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Before you buy or rent a factory in Johor, check one thing: is the lot far enough from the nearest houses, school or hospital for the work you plan to do? The Department of Environment (DOE) answers this with its Guidelines for the Siting and Zoning of Industry and Residential Areas. The guideline sorts industries into five categories and gives each a minimum distance, called a buffer zone: from 50 metres for light industry up to 1 kilometre or more for high-risk industry.
This article explains the parts of the guideline that matter to a factory buyer or tenant: the five categories, how the buffer is measured, the distances for common industries, and how to ask the state DOE about a site before you sign. It follows the Second Revised Edition (October 2012) of the guideline.
Who the guideline applies to
The guideline is used to decide whether a site is suitable for an industry. It applies to:
- new manufacturing or processing plants, inside an industrial estate or on new (greenfield) land,
- expansion of an existing plant that sits next to or close to a sensitive area,
- waste recovery, recycling, treatment and disposal facilities,
- mining, quarrying and other extraction of natural resources, and
- animal farms in feedlots or other confined spaces.
When a business applies for DOE approvals for a factory, the DOE looks at the site first, and the buffer distance is the main test.
The five industry categories and their buffer distances
Appendix A of the guideline groups industries by how much pollution and risk they create. Each category has an indicative primary buffer: the distance from the property boundary to the nearest sensitive receptor.
| Category | Type of industry | Minimum primary buffer |
|---|---|---|
| 1 | High risk: fire, explosion, radiation or highly hazardous chemicals; large emissions, wastewater or hard-to-treat scheduled waste | 1 km or more, set by a modelling study |
| 2 | Heavy: high air, noise or vibration pollution; large amounts of wastewater and scheduled waste | 300 m or more |
| 3 | Medium: moderate pollution and fire risk; scheduled waste that is readily treated | 150 m or more |
| 4 | Light: very low pollution, no hazardous raw materials or products, small scale | 50 m or more |
| 5 | Cottage industry: home-based, hand-made goods, low energy use | No minimum; 10 m or more where there is noise or heat |
A sensitive receptor is what the buffer protects. It includes residential areas (a recognised kampung counts), hospitals, schools, religious and heritage sites, cemeteries, parks and recreation areas, and ecologically sensitive areas such as wetlands, wildlife reserves and water catchments.
Primary, secondary and overall buffer
Each industry in the guideline has an overall buffer, made up of two parts:
- Primary buffer: the distance outside your property boundary, between your lot and the sensitive receptor. This part must always be met.
- Secondary buffer: the distance inside your own lot, from the source of pollution (process area, chimney, chemical store) to your boundary. It can make up the rest of the overall buffer.
Example: a plastic products factory needs an overall buffer of 200 m and a primary buffer of 150 m. If the nearest houses are 150 m from the lot boundary, the other 50 m has to come from inside the lot, by placing the moulding area at the far side of the site with the office, car park or warehouse in between.
The secondary buffer cannot be used by plants that handle highly hazardous chemicals or that carry a major fire or explosion risk. For those, the DOE expects the distance to come from a modelling study it approves.
If a site falls short by a small amount, for example 10 or 20 metres, the guideline allows a simple modelling study to show that the distance is still acceptable, together with extra pollution control.
Buffer distances for common industries
Appendix B lists the buffer for each activity by its MSIC 2008 code (the Malaysia Standard Industrial Classification). These are some of the industries we are asked about most:
| Activity | Category | Overall buffer | Primary buffer |
|---|---|---|---|
| Semiconductors and electronic components | 4 | 100 m | 80 m |
| Bakery, noodles, confectionery and similar food | 4 | 100 m | 60 m |
| Garments | 4 | 100 m | 60 m |
| Printing of books, magazines and advertising material | 4 | 150 m | 100 m |
| Pharmaceuticals | 4 | 150 m | 100 m |
| Soft drinks and bottled water | 4 | 150 m | 100 m |
| Plastic products (injection, extrusion, blow moulding) | 3 | 200 m | 150 m |
| Furniture | 3 | 200 m | 150 m |
| Motor vehicles and parts | 3 | 250 m | 200 m |
| Structural steel, tanks and metal frameworks | 3 | 250 m | 200 m |
| Electroplating and metal coating | 3 | 250 m | 200 m |
| Paints, varnishes and printing ink | 3 | 300 m | 250 m |
| Forging, pressing and stamping of metal | 2 | 350 m | 300 m |
| Sawmills | 2 | 500 m | 350 m |
| Slaughterhouses | 2 | 500 m | 500 m |
For many food, textile and rubber activities, the guideline also asks for a 20 m buffer around auxiliary equipment such as boilers, blowers, generator sets, pumps and fuel storage of 1,000 litres or more.
What can sit inside the buffer
A buffer zone is not empty land. Next to a residential area, the guideline accepts these uses inside the primary buffer:
- roads, road reserves and car parks,
- drains, rivers and their reserves, lakes, forests, parks and open space,
- commercial buildings,
- warehouses that do not store hazardous or dangerous goods, and
- light industries and workshops without significant emissions, noise or vibration.
So a main road between a factory and a housing area counts towards the distance, and a plain warehouse is one of the easiest uses to place near housing. Next to schools, hospitals and religious or heritage sites the rule is stricter: warehousing and all types of industry, including service workshops, are not accepted inside the primary buffer.
Inside your own lot, the secondary buffer can be made up of the office, canteen, car park, internal roads, building setback, packing areas and warehouses that do not hold hazardous goods.
How to ask the DOE about a site
The guideline advises getting the state DOE’s view on a site before you fully commit to buying it. This is the site suitability assessment, also called Penilaian Awal Tapak (PAT).
- Fill in Borang AS PAT 1-12 (Preliminary Site Assessment for Development Project) and submit it to the state DOE office where the site is. For a site in Johor, that is DOE Johor.
- Attach the site and location plan, the layout plan, a land use map showing the buffer distances, a project description, and your pollution prevention and control measures.
- For highly hazardous activities, add the modelling study report.
The DOE then checks five things: whether the use matches the land use in the gazetted structure or local plan, whether it fits the surrounding land use, whether the buffer distance is met, whether the area can take the extra pollution load, and whether the process and pollution control are suitable.
The site assessment is the first step. Depending on the activity, the guideline lists other DOE approvals that may follow:
- an Environmental Impact Assessment (EIA) for prescribed activities under Section 34A of the Environmental Quality Act 1974,
- written permission to build a prescribed premise (Section 19),
- written approval for fuel-burning equipment and chimneys under the Clean Air Regulations,
- prior notification for any new discharge of industrial effluent or sewage, and
- a licence to occupy and use a prescribed premise.
Checklist before you buy or rent a factory
- Find the MSIC code for your activity and look up its category and buffer in Appendix B.
- Measure from the lot boundary to the nearest house, kampung, school, hospital, mosque, temple or church.
- Look at what lies in between. A road, river or row of shops counts towards the buffer; an open field zoned for housing can become a receptor later.
- Check the layout: can the process area, chimney or chemical store sit on the side of the lot furthest from the receptor?
- Allow extra distance for boilers, generator sets and fuel tanks.
- Get the state DOE’s view through a PAT application, or ask an environmental consultant to do it, before you sign the sale and purchase agreement or the tenancy.
A lot inside an established industrial park is usually the safest choice for medium and heavy industry, because the neighbours are other factories. See our guide to industrial parks in Johor for the main estates, and how to buy a factory in Johor for the full buying process.
For heavier industry, areas such as Pasir Gudang and Tanjung Langsat are planned for it. For light manufacturing, electronics or storage, browse detached factory and warehouse listings, or industrial land if you plan to build.
The buffer distances in this article come from the DOE guideline. The DOE decides each site, so confirm with the Department of Environment before you commit. Tell us your activity and the size you need, and we will shortlist sites that are likely to meet the buffer before you view them: contact Jimmy Toh.
