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LEHDER News

Classification of Dangerous Goods Including Waste Streams

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TDG Part 2.2.1 states that a Consignor who allows a carrier to transport dangerous goods or imports dangerous goods is responsible for proof of classification for the dangerous goods information used on the shipping document.  This proof must be maintained for five (5) years and must be in a document that explains classification (i.e. test report, lab report, explanatory document) and include the following information:

  •  Date on which dangerous goods were classified;

  •  If applicable, the technical name of the dangerous goods;

  • The classification of the dangerous goods; and

  • If applicable, the classification method used under this Part or under Chapter 2 of the UN Recommendations.

For UN1267 (Petroleum Crude Oil) and UN1268 (Petroleum Distillates N.O.S.), special provision 92 states that proof of classification must be done on the basis of sampling and analysis.  The document used to explain the sampling method must include the following information:

  • The scope of the method;
  • The sampling apparatus;
  • The sampling procedures;
  • The frequency and conditions of sampling; and
  • A description of the quality control management system in place.

It is important to understand that the above applies not only to products but also waste. Any material shipped as a dangerous good, including waste, needs to have proof of classification of the determination of the UN number. If the waste stream is UN1267 or UN1268 then the waste stream must have been sampled and analysed in order to determine the appropriate classification.

For more information, please contact Mark Roehler.

New Air Dispersion Model Versions

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LEHDER Air Modeling ServicesThe MOECC has announced they will be adopting new updated versions of several regulatory air dispersion models shortly.  These models have been updated by the USEPA based on the latest available science.  The MOECC announcement to formally adopt new model versions was intended to provide clarity and consistency to the regulated community and stakeholders.  The mandatory use of the new versions of AERMOD, AERMET and ASHRAE models will become effective as of the date the MOECC posts an Information Notice on the EBR.  Based on the MOECC announcement, the posting of the Notice is expected in October 2015 which is  only a few months from now.

The new versions of AERMOD and AERMET will be version 14134 (dated May 14, 2014). The ASHRAE calculation method will be updated to the 2011 ASHRAE Handbook – HVAC Applications.

The transition to the new model versions can be complex depending upon the status of your ECA, pending ECA Application or abatement plans.  Once the new model version comes into effect, any modeling triggered for regulatory purposes must be completed using the new version unless your facility has a Section 7(1) notice.  Now is the time to evaluate how changes to the air dispersion models may affect your facility’s compliance.  

To learn more about how the new model version transition may affect your facility, please contact Penny McInnis at pmcinnis@lehder.com or (519) 336-4101 ext. 245.

Techincal Standard Posting and O. Reg. 419 Guidance Documents

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Technical Standard Posting

MOECC Techincal Standard Posting June 2015

The Ministry recently posted two proposal notices to the EBR related to Industry Standards.  The public comment period for the following documents ends June 18, 2015.

Amendment to the Foundries Industry Standard

Metal Finishers – Industry Standard


New Guidance Documents

New O. Reg. 419 guidance documents and technical bulletins are in the works, including:

  • Procedure for Preparing an Emission Summary and Dispersion Modelling Report
  • Air Dispersion Modelling Guideline for Ontario (ADMGO)
  • Guideline for the Implementation of Air Standards in Ontario (GIASO)
  • Guide to Requesting an Alternative Standard” (GRAS)
  • Guide To Applying For Registration To The Technical Standards Registry
  • Combined Assessment Of Modelled And Monitored Results (CAMM) as an Emission Rate Refinement Tool
  • Methodology For Using “Assessment Values” For Contaminants With Annual Air Standards
  • Approaches To Manage Open Industrial Fugitive Dust Sources

LEHDER is reviewing the proposed guidance documents and will discuss the details and potential ramifications of the proposed changes in the LEHDER News blog this fall.   For more information, please contact Marnie Freer at (519) 336-4101 ext. 226.