Comment
HRAI is requesting that the Ontario MECP remove the 90% RER requirement for mercury-containing thermostats from the HSP Regulation (O. Reg. 449/21) and replace it with a more appropriate 20% RER to ensure thermostat producers are in regulatory compliance, based on kg of metals recycled vs total weight (kg) of metal, glass, plastic and mercury recovered from thermostats. Metals are the only component of the thermostat that is recycled.
All of the mercury recovered from Category C mercury-containing thermostats is sent to Bethlehem Apparatus located in PA, USA where the mercury undergoes a stabilizing treatment process which converts elemental mercury into mercury sulphide, rendering it safe for disposal in a specially engineered permitted landfill. Once the mercury is processed by Bethlehem it is shipped back to Canada for safe disposal at Stablex Canada Inc. located in Quebec. The retirement process aims to remove mercury from the environment and safely dispose of it, not to recycle it and reintroduce it as raw material in product manufacturing.
Please refer to attached document to support this comment.
Kind Regards,
Kathleen O'Malley
Manager, Environmental Services
HRAI
Supporting documents
Submitted October 18, 2024 5:07 PM
Comment on
Amendments to four producer responsibility regulations for tires, batteries, electrical and electronic equipment, and hazardous and special products
ERO number
019-8866
Comment ID
101138
Commenting on behalf of
Comment status