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Completed Agreements

Environmental Performance Agreement Respecting the Use of Tin Stabilizers in the Vinyl Industry

Full Text of Agreement (PDF; 24 KB)

Annex 1: Guideline for the Environmental Management of Tin Stabilizers in Canada (PDF; 352 KB)
Annex 2: Participating Facility Commitment Form (PDF; 14 KB)

Responses to Comments Received on the Proposed Agreement


Progress Report for 2011


Purpose of Agreement

The purpose of the Environmental Performance Agreement Respecting the Use of Tin Stabilizers in the Vinyl Industry (the Agreement) is to prevent the release of mono- and di-organotin tin stabilizers to the environment, in quantities or concentrations above an acceptable level, through the full implementation of the Guideline for the Environmental Management of Tin Stabilizers in Canada (PDF; 352 KB) by all vinyl compounding facilities using tin stabilizers in Canada.  This Guideline was prepared by the Vinyl Council of Canada (VCC), the Tin Stabilizers Association (TSA), and tin stabilizer industrial users.  The objective of the Guideline is to prevent the release of tin stabilizers to the environment by ensuring that these substances and their packaging materials are handled, stored, used and disposed of in a responsible manner.  As stipulated in Section 5.3 of the Agreement, annual progress reports are to be published on Environment Canada's (EC) website.

Targets

As of March 2011, there were 34 signatories to the Agreement that continued to use tin stabilizers. It must be noted that there have been new signatories to the Agreement as well as some facility closures. The verification program to confirm that the Guideline is being implemented will be conducted at each participating facility during the five-year period (March 10, 2008, to March 9, 2013) provided for in this Agreement. Corrective action plans will be agreed upon for any deficiencies that are still unresolved when the final site visit report is issued.

Reports

The companies are required to present their annual reports to the VCC by completing the “Annual Report on Compliance with the Guideline for the Environmental Management of Tin Stabilizers in Canada” by June 30 of each year. The EC with a consolidated Annual Compliance Report referencing the status of compliance by September 30 of each year. EC is to publish on its website a yearly progress report on the site verifications. This is the third yearly progress report. The progress reports for 2009 and 2010 are also available.

Results

Update for March 10, 2010, to March 9, 2011, Verification Period:

A team consisting of a representative from the VCC and an EC official did the verifications. Following the verifications, site visit reports are prepared by the VCC with the concurrence of EC.

The following summarizes the verifications that were made during the verification period of March 10, 2010, to March 9, 2011. Any relevant updates from March 10, 2011, to the end of July 2011 is presented and specified as such. During this verification period, eight site verifications were conducted in order to determine the Guideline implementation status of the facilities.

  • June 18, 2010 (Roytec Vinyl located in Woodbridge, Ontario): The verifiers found no areas for improvement as per the implementation of the Guideline for the Environmental Management of Tin Stabilizers in Canada; therefore, no corrective action plan was required.
  • September 23, 2010 (Solucor located in Bradford, Ontario): The verifiers found four areas for improvement as per the implementation of the Guideline for the Environmental Management of Tin Stabilizers in Canada. Confirmation was provided that the four areas identified for improvement were already addressed before submission of the final report; therefore, no corrective action plan was required.
  • November 16, 2010 (IPEX located in London, Ontario): The verifiers found one area for improvement as per the implementation of the Guideline for the Environmental Management of Tin Stabilizers in Canada. Following the verification period, confirmation was provided that the area for improvement was addressed; therefore, no corrective action plan was required.
  • November 18, 2010 (Royal Pipe Systems located in Woodbridge, Ontario): The verifiers found three areas for improvement as per the implementation of the Guideline for the Environmental Management of Tin Stabilizers in Canada. Following the verification period, confirmation was provided that the three areas for improvement were addressed; therefore, no corrective action plan was required.
  • December 7, 2010 (IPEX located in Edmonton, Alberta): The verifiers found no areas for improvement as per the implementation of the Guideline for the Environmental Management of Tin Stabilizers in Canada; therefore, no corrective action plan was required.
  • December 8, 2010 (Kaytec Vinyl Inc. located in Carstairs, Alberta): The verifiers found a number of areas for improvement as per the implementation of the Guideline for the Environmental Management of Tin Stabilizers in Canada. An action plan may be required pending the review of material submitted by the company.
  • February 23, 2011 (REHAU Industries located in Winnipeg, Manitoba): The verifiers found two areas for improvement, as per the implementation of the Guideline for the Environmental Management of Tin Stabilizers in Canada. Following the verification period, confirmation was provided that the two areas for improvement were addressed; therefore, no corrective action plan was required.
  • March 9, 2011 (Georgia Gulf Compound located in Concord, Ontario): The verifiers found eight areas for improvement, as per the implementation of the Guideline for the Environmental Management of Tin Stabilizers in Canada. Following the verification period, confirmation was provided that the eight areas for improvement were addressed; therefore, no corrective action plan was required.

Update for March 10, 2008, to March 9, 2010, Verification Period:

During this verification period, nine facilities were verified, eight of which had fully implemented the Guideline. The following is an update up to the end of July 2011, on the status of the two facilities identified in the 2010 annual progress report as requiring follow-up activities.

  • July 8, 2009 (Royal Flex Lox Pipe located in Abbotsford, British Columbia): The verifiers found a number of areas for improvement as per the implementation of the Guideline for the Environmental Management of Tin Stabilizers in Canada. Most of the areas for improvement have now been addressed and the company is implementing the final elements of its corrective action plan.
  • December 8, 2009 (Plastique Reinier located in Marieville, Quebec): The verifiers found four areas for improvement as per the implementation of the Guideline for the Environmental Management of Tin Stabilizers in Canada. Confirmation was provided that the four areas identified for improvement were already addressed before submission of the final report; therefore, no corrective action plan was required.

Next Steps

Verifications will continue to be carried out in order to ensure all facilities subject to the Agreement are verified during the five-year term of the Agreement. The next progress report will be published in fall 2012.

Contact

Plastics Unit
Chemical Production Division
Environment Canada
351 St. Joseph Blvd., 11th Floor
Gatineau, QC K1A 0H3
Email: pgpc-cmp.dppc-cpd@ec.gc.ca

Background

In 2004, the VCC and TSA introduced a voluntary tin stabilizer handling Guideline to prevent the release of tin stabilizers to the environment by ensuring that these substances and their packaging materials are handled, stored, used and disposed of in a responsible manner.  On November 18, 2005, EC proposed developing an Environmental Performance Agreement with the VCC and the TSA to ensure full industry compliance with the Guideline.

On April 23, 2007, EC published a draft Follow-up to the 1993 Ecological Risk Assessment of Organotin Substances on the Domestic Substances List. The draft assessment report concluded that the actions implemented by the vinyl industry have reduced the potential for releases of mono- and di-organotins to levels that are not of concern to the environment. These actions are codified in the Guideline prepared and implemented by the VCC and TSA.  On August 8, 2009, the Final Follow-up Assessment Report on Non-Pesticidal Organotin Compounds concluded that mono- and di-organotins do not meet the criteria set out in section 64 of the Canadian Environmental Protection Act, 1999 and are therefore concluded to be not toxic.

EC worked with industry between 2006 and 2008 to establish an Environmental Performance Agreement.  The purpose of the Performance Agreement is to prevent the release of tin stabilizers to the environment, in quantities or concentrations above an acceptable level.

Responses to Comments

The draft Performance Agreement was posted on Environment Canada's Environmental Performance Agreements website for a 60-day public consultation period, which ended on June 22, 2007. The only comments received pertained to general questions of clarification (PDF; 17 KB). As a result, no revisions were made to the draft Agreement.

The Agreement was signed by representatives from Environment Canada, the Vinyl Council of Canada and the Tin Stabilizers Association on March 10, 2008.

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