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Toronto’s medical officer of health has announced his decision to ask the city to adopt a proposed Environmental Reporting, Disclosure and Innovation Program.

The Program includes a proposed bylaw which, if implemented, will require  a wide number of businesses and City operations to publicly report their use and release of 25 hazardous chemicals, to be phased in starting January 1, 2010.  The 25 chemicals include benzene and fine particulates, and are listed on Schedule A of the Bylaw.The data would be made available on a searchable Internet site for residents seeking information on their communities. Another significant part of the program is aimed at supporting businesses to reduce their use of hazardous chemicals through more efficient equipment and processes, alternative chemicals and recycling rather than disposal.

The Medical Officer of Health will present  his recommendations to the next Board of Health meeting on November 17, 2008.

When the proposal was released for public comment this spring, many were concerned about the reporting burden it would create and about the limited value of the information to be collected. For example,  large amounts of these hazardous substances are emitted into Toronto air by individuals or organizations that are exempt from the bylaw; some because they are outside Toronto, and others because they have been granted exemptions.

Nevertheless, the MOH has decided that partial information is better than none, and that collection of such information cannot be left to the federal and provincial governments. The federal government collects information, but only from larger companies. The city hopes that  large companies which already report under NPRI will be able to use the web-based One Window for National Environmental Reporting System (OWNERS) system to meet their municipal obligations.

The province has proposed to adopt a new Toxics law, which  will overlap but not duplicate the city’s by law. Again, the city hopes to minimize duplicate reporting through cooperation with the province, but does not want to wait until the province gets its system running.

The essence of the proposed bylaw will be an obligation for every facility that uses minimum quantities of  a priority substance to file a mass balance report. Unlike the federal and provincial rules, it will not matter how small is the organization or how few its employees.

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