The list of Toxics is based on the NPRI list and has been split into two
phases in this regulation. There are 96 contaminants on the Phase 1 Toxics list
and the first reporting year will be 2010 which makes the timeline associated
with this regulation extremely tight. Facilities will have to scramble in order
to put appropriate tracking systems/processes in place to gather the required
information.
The Phase 2 Toxics list contains all other NPRI contaminants and will be
phased in two years later, with an initial reporting year of 2012.
Under the Regulation, the main steps for industry will be:
- Establish baseline "usage" data starting with the 2010 operating year.
- Create Toxics Reduction Plan
- Submit Reduction Plan Summary and Progress Reports
Establishing the baseline usage data will require an enormous amount of work,
and is entirely dependent on how many processes are identified for a facility.
Who Will Be Required to Report?
If your facility:
- NAICS code begins with "31", "32", "33" and "212" [only if activities
include chemical refinement, extraction or concentration of an ore].
And
- reports releases or transfers of a contaminant under NPRI, you will need
to report under this regulation.
How Is This Different From NPRI?
NPRI tracks releases and transfers of listed contaminants from facilities on
an annual basis. This regulation has a much broader scope. It will require
facilities to conduct process accounting in order to prepare a mass balance of
toxic materials within internal process(es).
In addition to quantifying the amount of each contaminant that is released or
transferred offsite, the facility will need to track usage from arrival onsite,
and through each process in which it is used or created. Further, reduction
plans need to address options for decreasing usage within each of those steps.
A summary of the Reduction Plan must be submitted to the MOE and the plan
summary will be made public. Every year, the facility must provide an update on
the reduction options identified in the plan to show progress to the public.
Questions?
If you have any questions on how the Toxics Reduction Strategy will affect your facility, please contact:
Sid Lethbridge
slethbridge@lehder.com
Tel: 519.336.4101 ext. 222
Marnie Freer
mfreer@lehder.com
Tel: 519.336.4101 ext. 226 |
