Environmental recommendations for wood preservation facilities: acknowledgements: explanatory note

Explanatory Note

The Recommendations for the Design and Operation of Wood Preservation Facilities, 2013, is known as the Technical Recommendations Document 2013 (2013 TRD). This 2013 TRD is a revision of the 2004 version. The 2013 revision was to clarify recommendations from previous editions and to add additional information that was detailed in the TRD associated document (Technical Guidelines for the Design and Operation of Wood Preservation Facilities, 2004). The revision provides clarity, web references, and uniformity between similar preservatives and details recommendations to ensure comprehension and consistency from facility to facility.

The general background information has been separated from Chapter A of the 2004 version in order to keep only design and operational recommendations in the 2013 TRD Chapter A. The new Chapter A can be used as a generic chapter for future registered preservatives that are not yet included in the 2013TRD.

Chapter A must always be used in conjunction with the other preservative-specific chapters when applicable.

The Canadian Environmental Protection Act, 1999 (CEPA 1999) is an important part of Canada’s federal environmental legislation aimed at preventing pollution and protecting the environment and human health. The goal of CEPA 1999 is to contribute to sustainable development--development that meets the needs of the present generation without compromising the ability of future generations to meet their own needs. The risk management of the toxic substance used in the wood preservation sector was developed under CEPA 1988 and CEPA 1999. The exercise led to the development of the Technical Recommendations Document to prevent pollution and protect the environment and human health effects associated with such facilities. The recommendations are consistent with good pollution prevention practices and environmentally sound management.

The target audiences for this 2013 TRD are the owners and operators of wood preservation facilities and those who are designing new facilities or retrofitting existing ones. In many instances the document contains general summary information on topics such as potential environmental and human health hazards and environmental effects potentially associated with exposure to these preservatives.

Please note that you are required to comply with all municipal, provincial, territorial and/or federal legislation that applies to the work being carried out in relation to this technical recommendations document 2013 TRD.

Although the recommendations do reflect currently available best practices, local regulatory authorities may want to deviate to accommodate local conditions. The recommendations contained in this 2013 TRD may not be the only options available for attaining the stated objectives, and other recommendations for site-specific conditions may be more suitable. When programs are developed for a particular facility, the recommendations provided may be modified if it can be demonstrated that an alternative approach, more suitable to the facility conditions, would be equally effective for attaining the objectives. Provincial regulation of wood preservation facilities and industrial operations, in general, vary across Canada. Each facility should consult with all authorities that may have jurisdiction over it and its operations.

The Pest Management Regulatory Agency (PMRA) is the federal agency that is responsible for the regulation of wood preservatives in Canada. Under the Pest Control Products Act (PCPA), wood preservatives are required to be registered and used as per label requirements established under the PCPA. Labelling requirements are based on scientific data on occupational exposure, toxicology, and environmental chemistry and ecotoxicology associated with wood preservatives. In 2011, the PMRA amended the labelling requirements for several CEPA toxic wood preservatives (Re-evaluation Decision RVD2011-06, Heavy Duty Wood Preservatives: Creosote, Pentachlorophenol, Chromated Copper Arsenate (CCA) and Ammoniacal Copper Zinc Arsenate (ACZA)). These amendments stipulate that, as of November 2013, operational procedures in facilities using these preservatives must be consistent with the Recommendations for the Design and Operation of Wood Preservation Facilities: Technical Recommendations Document (TRD). The 2013 TRD is also intended as the core reference document for all other wood preservation facilities using non-CEPA toxic preservatives. Adoption of the 2013 TRD should minimize potential environmental and human health effects associated with wood preservation facilities.

The pesticide label is a label that conveys information required by the Pest Control Products Act (PCPA), or its related regulations, to accompany a pest control product. This includes requirements for adherence to directions on application rates; personal protective equipment; storage and disposal. Each facility is responsible for keeping available a copy of the most recent pesticide label for each registered pesticide used within the facility. The pesticide labels should be provided by the pesticide manufacturer and be available to the operators. Subject to regulations under the PCPA, all registered products must be handled, stored, transported, used or disposed in accordance with the information on a pesticide label. Any other document or specification may require additional or more protective measures; they may not be less protective.

As information may change over time, facilities must ensure that all information is current. At a minimum, annual reviews of content by the facility manager or designated health and safety individual are recommended.

Electronic copies of pesticide labels may be obtained from the Health Canada website.

For all purposes of interpreting and applying the law, users should consult the Acts as passed by Parliament, which are published in the “Assented to” Acts service, Part III of the Canada Gazette and the annual Statutes of Canada.

The above-mentioned publication is available in most public libraries. Official versions of the statutes and regulations can also be found at the Department of Justice website - Justice Laws website. The law as stated in the above-mentioned publications will prevail should any inconsistencies be found in this guidance document.