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Environmental Statement

Toxic Reduction Plan Summary

Facility Information

  • Name of Substance: Manganese and its compounds
  • CAS Number of Substance: NA-09
  • NPRI Identification Number: 0000007134
  • Ontario Regulation 127/01 identification number, if assigned: N/A
  • Company Name: Ingersoll Tillage Group
  • North American Tillage Tools Company
  • Facility Name: Same as above
  • Facility Address: 460 Sherman Avenue North, Hamilton, Ontario, L8L 8J6
  • Mailing Address, if different: Same
  • Number of Full-time Employees: 126
  • Two Digit NAICS Code: 33
  • Four Digit NAICS Code: 3312
  • Six Digit NAICS Canada Code: 331221
  • Latitude: 43.266300
  • Longitude: -79.829000

Company Contact Information

  • Name: Bruce Armstrong
  • Position: Operations Manager
  • Address: 460 Sherman Avenue North, Hamilton, Ontario, L8L 8J6
  • Telephone Number: 905-667-6548
  • Fax Number: 905-667-1075

Parent Company (PC) Information, if applicable

  • PC Legal Name: Ingersoll Tillage Group
  • PC Address, if different from Company:
  • Percentage Ownership for each PC: 100
  • Business Number for PC: 866040942

Parent Company (PC) Contact Information

  • Name: Bruce Armstrong
  • Position: Operations Manager
  • Address: 460 Sherman Avenue North, Hamilton, Ontario, L8L 8J6
  • Telephone Number: 905-667-6548
  • Fax Number: 905-667-1075

Toxic Substance Accounting Information

Names of Toxics Substances for which plans have been prepared

Manganese and its compounds

Statement of Intent

Elemental Manganese is used in the custom alloy steel coils that are purchased for NATTCO's component manufacturing, involving production of steel disks and sweeps. These manufactured components are sold to equipment manufacturers and original equipment component replacement suppliers of agricultural field cultivation and seeding equipment. NATTCO's customers specify very stringent material quality criteria for the products they purchase.

Manganese is a substance used in NATTCO's proprietary steel alloy formula, which has been developed and perfected over years of research and development. This element is needed to maximize the manufactured components' hardness and wear-resistance, while also minimizing brittleness (necessary to prevent premature breakage of components in use). At this time, there are no identified substitutes for manganese in the alloy feedstock used in NATTCO's manufacturing process.

NATTCO is committed to long-term and ongoing attention to reduced energy and materials consumption, and increased re-use and recycling, to achieve minimization of its overall waste streams, and to effect continuous process improvements.

In previous years, NATTCO has taken progressive measures to maximize the recycling/reuse of waste feedstock materials containing manganese, while also optimizing its manufacturing process to reduce residual scrap from the manufacturing process (Referenced in section titled Options To Be Implemented.)

NATTCO does not create or use elemental manganese in its processes, therefore this plan will not address reducing its creation.

Nevertheless, NATTCO continues to review further options to reduce the generation of waste steel scrap containing manganese.

Reduction Plan Objectives

It is NATTCO's corporate environmental policy to comply with all applicable environmental regulations and guidelines to the fullest extent possible, in all areas of its operations, including implementation of best industry practices.

NATTCO strives to maximize its reduction and recycling initiatives, relative to its overall manganese use, while continuing to produce a superior product that is competitive in the global marketplace in terms of cost and performance.

This plan will determine the technical feasibility of potentially available manganese reduction or elimination options to determine which, if any, are viable for implementation at this time.

Description of Substance

There is only one Phase I toxic substance that requires the development of a toxic substance reduction plan, based on the criteria set out in the Toxics Reduction Act, 2009 and Ontario Regulation 455/09. This substance is manganese, which is an integral component of the specified steel feedstock alloy used in the manufacture of NATTCO's agricultural implements.

The alloy feedstock that NATTCO uses to manufacture its agricultural implements:

  • is used throughout the facility's primary manufacturing processes
  • has unique quantifications
  • has direct and indirect costs

Toxic Substance Reduction Options to be Implemented (or, if none, rationale)

Prior to the implementation of the Toxics Reduction Act, 2009 and Ontario Regulation 455/09, NATTCO was continuously pursuing broad environmental stewardship principles and strategies in its operations, including specific measures in relation to Manganese:

  • to reduce and minimize manganese use and content in its manufacturing feedstock and process
  • to reduce and minimize the generation of scrap and other manufacturing residues that contain manganese
  • to maximize recovery and reuse/recycling of scrap and other manufacturing residues containing manganese.

Accordingly, by the time that this Regulation came into force, NATTCO had already taken the following steps addressing manganese:

  • modifying its feedstock steel alloy material for a partial reduction of manganese content
  • optimizing its production methods (stamping, blanking, and machining operations) to reduce residual scrap from the manufacturing process
  • optimizing all aspects of component design and quality control (i.e. base material, physical design parameters, hardening processes, etc.) to produce products that are durable and long-lasting, thereby minimizing replacement intervals and related disposal requirements
  • recovering, and directing for reuse and recycling:
    • residues of mill scale from the quenching processes
    • residues of shot blasting
    • metal dust collected from blanking and turning operations and extracting a significant portion of the above materials in recovery processes to recycle back to steel scrap vendors, rather than disposing of it as non-hazardous waste.
  • recovering fugitive shot blast media and reintroducing it back into the shot-blast process, rather than collecting it for disposal.

With the foregoing initiatives, NATTCO has already significantly reduced unnecessary manganese use, and addressed other actual and potential environmental effects in its operations. Accordingly, any further gains in manganese reduction or elimination will be challenging when starting from this established base of prior accomplishments in this regard.

In terms of manganese reduction/control, NATTCO considers itself to be on or near the leading edge of current metallurgical technology for its industry sector.

It is because NATTCO had already implemented all the improvements listed above that no options were identified.

Estimated Reductions for each Option (if any)

Not applicable.

Timelines for Achieving Reductions (if any)

Not applicable.

PLAN SUMMARY STATEMENT

This plan summary accurately reflects the content of the toxic substance reduction plan for manganese and its compounds, prepared on behalf of North American Tillage Tools Company, dated June 1, 2015.

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Click here to download the 2014 TRA Public Summary Report (PDF)

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