The line between “hazardous” and “non-hazardous” waste is often drawn in a somewhat arbitrary way, sometimes for historical reasons. Occasionally, it is possible to persuade the Ontario Ministry of the Environment to readjust the line. Canadian automotive manufacturers have had one of these rare successes, but mostly because the same waste has already been de-listed in the US.
The Canadian Vehicle Manufacturers Association (CVMA) and Ontario’s automobile manufacturers persuaded the MOE to follow the US and to amend Regulation 347 to remove one kind of automotive wastewater sludge produced by the chemical conversion coating of aluminum. Such sludges used to contain cyanide and chromium. According to the MOE, changes in the vehicle manufacturing process “have removed contaminants of concern which has resulted in the waste sludge no longer exhibiting any hazardous waste characteristics”…
However, it seems that that wasn’t enough. The MOE goes on to explain that it had OTHER good reasons to delist this particular waste:
“The amendment removes a disincentive to using more aluminum in the manufacturing of vehicles, producing lighter vehicles with better gas mileage and decreased exhaust emissions and greenhouse gas emissions. As well, it is in line with the US EPA’s delisting of this waste stream which helps maintain the competitiveness of Ontario’s automotive manufacturers.“
The sludge is therefore now a non-hazardous waste, and can go to an ordinary landfill, resulting in substantial savings to the auto companies. And if it is actually non-hazardous, this is exactly as it should be, regardless of vehicle gal mileage….