Toluene diisocyanates (TDIs): P2 notice performance report

Pollution Prevention (P2) Planning is a process by which organizations can improve their environmental protection by strategically planning to reduce or eliminate pollution before it is created.

Last update: January 2017

Facilities subject to the P2 Planning Notice (Notice) for the Polyurethane and Other Foam Sector (except Polystyrene) have submitted their declaration confirming that a Pollution Prevention Plan (P2 Plan) has been implemented.

Two progress reports were previously published in 2014 and in 2015 based on information reported within interim reports filed by the subject facilities. This final report summarizes the information and results of this Notice.

Context

In November 2011, Environment and Climate Change Canada published a Notice in the Canada Gazette which applies to any person or class of persons who, on the date of publication of the Notice or any time thereafter, meets the following two criteria:

1. owns or operates a facility within the polyurethane and other foam sector (except polystyrene) that, at any time, purchases, imports or uses 100 kg/yr or more of TDIs
2. is involved in one or more of the following activities:
   • manufacturing of flexible slabstock foam, flexible moulded foam, rigid foam or structural foam
   • rebonding of foam

Note that TDIs storage and the cutting and shaping of the above-mentioned foams are included in these activities.

Affected persons must prepare and implement a P2 plan, based upon consideration of all the factors to consider listed in the Notice. This includes determining industrial releases of TDIs to air and keeping their on-site releases to air at or below 100 kg/yr or, alternatively, their TDI concentration in ambient air at or below 0.2 µg/m³. In addition, individual facilities are required to report releases annually to Environment and Climate Change Canada for four consecutive years.

Following the publication of the P2 Planning Notice, 14 facilities were required to report annually. Information presented in this document is derived from these submissions. The submissions are available to the public upon request by contacting:

Environment and Climate Change Canada
Regulatory Innovation and Management Systems
Telephone (toll free): 1-844-580-3637
Fax: 819-420-7386 / 1-844-580-3638
Email: ec.planp2-P2Plan.EC@canada.ca

Summary of releases

The Notice identifies two options for determining industrial releases of TDIs to air. Of the 14 facilities, eight selected the option to measure or estimate actual on-site releases of TDIs to air, while six chose the option to predict TDI concentration at the facility boundaries using modelling. None of the facilities that measured or estimated actual on-site releases of TDIs to air exceeded the threshold of 100 kg/yr. However, 50% of the facilities that predicted their TDI concentration in ambient air surpassed the concentration threshold of 0.2 µg/m³ before they started implementing their actions. As of 2014, all 14 facilities met the quantity or concentration threshold.

All facilities implemented a set of actions to reduce or maintain their emissions under the threshold values stated in the P2 Notice. Twelve facilities completed the actions listed in their plan by November 26, 2014, and the remaining two facilities fully implemented their P2 plan in 2015. All 14 facilities that implemented their plan, have now submitted the "Declaration that a Pollution Prevention Plan Has Been Implemented."

Results for facilities that measured or estimated actual on-site releases of TDIs to air

Based on information submitted, over 213 kg of TDIs were released to air in the Preparation Year (2012), and about 95 kg of TDIs were released during the implementation year (2015). This represents an overall reduction of 55% of TDIs releases to air for all 14 facilities that implemented their P2 plans. These results do not include releases from the six facilities that reported on concentration of TDIs at or beyond the facility boundaries, as concentration cannot be directly related to emissions. Chart 1 illustrates the yearly actual on site releases of TDIs to air for each of the eight facilities for the four years between the preparation to the implementation of the plan.

Chart 1: Total TDIs on-site emissions by facility

Note that although none of the facilities that measured or estimated actual on-site releases of TDIs to air exceeded the emission threshold of 100 kg/yr by facility, six of them expressed their intent to implement actions to further reduce their emissions of TDIs.

Results for facilities that predicted TDI concentration in ambient air using modelling

Chart 2 shows the results for maximum 24-hour average concentration of TDIs at the fence line as reported by the six facilities that used modelling to predict TDI concentration in ambient air since the 2012 Preparation Year. All facilities assessed environmental protection options and implemented pollution prevention or pollution control methods to reduce their emissions and keep TDI concentrations at the facility boundaries at or below 0.2 µg/m³.This represents an average concentration reduction of 94% for the three companies that were above the concentration target of 0.2 µg/m³.

Chart 2: TDI concentration at the fence line

Releases of TDIs to air as reported in the National Pollutant Release Inventory (NPRI)

While the objective of the Notice is not an overall reduction of industrial releases of TDIs, the implementation of this Notice could yield a positive effect on the overall reduction of releases of these substances to the environment.

Chart 3 shows a chronology of Canadian emissions of TDIs from all facilities that met the reporting threshold for TDIs within the NPRI since 2006, when the assessment of TDIs was initiated by Environment and Climate Change Canada and Health Canada. Emissions began to decline progressively in 2008, when the substances were found to be toxic to human health. This chart also shows the estimated quantity of TDIs used annually in Canada since 2007.

Note that although the use of TDIs has not changed much in the last five years, emissions have been reduced considerably.

Eleven of the 14 facilities covered by the P2 Planning Notice also reported to the NPRI or have historically reported to the NPRI since 2006.

Chart 3: Releases of TDIs reported to the NPRI and estimated quantity of TDIs used in Canada (dual scale)

Sources: NPRI^Footnote1 and adapted from Statistics Canada.

In order to improve the monitoring of emissions of TDIs, Environment and Climate Change Canada reduced the reporting threshold to the NPRI from 10 tonnes (t) to 0.1 t (100 kg). This change was implemented in 2014, as published in the Canada Gazette on July 12, 2014. During the 2014 and 2015 reporting years, new facilities became subject to the new reporting threshold and began reporting to the NPRI. The total emissions of TDIs have increased due to this increase in the number of facilities reporting, and not necessarily due to increase of uses and releases of the substances.

Environmental Protection actions taken to achieve the risk management objective

The federal government’s position is that pollution prevention is the most effective means of protecting the environment, eliminating costly waste and promoting sustainable development. P2 focuses on avoiding the creation of pollutants rather than trying to manage them after they have been created. As a factor to consider in preparing their P2 plans, foam facilities were asked to give priority to P2 activities. In 2012, 79% of the actions completed or planned to be taken by subject facilities during the implementation of their respective plans were P2 methods (see Chart 4 below). The most common methods used were good operating practices and training (28%), and spill and leak prevention programs (24%). Some facilities chose a combination of P2 methods.

Chart 4: Distribution of environmental protection methods chosen by facilities subject to the Notice to reduce emissions of TDIs

Conclusion

Results in the reports submitted to Environment and Climate Change Canada over the lifetime of the Notice, demonstrate that all 14 facilities met the requirements of the Notice. The overall reduction of TDIs releases for the eight facilities that measured or estimated actual on-site releases of TDIs to air was 55%. The reduction of TDIs releases for the six facilities that used modelling to predict TDI concentration in ambient air was of 94%. All 14 facilities either remained or reduced their releases under the limits prescribed by the Notice.

Given total reduction of releases to air from the users of TDIs for the Polyurethane and Other Foam Sector (except Polystyrene), it is concluded that the objective of this Notice was successfully achieved. TDIs releases to the environment will continue to be monitored, notably through the NPRI, to determine if further risk management is warranted.

Sources

• Pollution Prevention Planning Online Reporting Tool and Database
• Factsheet for P2 Planning Notice in Respect of TDIs
• Environment and Climate Change Canada, National Pollution Reporting Inventory website  
• Adapted from Statistics Canada, Annual Data on Imports and Exports for specific HS10 and HS08 Codes by Country of Origin and by Country of Destination, 2014. This does not constitute an endorsement by Statistics Canada of this report.