Environmental Performance Agreement with Screenprinting and Graphic Imaging Association International

Table of Contents

Environmental Performance AgreementBetweenHer Majesty the Queen in Right of Canada

as represented by the Minister of the Environment represented by the Regional Director General, Environment Canada, Ontario Region (herein after called Environment Canada)

AndScreenprinting and Graphic Imaging Association International (SGIA)AndParticipating Facilities in Ontario

1.0 Purpose of this Environmental Performance Agreement (EPA)

The purpose of this environmental performance agreement (EPA) is to achieve verifiable reductions in the use, generation and release of specified priority substances that are used in the screenprinting and digital imaging sectors. This initiative will focus on, but not be limited to, the VOCs listed in Appendix I of this EPA. An outcome of this EPA will be the development of a business sustainability model.

For each year of the EPA (2003 to 2008), the SGIA and the project coordinator will be undertaking activities to increase printer participation in the EPA. These activities will include site visits, workshops, and on-going communication via the telephone, mail and the Internet. Case studies and other results from the EPA will be published and provided to prospective participants.

Progress in reducing VOCs and other substances will be reported in such a way that increasing the number of participating facilities will not cause an increase in the total reported releases.

2.0 Glossary of Terms

Annual progress report
A report written by the project coordinator with input from the task force. The annual progress report summarizes the progress that has been made by the participating facilities toward achieving their established objectives and targets, including how the achievements have been derived. The progress made toward reduction targets may be reported as an aggregate number of all participating facilities.

Environmental performance agreement (EPA)
An agreement between government agencies and industry representatives that commits certain sectors or facilities to specific environmental challenges or performance levels. Hereby, EPA refers to this agreement and its schedules, as amended from time to time, as per the sections contained herein.

Environmental management system (EMS)
A systematic method of organizing, planning, reviewing and improving operations for better environmental performance and improved profitability.

Participating facilities
SGIA members and other screenprinting and digital imaging facilities that sign Appendix III (participating facility commitment form) of the EPA.

Parties
Signatories of the environmental performance agreement. In the case of this EPA, the parties are SGIA, Environment Canada, and each of the participating facilities that sign Appendix III of this EPA (participating facility commitment form).

Pollution prevention (P2)
The use of processes, practices, material, products or energy that avoid or minimize the creation of pollutants and waste and reduce overall risk to human health or the environment.

Project coordinator
The facility/person responsible for working with the parties to the EPA, to help achieve the objectives and targets set by the participating facilities, and to help achieve the objectives of the EPA. In the case of this EPA, Envision Compliance Ltd. is the project coordinator.

Screenprinting
A commercial and industrial printing technique that involves passing a printing medium, such as ink, through a taut fabric to which a refined form of stencil has been applied. The stencil openings determine the form and dimensions of the imprint that is produced.

Screenprinting and Graphic Imaging Association International (SGIA)
A trade association representing the interests of screen printing and digital imaging industrial facilities.

Self-certification
The process by which a participating member facility reports results and acknowledges that the reports are accurate. These results are with respect to objectives and targets set by the participating facility. A specific protocol (and form), based on EMS principles, will be available and required for self-certification.

Substances addressed in this EPA (hereafter referred to as substance)s
A substance that appears on any one of several lists including the National Pollutant Release Inventory (NPRI), CEPA 1999, Schedule 1 - List of Toxic Substances, Priority Substance List (PSL 1), Second Priority Substance List (PSL 2), Binational Toxics Strategy (BTS), Canada-Ontario Agreement (COA) and the Toronto Sewer Use Bylaw.

Task force
A committee comprising one representative from each of the parties to the EPA (i.e., SGIA, Environment Canada, and each of the participating facilities). The task force may invite suppliers to participate in the EPA process.

Third-party spot verification
The process by which either an SGIA representative or the project coordinator confirm the results reported by a participating facility. These results are with respect to objectives and targets set by the participating facility. A specific form will be available and required for third-party verification.

3.0 Parties to the EPA

This EPA will be signed by the president of the Screenprinting and Graphic Imaging Association International (SGIA), on behalf of the SGIA and its members, and Her Majesty the Queen in Right of Canada as represented by the Minister of the Environment, represented by the Regional Director General, Environment Canada, Ontario Region.

Participating facilities will sign the participating facility commitment form (Appendix III) and the participating facility objectives and targets form (Appendix IV). The objectives and targets form will outline the facility's objectives, targets and timelines for pollution prevention activities. The incentives that they will receive for participating in this EPA are detailed in Appendix II. Additional facilities may participate in this EPA without the need to amend the EPA, by signing a commitment form.

SGIA commits to promoting and recruiting nonparticipating screenprinting and digital imaging facilities to take part in this EPA.

4.0 Environmental Policies of this Environmental Performance Agreement

Facilities that participate in this EPA, commit to the following items:

  • Being in full compliance with all applicable federal, provincial and municipal legislation, and regulations
  • Implementing and sustaining an EMS
  • Using pollution prevention (P2) practices and techniques, when practicable, to achieve the environmental objectives and targets of Canada (e.g., reduction/elimination of substances as listed in Section 2.0 Glossary of Terms)
  • Monitoring and reporting annually on progress towards their objectives and targets
  • Continuously improving their environmental performance

All case studies and information will be available for spot verification by SGIA or the project coordinator, at the discretion of SGIA and Environment Canada.

Appendix II contains a summary of the actions to be undertaken by the parties to achieve the environmental objectives of this EPA.

5.0 Legal Status

This EPA does not and is not intended to establish legally-binding obligations among the parties, and is to be construed as a reflection of the dedication of the parties to achieve verifiable reductions in the use, generation and release of specified priority substances in the screenprinting and digital imaging sectors. This EPA does not constitute admission of liability by any of the parties.

Nothing in this EPA precludes the federal government from developing and implementing regulatory or other measures it deems appropriate. Nothing in this EPA precludes a participating facility from implementing other environmental initiatives.

Signatories to the EPA may terminate their participation by notifying the task force in writing, indicating the reasons why they are no longer able to participate.

6.0 Requirements for Participation

The following requirements must be met by facilities for participation in this EPA:

  • Sign Appendix III, the participating facility commitment form
  • Collect baseline information
  • Submit facility's objectives, reduction targets and timelines
  • Implement an EMS
  • Sign the participating facility objectives and targets form (Appendix IV)
  • Attend task force committee meetings
  • Submit information to the SGIA and the project coordinator, who will develop case studies for publication, as detailed in each facility's objectives and targets (information must be submitted two times/year to allow the project coordinator to write at least one case study per year for each participating facility)

7.0 Environmental Management System (EMS)

All participating facilities and facilities shall develop and maintain a documented EMS. An important element of an EMS is to establish objectives and set targets for achieving those objectives. At a minimum, each participating facility must identify objectives and targets related to this EPA as part of their EMS. (Note: Participating facilities may also have many objectives and targets in their EMSs that are not related to this EPA).

In addition to EPA-related objectives and targets, each participating facility must include the following in its EMS:

  • Designation of who is responsible for achieving objectives and targets, and reporting on results, and the specific roles of the responsible people
  • Procedures and plans for how the objectives and targets will be achieved
  • Timeframe by which objectives and targets will be achieved

8.0 Objectives and Targets

Objectives and targets will be developed by each of the participating facilities, with input from the task force. Objectives and targets will take into consideration the participants; their financial, operational and business requirements; their potential environmental impact; the technological options available to them; their legal and other requirements; and the views of interested parties. Objectives and targets will be consistent with the environmental objectives of this EPA, including its commitment to pollution prevention.

The task force may choose to establish aggregate reduction targets for specific substances (see Appendix I), based on the individual reduction targets set by each participating facility. Therefore, each participating facility would be required to monitor and report progress to the SGIA on its objectives, implementation, methods and targets. The SGIA would provide a summary report to ts, the task force when necessary to protect proprietary information and would provide aggregate reductions to the task force for information only, with respect to the preparing the annual yearly progress report and case studies.

The use of aggregate reduction targets would not preclude a participating facility from publicly disclosing its individual progress toward objectives and targets, or to have a site-specific case study submitted to the task force for publication in the progress report.

9.0 Structure and Responsibility of the Task Force

This EPA will be managed by a task force comprising the project coordinator and a representative from each of the following organizations:

  • Screenprinting and Graphic Imaging Association International (SGIA)
  • Environment Canada
  • Representative from each of the signatory facilities

The role of the task force is to manage the implementation of this EPA, to review progress, to make recommendations for improvements,

to promote participation by screenprinting and digital imaging facilities, and to communicate with interested parties on progress made.

The task force will meet at least four times a year. The meetings will be held in conjunction with training sessions, when possible. A maximum of two meetings will be via teleconferencing. There must be a representative from at least two participating facilities in attendance in order to conduct a meeting.

Task force decisions will be achieved by a two-thirds or greater majority of all task force members, both present and not present at a meeting.

For each year of this EPA, the task force will publish an annual progress report. Additionally, the task force will aid the project coordinator in efforts to obtain new members/facilities to become signatories to this EPA. The incentives for attracting new facilities are detailed in Appendix II.

10.0 Training

Training courses will be provided by SGIA and Environment Canada when there is a common need identified by the task force. Training needs will be established and reviewed annually by the task force. Training in courses related to this EPA will be a requirement for participation in the EPA. (See Appendix II, Section 6.0 Incentives and Consequences.)

11.0 Communication

Communication of case studies shall be done via the Internet. All case studies will be posted on Environment Canada's The Green Lane website (www.on.ec.gc.ca), and SGIA's website (www.sgia.org). The task force will supply hardcopy versions of the case studies to the Canadian Centre for Pollution Prevention (C2P2). Environment Canada will send copies of this EPA to various members of the ENGO community and to the Canadian Centre for Pollution Prevention for their review and comment.

12.0 Case Studies

Twice each year, participating facilities must provide information to SGIA with respect to their progress in achieving their objectives and targets. The project coordinator will use the information to generate at least two one case studyies per year per participating facility. Facilities will be required to assist in the preparation of the case study. Prior to any publication of a case study or report the members of the task force will be given an opportunity to review and provide comments.

Case studies generated from this EPA, will be published within the annual progress report and will be made available to the general public for review on various web sites.

13.0 Document Control

Control of all documents related to this EPA is the responsibility of the task force SGIA. Participating facilities have the right not to release information that would put them at a competitive disadvantage.

All records created as a result of this EPA shall be kept so they are legible, identifiable, and traceable to their creator. Records must be stored so to avoid damage, deterioration or loss. All records related to this EPA must be retained for the life of the EPA and in accordance with regulatory requirements (i.e., three years according to CEPA record retention).

Upon written request by the participating facility, SGIA and the project coordinator will hold as confidential specific information identified. However, the results reported by all participating facilities will be used in reporting aggregate information, to fulfill the requirements for public reporting, as listed in this EPA.

14.0 EPA Control

Project control resides with the task force. The task force must agree to any changes made to this EPA. Suggested changes will be distributed to the task force prior to meeting and added to the agenda for discussion at the meeting.

The task force will review progress of actions under the EPA and review the need for new annexes to address emerging issues. With the consent of task force members, the signatories may, through mutual consent, amend Section 4.0 Environmental Policies of this Environmental Performance Agreement, to permit additional representatives to become participants.

15.0 Monitoring and Measurement

The participating facilities under their internal EMS will conduct monitoring and measurement of their objectives and targets. Updates toward documented objectives and targets with respect to this EPA shall be submitted to the task force every six months.

16.0 Corrective Action Report

All participating facilities that do not meet published objectives or targets must submit corrective action reports (CARs) to the SGIA (for confidentiality reasons) or to the task force, at the time of annual reporting. CARs will identify the root cause of the problem and make recommendations to avoid similar problems in the future. CARs, along with case studies, will demonstrate continuous improvement, towards objectives and targets. A summary of the number of CARs completed each year will be provided in the annual progress report.

17.0 Spot Verification of Case Study Information

Case study information, including both results and actions taken, as submitted by each participant, shall periodically undergo spot-verification using procedures and protocols that build upon established EMS principles. Spot verifications will be conducted periodically by either the project coordinator or SGIA, and at the discretion of SGIA and Environment Canada.

18.0 Time of EPA

This EPA will terminate on January 31, 2008 unless it is renewed through mutual written agreement of the signatories.

Any signatory to this EPA may terminate their participation by giving written notice to the other signatories/participating task force members at least 60 days in advance.

19.0 Public Consultation

The proposed EPA and appendices or future amendments to this EPA will be posted on Environment Canada's The Green Lane, and the SGIA website for a period of 30 days. Written comments on this EPA will be considered by the parties before finalizing the EPA.

Environment Canada will be responsible for translating the proposed EPA and appendices, as well as any future amendments, to French, prior to posting on the Environment Canada The Green Lane for a 30-day consultation period.

Addresses and Notices:

Unless otherwise expressly provided for in this EPA, any notice required or authorised to be given by any of the parties to the another shall be served by letter sent by facsimile or prepaid registered mail to either of the appropriate following addresses:

(a) If to the Regional Director General, Environment Canada, Ontario Region:

Brad Cumming, Head Pollution Prevention and Mining
Environmental Protection Branch - Federal Programs Division
4905 Dufferin St, 2nd Floor
Downsview, ON M3H 5T4
Tel.: (416)739-5883
Fax: (416)739-4342

(b) If to the SGIA and the participating facilities:

Marci Kinter, Vice President - Government Affairs
Screenprinting & Graphic Imaging Association International
10015 Main Street
Fairfax, VA 22031-3489
Tel.: (703) 359-1312
Fax: (703) 273-2870

or any other office, address or facsimile number as may be stipulated in writing by the parties in the future.

IN WITNESS WHEREOF, the Parties hereto have caused this EPA to be executed by their respective authorized representatives.

Michael Robertson, President and CEO
Screenprinting and Graphic Imaging Association International

Date:

Place:

John Mills
Regional Director General, Environment Canada, Ontario Region

Date:

Place:

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