5. Domestic Approach: Progress on Actions in Canada

The following section provides an update on domestic initiatives and discusses the implementation of risk management measures proposed in the Risk Management Strategy for Mercury. Actions prior to the strategy have also been taken by the Government of Canada to manage potential exposure sources of mercury, including paints, toys, cosmetics, natural health products, drinking water and pesticides. A list of these additional actions can be found in Annex I of this document.

5.1 Industrial sectors: coal-fired electricity power generation

5.1.1 Canada–wide Standard for Mercury Emissions from Coal-fired Electric Power Generation Plants

The Canada-wide Standard for Mercury Emissions from Coal-fired Electric Power Generation Plants (the Standard) was developed in 2006 by the Canadian Council of Ministers of the Environment as transitional risk management measure to address the largest mercury emitting sector in Canada. The Standard was the leading mercury control instrument in Canada until the publication of the Reduction of Carbon Dioxide Emissions from Coal-Fired Generation of Electricity Regulations in 2012 (see section 5.1.2).

The Standard has two risk management objectives:

  1. to reduce mercury emissions from the largest remaining human generated source of mercury emissions in Canada
  2. to set provincial caps on mercury emissions and performance standards or emission limits based on best available control technology for new units

The Standard also has two targets that set specific:

  1. caps on mercury emissions for each signatory jurisdiction, representing a 60% national capture rateFootnote 1 of mercury from coal burned from these facilities by 2010 (total cap of 1,130 kg)
  2. capture rates or emission limits for new facilities, based on best available control technology, effective in 2006

With the exception of Ontario, all provinces endorsed the Canada–wide Standard. Ontario phased-out mercury emissions from coal-fired electric power generation in 2014 with the Ending Coal for Cleaner Air Act (Government of Ontario, 2015).

Emissions of mercury from the plants covered by the Canada-wide Standard represented 96% of Canada’s total mercury emissions from electric power generation in 2010 (National Pollutant Release Inventory, 2018). The remaining 4% was emitted from electric power generation facilities using biomass and natural gas as fuel sources.

Results: Despite a 30% reduction in emissions between 2007 and 2010, emissions of mercury from the coal-fired electricity sector were 1,452 kg, 28% higher than the targeted emissions cap of 1,130 kg in 2010. The total emissions cap target was met in 2011 when mercury emissions from plants in all provinces totalled 913 kg. Since then, annual mercury emissions have been well below the cap. Overall mercury emissions from coal-fired electricity generation decreased by approximately 72% between 2007 and 2017 (Table 3).

Although the total emission cap was first met in 2011, the capture rate of mercury emissions was only 56%, 4% below the targeted capture rate of 60%. In 2014, approximately 662 kg of mercury were emitted and there was a total of 1947 kg of mercury in the coal burned, meaning that the capture rate of mercury was 67% and the 60% capture rate target was surpassed.

Table 3. Mercury emissions from coal-fired electric power generation plants by province
Province (with coal-fired power plants) 2007 Mercury Emissions (kg) 2010 Mercury Emissions Caps (kg) 2010 Mercury Emissions (kg) 2011 Mercury Emissions (kg) 2014 Mercury Emissions (kg) 2017 Mercury Emissions (kg)

AB

829

590

643

216

236

143

MB

0

20

1

1

0

0

NB

95

25

31

18

15

12

NS

156

651 (110)

81

95

54

66

ON

304

Not set

95

32

0

0

SK2

688

430

600

551

357

363

TOTAL3

2,072

1,130

1,452

913

662

584

1 The cap for 2010 was changed in Nova Scotia regulations from 65 kg to 110 kg, with the cap gradually declining to 35 kg/year in 2020.

2 Although these are the actual emissions for these years, this cap was achieved with accumulated credits for early action.

3 Totals may not add up due to rounding

Source: Air Pollutant Emissions Inventory (2019), reported under Source: Electric Power Generation (Utilities) Sector:  Coal.

In a review of the Standard, the Air Management Committee of the Canadian Council of Ministers of the Environment indicated that provincial caps for the Standard should be maintained, and monitoring and biennial reporting of mercury emissions from coal-fired electric power generation plants should continue until 2020.

Conclusion: The risk management objectives of the Standard were surpassed, but the transition to cleaner electric power generation in Canada progressed more slowly than anticipated between 2007 and 2010. The Canada-wide Standard itself was only one of the drivers for reducing mercury emissions from coal-fired plants. In some cases, the closing of coal-fired electric power generation facilities, introduction of non-coal facilities, and/or increased emissions abatement for existing facilities occurred after 2010 and also contributed to the decreased emissions.

5.1.2 The Reduction of Carbon Dioxide Emissions from Coal-Fired Generation of Electricity Regulations

The Regulations set a stringent performance standard for new coal-fired electricity generation units and those that have reached the end of their useful life. These regulations came into force on July 1, 2015 and are specific to greenhouse gases. However, because mercury is released during the combustion of coal, mercury will also be reduced when facilities close by the end of their economic lives, which is generally 50 years after commissioning.

In November 2016, the Government of Canada published a Notice of Intent to amend the Regulations in order to accelerate the phase-out of traditional coal-fired electricity by 2030 and replace it with cleaner sources. The Amendments were published in the Canada Gazette, Part II in December 2018 (Government of Canada, 2018).

Conclusion: Mercury emissions from coal-fired electricity generation units are expected to be reduced as a co-benefit by an estimated 1.4 tonnes. It is too early to assess the performance of this risk management instrument as most reductions are expected between 2020 and 2030.

5.2 Mercury pollution from products

Mercury has many useful properties, which have led to its use in a variety of different products traded globally. For example, it forms alloys with other metals, conducts electricity, and expands in response to changes in pressure and temperature. In 2008, an estimated 8,100 kg of mercury entered the Canadian marketplace in products (through manufacturing or import), with more than half (4,700 kg) contained in dental amalgam (Government of Canada, 2014). Mercury was also used in lamps, thermostats, switches and relays, batteries, thermometers, other measuring devices, and tire-balancing products. Since 2007, the Government of Canada has implemented several risk management instruments to address the use of mercury in products, as well as to manage the disposal of these products.

5.2.1 The Products Containing Mercury Regulations

The risk management objective for the Regulations is to protect human health and the environment by reducing releases of mercury from products used in Canada to the lowest level that is technically and economically feasible. The Regulations came into force in 2015 and prohibit the manufacture and import of products containing mercury or any of its compounds, with some exemptions for essential products with no technically or economically viable alternatives. The Regulations also include labelling, record-keeping, and reporting provisions and identify the maximum total quantities of mercury allowed to be contained in some exempted products. They additionally set phase-out dates for some exempted products.

The Regulatory Impact Analysis Statement indicated that the Regulations are expected to reduce the use of mercury in products by about 41,000 kg between 2015 and 2032. Releases of mercury from products to the environment during that period are estimated to decrease by 21,000 kg.

Results: In March 2017, industries submitted their first report for the year 2016. Fewer than 10 of the 123 reporting organizations manufactured products containing mercury in Canada. A preliminary analysis of the data collected indicates that in 2016, over 40 million units of permitted and exempted products were imported into Canada and over 25 million units were manufactured. These products together contain a total of approximately 1000 kg of mercury. Out of all exempted or permitted imported and manufactured products 54% were dental amalgams and 41% were lamps.

Conclusion: Additional data are needed to assess this instrument’s performance and will be collected through reports from industry that are required every three years. Data from the first report will be used as a baseline against which to measure progress in meeting the risk management objective. Amendments to the Products Containing Mercury Regulations are underway to achieve further mercury reductions in some product categories and to align with international agreements.

5.2.2 Controlling the export of mercury

Canada’s ratification of the Minamata Convention required comprehensive controls to be placed on the export of elemental mercury. As a result, in February 2017, the Regulations Amending the Export of Substances on the Export Control List Regulations were published in the Canada Gazette, Part II (Government of Canada, 2017c) and amendments were made to the Export Control List (Schedule 3 of CEPA). These amendments restrict the export of mixtures containing elemental mercury at a concentration of 95% or more (by weight), with certain exemptions in Canada.Footnote 2 These new controls help to reduce the global supply of elemental mercury, which can be used for artisanal small-scale gold mining in developing countries. This activity is the largest source of global anthropogenic mercury emissions.

Conclusion: As these regulatory requirements were recently introduced, there is not enough data at this time to report on their progress. Future evaluations will assess the effectiveness of these regulations by examining relevant import and export data.

5.3 Waste management

Products containing mercury enter the waste stream each year. Releases of mercury to the environment can also occur at any stage of a product’s life cycle, including manufacturing, use, recycling, and disposal. Mercury can also enter surface water from wastewater treatment facilities or landfills that contain mercury-containing consumer products, including batteries, compact fluorescent light bulbs, and electrical switches.

Risk management action on products containing mercury is expected to reduce the accumulation of mercury in the waste stream and associated mercury emissions and releases. Providing consumers with more information on how to dispose of their mercury-containing products will also change consumer behaviour and in turn help further protect Canadians and their environment from mercury emissions.

5.3.1 Notice Requiring the Preparation and Implementation of Pollution Prevention Plans in Respect of Mercury Releases from Mercury Switches in End-Of-Life Vehicles Processed by Steel Mills

Before January 1, 2003, mercury switches (small devices for activating the lights in automobile hoods and trunks and some anti-lock braking systems) were used in some vehicles. Each switch contained less than one gram of mercury. The pollution prevention planning notice on mercury switches in end-of-life vehicles processed by steel mills was published in 2007 and targeted all 13 manufacturers of vehicles and 10 steel mills processing vehicles being scrapped or the steel scrap derived from these vehicles.  

The vehicle manufacturers and steel mills subject to the notice were required to prepare pollution prevention plans for managing mercury switches from vehicles by July 2008 and to submit interim progress reports in 2009 and 2010 (Government of Canada, 2007). The risk management objective was to reduce releases of mercury to the environment through participation of vehicle manufacturers and steel mills in a mercury switch management program.  The target of this program was to collect 90% of mercury switches in vehicles  within the first four years of the program (2008-2011) based on forecasts made using a model in 2004.

Results: A total of 413,328 mercury switchesFootnote 3 were collected and reported under the pollution prevention notice within the first four years (2008 to 2011) (Table 4). This notice on mercury switches led to a vehicle mercury switch recovery program in all Canadian provinces and territories. With a vehicle life of 10 to 15 years, new vehicles manufactured in 2002 would likely be on the road until 2013 to 2018, with most mercury switches expected to be collected by 2018. For this reason, the national program has now been completed. During the course of the 10 year program, nearly 650 kg of mercury was recovered. All of this mercury was recycled or disposed of in an environmentally sound manner.

However, 90% of switches were not collected within the first four years of the pollution prevention notice. This was because the 2004 forecasts for number of switches available for annual collection were too high and reflected inaccurate assumptions about vehicle scrappage and decay rates. In addition, data gaps existed for the number of switches per vehicle, vehicle mortality rates, process rates of recyclers, and the scrapping of vehicles (dismantling, shredding, flattening, etc.) (Environment and Climate Change Canada 2013).

Table 4. Cumulative results of Mercury Switch-out Program
- 2008 2009 2010 2011 2018
Number of switches 64,011 112,167 76,866 67,542 448,203
Cumulative total - 176,178 253,044 320,586 768,789
Average g of mercury/switch 0.859 0.856 0.824 0.829 0.843
Approximate mercury recovered (kg) 55 96 63 56 378
Cumulative total (kg) - 151 214 270 648

Conclusion: The risk management objective of reducing releases of mercury to the environment through participation of vehicle manufacturers and steel mills in a mercury switch management program in Canada was achieved. While all vehicle manufacturers and steel mills subject to the notice on mercury switches participated in the mercury switch management program, 90% of mercury switches were collected after the target date.

5.3.2 Notice Requiring the Preparation and Implementation of Pollution Prevention Plans in Respect of Mercury Releases from Dental Amalgam Waste

The pollution prevention planning notice on dental amalgam waste was published on May 8, 2010 in the Canada Gazette, Part I (Government of Canada, 2010b). It targeted dental facilities that had not implemented the best management practices set out in a memorandum of understanding between the Canadian Dental Association and Environment and Climate Change Canada (PDF) (2002) that required these dental facilities to prepare and implement pollution prevention plans for mercury releases from dental amalgam waste. In 2009, it was estimated that between 6,300 to 8,100 of the existing 9,000 dental facilities were already using dental amalgam separators and implementing best management practices. The risk management objective of the notice was to implement plans to divert mercury waste and limit environmental releases from dental amalgam.

The notice on dental amalgam waste was intended to encourage a 95% national reduction of mercury releases to the environment from dental amalgam waste from a base year of 2000 (1,879 kg), a target that was originally established under the Canada-wide Standard on Mercury for Dental Amalgam Waste. The 900 to 2,700 dental facilities that were subject to the pollution prevention notice were expected to prepare and implement a pollution prevention plan by August 2010.

Results: As of December 31, 2010, Environment and Climate Change Canada had received a total of 204 declarations that a pollution prevention plan was prepared under the notice and had been implemented. In response to the low participation rate, a survey of dental facilities across Canada was commissioned in 2012 with the goal to assess the awareness of the pollution prevention plan notice, the overall implementation of best management practices for dental amalgam waste and the effectiveness of the notice. The survey complemented data collected from two earlier national surveys conducted in 2003 and 2007. The data from all the surveys are summarized below (Table 5).

Table 5. National survey of dental facilities in 2003, 2007, and 2012

-

Base year 2000 2003 2007 2012

Percentage1 of dental facilities using ISO-certified dental amalgam separators2 (%)

negligible

27

70

974

Quantity of mercury being released to the environment from dental amalgam waste(kg)

1,8793

1,046

452

75

1 Over 3,000 dentists were surveyed in each of 2003, 2007 and 2012. There were 984, 1,185, and 1,250 respondents, respectively.

2 A high-efficiency amalgam separator that meets ISO 11143:1999 standards.

3 These numbers were estimated with best available data at the time.

4 Three percent of respondents were unsure if their separator was ISO-certified. As the ISO 11134 standard was developed at the same time as the best management practices (2002), it was important at the time to specify if the separator was ISO certified or not. Some years after, the major retailers of amalgam separators were only selling ISO-certified equipment.

By 2007, 70% of dentists across Canada were using International Organization for Standardization (ISO)-certified amalgam traps (corresponding to a 57% reduction in mercury reaching dental wastewaters compared to the year 2000). The 2012 survey revealed that the national reduction target of 95% was surpassed, with an estimated 75 kg being released to wastewater. The survey also indicated that 97% of the 1,250 facilities that responded had put in place best management practices and installed an amalgam separator to collect mercury from waste.

The 2012 survey also revealed that the use of dental amalgam in Canada had decreased by 43% since 2003; this trend was also observed elsewhere, including the European Union. In addition, removal of dental amalgam has increased by approximately 70% since 2000. This reduction in the use of dental amalgam is likely due to preferences for other dental materials as well as increased awareness of dental amalgam’s environmental effects.

Conclusion: The risk management objective for this instrument was achieved, meaning that there was a 95% national reduction in mercury releases to the environment from dental amalgam from a base year of 2000. While the notice on dental amalgam waste itself may have played a role in the implementation of best management practices for managing mercury from dental amalgam waste, increased environmental awareness of mercury waste management among dental facilities, efforts made by dental amalgam separator suppliers, and provincial and municipal initiatives also played a role.

5.3.3 Code of Practice for the Environmentally Sound Management of End-of-Life Lamps Containing Mercury

In February 2017, Environment and Climate Change Canada published A Code of Practice for the Environmentally Sound Management of End-of-Life Lamps Containing Mercury (the Code) (Government of Canada, 2017b). This voluntary Code provides best practices for the collection, storage, transport, processing, and disposal of lamps containing mercury, as well as guidance for northern and remote areas where access to proper disposal is limited. The Code is designed to encourage collectors, transporters, and recyclers to incorporate best practices into their end-of-life management of mercury-containing lamps to prevent releases of mercury to the environment.

In the future, the Code will be updated to take into account advances in technologies and practices and new developments under international agreements. While the Code itself does not contain a specific target, it will be promoted and its implementation will be measured as part of the National Strategy for the Safe and Environmentally Sound Disposal of Lamps Containing Mercury Act.

5.3.4 National Strategy for the Safe and Environmentally Sound Disposal of Lamps Containing Mercury Act

On 22 June 2017, the National Strategy for the Safe and Environmentally Sound Disposal of Lamps Containing Mercury Act received Royal Assent (Government of Canada, 2017a). The Act required the Minister of Environment and Climate Change Canada to develop a national strategy by June 2019 and to report to Parliament on its implementation every five years. The Minister tabled the final strategy in Parliament on July 17, 2019.

The vision of the strategy is to eliminate lamps as a source of mercury pollution in Canada. In order to do so, it identifies six priorities:

  1. prohibit the manufacture and import of the most common types of lamps containing mercury
  2. increase public awareness of mercury lamps, their diversion programs, and energy efficient mercury-free alternatives
  3. increase participation in diversion programs by strengthening requirements and reducing barriers
  4. improve government operations
  5. increase accessibility and implementation of guidelines and best practices
  6. improve performance measurement and reporting

A national strategy web page is available featuring a baseline report, information on lamps, and a map of lamp collection sites in Canada. The web page will be updated as new information, data, and communications products become available.

In collaboration with key stakeholders, including provinces and territories, the Government of Canada will study the potential for and effectiveness of regulatory measures, such as extended producer responsibility programs and landfill disposal bans, and release an interim report in 2022.

Conclusion: it is too early to measure the performance of this risk management instrument. The strategy’s performance measurement framework describes the information the Government of Canada will collect and report on to assess the effectiveness of the strategy. In 2024, the Minister will present to Parliament the first report on the effectiveness of the strategy and their recommendations regarding the strategy.

5.4 Reducing exposure to mercury

The main source of exposure to mercury for most Canadians is eating fish and other seafood (Government of Canada, 2010a). However, the Government of Canada recognizes that both retail fish and country foods (foods caught for personal consumption through hunting or fishing) have significant nutritional benefits. Health Canada has set maximum levels for mercury in all retail fish. These levels are enforced by the Canadian Food Inspection Agency. The Canadian Food Inspection Agency  regularly tests domestic and imported commercial fish and shellfish, both freshwater and marine, to enforce the mercury guidelines.

Health Canada also provides consumption advice for certain types of fish that contain elevated mercury levels, such as tuna, shark, swordfish, marlin, orange roughy and escolar. For example, it is recommended that Canadians limit consumption of large, predatory species of fish such as shark, swordfish, fresh or frozen tuna and marlin to no more than one meal (150 grams) per week. Children, pregnant women and women of childbearing age are advised to eat no more than one meal per month of these kinds of fish. Most types of canned tuna are exempted from this advice, because they are regularly tested and found to be below the Health Canada guideline of 0.5 parts per million of mercury. Canned albacore or canned white tuna can have higher mercury levels compared to other canned tuna so consumption advice is also provided for this fish. Advisories on the consumption of country foods due to concerns about mercury are made by the appropriate authorities (e.g. local public health authorities in the North, or provinces).

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