Facility Inspection Reports
Summer seems to be the time that the Ministry of Environment & Climate Change (MOECC) is conducting Facility Inspection Reports. These inspections are intended to determine whether the facility has an environmental compliance approval (ECA), or if additional sources (i.e. new equipment or stacks) have been added since the last approval. Facility inspection reports look at all media: Air, Noise, Water, and Waste. Quite often overlooked, if your facility is located near a residential area, you may also be required to prepare an Acoustic Assessment Report in addition to the ECA application for Air.
So what are Facility Inspection Reports all about?
The MOECC has divided Ontario into five regions (Northern, Eastern, Central, West Central, and Southwestern) see map below.
Every year, each region is responsible for policing environmental enforcement within their boundaries. As environmental regulations change, each year the MOECC has a different set of priorities. In the past, we’ve seen things like Schedule 5 compliance with Environmental Compliance Approvals, checking on Toxics Reduction Plans, etc. In addition to these regulatory checkups, each year the MOECC seems to target a specific sector for compliance. In recent years it’s been the plastics sector, automotive manufacturing, and steel manufacturing sectors that got paid visits.
How does the MOECC determine which facilities to send their environmental enforcement officers to? That’s a mystery, but we see them pull facility contact information from a number of sources:
- Industry Canada – this has statistics on just about every company in Canada
- National Pollutant Release Inventory – the NPRI has a list of companies that have reported they have met the reporting criteria based on chemical usage
- Access Environment – MOECC’s registry of Environmental Compliance Approvals, Permits to Take Water, Renewable Energy Approvals, EASR, etc
Every business has an NAICS code which identifies the type of activities the facility is engaged in. These 6 digits codes help the MOECC to determine what type of environmental approvals a company should have.
What triggers an inspection from the MOECC?
It can be complaints driven, and in the case of nuisance issues such as dust, odour, or noise it is fairly common that if the MOECC will investigate. Perhaps your operations fall within a sector that is getting targeted this year, or the MOECC is following up because they should have received an amended ECA application years ago, but nothing was submitted in their system. However, quite often the inspections are random. If an MOECC officer shows up to your facility, you are legally required to let them onsite to inspect. Some officers’ call in advance to make an appointment, others just randomly show up. You never know what you are going to get.
How to be prepared for a Facility Inspection?
In an ideal world, you would have all your Environmental documents and approvals filed neatly on a shelf. The reality is most companies have a scattering of information from various consultants, some of it is printed out, some of it is stored electronically, and like most some is either missing or not done. Rubidium can help keep you prepared for the eventual visit with the MOECC. Our compliance services, such as Environmental Audits, and Gap Analysis can determine what you are missing, and what needs to be done.
The big ticket items for the environmental enforcement inspectors always seem to be:
- Environmental Compliance Approval (ECA) – Air
- Environmental Compliance Approval (ECA) – Industrial Sewage Works
- Permits to Take Water
- Hazard Waste – Hazardous Waste Information Network (HWIN)
On the radar for the MOECC recently have been facilities which are located in, or near residential areas. Historically, enforcement of Acoustic Assessment Reports as part of Environmental Compliance Approvals wasn’t great. Things have certainly changed in that regard, and we are seeing more and more facilities require noise abatement action plans to get into compliance.
If your facility has a pond on it, you can bet the MOECC inspector will ask questions about it. Stormwater management ponds have been an area of increased scrutiny these days. Actually, everything under the umbrella of water services the MOECC has been fairly active with recently. We’ve seen several facilities been ordered to get Industrial Sewage Works ECAs for their stormwater management ponds.
Been inspected? Call us, we can help get you back into environmental compliance. 905-635-4063