Consultation document on proposed revisions to Federal Halocarbon Regulations: chapter 6

Consultation Topics: Permits and Logs, Notices, Records and Reports

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.

Permits

The purpose of the Permits provisions is to allow certain prohibited activities to continue when no technically or financially feasible alternative to the use of a halocarbon exists.

Issue 16 - Permits to Install Fire-Extinguishing Systems

Permits are required to install fire-extinguishing systems that use any halocarbon listed as items 1-9 on Schedule 1 of the FHR 2003 on aircraft, military ships or military vehicles. Aircrafts, military ships and military vehicles are constructed for specific fire-extinguishing systems that cannot be replaced by any other substance due to size and weight constraints. Requiring a permit for each system installation is an administrative burden.

Proposed Revision

• Exempt the following fire-extinguishing systems from the requirement to apply for an installation permit:
  • systems for use on a military vehicle or a military ship,
  • systems for use on an aircraft, except those that are prohibited by the ICAO Convention on International Aviation (see Issue 11).

Logs, Notices, Records and Reports

The purpose of the Logs, Notices, Records and Reports provisions is to ensure that these documents are available and easily located.

Issue 17 - Regulatee Identification

The FHR 2003 has a large list of regulatee and covers a large number of systems and industry sectors. An accurate regulatee list is necessary to ensure that regulatees receive adequate guidance and compliance promotion materials.

Proposed Revisions

• Add a provision to require owners to submit to Environment Canada a report indicating the responsible position in the organization, location, and number and types of systems that they own.
• Exempt small refrigeration and air-conditioning systems from the requirement to report (i.e., domestic refrigerators, freezers, air-conditioners, etc).

Issue 18 - Unoccupied Sites

Subsection 36(4) currently requires that copies of all logs, notices, records and reports for unoccupied sites (i.e., sites that are not regularly occupied by the owner) are kept at a single location that is occupied by the owner. Owners were also required to submit information on these systems to Environment Canada in 2004, and update the information whenever it changed. The inventory of unoccupied sites is not necessary to effectively implement and enforce the FHR 2003 and results in administrative burden.

Proposed Revision

Revise subsection 36(4) to remove the requirement to update information on unoccupied sites and to require that copies of all logs and reports for unoccupied sites be kept at the nearest location to the site that is occupied by the owner.