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Refractory Ceramic Fibre Industry
Purpose of the Agreement
To gather actual emission data to determine whether additional controls on RCF emissions are needed and to confirm the commitment of the RCF industry to the establishment and maintenance of a product stewardship program.
Signatories (Period in Effect)
Between Environment Canada and six companies from the RCF industry [Fibercast, Pyrotek Industries, Wolf Steel, Thermal Ceramics, RHI Canada, and CFM Majestic] (Five-year agreement; active from February 20, 2002; expires on December 31, 2006).
To establish and maintain an atmospheric monitoring program requiring each manufacturer and processor to annually monitor RCF emissions. The monitoring program included stack monitoring as well as ambient air monitoring near the boundary of the facility's property, to determine the maximum level of RCF emissions to which a member of the public at ground level could potentially be exposed.
To report releases, transfers and disposals of RCFs to Environment Canada.
To establish and implement procedures to ensure that pollution control equipment is routinely maintained and inspected.
To introduce a product stewardship program within two years of the signing of the EPA.
- Air monitoring program:
- Using an independent consultant, the six participating companies, as well as an additional company that was not a signatory to the agreement, sampled and monitored stack (vent source) air emissions and ambient air concentrations of RCFs in 2002 and 2003. The monitoring showed that fenceline ambient levels of RCFs were very low to undetectable, and that stack emissions of RCFs had low fibre concentrations.
- Under the agreement, this monitoring program was to be in effect for a period of five years, with a review of data after the first two years, to determine whether the monitoring of process stacks should continue for the full five years. Environment Canada and Health Canada reviewed the monitoring results and confirmed that there is negligible health risk for the general public associated with RCF emissions from these plants, and that no further stack sampling was necessary.
- Reporting releases, transfers and disposals of RCFs to Environment Canada:
- Signatories were required to submit an annual report to Environment Canada in respect of RCFs, in accordance with the NPRI reporting requirements published each year in the Canada Gazette Part 1, as though RCFs were a substance listed in Part 1 of Schedule 1 of the NPRI Notices. Five of the six participating companies submitted data to Environment Canada in 2002 using the NPRI Inventory reporting format, and four out of six submitted data in 2003.
- Maintenance and inspection of pollution control equipment:
- The agreement did not include any reporting on inspection of equipment, although results of the air monitoring program suggest that equipment maintenance and inspection programs were adequate.
- Product stewardship programs:
- In 2004, the industry met with Health Canada, Natural Resources Canada and Environment Canada to discuss increasing the sector's participation in a product stewardship program. It was decided that the product stewardship program would be a key focus of a new agreement that would include a greater number of participating companies.
What is product stewardship?
Product stewardship is a cradle-to-grave management system based on industry and consumers taking responsibility for all stages in the life cycle (manufacture, use, storage, reuse, disposal, etc.) of the products that they produce and use. It includes, but is not limited to, measures to prevent pollution, to reduce the burden on waste disposal and recycling systems, and to internalize the cost of pollution associated with products and their packaging.
There is no template for a product stewardship system. Each company should design its own to suit its unique location, products, and overall approach. One company might focus its effort on product redesign to prevent pollution; another might see good potential to recycle its products; yet another might choose a combination of approaches.
- The 2002 Environmental Performance Agreement was a 5-year agreement, but was re-negotiated in 2004-2005 to include additional processors of RCFs identified as meeting the criteria outlined in the 2002 Agreement and to better define the details of the product stewardship program.
- In 2004, Environment Canada proposed that RCFs be added to the National Pollutant Release Inventory (NPRI) to ensure greater consistency in reporting across this industry.
- However, after consultation with stakeholders, Environment Canada concluded that RCFs would not be added to the NPRI list of substances, but that further consultation with industry should be conducted and consideration given to a sector-wide approach.
View more information on the NPRI Multi-stakeholder Working Group on Substances
View a summary of the consultation for the potential listing of RCFs on the NPRI
- A renewed agreement has been drafted, building on the lessons learned to date and emphasizing the development and implementation of a product stewardship program for the sector. The 2006 draft agreement:
- includes the four companies that were not signatories to the first agreement;
- reflects the fact that further stack sampling is not necessary;
- reflects the fact that reporting of RCF releases to the NPRI will no longer be required through this EPA;
- provides more details on what is expected for the product stewardship program;
- adds a requirement for an annual management review of performance with respect to the goals set, progress on continual improvement and corrective actions to address deficiencies;
- adds a requirement for annual progress reporting to Environment Canada;
- includes commitment of signatories to develop jointly with Environment Canada an acceptable verifiable audit process; and
- extends the timeframe for the EPA.
- Once signed, the 2006 agreement will cancel and replace the 2002 agreement. Environment Canada expects to finalize the new agreement in summer 2006.
Head, Controls Development
Industrial Sectors Division
Tél : (819) 953-6984
RCFs were declared "toxic" under the Canadian Environmental Protection Act, by Environment Canada and Health Canada in 1994. These fibres are human-made, and used primarily as insulation in high-temperature industrial applications such as furnace linings, kilns, process heaters, pipe wrapping, welding protection, filters, flame retardants and acoustical insulation. RCFs require full life cycle management, as a Track 2 substance under the Toxic Substances Management Policy, in order to prevent or minimize their release into the environment.
A multi-stakeholder issue table was formed to recommend management options for RCFs. While the risks associated with emissions of RCF into the environment were believed to be low, the issue table proposed that a time-limited monitoring program be established to provide additional trend-line information about RCF emissions (released from vents, outlets or stacks) as well as the concentrations of RCF in ambient air at the property boundaries of each plant to better determine the level of risk to the general population. The issue table also recommended that manufacturers and processors implement a comprehensive product stewardship program. Further information and background on the multi-stakeholder issue table and the management of RCFs are available on the Management of Toxic Substances website.
Responses to Comments
As part of the ongoing consultations on the risk management of refractory ceramic fibres, a draft copy of the 2006 Environmental Performance Agreement with the Refractory Ceramic Fibre (RCF) Industry was posted on Environment Canada's Green Lane for a 30-day public comment period from November 9 to December 8, 2005. Environment Canada received comments on the draft agreement from representatives of the RCF Industry as well as a representative from the Canadian Environmental Network's Toxics Caucus.
After conducting a review of a number of management options, the issue table concluded that the goal and targets for the manufacturing and processing of RCFs could be achieved by a voluntary agreement. The EPA was signed in 2002 to that effect.
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