Here is an outline of what is required of you to retain your MOE approval.

Enviro Database Solutions Inc. can get all this information for you and place it in your account on your behalf.

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With so many requirements for you to save documents relating to your Ministry of the Environment approvals, do you have the time to take care of this? Tired of searching for paperwork when you need to lay your hands on it immediately? Create your own account, accessible only by you, to produce the documents you need 'right away'. With your own account, you have control of everything you need. Update your maintenance logs, equipment & spray manufacturer and model numbers, exhaust filter systems, coating & manufacturer application records & amounts.

It is crucial to be able to produce the required documents 'on demand' when an inspector arrives. As regulations get tighter, the onus is on you to prove that you are operating within the constraints of your Certificate of Approval(CofA) or your Environment Compliance Approval(ECA).

Scratching down notes and filter changes is no longer good enough. Here are some excerpts from the MOE 245/11 Regulation and they are worth the read.

Here is what criteria you must meet to use EASR (Environmental Activity Sector Registry):

1. If the facility is located in a building that is wholly occupied by the facility, the facility has at least one and not more than three spray booths and does not exceed a facility-wide coating application rate of six litres per hour under normal operation.

2.   If the facility is located in a building that contains more than one unit, at least one of which is not occupied by the facility, the facility has only one spray booth and does not exceed a facility-wide coating application rate of two litres per hour under normal operation.

3.   For each of the facility’s spray booths, the distance, measured horizontally, between the following two points is not less than the minimum setback distance set out in Table 1 of this subsection for the facility’s facility-wide coating application rate under normal operation:

               i.   The centre of the spray booth’s exhaust stack.

              ii.   The point on the facility’s property line that is nearest to the centre of the spray booth’s exhaust stack.

4.   If the facility contains one or more spray booths that are served by fans that are indoors, for each of the spray booths one of the following criteria is satisfied:

               i.   The distance, measured horizontally, between the following two points is not less than the minimum setback distance set out in Table 2 of this subsection for the number of spray booths in the facility:

                        A.   The centre of the spray booth’s exhaust stack.

                        B.   The point nearest the spray booth’s exhaust stack that is on the property line of a noise receptor.

              ii.   Acoustic barriers that have a density of at least 12 kilograms per square metre are installed that block the direct line of sight between the spray booth’s exhaust stack and every noise receptor in respect of which the distance, measured horizontally, between the following two points is less than the minimum setback distance set out in Table 2 of this subsection for the number of spray booths in the facility:

                        A.   The centre of the spray booth’s exhaust stack.

                        B.   The point nearest the spray booth’s exhaust stack that is on the property line of a noise receptor.

5.   If the facility contains one or more spray booths that are served by fans that are outdoors, for each of the outdoor fans one of the following criteria is satisfied:

               i.   The distance, measured horizontally, between the following two points is not less than the minimum setback distance set out in Table 3 of this subsection for the number of spray booths in the facility:

                        A.   The outdoor fan.

                        B.   The point nearest the outdoor fan that is on the property line of a noise receptor.

              ii.   Acoustic barriers that have a density of at least 12 kilograms per square metre are installed that block the direct line of sight between the outdoor fan and every noise receptor in respect of which the distance, measured horizontally, between the following two points is less than the minimum setback distance set out in Table 3 of this subsection for the number of spray booths in the facility:

                        A.   The outdoor fan.

                        B.   The point nearest the outdoor fan that is on the property line of a noise receptor.

6.   The waste water from the facility, if any,

               i.   is transferred to a waste management system that is subject to an environmental compliance approval,

              ii.   is discharged to a sewage works that is subject to an environmental compliance approval, or

             iii.   is discharged to a municipal sanitary sewer.

7.   If the facility is located in an area of development control within the Niagara Escarpment Planning Area, the person engaging in the prescribed activity has obtained any development permit required under section 24 of the Niagara Escarpment Planning and Development Act and, if a permit has been issued, ensured that the requirements of this Regulation are not in conflict with any conditions of the permit.

Table 1
Minimum setback from facility’s property line

 

Item

Facility-wide coating application rate under normal operation

Minimum setback distance

1.

≤ 2 litres per hour

No setback required

2.

> 2 to ≤ 3 litres per hour

20 metres

3.

> 3 to ≤ 4 litres per hour

38 metres

4.

> 4 to ≤ 5 litres per hour

55 metres

5.

> 5 to ≤ 6 litres per hour

75 metres

Table 2
Minimum setback from noise receptor’s property line — Indoor fans

 

Item

Number of spray booths in the facility

Minimum setback distance

1.

1

40 metres

2.

2

55 metres

3.

3

75 metres

Table 3
Minimum setback from noise receptor’s property line — outdoor fans

 

Item

Number of spray booths in the facility

Minimum setback distance

1.

1

60 metres

2.

2

85 metres

3.

3

120 metres

    (3)  Any activities relating to the construction of a structure, equipment, apparatus, mechanism or thing that is used in an automotive refinishing facility for the purposes of automotive refinishing that are carried out at a site other than the automotive refinishing facility are not prescribed activities for the purposes of subsection 20.21 (1) of the Act.

    (4)  This section does not apply to the following automotive refinishing facilities:

      1.   A facility that manufactures motor vehicles or motor vehicle parts.

      2.   A facility that is primarily engaged in the replacement and repair of glass with respect to motor vehicles.

      3.   A facility that is primarily engaged in the repair of mechanical or electrical components of motor vehicles.

      4.   A mobile refinishing facility.

      5.   A facility that controls the emissions from a spray booth using water wash filtration.

 

 -On or before the first anniversary of the day you received approval and on or before every anniversary thereafter, you must review the information you submitted for approval and file complete and accurate information or file a confirmation that the information you submitted is complete and accurate.

 -On the fifth anniversary of when your Environmental Compliance Approval (ECA) came into effect, the approval ceases to apply to the activity and you must re-apply.

That is just the building & equipment criteria. Here are the Activity Requirements of the Act:

Activity Requirements:

    21.  (1)  For the purposes of clause 20.21 (1) (c) of the Act, a person shall not engage in an activity prescribed by section 19 of this Regulation with respect to automotive refinishing at an automotive refinishing facility unless,

    (a)   the facility’s spray booth filtration systems, coating application equipment, spray booths and other associated equipment are used, operated and maintained in a manner that satisfies the recommendations of the manufacturers of the systems, booths or equipment;

    (b)   the coatings that are used at the facility,

             (i)   meet the requirements of the Volatile Organic Compound (VOC) Concentration Limits for Automotive Refinishing Products Regulations, SOR-2009/197 made under the Canadian Environmental Protection Act, 1999, as amended from time to time,

            (ii)   are only applied within a spray booth,

           (iii)   are only applied between the hours of 7 a.m. and 7 p.m.,

           (iv)   are, with respect to being water-based or solvent-based, kept separate while stored or used and are not mixed together when disposed of, and

            (v)   are only applied by use of one of the following pieces of equipment:

                      (A)   HVLP spray equipment that is identified by the manufacturer as having a minimum transfer efficiency of 65 per cent,

                      (B)   electrostatic spraying equipment,

                      (C)   any other coating application equipment that is accompanied by documentation from the manufacturer that states the equipment has a minimum transfer efficiency of 65 per cent;

    (c)   subject to subsection (2), the facility’s spray booth exhaust stacks are vertical with no flow impediments and discharge at a velocity of not less than 12 metres per second;

    (d)   subject to subsection (2), the minimum height, above ground, of each of the facility’s spray booth exhaust stacks is,

             (i)   if the height of the building is completely uniform, at least 1.5 times the height of the building,

            (ii)   if the height of the building is not completely uniform, at least 1.5 times the height of the building where the stack is located and at least as high as the highest point of the building;

    (e)   all the intake or exhaust fans related to the facility’s spray booths are used and operated only between the hours of 7 a.m. and 7 p.m.;

    (f)   the facility’s spray booths are equipped with filters that are specified by the manufacturer to remove at least 95 per cent of particles from the spray booth exhaust stack’s emissions;

    (g)   the facility-wide coating application rate does not exceed the rate set out in Table 1 of subsection 19 (2) for the minimum setback distance with respect to the distance, measured horizontally, between the center of each of the facility’s spray booth exhaust stacks and the point on the facility’s property line that is nearest to the stack;

    (h)   any structure, equipment, apparatus, mechanism or thing that is used or operated in the facility for the purpose of sanding, grinding or buffing of motor vehicles or motor vehicle parts is only used or operated if all doors to the facility are closed, except to allow for the normal ingress and egress of vehicles and personnel; and

     (i)   the person engaging in the activity or the manager of the facility if the person engaging in the activity does not manage the facility, and all personnel engaged in the use of coatings at the facility, receive training in accordance with section 4.3 of the Canadian Council of Ministers of the Environment publication entitled National Standards and Guidelines for the Reduction of Volatile Organic Compounds from Canadian Commercial/Industrial Surface Coatings Operations - Automotive Refinishing, dated October 1998, as amended from time to time and available on the Council’s website.

    (2)  If an environmental compliance approval applies to an automotive refinishing facility, clauses (1) (c) and (d) do not apply to a spray booth exhaust stack that was part of the facility at the time the approval was issued, unless a change has been made to the exhaust stack or the spray booth has been replaced since that time.

 

Here are the records that are required to be kept:

Records:

    22.  (1)  A person who engages in an activity prescribed by section 19 with respect to an automotive refinishing facility shall ensure that the following documents and records are accessible at the facility:

      1.   A log in which the following information is recorded with respect to each of the automotive refinishing facility’s spray booths:

               i.   A record of the name of the manufacturer and the model number, if any, of the spray booth.

              ii.   A record of the name of the manufacturer and model number, if any, of all spray equipment.

             iii.   A record of the name of the manufacturer and model number, if any, of all spray booth exhaust filtration systems.

             iv.   A record of the name of the manufacturer, model number, if any, and rating in cubic metres per second of all spray booth exhaust fans.

      2.   A log in which the following information is recorded with respect to each coating application at the automotive refinishing facility:

               i.   A record of the date, time and duration of the application.

              ii.   A record of the name and manufacturer of each coating used in the application.

             iii.   A record of an estimate in litres of each coating used in the application.

      3.   A log in which the following information is recorded with respect to inspections, maintenance or repairs of any structure, equipment, apparatus, mechanism or thing that is used in the automotive refinishing facility for the purposes of automotive refinishing:

               i.   A record of each inspection, maintenance or repair, including the date and a summary of the inspection, maintenance or repair undertaken.

              ii.   A record of the name of the person who performed the inspection, maintenance or repair.

             iii.   If the person referred to in subparagraph ii is an employee, a record of the name of the person’s employer or the name of the business that employs the person.

             iv.   A record of any unsatisfactory conditions observed or discovered and the steps taken to correct such conditions.

      4.   A copy of every document relating to inspections, maintenance or repairs of any structure, equipment, apparatus, mechanism or thing that is used in the automotive refinishing facility for the purposes of automotive refinishing.

      5.   Documents relating to the recommendations of the manufacturer with respect to the use, operation and maintenance of any structure, equipment, apparatus, mechanism, or thing that is used in the automotive refinishing facility for the purposes of automotive refinishing.

      6.   A document containing a list of the persons responsible for the use, operation and maintenance of the facility and the training, including the course name and date, undertaken by each person who has received training referred to in clause 21 (1) (i).

      7.   If any equipment described in sub-subclause 21 (1) (b) (v) (A) or (C) is used at the facility, copies of documents provided by the manufacturer that specify the transfer efficiency of the equipment.

      8.   A log in which the following information is recorded with respect to a complaint received by the person with respect to the automotive refinishing facility that relates to the natural environment:

               i.   A record of the date and time each complaint was received.

              ii.   A record describing the complaint.

             iii.   A record describing the measures taken, if any, to address the complaint.

      9.   A copy of the complaint referred to in paragraph 8, if it is a written complaint.

    (2)  The person referred to in subsection (1) shall ensure that every document or record that is referred to in paragraphs 2 to 4, 6, 8 and 9 of subsection (1) is accessible at the site of the automotive refinishing facility for a period of five years from the day the record or document is created.

 

 

Not so easy and it must be accurate.

Enviro Database Solutions Inc. can get all this information for you and place it in your account on your behalf.

Why not let EDS handle everything for you?
Right from planning, to logging, to compliance, we can do it all!

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