The deadline for submitting Ontario Toxic Reduction Act (TRA) plan summariess is December 31, 2012. To help out those facilities subject to this act, ERA is answering the question “What exactly goes into a Toxic Reduction Plan?” in this two part series.
Remember - once you've written your Toxic Reduction Plan you need only submit a summary of the plan.
You can find basic information about the TRA including who is affected in our introductory article.
About Toxic Reduction Planning
The Canadian Ministry of the Environment has prepared some specific guidelines about what needs to go into your Toxic Reduction Plan. The process is designed to be as simple as possible and you should already have a lot of the required information on hand through your other environmental record keeping and other regulatory obligations.
Submitting a Toxic Reduction plan summary is not optional. However, at the moment there is no federal or provincial requirement that you complete all of the action plans or achieve all of the targets that you write into your Toxic Reduction Plan.
Currently, the Toxic Reduction Act is simply being used to ease Ontario manufacturers into the process of reducing toxic substances. However, it is expected that in the coming years Canadian regulations will begin to strictly enforce Toxic Reduction Plan targets.
When preparing your Toxic Reduction Plan, you should follow the nine sections laid out by the Canadian Ministry of the Environment (MOE). Note that each section of the plan should be carried out for each toxic substance. For facilities using or creating more than toxic substance, this means there could be a lot of overlap between the multiple Toxic Reduction Plans you submit.
This section should contain all the background information about your facility that any regulators would need to determine your intake and output of toxic materials. You’ll need to include a list of contact people (like your head environmental manager or other point person, a chief signing officer, and facility manager), as well as the name and license number of your toxic reduction planner(s) involved in the process.
It’s also essential that this section lists every single toxic substance that gets used in or created by your processes. Failing to include all regulated toxic substances covered by the Toxic Reduction Act will cause you to be noncompliant with the regulation.
Your Intent, Objectives, and Targets
Here’s where you’ll write a brief statement about your facility’s intent to reduce the use and creation of the specific toxic substance. Alternately, you can choose not to submit a statement about your intent to reduce the use of this toxic substance, although you will need to submit the reasons for this decision (and they will need to be very good reasons).
In addition, for each substance, you will need to need to create a list of specific objectives and targets (concrete numbers and details are definitely preferable here). For example, you may set the target to reduce formaldehyde used in your processes by 10% over the next year, and to bring levels down another 15% the year afterward.
There is no formal penalty for not meeting these targets - however you must still create achievable goals.
How and Where the Toxic Substance Gets Used
Include information about your facility’s stages as well as a description of all processes that the toxic chemical is involved in. This will need to include process flow diagrams and any other visual representations of the substance’s flow through your facility’s processes.
This section is all about understanding where each toxic substance gets used so that you, your planners, and any regulators can identify opportunities for reductions and just get a better picture of why you are using that substance in the first place.
Toxic Substance Accounting
This section is dedicated to detailing your Toxic Substance Accounting processes that you will do for each toxic substance. The MOE requires all facility managers to do toxic substance accounting using the following guidelines:
- Develop a comprehensive procedure to track and quantify toxic substances at the process level.
- Generate the information needed to understand the use and creation of toxic substances (which means you are actually capturing data using some sort of system or regular record keeping system).
- Establish a baseline you can use to track your reduction progress.
In this section of the plan, you’ll need to also include the calculation methods, equations, and any constants that you’ll use in determining your outputs and how you’ll calculate reductions.
If the input of the toxic substance and the outputs of the substance are not equivalent, you’ll need to give the reasons why.
Provide an estimate of your facility’s yearly direct and indirect costs related to the toxic substance. Be sure to include information about the cost you have related to shipping out or treating the toxic waste, as this will be one of the biggest areas you’ll see cost savings after you begin to reduce your use of the substance.
In our next Toxic Reduction Planning article we’ll cover the final sections of your Toxic Reduction Plan: reduction options, implementation plan, planner recommendations, and certifications.
October 29, 2012