A further enhancement to the…

A further enhancement to the O. Reg. 455/09; with reference to item 3, 'Simplifying the toxic substance plan review process' and possibly item 2, 'Modifying the planning process to focus on technically feasible options' of the "Proposed Amendments to O. Reg. 455/09"; that would further significantly reduce the burden, and therefore, costs to some companies to update their TRA Reduction Plans by December 31, 2019, would be that they can simply indicate there would be no change to or nothing to update in their TRA Reduction Plans, therefore, no update will be needed. This could specifically only apply to those reporting companies that indicated in their original TRA Reduction Plans that nothing feasible could be done to reduce the MPO use of "all" their reported substance. Or it could apply to any MPO reportable substance that a company had in their

TRA Reduction Plans.

We are a jobbing shop and we machine precision components to our customer's specifications, which includes the material to use. There can be various reasons why the customer specifies a specific material and our customer would only be interested in changing material if it meant the part would be cheaper. However, the customer would only change if the proposed alternative material would meet their strength, durability and other criteria of their design. Typically, cheaper to make means easier to machine material and that means a material that probably has one or more TRA reportable substance; as one example materials that contain, or contain a higher percentage, of lead.

An extreme scenario of total elimination of certain substances, equates to going out of business. No advantage to the environment, since the competition, possibly a smaller size company that does not have to report to TRA nor complies with the same environmental requirements as they should, would still be making the part from the same material as we were. Even worse, the customer imports the parts from overseas, which could contain more hazardous substances! Reduction is not the desired scenario; increase is the desired scenario, as it means more business, more profits! 

In all cases we recycle as much as possible by sending the turnings, scrap parts, and non-conforming parts back to the supplier for them to re-melt and make into more material. Virtually 100% recycle and reuse!

Understandably, completing the TRA Reduction Plans initially was a pure expense, with zero return since there was nothing that could be done to reduce the MPO use of any of the reportable substances reported. To go through the TRA Reduction Plans updating process by December 31, 2019, like the initial TRA Reduction Plans, would be a pure expense with zero return again. Can there be an enhancement to the TRA Reduction Plans, so it would be allowed to simply check a box in the NPRI on-line reporting under the TRA section  to indicate, "There is still no feasible solution to reduce the MPO use of this reportable substance. Therefore, there is no change to the last TRA Reduction Plan, and as such, no updated TRA Reduction Plan will be issued nor is required." Therefore, an updated TRA Reduction Plan and Certification by a Toxic Substance Reduction Planner will not be required for that substance. This would only be applicable to a reportable substance a company reported, in their initial TRA Reduction Plan, that it is not feasible to reduce the MPO use of that reportable substance. Or this could only apply if 'all' substances reported by a company are not feasible to reduce the MPO use, then no new TRA Reduction Plan and Certification by a Toxic Substance Reduction Planner will be required. Therefore, the original TRA Reduction Plan for the reportable substance flagged or the TRA Reduction Plans for 'all' the reportable substances will be deemed to be re-dated and valid for another 6 years. This would significantly reduce the burden and costs to those companies that will not be able to reduce the MPO use of a reportable substance or reportable substances. Every substance reported would have a separate check-box. The highest ranked employee would certify this in the usually manner.

Another completely different issue, remove the need to post a 'signed' copy of the TRA Reduction Plan on the company's website for reasons of fraud. Post a 'non-signed' version, just not a 'signed' version. We started to get fraudulent cheques showing up with the same signature of the 'most senior officer' that was on the posted NPRI report, so neither of our NPRI reports or TRA Reduction Plans posted have any actual signatures in them.

[Original Comment ID: 210826]