Want to comply with all applicable environmental regulations before starting up an automotive parts manufacturing facility? Need to update your Environmental Compliance Approval (ECA) or Environmental Activity and Sector Registry (EASR) application to reflect constant facility changes? Let Rubidium Environmental handle all your environmental needs and ensure that your facility is always up-to-date with all applicable environmental legislations that applies to your day-to-day operations.
Industry Sector Overview
One of the major challenges for automotive parts manufacturing facilities in today’s society is the regulatory burden. Environmental regulators are always seeking for ways to reduce emissions by phasing-in more stringent limits for contaminants discharged into the natural environment. Most operations from the automotive parts manufacturing industry are fairly large, which requires large equipment and processes to support major automotive make and models. Some of the equipment and activities within the automotive parts manufacturing sector include, stamping, pressing, welding, electroplating etc. Depending on the final products produced and the production capacity, a facility may have multiples of these processes and production lines in order to keep up with the day-to-day demands. With larger size facilities that support major automotive parts manufacturing operations, it is not uncommon that contaminants are being discharged into the atmosphere and noise emissions being generated. These types of automotive parts manufacturing operations typically require operating permits, for instance an Environmental Compliance Approval or an Environmental Activity and Sector Registry, such that assessments can be completed for the facility to demonstrate compliance towards Ministry standards and guidelines.
How do I know if I need a permit to operate?
For the automotive parts manufacturing industry, it is often required, by the Ministry of the Environmental, Conservation and Parks (MECP), to have facilities prepare an Emission Summary and Dispersion Modelling (ESDM) report in order to assess emissions from all on-site sources and to determine if the facility is in compliance with the prescribed MECP air quality standards under the Ontario Regulation (O.Reg) 419/05. Depending on the proximity of the property to nearby sensitive receptors, it may also be required that an Acoustic Assessment Report (AAR) be prepared to assess for off-property noise impact in accordance with NPC-300. Both of these reports form a critical part of the Environmental Compliance Approval application or the Environmental Activity and Sector Registry registration. Best Management Practice Plan (BMPP) for Odour, or Odour Control Report (OCR) are usually not necessary within this industry sector, but will certainly depend on the types of operations and processes that the facility has, such as spray painting, and whether or not public complaints for odour have been filed with the MECP against the facility. It is worth noting that although these reports may not be required for facilities from this sector upon completion of the Odour Screening Report (OSR), a BMPP for odour or an OCR may be required at the discretion of the MECP.
Does the ECA or EASR apply to my facility?
Not all automotive related manufacturing facilities are considered ‘high risk’ in the eye of the MECP. Some automotive related manufacturing facilities are required to undergo the Environmental Compliance Approval route, while others are eligible to register under the Environmental Activity and Sector Registry process. The types of application and eligibility will depend on the types of on-site operations, which is represented by a 6-digit North American Industry Classification System (NAICS) code. Most automotive parts manufacturing operations falls under the NAICS code 336 – Transportation Equipment Manufacturing, while others that manufacture vehicle components for the automotive industry can fall, for example, under the NAICS code 335 – Electrical Equipment, Appliance and Component Manufacturing.
Under O. Reg 1/17, any NAICS code that begins with 336 are required to obtain an ECA permit and are not eligible through the EASR process. If a facility is eligible to obtain a permit through the EASR process then a Licensed Engineering Practitioner (LEP) who completed the assessment can approve and stamp off the report, resulting in an immediate issuance of the approval for the facility, instead of waiting for the often 6+ months review time by the MECP.
|3361||Motor vehicle manufacturing|
|3362||Motor vehicle body and trailer manufacturing|
|3363||Motor vehicle parts manufacturing|
|3369||Other transportation equipment manufacturing|
With the world battling climate change and for the wellbeing of the public health, more stringent regulations are being phased-in by environmental regulators. It is often a challenge for facilities to comply with stringent air quality limits when there is nothing much companies can do to mitigate its emissions besides having to reduce its production level or install costly pollution control equipment.
With the growing demand, automotive parts manufacturing companies are also often faced with constant facility changes, either shifting processes around to improve work flow, decommissioning equipment to make space for new processes, installing new lines to increase production levels, or replacing old equipment with new ones to improve efficiency. More often than not, facilities now a days are finding its emissions more challenging to stay in compliance with the air quality standards and noise limits as the number of process grows, resulting in more emissions being generated. It is also not in the company’s favor when company decides to hire a consulting firm to prepare the required reports and documentations after the fact that the modification and new installations have already been completed. The benefit of retaining a Qualified Person (QP) from an engineering consulting company, like Rubidium Environmental, during the equipment proposal stages is that the we are able to provide useful feedback and insights on how the facility may affect the overall facility-wide emissions as a result of the proposed process implementations. In addition, our engineering staff are able to assist and conduct multiple model computational iterations and optimize where in the facility the proposed processes and/or stacks should be installed. Not only by following this approach will keep the facility emissions at its minimum, but will also leave some wiggle room in case the company has a plan in place for further future expansions. Proposed equipment installed in non-favourable locations throughout the plant may lead to non-compliance with air and noise limits applicable to the facility, and/or may require investment in costly pollution control technologies to mitigate its emissions.
How Rubidium Environmental can help?
Rubidium Environmental consist of staff with decades of experience within this industry sector, and are Licensed Engineering Practitioners (LEP) qualified to complete your regulatory reports. Whether you need an update to your Environmental Compliance Approval, Environmental Activity and Sector Registry, or discuss about the challenges that your facility is facing and how to achieve a cost-effective solution, Rubidium Environmental is eager to assist you in every way possible.
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