By Mike Davey
Toronto, Ontario -- November 11, 2015 -- The Ontario Ministry of Environment & Climate Change have recently posted updates to the Environmental Bill of Rights (EBR) and announced a second consultation proposal regarding standards for end-of-life vehicle (ELV) processors.
It's common knowledge in the recycling industry that some ELV processing facilities adhere to industry-led standards and already operate in an environmentally protective manner. In fact, adhering to those standards is a condition of membership for the various provincial associations, including the Ontario Automotive Recyclers Association (OARA). However, there are currently no regulatory requirements for the safe removal and management of contaminants from ELVs.
At the same time, past compliance activities undertaken by the Ministry of the Environment and Climate Change have identified environmental concerns pertaining to improper waste management at ELV sites. Bringing forward mandatory regulatory requirements would ensure that environmental management is happening across the whole of the ELV processing sector.
"More progressive recyclers have been modernizing practises to encompass sound materials and parts management. This regulatory proposal could theoretically help bring all ELV processors to meet the same minimum de-pollution and materials management standards," says Steve Fletcher, Executive Director of OARA. "Programs like the Canadian Automotive Recyclers Environmental Code, or CAREC, have meant that subscribers to that standard practice the due diligence needed to recycle vehicles properly and safely. It would seem like logical step to us to have a standard like CAREC apply market-wide as a means to modernize and professionalize the entire industry.”
The proposed approach is to bring forward a range of policy changes that would impose recycling standards in a way that aligns with the ministry of the Environment and Climate Change’s approvals modernization agenda. For example, most of the requirements would be imposed through the Environmental Activity and Sector Registry (EASR) so that consistent standards are applied to the sector through an efficient electronic registration process. The proposal also takes into account the fact that sites may need time to modify their facility operations to meet the new standards. To facilitate the transition to new standards, a phased implementation is proposed.
On February 5th, 2014, the ministry posted a technical discussion paper to the EBR (012-0678) for 60 days to gather comments relating to proposed environmental standards for end-of-life vehicle waste disposal sites. In addition, the ministry hosted public meetings in six Ontario communities to outline the discussion paper and consult with industry.
After a review of the comments received, the ministry is proposing draft regulations that would apply new environmental standards to ELV waste disposal sites. The proposal would amend Regulation 347 (General – Waste Management) made under the Environmental Protection Act (EPA), and create a new regulation that prescribes activities in respect of end-of-life vehicle waste disposal sites that require registration on the Environmental Activity and Sector Registry (EASR).
The draft regulations can be found here. Comments can be received up to December 13, 2015.
The Ontario Ministry of Environment is planning regional consultations with members of industry and the public. OARA will maintain a current list of those dates and locations at oara.com/industry-resources/elv-standards-consultation-2015.