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Performance Summary Report: The 2006 Refractory Ceramic Fibre (RCF) Environmental Performance Agreement
In 2006, a five year Refractory Ceramic Fibre (RCF) Environmental Performance Agreement was negotiated between Environment Canada and the following nine companies from the RCF industry:
- CFM Majestic,
- Canadian Ferro Industries,
- Fibercast Inc.,
- Gemcast Manufacturing Inc.,
- Pyrotek Industries Inc.,
- RHI Canada,
- Thermal Ceramics,
- Tremco Canada Division R.P.M. Canada, and
- Wolf Steel.
Two of these companies, CFM Majestic and RHI Canada had ceased operation by the end of the agreement in 2007 and 2010, respectively.
The Agreement required companies involved in the manufacturing or processing of RCFs to:
- submit an annual report to Environment Canada including the results of fenceline air monitoring, confirmation of the annual management review of RCF emission controls, and a description of the Product Stewardship Program elements that were adopted; and
- participate in a verifiable audit process.
The following summarizes the results achieved under the agreement based on the verification audits and the annual reports sent to Environment Canada by participating companies.
Annual report results
Canadian Ferro Industries, Fibercast Inc., Pyrotek Industries Inc., Thermal Ceramics, Tremco Canada Division R.P.M. Canada and Wolf Steel provided annual reports throughout the life of the agreement. Gemcast Manufacturing Inc. provided reports in 2007 and 2009. RHI Canada provided one report in 2007.
a) Air monitoring program
Annual fenceline ambient air monitoring was to be carried out from 2006 to 2010 by participating companies under the agreement to ensure that the maximum allowable fenceline concentration of RCFs in ambient air is not exceeded.
Fenceline monitoring for all participating companies has consistently shown levels of airborne RCF significantly below the maximum allowable fenceline ambient air concentration of 0.05 fibres/cc. Gemcast Manufacturing Inc. and RHI Canada each conducted only one year of monitoring, with results showing no detectable levels of airborne RCF. All other participating companies submitted annual reports as outlined in the agreement.
b) Maintenance and inspection of pollution control equipment
All participating companies have procedures to ensure that pollution control equipment is routinely maintained and inspected (weekly, monthly or at least every four months) and repaired in a timely manner, and that records of inspection and maintenance are kept for at least 5 years.
c) Product stewardship programs
Each participating company has a Stewardship Program in place, which includes, but is not limited to:
- the use of engineering controls;
- handling practice modifications and personal protective equipment for the purpose of controlling exposure to airborne RCF; and
- education of employees and promotion of guidance materials to customers on RCF stewardship.
Furthermore, all operating companies have decreased or eliminated the use of RCF in some products, opting for non-toxic substitutes (e.g. soluble fibres).
Verification audit results
In order to ensure the terms required under the agreement were satisfied, verification audits were conducted from June 2010 to December 2010 by Environment Canada personnel from the Ontario, Quebec, and National Capital Regions.
The verification team visited all operating participating companies and reviewed the following:
- documentation on procedures, equipment maintenance, management review and company product stewardship programs;
- equipment located inside and outside of the facility building;
- workspaces including the use of protective measures by employees; and
- information related to RCF emissions testing.
Verifiers determined that all facilities satisfied the requirements related to maintenance and inspections of pollution control equipment and the product stewardship program.
Based on the results of the verification audits and annual reports submitted to Environment Canada over the lifetime of the Agreement, six companies fully conformed with the terms of the agreement, and were able to maintain RCF levels in ambient air that were significantly below the maximum allowable concentration of 0.05 fibre/cc. Two companies met these objectives for the year they monitored. However they failed to provide all annual reports as required under the agreement. The audit of these two companies verified that they satisfied the other requirements of the agreement.
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