Consultation document on proposed revisions to Federal Halocarbon Regulations: chapter 5
Consultation Topics: Service Logs, Release Reports and Critical Systems
This section is organized using the same headings as found in the Federal Halocarbon Regulations, 2003 (FHR 2003). For each heading, the purpose of the provisions is provided for context, followed by a summary of each issue, the proposed revision, and any targeted questions for which Environment Canada is seeking input.
The purpose of the Service Logs provisions is to provide proof of proper system maintenance by recording all activities that may result in the release of a halocarbon, as well as the releases themselves. The Service Logs provisions also allow owners to track activities and discover trends, allowing for better decision-making.
Issue 13 - Exemption of Small Refrigeration and Small Air-Conditioning Systems from Service Log Requirements
Small refrigeration and small air-conditioning systems (see Issue 3) generally refer to domestic appliances that contain little refrigerant and are often easier to replace than to repair. These systems are already exempt from annual leak tests required under subsection 11 (2) of the FHR 2003. Consistent with that exemption, requiring service logs be maintained for these systems adds administrative burden and detracts focus from larger industrial systems, which have greater potential to negatively impact the environment.
- Exempt small refrigeration and air-conditioning systems from the Service Log provisions of the FHR 2003.
The purpose of the Release Reports provisions is to track the federal contribution to halocarbon releases to the environment.
Issue 14 - Reporting of Releases of 100 kg or More
Releases of 100 kg or more must be reported verbally or in writing within 24-hours after the release is detected, followed by another written report within 14 days. The 24-hour reports are directed to regional spill lines across the country and the 14-day written reports are directed to Environment Canada. While it is important for Environment Canada to be made aware of large releases as soon as possible, since halocarbons cannot be recovered after being released, their release should not be considered to trigger an emergency response by Environment Canada. In addition, for some of the largest systems, not all information to complete the 14-day report is available within those 14 days, so a mechanism should be available to update any information reported in those 14-days should more accurate information become available.
- Revise section 32 to require that releases of 100 kg of halocarbon or more be reported to Environment Canada within 3 days, followed by a 14-day written report.
- Add a provision to allow owners to revise the 14-day report to allow reported information to be updated from estimates to final measurements, when it becomes available.
- Is 14 days generally sufficient to gather information on a release of 100 kg or more?
The purpose of the Critical Systems provisions is to add the ability for owners to apply for their fire-extinguishing systems to be classified as critical, exempting them from charging prohibitions and applying for permits.
Issue 15 - Critical Systems
Some fire-extinguishing systems are in place in critical work environments, such as nuclear facilities, for which there are currently no alternatives to the use of a halocarbon that provide the same level of protection to human life or health for both those that work in the facility and/or living nearby. These systems must be immediately charged after fighting a fire, and cannot wait for permits to be issued. Owners of these systems currently apply annually for a charging permit as a precaution should the system be discharged and require an immediate charge, resulting in administrative burden to apply for and issue permits.
- Add provisions that allow owners to apply to Environment Canada to designate their fire-extinguishing systems as critical. Critical systems are those systems that, should the halocarbon be discharged to fight a fire, can be immediately recharged to maintain the safety to human life or health. In order to be designated as a critical system, owners would need to prove that the system is critical and that efforts have been undertaken to find an alternative substance to replace the halocarbon. The critical designation would be in effect for a period of 3 years, after which the owner must reapply for the designation.
- Add provisions to require owners of critical systems to report within 30 days when a system has been charged.
- Are there systems other than those in nuclear facilities that might be considered critical?
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