Since the deadline for Toxic Reduction Act (TRA) plan summaries is soon approaching, ERA is helping manufacturers find the answer to the question “What exactly goes into a Toxic Reduction Plan?” This article is the second half in our Toxic Reduction Plan series. If you haven’t read the first part, or just need a refresher, you can read it here.
This article will explain what type of information needs to be included in the last sections of the Toxic Reduction Plan, as outlined by the Canadian Ministry of the Environment (MOE). To make things as simple as possible for reporters, the MOE has provided some clear guidelines about what they expect to see in a Toxic Reduction Plan.
You should note that each of the sections outlined in this Toxic Reduction Plan series will need to be written out for each toxic substance. That means facilities with a high number of regulated toxic substances will probably have a lot of overlap between the each of their Toxic Reduction Plans.
Remember - once you've written your Toxic Reduction Plan you need only submit a summary of the plan.
You can find out if you’re required to submit a Toxic Reduction Plan summary and learn more about the December 31, 2012 deadline by reading our basics of the TRA article here. It covers everything you’ll need to know to discover if the regulation applies to you and what that means for your business.
Options to Reduce
This section probably requires some of the most thought and research to be done correctly. In it, you’ll need to describe all of the options being considered by your facility for reducing the emissions and/or creation of the toxic substance covered by the plan.
There are several options that are worth considering, and your licensed TRA planner will be able to help you determine which apply to your situation. For some toxics, you may find the best option is to install a new control technology, which could drastically cut back on your toxic outputs. You could also replace old equipment which may not be operating at peak efficiency.
If you purchase or use a lot of toxic materials, one of your best options will be to find a non-toxic alternative product (known as Environmentally Preferable Purchasing, or EPP). Generally speaking, this is the easiest and most cost-effective option for most facilities, but it requires a lot of preparation and research. You’ll need to determine which alternatives you can use, then perform a thorough cost analysis for each one, and finally do some emissions forecasting to see if the new substance would actually hurt or help your environmental impact.
Regardless of which options you choose to consider and include in your report, you will also need to include your calculations & estimates for how much each option would reduce the toxic emission/use by.
In addition, you’ll also need to include an analysis of the economic feasibility of the options you are considering, as that will play a big role in how successful your Toxic Reduction planning is. While it’s nice to report you’ll be able to reduce toxic emissions down to 1% using an expensive new control system and all new equipment, if that cost of implementing the plan is prohibitively expensive it shows your planning hasn’t been realistic or taken seriously.
Now that you’ve listed out and analyzed your options, it’s time to put those plans into motion. For every reduction option you’ve chosen, provide an action plan that includes the steps you will take, along with timelines for each step and when you plan on having toxic emissions reduced by. You’ll also want to include by how much each step or goal will reduce your target toxic emission.
You also have the option of choosing none of the reduction options, however you will need to provide some solid justifications as to why not. For example, if you outline in the previous section why none of the options is economically feasible or that your process simply cannot use any other substance, you can cite those as reasons.
Although this section is one of the most open ended and entirely up to you, it is also one of the most important: it will set out the actions you’ll be taking for the next months and years. It’s worth taking the time to create an achievable action plan that will reduce your toxic emissions in the most cost efficient way possible.
Note that currently there are no enforcement actions written into the TRA against facilities that choose not to follow the action plans they have written. Actual implementation is optional – for now.
Recommendations from your Planner
While working with your licensed TRA planner(s), as is required by the Toxic Reduction Act, they might make some recommendations and suggestions. If the planner has made any, they need to be included in this section.
As with most regulatory reports and environmental documentation, your Toxic Reduction Plan will need to be signed off on by authority figures from your facility. The highest ranking employee, most likely your facility manager or even a CEO if they have offices attached to the facility, as well as a signature from the toxic reduction planner(s) that worked with you.