Tin stabilizers in the vinyl industry: Environmental performance agreement overview

Objective

The objective of this agreement is to prevent the release of tin stabilizers into the environment through the full implementation of the Guideline for the environmental management of tin stabilizers in Canada (the guideline) by all Canadian vinyl compounding facilities using tin stabilizers. The guideline helps achieve this objective by providing direction on responsible handling, storage, use and disposal of tin stabilizers.

Signatories

As of October 2023, the agreement was signed by representatives from Environment and Climate Change Canada (ECCC), the Vinyl Institute of Canada (VIC) and 31 companies with vinyl compounding facilities.

Key requirements

The participating companies agree to:

• undergo site visit verifications to determine if the guideline continues to be fully implemented
• prepare corrective action plans for any required improvements identified during verifications

Each year of the agreement, 3 randomly selected participating facilities will undergo a site visit verification and new facilities will be verified within 24 months after the facilities start to use tin stabilizers.

Participating facilities that have undergone significant changes, as defined in the 2020 agreement, will submit all required documentation to the VIC and ECCC within 3 months following the signing of the agreement or following the submission of their annual compliance report identifying those changes. The verifiers will conduct a verification by examining the submitted documentation and by performing a site visit, if required.

Deadlines

• Facility annual reports (Appendix G): All participating facilities will submit their annual reports directly to the VIC 
  • Deadline: June 30 (annually) 
• Consolidated annual report: The VIC will submit the report to ECCC 
  • Deadline: September 30 (annually)   
• Summary of results: The results will be posted by ECCC under "Performance Results" and "Verification Results" below
  • Deadline: Annually

Performance results

The first, second and third consolidated annual reports were submitted by VIC to ECCC covering the period of April 1, 2020 to March 31, 2023. These reports indicate that all participating facilities have fully implemented the practices as outlined in the guideline.

Consolidated annual reports focus on the proper handling, storage and use of tin stabilizers, waste containing tin stabilizers, the handling of empty packaging, record keeping and any significant changes which have occurred at the facilities since the facility was last verified (whether under a former or the current agreement).

Verification results

A team consisting of representatives from the VIC and ECCC undertook the site verifications and site visit reports were prepared by the VIC with the concurrence of ECCC

Due to the COVID-19 pandemic, it was not possible to conduct the 6 site visit verifications planned for the first 2 years of the 2020 agreement. To compensate, a total of 9 site verifications were conducted in the third year of the agreement. The following information summarizes the verifications that took place during the third year of the agreement.

Third year

Based on the consolidated annual report submitted for the third year of the agreement, 1 facility reported a significant change. The facility started to receive tin stabilizers in bulk in addition to receiving tin stabilizers in totes. The verifiers found 1 area for improvement related to this significant change as per the implementation of the guideline. Following the verification period, confirmation was provided that the area for improvement was addressed before the final report was submitted. Therefore, neither a corrective action plan nor a site visit was required.

Site verifications undertaken during the third year of the agreement found areas for improvement at 8 out of the 9 facilities visited as indicated in the table below. In all cases, the areas for improvement were addressed before the final verification reports for each facility were submitted; therefore, no corrective action plan was required.

Next steps

• Continue the implementation of the 2020 agreement
• Perform site verifications as defined in the agreement to determine whether the practices and procedures identified in the guideline are being followed
• Put an environmental monitoring program in place to further evaluate the effectiveness of the agreement. 
  • This will determine whether any further action will be needed to prevent the release of tin stabilizers in the environment

Background information

As of 2004, the Vinyl Council of Canada (VCC), the Tin Stabilizers Association (TSA) and industrial users of tin stabilizers introduced the voluntary Guideline for the Environmental Management of Tin Stabilizers in Canada to prevent the release of tin stabilizers into the environment by ensuring that these substances and their packaging materials are handled, stored, used and disposed of in a responsible manner. On November 18, 2005, ECCC proposed developing an agreement with the VCC and TSA to ensure full industry adherence with the guideline.

On April 23, 2007, ECCC published the Draft Follow-up to the 1993 ecological risk assessment of organotin substances on Canada's domestic substances list. The draft assessment report concluded that the actions implemented by the vinyl industry have reduced the potential for releases of mono- and di-organotins to levels that are not of concern to the environment. These actions are codified in the guideline prepared and implemented by the VCC and TSA. In August 2009, ECCC concluded that tin stabilizers do not meet the criteria of toxicity set out in the Canadian Environmental Protection Act, 1999, due mainly to voluntary industry-wide stewardship practices in place to limit their environmental release. This had been achieved by the implementation of preventative measures identified in the guideline.

To verify that these stewardship measures were in place, a first 5-year agreement, from 2008 to 2013, was put in place between ECCC and the vinyl industry (the 2008 agreement). The purpose of this agreement was to prevent the release of tin stabilizers into the environment through the full implementation of the guideline by all vinyl compounding facilities using tin stabilizers in Canada.

The 2008 agreement was successful in achieving its intended objectives. All 33 facilities using tin stabilizers had fully implemented the guideline. A performance summary report was published in July 2014 summarizing the results achieved under the 2008 agreement. The performance summary report is available upon request.

When the 2008 agreement expired, ECCC, the Canadian Plastics Industry Association (CPIA), the VCC, and companies with facilities using tin stabilizers determined that a second agreement would be the best way to ensure the continued implementation of the guideline. The agreement was signed by representatives from ECCC and the VCC on March 17, 2015, and it expired on March 16, 2020 (the 2015 agreement). During this agreement, in January 2017, ECCC received notice from the CPIA that the VCC had elected to transfer its responsibilities under the agreement to the VIC. To ensure the continuous implementation of the agreement, the VIC took on all the roles and responsibilities previously assumed by the VCC as identified in the agreement.

The 2015 agreement met the objective of preventing the release of tin stabilizers into the environment. Based on the verifications and re-verifications subject to the 2015 agreement and the annual compliance reports, the facilities using tin stabilizers had fully implemented the guideline. A summary report was published in March 2021 summarizing the results achieved under the 2015 agreement.

In 2019, ECCC, the VIC and companies with facilities using tin stabilizers determined that a third agreement would be the best way to ensure the guideline will continue to be followed. This third environmental performance agreement is in effect for 5 years, from May 15, 2020 to May 14, 2025.

Response to comments

The proposed 2020 agreement was posted for a 1-month public consultation on the Government of Canada’s website, which ended on January 6, 2020. No public comments were received.

Past agreements

For the full text of the 2008 or 2015 agreement, guidelines, or the performance summary report of these agreements, please send your request to: epe-epa@ec.gc.ca. 

Related information

• Follow-up to the ecological risk assessment of organotin substances on Canada's domestic substances list
• Annual report on compliance with the guideline for the environmental management of tin stabilizers in Canada

The 2015 environmental performance agreement (the 2015 agreement) was in effect for 5 years from March 17, 2015 to March 16, 2020.

Objective

The objective of the agreement was to prevent the release of tin stabilizers into the environment through the full implementation of the Guideline for the environmental management of tin stabilizers in Canada (the guideline) by all Canadian vinyl compounding facilities using tin stabilizers. The guideline helps achieve this objective by providing direction on responsible handling, storage, use and disposal of tin stabilizers.

Signatories

The agreement was originally signed on March 17, 2015, by representatives from Environment and Climate Change Canada (ECCC), the Vinyl Council of Canada (VCC), an operating council of the Canadian Plastics Industry Association (CPIA), and participating companies with vinyl compounding facilities. In January 2017, ECCC received notice from CPIA that the VCC had elected to transfer its responsibilities under the agreement to the Vinyl Institute of Canada (VIC). The VIC agreed to take on the VCC’s roles and responsibilities identified in the 2015 agreement. On March 2, 2017, the agreement was amended and signed by all the parties.

As of March 2020, there were 31 facilities using tin stabilizers who were signatories to the 2015 agreement.  

Key requirements

The participating companies agreed to:

• undergo site visit verifications to determine whether the guideline continued to be fully implemented as specified in the agreement
  • more specifically, annually, at 3 randomly selected participating facilities that were previously verified under the former agreement but that did not meet the definition of new facilities
  • new facilities were to be verified within 24 months after the facilities started to use tin stabilizers
• prepare corrective action plans for any deficiencies that were identified when the final site visit report was issued

Participating facilities that had undergone significant changes, as defined in the 2015 agreement, were to submit all required documentation to the VIC and ECCC within 3 months following the signing of the agreement or following the submission of their annual compliance report identifying those changes. The verifiers were then to conduct a verification by examining the submitted documentation and by performing a site visit, if required.

Performance results

During the 2015 agreement, the following verification activities were conducted:

• 15 site re-verifications at randomly selected facilities
• 2 site verifications at new facilities, performed within 24 months after they started to use tin stabilizers
• 4 documentation verifications for the facilities that had undergone significant changes

All areas for improvement identified during the verifications were addressed by the facilities and therefore no action plans were required. These verifications demonstrated the full implementation of the guideline by facilities subject to the 2015 agreement by having in place the procedures and practices recommended in the guideline.

All facilities completed and submitted their annual compliance report to the VIC for each reporting year from 2015 to 2020. These reports were reviewed and consolidated by the VIC to produce an annual compliance report that was submitted to ECCC. The consolidated annual reports focused on the proper handling of tin stabilizers and wastes containing tin stabilizers, the handling of empty packaging, record keeping and any significant changes which had occurred at the facilities since the facility was last verified (whether under the former agreement or the current one). All reports received indicated that all participating facilities had fully implemented the practices as outlined in the guideline.

The results of the 2015 agreement show success in meeting the objective of preventing the release of tin stabilizers into the environment.

Verification results

A team consisting of a representative from the VIC and an ECCC official undertook the verifications, followed by site visit reports prepared by the VIC with the concurrence of ECCC.

The following summarizes the verifications that took place during the 5 years of the agreement. The fifth verification period took place from March 17, 2019, to March 16, 2020. During this period, 4 site verifications, including the verification of a new facility, were conducted.

First year

May 1, 2015 (Vi-Lux Building Products Inc. located in Napanee, Ontario): a significant change had occurred at this facility since the previous verification on October 19, 2011, under the former environmental performance agreement. The facility provided all required documentation to the verifiers and they determined that a site visit was not required in this case. Following the verification, the facility demonstrated the full implementation of the guideline as it pertained to the significant change. The verifiers found no areas for improvement; therefore, no corrective action plan was required.

September 30, 2015 (Gentek located in Burlington, Ontario): the verifiers found no areas for improvement; therefore, no corrective action plan was required. Following the verification, the facility demonstrated the continuing implementation of the guideline.

November 24, 2015 (Duchesne et Fils Ltee located in Yamachiche, Quebec): the verifiers found 3 areas for improvement. Following the verification, confirmation was provided that the 3 areas for improvement were addressed before the final report was submitted; therefore, no corrective action plan was required.

November 25, 2015 (Soniplastics Inc. located in Boucherville, Quebec): the verifiers found 2 areas for improvement. Following the verification, confirmation was provided that the 2 areas for improvement were addressed before the final report was submitted; therefore, no corrective action plan was required.

Second year

August 23, 2016 (IPEX Inc. located in Clarkson, Ontario): the verifiers found no areas for improvement; therefore, no corrective action plan was required. Following the verification, the facility demonstrated the continuing implementation of the guideline.

September 15, 2016 (Abbotsford Pipe, a Division of Royal Group Inc. located in Abbotsford, British Columbia): a significant change had occurred at this facility since the previous verification on July 8, 2009, under the former environmental performance agreement. The facility provided all required documentation to the verifiers and they determined that a site visit was not required in this case. The verifiers found 3 areas for improvement related to this significant change. Following the verification, confirmation was provided that the 3 areas for improvement were addressed before the final report was submitted; therefore, no corrective action plan was required.

September 28, 2016 (Westech Building Products Limited located in Calgary, Alberta): the verifiers found 3 areas for improvement. Following the verification, confirmation was provided that the 3 areas for improvement were addressed before the final report was submitted; therefore, no corrective action plan was required.

November 24, 2016 (Window City Industries Inc. located in Vaughan, Ontario): the verifiers found no areas for improvement; therefore, no corrective action plan was required. Following the verification, the facility demonstrated the continuing implementation of the guideline.

Third year

July 28, 2017 (IPEX Inc. located in Edmonton, Alberta): a significant change had occurred at this facility since the previous verification on September 7, 2010, under the former environmental performance agreement. The facility provided all required documentation to the verifiers and they determined that a site visit was not required in this case. Following the verification, the facility demonstrated the full implementation of the guideline as it pertained to the significant change. The verifiers found no areas for improvement; therefore, no corrective action plan was required.

September 12, 2017 (REHAU Industries Inc. Located in Baie-D’Urfé, Quebec): the verifiers found no areas for improvement; therefore, no corrective action plan was required. Following the verification, the facility demonstrated the continuing implementation of the guideline.

September 13, 2017 (Next Polymers located in Prescott, Ontario): the verifiers found no areas for improvement; therefore, no corrective action plan was required. Following the verification, the facility demonstrated the continuing implementation of the guideline.

October 25, 2017 (IPEX Inc. located in Saint-Joseph-de-Beauce, Quebec): the verifiers found no areas for improvement; therefore, no corrective action plan was required. Following the verification, the facility demonstrated the continuing implementation of the guideline.

Fourth year

March 28, 2018 (Blendtech Polymers Inc. located in Farnham, Quebec): the verifiers found 9 areas for improvement at this new facility. Following the verification, confirmation was provided that the 9 areas for improvement were addressed before the final report was submitted; therefore, no corrective action plan was required.

September 12, 2018 (IPEX Inc. located in Langley, British Columbia): a significant change had occurred at this facility since the previous verification on July 9, 2009, under the former environmental performance agreement. The facility provided all required documentation to the verifiers and they determined that a site visit was not required in this case. Following the verification, the facility demonstrated the full implementation of the guideline as it pertained to the significant change. The verifiers found no areas for improvement; therefore, no corrective action plan was required.

September 26, 2018 (IPEX Inc. located in Edmonton, Alberta): the verifiers found 3 areas for improvement. Following the verification, confirmation was provided that the 3 areas for improvement were addressed before the final report was submitted; therefore, no corrective action plan was required.

October 23, 2018 (Galata Chemicals Inc. located in Bradford, Ontario): the verifiers found no areas for improvement; therefore, no corrective action plan was required. Following the verification, the facility demonstrated the continuing implementation of the guideline.

October 24, 2018 (Royal Group Inc., Roytec Vinyl facility in Woodbridge, Ontario): the verifiers found 1 area for improvement. Following the verification, confirmation was provided that the 1 area for improvement was addressed before the final report was submitted; therefore, no corrective action plan was required.

Fifth year

August 28, 2019 (Kaytec located in Cowansville, Quebec): the verifiers found 6 areas for improvement. Following the verification, confirmation was provided that the 6 areas for improvement were addressed before the final report was submitted; therefore, no corrective action plan was required.

August 29, 2019 (IPEX Inc. located in Saint-Jacques-de-Montcalm, Quebec): the verifiers found 1 area for improvement. Following the verification, confirmation was provided that this area for improvement was addressed before the final report was submitted; therefore, no corrective action plan was required.

October 22, 2019 (Clariant Plastics and Coatings Canada Inc. located in Toronto, Ontario): the verifiers found 2 areas for improvement. Following the verification, confirmation was provided that the 2 areas for improvement were addressed before the final report was submitted; therefore, no corrective action plan was required.

October 23, 2019 (Vision Profile Extrusions located in Woodbridge, Ontario): the verifiers found 7 areas for improvement at this new facility. Following the verification, confirmation was provided that the 7 areas for improvement were addressed before the final report was submitted; therefore, no corrective action plan was required.

Response to comments

The proposed 2015 agreement was posted for public consultation on the Government of Canada’s website for 60 days, which ended on October 19, 2014. No public comments were received.

This environmental performance agreement (the agreement) was in effect from March 10, 2008 to March 9, 2013.

Objective

The objective of the agreement was to prevent the release of tin stabilizers into the environment through the full implementation of the Guideline for the environmental management of tin stabilizers in Canada (the guideline) by all Canadian vinyl compounding facilities using tin stabilizers. The guideline helps achieve this objective by providing direction on responsible handling, storage, use and disposal of tin stabilizers.

Signatories

The agreement was negotiated between Environment and Climate Change Canada (ECCC), the Vinyl Council of Canada (VCC) and the Tin Stabilizers Association (TSA).

Performance results

All facilities participating in the agreement completed their annual compliance report on handling practices of organotin stabilizers using the appendix G form for each reporting year. The reports from participating facilities were reviewed and consolidated by the VCC to produce an annual conformance report provided to ECCC for each reporting year.

The VCC completed and submitted to ECCC an update of annex B of the guideline, Report on tin stabilizer sold in Canada for the year 2011.

Overall, the guideline was implemented before the site verification by the majority of the facilities based on their best knowledge and understanding of the guideline. All areas for improvement that were identified during the site verifications were addressed by all of the facilities. 6 action plans have been developed, and all have been fully implemented.

Over the lifetime of the agreement (from March 2008 to March 2013), each of the 33 participating facilities were subject to a site verification conducted by representatives from ECCC and the VCC. The site verifications confirmed that the 33 facilities using tin stabilizers have in place the procedures and practices recommended in the guideline, and therefore have fully implemented the guideline.

Performance measurement of the agreement shows success in meeting the objective of preventing the release of tin stabilizers. It also confirmed the risk assessment assumption that if preventive measures are in place, tin stabilizers are non-toxic.

A performance summary report was published in July 2014 summarizing the results achieved under the 2008 agreement. It is available upon request.

Response to comments

The draft agreement was posted on ECCC's agreement website for a 60-day public consultation period, which ended on June 22, 2007. The only comments received pertained to general questions of clarification. As a result, no revisions were made to the draft agreement.