Air Emissions and Odours from Cabinet Manufacturing
Contents |
Introduction
Two companies, Canac Kitchens and Raywal Ltd., manufacture kitchen cabinets in Thornhill, north of Toronto. The local office of the Ministry of Environment and Energy has received complaints about odours as far back as 1995 from local residents concerned about fumes from spray-paint booths at these operations.
Both facilities are required to report their annual total emissions of certain pollutants to the National Pollutant Release Inventory (NPRI) administered by Environment Canada. Excerpts of the NPRI release data for the two facilities are listed in the tables below.
NPRI data on emissions
Canac Kitchens Ltd. (NPRI data: On-site Releases (emissions) in tonnes)
| Year | Toluene | Xylene (mixed isomers) | Methyl ethyl ketone | Ethyl-benzene | Isopropyl alcohol | Methanol |
|---|---|---|---|---|---|---|
| 2000 | 44.28 | 37.46 | 24.9 | 11.33 | 16.19 | 13.79 |
| 1999 | 32.37 | 29.57 | 16.15 | ---- | 11.38 | 10.61 |
| 1998 | 32.13 | ---- | 20.4 | ---- | 11.08 | 11.83 |
| 1997 | 26.07 | ---- | 18.01 | ---- | ---- | 11.48 |
Raywal Ltd., Thornhill Ontario (NPRI data: On-site Releases (emissions) in tonnes)
| Year | Toluene | Isopropyl alcohol | Xylene (mixed isomers) |
|---|---|---|---|
| 2000 | 10.77 | 2.91 | 3.62 |
| 1999 | 7.92 | 2.90 | --- |
| 1998 | 6.54 | --- | --- |
| 1997 | 8.55 | --- | --- |
The NPRI data indicate that both facilities are gradually increasing their total annual
emissions of toxic substances like toluene and xylene, which are both easily absorbed
through inhalation. MOEE’s new Air Quality Standard for Toluene notes that chronic
exposure has been observed to cause headaches, dizziness, intoxication and eye
irritation. MOEE’s new xylene standard notes that chronic inhalation exposure
produces irritation of the eyes and respiratory system, headaches, disorientation
and the loss of full control of bodily movements.
Steps taken to address odour problems
Over the years, MOEE has taken several steps to address the odour problems. MOEE issued a Control Order in 1996 to Canac Kitchens, requiring odour control technology. At the time, the company invited local residents to two meetings to discuss concerns, installed more efficient spray guns, and outsourced certain production activities. In the summer of 2000, Canac Kitchens applied to amend its certificate of approval (C of A) for air discharges in order to install a new paint spray booth. MOEE added conditions to this C of A requiring annual odour-source testing. Nevertheless, local residents continued to complain about odours.
Request for Investigation
In September 2001, a request for an investigation under the EBR was submitted, alleging that the two companies had contravened several sections of the Environmental Protection Act, and were emitting toxic chemicals beyond the levels permitted in their Cs of A. The EBR applicants noted that strong chemical odours were present several times a week in the vicinity of the plants, and that the odours had gradually been increasing in strength and frequency over the past three years. They alleged that the odours were unpleasant, caused coughing, and were being emitted into a densely populated residential area that included four daycare facilities and several old age homes and schools.
The applicants noted that they had already tried other avenues to resolve their concerns, including speaking directly to the management of both facilities, contacting the local MOEE office frequently with complaints, and raising the matter with two previous Ministers of Environment and Energy, without being able to trigger a thorough investigation of actual discharge levels.
Ministry Response
In response to the applicants’ request, MOEE stated that no EBR investigation would be conducted because investigations of both companies were already ongoing. The ministry provided a brief update: In the case of Canac Kitchens, annual source testing was being required under an amended C of A, but results for the first annual cycle were not yet available. In the case of Raywal Ltd., the ministry had issued a Provincial Officer’s Order following an inspection in May 2001.
The ministry also noted that Raywal Ltd. had applied for two amendments to its C of A for Air, which were posted on the Registry in late summer 2001, and were still under review. The company was planning to install two dust collectors and add two spray booths.
ECO Comment
The ministry provided a very weak response to this EBR application for an investigation. In addition to stating that investigations were already ongoing, the ministry described activities that appear to be components of routine abatement, without the commitments that come with an EBR investigation — which would at least have guaranteed the concerned residents both a clear deadline and a final report from the ministry. The ECO is concerned that MOEE appears to have opted for a continuing abatement approach, despite acknowledging that the facilities have been the subject of numerous odour complaints and abatement activities over a number of years. MOEE’s Compliance Guideline (1995) suggests, in fact, that MOEE may require mandatory compliance where non-compliance will have adverse effects on humans and where previous abatement efforts have failed.
Although MOEE states that odour incidents have decreased, the NPRI data indicate that total annual emissions of several toxic (and odourous) pollutants have been increasing since 1997. However, according to MOEE, ministry staff have not reviewed the NPRI data for these facilities. The fact that the companies are adding spray- paint booths also suggests that emissions may be gradually increasing. In two site visits, on March 1 and 25, 2002, ECO staff encountered strong chemical odours in the vicinity of the companies. More recently, MOEE informed the ECO that Canac Kitchens emissions of n butyl acetate exceed the odour threshold marginally, and that while emissions of other substances meet odour criteria, they may still be causing odours, since it is hard to model dispersion of emissions accurately from very short emission stacks.
The ministry’s decision to deny an EBR investigation was made by the District Manager of the same local MOEE office that has for years been overseeing the abatement activities. It would have been preferable if the ministry had assigned the decision to staff from another region, who might have reviewed the history of this case with greater independence and a fresh viewpoint.
MOEE provided very poor customer service to the EBR applicants in this case. Several follow-up actions would have been appropriate. At a minimum, the ministry could have promised that results of source testing at Canac Kitchens would be available to the applicants and to the public at large. When the applicants complained that they were unable to access a certain certificate of approval without paying a fee, the ministry should have clarified that Cs of A are public documents that can be viewed without charge at the local MOEE office. The ministry could also have made the applicants aware of their rights under the EBR to seek leave to appeal decisions on Cs of A.
MOEE could also have considered the establishment of a citizens’ liaison committee to allow ongoing three-way discussions between proponents, residents and the ministry. Another alternative would have been for the ministry to use the enhanced public participation provisions under the EBR, including oral deputations, public meetings and mediation. These sections of the EBR have only rarely been used by MOEE, despite recommendations in the ECO’s 1998 annual report that they be better publicized and that ministry staff be trained in their use.
| Recommendation 16:
The ECO recommends that the Ministry of Environment and Energy evaluate options for reducing toxic and odorous emissions from two manufacturing facilities in Thornhill, work with proponents to ensure that effective solutions are implemented, and find ways to involve the public in the process. |
| This is an article from the 2001/02 Annual Report to the Legislature from the Environmental Commissioner of Ontario. |
Citing This Article
Environmental Commissioner of Ontario. 2002. "Air Emissions and Odours from Cabinet Manufacturing." Developing Sustainability, ECO Annual Report, 2001-02. Toronto, ON : Environmental Commissioner of Ontario. 126-129.
