The June 1st deadline for environmental reporting less than a week away. Many facilities may find that in addition to annual reports, they may have Toxic Reduction Act (TRA) related obligations throughout the rest of the year.
The TRA in many ways is still new, and as a result we find many clients have questions as they deal with the complexities of the act and regulation.
With this in mind, provided below are some common questions we receive.
If you have any questions please contact Ajay Madan, P.Eng., TSRP by phone 905.363.1462 or Toll free at 1.855.746-2446 ext 1462 or use the Contact Us Form
Frequently Asked Questions
Q: Will I have to update my Toxic Reduction Plan?
A: The TRA and regulation under the act requires manufacturing facilities in Ontario to prepare annual reports and toxic substance reduction plans if specific criteria are satisfied. These reporting criteria are aligned with the National Pollutant release Inventory (NPRI). Several hundred chemicals were phased in back in 2012 and 2013. Many facilities have questions on whether they need to update these plans every year. The answer is no, not unless you trigger the requirements to update your plan which are listed below. Assuming you do not trigger one of these requirements, plans are updated every 5 years, with the next review year being 2018.
Q: What conditions would trigger the requirements to update a Toxic Reduction Plan?
A: A plan is required whenever a reporting threshold has been exceeded if:
- it is a plan review year (i.e., 2018),
- a plan has not been previously prepared for that substance,
- if a plan was prepared for a substance, but has been non-reportable for 3 or more years because reporting thresholds were not satisfied, and is now reportable again,
- if during the time the time the substance was non-reportable a mandatory plan review year has passed (i.e., 2018), or
- there was a significant process change at the facility.
If the facility does not meet any of these requirements an updated plan or a new plan would not be required. However, a plan can be updated or developed voluntarily by a facility at any time.
Q: What can I do if a Plan is required this year?
A: If you are an existing Pinchin client and we are preparing your annual environmental reports, we will notify you if a plan is required. If you are new to Pinchin, we will review with you the conditions for planning to ensure a plan is indeed required. If a plan is required, we can issue a quote for planning services. If you are new to environmental reporting and TRA reporting and planning we will work with you to evaluate your reporting obligations and step you through the process. It is important to note that the earlier the planning process begins, the more time you will have for the evaluation of reduction options. All new or revised Toxic Reduction Plans are due December 31st.
If you have any questions please contact Ajay Madan, P.Eng., TSRP by phone 905.363.1462 or Toll free at 1.855.746-2446 ext 1462 or use the Contact Us Form
