Did an Environmental Officer pay your facility a visit requesting to see your non-existent Environmental Compliance Approval or Environmental Activity and Sector Registry? Are you planning to expand your operations and need an update to your Emission Summary and Dispersion Modelling (ESDM) report and/or your Acoustic Assessment Report (AAR)? Rubidium Environmental can assist you with every aspect of the approval process.
Industry Sector Overview
Many companies do not know that they are subject to numerous regulations unless, one day, an environmental officer shows up at the door unannounced requesting for required environmental reports to demonstrate that the facility is operating in compliance with applicable air quality and noise limits. Most facilities performing metal fabrication and parts making does custom work of any size project. For the most part, these facilities take on any types of custom metal fabrication projects that they can possible handle. Because of the custom approach with demands that varies from client to client, metal fabrication and parts making facilities tend to source all sorts of raw materials with no day-to-day work flow consistency. Different raw material consists of different contaminants and composition which can be a burden when it comes to complying with all of the applicable air quality standards prescribed by the Ministry of the Environmental, Conservation and Parks (MECP).
Most metal fabrication and parts making facilities have operations, which consist of activities and processes that discharges contaminants into the natural environment and generates noise emissions that could potentially impact nearby noise receptors. Typical processes for the metal fabrication and parts making facilities include, welding, drilling, plasma cutting, sand blasting, spray painting, etc. For facilities with spray painting operations or a paint booth, countless contaminants can be emitted into the atmosphere from all of the different paints and coatings used depending on the custom work from each client. It can become a challenge to understand what exactly is being emitted, but Rubidium has dealt with many of these approvals and can assist with a smooth approval process.
Some companies even have outdoor metal working operations, without knowing the various limitations that the MECP has in place. One of the obstacles with a lot of metal fabrication and parts making facilities is that indoor space is very limited, and certain projects, such as those with bigger fabricated parts, must be completed outdoors. With MECP prescribed limitations for outdoor operations, it is often challenging for facilities to understand what is permitted and what is not permitted or under what conditions.
How do I know if I need a permit to operate?
If the facility has any activities, operations, or processes that has the potential to release any contaminants into the natural environment, or if an environmental officer requested to see the approval, either as a randomized check initiative or as a result of a public complaint, then the facility will most certainly require, by the Ministry of the Environmental, Conservation and Parks (MECP) to apply for an Environmental Compliance Approval (ECA) or register the facility under the Environmental Activity and Sector Registry (EASR).
Based on our experience, an Emission Summary and Dispersion Modelling (ESDM) report in support of the approval is a must for facilities within this industry. The ESDM report is an assessment that looks at the facility-wide emissions generated from all on-site sources and determine whether or not the facility is in compliance with applicable air quality standards under the Ontario Regulation (O. Reg) 419/05.
A second part of the approval is assessing for noise impact from all on-site noise sources towards off-property noise sensitive receptors. The noise assessment is typically covered under the Acoustic Assessment Report (AAR), completed in accordance with NPC-300. The AAR is required to be completed as part of the approval process only if the minimum separation distance has not been met, which is determined upon completion of the Primary Noise Screening (PNS) Form.
Because most metal fabrication and parts making facilities perform spray painting operations or has a paint booth or any other operations identified by the MECP as being odorous, it is likely that a Best Management Practice Plan (BMPP) for Odour or an Odour Control Report (OCR) or both may be required from the facility depending on the minimum separation distance calculated from the source of odour to the closest odour sensitive receptor. The requirement for either of these odour reports can be determined once the Odour Screening Report (OSR) has been completed. All of these reports form an integral part of the application.
Does the ECA or EASR apply to my facility?
There are many groups of metal fabrication manufacturing, some of which require an Environmental Compliance Approval (ECA), and some are eligible for the Environmental Activity and Sector Registry (EASR). The ECA process typically takes more than 6 months to be reviewed and approved by the MECP, as the ECA process focuses on industries that are considered ‘high risk’. On the other hand, the EASR route is a fairly quick process, in which the Qualified Person (QP) or the Licensed Engineering Practitioner (LEP) who has been retained to prepare the report, approves by sealing off the report, and the facility will be issued an approval immediately. Depending on which 6-digit NAICS code the facility belongs to that best represent on-site operations, it will determine whether the facility will require an ECA or EASR.
Under O. Reg 1/17, any NAICS code that begins with 3321 (Forging and Stamping), 33281 (Coating, Engraving, Cold and Heat Treating and Allied Activities), and 332999 (All Other Miscellaneous Fabricated Metal Product Manufacturing) must apply for an Environmental Compliance Approval. Other fabricated metal product manufacturing subgroups that are not listed above are eligible to apply for an approval under the Environmental Activity and Sector Registry process.
Below are all Fabricated Metal Product Manufacturing subgroups under the NAICS code 332.
|3321||Forging and stamping|
|3322||Cutlery and hand tool manufacturing|
|3323||Architectural and structural metals manufacturing|
|3324||Boiler, tank and shipping container manufacturing|
|3326||Spring and wire product manufacturing|
|3327||Machine shops, turned product, and screw, nut and bolt manufacturing|
|3328||Coating, engraving, cold and heat treating and allied activities|
|3329||Other fabricated metal product manufacturing|
How Rubidium Environmental can help?
If you are looking for an engineering consulting firm that understands the metal fabrication and parts making sector, Rubidium Environmental will certainly be one. Whether you need to apply for an ECA or register through EASR, someone to revise your reports, or a firm to handle all of your environmental regulatory matters, we are always here to help your business.