After years of effort by Ontario’s mainstream auto recyclers, in cooperation with automobile manufacturers, the Ministry of the Environment is getting close to a permit-by-rule system for recycling end of life vehicles. Given the elaborate market that already exists for vehicle recycling, this is far better than the MOE’s standard “extended producer responsibility” model for these vehicles.
The Ministry of the Environment has long struggled to provide appropriate oversight of scrapyards, and vehicle recyclers of all sizes. Most are now exempt from regulation as “waste disposal sites” under the Environmental Protection Act, leaving a big regulatory gap.
Now, “the Ministry of the Environment is seeking input on a technical discussion paper that proposes regulatory changes that would apply new environmental standards to end-of-life vehicle (ELV) processing. The paper proposes the following:
- Requiring all ELVs to have contaminants removed (depolluted) prior to crushing or shredding
- Requiring any shipment of depolluted ELVs from an ELV processing site be accompanied by a notice confirming depollution
- Requiring eligible ELV processing sites to register on the Environmental Activity and Sector Registry (EASR)
- Clarifying the application of the “derelict motor vehicle site” exemption in Regulation 347 under the Environmental Protection Act
- Requiring site environmental management for the storage of waste, maintenance of equipment, mitigation of emissions and staff training
- A phased implementation over 2 years to provide time for the sector to adapt to the new requirements
Purpose of Policy:
The recycling of vehicles is a significant waste diversion activity in Ontario with approximately 600,000 vehicles recycled annually in the province. While a number of ELV processing facilities adhere to industry-led standards and already operate in an environmentally protective manner, there are currently no regulatory requirements for the safe removal and management of contaminants from ELVs. At the same time, past compliance activities undertaken by the Ministry of the Environment have identified environmental concerns pertaining to improper waste management (from the operation of ELV sites or at ELV sites). Bringing forward mandatory regulatory requirements would ensure that environmental management is happening across the whole ELV processing sector.
The proposed approach, described in the attached technical discussion paper, is to bring forward a range of policy changes that would impose recycling standards in a way that aligns with the Ministry of the Environment’s approvals modernization agenda. For example, persons operating ELV facilities would be required to register the activity in the Environmental Activity and Sector Registry through an efficient electronic registration process. Requirements would be imposed on those engaging in such activities through regulation so that consistent standards are applicable to the sector. The proposal also takes into account the fact that some sites may need time to modify their facility operations to meet the new standards. To facilitate the transition to new standards, a phased implementation is proposed over a two year period.
If implemented, the Ministry of the Environment would enforce compliance through a risk-based approach in consideration of the proposed phasing of requirements. As with other activities registered in EASR, ELV processing facilities would also be included on the Ministry’s Access Environment website which would provide information to the public about the operations registered in their community (see link under Additional Information).
Ontario’s Draft Waste Reduction Strategy (see EBR # 011-9262, link under Additional Information) sets out the province’s proposed road map for removing the current barriers to increasing diversion, and harnessing the environmental and economic value of waste. One action identified in the Strategy is to develop recycling standards for end-of-life vehicles (ELVs) so that this important waste diversion activity is done in a manner that protects the environment.
Public Consultation:
This proposal has been posted for a 60 day public review and comment period starting February 05, 2014.