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Pollution Prevention


Pollution Prevention (P2) is about anticipating and preventing pollution instead of implementing downstream controls such as pollution control equipment. As the cost of pollution control systems continues to rise, implementing effective pollution prevention measures can not only help protect the environment but also reduce operating costs, helping your facility’s bottom line.

Depending on the nature of operations at your facility, you may be subject to one or more Pollution Prevention (P2) regulations.

Toxics Reduction Act (TRA)

The Toxics Reduction Act (TRA), and O. Reg 455/09 brought with it significant work for over 2,000 manufacturers and mining facilities in Ontario. At its core, the Toxics Reduction Act challenges companies to look at their operations, and incorporate environmental stewardship and pollution prevention planning into their operations. The intent of the Ministry of Environment & Climate Change (MOECC) was to enact a legislation that required businesses to focus on the process (“front-end”) use of toxic substance, and hopefully find cost saving opportunities to reduce their use or creation.

The Toxics Reduction Act (TRA), and its regulation (O. Reg 455/09) can be broken down into two components: 1) Reporting, and 2) Planning.

Toxics Reduction Report

Toxics Reduction Act Reporting is essential an extension of the National Pollutant Release Inventory (NPRI), and O. Reg 127/01, and uses the exact same substance list. While the National Pollutant Release Inventory focuses on releases from the facility, the Toxics Reduction Act completes the mass-balance around the facility, requiring facilities to report on amounts Used, Created, and Contained in Product. Simply put, all reportable substances are now accounted for in how they arrive on site, how they are released, recycled, disposed of, and how much ends up in the final products shipped off site. The Toxics Reduction Act reports are due June 1st annually, at the same time as the NPRI and O.Reg 127/01 reporting. These reports get filled in Environment Canada’s SWIM program. In addition to the report sent to the government, facilities are also required to post a summary version of this information online. As this information can contain confidential business information, facilities are given the ability to report the information in ranges and bands, as opposed to the exact usage, and release information.

Toxics Reduction Plan

Toxics Substance Use Reduction Plans are required for every substance that meets the reporting criteria. Plans require facilities to not only document how reportable substances are used or created on-site, but also require that facilities go through a detailed pollution prevention analysis. At the heart of the Toxics Use Reduction Plans is the technical, and economic feasibility study. The MOECC prescribes that facilities identify at least one option for each of the 7 pollution prevention categories:

  • Materials or Feedstock Substitution
  • Product Design or Reformulation
  • Equipment or Process Modification
  • Spill and Leak Prevention
  • On-site Reuse or Recycling
  • Improved Inventory Management or Purchasing Techniques
  • Training or Improved Operating Practices

For each of the above 7 categories, facilities must determine if a technically feasible option exists that would reduce the use or creation of a reportable substance. For every technically feasible option, facilities must undergo a financial analysis to determine the payback period of the option. Facilities must then decide if they want to implement the option identified. The Toxics Reduction Act is mandatory in that the reporting and planning must be done, however, implementation of any option is voluntary. Plans are valid for 5 years, but are required to undergo a mandatory review and recertification in 2018.

Finally, completed plans must be certified by the highest ranking employee at the facility, as well as a licensed Toxics Substance Reduction Planner (TSRP). Rubidium’s staff have completed over 300 Toxic Use Reduction Plans, enabling us to provide an efficient, hassle-free process. Our unique background coming from industrial manufacturing allows us to provide more than just environmental knowledge, but process insights into potential cost saving solutions.

Chemical Management Plan (CMP)

Environment Canada’s (EC) policy on use of domestic substances is constantly evolving. The Chemical Management Plan (CMP) was developed as a risk-based tool to provide EC with information as to the use and fate of various substances within Canada. Certain substances in use within Canada are required to undergo detailed monitoring and surveillance, and EC requires those facilities to disclose whether or not they meet the use or production thresholds for substances covered under the Chemical Management Plan. If the thresholds are met, then more detailed process information, including testing and modeling or releases, might be required. Often substances that are assessed as hazardous and used within Canada under the Chemical Management Plan get added to the Environmental Emergencies (E2) regulation. If you use significant quantities of VOCs, acids, plastics, or heavy-metals, you may be subject to the regulation.

Environmental Emergency (E2)

The Environment Emergency (E2) regulations came into force in 2003, and were developed to assist in the prevention, preparation, and response of environmentally hazardous releases. Substances listed in Schedule 1 of the Environmental Emergency regulations are classified by their emergency hazard characteristic such as explosive, flammable, inhalation toxic, aquatic toxic, or carcinogenic, and have divided amongst 3 substance groupings.

  • Substances likely to explode
  • Substances hazardous when inhaled
  • Otherwise hazardous

Requirements to prepare an E2 plan are based on the amount of a particular substance that is stored onsite, and the thresholds can be as high as 220 kg for some substances.
Facilities that meet the reporting criteria are required to develop and implement plans. E2 plans are required to contain:

  • how the substance is used and stored onsite
    • including its physical properties and amounts stored onsite
  • the potential consequences from an environmental emergency on the environment and on human health
  • the identification of any environmental emergency that can reasonably be expected to occur at the facility and that would likely cause harm to the environment or constitute a danger to human life or health, and identification of the harm or danger;
    • this includes modeling release scenarios of the substance to determine the impacted area
  • a description of the measures to be used to prevent, prepare for, respond to and recover from any environmental emergency identified
  • a list of the individuals, identified by name or position, who are to carry out the plan in the event of an environmental emergency, and a description of their roles and responsibilities;
  • the identification of the training required for each of those individuals;
  • a list of the emergency response equipment included as part of the E2 plan, and the equipment’s location; and
  • the measures to be taken by the person to notify, prior to, during and after an environmental emergency, those members of the public who may be adversely affected by an environmental emergency, and to inform them of the measures taken and what they need to do in the event of an environmental emergency.

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