WHAT DO I NEED TO DO?
In Ontario, auto refinish shops need to meet three provincial MINIMUM compulsory compliance environmental standards and they are identified on the next page as:
1) Possession of a valid Certificate of Approval (also called a C of A, air permit or Section 9 (Air) permit).
This is a legal instrument issued by the Director of the Environmental Assessment and Approvals Branch of the Ministry of the Environment that will "permit" a facility to emit certain chemicals (usually in paint coatings or solvents) to the natural environment, using a spray booth, paint spray guns etc. that are identified in the Certificate of Approval letter.
Every autobody, auto collision or auto refinishing facility in Ontario that spray-paint vehicles or parts of vehicles is required to possess a valid Ontario Ministry of Environment Certificate of Approval (Air). This Certificate, often called a CofA, identifies that the air emissions from the shop and at the edge of the property are within specific standards.
A valid Certificate is required for a shop, that is using solventbase OR waterborne paints, if converting to waterborne or any other low-VOC paint product and is also required for any shop that is installing a new booth or making major changes to their current booth that will change their emissions. Shops, that do not yet have any approvals, can apply for a Certificate for both product lines at the same time.
Shops in Ontario, can now take advantage of a new screening tool being piloted by the collision repair trade association in co-operation with the Ontario Ministry of Environment that makes obtaining this mandatory Certificate easier, faster and less expensive.
Because all the calculations needed for emissions reporting are included in the screening tool, the hiring of an engineer or consultant and their costs, can now be a thing of the past for most shops.
A one-page list of questions now replaces the 64-page guide and 51-page interpretation manual.
Application processing is dramatically improved in this new process with the goal of a 6-8 week approval window, compared to many months or even years in the old process.
A required training program that can be taken at the shop or at home is also required and can be completed in a couple of hours.
To get your shop started on the road to legal compliance and better environmental excellence, please call the collision repair trade association at 1 866 309 4272 or firstname.lastname@example.org
The Certificate from the Ministry of Environment will also include the following four requirements:
- that your shop use low VOC coatings product
- that your shop use high-efficiency transfer spray guns
- that you follow a code of practice or maintenance program
- that your shop must show successful completion of a training program for painters and at least one management employee
(Please see CERTIFICATE OF APPROVAL) and ( MANDATORY ENVIRONMENTAL TRAINING )
Call 1-866-309-4272 for a free Certificate of Approval assistance information.
2) Possession of a written agreement with an Ontario-licensed waste hauler
The operator of a retail collision repair shop has a responsibility to ensure that his wastes are handled and disposed of with proper care. In order to be exempt from manifest and registration requirements, the collision shop operator must have a current written agreement for the collection and management of his wastes with a carrier approved under Part V of the Environmental Protection Act for the operation of a waste management system. Failure to have such an agreement would result in the loss of this exemption, leading to requirements for generator registration and the use of manifests for these wastes. The retail collision repair shop operator must at all times have this agreement available for inspection by an Ontario Ministry of Environment and Energy inspector.
Retail collision repair shops must possess a written agreement with an Ontario-licensed waste hauler (please see LICENSED WASTE HAULERS ). As long as the shop has this agreement in place and can prove that specific volumes of paint and/or solvents are being picked up, even if the hauler dumps the wastes improperly, our experience is that the shop will not be charged. The shop must be able to prove by records, which include amounts and dates, that they are using a licensed hauler.
A number of shops have negotiated better priced agreements with haulers for those services in a competitive environment. Your paint company may also have an arrangement with a licensed waste hauler that could be used. We would strongly suggest that your shop investigate the use of a solvent recycler.
3) Reporting of emissions under Ontario Regulation 127/01
Shops are required to meet the conditions of the new Ontario Regulation 127/01 and report by July 1, 2003. This regulation deals with emissions to air from your shop and their measurement. (Please see REGULATION 127/01 ) If your shop uses less than 3000 kilograms of coating materials, paint or solvent in a year, you need do nothing. If your shop uses over 3000 kilograms of coating materials, paint or solvent annually, you need to print out the letter at REGULATION 127/01 , put it on your company letterhead and once signed, mail to the address shown. Your paint supplier can help you determine how much solvent and paint your shop uses in one year. If your shop emits over 10 tonnes ( 10,000 kilograms) annually of VOC (Volatile Organic Compounds) then a separate, more complex report is required and you will likely need professional assistance. Please call the association at 1-866-309-4272 or e-mail email@example.com . A federal requirement called NPRI may also kick-in at this level of emission.
Please also remember that shops that have accidental spills of chemicals, paints, solvents and other materials have a requirement to notify the Spills Action Centre and their local municipality. (Please see SPILLS )