SENES CONSULTANTS LIMITED: RENDERED OPINION |
The following paragraphs provide Dr. Garisto's personal Opinion on the ChemiGreen product. Dr. Nava Garisto is a risk assessment expert in the field of environmental compliance. As a part of her job she assesses the compliance level with regards to chemical spill. Her personal opinion on the ChemiGreen's product is provided below. Spills are receiving increasing regulatory attention in North America. For example, new requirements have come into effect in Ontario to encourage companies to develop spill prevention plans. These requirements are also linked to environmental penalties for environmental spills. More specifically, on June 9, 2005, the Ontario Legislature passed the Environmental Enforcement Statute Law Amendment Act (Bill 133). This legislation amended the Environmental Protection Act (EPA) and the Ontario Water Resources Act and introduces environmental penalties. In order to support tile implementation of the EPA provisions of the Environmental Enforcement Statute Law Amendment Act, the Ontario Ministry of the Environment ("MOE") recently published final Spill Prevention and Contingency Plans and environmental penalties ("EP") regulations under the Environmental Protection Act (the "EPA") and the Ontario Water Resources Act ("OWRA") (O. Reg. 224/07, O. Reg. 222/07, and O. Reg. 223/07, respectively) and several related guidance documents.). Section 3(1) of the EP Regulation defines regulated persons subject to EP. All of these plants are required to develop spill prevention and contingency plans which complies with O. Reg 224/07. New Ontario Regulation 224/07, Spill Prevention and Contingency Plans, was consolidated in June 2007 and in force as of September 1, 2008. The above paragraphs emphasize the regulatory-driven need for spills prevention. The product offered by ChemiGreen is a good, practical solution that can help industry address regulatory concerns and prevent spills from reaching the environment. To the best of my knowledge, there is no product available that gives the advantages of ChemiGreen's products, i.e. a safe, simple and a quick way to prevent large spills from entering the drains. I believe that many industries would benefit from implementing ChemiGreen's solution. |