Have you been ordered to apply for an Environmental Compliance Approval (ECA) or register through the Environmental Activity and Sector Registry (EASR) as a result of your on-site operations and processes? Need a better understanding of whether or not your paint booth, spraying operations or any relevant processes require an approval to operate? Rubidium Environmental has worked with countless automotive refinishing and body shops to provide guidance and obtain the necessary environmental permits to meet applicable environmental regulations and requirements.
Industry Sector Overview
With more vehicles on the streets now a days, the market for repairing and restoring automotive vehicles is certainly growing. The vast majority of the automotive refinishing market is dominated by small to medium family-owned businesses where clients are retained based on customer service excellence and quality workmanship on a personal level.
Automotive refinishing shops are typically required to prepare Emission Summary and Dispersion Modelling (ESDM) reports and/or Acoustic Assessment Reports (AAR) to support either the Environmental Compliance Approval (ECA) application or the Environmental Activity and Sector Registry (EASR) registration. If a shop has painting operations, a paint booth, parts washer, sanding operations, or any other ancillary equipment and activities that may have the potential to emit contaminants into the natural environment, then there is no doubt an ECA or EASR will be required in order to demonstrate compliance towards Ontario Regulation (O. Reg) 419/05 and/or the NPC-300.
Environmental regulators have long been monitoring emissions discharged by the automotive refinishing sector, and have even taken initiatives to educate and promote greener paint alternatives and spraying techniques through training in order to minimum its emissions, particularly Volatile Organic Compounds (VOCs).
Environmental conscious automotive refinishing shops and those who worries about not coming into compliance with applicable environmental regulations have switched from using paint with high level VOC content to water-base paint. Others have also taken the approach to reuse solvents to wash parts and paint guns multiple times before discarding the solution. Although these alternatives offer a greener solution, an Environmental Compliance Approval or Environmental Activity and Sector Registry is still required to assess the shop’s impact towards the environment and human health. However, using the proper greener alternatives may certainly be easier to comply with the Ministry of the Environment, Conservation and Parks (MECP) air and noise limits since emissions should now be lower.
Compliance towards the air quality standards and prescribed noise limits are typically based on the size of the shop’s property and the nearest sensitive receptors, such as residential housing, hotel, place of worship etc. It becomes even more challenging when the automotive body shops are operating under the same building as one or more other tenants, which would require a separate study to assess for same structure contamination using ASHRAE as the method of calculation.
It may seem very complicated and intimidating for what the MECP is requesting for, but Rubidium Environmental has helped many of our automotive refinishing clients comply without having to invest in costly environmental pollution control technologies. We understand the sector more than any other engineering consultant companies in the market, and we have also worked with Municipal governments identifying burdens that the sector has been facing, and coming up with best practices, techniques and approaches, and low cost and effective solutions for this sector should there be any non-compliance issues.
How do I know if I need a permit to operate?
If you own an automotive refinishing shop with processes that discharges contaminants into the atmosphere then it is certain that the preparation of an Emission Summary and Dispersion Modelling (ESDM) report, and/or an Acoustic Assessment Report (AAR) to support an ECA or EASR application is required. These assessments will allow the Ministry of the Environment, Conservation and Parks to determine whether or not the operations from the automotive refinishing shop has any air or noise impact towards off-property sensitive receptors, such as residential buildings, community centers, childcare center, place of worship, hotels, campgrounds etc.
In some cases, it may also be required to prepare Best Management Practice Plan (BMPP) for odour or an Odour Control Report (OCR) if potential adverse impact has been identified, especially when paint is involved in the day-to-day operation. If neither of the BMPP for odour or the OCR is required upon performing primary screenings; it could still be required at the discretion of the MECP should the inspectors believe odour emissions are present or that odour complaints have been filed against the shop with the MECP.
Does the ECA or EASR apply to my facility?
Automotive refinishing operations typically fall under the NAICS code 811121 – Automotive Body, Paint and Interior Repair and Maintenance. Under the Ontario Regulation (O. Reg) 1/17, any NAICS code that beings with 81, other than 81222 (Cemeteries and Crematoria), must apply for an Environmental Compliance Approval (ECA), which are applications that are MECP approved. Unlike the EASR process, where permits or approvals are issued almost immediately upon approval by a Qualified Person (QP) and a Licensed Engineering Practitioner (LEP), review and approval process for ECA normally takes more than 6 months, depending on the size and complexity of the facility, the nature of its operations, supporting information required etc. The ECA route is typically designated for operations that are more complex in nature and facilities that are considered ‘high-risk’ in the eye of the Minitry. MECP normally takes more time to review the applications to look for deficiencies, and to ensure that all sources of emission have been accounted for in the assessment.
How Rubidium Environmental can help?
Rubidium Environmental has dealt with numerous automotive refinishing environmental regulations case. If you are seeking guidance and assistance with getting an approval for your shop, we are here to help you in every step of the way. We work very closely with our clients to ensure we understand the challenges and obstacles your shop may have and work towards a cost-effective solution that works for you.