Refractory ceramic fibre industry: environmental performance agreement overview

This environmental performance agreement (the 2013 agreement) was in effect for 5 years, from March 18, 2013 to March 18, 2018. The 2013 agreement successfully met its commitments. It is the third agreement with the refractory ceramic fibre industry.

Full text of the 2013 agreement

Objectives

The objectives of the 2013 agreement were to maintain the maximum allowable fenceline concentration for refractory ceramic fibres in ambient air, maintain reporting requirements for refractory ceramic fibres, promote inspection and maintenance of pollution control equipment, and confirm the commitment of the refractory ceramic fibres industry to maintain a product stewardship program.

Signatories

The 2013 agreement was negotiated between Environment and Climate Change Canada (ECCC) and the following 5 companies from the refractory ceramic fibre industry:

• Canadian Ferro Industries
• Fibercast Inc.
• Pyrotek Industries Inc.
• Thermal Ceramics
• Wolf Steel Limited (Napoleon)

Key requirements

The participating companies agreed to:

• respect the maximum fenceline concentration of 0.05 fibre/cc
• ensure that pollution control equipment is routinely inspected and maintained, repaired in a timely manner, and that all records are kept for five years
• maintain a product stewardship program
• require an annual management review of refractory ceramic fibres pollution control equipment and ensure that all identified corrective actions are being addressed
• complete and submit annual reports by June 1 of each year and participate in a verifiable audit process

Performance results

Annual reports for the 2013 to 2016 reporting years were received from all participating companies. The following is a summary of how the companies met the targets established in the 2013 agreement, based on their submissions.

2013 to 2016 annual report summary:

• all companies submitted annual reports
  • no company exceeded their respective refractory ceramic fibres use threshold limit
  • no company made significant changes to its process or control equipment
• all companies conducted regular inspections of air pollution control equipment
  • in 2014, two companies identified and implemented corrective actions following the pollution control equipment inspections
• all companies had a product stewardship program in place
• all companies conducted annual management reviews of refractory ceramic fibres emission controls

Verification audit

In order to ensure the terms of the agreement were satisfied, verification audits were conducted in March 2017.

The verification team visited all participating companies and reviewed the following:

• refractory ceramic fibre manufacturing processes and quantities
• process equipment and machinery inside the facility
• pollution control equipment located inside and outside the facility
• implementation of a product stewardship program  including all safety procedures, Workplace Hazardous Materials Information System (WHMIS) information and personal protective equipment
  • this includes all safety procedures and equipment
• documentation on procedures, equipment maintenance, management review, safety procedures and annual reports

Based on the results of the verification audit, all five companies conformed to the terms of the 2013 agreement. One company confirmed that they no longer use refractory ceramic fibres in their facility. The information collected during the audits will be used to determine the appropriate path forward with the 2013 agreement following its expiry in 2018.

Next steps

Determine the appropriate path forward following the agreement’s expiration in 2018.

Background information

Refractory ceramic fibres were declared toxic under the Canadian Environmental Protection Act by Environment and Climate Change Canada and Health Canada in 1994. These fibres are man-made, and used primarily as insulation in high-temperature industrial applications such as furnace linings, kilns, process heaters, pipe wrapping, welding protection, filters, flame retardants and acoustical insulation. Refractory ceramic fibres require full life-cycle management, in order to prevent or minimize their release into the environment.

A multi-stakeholder issue table was formed to recommend management options for refractory ceramic fibres. While the risks associated with emissions of refractory ceramic fibres into the environment were believed to be low, the issue table proposed that a time-limited monitoring program be established to provide additional trend-line information about refractory ceramic fibres emissions (released from vents, outlets or stacks) as well as the concentrations of refractory ceramic fibres in ambient air at the property boundaries of each plant to better determine the level of risk to the general population. The issue table also recommended that manufacturers and processors implement a comprehensive product stewardship program.

After conducting a review of a number of management options, the issue table concluded that the goal and targets for the manufacturing and processing of refractory ceramic fibres could be achieved by a voluntary agreement.

In response, an environmental performance agreement was signed by ECCC and the manufacturers and processors of refractory ceramic fibres in 2002, and renewed in 2006 and 2013, with the objective to prevent and minimize emissions of refractory ceramic fibres.

Prior to the 2013 renewal, audits conducted in 2010 demonstrated that participating companies generally conformed to the 2006 agreement and air emissions of refractory ceramic fibres were well below the targeted threshold. Further, industry stakeholders have commented on the gradual replacement of refractory ceramic fibres materials with non-toxic substitutions (i.e., soluble fibre) in order to eliminate use of refractory ceramic fibres in some products. The 2013 renewal of the agreement was negotiated with industry in order to maintain the very low levels of air emissions and to encourage the use of alternatives. Modifications were incorporated into the 2013 agreement that reduce the overall burden, specifically:

• removal of the annual fenceline testing requirement, except in the case of any increase of refractory ceramic fibres use greater than the use criteria established in the previous agreements, when testing would be reinitiated and an air monitoring report required
• modification of the annual reporting requirements to include quantity used

For more information on refractory ceramic fibres, see Management of Toxic Substances

Response to comments

The 2013 agreement was posted for public consultation on ECCC's website for 30 days. No public comments were received.

Past agreements and reports

• For the full texts of the 2002 and 2006 agreements, please send an email to ec.epa-epe.ec@canada.ca
• Performance Summary Report: The 2006 Refractory Ceramic Fibre (RCF) Environmental Performance Agreement

Related information

Links to sites external to ECCC are provided as a convenience, and their inclusion in no way implies that ECCC endorses or accepts any responsibility for the content or use of these sites. As the organizations that maintain these sites may not be subject to the Official Languages Act, information found on these sites may be presented only in the language in which it was originally written.

• NIOSH Manual of Analytical Methods: NIOSH Method 7400, Asbestos and Other Fibres by PCM for ambient testing
• HTIW Coalition (High Temperature Insulation Wool Industry)
• Overall environmental performance agreement results

This environmental performance agreement (the 2006 agreement) was in effect for 5 years, from October 23, 2006 to October 23, 2011. The 2006 agreement successfully met its commitments. It was the second agreement with the refractory ceramic fibre industry.

Objectives

The objectives of the 2006 agreement were to establish a maximum allowable fenceline concentration for refractory ceramic fibres in ambient air, establish monitoring and reporting requirements for refractory ceramic fibre emissions, promote inspection and maintenance of pollution control equipment and confirm the commitment of the refractory ceramic fibre industry to establish and maintain a product stewardship program.

Signatories

The 2006 agreement was signed between Environment and Climate Change Canada and nine companies from the refractory ceramic fibre industry:

• CFM Majestic
• Canadian Ferro Industries
• Fibercast Inc.
• Gemcast Manufacturing Inc.
• Pyrotek Industries Inc.
• RHI Canada
• Thermal Ceramics
• Tremco Canada Division R.P.M. Canada
• Wolf Steel

Key requirements

The key requirements for the 2006 agreement were to:

• respect the maximum fenceline concentration of 0.05 fibres/cc
• establish and maintain an air monitoring program requiring each manufacturer and processor to annually monitor refractory ceramic fibre emissions
• establish and implement procedures to ensure that pollution control equipment is routinely maintained and inspected, repaired in a timely manner and that records of inspection and maintenance are kept for at least 5 years
• require participation in the Refractory Ceramic Fibres Coalition (RCFC) Product Stewardship Program by adopting key elements such as:
  • the use of engineering controls
  • handling practices and protective equipment to control exposure to airborne refractory ceramic fibres
  • education of employees and promotion of guidance materials to customers on refractory ceramic fibre stewardship
  • participation in site visits from the RCFC
  • require an annual management review of refractory ceramic fibre pollution control equipment to ensure implementation of corrective actions
• submit an annual report to Environment and Climate Change Canada by June 1^st of each year
• assist in developing and participating in a verifiable audit process for the agreement

Performance results

• Air monitoring program:
  • Using an independent consultant, the six participating companies (as well as an additional company that was not a signatory to the agreement) sampled and monitored stack (vent source) air emissions and ambient air concentrations of refractory ceramic fibres in 2002 and 2003. The monitoring showed that fenceline ambient levels of refractory ceramic fibres were very low to undetectable and that stack emissions of refractory ceramic fibres had low fibre concentrations. Fenceline ambient air monitoring will continue under the 2006 agreement to ensure that the maximum allowable fenceline concentration of refractory ceramic fibres in ambient air is not exceeded.
• Maintenance and inspection of pollution control equipment:
  • The 2002 agreement did not include any reporting on inspection of equipment, although results of the air monitoring program suggest that equipment maintenance and inspection programs were adequate. Further information on pollution control equipment maintenance, inspection and repair will be gathered and reported under the 2006 agreement to ensure continued implementation of these programs.
• Product stewardship programs:
  • In 2004, the industry met with Health Canada, Natural Resources Canada and Environment and Climate Change Canada to discuss increasing the sector's participation in a product stewardship program. It was decided that the product stewardship program would be a key focus of the renewed agreement.

Product stewardship definition

Product stewardship is a cradle-to-grave management system based on industry and consumers taking responsibility for all stages in the life cycle (manufacture, use, storage, reuse, disposal, etc.) of the products that they produce and use. It includes, but is not limited to, measures to prevent pollution, to reduce the burden on waste disposal and recycling systems, and to internalize the cost of pollution associated with products and their packaging.

There is no template for a product stewardship system. Each company should design their own stewardship system to suit their unique location, products and overall approach. One company might focus its effort on product redesign or process changes to prevent pollution whereas another might focus on recycling.

Background information

After conducting a review of a number of management options, the issue table concluded that the goal and targets for the manufacturing and processing of refractory ceramic fibres could be achieved by a voluntary agreement. The first agreement was signed in 2002 with six refractory ceramic fibre manufacturers and processors to establish and maintain monitoring of stack (vent sources) and ambient air concentrations of refractory ceramic fibre emissions at the property boundaries of facilities, to determine the maximum level of refractory ceramic fibre emissions to which a member of the public at ground level could potentially be exposed. The 2002 agreement also required reporting of refractory ceramic fibre releases, transfers and disposals, implementation of procedures to routinely maintain and inspect pollution control equipment and the introduction of a product stewardship program.

The results of the 2002 agreement informed the renewal of the agreement in 2006. The 2006 agreement built on the lessons learned in the first agreement and emphasized the development and implementation of a product stewardship program for the sector. The 2006 agreement:

• included three additional companies that were not signatories to the first agreement
• reflected the fact that further stack sampling is not necessary
• reflected the fact that reporting of refractory ceramic fibre releases to the National Pollutant Release Inventory will no longer be required through this agreement
• provided more details on what is expected for the product stewardship program
• added a requirement for an annual management review of performance with respect to the goals set, progress on continual improvement and corrective actions to address deficiencies
• added a requirement for annual progress reporting to Environment and Climate Change Canada
• included a commitment from signatories to develop jointly with Environment and Climate Change Canada an acceptable, verifiable audit process
• extended the timeframe for the agreement

This Environmental Performance Agreement (the 2002 agreement) was in effect for 5 years, from February 20, 2002 to December 31, 2006. The 2002 agreement successfully met its commitments. It was the first agreement with the refractory ceramic fibre industry.

Objectives

The objectives of the 2002 agreement were to gather actual emission data to determine whether additional controls on refractory ceramic fibre emissions were needed and to confirm the commitment of the refractory ceramic fibre industry to the establishment and maintenance of a product stewardship program.

Signatories

The 2002 agreement was signed between Environment and Climate Change Canada and six companies from the refractory ceramic fibre industry:

• Fibercast
• Pyrotek Industries
• Wolf Steel
• Thermal Ceramics
• RHI Canada
• CFM Majestic

Key requirements

The key requirements for the 2002 agreement were to:

• establish and maintain an atmospheric monitoring program requiring each manufacturer and processor to annually monitor refractory ceramic fibre emissions
  • the monitoring program included stack monitoring as well as ambient air monitoring near the boundary of the facility's property, to determine the maximum level of refractory ceramic fibre emissions to which a member of the public at ground level could potentially be exposed
• to report releases, transfers and disposals of refractory ceramic fibres to Environment and Climate Change Canada
• to establish and implement procedures to ensure that pollution control equipment is routinely maintained and inspected
• to introduce a product stewardship program within two years of the signing of the 2002 agreement

Performance results

The following is a summary of how the companies met the requirements of the 2002 agreement, based on their annual submissions.

• Air monitoring program:
  • Using an independent consultant, the six participating companies, as well as an additional company that was not a signatory to the agreement, sampled and monitored stack (vent source) air emissions and ambient air concentrations of refractory ceramic fibres in 2002 and 2003. The monitoring showed that fenceline ambient levels of refractory ceramic fibres were very low to undetectable, and that stack emissions of refractory ceramic fibres had low fibre concentrations.
  • Under this agreement, the monitoring program was to be in effect for a period of five years, with a review of data after the first two years, to determine whether the monitoring of process stacks should continue for the full five years. Environment and Climate Change Canada and Health Canada reviewed the monitoring results and confirmed that there was negligible health risk for the general public associated with refractory ceramic fibre emissions from these plants, and that no further stack sampling was necessary.
• Reporting requirements for releases, transfers and disposals of refractory ceramic fibres:
  • Signatories were required to submit an annual report to Environment and Climate Change Canada in respect of refractory ceramic fibres, in accordance with the National Pollutant Release Inventory (NPRI) reporting requirements published each year in the Canada Gazette Part 1, as though refractory ceramic fibres were a substance listed in Part 1 of Schedule 1 of the NPRI Notices. Five of the six participating companies submitted data in 2002 using the NPRI Inventory reporting format, and four out of six submitted data in 2003.
• Maintenance and inspection of pollution control equipment:
  • The agreement did not include any reporting requirements on the inspection of equipment, although results of the air monitoring program suggest that equipment maintenance and inspection programs were adequate.
• Product stewardship programs:
  • In 2004, the industry met with Health Canada, Natural Resources Canada and Environment and Climate Change Canada to discuss increasing the sector's participation in a product stewardship program. It was decided that the product stewardship program would be a key focus of a new agreement that would include a greater number of participating companies.

Background information

The 2002 agreement was a 5-year agreement, but was re-negotiated in 2004/2005 to include additional processors of refractory ceramic fibres identified as meeting the criteria outlined in the 2002 agreement and to better define the details of the product stewardship program.

In 2004, Environment and Climate Change Canada proposed that refractory ceramic fibres be added to the NPRI to ensure greater consistency in reporting across this industry. However, after consultation with stakeholders, Environment and Climate Change Canada concluded that refractory ceramic fibres would not be added to the NPRI list of substances, but that further consultation with industry should be conducted and consideration given to a sector-wide approach.

The 2006 agreement was drafted, building on the lessons learned from the 2002 agreement and emphasizing the development and implementation of a product stewardship program for the sector.