Performance Report – Pollution Prevention Planning Notice for the Polyurethane and Other Foam Sector (except Polystyrene) in Respect of Toluene Diisocyanates (TDIs)

Pollution Prevention (P2) Planning is a process by which organizations can improve their environmental protection by strategically planning to reduce or eliminate pollution before it is created.

 Last updated: October 2015

Performance Report – Pollution Prevention Planning Notice for the Polyurethane and Other Foam Sector (except Polystyrene) in Respect of Toluene Diisocyanates (TDIs) (PDF - 544 KB)

Facilities subject to the P2 Planning Notice for the Polyurethane and Other Foam Sector (except Polystyrene) have prepared and initiated the implementation of their P2 plans.

This report summarizes the information in the first three reports that have been received from those facilities. A final report is expected in the fall of 2016.

Context

In November 2011, Environment Canada published a P2 Planning Notice in the Canada Gazette. The Notice applies to any person or class of persons who, on the date of publication of the Notice or any time thereafter, meets the following two criteria:

(a) owns or operates a facility within the polyurethane and other foam sector (except polystyrene) that, at any time, purchases, imports or uses 100 kg/yr or more of TDIs;

AND

(b) is involved in one or more of the following activities:

• manufacturing of flexible slabstock foam, flexible moulded foam, rigid foam or structural foam
• rebonding of foam

Note that TDI storage and the cutting and shaping of the above-mentioned foams are included in these activities.

Affected persons must prepare and implement a P2 plan, based upon consideration of all the factors to consider listed in the Notice, including determining industrial releases of TDIs to air and keeping their on-site releases to air at or below 100 kg/yr or, alternatively, their TDI concentration in ambient air at or below 0.2 µg/m³. In addition, individual facilities are required to report annually to Environment Canada for four consecutive years.

All of the 14 facilities required to report annually have done so. These reports are available to the public on Environment Canada’s website, and the information presented in this document is derived from these submissions.

Summary of releases

The Notice identifies 2 options for determining industrial releases of TDIs to air. Of the 14 facilities, 8 selected the option to measure or estimate actual on-site releases of TDIs to air, while 6 chose the option to predict TDI concentration at the facility boundaries using modelling. None of the facilities that measured or estimated actual on-site releases of TDIs to air exceeded the threshold of 100 kg/yr. However, 50% of the facilities that predicted their TDI concentration in ambient air surpassed the concentration threshold of 0.2 µg/m³ before they started implementing their actions. As of 2014, all 14 facilities met the quantity or concentration threshold.

All facilities implemented a set of actions to reduce or maintain their emissions under the threshold values stated in the P2 Notice. Overall, 12 facilities completed the actions listed in their plan by November 26, 2014, and the remaining 2 facilities expect to fully implement their P2 plan by the same date of the following year. Of the 12 facilities that implemented their plan, only 3 submitted the “Declaration that a Pollution Prevention Plan Has Been Implemented.” Although this declaration is mandatory, it is not required to be submitted until December 25, 2015. The remaining facilities submitted their second “Interim Progress Report” and will be required to submit the mandatory “Declaration that a Pollution Prevention Plan Has Been Implemented” by December 25, 2015.

Anticipated results for facilities that measured or estimated actual on-site releases of TDIs to air

Based on information submitted, over 213 kg of TDIs were released to air in the Preparation Year (2012), and about 109 kg of TDIs were released during the 2014 reporting year. This represents an overall reduction of 49% of the TDI releases to air in the second year from facilities implementing their P2 plans. These results do not include releases from the six facilities that reported on concentration of TDIs at or beyond the facility boundaries, as concentration cannot be directly related to emissions. Chart 1 illustrates the yearly actual on site releases of TDIs to air for each of the 8 facilities for the past 3 consecutive years since 2012.

Chart 1: Total TDIs on-site emissions by facility

Note that although none of the facilities that measured or estimated actual on-site releases of TDIs to air exceeded the emission threshold of 100 kg/yr by facility, six of them expressed their intent to implement actions to further reduce their emissions of TDIs.

Anticipated results for facilities that predicted TDI concentration in ambient air using modelling

Chart 2 shows the results for maximum 24-hour average concentration of TDIs at the fence line as reported by the six facilities that used modelling to predict TDI concentration in ambient air since the 2012 Preparation Year. All facilities assessed pollution control options and implemented pollution prevention and environmental protection methods to reduce their emissions and keep TDI concentration at the facility boundaries at or below 0.2 µg/m³. This represents an average concentration reduction of 93% for the three companies that were above the concentration target of 0.2 µg/m³.

Chart 2: TDI concentration at the fence line

Releases of TDIs to air as reported in the National Pollutant Release Inventory

While the objective of the Notice is not an overall reduction of industrial releases of TDIs, the implementation of this Notice could have an effect on the overall reduction of releases of these substances to the environment.

Chart 3 shows a chronology of Canadian emissions of TDIs from all facilities that met the reporting threshold for TDIs within the National Pollutant Release Inventory (NPRI) since the assessment of TDIs was initiated by Environment Canada and Health Canada in 2006. Emissions started to decline progressively in 2008, when the substances were found toxic to human health. Additionally, this chart shows the estimated quantity of TDIs used annually in Canada since 2007. Note that although the use of TDIs has not changed much in the last five years, the emissions have been reduced considerably.

Eleven (11) of the 14 facilities reporting to the P2 Planning Notice also reported to the NPRI or have historically reported to the NPRI since 2006.

Chart 3: Releases of TDIs reported to the NPRI and estimated quantity of TDIs used in Canada (dual scale)

Sources: NPRI^{Footnote 1} and adapted from Statistics Canada.

In order to improve the monitoring of emissions of TDIs, Environment Canada reduced the reporting threshold for TDIs for the NPRI from 10 tonnes to 0.1 tonnes (100 kg). This change was implemented in 2014, as published in the Canada Gazette on July 12, 2014. In the 2014 reporting year, three new facilities reported to the NPRI because they were subject to the new reporting threshold. However, it is noted that the total emissions of TDIs have not increased even with these three new reporting facilities. It is still possible that total emissions may increase in the future, but it would be as a consequence of additional facilities reporting their emissions to NPRI (that had not previously been required to report) and not necessarily due to increase of uses and releases of the substances.

P2 actions planned to be taken to achieve the risk management objective

The federal government believes that pollution prevention is the most effective means of protecting the environment, eliminating costly waste and promoting sustainable development. P2 focuses on avoiding the creation of pollutants rather than trying to manage them after they have been created. As a factor to consider in preparing their P2 plans, foam facilities were asked to give priority to P2 activities. In 2012, 79% of the actions completed or planned to be taken by subject facilities during the implementation of their respective plans were P2 methods (Chart 4), of which good operating practices and training led the way (28%), followed by spill and leak prevention programs (24%). Some facilities chose a combination of P2 methods.

Chart 4: Distribution of P2 methods chosen by facilities subject to the Notice to reduce emissions of TDIs

Sources

• Pollution Prevention Planning Online Reporting Tool and Database
• Factsheet for P2 Planning Notice in Respect of TDIs
• Environment Canada. National Pollution Reporting Inventory website
• Adapted from Statistics Canada, Annual Data on Imports and Exports for specific HS10 and HS08 Codes by Country of Origin and by Country of Destination, 2014. This does not constitute an endorsement by Statistics Canada of this report.

Date modified:

2018-01-19