Proposed Hazardous Waste Fees Increase

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TDG Overpack RequirementsThe Ontario Ministry of the Environment and Climate Change (MOECC) is proposing a regulation to amend O. Reg. 347 under the Environmental Protection Act. The proposed regulation would increase the tonnage component of the Hazardous Waste Fees for hazardous waste transferred or disposal of, including:

An increase from $10 to $20 per tonne for waste transfer/disposal between January 1, 2016 and January 1, 2017; and

An increase to $30 per tonne after January 1, 2017.                  

Comments are being accepted for this proposed regulation until September 19, 2015. For more information or to provide comments, please see EBR Registry posting 012-3915.

For more information, please contact LEHDER Principal Mark Roehler.

TDG Overpacks - Are You Labelling Properly?

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TDG Overpack Labelling Requirements

The wording of section 4.10.1 Safety Marks on an Overpack of the Transportation of Dangerous Goods Regulation in Canada can cause some confusion in regards to overpack labelling requirements for domestic shippers, especially when taking other regulatory requirements into account (e.g. UN Model Regulations, IMDG, IATA, and 49 CFR).  Essentially, even if the TDG labels are visible from the outside of the individual DGs in a combined shipment, an overpack label must be provided on the exterior of the overpack. 

For more information, please contact Mark Roehler or to attend one of LEHDER's upcoming TDG courses, please review our training schedule via the Regulatory Training page.

CEPA - Risk Management Scope Document on Selenium Released for Comments

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The draft Screening Assessment Report and Risk management Scope document for selenium and its compounds under the Substance Groupings Initiative of the Chemicals Management Plan has been published. The draft Screening Assessment Report proposes that selenium and its compounds may be harmful to the environment and to human health and meet the criteria set out in sections 64 (a) and (c) of the Canadian Environmental Protection Act, 1999. A Risk Management Scope document has been published for selenium and its compounds which outlines the risk management options that are being given initial consideration. Links to these documents can be found below.  

Interested stakeholders are invited to submit comments on the content of these documents or provide other information that would help to inform decision-making prior to September 17, 2015. Comments provided will be taken into consideration by the Government of Canada in the final Screening Assessment Report and Risk Management Approach document, if required.

Draft Screening Assessment Report for Selenium and its Compounds

Risk Management Scope for Selenium and its Compounds

For more information, please review the Government of Canada's Substance Groupings Initiative.

Documentation Requirements for Dangerous Goods Including Wastes

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The Canada Gazette Part II amendment (SOR/2014-306), published December 31, 2014 which included a 6 month transition period, called for modification of TDG Part 3.5(1)(c) which requires that dangerous goods descriptions must be in the order of Columns 1, 2, 3 and 4 of TDG Regulations, Schedule 1 or UN number, Shipping Name, Class (Subsidiary Class) and Packing Group.

TDG Part 3.6.1 states that as of July 15, 2015, a Consignor must state their name and make a Consignor’s Certification on any shipping document containing dangerous goods.  This certification can be authorized by 49 CFR, ICAO Technical Instructions, IMDG Code, or UN Recommendations.  Alternatively, you would use the TDG certification language which is as follows:

“I hereby declare that the contents of this consignment are fully and accurately described above by the proper shipping name, are properly classified and packaged, have dangerous goods safety marks properly applied or displayed on them, and are in all respects in proper condition for transport according to the Transportation of Dangerous Goods Regulations.”

Documentation Requirements for Dangerous Goods Including WastesThe Canadian standard Movement Document/Manifest adopted by Canadian provinces and territories for use in waste shipments across Canada has been recently updated to include the new certification requirements of a Consignor.  You will note that this certification requirement states that the correct classification under TDG is used (note Part 2.2.1 above).  However, the manifest description for dangerous goods is not in compliance with Part 3.5(1)(c) of TDG as the description is still shown as Shipping Name, Class, UN No. and Packing Group.
If the Movement Document/Manifest is not modified and adopted by provincial/territorial authorities by June 30, 2015, with the correct TDG description order, which is not likely to occur, then all dangerous goods waste shipped on a Movement Document/Manifest must be accompanied by a bill of lading with the correct TDG description.

For more detailed information in regards to waste handling, please contact Mark Roehler.

Classification of Dangerous Goods Including Waste Streams

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TDG Part 2.2.1 states that a Consignor who allows a carrier to transport dangerous goods or imports dangerous goods is responsible for proof of classification for the dangerous goods information used on the shipping document.  This proof must be maintained for five (5) years and must be in a document that explains classification (i.e. test report, lab report, explanatory document) and include the following information:

  •  Date on which dangerous goods were classified;

  •  If applicable, the technical name of the dangerous goods;

  • The classification of the dangerous goods; and

  • If applicable, the classification method used under this Part or under Chapter 2 of the UN Recommendations.

For UN1267 (Petroleum Crude Oil) and UN1268 (Petroleum Distillates N.O.S.), special provision 92 states that proof of classification must be done on the basis of sampling and analysis.  The document used to explain the sampling method must include the following information:

  • The scope of the method;
  • The sampling apparatus;
  • The sampling procedures;
  • The frequency and conditions of sampling; and
  • A description of the quality control management system in place.

It is important to understand that the above applies not only to products but also waste. Any material shipped as a dangerous good, including waste, needs to have proof of classification of the determination of the UN number. If the waste stream is UN1267 or UN1268 then the waste stream must have been sampled and analysed in order to determine the appropriate classification.

For more information, please contact Mark Roehler.

New Air Dispersion Model Versions

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LEHDER Air Modeling ServicesThe MOECC has announced they will be adopting new updated versions of several regulatory air dispersion models shortly.  These models have been updated by the USEPA based on the latest available science.  The MOECC announcement to formally adopt new model versions was intended to provide clarity and consistency to the regulated community and stakeholders.  The mandatory use of the new versions of AERMOD, AERMET and ASHRAE models will become effective as of the date the MOECC posts an Information Notice on the EBR.  Based on the MOECC announcement, the posting of the Notice is expected in October 2015 which is  only a few months from now.

The new versions of AERMOD and AERMET will be version 14134 (dated May 14, 2014). The ASHRAE calculation method will be updated to the 2011 ASHRAE Handbook – HVAC Applications.

The transition to the new model versions can be complex depending upon the status of your ECA, pending ECA Application or abatement plans.  Once the new model version comes into effect, any modeling triggered for regulatory purposes must be completed using the new version unless your facility has a Section 7(1) notice.  Now is the time to evaluate how changes to the air dispersion models may affect your facility’s compliance.  

To learn more about how the new model version transition may affect your facility, please contact Penny McInnis at pmcinnis@lehder.com or (519) 336-4101 ext. 245.

Techincal Standard Posting and O. Reg. 419 Guidance Documents

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Technical Standard Posting

MOECC Techincal Standard Posting June 2015

The Ministry recently posted two proposal notices to the EBR related to Industry Standards.  The public comment period for the following documents ends June 18, 2015.

Amendment to the Foundries Industry Standard

Metal Finishers – Industry Standard

New Guidance Documents

New O. Reg. 419 guidance documents and technical bulletins are in the works, including:

  • Procedure for Preparing an Emission Summary and Dispersion Modelling Report
  • Air Dispersion Modelling Guideline for Ontario (ADMGO)
  • Guideline for the Implementation of Air Standards in Ontario (GIASO)
  • Guide to Requesting an Alternative Standard” (GRAS)
  • Guide To Applying For Registration To The Technical Standards Registry
  • Combined Assessment Of Modelled And Monitored Results (CAMM) as an Emission Rate Refinement Tool
  • Methodology For Using “Assessment Values” For Contaminants With Annual Air Standards
  • Approaches To Manage Open Industrial Fugitive Dust Sources

LEHDER is reviewing the proposed guidance documents and will discuss the details and potential ramifications of the proposed changes in the LEHDER News blog this fall.   For more information, please contact Marnie Freer at (519) 336-4101 ext. 226.