Toxics Substance Reduction Plan For MANGANESE (CAS # NA-10) Snap-On Tools of Canada Ltd Millcreek Drive Mississauga, Ontario L5N 2W6

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1 Toxics Substance Reduction Plan For MANGANESE (CAS # NA-10) Snap-On Tools of Canada Ltd Millcreek Drive Mississauga, Ontario L5N 2W6 December 6, 2012 Pinchin File: Copyright 2012 by Pinchin Environmental Ltd MILLTOWER COURT, MISSISSAUGA, ONTARIO L5N 7W5 PHONE: (905) FAX: (905) ENVIRONMENTAL HEALTH & SAFETY MANAGEMENT SERVICES FROM OFFICES ACROSS CANADA

2 EXECUTIVE SUMMARY Snap-On Tools of Canada Ltd. (Snap-On) manufactures automobile service lifts and related products at its 6500 Millcreek Drive site in Mississauga. Processes include welding, cutting, cleaning and painting of steel products. Manganese is contained in steel components that are assembled at the facility. The facility has undertaken a review of its operations in an effort to identify options to reduce its use of manganese, in compliance with the requirements of the Toxics Reduction Act. At this time, no options could be identified. A number of efficiencies have already been implemented, including requirements to suppliers to provide components that generate a minimum amount of scrap during processing, and procedures to rework nonconforming processes where possible. The facility will continue to review its operations as part of continual improvement activities Pinchin Environmental Ltd. Page i

3 TABLE OF CONTENTS EXECUTIVE SUMMARY...I 1.0 BASIC FACILITY INFORMATION STATEMENT OF INTENT OBJECTIVES OF THE PLAN & ANY TARGETS OPTIONS TO BE IMPLEMENTED CONTENTS OF THIS PLAN SUMMARY REFLECTS PLAN CERTIFICATION BY HIGHEST RANKING EMPLOYEE CERTIFICATION BY LICENSED PLANNER Pinchin Environmental Ltd. Page ii

4 1.0 BASIC FACILITY INFORMATION Substance Information Name CAS # Manganese NA-10 Facility Information Company Name Facility Address Site Coordinates (main entrance of site) Snap-On Tools of Canada Ltd Millcreek Drive, Mississauga, ON, L5N 2W6 17T, m E, m N NPRI ID MOE ID Number of Full-Time Employees in Digit NAICS Code 4-Digit NAICS Code 6-Digit NAICS Code Manufacturing Other General-Purpose Machinery Manufacturing Material Handling Equipment Manufacturing Facility Contact Information Public Contact Dean Fisher Safety Manager Phone: x 486 Fax: dean.fisher@snapon.com Address same as facility address 2012 Pinchin Environmental Ltd. Page 1

5 2.0 STATEMENT OF INTENT Snap-On Tools of Canada Ltd. is committed to playing a leadership role in protecting the environment. The use of manganese is an integral part of the steel products that we manufacture, and it is not technically or economically feasible to reduce. We will continue to use this substance in strict accordance with all applicable environmental regulations. With reference to the Ontario Toxics Reduction Act, the reduction objectives are outlined in Section 3.0 of this Plan for manganese. 3.0 OBJECTIVES OF THE PLAN & ANY TARGETS Snap-On Tools of Canada Ltd. prides itself on technological innovation in order to produce high quality products in an environmentally responsible manner. We will strive to optimize the use of manganese at the facility. At this time, no reduction options have been identified, and as part of the continuous improvement practices at the facility, technical advances will be monitored for new opportunities to reduce the use of manganese at the facility. 4.0 OPTIONS TO BE IMPLEMENTED At this time, no options for reduction have been identified. As a component processor, the facility does not have the same opportunity for efficiencies that a facility processing raw steel might be able to identify. Furthermore, many options have already been identified and implemented as part of the facility s ISO 9001 and ISO programs. However, because of these programs, the facility is committed to ongoing review of reduction options as part of their continual improvement activities. 5.0 CONTENTS OF THIS PLAN SUMMARY REFLECTS PLAN This Plan Summary accurately reflects the Toxic Substance Reduction Plans dated November 22, 2012, prepared for the substances listed in Section 1.0 of this Summary Pinchin Environmental Ltd. Page 2

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7 6500 Millcreek Drive, Mississauga, ON November 22, CERTIFICATION BY LICENSED PLANNER As of November 22, 2012, I certify that I am familiar with the processes at Snap-On Tools of Canada Ltd. that use or create manganese, that I agree with the estimates referred to in subparagraphs 7 iii, iv and v of subsection 4 (1) of the Toxics Reduction Act, 2009 and the Ontario Regulation 455/09 (General) made under that Act. Robin Brown, TSRP #0018 Operations Manager Pinchin Environmental Ltd. rbrown@pinchin.com Pinchin Master Report Guide, Ver. 1, May 2007 J:\69000s\69018 Snap-On Tools-TRA\TRA\69018 Snap On Manganese TSRP.docx 2012 Pinchin Environmental Ltd. Page 7