List of pollution prevention planning notices and their performance
Proposed notices
Below are the proposed notices.
Consultation period: Opened on August 1st, 2023, for a 30-day public comment period ending on August 30th, 2023.
Objective: The P2 notice would seek to reduce the environmental impact of primary food plastic packaging along the value chain to the greatest extent practicable through the elimination of unnecessary or problematic packaging and design for circularity.
Notices in effect
Below are the notices in effect.
Bisphenol A in industrial effluents
The bisphenol A in industrial effluents P2 notice applies to owners of facilities that manufacture or use greater than 100 kg of bisphenol A per year alone or in a mixture, release effluents containing bisphenol A, and are involved in the activities specified in the notice.
Objective: Achieve and maintain the lowest total BPA concentration that is economically and technically feasible and is less than 1.75 µg/L in effluent released.
Results: The notice remains in effect. As of 2017, results demonstrate that despite the shift to non-BPA products, the substance is still present in effluents above the target for 2 of the 4 facilities. They have agreed to pursue sampling twice a year until the achievement of the risk management objective. There has been an overall 99% reduction in the amount of BPA used. An overall reduction of 94% of BPA sent off-site wastewater systems was achieved. An overall reduction of 83% has been achieved to date for the average concentration of BPA in effluents.
Dental amalgam waste (mercury)
The dental amalgam P2 notice applies to owners of dental facilities that perform activities in relation to dental amalgam or elemental mercury.
Objective: Contribute to a 95% national reduction in mercury releases to the environment from dental amalgam waste, from base year of 2000.
Results: The notice is in effect. The P2 notice, coupled with other factors outside of the scope of the notice (e.g.: increased environmental awareness of mercury waste management among dental facilities, efforts from dental amalgam separators suppliers, and provincial and municipal initiatives) may have played an important role in implementing best management practices in managing mercury from dental amalgam wastewater. Furthermore, a 2012 follow up survey indicated that 97% of the 1250 facilities that responded had put in place best management practices and had installed an amalgam separator to collect mercury from waste. These factors contributed to the achievement of the objective.
Halocarbons
The halocarbons P2 notice applies to owners of companies that import, manufacture or reclaim halocarbons used as a refrigerant in refrigeration systems or stationary air-conditioning systems other than domestic appliances, in quantities of 100 kg or more annually.
Objective: Manage halocarbon refrigerants in an environmentally-sound manner in order to minimize the release of halocarbons into the environment.
Results: The notice is in effect. As of May 1, 2019, 9 companies had implemented their pollution prevention plan and therefore the companies had met the risk management objective. A 10th company is currently implementing their P2 plan and their results will be included in the next performance report. Since 2016, this P2 notice has prevented the release of more than 585 tonnes of halocarbons into the environment.
Hydrazine
The hydrazine P2 notice applies to any person who operates a facility in the electricity sector. The facility must have a concentration of hydrazine that is higher than the specified target levels under normal operating conditions and at any final discharge point.
Objective: The notice is still in effect. Achieve and maintain a total hydrazine concentration in effluent at each final discharge point of the facility that is less than or equal to the specified target levels. The levels are: 26 ug/L, if discharged to a Great Lake; 26 ug/L, if discharged to a large freshwater body; 2.6 ug/L, if discharged to freshwater body that is not a large freshwater body or a Great lake; or 2.0 ug/L, if discharged to sea water.
Results: The vast majority of facilities in this sector have not exceeded the maximum concentration of hydrazine in their effluents. Although Manitoba Hydro’s Selkirk facility implemented a pollution prevention plan and submitted a Declaration of Preparation and a Declaration of Implementation, it is no longer in operation. Therefore, the facility is no longer using hydrazine or releasing it into the environment.
Iron, steel and ilmenite sector
The iron, steel and ilmenite sector P2 notice applies to owners of facilities in the iron, steel and ilmenite facilities.
Objective: Achieve and maintain the base level industrial emissions requirements (BLIERs) air emission targets for oxides of nitrogen (NOX) and sulphur dioxide (SO2). Implement best practices to reduce fugitive volatile organic compounds (VOCs) emissions, where appropriate and practicable.
Results: The notice is in effect. Facilities subject to the P2 notice must report annually an interim progress report that details progress made in implementing their plan. The reporting date of interim progress reports have been moved from June 1 of each year to September 1. All 13 facilities subject to the notice submitted their sixth interim progress report (schedule 4) with data from the 2023 calendar year. The ilmenite smelting facility met its SO2 target. Eleven of twelve iron and steel facilities met their NOx target. All other targets on SO2 and VOCs are to be met by 2025 or beyond. These will be assessed at a future date, as appropriate. The industry seventh interim progress reports with data from 2024 calendar year are expected by September 1, 2025.
Reaction products of 2-propanone with diphenylamine (PREPOD)
The PREPOD P2 notice applies to owners or operators of facilities within the chemical manufacturing or rubber products manufacturing sectors, that in 2019 or any year thereafter, have an industrial effluent and that manufacture or use PREPOD, or a mixture or compound containing PREPOD, in a quantity greater than 100 kg per calendar year.
Objective: Reduce the presence of PREPOD in industrial effluents by reducing the concentration of the component diisopropyldimethylacridan (DIPDMA) below its level of quantification of 0.12 ng/L.
Result: The notice is in effect. All 3 facilities subject to the P2 notice met the implementation date of July 1, 2023. In accordance with their P2 plans, all facilities ceased their manufacture and/or use of PREPOD containing products. While no facility met the objective by the implementation date, voluntary sampling conducted by 2 facilities in the fall of 2023 provided analytical results demonstrating concentrations of DIPDMA below 0.12 ng/L.
Siloxane D4 in industrial effluents
The siloxane D4 in industrial effluents P2 notice applies to owners of facilities that manufacture or use 100 kg or more of siloxane D4 per year alone or in a mixture, release effluents containing siloxane D4, and engage in the activities specified in the notice.
Objective: To reduce total siloxane D4 releases to the aquatic environment from the sum of all facilities subject to the notice by 80%, from the preparation year levels, by the end of the implementation period.
Results: The notice is in effect. Results from 2017 demonstrate that 5 of the 6 facilities met the target and reduced the D4 concentration in their effluents to a level that is less than or equal to 17.3 μg/L or released a total quantity of D4 in their effluents that is less than or equal to 3 kg per year. One facility did not meet the risk management objective despite significant reductions in their D4 releases. Because that facility is the biggest D4 user, the overall risk management objective of the notice was not met. The total D4 releases by the 6 facilities were nevertheless reduced by 56%.
In 2023 and 2025, Environment and Climate Change Canada sampled the effluent of certain industrial facilities and the effluent of the receiving municipal wastewater treatment plants. Although the concentration of D4 in the effluent from two of the sampled industrial facilities was higher than the target of 17.3 µg/L, it remained significantly lower than the concentrations observed before the implementation of the pollution prevention plans. In addition, the concentration measured in the effluent of the municipal wastewater treatment plants allows us to estimate that the concentration of D4 in the receiving natural environment remains below the estimated no-effect concentration.
Synthetic rubber manufacturing sector (isoprene)
The isoprene P2 notice applies to owners of facilities in the synthetic rubber manufacturing sector that purchase, import or use greater than 100 kg of isoprene per year and are involved in the activities specified in the notice.
Objective: To reduce human exposure to isoprene through the reduction of industrial emissions of isoprene to the environment by 80% relative to the base year (2009), using best available techniques that are economically achievable.
Results: The notice is in effect. As of late 2019, 1 facility, Arlanxeo East, located in Sarnia, Ontario, was subject to the notice and implemented a P2 plan. In 2018, the facility’s emissions of isoprene to the environment were 3 862 kg. This corresponded to a reduction of 78% relative to their 2009 baseline year and a partial achievement of the objective which targeted a reduction of 80%.
Toluene diisocyanates (TDIs)
The TDI P2 notice applies to owners of facilities who, in 2018 or any time thereafter, release into the ambient air 100 kg or more of TDIs per calendar year.
Objective: Reduce human exposure to TDIs through the reduction of industrial TDI emissions to ambient air to the greatest extent practicable, using best available techniques economically achievable.
Triclosan
The Triclosan notice applies to any person who either imports 100 kg or more of triclosan in a calendar year contained in cosmetics, natural health products or drugs or uses 100 kg or more of triclosan in a calendar year in the manufacture of cosmetics, natural health products or drugs.
Objective: Reduce the quantity of triclosan released to the aquatic environment as a result of the use of triclosan-containing products that companies import into or manufacture in Canada.
Results: The notice is still in effect. The three known companies subject to the notice submitted their final declaration (Schedule 5 of the notice) summarizing the outcomes of their implemented P2 plan by the deadline of November 9, 2023. These companies have met the target by reducing the total mass of triclosan by at least 30% in the manufacture or import of their products subject to the notice. Two of the three companies have completely discontinued the manufacture and import of triclosan in their products subject to the notice.
Notices no longer in effect
Below are the notices no longer in effect.
Acrylonitrile
The acrylonitrile P2 notice applied to owners of facilities that manufactured synthetic rubber using acrylonitrile which resulted in releases of acrylonitrile to the environment.
Objective: Reduce the release of acrylonitrile from synthetic rubber manufacturing sources to the lowest achievable level by the application of best available techniques economically achievable.
Results: The notice has been successful. Total releases were reduced by 85%. The following is a breakdown of the results:
- Off-site disposal reduced by 100% (12 600 kg)
- Fugitive releases reduced 89% (4150 kg)
- Storage and handling releases reduced 82% (400 kg)
- Stack or point releases increased 14% (300 kg)
Base metals smelters and refineries and zinc plants (specified toxic substances)
The base metals smelters and refineries and zinc plants (specified toxic substances) P2 notice applied to 11 facilities where processing activities (such as smelting, refining or other) result in the release of toxic substances to the environment.
Objective: The application of best available techniques for pollution prevention and control to avoid or minimize the creation and release of pollutants and waste and to reduce the overall risk to the environment or human health.
Results: The notice was successful. Facilities implemented both pollution prevention and control methods. They took into consideration most of the factors to consider from the notice like the recommended practices of the code of practice and the 2008 and 2015 air limit targets. Seven out of 9 facilities and 8 out of 9 facilities met the 2015 targets respectively for sulphur dioxide and particulate matter while each of the 2 facilities subject to the 2008 air limit target met it respectively for mercury and dioxins and furans.
In addition, the sector achieved its 90% target reduction of total releases for metals as set out in the recommendation of the base metals smelting sector strategic options report in reducing 93% of total releases for metals of arsenic, cadmium, lead, nickel and mercury from 1988 levels.
Dichloromethane
The dichloromethane P2 notice applied to owners of facilities involved in certain activities and that used 1000 kg or more of dichloromethane per year.
Objective: Reduce aggregate dichloromethane releases by 85% from the 1995 base year levels by January 1, 2007. Note that 5 sectors had different targets specific to each sector.
Results: The notice has mostly been successful. Aggregate releases were reduced by 93% (-842 642 kg). Although the overall objective was achieved, 3 of 5 industry sectors did not achieve their individual objectives.
Inorganic chloramines and chlorinated wastewater effluents
The inorganic chloramines and chlorinated wastewater effluents P2 notice applied to owners of wastewater systems that released effluents to surface water and where the concentration of total residual chlorine in the effluent was greater than 0.02 mg/L.
Objective: Achieve and maintain a concentration of total residual chlorine that is less than or equal to 0.02 mg/L in effluent released to surface water by December 15, 2009.
Results: The notice has mostly been successful. 80% of facilities met the objective. Residual chlorine concentration reduced by 85%. A third of facilities reported a 100% reduction in total residual chlorine. Even though the overall objective was met for this notice, some facilities either needed more time to implement, upgrade or build new wastewater treatment systems or they did not implement their P2 plan. Facilities that were subject to this notice are now subject to the Wastewater Systems Effluent Regulations.
Mercury releases from mercury switches in end-of-life vehicles
The mercury releases from mercury switches in end-of-life vehicles P2 notice applied to manufacturers of vehicles that contained mercury switches and owners of steel mill that processed end-of-life vehicles or steel scrap from end-of-life vehicles.
Objective: Reduce releases of mercury to the environment through participation by vehicle manufacturers and steel mills in a mercury switch management program. Ultimate objective: achieve an annual mercury switch capture rate of 90% within the first 4 years of participation in program.
Results: The notice has somewhat been successful even though the ultimate objective of achieving a capture rate of 90% within the first 4 years of the program has not been achieved. Results demonstrate that all the vehicle manufacturers and steel mills subject to the notice participated in the mercury switch management program. A total of 413 328 mercury switches were collected and reported under the P2 notice. The Switch Out program expanded nationally and switches are still being collected.
Nonylphenol and its ethoxylates (NP/NPEs) contained in products
The NP/NPEs contained in products P2 notice applied to owners of facilities that manufactured or imported soap and cleaning products, processing aids used in the textile wet processing, or pulp and paper processing aids.
Objective: Reduction of NP/NPEs in soap and cleaning products, processing aids used in textile wet processing, and pulp and paper processing aids manufactured in or imported into Canada:
- Phase 1: 50 % reduction from base year of the total mass (used or imported annually)
- Phase 2: 95% reduction from base year levels of the total mass (used or imported annually)
Results: The notice has been successful. Overall reduction of 96% in NP/NPEs used to manufacture products or imported in products. The following is a breakdown of the results:
- manufacture reduced by 96% (2 014 000 kg)
- import reduced by 96% (823 000 kg)
Polyurethane and other foam sector (except polystyrene) in respect of toluene diisocyanates (TDIs)
The TDI P2 notice applied to owners of facilities in the polyurethane and other foam sector that purchased, imported or used 100 kg or more of TDIs per year.
Objective: Reduce human exposure to TDIs through the reduction of industrial TDI emissions to the environment to the greatest extent practicable, using best available techniques economically achievable.
Results: The notice has been successful. Results demonstrate that all facilities met the objective. Overall actual on-site releases of TDIs to air were reduced by 55% (-118 kg/year). The average predicted concentration of TDIs at the fence line was reduced by 94% for the 3 facilities that were above the concentration target of 0.2 µg/m3 (reduced from 0.804 to 0.0472 µg/m3).
Textile mills that use wet processing (nonylphenol (NP) and its ethoxylates (NPEs))
The NP and NPEs P2 notice applied to owners of mills that manufacture textiles using wet processing, NP and its NPEs, and discharged their effluents with a daily flow greater than 30 cubic metres to an off-site wastewater treatment facility.
Objective: For NP/NPEs used in textile wet processing, reduce the annual use by at least 97% on a mass basis relative to annual use for the base year. For textile mill effluents, achieve and maintain through means other than dilution, a maximum acute toxicity of 13% IC50 (50 percent inhibiting concentration) for effluents discharged to an off-site wastewater treatment facility no later than 2009.
Results: The notice has somewhat been successful even though the objective for textile mill effluents was not achieved. Use of NP/NPEs was reduced by 99.99% (207 049 kg). Effluent toxicity target was met or partially met by 92% of active mills. The government of Canada continues to monitor NP/NPEs for increases in use quantities and levels in the environment to determine the need to develop further measures.
Wood preservation facilities (specified toxic substances)
The wood preservation facilities P2 notice applied to 5 facilities that used wood preservatives containing toxic substances as specified in the notice.
Objective: Reduce the release of targeted toxic substances (see Annex 1) during wood preservation processes to the lowest achievable levels by the application of or by achieving equivalence with best management practices.
Results: The notice has been successful. Although compliance with the P2 notice was difficult to achieve, 3 facilities eventually met their objectives. The other 2 facilities closed. Note that there were no reductions targets for this P2 notice.
Contact us
Regulatory Innovation and Management Systems
Environment and Climate Change Canada
351 St-Joseph Boulevard
Gatineau QC K1A 0H3
Email: planp2-p2plan@ec.gc.ca