DAOD 4003-6, Ozone-depleting Substances, Halocarbons, and Related Equipment

Table of Contents

1. Introduction
2. Definitions
3. Abbreviations
4. Overview
5. Operating Principles
6. Planning
7. Implementation
8. Monitoring and Reporting
9. Release
10. Record Keeping
11. Oversight
12. Compliance and Consequences
13. Responsibilities
14. References

1. Introduction

Date of Issue: 2025-07-03

Application: This DAOD is a directive that applies to employees of the Department of National Defence (DND employees) and an order that applies to officers and non-commissioned members of the Canadian Armed Forces (CAF members).

Supersession: ED 4003-05, Directive Regarding ODS and Halocarbon Management

Approval Authority: Assistant Deputy Minister (Infrastructure and Environment) (ADM(IE))

Enquiries: Director Environment and Sustainable Management (DESM)

2. Definitions

container (récipient)

A container that contains or is designed to contain a halocarbon for the purpose of storage or transportation. (Federal Halocarbon Regulation, 2022)

fire-extinguishing system (système d’extinction d’incendie)

A portable or fixed system that contains or is designed to contain a halocarbon fire extinguishing agent. (Federal Halocarbon Regulation, 2022)

halocarbon (halocarbure)

A substance set out in Schedule 1, whether existing alone or in a mixture, and includes isomers of any such substance. (Federal Halocarbon Regulation, 2022)

3. Abbreviations

4. Overview

Interpretation

4.1 In this DAOD HVAC-R means an air-conditioning system or refrigeration system that has a compressor, condenser, evaporator and expansion valve, and that contains or is designed to contain a halocarbon refrigerant.

Context

4.2 ODS and halocarbons are:

1. used domestically and abroad in fire extinguishing systems, HVAC-R systems, and containers; and
2. a significant environmental aspect in the DND EMS.

4.3 Environmental impacts from the use of ODS and halocarbons primarily result from releases to the atmosphere. Most of these substances have high ODP, GWP or both. Requirements for ODS and halocarbons and their related systems and containers are defined in the ODSHAR and the FHR, under the CEPA.

4.4 ODSHAR is aligned with the MP which is a longstanding multinational agreement regulating and stipulating phasedown of production, and use of ODS and halocarbons. The intent is to protect the ozone layer and climate by reducing and preventing emissions from ODS and halocarbons. ODSHAR represents the means of Canada meeting MP obligations with requirements around manufacture, import, export, sale, and use of ODS and halocarbons. In line with the ODSHAR phasedown of select substances, the GGS targets the phasedown of select RP systems.

4.5 FHR details minimum maintenance requirements for ODS and halocarbons, and their related systems and containers. Effective management including preventative and standardized practices for the planning, implementation, decommissioning, monitoring, reporting, and oversight limits the potential environmental impacts from the use of ODS and halocarbons.

Purpose

4.6 The purpose of this DAOD is to provide direction with regard to ODS, halocarbons and related systems, and containers managed by the DND and the CAF.

Legal Implications

4.7 CEPA and Regulations (ODSHAR and FHR) and GGS define key federal requirements applicable to the management of ODS and halocarbons by the DND and the CAF, and third parties.

4.8 Guidance and relevant codes of practice are available from ECCC and the Treasury Board (see section 14).

4.9 Provincial, territorial and municipal legislation such as laws, guidelines and by-laws:

1. must be applied at the design, implementation, and decommissioning stages of systems using ODS and halocarbons; and
2. along with international legislation for related systems and containers outside Canada, define requirements for ODS and halocarbons.

5. Operating Principles

5.1 The DND and the CAF must:

1. manage and phase down ODS, halocarbons and related systems and containers in line with federal legislative and policy requirements, and if appropriate, international, provincial, territorial, and municipal legislative requirements; and
2. protect the ozone layer and mitigate climate change by adhering to legislative requirements and implementing best management practices.

5.2 Integrating phasedown of ODS and halocarbons as a consideration across the life cycle of their systems and containers helps to reduce ozone depletion and GHG emissions that result from releases.

6. Planning

6.1 The management of containers and systems (HVAC-R and fire extinguishing) containing ODS and halocarbons must adhere to applicable ADM(IE) and Assistant Deputy Minister (Materiel) (ADM(Mat)) policies.

6.2 Alternative low ODP and low GWP substances and their systems are available and feasible for use in select circumstances. However, some alternatives have high flammability or toxicity ratings and therefore may not be suitable for use in specific circumstances such as aircraft cockpits. Appropriate alternatives must be used whenever possible, taking into consideration safety and certification requirements.

6.3 Effective planning:

1. enables due diligence and reduces the potential impacts on the environment;
2. enables compliance with environmental requirements including regulatory reporting; and
3. integrates environmental considerations and related management measures such as phasedown into all stages of the life cycle (planning, designing, installation, operation and maintenance, and decommissioning).

6.4 The DND and the CAF manage a stockpile of halons that is used in select fire extinguishing systems if alternatives are not available or feasible. When considered appropriate, use of halon must be sourced from the Halon Bank located at Canadian Forces Base Borden.

6.5 When planning to undertake activities requiring the use or transboundary movement of ODS or halocarbons for use in fire extinguishing systems, the DND and the CAF must ensure that the necessary permits are acquired prior to undertaking related activities.

6.6 Prior to commencing any work on ODS or halocarbon systems, including installation, servicing and withdrawal from use, the DND and the CAF must ensure the validity of the qualifications and training certifications of all individuals involved in the work, including third parties.

7. Implementation

7.1 The release of ODS and halocarbons from systems and containers is not permitted except for the use of certain firefighting emergency response equipment and activities under permit.

7.2 Proactive management of ODS and halocarbons through complete and up-to-date inventories as well as proper maintenance:

1. improves the ability to identify and repair system issues before a release occurs; and
2. enables compliance with environmental requirements including regulatory record keeping and reporting.

7.3 At a minimum, the DND and the CAF must:

1. maintain inventories for ODS, halocarbons, and their related systems and containers;
2. complete and record management documentation as per legislative requirements;
3. recover halocarbon from withdrawal activities and manage via the Halon Bank for halons or via an approved facility for environmentally sound recycling, reclamation, or disposal; and
4. integrate DND and CAF requirements into contracts such as accessible up-to-date records.

Back to top

8. Monitoring and Reporting

Monitoring

8.1 Monitoring of ODS and halocarbons and their related systems and containers includes:

1. ensuring compliance with:
   1. legislative and policy requirements;
   2. ongoing performance for environmental protection;
2. reviewing policy and procedures to ensure ongoing validity; and
3. auditing of activities undertaken for these substances as compared with related KPIs.

Reporting

8.2 The DND and the CAF are responsible for internal and external reporting on various aspects of the ODS and halocarbons portfolio. Examples include release, performance and phasedown progress reporting.

9. Release

9.1 Releases must be prevented through:

1. diligent implementation of the technical planning, designing, installation, operation and maintenance; and
2. decommissioning of components for ODS and halocarbons systems and containers.

9.2 If a release occurs, applicable emergency response and reporting must be undertaken. The designated local responsible person must have procedures in place to meet response and reporting requirements.

10. Record Keeping

10.1 Record keeping:

1. is an important element of demonstrating compliance to environmental enforcement officers;
2. allows for analysis of data to determine trends, identify challenges and define improvements;
3. aligns with the DND and CAF Data Management Strategy whereby data is managed as a shared asset; and
4. allows data to then be leveraged in all aspects of DND and CAF programs by:
   1. enhancing capabilities and decision-making; and
   2. providing an information advantage during military operation.

10.2 At minimum, the following types of records regarding ODS, halocarbons and related equipment must be maintained and accessible within DND Data Management Strategy:

1. planning and design information and drawings;
2. as-built drawings and records of system modifications;
3. phasedown planning;
4. inventory and Activity Log;
5. management records (e.g. permit);
6. corrective action plans;
7. transfer records for recovered substance (whether recycled, reclaimed, disposed, stored, or reused);
8. notification and reporting records (e.g. release, recurring reporting, and preventive necessary charging); and
9. records that demonstrate training and qualification requirements are met.

11. Oversight

11.1 Effective oversight must:

1. promptly identify non-compliance with environmental requirements;
2. ensure appropriate corrective steps are recommended; and
3. ensure mitigative measures to prevent similar occurrences are implemented.

11.2 At a minimum, oversight must include:

1. assessing of compliance with environmental requirements and related KPIs;
2. reviewing ODS and halocarbons records and implementation, and if appropriate, defining and implementing needed improvements to correct and prevent issues; and
3. providing risk-based status report for senior management.

12. Compliance and Consequences

Compliance

12.1 DND employees and CAF members must comply with this DAOD. Should clarification of the policies or instructions set out in this DAOD be required, DND employees and CAF members may seek direction through their channel of communication or chain of command, as appropriate. Managers and military supervisors have the primary responsibility for and means of ensuring the compliance of their DND employees and CAF members with this DAOD. 

Consequences of Non-Compliance

12.2 DND employees and CAF members are accountable to their respective managers and military supervisors for any failure to comply with the direction set out in this DAOD. Non-compliance with this DAOD may result in administrative action, including the imposition of disciplinary measures, for a DND employee, and administrative or disciplinary action, or both, for a CAF member. Non-compliance may also result in the imposition of liability on the part of His Majesty in right of Canada, DND employees and CAF members.

Note – In respect to the compliance of DND employees, see the Treasury Board Framework for the Management of Compliance for additional information.

13. Responsibilities

13.1 The following table identifies the responsibilities associated with this DAOD:

14. References

Acts, Regulations, Central Agency Policies, and DAODs

• Canadian Environmental Protection Act, 1999
• Ozone-depleting Substances and Halocarbon Alternatives Regulations
• Federal Halocarbon Regulations, 2022
• Framework for the Management of Compliance,Treasury Board
• Greening Government Strategy: A Government of Canada Directive, Treasury Board
• Guidelines for Heating, Ventilation, Air Conditioning and Refrigeration Guidance, Treasury Board
• Policy on the Planning and Management of Investments, Treasury Board
• DAOD 1000-11, Policy Framework for Infrastructure and Environment
• DAOD 4003-0, Environmental Protection and Stewardship

Other References

• DAOD 3015-0, Green Procurement
• DAOD 3015-1, Management of Green Procurement
• DAOD 4001-0, Real Property Life Cycle Management
• DAOD 6000-0, Information Management and Information Technology
• DAOD 6500-0, Data Management and Analytics
• Department of National Defence and Canadian Armed Forces Data Strategy
• Ozone-depleting Substances and Halocarbon Alternatives Regulations: general information, Environment and Climate Change Canada
• Federal Halocarbon Regulations information, Environment and Climate Change Canada
• Environmental Code of Practice for the Elimination of Fluorocarbon Emissions from Refrigeration and Air Conditioning Systems, Environment and Climate Change Canada
• Standard 4003-6-1, Ozone-depleting Substances (ODS), Halocarbons, and Related Equipment
• Access to 3^rd party paperless standards/publications
• ADM(IE) Green Building Directive, ADM (IE) intranet site
• ADM(IE) Standard on Sustainability Requirements for Buildings, ADM (IE) intranet site
• Environment and Sustainable Management, ADM(IE) DGESM intranet site
• ADM(IE) Management Manual, ADM(IE) SharePoint site
• CSA B52:23 Mechanical refrigeration Code – Thirteenth Edition
• Montreal Protocol on Substances that Deplete the Ozone Layer, UN Environment Programme, Ozone Secretariat website

Back to top