Comments on ERO Registry…

The Ontario Automotive Recyclers Association (OARA) is a voluntary industry association representing 115 professional automotive recyclers across the province. Formed in 1992, OARA Members have been at the forefront of the industry, working with governments, manufacturers, repairers, vendors and allied industries to bring responsible progress to the industry. Our Members are all audited to the Canadian Auto Recyclers Environmental Code (CAREC), developed for Environment Canada for the National Vehicle Scrappage Program. They are also all registered as End-of-Life Vehicle Waste Disposal Sites on the Ministry’s Environmental Activity and Sector Registry (EASR).

John Zubick Limited is a leader in the scrap industry within southwestern Ontario, and should be applauded for bringing their facility in to compliance with the Environmental Protection Act, most notably with the new requirements regarding ELV Waste Disposal Sites.

As the Regulations have been in place since September 2016, it is disappointing that it has taken this long to submit an ECA, and from all we can see, this is only an ECA for waste. We see no ECA or component of this ECA proposal dealing with air issues. The October 2017 MOECC Inspection also noted the lack of an approval for an already operating significant installation. Given they have been operating a shredder for many years, an ECA for air should be forthcoming. In addition, from the input/output information supplied and their desire to operate 7:00 am to 7:00 pm, seven days per week and 365 days per year – they will be exceeding the 50 days per year crushing limit within the EASR requirements, indicating further air and noise related issues that need to be addressed.

The ECA proposal indicates that they will be accepting decommissioned vehicles from other businesses along with Certificates that these have been processed in accordance with the Regulations. They indicate that they will then mix these vehicles with their decommissioned vehicles and issue Certificates when a load moves out. Their Certificate certifies that the ELVs contained in the load have been processed and prepared in accordance with 5.1 of the EPA. In our opinion this will be impossible for Zubicks to certify vehicles they did not decommission. This is not a problem solely applicable to Zubicks – this is a structure problem with the Regulations. However, Zubicks must understand that they are assuming the risk of other operators conforming to the Regulations – something they can only certify if they are conduction regular and thorough audits of their suppliers. If they are doing this, these procedures are absent from the ECA proposal.

The Standard Operating Procedures (SOPs) identified seemed reasonable from an industry best practice review. A few areas of deficiencies: it is not clear if all decommissioning is occurring under cover and on an impermeable surface; there are no procedures identified for disposing of refrigerant through a regulated environment; there are no procedures identified for disposing of mercury or asbestos recovered from ELVs; and there are no procedures identified to record days of crushing.

The supplied contingency plan did not have any procedures to deal with explosions, which is a significant problem with shredders (although that may be covered in their air ECA).