Ontario Toxics Reduction Act
Ontario’s Toxics Reduction Act (TRA) came into effect January 1st, 2010. This regulation requires thousands of Ontario manufacturers to report to the MOE
Pinchin’s qualified and experienced team can help with:
- customized compliance programs
- show you potential cost savings and environmental benefits
Toxics Reduction Act, O. Reg. 455/09 Designed to Reduce Front-End Toxic Substances
Starting Jan. 1, 2010, the Toxic Reduction Act (TRA) requires many Ontario manufacturers to prepare and publish certified toxic substance reduction plans, although the implementation of these plans is voluntary. The Ministry of the Environment’s goal is to reduce the creation, use, release and/or off-site transfer of toxic substances and to encourage greener alternatives, including new technologies.
The TRA focuses on reducing the front-end production of toxic substances in the manufacturing process: it’s designed for pollution control, not prevention. It’s anticipated that approximately 2,000 Ontario companies must now account for any toxic chemicals manufactured, processed or incidentally produced at their facilities.
Specifically, TRA Regulations Require Companies to:
- Track and quantify the toxic substances they use, create and release
- Develop plans, including options to reduce their use of toxic substances
- Make summaries of their plans available to the public
- Report to the ministry on their progress in reducing toxic substances and make certain information available to the public
What is a Toxic Substance?
A toxic substance is one that has the potential to cause harm to living organisms. For the purpose of the TRA, this includes all substances in Schedule 1 of the National Pollutant Release Inventory Notice (NPRI Notice) (Parts 1 to 5) plus acetone. A complete listing is available at http://canadagazette.gc.ca/rp-pr/p1/2008/2008-02-16/pdf/g1-14207.pdf
TRA Affects All Facilities Identified by NAICS Codes 31, 32, 33 and 212
The list of included raw material and manufactured products is very broad and mirrors the NPRI list. It ranges from food and beverages to chemicals, pharmaceuticals, metals, woods, resins, plastics, coatings, non-metallic minerals, transportation equipment and parts and many others.
If you report to the NPRI, chances are that you will have to report to the TRA. If the NPRI reporting thresholds are met, the owner/operator of the facility - and this includes companies with as few as 10 employees - must prepare a Toxics Substance Reduction Plan certified by the facility’s highest ranking employee with management responsibilities, as well as an accredited Toxics Reduction Planner.
If you aren’t sure of your NAICS (North American Industry Classification System) code you can access a full listing at http://www.statcan.gc.ca/subjects-sujets/standard-norme/naics-scian/2007/list-liste-eng.htm
First Report on Priority Toxic Substances Due June 1, 2011
For toxic substances labeled as “priority” in the TRA, a report was due June 1, 2011, for the calendar year 2010. Facilities must have developed their toxic substance reduction plan by December 31, 2011. Summaries of the plan will be made available to the public.
Facilities that use or create a substance listed in the NPRI, but is NOT listed as a priority substance, will provide their first report to the MOE by June 1, 2013, covering the calendar year 2012. Summaries of the plan must be made available to the MOE and the public by December 31, 2013.
Not Just Another Reporting Chore: Environmental and Bottom-Line Benefits are Achievable
Beyond the obvious benefits of toxic substance reduction that include reduced worker, consumer and environmental exposure to toxics, there are a number of potential bottom line savings, including:
- Lower material feed costs
- Lower waste disposal costs
- Potential increased sales because of consumer “green” demand
The TRA will also force many companies to perform an in-depth analysis of their processes, asking one vital question: “Why do we do things the way we do?” Given the detailed process characterization and reporting requirements this question demands, many companies will need help in becoming compliant. Pinchin Environmental’s experienced team of professional engineers and technologists can help you to become TRA compliant - and use the TRA to your bottom-line benefit.
Pinchin is currently the only company in Canada to have a Toxics Use Reduction Planner on staff, certified by the Massachusetts Department of Environmental Protection. In 1989, Massachusetts was the first U.S. state to pass a comprehensive toxics use reduction act, emphasizing pollution prevention. Over a nine-year period, the state reduced their use of toxic by-products by 69% and use of toxic chemicals by 45%.
We have the experience, qualifications and resources to help you become compliant - and move beyond into achieving significant environmental and financial savings.
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