Canadian Environmental
Protection Act
Strategic Options for the
Management of Toxic Substances
REFRACTORY CERAMIC FIBRES
Report of Stakeholder Consultations
Canada
BACKGROUND
When the Ministers of the Environment and of Health announced the results of the
assessment of the substances, on the first Priority Substances List (PSL), that were found
to be toxic under the Canadian Environmental Protection Act (CEPA), they committed to
consult stakeholders. The purpose of these consultations is to recommend options for the
toxic substances that will reduce exposure and/or environmental impacts and to find out
whether regulations are warranted under CEPA.
DISCLAIMER
This report on stakeholder consultation is published by Environment Canada and Health
Canada. It presents the results of the consultation, requested by the Minister of
Environment and the Minister of Health Canada, regarding management options for the
substances declared toxic under CEPA, in this case: Refractory Ceramic Fibres (RCFs)
Publishing this report does not constitute endorsement/approval of the Ministers of
Environment and Health of all its content.
ACKNOWLEDGMENT
The Chair of this Issue table would like to extend his appreciation to all the members,
corresponding members and other stakeholders that participated in the development and
review of this report.
ii
Abstract
Refractory Ceramic Fibres have been assessed and declared toxic under the
Canadian Environmental Protection Act. An Issue Table has been established to make
recommendations to Ministers for the management of these substances in Canada. In this
report, health, scientific, technical, and socioeconomic factors were studied by the Issue
Table members so that recommendations could be made for preferred control options to
prevent or minimize exposure to, and/or releases into the environment of Refractory
Ceramic Fibres.
iii
Résumé
Les fibres de céramique réfractaire ont été évaluées et déclarées toxiques aux
termes de la Loi canadienne sur la protection de l'environnement. Une table de
concertation a été créée visant a formuler des recommandations aux ministres sur la
gestion de ces substances au Canada. Dans le présent rapport, les membres de la table de
concertation ont étudié des facteurs liés a la santé, ainsi que des facteurs scientifiques,
techniques et socio-économiques en vue de formuler des recommandations portant sur les
options de contrôle préférables devant prévenir ou minimiser l'exposition aux fibres de
céramique réfractaire et le rejet de ces substances dans l'environnement.
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EXECUTIVE SUMMARY
Introduction
Management of existing toxic substances under the Canadian Environmental
Protection Act (CEPA) involves identifying substances that may be toxic,
assessing them to determine whether they are toxic as defined in Section 11,
and, for substances that are found to be toxic, establishing and applying controls
to prevent harm to human health and/or the environment.
Refractory ceramic fibres have been declared toxic under paragraph 11(c) of the
Canadian Environmental Protection Act (CEPA). According to this paragraph of
the Act, a substance is toxic if it is entering or may enter the environment in a
quantity or concentration or under conditions constituting or that may constitute a
danger in Canada to human life or health.
The management of toxic substances is also guided by the Toxic Substances
Management Policy (TSMP), which puts forward a preventive and precautionary
approach to deal with substances that enter the environment and could harm the
environment or human health.
Under the TSMP, refractory ceramic fibres are categorized as Track 2
substances, thus requiring a life cycle management approach.
To ensure that the most effective and efficient options for managing CEPA toxic
substances, within the context of pollution prevention and sustainable
development, are being recommended to the accountable federal and provincial
ministers, Environment Canada, Health Canada and key partners have proposed
a multi-stakeholder approach: the Strategic Options Process (SOP).
The first step of the SOP involves the establishment of an Issue Table, chaired
or co-chaired by federal or provincial representatives. The task of the Issue
Table is to agree on the overall agenda for the table, the environmental and
health objectives and the time frame for achieving them in a sustainable
development context; develop a work plan with timelines, deliverables and
milestones; and ensure that the scientific, technical and socio-economic
information necessary for the evaluation of strategic options is available.
The objective of the Strategic Options Report (SOR) is to summarize the work
done by the Issue Table and to present to Ministers of Environment and Health
recommendations for the management of RCFs as required under the Priority
Substance List 1 exercise.
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Problem Definition
LIFE CYCLES CANADIAN EMISSION DATA
AIR WASTE
1- PRODUCTION OF RCF
Stack 3.6 kg/yr
Waste Generation Estimated to be
small
2- INDEPENDENT PROCESSING OF RCF
Stack 15.8 to 34.6 kg/yr
Waste Generation Estimated to be
small
3- END-USES OF RCF AND RCF CONSUMER
PRODUCTS
*
Distribution 1 kg/yr
*
Installation & Finishing 1 kg/yr
*
Secondary Processing (e.g. cutting & fitting) 1 kg/yr
*
Maintenance & Removal
1 kg/yr
Total ________
4 kg/yr
Waste Disposal (commercial & industrial 4 kt/yr
products and consumer products)
4- TOTAL 23.4 to 42.2 kg/yr 4 kt/yr
* These include estimates of emissions from utilization of RCF and RCF consumer products.
The Issue Table members draw the following conclusion based on the current
knowledge of RCF, and RCF production and processing.
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Error! Reference source not found.Error! Reference source not
found.
The Issue Table members agreed that a reassessment of the hazard-based
classification of RCF, pursuant to paragraph 11(c) of CEPA, was not an option. The
Issue Table was able to evaluate an observation made on page vi of the Priority
Substances List Assessment Report, Mineral Fibres, (1993).
"(...) estimated (RCF) exposure is compared to quantitative estimates of
cancer potency to characterize risks and provide guidance for further
action (i.e. analysis of options to reduce exposure); however, owing to
their use principally in high-temperature industrial applications, with the
exceptions possibly of areas in the vicinity of industrial sources for
which relevant Canadian data were not identified, exposure of the
general population and resulting exposure potency index (EPI) [and
hence priority for further action under CEPA] are expected to be very
low."
The Issue Table review confirmed that RCF exposure to the general population or to
the environment, including the vicinity of industrial sources is very low.
The Issue Table members conclude that the main potential risks associated with RCF
exposure are principally related to occupational environments. In the U.S., where
more data are available, occupational exposures appear to be low and declining due
to the implementation of a comprehensive Product Stewardship Program.
The Issue Table also suggests that a copy of this strategic options report should be
forwarded to provincial authorities.
Although, the risks associated with emissions of RCF into the environment are
believed to be small, the Issue Table proposes that a time-limited monitoring program
be established in order to obtain additional trend-line data on RCF emissions (stack
or outlet) and ambient air RCF concentrations at the boundary of the plant property to
better determine the level of risks to the general population.
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Goals and targets
For manufacturing, the following targets are proposed:
TARGETS FOR MANUFACTURING OF RCFS
1- A small time-limited (5-6 years) program to monitor air emissions (stack or
outlet) and ambient air concentrations at the boundary of the plant property.
2- End of production cycle inspections of pollution control equipment, and
periodic preventive inspections.
3- New facilities should demonstrate that they will, at least, meet the existing
facility stack emissions and ambient air RCF concentrations at the boundary of
their plant properties.
The same targets are proposed for the processing of RCFs.
TARGETS FOR PROCESSING OF RCFS
1- A small time-limited (5-6 years) program to monitor air emissions (stack or
outlet) and ambient air concentrations at the boundary of the plant property.
2- End of production cycle inspections of pollution control equipment, and
periodic preventive inspections.
3- New facilities should demonstrate that they will, at least, meet the existing
facility stack emissions and ambient air RCF concentrations at the boundary of
their plant properties.
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For end use activities, the following targets are proposed:
TARGETS FOR END-USE ACTIVITIES
1- Development and promotion of a product stewardship program.
2- Research on selected applications.
3- Ensure landfilling practices are acceptable.
Recommended Management Action
Error! Reference source not found.Error! Reference source not
found.
The Issue Table members recommend that emissions from RCF manufacturers and
processors be subject to a 5-6 year limited monitoring program in order to gather
trend-line data on the quantities of RCF emitted annually and to allow health and
environmental specialists to better evaluate the levels of risk to the general
population and the environment.
The Issue Table has agreed to explore different options, including voluntary
agreements to implement its target recommendations.
Recommended Control Options
Manufacturing of RCFs
Error! Reference source not found.Error! Reference source not
found.The Issue Table recommends that a Memorandum of Understanding (MOU)
between the Canadian manufacturer of RCFs and the Federal Government be
developed and signed.
The scope of the MOU should be such that it will encompass the targets identified for
the manufacturing of RCFs in Canada.
The MOU should also be signed by any firms that will engage in the future in the
manufacturing of RCFs in Canada.
If there is evidence of non-compliance with the MOU, or if all RCF manufacturers are
not signatories of the MOU, the Federal Government should consider introducing
regulations under the Canadian Environmental Protection Act (CEPA).
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Processing of RCFs
The Issue Table recommends that a Memorandum of Understanding (MOU) between
the Canadian processors of RCFs and the Federal Government be developed and
signed.
The scope of the MOU should be such that it will encompass the targets identified for
the processing of RCFs in Canada.
If the industry is reluctant to develop a voluntarily communication package to inform
customers about RCFs, their potential risks, the proper handling and disposal
procedures, such provisions should be included in the MOU.
The MOU should also be signed by any firms that will engage in the future in the
processing of RCFs in Canada.
If there is evidence of non-compliance with the MOU, or if all RCF processors are not
signatories of the MOU, the Federal Government should consider introducing
regulations under the Canadian Environmental Protection Act (CEPA).
End-Use Activities of RCFs
Error! Reference source not found.Error! Reference source not
found.The Issue Tables recommends that the RCF manufacturers, suppliers, and
processors, along with users of RCF containing products, labour groups, and
consumer organizations get together to review and adapt the Refractory Ceramic
Fibers Coalition Product Stewardship Program to the Canadian situation.
If there is evidence of a lack of willingness to undertake the Canadian stewardship
program, the appropriate federal and/or provincial authorities should get involved.
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1. INTRODUCTION
1.1 Context
Management of existing toxic substances under the Canadian Environmental
Protection Act (CEPA) involves identifying substances that may be toxic, assessing
them to determine whether they are toxic as defined in Section 11, and, for
substances that are found to be toxic, establishing and applying controls to prevent
harm to human health and/or the environment. Section 11 of CEPA defines a
substance as toxic if it is entering or may enter the environment in quantity or
concentration or under circumstances:
a) having or that may have an immediate or long-term harmful effect on the
environment;
b) constituting or that may constitute a danger to the environment on which
human life depends; or
c) constituting or that may constitute a danger in Canada to human life or health.
The first CEPA Priority Substances List (PSL 1), which identify 44 substances for
priority assessment, was published in 1989. Assessment of these priority substances
was completed early in 1994 and 25 of them were found to be toxic under CEPA as
defined by Section 11.
Refractory ceramic fibres have been declared toxic under paragraph 11(c) of the
Canadian Environmental Protection Act (CEPA). According to this paragraph of the
Act, a substance is toxic if it is entering or may enter the environment in a quantity or
concentration or under conditions constituting or that may constitute a danger in
Canada to human life or health. (Reference 14)
The management of toxic substances is also guided by the Toxic Substances
Management Policy (TSMP), which puts forward a preventive and precautionary
approach to deal with substances that enter the environment and could harm the
environment or human health. (Reference 15)
The key management objectives are:
a) virtual elimination from the environment of toxic substances that result
predominantly from human activities and that are persistent and
bioaccumulative (referred to in the policy as Track 1 substances); and
b) management of other toxic substances and substances of concern, through
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their entire life cycles, to prevent or minimize their release into the environment
(referred to in the policy as Track 2 Substances).
Under the TSMP, refractory ceramic fibres are categorized as Track 2 substances,
thus requiring a life cycle management approach.
Environment Canada and Health Canada share responsibility for managing CEPA
toxic substances.
1.2 Strategic Options Process (SOP)
To ensure that the most effective and efficient options for managing CEPA toxic
substances, within the context of pollution prevention and sustainable development,
are recommended to the accountable federal and provincial ministers, Environment
Canada, Health Canada and key partners have proposed a multi-stakeholder
approach: the Strategic Options Process (SOP). (Reference 5)
The SOP, a multistakeholder consultation process, is to identify, evaluate and
recommend goals, targets and management options for reducing exposure to these
CEPA toxic substances. The principles of the options evaluation are:
a) public participation;
b) openness and transparency in the decision-making process;
c) exploring instruments beyond traditional command and control regulations;
d) cost-effectiveness;
e) flexibility;
f) cross-sectoral equity; and,
g) harmonizing environmental management of CEPA toxic substances among
federal and provincial governments.
The first step of the SOP involves the establishment of an Issue Table, chaired or co-
chaired by federal or provincial representatives. The task of the Issue Table is to
agree on the overall agenda for the table, the environmental and health objectives
and the time frame for achieving them in a sustainable development context; develop
a work plan with timelines, deliverables and milestones; and ensure that the scientific,
technical and socio-economic information necessary for the evaluation of strategic
options is available.
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A SOP may follow a sector or a substance approach. The former is for substances
whose entry into the environment is predominantly the results of identifiable industrial
processes. The latter is for substances whose entry is primarily the result of
commercial uses. Refractory ceramic fibres (RCFs) were identified for a substance
approach. A list of the Issue Table members and corresponding members is found in
Appendix 1.
The terms of reference for the Issue Table were approved at the March 15, 1995
meeting. (See Appendix 2).
Three meetings of the Issue Table were held in Ottawa, and one was held in Oakville.
The first meeting took place in Ottawa on December 19-20, 1994. The agenda and
minutes of each of these meetings are available on public file. In addition, two
conference calls were held to keep members informed of progress on this file and to
solicit their input.
1.3 Strategic Options Report (SOR)
The objective of the Strategic Options Report (SOR) is to summarize the work done
by the Issue Table and to present to Ministers of Environment and Health
recommendations for the management of RCFs as required under the Priority
Substance List 1 exercise.
The recommendations of the Issue Table for refractory ceramic fibres are
summarized in this report -Strategic Options Report for the Management of refractory
ceramic fibres.
1.4 Structure of the SOR
Section 2 of this report describes the scope of the substance and products
considered by the Issue Table.
In Section 3, the long term goal for the management of the substance is outlined and
specific time-limited targets are developed.
Section 4 summarizes the recommendations of the Issue Table members concerning
the management action for refractory ceramic fibres with respect to the conclusion
given in section 2 and the goals and targets developed in section 3.
In Section 5, a detailed assessment of the various management options/tools that
could be used to achieve the stated targets for each stage of RCF life-cycle is given.
Finally, the consensus conclusions of the Issue Table members on the most effective
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and efficient tools are noted.
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2. PROBLEM DEFINITION
2.1 Substance
2.1.1 What are refractory ceramic fibres
RCFs are amorphous man-made fibres produced from the melting of calcined kaolin
clay or a combination of alumina (Al2O3) and silica (SiO2). Approximate percentage
of components may vary as follows: Alumina, 40 to 60 percent; silica, 40 to 60
percent; and other oxides, 1 to 5 percent. The Chemical Abstracts Service (CAS)
Registry Number for RCF is 142844-00-6.
RCFs were developed in 1942 and first commercialized in 1953. RCFs are found on
the market under various trade names (e.g. Fiberfrax , Cerwool , Kaowool ).
2.1.2 The Canadian Market
Production and Consumption Trends
The Thermal Ceramics division of Morgan Crucible Canada is the only domestic
producer of RCFs. The Issue Table members had the opportunity to visit the plant on
March 16, 1995. Members were shown how the fibres were made; the various forms
in which they are manufactured; and some vacuum formed products. Particular
attention was given to emission control technologies and procedures.
Thermal Ceramics and six other companies are involved in the processing of RCFs;
they are referred to as vacuum formers (see definitions 2.3).
Cheminfo Services and Statistics Canada estimated the 1995 Canadian consumption
(production + imports - exports) at about 4.3 kilotonnes, which represents about 10%
of US consumption. (References 3 and 19)
Error! Reference source not found.Error! Reference source not
found.Conclusion:
For the purpose of this report, the Issue Table agreed that the Canadian consumption
of refractory ceramic fibres is about 10% of U.S. consumption, therefore the
Canadian consumption of RCFs is estimated at 4 kilotonnes per year.
In the short to medium term, Canadian consumption is expected to remain at 10% of
U.S. consumption.
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Between 1988 and 1994 the total consumption of RCFs in Canada increased by
50%: Statistics Canada, 1994 (reference 19). This increase does not include RCFs
that may be imported or exported via assembled consumer goods or products. The
estimated value of annual imports of RCF to Canada ranges between $ 15 to $ 25
million Canadian dollars, while exports amounted to 4 million Canadian dollars
(Statistics Canada). Nearly 90% of the total imports originate from the USA.
In Canada, the market for RCFs is almost all in high-temperature applications (up to
3000F or 1650C). They are used mainly to manufacture:
. lining in industrial furnaces, kilns and process heaters (95% of
Canadian usage)
. pipe wrapping
. welding protection
. gaskets
. filters
. flame retardants
. acoustical insulation
A more exhaustive list of about 2000 applications has been developed by the US
industry for the purpose of a Significant New Use Rule (SNUR) developed by the US
Environmental Protection Agency (EPA). The complete list is available on public file.
The range of uses of RCFs has diversified significantly over the last 15 to 20 years,
with an increasing number of industrial and consumer applications. In Canada, RCF
is chiefly an industrial product. Consumer uses include automobiles, natural gas fire
places and natural gas fire place logs.
With respect to the geographic distribution of RCFs in Canada, about 75-80% of total
fibre consumption (including fibres and finished fibre products but excluding
consumer products) occurs in Ontario and Quebec (ferrous and non-ferrous metals,
aluminium, bricks, ceramics, refractories, automotive, glass). Ontario and Quebec
account for about 90% of total fibre imports (including fibres and finished fibre
products but excluding consumer products). Most of the RCFs used in Western
Canada takes place in Alberta (petrochemicals, refineries, oil sands).
Estimated Employment
It is difficult to estimate the total number of employees engaged in the manufacturing
and processing of RCFs. In the U.S., about 80 million pounds of RCFs are produced.
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The current best estimate of the potentially exposed workforce in producing and
processing RCF in the U.S. includes approximately 660 workers at RCF production
facilities and 22,180 workers at processing and using facilities, totalling approximately
22,840 workers (Source: Everest Consulting). If the numbers of workers are
proportional to the total volume of business, then the number of workers in the
Canadian RCF production and processing industries would be about 2,284. If 80% of
the total business of RCFs is in Ontario and Quebec, then the total employment
(including manufacturing and processing) in these provinces would be about 1,827,
while the remaining jobs would be in Western Canada and Atlantic provinces.
2.1.3 Global production
In the USA, RCFs are manufactured by 5 companies: Unifrax, Premier Refractories,
Thermal Ceramics, A.P. Green Industries, and Engineered Thermal Systems. The
first three companies account for approximately 90% of the US production. All firms
manufacture RCFs in several forms. RCF sales in the USA total approximately 36
kilotonnes (80 million pounds), worth an estimated $125 million U.S. annually.
RCFs are produced and consumed in several other countries including Australia,
Brazil, Canada, China, England, France, Germany, India, Italy, Japan, Korea,
Mexico, Russia, Spain, Taiwan, and Venezuela, and they are sold in many other
countries.
RCFs are sold in a variety of physical forms, including bulk fibre, blankets, boards,
felt, woven fibre, paper, vacuum-formed shapes, and textiles. RCFs are principally
industrial products, used as insulating materials for furnaces, heaters, kiln linings,
furnace doors, metal launders, tank car insulation, and related products designed to
be used at high temperature (up to 3000F or 1650C). Some of the newer
applications for RCFs include fire protection materials, automotive uses (e.g.,
catalytic converters, metal alloy reinforcement, heat shields, brake pads), and
aerospace uses (e.g., heat shields, nose cones). Major RCF consuming industries
include the steel, petrochemical, ceramic, automotive, and primary metal industries.
2.1.4 Substitutes
A recent study in the US (Reference 18) examined the cost, availability, and technical
and economic feasibility of replacing RCF with conventional refractory and fibrous
substitutes. The study focused upon furnace related applications, where the
availability of substitutes is probably the greatest because many end-users in this
segment employed other fibrous and non-fibrous refractories.
The analysis concluded that there are technically acceptable substitutes for RCF in
furnace related applications. It also found that replacement by conventional
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refractory substitutes would impose incremental costs on firms now using RCF.
Cost increases are resulting from decreased energy efficiency, higher maintenance
costs, retrofitting furnaces, and reduced product quality. The study estimated that
replacing RCF with conventional refractory alternatives in six selected sectors
(ceramics, glass, forging, petrochemical, aluminium, and steel) would impose
incremental annual costs 1.31 billion Canadian dollars ($954 million US).
Increased energy consumption for these six sectors has been estimated at 164 trillion
BTU annually, equivalent to 27.8 million barrels of oil.
Again, if the Canadian consumption of RCF is posed at ten percent of the US
consumption, the cost impact of substitutes can be estimated at 131 million Canadian
dollars.
2.1.5 Summary
The socio-economic characteristics of the RCF industry in Canada indicates that:
1. the business of RCF is characterized by small and fragmented Industrial markets;
2. the total trade value is less than 30 million Canadian dollars;
3. there is only one manufacturer;
4. nearly 95% of imports originated from the USA;
5. the market seems to be characterized by a stable demand;
6. about 80% of the consumption occurs in Ontario and Quebec;
7. there are no widely available cost-effective and energy-saving substitutes.
2.2 Scope
The Issue Table members agreed to take a life cycle approach. It was decided that
the mandate of the Issue Table was to determine the environmental and health goals
and targets, and to identify and evaluate, throughout the life cycle of RCF and RCF
products, the available control options for meeting these goals and targets. (see
Terms of Reference in Appendix 2).
There were lengthy and detailed discussions of the various segments of the industry,
the sources of possible emissions to the environment, technology used, the data that
was already available or could be obtained for each emission source and health risks
that must be considered.
The industry can be conveniently broken down into three major groups:
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a) Producers of RCF;
b) Processors of RCF (Product manufacture)
i) Vacuum forming
ii) Other uses;
c) End Users of RCF.
In the next sections, each of these groups will be characterized, sources of emissions
will be identified and quantified, goals and targets will be set, control options/tools will
be evaluated, and finally recommendations will be presented.
2.3 Definitions
Production of RCF means the melting of a combination of Al2O3 and SiO2 or kaolin
clay that is made into fibre either by blowing an air stream on the molten material
(blowing process), or by directing the molten material into a series of spinning wheels
(spinning process). The fibres are either collected directly as bulk fibre
or made into a blanket by a needling process.
Processing of RCF means the subsequent manufacturing steps (e.g. vacuum
forming, module manufacturing), where the bulk material (bulk fibres, blankets) are
converted or fabricated into other RCF products, such as board, cloths, cements,
putties, modules, paper, coatings, felt, vacuum-formed shapes, rope, braid, tape, and
other textiles.
End-Uses of RCF includes the distribution, installation and maintenance, and the
secondary processing of industrial and commercial RCF products.
RCF Products In-Use means products in commerce used by consumers and would
include products such as furnaces, fire place logs, breaks, air filters, catalytic
converters, gaskets, appliances, fire protection devices, etc.
2.4 Health and Environmental Effects
The following discussion is taken from the findings outlined in the assessment report
that led to the conclusion that RCFs are CEPA toxic. (Source: Canadian
Environmental Protection Act, Priority Substances List Assessment Report: Mineral
Fibres (Man-Made Vitreous Fibres), 1993. (Reference 14)
2.4.1 General
Through their life-cycle, RCFs have the potential to enter the environment at all
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stages and in various ways. Although most of the fibres will enter the environment as
solid waste, some will enter the environment by air emission. As RCFs are solely
anthropogenic substances, ambient exposures will solely be associated with the
various stages of their life-cycle.
2.4.2 Environmental effects
Although refractory ceramic fibres may enter the atmosphere in Canada, no data
were identified on concentrations in Canadian air, water, sediment or soil.
Furthermore, no relevant data were found on the effects of refractory ceramic fibres
on exposed biota such as terrestrial mammals or birds. It has been concluded that
available information was insufficient to conclude whether refractory ceramic fibres
were toxic under paragraph 11(a) of CEPA i.e. whether or not refractory ceramic
fibres are entering the environment in quantities or under conditions that may be
harmful to the environment.
Because refractory ceramic fibres are relatively inert solid particles, they do not
contribute to global warming, or to depletion of stratospheric ozone. Therefore, it has
been concluded that refractory ceramic fibres are not toxic under paragraph 11(b) of
CEPA i.e. that refractory ceramic fibres are not entering the environment in quantities
or under conditions that may constitute a danger to the environment on which human
life depends.
2.4.3 Human health effects
On the basis principally of the increased incidence of pulmonary tumours in rats and
increases in mesotheliomas in rats and hamsters observed in inhalation bioassays
and supporting data, refractory ceramic fibres have been classified by Health Canada
"probably carcinogenic to humans" i.e. as a substance for which there is believed to
be some chance of adverse health effects at any level of exposure. The objective for
compounds which are classified as "probably carcinogenic to humans" is to reduce
exposure wherever possible. It is, however, recognized that the risks associated with
the RCF for the general population are likely to be low due to the limited potential for
exposure.
Based on these studies refractory ceramic fibres have therefore been found "toxic"
under paragraph 11(c) of CEPA i.e. that refractory ceramic fibres may enter the
environment in quantities or under conditions that may constitute a danger in Canada
to human life or health.
Because RCFs are used principally in high temperature industrial applications and
may be present in the vicinity of one production and six processing plants, exposure
to the general population is expected to be low. More information on estimated
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emissions into the Canadian environment is presented in section 2.5 (Analysis of
Emissions - Sources & Quantities).
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Cristobalite
Because the principal ingredients in the manufacture of RCF are alumina and silica,
the Issue Table considered the health effects associated with cristobalite, a form of
crystalline silica. Inhalation of dust containing crystalline silica can aggravate upper
respiratory conditions such as asthma or emphysema. Long-term unprotected
exposure beyond acceptable concentrations can lead to a lung disease called
silicosis.
As produced, RCF is an amorphous material, and as such does not contain
cristobalite. Therefore, the small quantity of RCF emitted from production and
processing facilities does not contain cristobalite. However, studies show that after
prolonged heating at temperatures in excess of 1 000 0 C, cristobalite may begin to
precipitate within RCF fibres. It is important to note that both temperature and time
are key to the formation of cristobalite. One sources indicates that cristobalite begins
to form after 3 000 hours at 1 1000 C, after 300 hours at 1 2000 C, and after 50 hours
at 1 3000 C. Thus, after-service RCF may contain cristobalite, depending upon the
conditions of use. However, the material will not generally present an inhalation
hazard unless disturbed, as in a furnace removal operation.
The workplace monitoring program conducted by the Refractory Ceramic Fiber
Coalition (see section 2.7.2) in the United States includes collection of cristobalite
samples during furnace removal operations. To date, a total of 79 cassette samples
collected during removal operations have been analyzed for cristobalite. Of these, 77
(97.5%) were beneath the limit of detection. Based upon these data, the probability
of significant inhalation of cristobalite from RCF is negligible, even under the most
likely exposure scenario. (Reference 10)
Because RCF as produced does not contain cristobalite, and because cristobalite
concentrations measured during furnace removals have been shown to be negligible,
the Issue Table concludes that cristobalite will not be considered as a health risk in
connection with RCF.
2.5 Analysis of Emissions (Sources & Quantities)
At the March 15-16, 1995 meeting it was decided to compile a spreadsheet/matrix of
the information available and obtainable as an aid to the Issue Table in focusing on
whether the information available is sufficient for its needs, identifying gaps and
revising affordable strategies for closing the gaps.
The matrix was developed and discussed at the May 11, 1995 teleconference. The
entries were explained, available and missing information were identified and
discussed. At the August 29-30, 1995 a report developed by Environment Canada,
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based on information and reports tabled by the members was presented. Results are
summarized in section 2.5.1
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2.5.1 Environment Canada report on emissions and sources
Error! Reference source not CANADIAN EMISSION DATA
found.Error! Reference source not
found. LIFE CYCLES
AIR WASTE
1- PRODUCTION OF RCF
Stack 3.6 kg/yr
Waste Generation Estimated to be
small
2- INDEPENDENT PROCESSING OF RCF
Stack 15.8 to 34.6 kg/yr
Waste Generation Estimated to be
small
3- END-USES OF RCF AND RCF CONSUMER
PRODUCTS
*
Distribution 1 kg/yr
*
Installation & Finishing 1 kg/yr
*
Secondary Processing (e.g. cutting & fitting) 1 kg/yr
*
Maintenance & Removal
1 kg/yr
Total ________
4 kg/yr
Waste Disposal (commercial & industrial
products and consumer products) 4 kt/yr
4- TOTAL 23.4 to 42.2 kg/yr 4 kt/yr
* These include estimates of emissions from utilization of RCF and RCF consumer products.
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2.5.2 Estimates of quantities
Production Facility
In June 1995, Stephen Lamming Associates Ltd., a meteorological and
environmental consulting firm, was contracted by Thermal Ceramics to conduct an air
quality survey of emissions from its Burlington plant. (Reference 20) The work was
carried out between June 15 and June 20, 1995. The survey consisted of:
a) an assessment of total suspended particulate loading at the boundary of the
plant property;
b) an assessment of RCF emissions from selected stacks, exhaust ducts and
roof ventilation fans; and,
c) an evaluation of total plant fibre emission to the atmosphere.
The results of this study were presented at the August 29-30, 1995 meeting. The
compilation of data was done in a way to avoid disclosure of confidential business
information and to allow comparison to US data.
There are three main sources of emissions: primary manufacture; vacuum forming;
and general ventilation. The total fibre air emission was estimated at 3.59 kg/yr, and
are broken down as:
Production (fibre & blanket) = 1.14 kg/yr (2.5 lb/yr)
Vacuum forming = 0.45 kg/yr (1.0 lb/yr)
General ventilation = 2.00 kg/yr (4.4 lb/yr)
Total = 3.59 kg/yr (7.9 lb/yr)
Independent Vacuum Forming Facilities
In Canada, there are 6 companies performing only vacuum forming, referred to as
independent vacuum formers.
Estimate of emissions from independent U.S. vacuum formers is 142.5 kg (313.5
lbs). This estimate is based on 28.8 lbs RCF emissions per million pounds
throughput (as measured from vacuum forming operations at U.S. RCF
manufacturing facilities), and an estimated throughput of 10.9 million pounds of RCF
at U.S. independent vacuum formers. Assuming that emissions per pound of
throughput will be the same at independent vacuum formers as it is for vacuum
forming at manufacturing plants, these quantities can be multiplied to arrive at the
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estimate of 142.5 kg per year (313.5 lbs per year). In the U.S., this estimate is
spread over 54 independent vacuum forming plants, so an estimate of the emissions
per U.S. plant is 142.5/54 or 2.64 kg per plant. If the emissions per independent
vacuum forming plant are the same in Canada, estimated total emissions from
independent vacuum formers in Canada would be 6 times 2.64 kg or 15.8 kg.
(Source: Everest Consulting, 1996)
Alternately, emissions from independent Canadian vacuum formers can be estimated
based upon estimated RCF throughput of 1.2 kt/yr for 6 Canadian vacuum forming
plants, and assuming that emissions per pound of throughput are the same as
measured at U.S. facilities. By this method, estimated RCF emissions are 1.2 kt/yr
times 28.8 kg emitted/kt throughput or 34.6 kg/yr. (Source: Everest Consulting, 1996)
End-uses of RCF and RCF Consumer products
No direct data on either stack or fugitive emissions exist for end-uses as defined in
section 2.3. Dr. Dan Maxim suggested that, using simple engineering models, a
numerical example estimating emissions from a typical insulation removal activity
could be carried-out. His calculations indicated the removal operation would yield to
an annual emissions rate of approximately 0.005 kilogram of RCFs per year.
(References 7 and 10)
To estimate the total annual emissions of RCFs in Canada from end-users, the
following assumptions were made:
0.005 kg/unit from insulation removal (as per D. Maxim's calculations,
prepared for the May 11, 1995 teleconference);
same amounts for distribution, installation & finishing, cutting & fitting (
0.005 times 4 gives 0.02 kg/unit repaired);
20 units per year (0.02 kg/unit times 20 units gives 0.4 kg/yr);
10 times for including a security factor and emissions during use -
wearing out- (0.4 kg/yr times 10 gives 4 kg/yr).
For a total of 4 kilograms per year.
Waste Generation
At the August 29-30, 1995 meeting there was a discussion on the amount of RCF
going to landfills from manufacturing and vacuum forming. There was a general
agreement that the amount of RCF would be small, because off-spec fibre and
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STRATEGIC OPTIONS REPORT FOR THE MANAGEMENT OF
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formed products are generally recycled, reprocessed, or sold as off-spec material.
Wastes containing little or no RCF account for more than 82% of all wastes going to
landfills from RCF producers.
Used RFC material (e.g. worn modules from a furnace removal) are not recycled,
because of the presence of impurities in the RCF material that accumulate over time
as the furnace is used (material that is being processed in the furnace may spatter or
fume off and deposit on the RCF lining). Used RCF materials are disposed of in
landfills after use. The annual quantity of RCFs disposed in Canada could be
evaluated easily by estimating that the total annual consumption ends up in landfills.
Therefore, we can estimate at 4 kt the annual quantity of RCF going to waste
disposal facilities such as landfills.
The Refractory Ceramic Fiber Coalition referred to monitoring data collected at a U.S.
landfill where RCF was being disposed of. These data show that for 63 high volume
and personal samples, all concentrations were at or beneath the detection limit
(average detection limit: 0.00319 fibres/cubic centimetre). Based upon these data,
RCF emissions from landfills are likely to be very small.
Error! Reference source not found.Error! Reference source not
found.CONCLUSION:
Members agreed that the estimated emissions were sufficiently accurate for the Issue
Table.
2.6 Existing Federal / Provincial Regulations
The Federal government, the Provinces and the Territories have all Occupational
Health Regulations prescribing occupational standards relating to gases, vapours,
fumes, smoke, dust, chemical substances.
Quebec and Alberta are the only two jurisdictions prescribing a specific Occupational
Exposure Limit (OEL) for refractory ceramic fibres. In Quebec, the OEL is set at 1
fibre/cm3 (reference 4). In Alberta, the OEL is set at 0.5 fibre/cm3.
Most of the other jurisdictions, including the Federal government, have Regulations
referring to the Threshold Limit Values for Chemical Substances and Physical
Agents, published by American Conference of Governmental Industrial Hygienists
(ACGIH). Threshold Limit Values are given for many substances; among the fibre
family, only Asbestos, Fibrous Glass Dust, and Mineral Wool Fibres are addressed.
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STRATEGIC OPTIONS REPORT FOR THE MANAGEMENT OF
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At the moment, there is no specific allusion to Refractory Ceramic Fibres; however,
the situation is under review by the ACGIH.
The only Code of Practice for insulation wools, including refractory ceramic fibres,
known to the Issue Table members, has been developed by the Quebec Federation
of Labour. (Reference 13)
There are no Canadian (Federal nor Provincial) environmental regulations concerning
refractory ceramic fibres.
2.7 USEPA and RCF Coalition Programs
2.7.1 Regulatory status in the USA
RCFs are the subject of a testing requirement under an enforceable Consent Order.
On May 14, 1993, the EPA and the RCFC voluntarily entered into an agreement
which required the three primary manufacturers of RCFs perform workplace exposure
monitoring of RCFs for all workplace activities. The primary goals for the program
developed in the Consent Order are to provide a baseline for occupational exposure,
a study of trends in exposure levels over time (minimum 5 years), and a study of
differences in workplace concentrations among employees engaged in various tasks.
At the August 29-30, 1995 meeting, the latest results of a workplace exposure study
were presented. These are interim results representing 2 years of a 5 year study.
Results available to date show that there has been a significant decline in exposure
since 1990. Weighted average exposures (representative of the exposure of a
"composite" industry worker) for the first five 5 months of 1995 are 0.18 fibres/cubic
centimetre for manufacturers, and 0.23 fibres/cubic centimetre for customers, well
beneath the industry recommended exposure guideline (REG) of 1.0 fibre/cubic
centimetre. Average exposures of workers in individual functional categories may be
higher or lower than the weighted average exposure. Of all functional categories
monitored, workers performing furnace removals had the highest average exposure
value at 1.09 f/cc for samples collected during the second monitoring year (3 June
1994 to 2 June 1995). However, it is considered as one of the lowest actual
exposures due to the predominate use of personnel protection equipment (e.g.
respirators).
The US Environmental Protection Agency (EPA) published on March 21, 1994 a
proposed Significant New Use Rule (SNUR) that would require persons to notify the
EPA at least 90 days before commencing the manufacture, import or processing of
refractory ceramic fibres in any new product form, or any new application of an
existing product form. This rule has not yet been made final.
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The required notice would provide the EPA with the opportunity to evaluate the
intended use and associated activities, and an opportunity to protect against risks
that could result from exposure to the significant new uses.
2.7.2 RCF Coalition Programs
The Refractory Ceramic Fiber Coalition (RCFC) is a US trade organization that
focuses on research, product stewardship, and regulatory issues relevant to RCFs.
RCFC membership includes primary manufacturers of RCFs, and other interested
parties negotiating with the EPA to develop an exposure testing program to monitor
workplace exposures throughout the RCF life cycle. Worker sampling schemes,
protocols for the collection and analysis of fibres, and provisions for evaluation of the
resulting data were developed.
RCFC has developed and implemented a Product Stewardship Program consisting of
seven elements:
Health effects research
Three major health effect studies are either completed or in progress: a single-dose
multiple-fiber inhalation study in rats; a single-dose single-fiber inhalation study in
hamsters; a single-fiber multiple-dose inhalation study in rats; and, an ongoing
human epidemiological study of present and former workers.
The Chemical Industry Institute of Toxicology (CIIT) is conducting a study, to which
the RCFC is collaborating, on "Factors Influencing the Toxicity and Carcinogenicity of
Fibers".
The purpose of these studies is to identify possible adverse health effects associated
with RCF exposure and to provide a data base for quantitative dose-response
analysis.
Workplace exposure monitoring
The purpose of this monitoring is to assess the potential for worker exposure to
airborne RCFs, identify production stages or operations with elevated fiber
concentrations, and measure the effectiveness of engineering controls, workplace
practices, and other measures designed to reduce worker exposure. Results of
some of those studies have been discussed above.
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Workplace exposure control measures
Manufacturing and processing operations that generate elevated fibre concentrations
are the subject of engineering studies to develop relevant control technologies.
There are five generic techniques for reducing workplace exposure to RCF.
1- Reduction of fibre emissions rates by:
- encapsulating material to be handled;
- increasing humidity in workplace area or moistening products;
- increasing frequency and effectiveness of cleanups;
- providing laundry facilities or disposable clothes.
2- Contain/isolate activity by:
- enclosing high-exposure work area;
- using hoods, glove boxes, etc;
- providing separate rooms for eating, coffee breaks, meetings, etc.
3- Process redesign to eliminate high-exposure jobs.
4- Reduce fiber concentrations by installing local exhaust ventilation (LEV).
5- Provide personal protective equipment.
Exposure assessments
Exposure assessments are performed using both qualitative and quantitative
analysis. Producers are completing a systematic analysis of all their products and
applications. Each product/application combination will be reviewed to estimate the
potential number of workers involved, and their potential exposure.
Some RCF-containing materials find their way into consumer products. For the most
part they are encapsulated, and therefore, potential exposure is almost nonexistent.
Nonetheless, potential consumer exposure to RCF products is evaluated.
The objective of these analyses is to evaluate potential control options, and product
substitutes.
Product research
Research to develop new products of comparable efficiency to the present product
line that requires less sophisticated handling constraints to ensure people safety.
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Special studies
Special studies is a catch-all activity description. It includes the preparation of
focused analyses on diverse topics of interest. Examples of such studies would
include, waste-minimization programs, solid waste handling procedures, study of
emissions from truck brakes made with RCF materials.
Communication
The communications include, warning labels, material safety data sheets, special-
purpose communication packages, safe-handling videotapes, presentations to
professional societies or trade groups, customer seminars/workshops, employee
communications, health kits, and report to regulatory agencies.
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2.8 Conclusion
The following conclusion is based on the current knowledge of RCF, and RCF
production and processing.
Error! Reference source not found.Error! Reference source not
found.
The Issue Table members agreed that a reassessment of the hazard-based
classification of RCF, pursuant to paragraph 11(c) of CEPA, was not an option. The
Issue Table was able to evaluate an observation made on page vi of the Priority
Substances List Assessment Report, Mineral Fibres, (1993).
"(...) estimated (RCF) exposure is compared to quantitative estimates of
cancer potency to characterize risks and provide guidance for further
action (i.e. analysis of options to reduce exposure); however, owing to
their use principally in high-temperature industrial applications, with the
exceptions possibly of areas in the vicinity of industrial sources for
which relevant Canadian data were not identified, exposure of the
general population and resulting exposure potency index (EPI) [and
hence priority for further action under CEPA] are expected to be very
low."
The Issue Table review confirmed that RCF exposure to the general population or to
the environment, including the vicinity of industrial sources is very low.
The Issue Table members concluded that the main potential risks associated with
RCF exposure are principally related to occupational environments. In the U.S.,
where more data are available, occupational exposures appear to be low and
declining due to the implementation of a comprehensive Product Stewardship
Program.
The Issue Table also suggests that a copy of this Strategic Options Report should be
forwarded to provincial authorities.
Although, the risks associated with emissions of RCF into the environment are
believed to be small, the Issue Table proposes that a time-limited monitoring program
be established in order to obtain additional trend-line data on RCF emissions (stack
or outlet) and ambient air RCF concentrations at the boundary of the plant property to
better determine the level of risks to the general population.
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3. GOALS AND TARGETS
3.1 Goals
The Issue Table members agreed on the following goal statement.
Error! Reference source not found.Error! Reference source not
found.GOAL STATEMENT:
To assess the general population exposure to refractory ceramic fibres;
To identify unacceptable ambient exposure issues;
To recommend technically and economically feasible measures to mitigate
environmental exposure management weaknesses.
3.2 Targets
As stated in the previous chapter, the objective for "probably carcinogenic to humans"
substances, such as refractory ceramic fibres, is to reduce exposure wherever
possible. In setting the targets, it was agreed to consider technology and incremental
costs when considering appropriate targets for each main source of emissions
(manufacturing, processing, end-use).
For manufacturing, the following targets were proposed:
Error! Reference source not found.Error! Reference source not
found.TARGETS FOR MANUFACTURING OF RCFS
1- A small time-limited (5-6 years) program to monitor air emissions (stack or
outlet) and ambient air concentrations at the boundary of the plant property.
2- End of production cycle inspections of pollution control equipment, and
periodic preventive inspections.
3- New facilities should demonstrate that they will, at least, meet the existing
facility stack emissions and ambient air RCF concentrations at the boundary of
their plant properties.
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STRATEGIC OPTIONS REPORT FOR THE MANAGEMENT OF
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The same targets were proposed for processing.
Error! Reference source not found.Error! Reference source not
found.TARGETS FOR PROCESSING OF RCFS
1- A small time-limited (5-6 years) program to monitor air emissions (stack or
outlet) and ambient air concentrations at the boundary of the plant property.
2- End of production cycle inspections of pollution control equipment, and
periodic preventive inspections.
3- New facilities should demonstrate that they will, at least, meet the existing
facility stack emissions and ambient air RCF concentrations at the boundary of
their plant properties.
For end use activities, the following targets were proposed:
Error! Reference source not found.Error! Reference source not
found.TARGETS FOR END-USE ACTIVITIES
1- Development and promotion of a product stewardship program.
2- Research on selected applications.
3- Ensure landfilling practices are acceptable.
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4. RECOMMENDED MANAGEMENT ACTION
This section summarizes the recommendations of the Issue Table members
concerning the management action for refractory ceramic fibres with respect to the
conclusion given in section 2 and the goals and targets developed in section 3.
Error! Reference source not found.Error! Reference source not
found.
The Issue Table members recommend that emissions (stack or outlet) from RCF
manufacturers and processors be subject to a 5-6 year limited monitoring program in
order to gather trend-line data on the quantities of RCF emitted annually and to allow
health and environmental specialists to better evaluate the levels of risk to the
general population and the environment.
The Issue Table has agreed to explore different options, including voluntary
agreements to implement its target recommendations.
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5. OPTIONS EVALUATION AND RECOMMENDED CONTROL OPTIONS
5.1 Introduction
Overview
As described in section 2, the life-cycle of RCFs can be conveniently broken down in
three categories: production, processing, and end-uses and in-use RCF products.
The goals and targets for managing RCFs at each stage of their life-cycle were
identified in section 3. The Table below sets out each options/tools that were
considered by the Issue Table members.
More details on the assessment of the preferred options/tools for recommendations
to the Ministers is summarized in the text that follows the Table. Finally, the
recommendations of the Issue Table members are given.
Management options
Assessment of management options should consider the impact of the substance on
human health at each stage of the life cycle. This section describes feasible policy
options that will ensure the attainment of the desired goal of minimizing exposure of
humans to RCFs.
There is one manufacturer, six processors or vacuum forming facilities and a
multitude of end-users. Most emissions of RCFs occur at the stage of production and
processing. Management options for RCFs target seven plants located in Ontario
and Quebec because more than 80% of RCFs business is performed by these plants
( see section 2).
Management options/tools to achieve environmental targets can be broadly classified
into four: a) command-and-control tools (e.g. regulations), b) market-based tools
(e.g. economic instruments), c) voluntary tools (e.g. memorandum of
understanding), and d) information provision tools (e.g. labelling). Command-
and-control tools impose legally binding restrictions subject to prosecution and fines
on firms' activities; market-based tools refer to market intervention designed to modify
prices and thus behaviour; voluntary tools refer to measures that are not enforceable
by law; and, information provision tools refer to measures related to the exchange of
information to raise awareness and thus make workers and plant managers take
appropriate decisions and measures. These approaches are further subdivided into
specific options, a complete list of the management options/tools, and their
respective definitions, is given in Appendix 3. In addition, the status quo option -the
option of leaving the regulatory authority's management (if any) of the substance as it
currently exists - was considered by the Issue Table.
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STRATEGIC OPTIONS REPORT FOR THE MANAGEMENT OF
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Evaluation criteria
The criteria that were used in the Issue Table members assessment of each
management option/tool included, among others: a) environmental-effectiveness, b)
cost-effectiveness, c) enforceability, d) public acceptability, and e) growth.
Environmental-effectiveness refers to the extent to which the environmental target
can be achieved/ensured with the use of this tool. Cost-effectiveness refers to the
ability of the tool to achieve the target in a manner that minimizes the financial burden
to the industry and government. Enforceability refers to the ability of the Federal
Government to monitor and enforce the option/tool. Public acceptability refers to
the readiness with which the public will accept the use of this option/tool for
environmental management. Growth refers to the structure of the option to allow for
economic growth while still meeting the environmental target. A complete list of the
evaluation criteria, and their respective definitions, is given in Appendix 4.
5.2 Life Cycles
5.2.1 Manufacturing of RCFs
Targets
The Issue Table members recommended (see section 3): a small time-limited (5-6
years) program to monitor air emissions (stack or outlet) and ambient air
concentrations at the boundary of plant property; end of production cycle inspections
of pollution control equipment, and periodic preventive inspections; and, that new
facilities should demonstrate that they will, at least, meet the existing facility stack
emissions and ambient air RCF concentrations at the boundary of their plant
properties.
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STRATEGIC OPTIONS REPORT FOR THE MANAGEMENT OF
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Options considered
Error! Reference source ASSESSMENT SUMMARY
not found.Error!
Reference source not
found. TOOLS
A) COMMAND-AND-CONTROL Not Recommended
1. Quantity Controls The Issue Table concluded that restricting the quantities of RCFs that
can be manufactured and imported into Canada is not an
economically sound option because of the small quantities of RCF
emissions involved.
Not recommended
2. Performance Standards The Issue Table concluded that this option will not lead to any
decrease in RCF emissions. The sole Canadian producer of RCF
being equipped with the best available control technology, no
regulation could reasonably require emission standards under what is
currently achieved (0.02 f/cc).
3. Technology Controls Not recommended
The Issue Table concluded that a regulation of that nature would be
redundant since the equipment used by the sole Canadian
manufacturer of RCF is the best available control technology.
4. Supplier Controls Not recommended
The Issue Table concluded that this option is not applicable.
5. Information Controls Potential tool
The Issue Table concluded that communication of information on
RCF potential impacts on the environment and human health has
some merits to decrease general population exposure to RCF, but it
is believed that the objective could be better achieved through tools
other than regulations.
This option has no impact on emission reductions from the
manufacture of RCFs.
B) MARKET-BASED Not recommended
1. Trading programs The Issue Table concluded that this option is not applicable since
there is only one manufacturer of RCFs in Canada.
2. Environmental Not recommended
Charges/Taxes
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STRATEGIC OPTIONS REPORT FOR THE MANAGEMENT OF
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Error! Reference source ASSESSMENT SUMMARY
not found.Error!
Reference source not
found. TOOLS
The Issue Table concluded that the introduction of taxes on RCF
emissions would not lead to any reductions in RCF emissions. No
measurable environmental or health impacts can be expected. The
only Canadian manufacturer of RCFs uses the best available control
technology.
3. Financial Incentives Not recommended
The Issue Table concluded that financial incentives would not lead to
RCF emission reductions. The sole Canadian manufacture of RCFs
is currently engaged in various programs, set under the auspices of
the Refractory Ceramic Fibre Coalition (RCFC), to reduce emissions
from RCF manufacturing and processing activities, and in research
of new products and technologies.
4. Environmental Liability Not recommended
The issue Table concluded that this option is not feasible.
5. Deposit-Refund Systems Not recommended
The Issue Table concluded that this option is not applicable.
C) VOLUNTARY ACTIONS Recommended
1. Structured The Issue Table concluded that a Memorandum of Understanding
(MOU) between the Canadian RCF manufacturer and the Federal
Government would be the best option to meet the objective and the
targets specified for the manufacture of RCFs. The MOU should
also be signed with any new RCF producer in Canada.
Recommended
2. Unstructured
The Issue Table is of the opinion that the sole Canadian
manufacturer of RCFs is already engaged in such activity by its
participation in various programs set under the auspices of the
Refractory Ceramic Fibre Coalition (RCFC), and recommends that
such participation be continued.
D) INFORMATION PROVISION
Recommended
1. Environmental Labelling
The WHMIS labelling requirements are suitable for that purpose.
2. Technology Development & Potential option
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STRATEGIC OPTIONS REPORT FOR THE MANAGEMENT OF
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Error! Reference source ASSESSMENT SUMMARY
not found.Error!
Reference source not
found. TOOLS
Transfer
The Issue Table concluded that the participation of the Canadian
manufacturer in the RCFC programs do achieve this tool. This
option should be considered by any other firm which could be
engaged in the future in the production of RCFs in Canada.
3. Quality Standards & Not recommended
Objectives
The Issue Table concluded that this option in not applicable as there
is only one manufacturer of RCFs in Canada, which is using the best
available control technology.
4. Citizenship Programs Not recommended
The Issue Table concluded that this option is not applicable since
this section is addressing the manufacture of raw RCF fibres.
E) STATUS QUO Not recommended
The Issue Table concluded that the status quo will not provide
continuous estimates of RCF emissions going into the environment.
Those data will allow the Federal Government to have a better
understanding on the potential risks of RCF emissions to the general
population.
Conclusion
The Issue Table concluded that the goal and targets for the manufacturing of
refractory ceramic fibres could be achieved by a Memorandum of Understanding
(MOU) and by the continuing participation of the Canadian manufacturer of RCFs in
the Refractory Ceramic Fiber Coalition (RCFC) programs (see 2.7.2) or any similar
organization that could eventually be set up in Canada.
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STRATEGIC OPTIONS REPORT FOR THE MANAGEMENT OF
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Recommendation
Error! Reference source not found.Error! Reference source not
found.The Issue Table recommends that a Memorandum of Understanding (MOU)
between the Canadian manufacturer of RCFs and the Federal Government be
developed and signed.
The scope of the MOU should be such that it will encompass the targets identified for
the manufacturing of RCFs in Canada.
The MOU should also be signed by any firms that will engage in the future in the
manufacturing of RCFs in Canada.
If there is evidence of non-compliance with the MOU, or if all RCF manufacturers are
not signatories of the MOU, the Federal Government should consider introducing
regulations under the Canadian Environmental Protection Act (CEPA).
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STRATEGIC OPTIONS REPORT FOR THE MANAGEMENT OF
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5.2.2 Processing of RCFs
Target
The Issue Table members recommended the same targets for processing as for the
manufacturing of RCFs (see section 3).
Error! Reference source not found.Error! Reference source not
found.Options consideredOptions considered
Error! Reference source ASSESSMENT SUMMARY
not found.Error!
Reference source not
found. TOOLS
A) COMMAND-AND-CONTROL Not Recommended
1. Quantity Controls The Issue Table concluded that restricting the quantities of RCFs that
can be processed into Canada is not an economically sound option.
Potential option
2. Performance Standards The Issue Table concluded that setting emission limits for RCF
processors may have some merits to decrease RCF emissions from
this sector of activity. However, because of the limited number of
facilities (6) engaged in the processing of RCFs in Canada, the Issue
Table believed that the objective could be better achieved through
tools other than regulations.
3. Technology Controls Not recommended
The Issue Table concluded that prescribing a specific emission
control technology through regulations would not be efficient as
technologies will evolved over time. Other means to have the best
available control technologies should be considered.
4. Supplier Controls Not recommended
The Issue Table concluded that this option is not applicable.
5. Information Controls Potential tool
The Issue Table concluded that communication of information on
RCF potential impacts on the environment and human health has
some merits to decrease exposure of the general population to RCF,
but it believed that the objective could be better achieved through
tools other than regulations.
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STRATEGIC OPTIONS REPORT FOR THE MANAGEMENT OF
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Error! Reference source ASSESSMENT SUMMARY
not found.Error!
Reference source not
found. TOOLS
This option has no impact on emission reductions from the
processing of RCFs.
B) MARKET-BASED
Not recommended
1. Trading programs
The Issue Table concluded that this option is not applicable because
the number of players is not large enough (6) to allow the
development of an efficient market.
2. Environmental Not recommended
Charges/Taxes
The Issue Table concluded that environmental charges or taxes on
RCF emissions from vacuum forming activities may create an
unnecessary financial burden to the industry and that more efficient
tools to reduce RCF emission from that sector should be used.
3. Financial Incentives Not recommended
The Issue Table concluded that, given the current fiscal restraint
situation, financial incentives are not feasible.
4. Environmental Liability Not recommended
The issue Table concluded that this option is not feasible for
reducing RCF emissions.
5. Deposit-Refund Systems Not recommended
The Issue Table concluded that this option is not applicable.
C) VOLUNTARY ACTIONS
Recommended
1. Structured
The Issue Table concluded that a Memorandum of Understanding
(MOU) between the Canadian RCF processors and the Federal
Government would be the best option to meet the objective and the
targets specified for the processing of RCFs. The MOU should also
be signed with any new RCF processor in Canada.
2. Unstructured Recommended
The Issue Table concluded that the RCF processing industry should
develop its own informal reduction and information plans with an
objective to look into current and new technologies to reduce RCF
emissions from processing facilities; and, to develop a
40
STRATEGIC OPTIONS REPORT FOR THE MANAGEMENT OF
REFRACTORY CERAMIC FIBRES
Error! Reference source ASSESSMENT SUMMARY
not found.Error!
Reference source not
found. TOOLS
communication package to raise the awareness of their customers on
the potential risks associated to RCFs and procedures to reduce
exposure to RCF.
D) INFORMATION PROVISION
Recommended
1. Environmental Labelling
The WHMIS labelling requirements are suitable for that purpose.
2. Technology Development & Recommended
Transfer
The Issue Table concluded that the RCF processing industry should
create or participate in existing organizations with programs to
reduce emissions from RCF processing activities, and into research
of new products and technologies (See 2.7.2).
3. Quality Standards & Not recommended
Objectives
The Issue Table concluded that this option is not applicable to the
situation.
4. Citizenship Programs Not recommended
The Issue Table concluded that this option is not applicable since the
large majority (over 90%) RCF containing products is used in
industrial and commercial applications.
E) STATUS QUO Not recommended
The Issue Table concluded that the status quo will probably not
answer the question of actual RCF emissions going into the
environment. Data on those RCF emissions will allow the Federal
Government to have a better understanding on the potential risks of
RCF emissions to the general population.
Conclusion
The Issue Table concluded that the goal and targets for the processing of refractory
ceramic fibres could be achieved by a Memorandum of Understanding (MOU) and by
voluntary actions from the RCF processing industry to undertake research into ways
of minimizing RCF emissions from its activities and, to develop a communication
program to raise the awareness of their customers to the potential risks related to
RCFs, to describe procedures to reduce exposure to RCFs and to identify the best
ways to dispose of RCFs.
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STRATEGIC OPTIONS REPORT FOR THE MANAGEMENT OF
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42
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Recommendation
Error! Reference source not found.Error! Reference source not
found.The Issue Table recommends that a Memorandum of Understanding (MOU)
between the Canadian processors of RCFs and the Federal Government be
developed and signed.
The scope of the MOU should be such that it will encompass the targets identified for
the processing of RCFs in Canada.
If the industry is reluctant to develop a voluntarily communication package to inform
customers about RCFs, their potential risks, the proper handling and disposal
procedures, such provisions should be included in the MOU.
The MOU should also be signed by any firms that will engage in the future in the
processing of RCFs in Canada.
If there is evidence of non-compliance with the MOU, or if all RCF processors are not
signatories of the MOU, the Federal Government should consider introducing
regulations under the Canadian Environmental Protection Act (CEPA).
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STRATEGIC OPTIONS REPORT FOR THE MANAGEMENT OF
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5.2.3 End-Use Activities of RCFs
Target
The Issue Table members recommended (see section 3): the development and
promotion of a product stewardship program; research on selected applications; and
the insurance that landfilling practices are acceptable. It should be noted that this
section addresses RCF containing products including consumer products.
Options considered
Error! Reference source ASSESSMENT SUMMARY
not found.Error!
Reference source not
found. TOOLS
A) COMMAND-AND-CONTROL Not Recommended
1. Quantity Controls The Issue Table concluded that command-and-control options are
not applicable against the targets set out for this part of the life-cycle
of RCFs and/or RCF containing products.
Not recommended
2. Performance Standards
The Issue Table concluded that command-and-control options are
not applicable against the targets set out for this part of the life-cycle
of RCFs and/or RCF containing products.
3. Technology Controls Not recommended
The Issue Table concluded that command-and-control options are
not applicable against the targets set out for this part of the life-cycle
of RCFs and/or RCF containing products.
4. Supplier Controls Not recommended
The Issue Table concluded that command-and-control options are
not applicable against the targets set out for this part of the life-cycle
of RCFs and/or RCF containing products.
5. Information Controls Not recommended
The Issue Table concluded that command-and-control options are
not applicable against the targets set out for this part of the life-cycle
of RCFs and/or RCF containing products.
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STRATEGIC OPTIONS REPORT FOR THE MANAGEMENT OF
REFRACTORY CERAMIC FIBRES
Error! Reference source ASSESSMENT SUMMARY
not found.Error!
Reference source not
found. TOOLS
B) MARKET-BASED
Not recommended
1. Trading programs
The Issue Table concluded that this option in not applicable.
2. Environmental Potential tool
Charges/Taxes
The Issue Table concluded that the introduction of an environmental
charges or taxes on RCF containing products would create an
unnecessary financial burden to the industry and consumers, and that
more efficient tools to achieved the targets should be used.
However, if RCF containing products are found to cause health or
environmental hazards, this tool should be re-assessed.
3. Financial Incentives Not recommended
The Issue Table concluded that given the current situation, financial
incentives are not feasible.
4. Environmental Liability Potential tool
The Issue Table concluded that this option is not feasible for
reducing RCF emissions.
However, if RCF containing products are found to cause health or
environmental hazards, this tool should be re-assessed.
5. Deposit-Refund Systems Not recommended
The Issue Table concluded that a deposit-refund system will not be
useful because used RFC material (e.g. worn modules from a furnace
removal) are not recyclable (see discussion on p.18).
C) VOLUNTARY ACTIONS
Not recommended
1. Structured
The Issue Table concluded that the targets could be achieved through
voluntary actions without necessarily formalizing them by a
Memorandum of Understanding (MOU) or any other means of that
nature.
2. Unstructured Recommended
The Issue Table concluded that the RCF manufacturers and
processors, along with users of RCF containing products, labour
45
STRATEGIC OPTIONS REPORT FOR THE MANAGEMENT OF
REFRACTORY CERAMIC FIBRES
Error! Reference source ASSESSMENT SUMMARY
not found.Error!
Reference source not
found. TOOLS
groups, and consumer organizations should get together to develop a
product stewardship program to look at: new products and
technologies, a communication package, conducting research on
selected applications, and developing appropriate disposal practices.
D) INFORMATION PROVISION
1. Environmental Labelling Recommended
The Issue Table concluded that a labelling program consistent with
the WHMIS labelling requirements should be part of the stewardship
program discussed in C.2.
2. Technology Development & Not recommended
Transfer
The Issue Table concluded that the stewardship program discussed
above will cover this activity.
3. Quality Standards & Not recommended
Objectives
The Issue Table concluded that this option is irrelevant to the targets
set for end-use activities.
4. Citizenship Programs Not recommended
The Issue Table concluded that this option is not applicable since the
large majority (over 90%) RCF containing products is used in
industrial and commercial applications.
E) STATUS QUO Not recommended
The Issue Table concluded that the status quo is not acceptable as
none of the targets would be achieved.
Conclusion
The Issue Table concluded that the goal and targets for the end-use activities of
refractory ceramic fibres could be achieved by a voluntary action to be undertaken by
the industry, users, and other interested organizations to develop a product
stewardship program.
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STRATEGIC OPTIONS REPORT FOR THE MANAGEMENT OF
REFRACTORY CERAMIC FIBRES
Recommendation
Error! Reference source not found.Error! Reference source not
found.The Issue Table recommends that the RCF manufacturers, suppliers, and
processors, along with users of RCF containing products, labour groups, and
consumer organizations get together to review and adapt the Refractory Ceramic
Fiber Coalition Product Stewardship Program to the Canadian situation.
If there is evidence of a lack of willingness to undertake the Canadian stewardship
program, the appropriate federal and/or provincial authorities should get involved.
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STRATEGIC OPTIONS REPORT FOR THE MANAGEMENT OF
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6. REFERENCES
1- Breitsman B. et al. on behalf of TIMA Inc., RCF Emissions from Domestic
Production Facilities and Related Matters: Phase I Final Report, Washington,
20 April 1992.
2- Camford Information Services Inc., Corpus Profile Index, December, 1992.
3- Cheminfo Services, 1995.
4- Commission de la santé et de la sécurité du travail, Rglement modifiant le
Rglement sur la qualit du milieu de travail (Rvision de l'annexe A),
Bibliothque nationale du Qubec, 1994.
5- Environment Canada, Guidance Document on the Options Evaluation
Process, Ottawa, 1994.
6- Everest Consulting, Cost Impact of a Potential Ban on RCF for Furnace-
Related Application: Technical and Economic Analysis, 1992.
7- Everest Consulting, Dr. Maxim's letter to Serge Langdeau dated May 2, 1995.
8- Everest Consulting Associates Inc., Revised Estimate of RCF Stack Emissions
from Plants Operated by RCF Producers, June 21, 1995.
9- Everest Consulting Associates on behalf of the Refractory Ceramic Fibre
Coalition, Second-Year Report on Workplace Monitoring (DRAFT), July, 1995.
10- Everest Consulting, John Allshouse's faxs to Serge Langdeau dated April 4,
1996 and June 14, 1996.
11- Federal Register, Rules and Regulations, Testing Consent Order for
Refractory Ceramic Fibres, Page 28517, Vol. 58, No. 92, Friday, May 14,
1993.
12- Federal Register, Proposed Rules, Refractory Ceramic Fiber; Proposed
Significant New Use of a Chemical Substance, Page 13294, Vol. 59, No. 54,
Monday, March 21, 1994.
13- Fédération des travailleurs et travailleuses du Québec, Model Code of Practice
for the Safe Use of Manufactured Vitreous Fibres (MVF), 1996
14- Government of Canada, Environment Canada, Health Canada, Canadian
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STRATEGIC OPTIONS REPORT FOR THE MANAGEMENT OF
REFRACTORY CERAMIC FIBRES
Environmental Protection Act, Priority Substances List Assessment Report:
Mineral Fibres (Man-Made Vitreous Fibres), Ottawa, 1993.
15- Government of Canada, Environment Canada, Toxic Substances
Management Policy, Ottawa, June 1995.
16- Refractory Ceramic Fibre Coalition, RCF Monitoring Project: Quality
Assurance Project Plan (QAPjP), Washington, May 24, 1993.
17- Refractory Ceramic Fibre Coalition, RCF Background Briefing Material,
Washigton, October 20, 1994.
18- Refractory Ceramic Fibre Coalition, Refractory Ceramic Fibers: A Substitute
Study, prepared by Everest Consulting, submitted to the US EPA, Washington,
April, 1996.
19- Statistics Canada, Data on Import and Export of RCFs, 1994.
20- Stephen Lamming Associates Ltd., Air Quality Survey for Total Refractory
Ceramic Fibre Emission, Final Report, Prepared for Thermal Ceramics,
Burlington, July, 1995.
21- The Energy Conservation Center, Ceramic Fibre Insulation Theory and
Practice, Edited by Eiji Horie, Tokyo, Japan.
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STRATEGIC OPTIONS REPORT FOR THE MANAGEMENT OF
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Appendix 1
Issue Table Members and Corresponding Members.
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REFRACTORY CERAMIC FIBRES
DISTRIBUTION - PARTICIPATING MEMBERS - REFRACTORY CERAMIC FIBRES
NAME ORGANIZATION
Mr. Jim Armstrong Environment Canada
Mr. James E. Cason UNIFRAX Corp.
Mr. Bill Denault Renault & Associates
Mr. Tom Hall Narco Canada
Mr. Tom Walters Premier Refractories
Dr. Richard Waugh Thermal Ceramics
Mr. P. Walters Health Canada
Mr. P. Morel-&-L'Huissier Natural Resources Canada
Mr. Yohannes Mariam Environment Canada
Mr. Stéphane Gingras Great Lakes United
Mr. Serge Langdeau Environment Canada
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REFRACTORY CERAMIC FIBRES
DISTRIBUTION - CORRESPONDING MEMBERS
A.P. Green Industries Inc. Mr. David McCumber
Alberta Labour Ms. Roxanne Grade
Automotive Part Manufacturers
Association of Canada Mr. Mark Cotter
Alcan Automotive Castings Mr. E. Willa
BC Ministry of the Environment Mr. L. Hubbard
Canadian Labour Congress Mr. David Bennett
Canadian Federation of Labour Mr. Michael Gannon
Canadian Fireplace Manufacturers Ms. Donna Bush
Canadian Manufacturers' Association Mrs. Doreen Henley
Canadian Public Health Association Mr. John Oudyk
Clayburn Mr. David Lane
Commission de la santé et de la
sécurité au travail Mr. Bernard Chabot
Commission de la santé et de la
sécurité au travail Mr. Yves Brissette
Department of Labour (Manitoba) Mr. Geoff Bawden
Department of Labour (Nova Scotia) Mr. Jim Leblanc
Department of Labour and Employment
Relations (Newfoundland) Mr. Dave Clark
Dow Corning Mr. Richard W. Mast
Environment Canada
Atlantic Region Mr. Les Rutherford
Environnement Canada
Québec Region Mr. John Ayres
Environment Canada
Ontario Region Mr. Jim Smith
Environment Canada
Prairie & Northern Region Mr. A. Beckett
Environment Canada
Pacific & Yukon Ms. Liz Gordy
Everest Consulting Associates Dr. Daniel Maxim
Everest Consulting Associates Mr. John Allhouse
Fédération des travailleurs et
travailleuses du Québec M. Serge Trudel
Fibrecast President
Fisher Scientific Mr. Chris McDonald
Foseco President
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Human Resources Development Canada Mr. Richard Lafrance
Human Resources Development Canada Mr. Gerry Blanchard
Imperial Oil Ltd Mr. Roger Keefe
International Fibre Safety Group Mr. Scott Houston
Manitoba Environment Mr. Ed Yee
Ministere de l'environnement
et la faune du Québec Mr. Jean Lavergne
Ministry of Labour (Ontario) Mr. Ed McCloskey
National Defence Mr. Holmer Berthiaume
NB Environment Mr. Mike Murphy
Newfoundland and Labrador Mr. Darrel Gover
Occupational Health and Safety
of Saskatchewan Mr. Jeff Parr
Premier Refractories Canada Ltd Mr. Stephen A. Becker
Pyrotek Industrial Products Mr. J.P. Drolet
Refractory Ceramic Fibre Coalition Mr. Willis Breitsman
Saskatchewan Environment and
Resource Management Mr. Randy Sentis
STELCO, Inc. Mr. A. A. Schuldt
Thermal Ceramics Mr. John Breed
Wolf Steel Mr. Garry McKee
Workers' Compensation Board
of British Columbia Dr. Shawn Mitton
Workers' Compensation Board
of British Columbia Mr. Allan Luck
Workers' Compensation Board
of Alberta Ms. Susan LeClair
Workers' Compensation Board
of Saskatchewan Mr. Terry Brown
Workers' Compensation Board
of Manitoba Mr. Vic Werhrmann
Workers' Compensation Board
of Ontario Mr. Garth Dee
Workers' Compensation Board
of Nova Scotia Ms. Suellen Murry
Workers' Compensation Board
of New Brunswick Ms. Nora Kelly
Workers' Compensation Board
of Prince Edward Island Ms. Judy Tassell
Workers' Compensation Board
of Prince Edward Island Mr. Greg MacCallum
Worker's Compensation Board
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REFRACTORY CERAMIC FIBRES
of Newfoundland & Labrador Mr. Michael Rose
Worker's Compensation Board
of the Northwest Territories Mr. Trevor Alexander
Worker's Compensation Board
of the Northwest Territories Mr. Dave Turner
Workers' Compensation Health
and Safety Board Mr. Mike Tischer
Workplace Health, Safety and Compensation
Commission of New Brunswick Mr. Richard Blais
Yukon Workers' Compensation
Health & Safety Board Ms. Isabelle Bordage
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Appendix 2
Terms of Reference for the Issue Table.
55
STRATEGIC OPTIONS REPORT FOR THE MANAGEMENT OF
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ISSUE TABLE
REFRACTORY CERAMIC FIBRES - TERMS OF REFERENCE
OBJECTIVE
A multistakeholder issue table to develop a Strategic Options Report for managing
exposure of the general population to refractory ceramic fibres.
BACKGROUND TO THE STRATEGIC OPTIONS PROCESS
In order to examine options to reduce exposure to CEPA "toxic" substances,
Environment Canada has developed a "Strategic Options Process" (SOP). The SOP
is a consultative multistakeholder approach designed to identify and evaluate a broad
range of options for the effective management of environmental issues before making
recommendations to the Minister of the Environment and the Minister of Health on
actions. It was developed and refined in consultation with other federal departments,
provincial governments, industry and non-governmental organizations.
The SOP involves the setting up of an issue table for each substance or industrial
sector to be examined. The decision to choose a substance or sector approach is
based on the scale and the scope of the issue. In general, a sector approach is
recommended for substances whose entry into the environment is predominantly the
result of an identifiable industrial process. The substance approach is recommended
for substances whose entry is primarily the result of its commercial use.
The membership of an issue table should be limited to a maximum of 20 persons.
These members must have the authority to talk in the name of their constituents and
commit their organization.
Refractory ceramic fibres have been identified, in the 1994-95 workplan, for a
substance approach; however, they also enter the environment as a result of their
manufacturing.
BACKGROUND TO REFRACTORY CERAMIC FIBRES
Refractory ceramic fibres are used mainly for high-temperature furnace and kiln
insulation, and also other high-temperature applications such as catalytic converters,
filtration, and gaskets and seals for expansion joints. There is only one production
plant in Canada.
Because RCFs are used principally in high temperature industrial applications,
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REFRACTORY CERAMIC FIBRES
exposure to the general population is expected to be low.
Releases of refractory ceramic fibres are poorly quantified, but of those that enter the
Canadian environment, most are likely emitted into air. Most RCFs are relatively
stable and are expected to persist in the ambient environment.
On the basis principally of the increased incidence of pulmonary tumours in rats and
increases in mesotheliomas in rats and hamsters observed in inhalation bioassays
and supporting data, refractory ceramic fibres have been classified "probably
carcinogenic to humans" i.e. as a substance for which there is believed to be some
chance of adverse health effects at any level of exposure.
STATEMENT OF WORK
The issue table members will have to establish environmental and health objectives
and identify the most cost effective and efficient options for achieving those
objectives for managing refractory ceramic fibres. This will be accomplished by:
1- gathering the necessary scientific, technical, socio-economic information; and
2- identifying and evaluating, throughout the life cycle of RCF and RCF products,
the available control options.
The information gathering phase should be completed by no later than 9 months after
the issue table has been set up and should be achieved by developing:
1- socio-economic studies to provide a social and economic profile of the
refractory ceramic fibre; and
2- technical background studies identifying and assessing the available and
feasible input, process or abatement technologies to mitigate the
environmental and health problems associated with refractory ceramic fibre.
The options identification and evaluation phase should be completed by no later than
18 months after the issue table has been set up and should be achieved by:
1- determining the environmental and health goals and targets;
2- identifying and assessing all the available control options, throughout the life
cycle of RCF and RCF products, for meeting these objectives;
3- selecting the most feasible options;
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4- doing a costs/benefits analysis of the selected options; and
5- recommending an option.
The issue table will have to identify what information is already available and what
needs to be generated. It will also have to decide on the need for outside consultant
studies and the level of effort needed to acquire, gather and analyze the information.
MEETINGS
A first meeting will be held shortly after the issue table membership will be
established. Its purpose will be to present and agree on a proposed set of ground
rules. Items for discussion will cover among others, the following points:
- the strategic options process;
- discussion on the mandate of the table (objectives, terms of reference,
milestone & work plan);
- developing a consensus approach and fall-back positions;
- review and define roles and responsibilities;
- review and discussions of non-negotiable items.
Approximately, one month later a second meeting should be held to discuss the
followings:
- confirm or modify our understandings of the process, its objectives, the roles &
responsibilities of members;
- confirm or modify the work plan, and schedule;
- table and review data and information available from members;
- establish information gaps;
- discuss the need for and scope of consultant studies.
Other meetings could be held on an as needed basis, depending on how easily the
information is accessible and the consensus is reached. Telephone conference may
be considered as alternatives to formal meetings.
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59
STRATEGIC OPTIONS REPORT FOR THE MANAGEMENT OF
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Appendix 3
Management Options to Minimize Environmental
and Health Impacts of RCFs in Canada
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The range of tools to achieve environmental objectives has rapidly expanded in
recent years. This is a result of the increasing scope and complexity of the
environmental issues of interest and of the limitations of the traditional command-
and-control tools. The list of management options that might be assessed (alone or
in combination) are outlined below.
A- COMMAND-AND-CONTROL TOOLS
Command-and-control tools are regulations that impose legal restrictions on firms'
activities. These tools are generally uniformly applied across pollutant sources and
have numerous and diverse applications including those noted below.
1. Quantity Controls
Regulations may set limits on the quantity of an input, good/service that can be
produced, imported or consumed, and are usually implemented through a
quota system.
2. Performance Standards
Performance standards prescribe the results or objective to be achieved but
do not specify the exact means of compliance. Limitations can be applied on
the concentration of pollutants in inputs, products or wastes.
3. Technology Controls
Detailed equipment and/or design requirements can be used to provide highly
specific information about what must be done to ensure compliance.
4. Supplier Controls
Control can be applied through licensing and certification, the use of permits or
by direct regulation of management practises.
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5. Information Controls
Regulations requiring the disclosure of information on attributes of a product,
process or situation can be accomplished through labelling requirements,
advertising controls and disclosure statements. Some forms of information
control incorporate restrictions on inputs, products and processes.
B- MARKET-BASED TOOLS
1. Trading Programs
Under trading programs, environmental regulators set a total limit on pollutant
releases/quantities of a product or input that is manufactured, imported or
consumed, allocate this limit among the sources using a permit system, and
allow these allocations to be traded among sources. A wide range of trading
variations are possible including point/non-point source trading and cross-
pollutant trading.
2. Environmental Charges/Taxes
Charges and taxes refer to fees levied on processes or products that are
sources of environmental problems. These fees can be designed to provide an
incentive to modify environmental behaviour, and/or raise revenue to finance
environmental protection programs or other government activities.
3. Financial Incentives
Financial incentives alleviate the costs of meeting pollution control/reduction
goals to obtain environmentally desirable behaviour. Financial incentives
include: tax write-offs, investment tax credits and flow-through arrangements;
government loans, loan guarantees and subsidized interest rates; and grants,
subsidies and cost-sharing programs.
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4. Environmental Liability
Assignment of liability involves the passing of legislation and regulations that
hold individuals, firms or institutions responsible for the costs of environmental
degradation. Liability can be used as a policy tool to serve either as a deterrent
or for revenue generation. (In other cases, liability is the foundation for
enforcing a regulation or other tools and is more appropriately discussed as an
intervention.)
5. Deposit-Refund Systems
Deposit-refund systems involve the placing of a surcharge or deposit at the
point of final sale on products (or packaging) that may be detrimental to the
environment. The surcharge is refunded when the item is returned to the point
of sale or to a collection depot. Deposit-refund systems may be used for
collection of products for re-use or recycling, and/or for collection of products
to prevent environmentally unsafe disposal.
C- VOLUNTARY TOOLS
1. Structured Voluntary Action
Voluntary action can be structured through instruments such as codes,
guidelines, standards and agreements. Although the behaviourial
requirements are not made mandatory, specific rules are developed.
2. Unstructured Voluntary Action
Associations of producers/users can develop their own informal voluntary
reduction plans. Governments can assist through training or advisory services,
rather than through legally binding rules which specify behaviour.
D- INFORMATION PROVISION TOOLS
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1. Environmental Labelling
Environmental labelling is a tool to inform consumers about the environmental
aspects of a product such as recyclability and biodegradability. Labelling
programs may be used to issue guidelines or standardize definitions for
descriptions, logos or other representations that describe or imply
environmental features of consumer products.
2. Technology Development and Transfer
Technology transfer and development programs facilitate greater awareness,
innovation and adoption of advanced environmental technologies. Such
programs involve the diffusion of technical knowledge and/or provide funds for
research and development into environmentally sound technologies.
3. Quality Standards and Objectives
Environmental quality standards and objectives define the broad goals we as a
society would like to achieve. These standards and objectives can provide a
framework against which to assess the actions of all levels of government,
industry and the public.
4. Citizenship Programs
Environmental citizenship programs provide Canadians with knowledge, skills
and values that will lead to enhanced awareness, understanding and
commitment to environmental protection goals.
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Appendix 4
Criteria for the Evaluation of Options
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The Evaluation Criteria that the Issue Table used for the assessment of appropriate
management option.
1) environmental-effectiveness
To what extent can the environmental / health targets be achieved/ensured
with the use of this management tool?
2) cost-effectiveness/competitiveness
Will this tool minimize the financial burden to industry and to government of
dealing with the environmental / health targets? What impact on the
international competitiveness of Canadian industry will result from the use of
this tool to achieve the environmental objective?
3) incentives
Does the tool directly or indirectly stimulate creativity and innovation through
some form of incentive acquired by decision-makers to develop and implement
cleaner technologies and ways of operation?
4) enforceability/compliance
How easily will we be able to enforce and monitor compliance with this tool?
5) growth
Can the tool be structured in such a way as to allow for economic growth
(entry of new producers into an industry, for example) while still meeting
environmental requirements and/or Canadian commitments?
6) speed
How quickly will the environmental / health targets be reached with this tool?
7) fairness
Does this tool impose an unfair burden on certain individuals/sectors in the
market?
8) intrusiveness/flexibility
What level of government knowledge and involvement will be required to
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effectively apply this tool? To what extent does this tool leave to producers and
consumers the specific detailed decisions about how to achieve environmental
/ health targets?
9) data requirements
What will be the data requirements for the use of this tool (including monitoring
data) in terms of quality, intensiveness, and availability?
10) compatibility
Will the application of this tool support or be in conflict with established
jurisdictional responsibilities, existing regulations and/or self-regulation
initiatives? Is the enabling legislation for this tool currently available?
11) public acceptability
Will the use of this tool for environmental management be readily accepted by
the public?
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