Refractory ceramic fibre industry: Environmental performance agreement overview

Objectives

The objectives of the 2024 agreement are to further 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 reaffirm the commitment of the refractory ceramic fibres industry to maintain a product stewardship program.

Signatories

The 2024 agreement was negotiated between Environment and Climate Change Canada (ECCC) and the following 4 companies from the refractory ceramic fibre industry:

• Fibercast Inc.
• Pyrotek Industries Inc.
• Thermal Ceramics (Morgan PLC)
• Wolf Steel Limited (Napoleon)

One company from the previous agreement withdrew after confirming they no longer use refractory ceramic fibres (RCF) in their facility.

Key requirements

The participating companies agree 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 5 years
• maintain a product stewardship program
• require an annual management review of RCF 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 will be received from all participating companies over the duration of the agreement. A summary of the annual report submissions will be produced and posted after every reporting year.

Verification audit

In order to ensure the terms of the agreement are satisfied, verification audits will be conducted at some point over the duration of the agreement and results will be posted. 

Background information

RCF were declared toxic under the Canadian Environmental Protection Act by ECCC and Health Canada in 1994. These are amorphous man-made vitreous fibres produced from the melting of calcined kaolin clay or a combination of alumina and silica, whose primary market is in high-temperature industrial applications such as furnace linings, kilns and process heaters, pipe wrapping, welding protection, gaskets, filters, flame retardants, and acoustical insulation.  

RCF require full life-cycle management to prevent or minimize their release into the environment.

A multi-stakeholder issue table was formed to recommend management options for RCF. While the risks associated with emissions of RCF 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 RCF emissions (released from vents, outlets or stacks) as well as the concentrations of RCF 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 several management options, the issue table concluded that the goal and targets for the manufacturing and processing of RCF could be achieved by a voluntary agreement.

The first agreement was signed in 2002 with 6 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 which determines the maximum level of refractory ceramic fibre emissions to which a member of the public at ground level could potentially be exposed. It also required the 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 2 years after signing the 2002 agreement. The 2002 agreement was a 5-year agreement but was re-negotiated in 2004/2005 to also include additional processors of RCF identified as meeting the criteria outlined in the 2002 agreement.

In 2004, ECCC proposed that RCF be added to the National Pollutant Release Inventory (NPRI) to ensure greater consistency in reporting across this industry. However, after consultation with stakeholders ECCC concluded that RCF 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 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 further implementation of a product stewardship program for the sector. The 2006 agreement:

• included 3 additional companies that were not signatories to the first agreement
• reflected the fact that further stack sampling was not necessary
• reflected the fact that reporting of refractory ceramic fibre releases to the NPRI will no longer be required through the agreement 
• provided more details on what was 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 ECCC
• included a commitment from signatories to develop jointly with ECCC an acceptable, verifiable audit process
• extended the timeframe for the agreement

Audits conducted in 2010 demonstrated that participating companies generally conformed to the 2006 agreement and air emissions of RCF were well below the targeted threshold. Further, industry stakeholders have commented on the gradual replacement of RCF materials with non-toxic substitutions (such as soluble fibre) in order to eliminate use of RCF 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 reduced the overall burden, specifically:

• removal of the annual fenceline testing requirement, except in the case of any increase of RCF 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

The 2024 agreement was established based on previous agreements.

Response to comments

The 2024 agreement was posted for public consultation on ECCC's website for 30 days. No public comments were received.

Consultation on proposed renewal of the environmental performance agreement for the refractory ceramic fibre industry.

Related information

• Management of Toxic Substances: Refractory ceramic fibres
• NIOSH Manual of Analytical Methods: NIOSH Method 7400, Asbestos and Other Fibres by PCM for ambient testing
• HTIW Coalition (High Temperature Insulation Wool Industry)

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

For a copy of the agreement, email: epe-epa@ec.gc.ca

Objectives

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

Signatories

The 2013 agreement was negotiated between 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 5 years
• maintain a product stewardship program
• require an annual management review of RCF 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 2018 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 2018 annual report summary:

• all companies submitted annual reports
  • no company exceeded their respective RCF 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, 2 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 RCF 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, personal protective equipment, and 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 5 companies conformed to the terms of the 2013 agreement. One company confirmed that they no longer use RCF in their facility.

Response to comments

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

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.

For a copy of the agreement, email: epe-epa@ec.gc.ca

Objectives

The objectives of the 2006 agreement were to establish a maximum allowable fenceline concentration for RCF 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 ECCC and 9 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 RCF
  • 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 ECCC 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 6 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 RCF in 2002 and 2003. The monitoring showed that fenceline ambient levels of RCF were very low to undetectable and that stack emissions of RCF had low fibre concentrations. Fenceline ambient air monitoring will continue under the 2006 agreement to ensure that the maximum allowable fenceline concentration of RCF 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 ECCC 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.

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.

For a copy of the agreement, email: epe-epa@ec.gc.ca

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 ECCC and 6 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 RCF to ECCC
• to establish and implement procedures to ensure that pollution control equipment is routinely maintained and inspected
• to introduce a product stewardship program within 2 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 6 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 RCF in 2002 and 2003. The monitoring showed that fenceline ambient levels of RCF were very low to undetectable, and that stack emissions of RCF had low fibre concentrations.
  • Under this agreement, the monitoring program was to be in effect for a period of 5 years, with a review of data after the first 2 years, to determine whether the monitoring of process stacks should continue for the full 5 years. ECCC 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 RCF:
  • Signatories were required to submit an annual report to ECCC in respect of RCF, in accordance with the NPRI reporting requirements published each year in the Canada Gazette Part 1, as though RCF were a substance listed in Part 1 of Schedule 1 of the NPRI Notices. 5 of the 6 participating companies submitted data in 2002 using the NPRI inventory reporting format, and 4 out of 6 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 ECCC 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