HARD TALK : HAZE: IT IS NOT JUST ABOUT SMOKE — SCIENCE, SOURCES, LAW, ESG AND RESPONSIBILITY

Haze is back!!

But perhaps the bigger problem is that every time haze appears, the public discussion quickly becomes emotional:

“It's Indonesia”, “It's Malaysia”, “It's open burning,” “It's factories”, “It's smokers”, “It's barbecues”, “It's volcanoes”, or simply “Just do cloud seeding.”

Then social media takes over. But haze is not a social-media argument.

It is an atmospheric, environmental, public-health, legal, governance and increasingly climate-risk issue.

The recent situation in Sarawak demonstrates how serious it can become. On 4 September 2026, Serian recorded an Air Pollution Index (API) of 519, exceeding the 500 threshold associated with emergency conditions. Malaysia subsequently declared an emergency in the district. The declaration was lifted on 7 September after air quality improved, although health risks remained.

So perhaps we should stop asking only:

“Who caused the haze?”

and start asking:

“What caused it, what evidence do we have, who is responsible, what does the law say, what should organisations do, and why are we still treating haze as an annual surprise?”

1. WHAT EXACTLY IS HAZE?

Haze is not simply “smoke in the air”.

It is a condition where fine particles and other pollutants reduce visibility and affect air quality.

The particles may originate from:

• forest and peatland fires, 

• agricultural burning, 

• vegetation and land-clearing fires, 

• industrial combustion, 

• vehicle emissions, 

• construction and other local sources, 

• domestic burning, 

• volcanic emissions in appropriate circumstances and

• transboundary fires.

The important point is:

Different sources produce different pollutants, at different scales and with different atmospheric behaviour.

Therefore, seeing smoke does not automatically tell us where it came from.

2. TRANSBOUNDARY HAZE IS REAL BUT SO IS LOCAL HAZE

Malaysia has experienced transboundary haze from major fires in neighbouring countries, particularly Sumatra and Kalimantan.

The recent Sarawak episode is a very clear example. Reuters reported that hazardous haze affecting Serian was associated with fires on the Indonesian side of Borneo.

But that does not mean Malaysia has no responsibility of its own.

Malaysia also has:

• open burning, vegetation fires, peat fires, agricultural burning, industrial emissions, construction-related dust and combustion sources and other local contributors to air pollution.

Therefore, the intelligent position is not:

“Everything is Indonesia's fault.”

Nor is it:

“Malaysia is equally responsible for everything.”

The scientifically responsible question is:

What proportion came from which source, where, when, under what meteorological conditions, and based on what evidence?

3. WHAT ABOUT THE CLAIM THAT MALAYSIA CONTRIBUTES 30%?

This claim has circulated in different forms over the years.

There have also been historical disputes involving allegations that fires in Malaysia contributed to haze affecting neighbouring countries, as well as allegations concerning Malaysian-linked companies operating in Indonesia.

But there is an important distinction between:

an allegation, a political statement, a historical incident, and a scientifically established contribution percentage.

I have not found a credible scientific basis for simply stating:

“Malaysia contributes 30% of the regional haze.”

without specifying:

• 30% of what? measured where? during what period? which pollutant? from which sources? using what atmospheric model? based on what satellite or ground measurements?

Interestingly, scientific literature has reported figures around 30% in a completely different context for example, Indonesian peatland fires contributing approximately 30% of retrieved PM2.5 concentrations measured in Petaling Jaya during a particular study period.

That is not the same thing as saying:

“Malaysia causes 30% of regional haze.”

This is precisely why environmental discussions require evidence rather than slogans.

4. MALAYSIA STILL HAS A SERIOUS OPEN-BURNING PROBLEM

Transboundary haze should never become an excuse to ignore domestic environmental offences.

Under Malaysia's Environmental Quality Act 1974, open burning is regulated and prohibited except for specified circumstances or exclusions.

The Department of Environment (DOE) has enforcement responsibilities relating to open burning and investigates complaints through various mechanisms, including field investigations, public complaints and hotspot information.

This matters because:

A country cannot demand environmental accountability from its neighbour while ignoring illegal burning at home.

Environmental governance must work both ways.

5. PEATLANDS ARE A DIFFERENT BEAST

Peat fires are particularly dangerous because peat contains large quantities of partially decomposed organic material accumulated over long periods.

When peat dries, it becomes highly vulnerable to fire.

The fire can:

• burn below the surface;

• smoulder for long periods;

• be difficult to detect;

• produce substantial particulate pollution;

• reignite after appearing to be extinguished.

This is why simply looking for a visible flame can be misleading.

A fire does not need to look spectacular to become an environmental disaster.

6. WHAT ABOUT VOLCANIC VENTS?

Volcanic activity can certainly affect air quality. Volcanoes can release:

• volcanic ash, sulphur dioxide, other gases and fine particulate matter.

Sulphur dioxide can undergo atmospheric reactions and contribute to fine particulate pollution. But we should not automatically blame volcanic activity whenever haze appears.

A credible volcanic attribution requires evidence such as:

• confirmed volcanic activity, satellite observations, atmospheric measurements, wind trajectories, chemical signatures and atmospheric modelling.

Again: Possibility is not proof.

7. WHAT ABOUT BARBECUE?

This is where environmental discussions sometimes become ridiculous.

A controlled barbecue is not automatically equivalent to illegal open burning.

There are specific exclusions and regulatory provisions concerning certain activities, including certain grilling/barbecue activities under prescribed circumstances.

But that does not mean: “Barbecue is legal, therefore I can burn anything.”

Burning:

• plastic, household rubbish, construction waste, contaminated materials, vegetation or waste in prohibited circumstances

is an entirely different matter.

The correct principle is:

Not every fire is illegal but not every fire is environmentally acceptable.

8. WHAT ABOUT CIGARETTE SMOKING?

Cigarette smoke is a genuine source of air pollutants and a serious public-health concern.

But we must maintain scientific proportion. A cigarette contributes localised smoke exposure. A large-scale peat or forest fire can produce enormous quantities of particulate matter over a wide geographical area.

Therefore: 

Cigarette smoke is a health problem, but it is not a credible explanation for regional Southeast Asian haze.

This is another example of why:

source, scale, pollutant and exposure matter.

9. A HOTSPOT IS NOT AUTOMATICALLY AN OFFENCE

Satellite hotspot maps are extremely useful.

But a hotspot is essentially an indication of a possible thermal anomaly.

It is not automatically:

• a confirmed illegal fire, proof of arson, proof of land ownership, proof of corporate responsibility or proof that the smoke affecting a particular city originated there.

Cloud cover, industrial heat sources, flaring and other factors can complicate interpretation.

Therefore:

A satellite hotspot is a lead for investigation not a conviction.

10. WHO IS RESPONSIBLE?

Environmental enforcement is not the responsibility of one agency alone.

Depending on the nature and location of the incident, different authorities may become involved, including:

• Department of Environment (DOE), 

• Fire and Rescue Department (JBPM/BOMBA),

• Royal Malaysia Police, 

• local authorities,

• Ministry of Health, and

• other relevant government agencies.

The appropriate authority depends on the actual circumstances.

• A dangerous active fire is one matter,
• An environmental offence is another,
• A suspected criminal act is another, and
• A public-health emergency is another.

11. DO I NEED TO MAKE A POLICE REPORT BEFORE REPORTING OPEN BURNING?

No. An environmental complaint can be made directly to the DOE.

A police report may become appropriate where there is suspected criminal conduct, deliberate fire-setting, threats or other matters falling under police jurisdiction.

For an immediate dangerous fire, the emergency services should be contacted.

The important principle is:

Do not delay reporting an environmental problem simply because you have not made a police report.

A useful complaint should contain:

• exact location, 

• date and time, 

• photographs/video where safely obtainable, 

• description of the activity, 

• direction of smoke movement, 

• suspected source, 

• nearby landmarks, 

• vehicle registration numbers where relevant and lawfully observed, 

• company/site information where known,  and

• any supporting evidence.

Evidence beats emotion.

12. NGO : WATCHDOG, EDUCATOR OR ENFORCER?

Environmental NGOs have an important role.

They can educate the public, conduct research, monitor environmental conditions, document incidents, advocate better policy, engage government, support affected communities and raise public awareness.

• But NGOs are not enforcement agencies, 
• Neither are social-media users, 
• An NGO allegation still needs evidence, 
• A viral video still needs verification,
• A photograph still needs context, and
• And a company should not be declared guilty simply because somebody has posted its name online.

13. VIRALITY IS NOT ENFORCEMENT

This is increasingly important. A social-media post can reach one million people.

That does not make it evidence. A viral accusation cannot automatically establish:

who owns the land, who started the fire, whether the fire was legal, whether the company caused it, whether the smoke originated there, whether the company had operational control, and whether the person shown was responsible.

• Social media can identify a lead.
• Authorities must investigate the lead.
• Evidence must establish the facts and
• Enforcement must establish accountability.

Therefore: Virality is not enforcement.

14. CLOUD SEEDING : SOLUTION OR TEMPORARY MITIGATION?

Cloud seeding is useful under suitable atmospheric conditions. But cloud seeding requires clouds. You cannot simply “manufacture rain” from a completely unsuitable atmosphere. And even when successful, cloud seeding does not:

• stop a forest fire;

• stop peatland burning;

• prosecute offenders;

• restore damaged ecosystems;

• change land-use practices;

• eliminate pollution at source.

Malaysia has again used cloud-seeding operations during the current haze situation, including during the Serian emergency.

So let us call it what it really is:

Cloud seeding is a mitigation tool not a root-cause solution.

15. NOW COMES THE BIGGER QUESTION: CLIMATE CHANGE

This is where haze becomes much more than an environmental issue.

Climate change can influence:

• rainfall patterns, 

• temperature, 

• drought conditions, 

• soil and vegetation dryness, 

• fire-weather conditions, 

• water availability, and

• ecosystem resilience.

It does not mean: “Climate change caused every fire.” That would be scientifically simplistic. But climate conditions can alter the risk environment in which fires occur and spread.

And this is exactly why climate change has increasingly entered the world of organisational management systems.

16. WHY ARE ISO MANAGEMENT SYSTEMS NOW TALKING ABOUT CLIMATE CHANGE?

In February 2024, ISO and the International Accreditation Forum (IAF) introduced Climate Action Amendments to a number of ISO management-system standards.

Two important additions were made to the Harmonized Structure:

Clause 4.1 : Context of the organization - The organization shall determine whether climate change is a relevant issue.

And under: Clause 4.2 : Needs and expectations of interested parties - the standard recognises that relevant interested parties can have requirements related to climate change.

This is extremely important. It does not mean: “Every organisation must automatically implement the same climate programme.” It means the organisation must determine whether climate change is relevant to its context and address it appropriately where relevant. That is a much more risk-based approach.

17. SO WHAT HAS HAZE GOT TO DO WITH ISO 9001?

Quite a lot.

Imagine a construction company operating during severe haze.

Haze can affect:

• worker exposure, outdoor work, productivity, visibility, transportation, material delivery, project schedules, emergency response, subcontractors, client requirements and quality performance.

Under a quality-management perspective, climate-related conditions can become part of the organisation's context and risks affecting its ability to consistently deliver products and services.

Therefore:

Climate change is not necessarily “the environmental department's problem”. It can become a quality, operational and business problem.

ISO's own auditing guidance has recognised the need for auditors to consider how organisations demonstrate their treatment of climate-change issues under the amended context requirements.

18. ISO 14001 : THE ENVIRONMENTAL CONNECTION IS OBVIOUS

ISO 14001 is perhaps the most obvious connection. But there is an important 2026 update. ISO 14001:2026 is now the current edition.

ISO 14001:2015 has been withdrawn and replaced by ISO 14001:2026. The earlier 2024 climate-action amendment to ISO 14001:2015 has also been withdrawn because the new edition has superseded it.

The new 2026 edition strengthens the emphasis on environmental performance, clearer structure and alignment with contemporary environmental priorities. ISO describes the new edition as providing a clearer way to turn environmental ambition into measurable results.

That should make us think differently about haze. 

An environmental management system should not merely contain a beautiful environmental policy hanging on the office wall.

It should ask:

• What are our actual environmental aspects?
• What are our significant risks?
• What happens during an environmental incident?
• How do we monitor performance?
• What do we do when conditions deteriorate?
• What evidence demonstrates improvement?

19. ISO 45001 : HAZE IS ALSO AN OCCUPATIONAL HEALTH ISSUE

Now consider workers. Construction workers, road workers, plantation workers, outdoor maintenance personnel, security personnel and other outdoor workers may experience prolonged exposure to poor air quality.

That introduces questions about:

• exposure;

• respiratory protection;

• work-rest arrangements;

• outdoor work;

• emergency response;

• communication;

• vulnerable workers;

• monitoring;

• risk assessment.

ISO 45001 provides a framework for systematically managing occupational health and safety risks.

Therefore:

A serious haze episode should trigger occupational-health thinking not merely a WhatsApp message saying “API is unhealthy today.”

20. ISO 22301 : WHAT IF HAZE DISRUPTS BUSINESS?

Haze can also become a business-continuity issue.

What happens if:

• workers cannot safely reach a site?

• schools close and employees have family responsibilities?

• airports or transport operations are disrupted?

• visibility affects logistics?

• outdoor construction must slow down?

• critical suppliers cannot operate?

• emergency services become overloaded?

That is where business continuity becomes relevant.

Haze can therefore move through the chain:

Environment → Health → Operations → Supply Chain → Business Continuity.

This is why treating climate risk as a purely environmental issue is increasingly outdated.

21. ISO 37301 : COMPLIANCE

Climate-related risks can also become compliance risks.

Organisations may have to consider:

• environmental legislation;

• emissions requirements;

• open-burning restrictions;

• occupational-health requirements;

• client contractual requirements;

• reporting obligations;

• sustainability commitments;

• regulatory changes.

ISO 37301 therefore becomes relevant from a compliance-management perspective.

The question is not simply:

“Do we have a compliance register?”

It is:

“Does our compliance system actually recognise the environmental and climate-related obligations relevant to our operations?”

22. ISO 37001 : WHERE DOES ANTI-BRIBERY FIT INTO HAZE?

At first glance, somebody may ask: “What does anti-bribery have to do with haze?”

Quite a lot, particularly when environmental projects involve: 

land, permits, approvals, environmental, assessments and monitoring, concessions, procurement, contractors, enforcement, remediation, and carbon projects.

Climate and environmental programmes involve money. Where there is money, procurement, approvals and discretion, there can potentially be corruption risk. Therefore, climate and environmental governance should not become a new playground for bribery.

An organisation can have an impressive ESG report while having poor anti-bribery controls. That is not sustainability. That is green governance theatre.

23. WHAT ABOUT ISO 37000?

Here we need to be technically accurate.

ISO 37000:2021 is a governance guidance standard, not a certifiable management-system standard in the same sense as ISO 9001, ISO 14001 or ISO 37001.

Therefore, we should not incorrectly say that ISO 37000 received the same 2024 climate-action amendment. But climate change clearly fits within the governance questions addressed by ISO 37000:

• organisational purpose, strategy, oversight, accountability, stakeholder expectations, risk, long-term viability and responsible decision-making.

In other words: Climate change is increasingly a governance issue, even where the standard itself does not contain a specific climate clause.

24. THIS IS WHERE ESG ENTERS THE PICTURE

ESG is broader than ISO 14001. And an ISO 14001 certificate does not automatically mean:

“This company is ESG compliant.”

Likewise, publishing an ESG report does not prove that an organisation has an effective environmental-management system. Haze provides an excellent practical ESG test.

ENVIRONMENTAL

Ask:

• What are our emissions?

• What are our environmental aspects?

• Do our operations contribute to air pollution?

• How do we control combustion and waste?

• What are our climate-related risks?

• What happens during haze?

SOCIAL

Ask:

• Are workers protected?

• Are communities exposed?

• What happens to schools?

• What about elderly and vulnerable people?

• Are workers expected to continue hazardous outdoor work simply to maintain productivity?

GOVERNANCE

Ask:

• Who is accountable?

• Who makes the decision?

• Is there board oversight?

• Are environmental incidents reported honestly?

• Are contractors controlled?

• Are complaints investigated?

• Are environmental obligations monitored?

• Are procurement and enforcement processes protected against corruption?

That is ESG in practice.

Not just a glossy sustainability report.

25. ESG SHOULD BE TESTED WHEN THINGS GO WRONG

This is perhaps the most important point. Anybody can publish an ESG statement when everything is normal. The real test is what happens when: the API turns hazardous.

Does the company:

• monitor air quality?

• reassess risk?

• protect workers?

• modify outdoor activities?

• communicate with employees?

• protect vulnerable personnel?

• activate business continuity procedures?

• manage contractors?

• document incidents?

• report environmental performance honestly?

• engage authorities where necessary?

If the answer is “we never thought about it”, then the organisation may have a climate policy but not genuine climate resilience.

26. THE ISO MESSAGE IS ACTUALLY VERY SIMPLE

The 2024 climate amendments are not saying: “Climate change replaces quality, safety, environment, compliance or governance.”

They are saying something much more logical: If climate change is relevant to your organisation, you must consider it within the organisation's context and management system.

And haze is a perfect practical example. A construction company may face:

Climate risk → dry conditions → fire/haze → poor air quality → worker exposure → reduced productivity → delayed project → supply-chain disruption → contractual consequences → financial impact → reputational risk.

That is not just an environmental issue anymore. It is an integrated organisational risk.

27. THE BIGGEST MISTAKE: CERTIFICATION AS A TROPHY

There is a danger in the modern ESG and ISO environment.

Organisations can become obsessed with:

• certificates, logos, awards, ESG reports, sustainability claims, carbon pledges, policies.

But the real question is: What happens on the ground?

A certificate demonstrates that a management system has been assessed against specified requirements. It does not mean an organisation has magically eliminated every environmental problem.

ISO itself makes clear that certification is a conformity-assessment activity and that ISO develops the standards rather than issuing certificates itself.

Therefore: Certification should be evidence of a functioning management system not a substitute for actual performance.

28. WHAT SHOULD ORGANISATIONS ACTUALLY DO?

For organisations operating in haze-prone environments, a practical integrated approach could include:

1. IDENTIFY

Identify climate, environmental and air-quality risks.

2. ASSESS

Assess the likelihood and consequences.

3. MONITOR

Monitor API, weather, operational conditions and relevant alerts.

4. CONTROL

Implement appropriate operational controls.

5. PROTECT

Protect workers, communities and critical operations.

6. RESPOND

Activate emergency and business-continuity arrangements when required.

7. DOCUMENT

Keep evidence of decisions, actions, monitoring and incidents.

8. REVIEW

Evaluate whether controls actually worked.

9. IMPROVE

Use lessons learned to strengthen the management system.

That is the difference between:

having a system and using a system.

29. WE CANNOT SOLVE REGIONAL HAZE WITH ONE COUNTRY ALONE

The ASEAN haze problem is inherently regional.

Malaysia, Indonesia, Singapore, Brunei and other affected countries need:

• information sharing, 

• hotspot monitoring, 

• enforcement cooperation, 

• land-management improvements,

• peatland protection, 

• firefighting cooperation, 

• scientific modelling, 

• atmospheric monitoring, 

• responsible corporate practices, and

• transparent investigations.

But regional cooperation should not become an excuse for domestic inaction. Every country should be able to say: “We will control what we can control.”

30. SO WHAT IS THE REAL SOLUTION?

There is no single magic solution.

• Not cloud seeding, 
• Not blaming Indonesia, 
• Not blaming Malaysia, 
• Not banning barbecues, 
• Not blaming smokers, 
• Not posting satellite maps, 
• Not going viral, and
• Not simply issuing another policy.

The real solution requires a chain:

PREVENTION → MONITORING → EARLY WARNING → ENFORCEMENT → RESPONSE → ACCOUNTABILITY → RESTORATION → CONTINUAL IMPROVEMENT.

And increasingly:

CLIMATE RISK → ESG → GOVERNANCE → ORGANISATIONAL RESILIENCE.

31. THE FINAL QUESTION

Perhaps the most uncomfortable question is not: “Who caused today's haze?”

It is: “Why do we still seem surprised when it happens?”

• We already know the risk,
• We know the geography,
• We know the dry seasons,
• We know peatlands can burn, 
• We know fires can cross borders, 
• We know wind can transport smoke, 
• We know poor air quality affects health, 
• We know businesses can be disrupted, 
• We know workers can be exposed, 
• We know climate conditions can increase fire risk, 
• We know environmental laws exist, 
• We know management systems exist, 
• We know ESG frameworks exist, and
• We even have satellite technology capable of detecting hotspots.

So perhaps the real failure is not lack of knowledge. It is the gap between:

knowledge and action, policy and implementation, certification and performance and ESG reporting and ESG reality,

and ultimately: responsibility and accountability.

32. HUMAN ATTITUDE : THE MISSING LAYER

But there is one more element that we often overlook: Human attitude.

• We can have ISOs 14001 or ISO 45001, 
• We can have ESG policies, 
• We can have environmental laws, and
• We can have SOPs, risk assessments, emergency plans, satellite monitoring and enforcement agencies.

But if human behaviour does not change, all of these can become merely documents.

A person who throws rubbish into a drain because “someone else will clean it” may have a very different attitude when dealing with environmental responsibility at a larger scale.

• A contractor who says: “It's only a little burning.”
• A worker who says: “I've done this many times and nothing happened.”
• A supervisor who says: “Just finish the job.”
• A manager who says: “Don't make trouble; it will affect the project.”
• And an organisation that says: “We have ISO, so everything must be under control.”

These attitudes can be more dangerous than the absence of a procedure.

32.1 ATTITUDE TOWARDS RISK

One of the biggest problems in environmental, safety and construction management is the mentality of: “As long as nothing happens, everything is okay.”

No.

The absence of an incident does not prove the absence of risk.

• A fire that did not spread is still a fire, 
• A worker who was exposed to unhealthy air but did not immediately become ill does not mean the exposure was acceptable, 
• A contractor who escaped enforcement does not mean the activity was legal, and
• A company that has never experienced a major environmental incident does not mean its controls are effective.

Risk management is about controlling what could happen — not explaining what already happened.

32.2 ATTITUDE TOWARDS SOPs

We also need to be honest about SOPs. 

Some people follow an SOP because they understand the reason behind it. Others follow it only when somebody is watching.And some follow it mechanically without understanding the risk.

There is a major difference between:  “I know the SOP.” and “I understand why the SOP exists.” The latter is much more important.

A person who understands the hazard can often recognise an unsafe situation even when the exact scenario is not written in the SOP. That is what we should be developing: risk awareness, not merely rule obedience.

32.3 ATTITUDE TOWARDS THE ENVIRONMENT

Environmental responsibility also starts with very ordinary behaviour.

• Do we burn something because it is convenient?
• Do we dump waste because nobody is watching?
• Do we ignore smoke because it is coming from somebody else's premises?
• Do we assume environmental responsibility belongs only to the DOE?
• Do we share an unverified accusation online because it supports our personal opinion?

These are not merely environmental questions. They reveal our attitude towards responsibility.

32.4 ATTITUDE TOWARDS ESG

This is also where ESG can fail. If ESG becomes:

“We need something to put into the annual report,”

then we have missed the point.

ESG should influence behaviour and decisions.

• If an organisation claims environmental responsibility but ignores pollution because addressing it is inconvenient, that is not meaningful ESG, 
• If a company claims strong governance but employees are afraid to report environmental misconduct, that is not strong governance, and
• If a company claims to value its people but continues exposing workers to unnecessary hazards because “the project must continue”, that is not genuine social responsibility.

ESG should be visible in behaviour, not just in reports.

32.5 ATTITUDE TOWARDS MONEY

There is another uncomfortable reality. Sometimes the environmentally wrong decision is also the financially convenient decision.

• Proper waste disposal costs money, 
• Environmental controls cost money, 
• Training costs money, 
• Monitoring costs money, 
• Proper maintenance costs money, and
• Stopping work because conditions are unsafe can cost money.

But the question should never be: “How much will compliance cost us?”

We should also ask: “How much could failure cost us?”

The cost can eventually include:

• fines, clean-up, project delays, compensation, health impacts, reputational damage, loss of contracts, loss of investor confidence and loss of public trust.

And sometimes, the cost cannot be measured in ringgit.

32.6 ATTITUDE TOWARDS ACCOUNTABILITY

Perhaps the most important change we need is this: 

Stop asking: “Who can I blame?”

Start asking: “What part of the system failed, and what part of human behaviour contributed to it?”

Accountability does not mean automatically blaming an individual. It means understanding:

• Who knew?
• Who should have known?
• Who had authority?
• Who had responsibility?
• Who failed to act?
• What information was available?
• Was the risk communicated?
• Was the control actually implemented?

That is mature governance.

32.7 FROM “TAK APA” TO “WHAT IF?”

There is a familiar attitude in our society:

• “Tak apa.” 
• “It should be okay.”
• “Nothing happened before.”
• “Everyone does it.”
• “It's only a small fire.”
• “It's only smoke.”
• “Don't worry.”

But environmental and safety management require a different question:

“What if?”

• What if the fire spreads?
• What if the wind changes?
• What if the smoke reaches a school?
• What if a worker has a serious reaction?
• What if the fire enters peatland?
• What if the pollution becomes regional?
• What if somebody dies?

The purpose of risk management is precisely to ask these uncomfortable questions before reality answers them for us.

32.8 THE HUMAN FACTOR IS THE FINAL CONTROL

Ultimately, we can build sophisticated systems.

We can install sensors,  use satellites, develop AI, write standards, create ESG frameworks, or we can strengthen legislation.

But someone still has to make a decision, 

• Someone has to stop the unsafe work, 
• Someone has to report the illegal burning, 
• Someone has to investigate, 
• Someone has to refuse a bribe, and
• Someone has to tell management: “This is not acceptable.”

That person needs something that cannot be purchased with a certificate: the right attitude. Because the strongest management system can still fail when people choose to bypass it.

And sometimes the weakest-looking control - a person simply saying “No, this is unsafe and environmentally wrong”  can prevent a much bigger disaster.

Technology detects, standards structure, laws regulate, auditors verify and management decides.

But ultimately: Human beings act.

And that is why the fight against haze is not only about controlling smoke.

It is also about changing human attitude towards responsibility.

33. AGRICULTURAL BURNING: WHEN “WASTE” BECOMES AN ENVIRONMENTAL DECISION

There is another part of the haze discussion that deserves much more attention: agricultural residue.

After harvesting or before replanting, farmers and plantation operators may have substantial quantities of biomass residue:

• padi straw, 

• sugar-cane residue, 

• oil-palm biomass, 

• branches and vegetation, and

• other agricultural materials.

The traditional argument is straightforward: “We burn it because it is the quickest way to clear the land.”

But environmental management cannot stop at convenience.

The real questions are:

• Is the burning legally permitted?
• Is it an activity excluded from the definition of open burning under the applicable regulations?
• Are there restrictions because of air-quality conditions?
• What alternatives are available?
• What are the particulate emissions?
• What are the greenhouse-gas emissions?
• What is the impact on neighbouring communities?
• And has the organisation actually assessed the environmental aspect and risk?

Under Section 29A of the Environmental Quality Act 1974, open burning is generally prohibited, subject to prescribed exclusions under Section 29AA. DOE defines open burning as combustion or smouldering in the open air that is not directed through a chimney or stack.

Therefore, agricultural burning should never be treated as: “It is farm waste, so I can burn it.”

The legal position depends on the particular material, activity, location and applicable exemption or restriction.

34. THE CARBON QUESTION

There is another issue which is often overlooked. Even where a particular burning activity is legally permissible, that does not automatically make it environmentally neutral.

When biomass is burned, carbon contained in the material is released mainly as carbon dioxide, together with other pollutants depending on combustion conditions.

Incomplete combustion can also generate:

• particulate matter,

• carbon monoxide, 

• other products of incomplete combustion, and

• smoke and other air pollutants.

From an ESG perspective, therefore, we should distinguish between:

legal compliance vs environmental performance.

Something can potentially comply with a particular legal provision while still requiring an organisation to ask whether a lower-emission or higher-value alternative is available. That is where the circular-economy principle becomes important.

Instead of viewing biomass only as: “waste to be disposed of,”

we should increasingly ask whether it can become: “a resource to be recovered.”

• Padi straw can potentially be utilised or incorporated rather than simply burned, 
• Palm biomass can have energy, soil-conditioning or other material uses, and
• Agricultural residues can potentially become inputs into other processes.

The precise technical and economic option will depend on the crop, location, contamination, moisture, logistics and intended use.

But the principle is clear: Before burning biomass, ask whether we are destroying a resource merely because disposal is convenient.

35. WHAT ABOUT A PRIVATE CHIMNEY?

Here we need to be equally careful. A private chimney does not automatically mean:

“No open burning law applies.”

Nor does it mean:

“Anything coming out of the chimney is acceptable.”

The Environmental Quality (Clean Air) Regulations 2014 apply to relevant industrial or trade premises, processes capable of discharging air pollutants, industrial plants and fuel-burning equipment.

DOE provides requirements and procedures relating to:

• fuel-burning equipment,

• chimneys and exhausts,

• air-pollution-control systems,

• emission monitoring, 

• CEMS and PEMS w/a, and

• periodic stack/chimney monitoring.

DOE states that periodic chimney emission monitoring is required at least once a year under Regulation 16, unless otherwise directed by DOE, and reports are submitted for monitoring and evaluation.

So a chimney is not a licence to pollute.It simply changes the question from:

“Is this open burning?” to potentially:

“What is this emission source, what regulations apply, what pollutants are being discharged, what control equipment is installed, and are the emissions within the applicable limits?”

That distinction is extremely important.

36. CONTROLLED BURNING IS NOT THE SAME AS UNCONTROLLED BURNING

If burning is legally permitted or specifically excluded from the definition of open burning, that does not mean: “Light the fire and walk away.”

Good environmental practice should consider:

• weather

• wind direction, 

• wind speed, 

• dryness, 

• proximity to houses, 

• schools, 

• roads, 

• waterways, 

• peatland, 

• neighbouring farms, 

• sensitive populations, 

• availability of firefighting equipment, 

• firebreaks, 

• supervision, 

• timing, 

• smoke dispersion, and

• emergency arrangements.

And if air quality is already poor, the environmental risk becomes even more significant. The correct philosophy should be:

37. CONTROL THE SOURCE : DON'T JUST CONTROL THE STORY. THIS IS WHERE ESG BECOMES REAL

Imagine a plantation or agricultural company saying: “We comply with the law.” That is necessary. But an ESG-minded organisation should ask additional questions:

ENVIRONMENT

• Can we reduce open burning?
• Can biomass be recovered?
• Can emissions be reduced?
• Can we measure our carbon footprint?
• Can we reduce particulate emissions?

SOCIAL

• Will smoke affect neighbouring communities?
• Will workers be exposed?
• Are vulnerable people nearby?

GOVERNANCE

• Who authorised the activity?
• Was the risk assessed?
• Was the applicable legal requirement checked?
• Was the decision documented?
• Was monitoring carried out?
• Were complaints investigated?
• Was the contractor properly controlled?

That is a much more mature approach than simply asking: “Do we have permission?”

37. 1 HUMAN ATTITUDE AGAIN

And this brings us back to the human factor.

There is a major difference between: “We burn because everyone has always done it.”

and: “We have assessed the legal, environmental, safety and climate implications and determined the most appropriate method.”

The first is tradition. The second is environmental management.

Tradition deserves respect. But tradition is not automatically a defence against environmental risk.

If a better, safer and more sustainable method becomes technically and economically viable, responsible management should be willing to change.

That is what continual improvement is supposed to mean.

37.2 FROM “BURN AND CLEAR” TO “RECOVER AND REUSE”

Perhaps this is the direction Malaysia should increasingly move towards.

Instead of asking: “How quickly can we get rid of the residue?”

ask: “How much value can we recover from it?”

That is where:

ESG + circular economy + climate management + ISO 14001 + responsible agriculture can begin to converge.

And that is much more interesting than simply arguing about who produced today's smoke. Because ultimately, the best smoke-control strategy is not always a better chimney.

Sometimes: the best chimney is the one we don't need because we found a better way to use the material.

38. AUTOMOBILES, LORRIES AND BUSES : THE MOVING SOURCES OF AIR POLLUTION

Now let us talk about something we see every day: vehicles.

Cars, Lorries, Buses, Vans, Motorcycles.

Every one of them has an environmental footprint.

But again, we need to separate carbon emissions from air pollutants.

A vehicle can contribute to climate change through its greenhouse-gas emissions while simultaneously contributing to local air pollution through pollutants such as nitrogen oxides, carbon monoxide, hydrocarbons and particulate matter.

DOE specifically regulates emissions from petrol and diesel vehicles under Malaysia's environmental regulations.

38.1 DIESEL LORRIES AND BUSES

This is particularly important. A diesel vehicle emitting thick black smoke is not merely producing an unpleasant smell. Visible black smoke is an indication of excessive particulate emissions and incomplete combustion.

Malaysia's diesel-emission regulations establish a maximum smoke density of 50 HSU under the applicable test. A vehicle exceeding 70 HSU can be subjected to a prohibition order preventing further operation until the problem is rectified and the vehicle passes the required retest.

DOE conducts enforcement operations together with agencies including JPJ and the police, including roadside operations and observation of excessive black smoke.

And this is not merely historical enforcement.

In August 2026, DOE Selangor reported an integrated diesel-vehicle operation in which vehicles suspected of excessive emissions were issued notices requiring corrective action under Section 31(1) of the Environmental Quality Act 1974.

So when we see a heavily smoking lorry climbing a hill, we should not simply say:

“That's an old lorry.”

Age may be a factor. But maintenance, combustion condition, injection system, turbocharger, air supply, fuel quality, exhaust-treatment systems and operating condition can all influence emissions.

The question should be: “Is this vehicle complying with the applicable emission requirements?”

38.3 BUT WHAT ABOUT CO₂?

Here we need another distinction.

The black smoke that we can see is not the same thing as the carbon dioxide that contributes to climate change.

CO₂ is invisible. A vehicle can produce substantial CO₂ without producing visible black smoke.

Conversely, excessive black smoke indicates a local air-pollution problem, but the visible smoke itself is not a direct measurement of the vehicle's total carbon footprint.

Therefore: No black smoke does not mean zero carbon emissions.

And: Black smoke does not tell us the vehicle's exact CO₂ emissions.

This is why ESG and climate accounting require more than simply looking at the exhaust pipe.

38.4 THE VEHICLES RUNNING ALL DAY

Consider:

• A private car travels perhaps a limited distance each day, 
• A heavy goods vehicle may travel hundreds of kilometres, carry substantial loads and operate for long hours, 
• A bus may operate continuously on an urban route.

A construction fleet may have:

lorries, excavators, cranes, generators, concrete trucks, mobile equipment.

The fuel consumption adds up.

From an ESG perspective, organisations therefore need to look beyond:

“Does the vehicle have a road tax and inspection?”

They should also ask:

• How much fuel are we consuming?

• How many kilometres are being travelled?

• What is the vehicle's fuel efficiency?

• What is the age and condition of the fleet?

• What emissions are being generated?

• Are vehicles properly maintained?

• Can routes be optimised?

• Can unnecessary idling be reduced?

• Can lower-emission vehicles be introduced?

• Can logistics be consolidated?

This is where environmental management becomes operational management.

38.5 IDLING IS ALSO AN ATTITUDE

A lorry parked outside a construction site with its engine running for 30 minutes because: “I'm waiting for the supervisor.” is still consuming fuel.

A bus waiting unnecessarily with its engine running is still consuming fuel.

A company vehicle left idling because: “The air-conditioning is more comfortable.” is still producing emissions.

These may look like small things. Multiply them by:

• 10 vehicles, 

• 100 vehicles, 

• 1,000 vehicles, and

• 365 days.

Suddenly, the “small” behaviour becomes an organisational carbon footprint. This is where human attitude returns to the discussion. 

Technology can improve engine efficiency. But technology cannot stop someone from unnecessarily leaving the engine running.

38.6 VEHICLE EMISSIONS DURING HAZE

There is another important point. When regional haze arrives, it is tempting to blame every visible pollution problem on the haze itself.

But the relationship can work both ways. Regional smoke can increase background particulate concentrations. At the same time, traffic continues producing local emissions.

Therefore, in a heavily congested urban area:

transboundary smoke + local combustion + traffic emissions + industrial emissions + weather conditions

can produce a much worse overall air-quality situation than any one source alone. This is why air-quality management requires a multi-source approach.

We should not say: “The haze is from Indonesia, therefore Malaysian emissions don't matter.”

Nor: “Traffic is polluted, therefore the haze must be from Malaysian vehicles.”

Both conclusions are scientifically weak.

38.7 CONSTRUCTION FLEETS DESERVE SPECIAL ATTENTION

For the construction industry, this becomes even more relevant.

A project may have dozens or hundreds of mobile emission sources:

• dump trucks, 

• excavators,

• bulldozers, 

• cranes, 

• piling equipment,

• generators,

• concrete mixers,

• water tankers, 

• buses, and

• workers' vehicles.

A serious environmental management plan should therefore consider:

mobile sources as well as stationary sources.

And this should be connected to:

• ISO 14001 environmental aspects,
• ISO 45001 occupational risk,
• ESG environmental performance, and
• carbon accounting,

and where relevant, business continuity and climate-risk management.

38.8 DO WE NEED TO WAIT FOR A LAW TO CHANGE OUR BEHAVIOUR?

This is the bigger question.

If a vehicle is legally compliant, does that automatically mean it represents best environmental practice? Not necessarily.

Compliance is the baseline. Good environmental management asks:

“Can we do better?”

For example:

• A compliant vehicle may still consume excessive fuel,
• A compliant fleet may still have unnecessary mileage, 
• A compliant lorry may still spend hours idling, and
• A compliant logistics system may still send half-empty trucks across town.

An organisation genuinely serious about ESG should look beyond: “We comply.” and ask: “What is our actual environmental performance?”

38.9 THE CARBON QUESTION FOR FLEET OWNERS

• For companies, fleet emissions should increasingly be treated as part of the organisation's carbon-management discussion.
• Fuel consumption can be tracked, 
• Mileage can be tracked, 
• Vehicle utilisation can be tracked, 
• Maintenance can be tracked, 
• Driver behaviour can be monitored, 
• Idling can be reduced, 
• Routes can be optimised, 
• Fleet replacement can be planned, and
• Lower-emission technologies can be evaluated.

This turns carbon reduction from a slogan into something measurable. And that is exactly where ESG should be heading: from promises to data.

38.10 AGAIN - HUMAN ATTITUDE

The most sophisticated vehicle emission programme can still fail if the attitude is: “As long as the lorry moves, don't bother me.” That mentality creates problems.

The better attitude is: “The vehicle is a workplace, a combustion source and an environmental asset. Its condition affects people, air quality, operating cost and our carbon footprint.”

That is the difference between merely operating a fleet and managing a fleet responsibly.

39. THE BIGGER PICTURE

So when we discuss haze, let us not fall into the trap of searching for only one culprit.

There can be:

• forest fires,
• peat fires,
• agricultural burning,
• industrial combustion,
• stationary sources,
• vehicle emissions,
• construction activities,
• domestic sources,

and atmospheric conditions interacting at the same time. The job of environmental management is not to find the most convenient culprit.

It is to:

• identify sources,
• measure impacts,
• control emissions,
• enforce the law,
• reduce risk,
• and continually improve performance.

Because whether the pollution comes from a burning field or a smoking lorry, the principle remains the same: If we can prevent unnecessary pollution, why wouldn't we?

CONCLUSION

Haze should never be reduced to a photograph of a grey skyline.

Behind that grey sky are questions of:

• science,
• land management,
• climate,
• public health,
• law,
• governance,
• corporate responsibility,
• worker protection,
• ESG,
• business continuity,
• and regional cooperation.

And perhaps this is the lesson we should take into every organisation:

Climate change is not merely an environmental department issue.

It can become :

• A quality issue.
• A safety issue.
• A compliance issue.
• A business-continuity issue.
• A governance issue.
• A financial issue.
• A reputation issue.
• And, ultimately, a leadership issue.

So the next time haze arrives, don't just ask: “Where is the smoke coming from?”

Ask:

• “What evidence do we have?”
• “What law applies?”
• “Who is responsible?”
• “What are we doing about the risk?”

And for organisations claiming to embrace ESG and ISO management systems:

“When the environment is under stress, does our management system actually work?”

Because when the sky turns grey, a policy on paper is not enough.

• Performance is what matters.
• Accountability is what matters.
• And prevention is always better than explaining the haze after it has arrived. (NIK ZAFRI)