The O.F.A. - Ontario Fabricare Association

Environment Canada is developing a national Regulation under Canadian Environmental Protection Act (CEPA) regarding PERC use and disposal by dry cleaning facilities.

Based on the report of the Ministers Expert Advisory Panel, PERC is considered to be a controlled substance and is subject to part 5 of controlled substances in Schedule one of CEPA.

In November 1999, pursuant to subsection 93(1) of the CEPA, the discussion paper #3a, "A proposal to Regulate Tetrachloroethylene for use in Dry Cleaning" was issued for consulation, with the objective of controlling multi-media discharge of PERC. The proposed regulations addresses general prohibitations, transfers and transport of solvent, discharge guidelines and reporting requirements for importers, and distributors of PERC.

Ontario Regulation 323/94 requires all sites where Dry -Cleaning is performed to have a fulltime person trained in the proper operation of equipment and handling procedures of solvents, wastes and residues in order to protect the environment and worker health and safety.

The following is a brief summary of the regulations governing the use of PERC and petroleum solvents in a Dry-Cleaning plant. It is imperative that every Dry-Cleaner in the Province of Ontario knows and understands these and all other regulations applicable to their plant and the industry in general. Knowing the Rules benefits everybody.

Our mission is to serve the customer and inform our members. We look forward to hearing from you.

1 As of June 30,1996 all Dry-Cleaning facilities in the Province of Ontario must have a minimum of one trained and licensed Certified Environmental Dry-Cleaner on staff working the normal regular hours of the cleaning operation. This requirement applies to both PERC and Petroleum plants. The licensed individual can be an owner, manager, or employee.

2 The owner of a Dry-Cleaning facility must apply to the Ontario Ministry of the Environment, for a Generator Registration Number to ship waste material.

3 All PERC and Petroleum waste from a Dry-Cleaning plant must be transported by a licensed carrier and accompanied by the proper documentation from cradle to grave. It is the plant owner's responsibility to ensure correct documentation is used; the quantity and type of waste being shipped and the maintenance and availability of records are on site for inspection.

4 All solvent must be kept in sealed containers, and inspected for leaks on a daily basis.

5 Accurate records of equipment maintenance should be kept up to date and on premises.

6 Air quality test should be preformed on a regular basis.

7 Keep an accurate record of the amount of chemicals used in dry-cleaning machine, soap sizing and PERC.

8 Keep an accurate record of the amount of clothes cleaned and the amount of PERC used. (pounds of clothes cleaned per gallon of PERC used)

9 All plant personnel must be instructed on how to react to a spill, and who to notify, in an emergency.

10 The spill team must have the necessary training and safety equipment available to react to a spill.

11 Workplace Hazardous Material Information System or WHMIS, clearly states that employees must be protected from all hazardous substances.

12 This is accomplished with proper material labeling,

13 Provide Material Safety Data Sheets (MSDS)

14 Train employees on precautions and handling procedures for hazardous material.

Additional information can be obtained from the Ontario Ministry of Environment and Energy MOOE, and from the Ontario Ministry of Labor MOL.

Tetrachloroethylene Regulations

(Use in Dry Cleaning and Reporting Requirements)

Regulation Background

Proposed regulation was published on August 18, 2001 Final Regulation: - Registered (law) on February 27, 2003 - Published in Canada Gazette on March 12, 2003 - Available in English, French, Chinese, Korean, Punjabi - Full regulatory text published in March/April issue of Fabricare magazine

Major Changes

Five major changes were made to the final regulation from the proposed regulation: Staggered timeline for coming into effect requirements Transport of residue and wastewater Annual reporting Carbon adsorber Drain plug

Prohibitions

No PERC in spotting agents - Jan 1 2004 No open containers for PERC or PERC-contaminated wastewater and residues - Jan 1, 2004 No transfer or second-generation machines - Jan 1, 2004 Includes - new machines to meet 10kg (6.2L) of PERC per 1,000 kg clothes cleaned - Aug 1, 2003 No PERC use in self-service machines - Feb 03 Impermeable containment for machine and containers capable of containing 110% capacity - Jan 1 2004 PERC resistant drain plugs that are readily available for use - Jan 1 2004 Sellers can provide PERC for use in machines with carbon adsorber until Jul 31 2005 All dry cleaning machines must be closed loop dry to dry refrigerated machines - Aug 1 2005

Waste, Water and Residue

Waste water means waste water containing PERC, that is produced by a dry-cleaning machine or during the regeneration of a carbon adsorber Owner/Operator Has Two Options For Disposal - Jan 1, 2004: - Send to waste management facility every 12 months; or - Treat by integral PERC water separator in machine or adsorber On-site waste water treatment system with: - A 2nd PERC-water separator to treat waste water from the integral separator - An initial filter with activated carbon - A monitor alarm that shuts down the waste water treatment system - A 2nd filter containing activated carbon that removes PERC from waste water after it passes the initial filter & alarm Transport of Waste Water: includes all waste water in dry clean facility at time of transport that has not been treated by 2nd treatment system - Jan 1, 2004 All residue to be transported to a waste management facility every 12 months - Jan 1, 2004 All residue in dry clean facility is to be transported at time of transport - Jan 1, 2004

Transfer Requirements

Applies to the transfer of PERC to a dry clean facility: PERC shall be transferred in a closed direct-coupled delivery system, which prevents the release of PERC - Jan 1, 2004

Reporting and Record keeping

Dry Cleaners - must use standard reporting form (to be supplied by Environment Canada) First annual report due April 30, 2005 Submit future annual reports by April 30th of each subsequent year Starting Jan 1 2004 begin record keeping and maintenance of books and records Keep records on site for five years

For more information

Gazette 2 information: http://www.ec.gc.ca/CEPARegistry/regulations Contact information: Environment Canada Ontario Region

- Brad Cumming (416) 739-5883 or brad.cumming@ec.gc.ca

- Lori Fryzuk (416) 739-5859 or lori.fryzuk@ec.gc.ca

- Brad May (416) 739-5901 or brad.may@ec.gc.ca