Sector Performance Report - Plastics Products Manufacturing

In fiscal year 2007-08, Sector Compliance Branch (SCB) inspected 147 plastics products manufacturing facilities in the following five sub sectors:

• Plastic Bag Manufacturing
• Plastic Plumbing Fixtures Manufacturing
• Plastic Bottle Manufacturing
• Polystyrene Foam Product Manufacturing
• All Other Plastics Products Manufacturing

The facilities were selected randomly and were located throughout the province of Ontario. This allowed for an assessment of behavioral trends in environmental compliance.

The manufacturing of plastic products includes three basic processes:

(1) addition of chemical additives to the plastic resin; (2) converting plastic resin mixture into a formed shape through molding; and (3) finishing the product.

Emissions and discharges from the manufacturing operations may include spills, leaks and fugitive emissions of chemicals during the application of additives prior to molding or during finishing; plastic pellet releases to the environment prior to molding; waste water discharges during cooling and heating, cleaning and finishing operations; and fugitive emissions from molding and extruding machines.

All generators of subject waste (hazardous waste and liquid industrial waste) are required to register in the ministry's  HWIN web-based system. The system tracks the types and quantities of subject waste generated and shipped for disposal.

Various types of wastes were generated by the plastics products industry. Some of the registered facilities generate more than one class of waste.

The top three wastes generated and shipped in 2007 by quantity were waste oils & lubricants, aliphatic solvents, and oil skimming & sludge.
Fugitive emissions from the molding processes include volatile organic compounds (VOCs).

Common chemicals emitted and released by plastics products manufacturers that are required to be reported to the Federal National Pollutant Release Inventory (NPRI) include VOCs, Nitrogen Oxides (NOx), Particulate Matter, Styrene, Toluene, Xylene (all isomers), Methyl ethyl ketone.

Inspection results: 

• 29 facilities (19.7%) were in compliance with all legislative requirements
• 118 facilities (80.3%) did not meet one or more administrative requirements of the regulations (administrative fail), but there were no associated environmental or health concerns
• No facilities failed the inspection i.e. had significant non-compliance resulting in environmental or health concerns.

The predominant issues found during the inspection sweep were:

• 78 instances where facilities lacked the required Certificates of Approval for air emissions (Environmental Protection Act – Section 9);
• 48 instances where wastes were retained on-site longer than 90 days  without notifying the ministry (Reg. 347); and
• 27 instances where a copy of the manifest was not returned to the ministry within the stipulated time (Reg. 347).

Following inspections of the 147 facilities, the SCB inspectors issued three Provincial Officers Orders, 115 Notices of Violation to 107 facilities, and 16 letters. 

The SCB continues to follow-up on Notices of Violations, Orders and letters issued to companies to ensure corrective action has been taken and compliance has been achieved. 

As of June, 113 facilities out of 118 have complied with their Notice of Violation, Order or letter. The ministry is working with the remaining 5 facilities to bring them into compliance.

Sector Performance Report: Plastics Products Manufacturing