Plan Summary Preview. Company Details. Report Details. Activities. Select the Facility Contacts. Organization Validation. Contacts

Transcription

1 Plan Summary Preview Company Details Company Legal Name: Pittsburgh Glass Works, ULC Company Address:, () Report Details Facility: Pittsburgh Glass Works, ULC - Facility Address:, () Update Comments: Activities Select the Facility Contacts Contacts Public Contact:* Ted Huyett Highest Ranking Employee: Mike Molnar Person responsible for Toxic Substance Reduction Plan preparation: Frankie Man Organization Validation Company and Parent Company Information Company Details Company Legal Name:* Company Trade Name:* Pittsburgh Glass Works, ULC Pittsburgh Glass Works, ULC Page 1 of 11

2 Business Number:* Post Office Box PO Box or Rural Route Number: 901 L9R1W1 Physical Address L9R1W1 Additional Information: Land Survey Description: National Topographical Description: Parent Companies Pittsburgh Glass Works, ULC Company Legal Name:* Pittsburgh Glass Works, ULC Percentage owned:* Business Number:* General Delivery PO Box or Rural Route Number: 1959 Upper Water Street, Suite 900 Page 2 of 11

3 Halifax Nova Scotia B3J 2X2 Physical Address 1959 Upper Water Street, Suite 900 Halifax Nova Scotia B3J 2X2 Additional Information: Land Survey Description: National Topographical Description: Facility Validation Facility Information Facility:* Pittsburgh Glass Works, ULC - NAICS Id:* NPRI Id:* ON Reg 127/01 Id: Post Office Box PO Box or Rural Route Number: 901 L9R 1W1 Page 3 of 11

4 Physical Address L9R 1W1 UTM Zone: 17 UTM Easting: UTM Northing: Latitude: Longitude: Additional Information: Land Survey Description: National Topographical Description: Contact Validation Contacts Public Contact: First Name:* Last Name:* Position:* Ted Huyett Manager, EHS Telephone:* Ext: Fax: * Page 4 of 11

5 Post Office Box PO Box or Rural Route Number: 901 L9R 1W1 Highest Ranking Employee: First Name:* Last Name:* Position:* Mike Molnar Senior Site Manager Telephone:* Ext: 222 Fax: * Post Office Box PO Box or Rural Route Number: 901 L9R 1W1 Person responsible for the Toxic Substance Reduction Plan preparation: First Name:* Last Name:* Frankie Man Page 5 of 11

6 Position:* Toxic Substance Reduction Planner Telephone:* Ext: 397 Fax: * General Delivery PO Box or Rural Route Number: Town Center Boulevard Markham L3R 5Z6 Employees Employees Number of Full-time Employees:* 220 Substances NA - 08, Lead (and its compounds) NA - 08, Lead (and its compounds) Substances Section Data Statement of Intent Use Is there a statement that the owner or operator of the facility intends to reduce the use of the toxic substance at the facility?:* No If yes, exact statement of the intent that is included in the facility s TRA Plan to reduce the use of the toxic substance at the facility:** Page 6 of 11

7 If no, reason in the facility s TRA Plan for no intent to reduce the use of the toxic substance at the facility:** As lead is used in the soldering material pre-applied on components specified by customers and manufactured off-site, the PGW Facility in is not in a position that would easily allow it to pursue reduction options. As such, the Facility does not intend to pursue reduction in the use or creation of lead at the Facility. However, PGW is committed to reducing the generation of scrap in its assembly lines in an effort to reduce the quantity of lead-containing components used. Creation Is there a statement that the owner or operator of the facility intends to reduce the creation of the toxic substance at the facility?:* No If yes, exact statement of the intent that is included in the facility s TRA Plan to reduce the creation of the toxic substance at the facility:** If no, reason in the facility s TRA Plan for no intent to reduce the creation of the toxic substance at the facility:** As lead is used in the soldering material pre-applied on components specified by customers and manufactured off-site, the PGW Facility in is not in a position that would easily allow it to pursue reduction options. As such, the Facility does not intend to pursue reduction in the use or creation of lead at the Facility. However, PGW is committed to reducing the generation of scrap in its assembly lines in an effort to reduce the quantity of lead-containing components used. Objectives, Targets and Description Objectives Objectives in plan:* In light of the Statement of Intent above, PGW s objectives are to reduce the creation of leadcontaining wastes to the greatest extent that circumstances permit, and to prioritize the treatment of waste in the order of reuse, recycling, and disposal. Use Targets What is the targeted reduction in use of the toxic substance at the facility?* Quantity Unit No quantity target or What is the targeted timeframe for this reduction?* No timeline target or years Description of targets: Page 7 of 11

8 Creation Targets What is the targeted reduction in creation of the toxic substance at the facility?* Quantity Unit No quantity target or What is the targeted timeframe for this reduction?* No timeline target or years Description of targets: Reasons for Use Why is the toxic substance used at the facility?:* Ancillary other use Summarize why the toxic substance is used at the facility:** The main process at the Facility is the assembly of components onto automotive glass. Only the back windows of the automotive glass contain leaded components. Lead is used in the soldering material pre-applied on components specified by customers and manufactured offsite. All the lead involved in the processes at the Facility is contained in the lead solder that is preapplied on the clips, buttons and harnesses which are heated and soldered to the back windows. PGW does not directly use or create lead in the facility. Reasons for Creation Why is the toxic substance created at the facility?:* This substance is not created at the facility Summarize why the toxic substance is created at the facility:** The main process at the Facility is the assembly of components onto automotive glass. Only the back windows of the automotive glass contain leaded components. Lead is used in the soldering material pre-applied on components specified by customers and manufactured offsite. All the lead involved in the processes at the Facility is contained in the lead solder that is preapplied on the clips, buttons and harnesses which are heated and soldered to the back windows. PGW does not directly use or create lead in the facility. Toxic Reduction Options for Implementation Description of the toxic reduction option(s) to be implemented: Page 8 of 11

9 Is there a statement that no option will be implemented?:* Yes If you answered No to this question, please add the option(s) under the appropriate Toxic Substance Reduction Categories (e.g. Materials or feedstock substitution, Product design or reformulation, etc.). If you answered Yes please provide an explanation below why your facility is not implementing an option. Explanation of the reasons why no option will be implemented:** As lead is used in soldering material for bonding the clips to the glass according to the specifications of the customers, and there is no economically viable option identified for using lead-free solder, the PGW Facility in cannot easily pursue reduction options. As such, the Facility does not intend to reduce the use or creation of lead at the Facility in its alloys, unless lead-free solder costs are reduced and customers specifications are changed. In the immediate term, PGW is committed to reducing the generation of scrap in the assembly lines in an effort to improve the utilization of leaded clips. Materials or feedstock substitution Product design or reformulation Equipment or process modifications Spill or leak prevention On-site reuse, recycling or recovery Improved inventory management or purchasing techniques Good operator practice or training Rationale for why the listed options were chosen for implementation: N/A General description of any actions undertaken by the owner and operator of the facility to reduce the use and creation of the toxic substance at the facility that are outside of the plan: Page 9 of 11

10 PGW s objectives are to reduce the creation of lead-containing wastes to the greatest extent that circumstances permit. With this objective in mind, the facility has initiated the following initiatives listed below in an effort to reduce wastes to the greatest extent possible. The initiatives are listed based on reduction option categories. 1) Material or Feedstock Substitution Indium-based solder (lead-free) has been in the market for a while, and PGW has tested the lead-free solder in other facilities. While the lead-free solder performs similarly, the viscosity of the solder was less than the leaded one when melted. In the facility, the assembly machines placed the glasses in a vertical position; therefore, if the Facility tested the use of lead-free solder, it would run out of the adhesion area before it is solidified and bonded between the clips to the glass due to the reduced viscosity, resulting improper soldering. In order to substitute lead-free solder clips for lead-containing products, the facility would need to modify or replace all existing soldering equipment, at a prohibitive cost. In addition, since the components used in the Facility are purchased according to customer s order and specification, and unless the customers specify the lead-free solder materials for the clips, the Facility is not in a position to substitute the lead solder with lead-free one. 2) Equipment or Process Modification Over the years, the Facility continues to improve its equipment and processes in order to reduce the amount of scrap generated. For instance, the part holders on one of the assembly machines was modified to better recognize the presence of the clip despite minor inconsistencies, and therefore utilized more clips instead of rejecting slightly defected ones. In 2011, the Facility achieved a facility-wide 10% reduction of lead waste from soldering activities by improving assembly equipment and processes. 3) Spill and Leak Prevention Lead was contained in the pre-applied layer of solder on the clips that are received from the supplier. The clips were in stable state and did not contribute to any leak or spill. When the automated solder gun at the assembly station applies heat to the solder, the solder melts but quickly cools to solidify and bond the clips with the glass. Any damaged or defected clips were collected, recorded and properly disposed of in a solid state. Furthermore, the Facility has a Lead Control Program in effect since It provided an overview of the health risk of lead and described the controls that the Facility had implemented to minimize the risk of lead exposure. Engineering control were described and implemented to reduce the risk of lead exposure at each assembly station. The program also outlined the proper work practices and procedures for workers to follow. With this detail lead control program implemented, the Facility did not identify any further reduction option at this time. 4) On-site Reuse or Recycling All the collected clips were sent to Detox for landfill disposal. Some glass sent to NexCycle for recycling contains clips that cannot be removed at the Facility. As the automotive glass is tempered and removing the clips from the glass may risk shattering the glass, the Facility has not been separating the clips from the defective glass prior to disposal of the glass, or performing any on-site recycling on the applied clips. The waste or spent clips that failed the pull test cannot be reused because the solder materials were already melted. For slightly damaged or defective clips, the Disposal of Discarded lead Solder Clips procedure was issued to workers for instructions to reuse or dispose these clips. The above initiatives demonstrate a willingness by PGW to reduce to toxic substances to the greatest extent possible. License Number of the toxic substance reduction planner who made recommendations in the toxic substance reduction plan for this substance (format TSRPXXXX):* TSRP0177 Page 10 of 11

11 License Number of the toxic substance reduction planner who has certified the toxic substance reduction plan for this substance (format TSRPXXXX):* TSRP0177 What version of the plan is this summary based on?:* New Plan Page 11 of 11