STAFF REPORT
January 24, 2000
To: Works Committee
From: Barry H. Gutteridge, Commissioner, Works and Emergency Services
Subject:Burning of Used Motor Oil
All Wards
Purpose: To report on the corporate investigation of facilities burning used motor oil.
Financial Implications and Impact Statement:
No funding sources or financial implications at this stage. Enforcement resources will be required should Council enact a
draft By-law to prohibit the burning of used motor oil.
Recommendations:
It is recommended that:
(1) the Medical Officer of Health (MOH) be authorized to prepare a public information fact sheet on the health and
environmental impacts of the various contaminants present in used motor oil;
(2) the Commissioner of Works and Emergency Services (WES) be authorized to formally request the owners/managers of
the remaining facilities still burning waste oil to cease this practice;
(3) the Commissioner of WES be requested to report back to the Works Committee (WC) one year following the
distribution of information to facilities still burning waste oil and prior to Council's consideration of enacting the By-law to
Prohibit the Burning of Used Motor Oil; and
(4) the appropriate City Officials be authorized and directed to take the necessary action to give effect thereto.
Background:
City Council, at its meeting of July 29, 30 and 31, 1998, adopted Clause 3 of the Works Committee Report No. 7 entitled
"Corporate Voluntary Challenge and By-law to Prohibit the Burning of Used Motor Oil". The Clause contained the report
from the Commissioner of Works and Emergency Services, dated July 6, 1998, entitled "Burning of Waste Oil", which
contained the recommendations that:
(1) the City of Toronto initiate a voluntary challenge to businesses in the City and showcase those that adopt a corporate
policy not to burn used motor oil; and
(2) the proposed By-law, given in an attachment to this report, be considered for enactment by City Council by December
31, 1998, if still required, in order to completely eliminate the burning of used motor oil in space heaters.
City Counci, at its meeting of June 9, 10 and 11, 1999, received for information the interim report of the Commissioner of
Works and Emergency Services dated May 11, 1999, on the Burning of Used Motor Oil. The report provided an update on
the voluntary challenge to cease burning of waste oil, advised that site visits would be completed to determine the degree
of voluntary participation, and that upon completion of this investigation, a report would be submitted to the Committee.
Comments:
On March 19,1998, the Minister of the Environment placed a moratorium on the approval of any new small space heaters
that burn waste oil. Staff at the Ministry have been consulted and they have advised that the current Minister of the
Environment has taken the formal position that this moratorium should remain in effect permanently. There are 45
facilities within the City of Toronto listed as having received a Certificate of Approval (C of A) from the Ministry of
Environment(MOE) prior to the moratorium.
- Summary of Investigation:
All 45 facilities which have a MOE Certificate of Approval were contacted and visited by Works and Emergency Services
Department's Industrial Waste Control Inspectors.
Inspections were carried out in the summer of 1999 with compilation of information and follow-up occurring in the fall of
1999.
The results of the inspection were that two of the facilities no longer exist, 24 are currently not burning waste oil and 19 are
currently burning waste oil. Two companies currently not burning waste oil have the intention of burning in the future.
These two companies were willing to reconsider if instructed to refrain from burning waste oil.
Those companies who have stopped burning waste oil stated that they had done so in the past few years. Following are
some reasons cited by companies who have voluntarily stopped the practice of burning of waste oil:
(i) The furnace was not working well, it was hard to maintain or too expensive;
(ii)They stopped for reasons of poor public perception;
(iii)They were told to stop the practice several years ago; and
(iv)They no longer generate waste oil on their premises.
The majority of facilities that stated they stopped burning waste oil submitted invoices for waste oil haulage as a method of
proof. For the remaining facilities that ceased the burning of waste oil, Safety-Kleen Limited, a recycler of waste oil,
confirmed that they provided haulage services to those companies.
For those companies who are currently burning oil, only one was willing to stop without explanation, while two facilities
were willing to stop if they were given adequate proof that there are detrimental environmental impacts from waste oil
burning furnaces. An additional two were willing to stop if they were compensated for the costs that they recently incurred
by purchasing a waste oil furnace. Two companies made no comment on whether or not they would stop and 12 were not
willing to stop under any voluntary circumstance. Those companies that were not willing to voluntarily stop burning waste
oil gave the following reasons:
(i) Furnaces were perceived to burn "clean";
(ii)Oil was burned in the winter when there were no smog problems;
(iii)Monetary savings for heat and disposal costs; and
(iv)A recent large investment in a furnace.
(b)Showcasing:
Five options were considered as potential venues for showcasing companies that ceased burning of waste oil for their
environmental leadership:
(i) Notice and name published in Environmental Task Force Newsletter;
(ii) Notice and name published in Toronto Waste Watch;
(iii)Notice and name published in Auto Mart;
(iv) Notice and name published in Auto Trader; or
(v) Presenting companies who have voluntarily stopped burning waste oil with a certificate.
When the companies were inspected, they were advised of the City's intentions to showcase the companies which have or
will voluntarily cease burning of waste oil as well as the City's intent to pass a by-law to prohibit the burning of used
motor oil in space heaters in the case of a lack of voluntary action.
The companies were specifically asked about their interest in being showcased. Most companies did not respond to the
Showcasing question, while others were indifferent, or gave a negative response to one or more publishing option. Positive
responses were given by two companies that are currently not burning and two that are. In general, companies currently
burning waste oil would be willing to stop if:
(i)An official request to cease burning of waste oil was received;
(ii) were compensated for their monetary loss;
(iii) ere given evidence showing the relative damage compared to vehicle emissions; or
(iv) equipment needed replacing or major repairs.
(c)Enforcement:
Currently, the Ministry of the Environment does not revoke Certificates of Approval, Enforcement of prohibition the
burning of waste oil would first require the City to pass an applicable by-law. In a Report dated April 16, 1998 entitled
"Options to Ban or Grandfather the Operations of Waste Oil Heaters", followed by a Memorandum to Kevin T.
Loughborough, dated July 2, 1998, the City Solicitor commented on the feasibility of implementing such a by-law. The
Solicitor's Report and Memorandum including a draft By-law are attached.
Conclusions:
More than half of the companies in the City of Toronto with a C of A for burning waste oil have ceased burning waste oil
for various reasons. The proposed corporate voluntary challenge, which offered the showcasing of those companies which
voluntarily stop burning waste oil, appears not to be a viable incentive.
The companies that continue to burn waste oil do so mostly because they have the perception that burning waste oil in
space heaters does not pose a threat to the environment and human health. This view was based on the perception that
waste oil burning was a minor contributor to overall air emissions in the City. These companies consider burning waste oil
as a money-saving practice.
As noted above, some companies indicated willingness to stop if they received information that the practice was harmful to
the environment or if the City officially requested them to stop burning their waste oil.
There has been substantial progress in voluntarily reducing the number of facilities that burn waste oil in the City of
Toronto. Our investigation has indicated that there is additional potential for voluntary action. Accordingly, it is
recommended that the Medical Officer of Health be authorized to prepare an information fact sheet containing information
on the health impacts of various contaminants contained in waste oil, and that the Commissioner of Works and Emergency
Services be authorized to send out a letter to the respective facilities requesting the ceasing of burning of waste oil.
Staff will review and report on the voluntary actions in one year's time and advise on the necessity of enacting the draft
By-law prohibiting the burning of waste oil in the City of Toronto.
Contact:
John Warren
Director, Environmental Services
Tel: 416-397-4625
Fax: 416-392-6279
E-Mail : John_Warren@toronto.ca
Tom G. Denes, P.Eng.
Executive Director
Technical Services
Barry H. Gutteridge
Commissioner
KH/vt
List of Attachments:
Attachment #1: Report to Works Committee "Options to Ban or Grandfather the Operation of Waste Oil Heaters"
Attachment #2: Memorandum regarding Draft Proposed By-law of Councillor Sgro Banning the Burning of Used Motor
Oil
