Ontario’s Toxics Reduction Act


Owners and operators at companies in Ontario have increased environmental reporting and planning obligations under the Toxics Reduction Act (TRA).  Facilities in a prescribed sector (NAICS code commencing with “31,” “32,” “33,” or “212” that process minerals) are required to report under the Ontario TRA.  The chemicals that must be reported in the TRA are those chemicals found on (Environment Canada’s) National Pollutant Release Inventory (NPRI) list.  Additionally, facilities are required to report for acetone under O.Reg.127/01, which is not on the NPRI list.

For those who are required to develop a TRA Plan (Plan), your Plan must include an approach to reduce each substance.  It is important to note that while the Plan is required, the implementation is voluntary.

There are seven acceptable reduction options:

  1. Materials substitution
  2. Product  design or reformulation
  3. Equipment or process modification
  4. Spill or leak prevention
  5. On-site reuse or recycling
  6. Improved inventory management and purchasing techniques
  7. Training or improved operating techniques

Some key points to consider include: “no reduction” can also be an option; in other words, there may not be a suitable option to reduce the amount of a toxic chemical.  Your Plan is based on the previous year’s data. The Plan will be kept at your facility (one plan per facility), and there is no prescribed format.   Keep in mind the Plan must be certified jointly by a Toxic Substance Reduction Planner and by the highest ranking employee at the facility.

Some key upcoming dates to keep in mind:  For facilities subject to the TRA, a Plan Summary is to be submitted to Ministry of the Environment and provided to the public by December 31, 2012.  An annual report must be submitted to the Ministry by June 1, 2013.

These are just a few considerations as you prepare for your TRA Compliance requirements. If you have question or need assistance with your TRA Compliance, contact Christopher Paré (cpare@dragun.com) at 519-979-7300.

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