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Refractory Ceramic Fibre Industry
Purpose of the Agreement
The purpose of the refractory ceramic fibre (RCF) performance agreement is to establish a maximum allowable fenceline concentration for RCFs in ambient air, establish monitoring and reporting requirements for RCF emissions, promote inspection and maintenance of pollution control equipment and confirm the commitment of the RCF industry to establish and maintain a product stewardship program.
Signatories (Period in effect)
The EPA has been negotiated between Environment Canada and 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]. This is a five year agreement that commenced on October 23, 2006 and expires on October 23, 2011.
To respect the maximum fenceline concentration of 0.05 fibres/cc.
To establish and maintain an air monitoring program requiring each manufacturer and processor to annually monitor RCF emissions.
To establish and implement procedures to ensure that pollution control equipment is routinely maintained and inspected, repaired in a timely manner and that records of inspection and maintenance are kept for at least 5 years.
To require participation in the Refractory Ceramic Fibres Coalition (RCFC) Product Stewardship Program (PSP) by adopting key elements such as the use of engineering controls, handling practices and protective equipment to control exposure to airborne RCF; education of employees and promotion of guidance materials to customers on RCF stewardship; as well as participation in site visits from the RCFC.
To require an annual management review of RCF pollution control equipment to ensure implementation of corrective actions and to submit a RCF Annual Report Form to Environment Canada by June 1st of each year.
To assist in developing and participating in a verifiable audit process for the agreement.
- 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. Fenceline ambient air monitoring will continue under the 2006 agreement to ensure that the maximum allowable fenceline concentration of RCFs in ambient air is not exceeded.
- Maintenance and inspection of pollution control equipment:
- The 2002 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. Further information on pollution control equipment maintenance, inspection and repair will be gathered and reported under the 2006 agreement to ensure continued implementation of these programs.
- 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 the renewed agreement.
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 their own stewardship system to suit their unique location, products and overall approach. One company might focus its effort on product redesign or process changes to prevent pollution whereas another might focus on recycling.
- Performance Summary Report: The 2006 Refractory Ceramic Fibre (RCF) Environmental Performance Agreement (PDF; 79 KB)
- Implementation of the renewed 2006 agreement.
- Monitoring and reporting of information required under the agreement.
- Completion of a verification audit of each company during 2008 to ensure compliance with the performance requirements and objectives in the renewed 2006 agreement.
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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.
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 first EPA was signed in 2002 with six RCF manufacturers and processors to establish and maintain monitoring of stack (vent sources) and ambient air concentrations of RCF emissions at the property boundaries of facilities, to determine the maximum level of RCF emissions to which a member of the public at ground level could potentially be exposed. The 2002 agreement also required reporting of RCF releases, transfers and disposals, implementation of procedures to routinely maintain and inspect pollution control equipment and the introduction of a product stewardship program.
The results of the 2002 agreement informed the renewal of the agreement in 2006. The 2006 agreement builds on the lessons learned in the first agreement and emphasizes the development and implementation of a product stewardship program for the sector. The 2006 agreement:
- includes three additional 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.
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