing of Environmental Management in Industrial Zones of Vietnam Case
Study of Industrial Zones in Lao Cai Province. Archives of Business Research, 10(8). 74-98.
URL: http://dx.doi.org/10.14738/abr.108.12858
(comparative price in 2010) reached 18,764.2 billion VND, up 12% over the same period in
2020. Notably, the development of the processing and manufacturing industry such as the
production of yellow phosphorus, fertilizers, and phosphoric acid has increased output. In
addition, the province's handicraft production value reached 2,976.2 billion VND due to the
interest in developing and promoting the efficiency of industrial promotion capital.
Currently, there are three operating industrial zones (IZs) in Lao Cai province, including Bac
Duyen Hai Industrial Park, Dong Pho Moi Industrial Park, Tang Loong Industrial Park, and Kim
Thanh Industrial Park - a newly announced industrial park in 2020. Notably, the occupancy rate
of 3 operating industrial parks is over 85%, and the Kim Thanh zone is above 50%. Three areas
are operating with a total area of 1,285 hectares, and 12 industrial clusters with a total area of
145.67 hectares. In the coming time, the province will create conditions for the development of
supporting industries as well as help small and medium enterprises in the province. It needs to
accelerate the implementation of planning on industrial zones and clusters to create clean
premises to attract investment.
Presently, the technical infrastructure for environmental protection in industrial zones in Lao
Cai province has not been invested in and built synchronously, especially since there is no
centralized wastewater treatment system. The planning of construction of industrial zones has
not yet complied with regulations; some production, business, and service establishments have
not strictly complied with regulations on environmental protection, especially Tang Loong
Industrial Park. Therefore, the study “Auditing of environmental management in industrial zones
in Lao Cai province” is necessary and urgent in both theory and practice. The audit will help
evaluate the roles and responsibilities of state management agencies, production, and business
establishments in environmental protection, thereby clarifying shortcomings, and limitations
and making recommendations to enhance public management, environmental protection, as
well as minimizing the risk of causing environmental pollution for economic and industrial
zones in Lao Cai province.
RESEARCH OVERVIEW
In the world, an environmental audit is always considered an optimal tool and is widely applied
in many countries in order to check and evaluate the implementation of regulations in the field
of environmental management and protection, or international standards on environmental
management like ISO 14001 standard (S. Heras, O. Boiral, E. Allur, 2018). According to the
World Bank (WB), “EIA is a method of examining environmental information about an
organization, facility or website to verify data, or to some extent, they are subject to specific audit
criteria”. The criteria can be based on local, national, or global environmental standards.
Therefore, it is a systematic process of collecting and evaluating the information on
environmental aspects (ASOSAI, 2013, p.9).
Countries around the world such as the US, Australia, the UK, the countries of the European
Union, New Zealand, and Canada are leaders in this field. In reality, the application of
environmental audits can be done in many forms, including voluntary and compulsory, internal
or independent audits. Content and standards of audit, especially voluntary or internal audits
can be flexibly developed, depending on the different purposes and needs of enterprises,
production facilities, and business organizations. Most audit programs can be defined based on
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legal regulations, environmental criteria, or other standards such as Global GAP and ISO 14001
(E. Wall, A. Weersink, & C. Swanton, 2001).
Some major programs on environmental management apply audit tools such as The Ontario
Farm Environmental Plan - EFP (Canada, 1992), The UK Linking Environment and Farming
program - LEAF (Squire, 2013) (J. Mills, N. Lewis, and J. Dwyer, 2010), The National Association
of Sustainable Agriculture Australia (NASAA, 2018), Eco-Management Audit Scheme - EMAS (T.
Feldman, 1996).
In many countries around the world, the Supreme Audit Institutions (SAIs) with their important
role need to participate in this field to ensure that natural resources are managed, exploited,
and used effectively. INTOSAI's Working Group on Environmental Audit (WGEA) was
established at the 14th Congress (Wasington D.C, USA, 1992) with 12 SAVs founding members.
Currently, the number of members has increased to more than 70 and has become the largest
working group of INTOSAI, chaired by the Estonian State Audit, the State Audit of Vietnam has
joined as a member of this Working Group. In addition, the ASOSAI Working Group on
Environmental Audit was also founded at the 8th Congress (Chiengmai, Thailand, 2000) with
31 members, including Vietnam.
In Vietnam, environmental audit activities have been recognized by state management agencies
as an effective environmental management tool and encouraged to be promoted and
implemented (Clause 7, Article 6, Law on Environmental Protection, 2014). Environmental
audit activities in Vietnam currently focus heavily on waste audits, for example, Van Diem Paper
Factory, Hoang Van Thu Paper Factory, Dong Nai Paper Company, Viet Tri Chemical Factory,
Capital Brewery, Factory Southeast Asia Beer, etc (T. T. Trinh, T. H. Nguyen, 2003), and some
other audit contents such as the audit of the environmental management system at Trung Son
-Hung Yen Food Joint Stock Company ( 2014), audit of environmental impacts at Nui Seu quarry
(T. V. A. Pham, D. K. Nguyen, 2016), Nam Dinh Textile company (T. V. A. Pham, V. T. Hoang,
2017), Khe Giang domestic solid waste treatment plant, city Uong Bi (2019), energy audit at
Faculty of Science - Can Tho University (M. T. Dinh, 2012), Bitis Lao Cai Trade Center (H. Ba,
2011), Ho Chi Minh City energy saving programs (H. P. Pham, 2007), (Y. Millet, 2011).
Since 2008, after becoming a member of the Working Group on Environmental Audit of Asian
Organization of Supreme Audit Institutions (ASOSAI), the State Audit of Vietnam has
researched, established the apparatus, and piloted the environment audits, including the
content of environmental audit in the action plan to implement the State Audit Development
Strategy until 2022. Statistics show that, from 2010 to now, the State Audit has carried out an
average of 5 environmental audits per year, with topics ranging from forest, land, and clean
water management to waste management, mining, and, recently, low-carbon metabolism. This
is an important step forward in the operation of the State Audit with the approach of developing
new types and fields of audit following international trends and practices.
RESEARCH METHODS
The research team mainly uses statistical-descriptive, statistical-comparative methods to
analyze and evaluate environmental management activities in industrial zones in Lao Cai
province in the period 2017-2020 according to the contents and audit criteria.
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Hien, T. T., Hieu, N. K., Duong, T. D., Hanh, N. T. H., & La, N. T. T. (2022). Auditing of Environmental Management in Industrial Zones of Vietnam Case
Study of Industrial Zones in Lao Cai Province. Archives of Business Research, 10(8). 74-98.
URL: http://dx.doi.org/10.14738/abr.108.12858
The data system is provided by audited units, including the Department of Natural Resources
and Environment of Lao Cai Province, Economic Zone Authority of Lao Cai Province, and,
comparative audit units. The figures are directly investigated by the Auditing Group on
environmental management activities - State Audit Region VII.
RESEARCH RESULTS
Overview of industrial parks and environmental management in industrial zones in Lao
Cai province
Lao Cai is a mountainous province, bordering the Northwest region of Vietnam, with a favorable
geographical position, inter-regional transportation system, and rich and diverse natural
resources. All have created the potential for Lao Cai to attract investment for comprehensive
socio-economic development, notably in industrial fields. Here is some information about
industrial zones (IZ) in Lao Cai province.
(1) Bac Duyen Hai Industrial Park
- Decision approving the adjustment of detailed planning No. 1023/QD-UBND dated May 11,
2012, of Lao Cai Provincial People’s Committee on the adjustment of detailed construction
planning of 1/2000 scale was approved by the Prime Minister to convert from an industrial
cluster to an industrial zone in Document No. 834/TTg-KTN dated May 19, 2016.
- Total area is 850,000 m2 (85 hectares), of which land planned for the industry is 61.85
hectares. The Economic Zone Authority of Lao Cai province has handed over to the People’s
Committee of Lao Cai city to build handicraft production facilities of 12.7 hectares. The area of
industrial land under the management of the Economic Zone Authority is 49.15 hectares.
- The occupancy rate of Bac Duyen Hai Industrial Park is 89.8%.
- Types of attractive investment production in the IZ: electronic assembly industry, processing,
and manufacturing of consumer and export products such as garments, handicrafts, etc, and
storage facilities, goods transshipment warehouse.
- Up to now, the industrial zone has had 64 projects in operation and registered for investment
with a total capital of approximately 1,037 billion VND.
(2) Dong Pho Moi Industrial Park
- Decision on the establishment of Industrial Park No. 717/QD-UBND dated March 30, 2009, of
the Provincial People’s Committee (PCC); The detailed construction planning of Dong Pho Moi
Industrial Park of 1/2000 scale had been approved by the People's Committee of Lao Cai
province in Decision No. 4099/QD-UBND dated December 25, 2008.
- Total area is 1,000,000 m2 (100 hectares), of which 71.85 hectares are planned for industry,
Lao Cai Economic Zone Authority has handed over to the Lao Cai City People’s Committee to
build 2.2 hectares of handicraft production facilities. The industrial land area managed by the
Economic Zone Authority of Lao Cai province is 69.95 hectares.
- The occupancy rate of Dong Pho Moi Industrial Park is 82.47%.
- Types of production that are attractive to invest in the IZ, including factories, production
workshops, mechanical assembly, agricultural and forestry machines; workshops for
manufacturing and assembling refrigeration electronics, processing agricultural and forest
products; a workshop for the production of building materials; goods storages, transit
warehouses; other suitable industries;
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Up to now, the IZ has had 42 projects in operation and registered for investment with a total
capital of about 1,086 billion VND.
(3) Tang Loong Industrial Park
- It was added by the Prime Minister to the industrial zone development planning in Document
No. 1835/TTg-KTN dated October 5, 2009, and accepted in Decision No. 601/QD-UBND dated
March 15, 2011, of Lao Cai Provincial People’s Committee on the establishment of Tang Loong
Industrial Park, Bao Thang district, Lao Cai province. There was detailed planning on the
construction of Tang Loong Industrial Park, subdivision scale 1/2000 Decision No. 1881/QD- UBND dated June 22, 2020.
- Total area is 1,100 hectares according to Decision No. 285/QD-UBND dated February 10, 2011,
of Lao Cai Provincial People’s Committee on approval of detailed planning and adjusting and
expanding Tang Loong Industrial Park, scale 1/2000. Of which, the planned land for the IZ is
631.6 hectares.
- The occupancy rate of Tang Loong Industrial Park is 81.69 %.
- Types of production that are attracted to invest in the IZ: metallurgy, mechanics, chemicals,
fertilizers, building materials, electricity, electronics, and other suitable industries.
- Tang Loong Industrial Park has attracted 30 registered investment projects, of which 25
projects have been put into stable production and business operations, including 13 fertilizer
and chemical factories, 03 metallurgical plants, 01 ore sorting factory, and some ancillary
projects. Total investment capital is over 21,800 billion VND.
(4) Kim Thanh Industrial and Commercial Area
- The People’s Committee of Lao Cai province approved the detailed planning of the Kim Thanh
commercial area for the first time in Decision No. 366/2001/QDUB dated 21 November 2001.
Construction planning was adjusted 06 times in 2003, 2006, 2008, 2013, 2014, and 2020
respectively.
- The occupancy rate of Kim Thanh Trade and Industry Zone is 51.88%. The total number of
investors in the trade zone is 25 projects.
(5) The implementation of environmental management in industrial zones in Lao Cai
province in the period 2017-2020.
- The assessment of environmental records:
The approved environmental documents and permits ensure the full content of environmental
impact assessment, environmental protection solutions, and related issues according to
guidelines and regulations
The Department of Natural Resources and Environment (DONRE) has submitted to the
Provincial People’s Committee for approval 05 EIA reports/Environmental Protection Scheme,
grant certificates of completion of environmental protection work for 03 projects, issuance of
03 permits for discharging wastewater into water sources and; issued as well as adjusted
hazardous waste source owners' books for 11 units in industrial zones in the province; the
approval of 20 Environmental Protection Plans by the Economic Zone Authority (EZA). The EZA
acts as a member of the council to appraise and approve environmental impact assessment
reports for 12 projects.
- Inspection, examination, guidance, and settlement of complaints and denunciations:
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Hien, T. T., Hieu, N. K., Duong, T. D., Hanh, N. T. H., & La, N. T. T. (2022). Auditing of Environmental Management in Industrial Zones of Vietnam Case
Study of Industrial Zones in Lao Cai Province. Archives of Business Research, 10(8). 74-98.
URL: http://dx.doi.org/10.14738/abr.108.12858
Relevant state agencies have taken measures to monitor and supervise the explanation,
remedy, and implementation of verification conclusions, inspection, and instructions of
violating establishments in a complete and timely manner.
Sectors at all levels have organized 04 rounds of inspection with 64 turns of establishments in
industrial zones in the province on the observance of legal regulations on environmental
protection, including the Inspector of the Ministry of Natural Resources and Environment
(MONRE) organized an inspection in 2017 (for 20 institutions), The General Department of
Environment implemented 02 meetings (in 2019: 19 establishments; in 2020: 06
establishments), and The Department of Natural Resources and Environment of Lao Cai
province carried out an unexpected inspection in 2018 for 19 facilities in Tang Loong Industrial
Park. Annually, the Economic Zone Authority inspects the fields of investment, planning,
construction, environmental protection, fire prevention and safety, and labor safety for
enterprises under its management according to the work program of the Board.
Basic information about the audit
* Audit objective
Evaluate the effectiveness and compliance in environmental management and protection
activities of economic zones (EZs) and industrial zones (IZs) of relevant state agencies as well
as production, business, and service establishments in Lao Cai province.
Thereby pointing out the shortcomings, limitations, and factors that can negatively affect the
environment to propose to the audited units in Lao Cai province to correct the management
and operation of the units.
Propose competent authorities to complete inadequate mechanisms and policies; promptly
detect violations, clearly define collective and individual responsibilities for handling in
accordance with the law.
Provide timely information and data for Party and State leaders in leadership and direction in
environmental management and protection.
* Content and audit criteria
- Audit content 1: Assessing the implementation of responsibilities for environmental
management and protection of industrial zones at relevant state agencies in the period 2017-
2020.
+ Auditing Criterion 1: Regarding the promulgation, propaganda, dissemination, and
implementation of regulations and guidance on environmental management and protection:
Auditing Criterion 1.1: Relevant state agencies have developed and issued documents,
regulations, guidelines, programs, and plans on management and environmental protection
fully, timely, and following the legal documents of the state.
Audit Criterion 1.2: Regulations, guidelines, programs, and plans on environmental
management and protection have been propagated, disseminated, and implemented fully,
promptly, and on schedule.
+ Auditing Criterion 2: Regarding the appraisal and approval of environmental documents
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Auditing Criterion 2.1: The appraisal and approval of environmental records are strictly
ensured, in compliance with the prescribed processes and procedures.
Auditing Criterion 2.2: The approved dossiers and environmental permits have sufficient
content on EIA, environmental protection solutions, and related issues according to guidelines
and regulations.
+ Auditing Criterion 3: Regarding the inspection, guidance, and settlement of complaints and
denunciations:
Auditing Criterion 3.1: The inspection, guidance, and settlement of complaints and
denunciations have been done regularly and promptly, ensuring the correct processes and
procedures with close coordination between the relevant agencies.
Auditing Criterion 3.2: Violations of environmental protection are fully reported to the
competent authorities and strictly handled under the law.
Auditing Criterion 3.3: Relevant state agencies should take measures to monitor and supervise
the explanation, remedy, and implementation of inspection conclusions and instructions of
violating establishments in an adequate and timely manner.
+ Auditing Criterion 4: Regarding monitoring, supervision, and assessment of waste
management and treatment activities and, the current environmental status of the IZ
Auditing Criterion 4.1: State agencies build, store and update databases and systems of reports
and information on environmental protection, environmental monitoring, and waste
management in service observation and monitoring of the current environmental status fully
and regularly.
Auditing Criterion 4.2: The shortcomings, limitations, and violations of the law on
environmental protection detected through the database system are promptly handled and
particularly reflected in periodic, unexpected reports.
Auditing Criterion 4.3: The coordination and information sharing among the management
agencies is completely and timely implemented.
+ Auditing Criterion 5: The formulation and adjustment of planning and the implementation of
construction and operation of infrastructure systems for environmental protection of the IZ:
Auditing Criterion 5.1: The planning and adjustment work is carried out to ensure compliance
with legal regulations.
Auditing Criterion 5.2: The implementation of planning, construction, and operation of
environmental protection infrastructure systems (collection works, waste treatment systems,
environmental monitoring) in industrial zones [through the form of socialization, private
investment, or public investment capital (if any)] was implemented to ensure progress, quality
and in accordance with the goals.
- Audit content 2: Assessing the implementation of responsibilities for environmental
management and protection of industrial zones at relevant state agencies in the period 2017-
2020.
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Study of Industrial Zones in Lao Cai Province. Archives of Business Research, 10(8). 74-98.
URL: http://dx.doi.org/10.14738/abr.108.12858
+ Auditing Criterion 1: Regarding the implementation of responsibility for the management and
environmental protection at production, business, and service establishments in the EZs and
IZs.
+ Auditing Criterion 2: Management and treatment of wastewater; solid waste management
and treatment; management and treatment of emissions.
* Scope, limits, and grounds of audit
- Audit scope
+ Audited period: Period 2017-2020 and related periods before and after.
+ Audited unit:
Table 1. List of audited and compared units
No Name of units
I General audit unit
1 Department of Natural Resources and Environment.
2 Economic Zones Authority
II Comparative unit
1 Duc Giang Chemical One Member Co., Ltd
2 Viet Trung Minerals and Metallurgy Co., Ltd
3 DAP 2 Vinachem Joint Stock Company
4 Nam Tien Lao Cai Joint Stock Company
5 Apatit Vietnam Co., Ltd
6 Lao Cai copper refining branch - Vimico
Source: State Audit of Vietnam, 2021
- Audit limits
+ Only audit for environmental protection work based on records and documents provided by
the units. The unit is responsible for the legality and correctness of the documents provided to
the audit team.
+ Do not audit the financial statements of the units. Failing to conduct detailed audits and
confirm investment costs of collection infrastructure works, waste treatment, and
environmental monitoring systems that are not built with public investment capital.
+ Do not audit for waste collection and treatment infrastructure system, monitor environment
with public investment capital due to the absence of an audit period.
+ For field observation facilities: do not observe for underground or elevated environmental
protection works; failing to observe and determine the quality of waste treatment.
- Audit basis
+ Law on State Audit, Law on Public Investment, Law on Environmental Protection, Law on
Water Resources and other relevant legal documents; regulations and standards on
environmental quality;
+ System of auditing standards, audit process, regulations on organization and operation of the
audit team of the State Audit Office;
+ The audit report is prepared based on audit evidence, audit reports, minutes of data
confirmation and audit situation of the auditors, and reconciliation minutes at 06 production
and business establishments.
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Result of the audit
Audit content 1
Assessing the implementation of responsibilities for management and environmental protection
of industrial zones at relevant state agencies in the period 2017-2020
Auditing Criterion 1
Regarding the promulgation, propaganda, dissemination, and implementation of regulatory
documents and guiding the implementation of environmental management and protection
* The adjustment of authorization documents is not timely
The Economic Zone Authority is authorized to appraise and certify the Environmental
Protection Plan from the People’s Committee of Lao Cai City, Muong Khuong District, Bat Xat
District, and Bao Thang District for projects within the scope of its assigned management
according to Article 19, Decree 18/2015/ND-CP dated February 14, 2015. However, in Decree
40/2019/ND-CP dated May 13, 2019, which took effect from July 1, 2019, regulation on Article
19, Decree 18/2015/ND-CP dated February 14, 2015, was amended, according to that, the
authorization content for the certification of environmental protection plans in industrial zones
and clusters was not regulated, and at the same time, the provisions guiding the authorization
in Decree No. 18/2015/ND-CP and Circular No. 27/2015/TT-BTNMT of MONRE were annulled.
Therefore, it is not appropriate for the People's Committee of Lao Cai City, Muong Khuong, Bat
Xat, and Bao Thang districts to terminate the implementation of authorization for the Economic
Zone Authority to appraise and confirm the Environmental Protection Plan with the provisions
of Article 19 of Decree 40/2019/ND-CP dated May 13, 2019. (Currently, the Economic Zone
Management Board does not certify the registration of the environmental protection plan).
* Decision No. 3459/QD-UBND dated August 2, 2017, promulgating regulations on coordination
in environmental management and protection in Lao Cai province: This is an important and
decisive document on the management and coordination mechanism between sectors in the
environmental protection work of Lao Cai Provincial People’s Committee, but there are still
some shortcomings as follows:
- Inadequate and clear on specific responsibilities: assign the Economic Zone Authority as the
unit responsible for regularly and comprehensively inspecting and monitoring the
implementation of environmental protection contents of the industrial park infrastructure
investors and enterprises in IZs in the province, however, the responsibilities of the Economic
Zone Authority have not been clearly defined in case of serious environmental pollution
incidents in projects under management. Meanwhile, the District People’s Committee has a role
to coordinate environmental management in IZs but is responsible before the Provincial
People's Committee for environmental pollution in the area according to the provisions of the
Law on Environmental Protection 2014. At the same time, this can lead to the shifting of
responsibilities between agencies.
- The assignment of planning to respond to environmental incidents in industrial zones and
clusters by the Provincial People’s Committee does not have clear and specific regulations on
the unit responsible for the implementation. In the regulations, only the Economic Zone
Authority is assigned to monitor and guide the formulation and implementation of plans to
prevent and respond to environmental incidents in industrial zones and clusters. Moreover, the
District People’s Committee is responsible for making and implementing the plan to prevent
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Hien, T. T., Hieu, N. K., Duong, T. D., Hanh, N. T. H., & La, N. T. T. (2022). Auditing of Environmental Management in Industrial Zones of Vietnam Case
Study of Industrial Zones in Lao Cai Province. Archives of Business Research, 10(8). 74-98.
URL: http://dx.doi.org/10.14738/abr.108.12858
and respond to environmental incidents in the area under management, however, the
management area of the District People’s Committee includes establishments of the IZ in the
area but under the management of the Economic Zone Authority, the regulations are not clearly
stated. In reality, the Provincial People’s Committee assigned the Department of Natural
Resources and Environment to assume the prime responsibility for implementing an
environmental incident response plan and issued an environmental incident response plan
according to Decision No. 726/QD-UBND dated March 24, 2020, of Lao Cai Provincial People’s
Committee.
* Provincial People’s Committee was slow in promulgating an environmental incident response
plan, specifically: According to the 2017 coordination regulation, the PPC assigned the EZA to
monitor and guide the preparation of a response to environmental incidents in industrial zones
and clusters. However, by 2020, the Lao Cai Provincial People’s Committee organized a master
plan to prevent and respond to environmental incidents in Tang Loong Industrial Park. The
delay of the Provincial People’s Committee in promulgating the plan to respond to
environmental incidents is inconsistent with the provisions of Point c, Clause 2, Article 108 of
the Law on Environmental Protection 2014.
Auditing Criterion 2
Regarding the appraisal and approval of environmental dossiers, granting, extension, and
revocation of environmental permits and certificates of state agencies for projects in industrial
zones
- Industrial zones, when implementing investment, construction, and adjusting the IZ planning
without environmental impact assessment, are not consistent with regulations, specifically:
+ Kim Thanh Commercial and Industrial Park issued Decision No. 366/2001/QDUBND dated
November 21, 2001, without an environmental impact assessment report, which was not
consistent with the provisions of Article 18, Law on Environmental Protection 1993. After 17
years of operation, the Lao Cai Provincial People’s Committee approved the environmental
protection project (Decision No. 1241/QD-UBND dated April 26, 2018).
+ Dong Pho New Industrial Park established Industrial Park No. 717/QD-UBND on March 30,
2009, without an environmental impact assessment report, which was not justifiable with the
provisions of Article 6, Decree No. 80/2006/ND-CP dated 9/8/2006 took effect from
24/8/2006. After 1 year, the unit accepted the environmental protection project (Decision No.
91/QD-TNMT dated March 18, 2010).
According to Article 3 of Circular No. 01/2012/TT-BTNMT dated March 16, 2012, effective from
May 2, 2012, the entities are subject to the requirement to make an environmental impact
assessment report but fail to do must prepare an environmental protection project. However,
the formulation, appraisal, and approval of the environmental protection scheme are still slow
compared to the regulations, specifically:
+ Tang Loong Industrial Park approved the Environmental Protection Project, Decision No.
1975/QD-BTNMT dated July 30, 2019, 7 years behind. The reason was that on December 25,
2018, the Economic Zone Authority had just completed and submitted it to the Ministry of
Natural Resources and Environment for approval (6 years later), after nearly 7 months, the
Ministry of Natural Resources and Environment approved it, 6 months later than the regulation
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at Point a, Clause a, Article 7 of Circular No. 26/2015/TT-BTNMT dated May 28, 2015, of the
MONRE.
+ Kim Thanh Industrial and Commercial Zone accepted the environmental protection project
under Decision No. 1241/QD-UBND dated April 26, 2018, with 6 years behind. The reason was
that on February 7, 2018, the Economic Zone Authority had just completed and submitted it to
the PPC for approval (6 years later), after more than 2 months, the Provincial People’s
Committee approved 38 days later than the provisions at Point a, Clause a of Article. 7 Circular
No. 26/2015/TT-BTNMT dated May 28, 2015, of the MONRE.
Auditing Criterion 3
Regarding the work of inspection and examination, and guiding the settlement of complaints
and denunciations.
- In the period 2017-2020, in Tang Loong Industrial Park, there were many collective
recommendations of households living in the industrial park with the content that
manufacturing plants caused the noise, polluted air, polluting waste discharge, and proposed
to be moved out of the industrial zone to ensure a long and stable life. The People’s Committee
of Lao Cai province directed the agencies to review, check and assess the environmental quality
and had a plan to move the number of households out of the polluted area. There were 106
households in the relocation plan for 2019-2020, however, by the time of the audit, the entire
household has not been moved as planned (71/106 households according to the unit’s report).
- Causes: some households were still not satisfied due to the low level of support and the plan
of resettlement location, leading to difficulties in completing the dossier, moreover, the families
arbitrarily divided land plots as well as changing the purpose of land use from agricultural land
to residential land, etc, according to the 2021 plan, it made payment and site clearance for
85/106 households (According to Document No. 836/BC- UBND on December 26, 2020).
- Thematic audit team on environmental management activities conducted interviews with 10
households living near and directly affected by the environment of Tang Loong Industrial Park.
Table 2. Satisfaction with environmental quality in the living area
No Criteria Number of
households
Proportion
(%)
1 Satisfied 0 0%
2 Unsatisfied 4 40%
3 Very unsatisfied 6 60%
4 No ideas 0 0%
Source: State Audit of Vietnam, 2021
The results showed that 100% of the interviewed households were not satisfied with the
quality of the environment in the living area, of which 60% of them were “very dissatisfied” and
thought that the operation of the IZ had a negative impact on the living environment. In
particular, the main cause was the environment of wastewater, exhaust gas, and solid waste
generated from the industrial park during its operation.
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Study of Industrial Zones in Lao Cai Province. Archives of Business Research, 10(8). 74-98.
URL: http://dx.doi.org/10.14738/abr.108.12858
Table 3. The degree of influence of the operation of the IZs/EZs on the quality of the
surrounding environment
No Criteria Number of
households
1 No effect 0
2 Little effect 0
3 Effect 5
4 Serious effect 5
Source: State Audit of Vietnam, 2021
10/10 of interviewed households found that the water quality of rivers, ponds, and lakes was
polluted with black color (sometimes yellow, green), bad smell, dead fish, especially after heavy
rains, and the idea of dumping untreated wastewater into the environment.
Table 4. Impact of each type of waste from the IZ/EZ on the surrounding environment Unit:
number of households
No Types of waste from
IZs/EZs No effect Little effect Effect Serious
effect
1 Wastewater 10
2 Solid waste, industrial waste 9
3 Emissions 10
Source: State Audit of Vietnam, 2021
- Environmental issues in the IZ were reflected directly by the people or through meetings with
voters. Through interviews with 10 households, it was said that people had complained to local
authorities about the environmental situation, but these shortcomings were not resolved by
the management agencies thoroughly and promptly.
Table 5. The extent to which local authorities respond and handle people’s suggestions related
to the environmental pollution of IZs/Ezs
No Criteria Number of
households
5.1 Timely, complete, public 1
5.2 Not timely 6
5.3 Not complete 1
5.4 Not public
Source: State Audit of Vietnam, 2021
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Audit Criterion 4
Regarding the monitoring, supervision, and assessment of waste management and treatment
activities and the current state of the environment of the industrial park
* For monitoring and evaluation of waste management and treatment activities
The Economic Zone Authority did not have a database system, a reporting system, and
information on environmental protection, environmental monitoring, and waste management
to serve the monitoring and supervision of environmental status.
- For the management of emissions
The audit showed that there were still 06 per 25 enterprises in industrial zones without
periodical monitoring reports for the period 2017-2020 to the Department of Natural
Resources and Environment, the DONRE had urged the units but the units did not comply with
regulations.
- For the management of solid waste, hazardous waste (SW, HW)
Currently, there were 06 per 25 enterprises in 04 industrial zones without making reports on
hazardous waste management and treatment to the Department of Natural Resources and
Environment, and the DONRE had sent a dispatch to urge businesses (Dispatch No. 492/).
STNMT-MT dated March 15, 2017; Official Dispatch No. 2019/STNMT-MT dated September 16,
2019), but the units did not strictly follow the regulations.
- For automatic monitoring system
The Department of Natural Resources and Environment has been responsible for receiving
automatic and continuous emission monitoring data (emissions, wastewater) from facilities
according to the regulations since 2015. However, until January 2018, the DONRE of Lao Cai
had just completed the online automatic monitoring data receiving system and officially
received data from May 2018 from the Lao Cai copper refining branch - VIMICO (after more
than two years).
On April 26, 2019, the Department of Natural Resources and Environment issued Document No.
805/STNMT-MT requiring some businesses to install a continuous automatic emission
monitoring system to urgently complete and transmit data to the DONRE before May 2019. On
June 29, 2020, the Department of Natural Resources and Environment issued Document No.
2869/STNMT-BVMT allowing an extension until December 31, 2020, for businesses that had to
install automatic monitoring systems. However, by the time of the audit, there were still 04
enterprises that had not yet fully installed automatic monitoring data and transmitted
monitoring data to the DONRE for monitoring according to regulations (Vietnam Phosphorus
Joint Stock Company with 01 waste source; Lao Cai Yellow Phosphorus Joint Stock Company
with 01 waste source; Nam Tien Lao Cai Group Joint Stock Company with 01 waste source;
Vietnam Apatite One Member Limited Company with 03 waste sources and installation units
short).
During the automatic monitoring process at 04 stations of Vietnam Yellow Phosphorus Co., Ltd.,
Apromaco Lao Cai Superphosphate Co., Ltd., Lao Cai Southeast Asia Co., Ltd., Duc Giang
Chemical Co., Ltd., there were faulty or damaged devices so the Department of Natural
Resources and Environment had issued document No. 2869/STNMT-BVMT urging the above
businesses to review, repair and replace damaged equipment and to be completed before July
31, 2020. However, up to now, according to the report of the DONRE, the above enterprises
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Study of Industrial Zones in Lao Cai Province. Archives of Business Research, 10(8). 74-98.
URL: http://dx.doi.org/10.14738/abr.108.12858
have not been able to fix or repair faulty and damaged automatic monitoring devices (according
to the unit's report, due to the influence of the Covid epidemic, so the repair devices has not been
imported).
* For monitoring and assessment of the current environmental status.
- Air environment: The results of periodic monitoring and inspection of the natural resources
and environment monitoring center under the Department of Natural Resources and
Environment in the period 2017 - 2020 showed that the dust parameter exceeded the allowable
threshold (According to QCVN 05:2013/BTNMT; QCVN 26:2010/BTNMT) from 1.2 to 1.5 times
at monitoring times (mainly in Tang Loong Industrial Park), and through inspection records of
the General Department of Environment showed that some enterprises had emissions
exceeding technical regulations (Viet Trung Minerals and Metallurgical Company Limited had
emissions exceeding the technical regulation on waste by 1.5 to less than 02 times; Vietnam
Phosphorus Joint Stock Company was by 1.1 to 1.5 times).
- Wastewater environment: Results of checking the periodic monitoring records of the natural
resources and environment monitoring center under the DONRE and selecting a sample of 04
periodic environmental monitoring reports of the units (Lao Cai Iron and Steel Factory of Viet
Trung Minerals and Metallurgy Co., Ltd., DAP2 – Vinachem JSC., Lao Cai Yellow Phosphate JSC.,
Apromaco Superphosphate Co., Ltd.) in 2020 showed that water quality in industrial zones still
had local pollution in terms of organic matter content in water, specific indicators such as COD,
BOD5, TSS, CR6+, NH4+ in Dong Pho Moi, Bac Duyen Hai, and Tang Loong industrial zones
exceeded the threshold for permitted (QCVN 08-MT: 2015/BTNMT) from 1.03 to 2.2 times. In
Dong Pho Moi Industrial Park, when monitoring on August 5, 2020, pointed out that these
parameters exceeded 6 to 19.5 times.
Auditing Criterion No. 5
The formulation and adjustment of planning and the implementation of construction and
operation of infrastructure systems for environmental protection of industrial zones
- The adjustment and expansion of the general construction planning of Tang Loong Industrial
Park did not ensure the conditions for completing the entire industrial park infrastructure
system, especially the system of environmental protection works according to regulations.
- There were 05 enterprises (Viet Trung Minerals and Metallurgy Co., Ltd; Duc Giang Chemical
One Member Co., Ltd; DAP 2 - Vinachem JSC., Vietnam Yellow Phosphorus Co., Ltd; Lao Cai
Minerals and Metallurgical Materials JSC.,) that had not yet connected the wastewater
treatment system to the centralized wastewater treatment system of Tang Loong Industrial
Park. The DONRE reported that the industrial park was building a phase 2 wastewater
treatment system, there was no connection system between the enterprise's wastewater
treatment system and the centralized wastewater treatment system of the industrial park.
(Wastewater treatment system No. 2 was expected to be put into trial operation in the second
quarter of 2021 and handed over the work to be put into use in the second quarter of 2021).
- The operation of the solid waste treatment system of the DAP 2 plant caused the GYPS dam
failure.
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- The construction and handover of the collection system and wastewater treatment station No.
2 were slower than required, according to the provisions of the environmental protection
project of Tang Loong Industrial Park, which should be handed over before June 30, 2020,
however, by the time of the audit, wastewater treatment station No. 2 had not been completed
according to regulations.
- Dong Pho Moi Industrial Park had a wastewater treatment station when constructing and
operating environmental protection technical infrastructure, however, by the time of the audit,
it had not yet operated (Plan started in October 2012 and completed construction in May 2013).
The reason was that there were a number of projects that had applied to change investment
goals, and, the activities of these projects were mainly warehouses, pharmaceutical production,
and gas extraction.
- The planning of Tang Loong Industrial Park still had the problem that there were still
households living in the area.
Audit content 2
Assessment of management and environmental protection at production, business, and service
establishments in the period 2017-2020
- Discharged to the environment parameters exceeds regulations, for example, Lao Cai
Apromaco Superphosphate Company Limited discharged some parameters that exceeded
100% of the standards prescribed for receiving wastewater from construction investors and
industrial park infrastructure business, this violation was administratively fined 76 million
VND by the authorities; Phuc Lam Chemical Joint Stock Company did not thoroughly treat the
tail gas of the sulfuric acid production workshop, which affected the surrounding environment,
causing trees to burn and peel leaves, this violation was administratively fined 80 million VND
by the authorities.
- Not strictly implemented inspection and examination conclusions, for instance, DAP 2
Company did not properly and fully comply with the contents and requirements in the agency's
inspection and examination conclusions on environmental protection by competent state
agencies to cause to break off the Gyps dam, for this action, the unit was administratively fined
560 million VND. Apromaco Lao Cai Superphosphate One Member Co., Ltd. did not fully comply
with the requirements of the inspection conclusion (not yet completed the legal procedures on
the environment for drying and grinding items as required), and, the unit was administratively
fined 100 million VND by the authorities.
- Not strictly implemented regulations on environmental protection, specifically: At the
construction project of waste lake No. 2, Tang Loong apatite ore processing plant, Bao Thang
district, Lao Cai province, has been operating since February 2018 without Certificate of
Completion of Environmental Protection Works, leading to violations of the regulations on
environmental protection, until July 2019, the unit was granted a Certificate of Completion of
the Environmental Protection Project, even though it had been in operation for more than 1
year. DAP2 Joint Stock Company has been in operation since 2015 and was recognized with a
Certificate of Completion of Environmental Protection Works, however, there was still the
category of domestic wastewater treatment station and rainwater collection road which has
been operating since 2015 without a certificate of completion of environmental protection
works, violating regulations on environmental protection (until 2018 the unit was accepted a
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Study of Industrial Zones in Lao Cai Province. Archives of Business Research, 10(8). 74-98.
URL: http://dx.doi.org/10.14738/abr.108.12858
certification, even though there were facilities that had been in operation for 3 years). These
were the actions that could be sanctioned based on Point n, Clause 1,2, Article 9, Decree No.
155/2016/ND-CP, but by the time of the audit, the authorities have not clarified the subjective
and objective reasons for the delay in granting the certification to have a basis for
administrative sanctioning of the above companies according to regulations.
In addition, the inspection and comparison of 06 enterprises operating in Tang Loong Industrial
Park (Duc Giang Chemical One Member Co., Ltd; Viet Trung Minerals and Metallurgy Co., Ltd;
DAP 2 Vinachem JSC.; Nam Tien Lao Cai JSC.; Apatit Vietnam Co., Ltd; Lao Cai copper refining
branch - Vimico), pointed out that the units still had some shortcomings, specifically as follows:
Table 6. Summary of shortcomings/limitations in environmental protection at
audited/compared units
No Unit name Number of
decisions
approving
EIA/Detailed
Environmental
Protection
Scheme/
Number of
discharge
permits
Comparative assessment results
(1) (2) (4) (5)
I Lao Cai Province
Tang Loong Industrial Park
1 Apatit Vietnam Co., Ltd Decision No.
355/QD-MTg
dated March 29,
1997, factory
capacity of
400,000
tons/year
Decision
166/QD-UBND
dated January
20, 2009, of Lao
Cai Provincial
People’s
Committee;
- The field sampling sheet did not
have sampling coordinates (in the
report on environmental quality
monitoring results in the first
quarter of 2018)
- At the construction project of the
waste lake No. 2, Tang Loong
apatite ore extraction plant has
been operating since February
2018 without a certificate of
completion of environmental
protection works, violating
regulations on environmental
protection, until July 2019, the unit
was granted a certification,
although it had been in operation
for more than 1 year.
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2 DAP 2 Vinachem., JSC Decision No.
1579/QD- BTNMT dated
August 26,
2010, of the
Ministry of
Natural
Resources and
Environment
- The GYPS waste dump in some
locations exceeded the design
capacity (+30m) of +15m
- The operation time of Gyps waste
dumping had not met the
regulations (Section 1. II, objective
of Decision No. 452/QD-TTg dated
April 12, 2017, temporary waste
dumps can only be stored for a
limited period of 2 years of
production)
- The 220 kV line (Yen Bai - Lao Cai)
and the 110 kV line (of Su Pan 2
Hydropower Joint Stock Company)
have been in operation since 2006,
during the operation, DAP 2
company dumped waste in the
power line. Visually, the Gyps dump
had a higher elevation than the
power line, the slope had a slope
that threatened to cause unsafety,
below the power line area had been
dumped Gyps (safe distance could
not be assessed by eyes) and at the
same time, the company had a
safety warning sign in accordance
with regulations.
3 Lao Cai copper refining branch Vimico Decision No.
2154/QD- BKHCNMT
dated October
10, 2001, of the
Ministry of
Science,
Technology,
and
Environment
- Minutes of on-site monitoring
sampling (in the dossier of the
fourth quarter of 2018) lacked the
signature of the representative of
the production and business
establishment
4 Duc Giang Lao Cai Chemical One
Member Co., Ltd
- Decision No.
522/QD- BTNMT dated
March 20, 2009,
of MONRE
- Failure to handle and repair faulty
or damaged automatic monitoring
equipment at the request of the
Department of Natural Resources
and Environment, which had to be
completed before July 31, 2020, but
so far the unit has not completed
the repair. (at the WPA workshop)
- Duc Giang Chemical Plant, Food
Acid and Phosphate Salts Factory
went into operation without a
Certificate of Completion of
Environmental Protection Works,
violating regulations on
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Study of Industrial Zones in Lao Cai Province. Archives of Business Research, 10(8). 74-98.
URL: http://dx.doi.org/10.14738/abr.108.12858
environmental protection (until
2018 the unit was granted a
certification). (The People’s
Committee of Lao Cai province had
issued an administrative sanction
decision according to regulations)
5 Viet Trung Minerals and Metallurgy
Co., Ltd
Decision No.
740/QD- BTNMT dated
April 21, 2010,
of MONRE
- There was no automatic and
continuous emission monitoring
device for SO2 parameter as
prescribed in Document No.
680/STNMT-CCBVMT dated April
19, 2016, of DONRE on the
installation of automatic and
continuous monitoring equipment
for emissions and wastewater
- The company has been operating
since 2015 without a Certificate of
Completion of Environmental
Protection Works, violating
regulations on environmental
protection (until 2018 the unit was
accepted a certification although
there were facilities that had been
in operation for 3 years) (Lao Cai
People's Committee had issued a
decision on administrative
sanctions as prescribed)
The field sampling sheet did not
have sampling coordinates (in the
report on environmental quality
monitoring results in the first and
second quarters of 2020).
Source: State Audit of Vietnam, 2021
General conclusion of the audit
These achievements
Firstly, the issuance of documents to urge and guide establishments to implement rules on
environmental protection, propaganda, and implementation of texts, regulations, and plans on
environmental protection are carried out in IZs and EZs quite completely.
Secondly, the appraisal and approval of environmental documents ensure that the order and
procedures are in accordance with the State’s regulations.
Thirdly, the inspection, examination, and guidance have discovered that many establishments
have not strictly complied with regulations on environmental protection, etc.
Fourthly, the Lao Cai People’s Committee in collaboration with the Department of Natural
Resources and Environment has supported IZs and EZs to invest in upgrading infrastructure
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for environmental protection in industrial zones, clusters, and urban centers of grade IV or
higher. Result:
- 100% of IZs have invested in centralized wastewater treatment systems;
- Investment and installation of 01 automatic emission monitoring station;
- The project is underway to build a concentrated solid waste treatment area in Tang Loong
Industrial Park;
- 100% of new investment projects must apply waste treatment technology up to
environmental standards;
- Production and business establishments in the province have focused on investing in
technological innovation towards environmentally friendly clean production;
- 100% of mining projects must make a deposit, and after the mining is finished, the
environment must be renovated and restored according to regulations;
- Basically, the arising environmental problems are handled and promptly resolved by all levels
of the industry.
Existing limitations and reasons
Firstly, regarding the work of promulgating documents
- Regulation on coordination in environmental management and protection in Lao Cai province,
No. 3459/2017/QD-UBND dated August 2, 2017, of the Provincial People’s Committee after
more than 3 years of implementation from 2017 to now, has revealed several problems that are
not consistent with current regulatory documents, and still inadequate and limited compared
to reality.
- The Provincial People’s Committee was late in issuing the plan to respond to environmental
incidents. However, until 2020, the Lao Cai People’s Committee has organized a master plan to
prevent and respond to environmental incidents in Tang Loong Industrial Park.
Secondly, regarding the appraisal and approval of environmental documents
The appraisal, licensing, and approval of environmental documents by the Department of
Natural Resources and Environment and the Economic Zones Authority still have some
shortcomings and limitations that have not been discovered and adjusted.
Thirdly, regarding the work of inspection, examination, and settlement of complaints and
denunciations
The Economic Zones Authority has not fulfilled its duties and responsibilities to cause an
environmental incident at the GYPS dump of DAP2.
Fourthly, regarding monitoring, monitoring, and evaluation of waste management and
treatment activities and the current state of the environment.
The functional units have had many solutions to overcome the environmental pollution,
however, so far the environmental pollution in Tang Loong Industrial Park has not been
completely overcome, causing prolonged frustration for the households living in IZs; there is
an inadequacy in GYPS dump of DAP2.
Fifthly, about the construction and operation of environmental protection technical
infrastructure works of the EZ
The adjustment and expansion of the general construction planning of Tang Loong Industrial
Park have not yet ensured the conditions for the completion of the entire infrastructure system
of the EZ, especially the system of environmental protection works according to regulations.
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Study of Industrial Zones in Lao Cai Province. Archives of Business Research, 10(8). 74-98.
URL: http://dx.doi.org/10.14738/abr.108.12858
Sixthly, in terms of management and environmental protection at production, business, and
service establishments in the period 2017-2020, there were still many shortcomings and
typical shortcomings as follows:
- It did not implement strict regulations on environmental protection. Some businesses and
establishments operated all or part of a project without a Certificate of Completion of
Environmental Protection Works. The main responsibility belonged to the project owner who
did not harshly comply with regulations on environmental protection;
- The parameters of discharge into the environment exceeded the regulations, in the course of
operation, some factories still had problems, leakage of exhaust gas in order to cause resonance
effects affecting the trees and crops of people living around the area such as DAP2 Factory, DCP,
etc.
- The management and environmental protection of production and business establishments
still had many shortcomings and inadequacies, thereby reducing the effectiveness, efficiency,
and compliance in performing the responsibilities and duties of state management agencies in
charge of the environment and the implementation of regulations on environmental protection
by production, business and service establishments in IZs and EZs of Lao Cai province. This led
to widespread violations of regulations on environmental protection, lasting for many years,
increasing the risk of environmental pollution.
One of the main reasons leading to the shortcomings in environmental management in IZs and
EZs in Lao Cai province was limited province funding, so the investment in infrastructure for
environmental protection was synchronized, for example, it invested in concentrated solid
waste and wastewater treatment zones in industrial zones and clusters, especially Tang Loong
Industrial Park.
In addition, the awareness of businesses in complying with legal regulations on environmental
protection was not high, leading to some incidents that affected people’s lives and cause a loss
of security and order such as leakage of non-ferrous metallurgy plant, Ban Lau commune,
Muong Khuong district and the breakdown of sewage return pipeline at the Gysp dump of DAP2
factory, etc.
SOME RECOMMENDATIONS
Recommendations of the State Audit
Firstly, for the Department of Natural Resources and Environment of Lao Cai province
- Coordinate with the Economic Zone Authority to advise the Provincial People’s Committee to
remove problems with State regulations related to Gyps temporary dumping site of DAP 2 Joint
Stock Company to ensure environmental safety.
- Review violations of Vietnam Apatite One Member Company Limited (construction project of
waste lake No. 2, Tang Loong apatite ore processing plant, Bao Thang district, Lao Cai province,
which has been operating since February 2018 without Certificate of Completion of
Environmental Protection works) and DAP 2 Joint Stock Company (the domestic wastewater
treatment station and rainwater collection road has been operating since 2015 without
Certificate of completion of the environmental protection works) have subject to fines
according to the provisions of Decree No. 155/2016/ND-CP. If they are subject to fines, the
DONRE shall report to the Provincial People's Committee to sanction according to regulations.
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- Review and make statistics on the number of establishments subject to periodic hazardous
waste management reports and those that fail to comply with the reporting regime to take strict
measures by regulations of law.
- Combine with Economic Zone Authority to urge businesses that have not yet installed
continuous automatic monitoring systems to urgently install and complete them before
December 31, 2021, in accordance with regulations.
- Coordinate with Economic Zone Authority to urge businesses (Vietnam Yellow Phosphorus
Co., Ltd., Apromaco Lao Cai Superphosphate Co., Ltd., Lao Cai Southeast Asia Co., Ltd., Duc Giang
Chemical One Member Co., Ltd.) repair and fix broken automatic monitoring system equipment.
Moreover, Viet Trung Minerals and Metallurgy Co., Ltd must add SO2 gas parameters to the
automatic monitoring system in accordance with regulations.
Secondly, for the Economic Zone Authority and Industrial Zones of Lao Cai Province
- Rectify and strengthen regular and comprehensive inspection and supervision of enterprises
in industrial zones under management in the implementation of the contents of inspection and
examination conclusions, instructions of the competent authorities, and the reports of
environmental protection. It is necessary to review and learn lessons for not performing all
functions and tasks to cause the Gyps dam failure of DAP 2 Company, and to take drastic
measures to prevent similar environmental incidents from happening.
- Strengthen special supervision for the Gyps dumping site of DAP2 Company operating in
accordance with regulations and taking safety measures for the Gyps dumping site (especially
when the rainy season is coming) to avoid this dam failure as happened in 2018.
- Research and build a scientific and effective database software system for monitoring,
supervising, and urging facilities to make periodical monitoring reports to ensure compliance
with regulations.
- Advise the Provincial People's Committee to have a plan to deal with the relocation of
households living close to the Tang Loong industrial park under the set schedule. It coordinates
with the Department of Natural Resources and Environment to take timely measures to settle
petitions and complaints of people and take drastic measures to solve the problem of
environmental pollution in the Tang Loong industrial park.
- Coordinate with 220 KV and 110 KV power line management companies in the Gyps dump
area of DAP 2 company to assess the safe distance according to current regulations and take
measures to ensure safety for the Gyps yard adjacent to high-voltage power lines with a steep
slope to avoid landslides that affect the safety of the national power grid.
- Review, make statistics and make a list of establishments that do not strictly and fully
implement the environmental monitoring program and violate regulations on environmental
protection through inspection results and guidance in the period 2017-2020 and, report to
competent authorities for establishments committing acts of violating environmental
protection for timely handling according to regulations.
Thirdly, for the People's Committee of Lao Cai province
- Direct the Department of Natural Resources and Environment, the Economic Zone Authority,
and relevant units to strictly implement the recommendations of the State Audit of Region VII,
in which special attention should be paid to directing the Economic Zone Authority to
strengthen supervision of the Gyps dumping site of DAP 2 Company to operate in accordance
with regulations and have safety measures for Gyps dumping site (especially when the rainy
season is coming) to avoid the dam breaking of this dumping site as happened in 2018.
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Study of Industrial Zones in Lao Cai Province. Archives of Business Research, 10(8). 74-98.
URL: http://dx.doi.org/10.14738/abr.108.12858
- Direct the Economic Zone Authority and related units to review and draw lessons from
collectives and individuals related to shortcomings in environmental protection management
as stated in the audit results, specifically some shortcomings, for instance, industrial zones have
not yet assessed their environmental impacts, delay in approving the Environmental Protection
Scheme as well as delay in formulating plans to prevent and respond to environmental
incidents, fail to fulfill responsibilities, leading to the breakdown of Gyps dump spilling into the
environment
- Direct functional units to correct and draw experience in advising and promulgating Decision
No.3459/QD-UBND dated August 2, 2017, of Lao Cai Provincial People’s Committee
promulgating regulations on coordination in environmental management and protection in Lao
Cai province on the assignment of planning to respond to environmental incidents in industrial
zones and clusters of the Provincial People’s Committee without clear regulations.
- Direct the People’s Committee (Lao Cai city, Muong Khuong district, Bat Xat district, Bao Thang
district) to stop authorizing the appraisal and certification of the Environmental Protection
Plan to be in line with current regulations.
- Carry on organizing the relocation of households living close to the Tang Loong industrial zone
according to the set schedule. It needs to take timely measures to settle petitions and
complaints of people in Tang Loong industrial park and direct functional units to deal with the
environmental pollution in Tang Loong industrial park.
- Continue to inspect and review the status of management and operation of the Gyps dump of
DAP 2 Company to handle violations (if any), and at the same time coordinate with the
enterprises to report face difficulties and obstacles to the Ministry of Natural Resources and
Environment, Ministry of Industry and Trade; The Ministry of Construction and the Prime
Minister in the implementation of the provisions of Decision No. 452/QD-TTg dated April 12,
2017, of the Prime Minister.
- Direct the Economic Zone Authority, and the Department of Natural Resources and
Environment to coordinate with relevant units to organize the assessment, sum up, and review
the shortcomings in the process of implementing the regulation on coordination of
environmental protection in IZs and EZs in the province in Decision No. 3459/QD-UBND to
amend and adjust following current practice and legal documents.
Fourthly, for the Ministry of Natural Resources and Environment
It is important to learn from collective and individual experiences related to the approval of the
environmental protection project of Tang Loong Industrial Park 6 months behind regulations.
Some recommendations of the research team
Some solutions for Lao Cai province
- Firstly, continue to focus on leading and directing thoroughly, concretizing and drastically
implementing the guidelines and policies of the Party and State on environmental protection.
- Secondly, carry out propaganda and education work to raise awareness and responsibility for
environmental protection work at all levels of the Party committees, authorities, socio-political
organizations, management boards of the EZs, IZs, production and business establishments,
and all classes of people.
- Thirdly, resolutely eliminate projects with outdated technology, limit investment in projects
with high potential for environmental pollution that investors do not clarify, and provide
specific solutions on environmental remediation.
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- Fourthly, assess the technological level of manufacturing plants in industrial zones and ask
enterprises to develop a roadmap to replace outdated technologies.
- Fifthly, strengthen the inspection and examination of the observance of legal provisions on
environmental protection in production facilities and strictly handle violations of the law.
- Sixthly, economic zones and commercial zones must invest in building environmental
protection and technical infrastructure works.
- Seventhly, the Provincial People's Committee can come up with policies to attract domestic
and foreign investment in the field of environmental protection, waste and wastewater
treatment in the province in general, and IZs and EZs in particular.
Some solutions to improve the audit of environmental management in industrial parks across the
country
- It is important to complete the development of the environmental audit process, guidelines,
and system of documents and forms on an environmental audit from the legal perspective as
well as auditing standards (order, procedures, and methods of performing environmental
audit). In particular, focusing on building a system of criteria, a detailed audit program, and an
audit method suitable to the audit content and objectives is the key content, ensuring the
success of an audit.
- It is necessary to ensure sufficient content, practicality, and feasibility when developing the
audit outline about the implementation of environmental audit activities, the assurance audit
outline is a “hand-held” document for auditors who do not have practical experience with this
audit content. At the same time, develop an audit plan to ensure that the audit material is
correctly identified, thereby determining the appropriate contents and criteria, meeting social
needs, and being realistic and feasible to make valid recommendations on mechanisms and
policies in environmental protection in all fields.
- Regarding human resources for environmental audit, it is necessary to arrange a sufficient
number of auditors with appropriate skills and capacities. Before performing the audit, it needs
to organize seminars, and training, share experiences, ensure that the auditors participating in
the audit have enough basic knowledge about the audit content as well as the technology used
in the environmental protection work, or hire consultants (if necessary) for audits of high
technical expertise, etc.
- In addition, the State Audit also needs to improve the organizational structure in terms of
personnel both size and quality, because currently, there is only one Department of
Environmental Audit under specialized State Audit III. Besides, it is also necessary to strengthen
exchanges and expand international cooperation on environmental economics.
CONCLUSION
Over the past time, environmental audit in Vietnam has played a very important role and is an
effective tool to help the State assess environmental management, and evaluate the economy,
validity, and effectiveness of strategies, policies, and legal system. However, environmental
audits performed by the State Audit are still mainly integrated into financial statement audits,
and compliance audits and few environmental audits are operational or are performed
independently, so the audit results are not as expected.
The research team wants to provide complete, scientific, and comprehensive information about
an audit in a specific locality with in-depth research, analysis, and evaluation of environmental
management in industrial zones in Lao Cai province in order to help readers have an overview
of this activity of the State Audit of Vietnam. In addition to the recommendations of the State
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Hien, T. T., Hieu, N. K., Duong, T. D., Hanh, N. T. H., & La, N. T. T. (2022). Auditing of Environmental Management in Industrial Zones of Vietnam Case
Study of Industrial Zones in Lao Cai Province. Archives of Business Research, 10(8). 74-98.
URL: http://dx.doi.org/10.14738/abr.108.12858
Audit for environmental management agencies in Lao Cai province, the research team also has
several proposals and recommendations from the perspective of researchers for Lao Cai
province and some proposed solutions to promote the validity and efficiency of environmental
audit activities in general and audit activities of environmental management in particular
throughout the country in the coming time.
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