The line between "hazardous" and
"non-hazardous" waste is often drawn in a somewhat
arbitrary way, sometimes for historical reasons. Occasionally, it
is possible to persuade the Ontario Ministry of the Environment to
readjust the line. Canadian automotive manufacturers have had one of
these rare successes, but mostly because the same waste has
already been de-listed in the US.
The Canadian Vehicle Manufacturers Association (CVMA) and
Ontario's automobile manufacturers persuaded the MOE to follow
the US and to amend Regulation 347 to remove one kind of
automotive wastewater sludge produced by the chemical
conversion coating of aluminum. Such sludges used to contain
cyanide and chromium. According to the MOE, changes in the
vehicle manufacturing process "have removed contaminants of
concern which has resulted in the waste sludge no longer exhibiting
any hazardous waste characteristics"...
However, it seems that that wasn't enough. The MOE goes on
to explain that it had OTHER good reasons to delist this particular
"The amendment removes a disincentive to using more
aluminum in the manufacturing of vehicles, producing lighter
vehicles with better gas mileage and decreased exhaust emissions
and greenhouse gas emissions. As well, it is in line with the US
EPA's delisting of this waste stream which helps maintain the
competitiveness of Ontario's automotive
The sludge is therefore now a non-hazardous waste, and can go to
an ordinary landfill, resulting in substantial savings to the auto
companies. And if it is actually non-hazardous, this is exactly as
it should be, regardless of vehicle gal mileage....
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