Halocarbons: pollution prevention notice performance report

This report provides a summary of the effectiveness of the halocarbons pollution prevention planning notice (P2 notice) in achieving its objective from May 2016 to May 2019.

This P2 notice applies to companies who either:

The risk management objective of the halocarbons P2 notice is to manage halocarbon refrigerants in an environmentally sound manner to minimize the release of halocarbons into the environment. Certain halocarbons are damaging to the earth’s ozone layer and may have a high global warming potential.

Summary

As of May 1, 2019, all of the 9 companies that became subject to the P2 notice when it was published in May 2016 reported having successfully implemented their pollution prevention plan. All companies submitted their declarations on time. Another company that became subject to the P2 notice in October 2018 has submitted their Declaration of preparation in accordance with the requirements of the notice and is currently implementing its P2 plan. This performance report is a summary of information provided by the companies subject to the P2 notice.

Since 2016, this P2 notice has prevented the release of more than 585 tonnes of halocarbons into the environment. The P2 notice remains in effect for halocarbons and will apply to any new companies that undertake the activities captured by the P2 notice.

Actions taken to achieve the objective

To minimize the release of halocarbon refrigerants, companies joined or developed (or are developing, in the case of the 10th company) a stewardship program to collect halocarbons after their use in the stationary refrigeration and air conditioning sector.

8 companies are members of Refrigerant Management Canada (RMC). These are listed below:

RMC established a stewardship program for refrigerants in 2000. This program is now used by industry as a means to comply with the requirements of this P2 notice. Their results regarding the quantities recovered and success of the P2 notice are presented together.

Another company subject to the P2 notice, United Refrigeration of Canada Ltd, has a separate stewardship program to comply with the P2 notice. Their system is called the United Refrigeration of Canada Recovered Refrigerant Management Program, and was developed and implemented in 1991.

AGas Canada is a newly established company that became subject to the P2 notice for halocarbons in October 2018. They have developed their P2 plan and are currently in the implementation phase. Their program is called AGas Canada P2 Plan Refrigerant Management Program.

Overall results

Because the results are combined for the RMC participants, and confidential for United Refrigerants of Canada Ltd, each company’s exact amount of refrigerants recovered for reclamation or destruction cannot be disclosed to protect competitiveness. However, since the coming into force of the P2 notice, the stewardship programs together have prevented the release of more than 585 tonnes of chlorofluorocarbons (CFC), hydrochlorofluorocarbons (HCFC) and hydrofluorocarbons (HFC) refrigerants to the atmosphere. This prevented further damage to the earth’s ozone layer, and avoided the release of highly potent greenhouse gases.

AGas Canada, a new importer of halocarbons as of 2018, submitted its Declaration of preparation in May, 2019, after becoming subject to the P2 notice in 2018. More information is expected after the implementation of their plan, as per the P2 notice requirements.

The declarations from the companies are available on the search tool below by selecting “Halocarbons” in the “P2 Code” field:

Pollution prevention planning reports

Factors to consider

There were 5 main factors to consider in developing the pollution prevention plan:

  1. Halocarbons covered: halocarbons covered under this P2 notice include chlorofluorocarbons (CFCs), hydrochlorofluorocarbons (HCFCs) and hydrofluorocarbons (HFCs)
  2. Risk management objective: the objective is to manage halocarbon refrigerants in an environmentally sound manner to minimize their release into the environment
  3. Priority to pollution prevention: in preparing the plan, priority must be given to pollution prevention activities
  4. Stewardship program: joining or developing a stewardship program which includes 12 characteristics (detailed below, from (a) to (l))
  5. Funding: establishing and maintaining funding to support the stewardship program

The 10 companies demonstrated that all the main factors were taken into consideration when developing and implementing P2 plans.

Stewardship program information

The establishment of a stewardship program is the most complex factor to consider and forms the core of the plans that were developed. The 12 characteristics described in the P2 notice are reported on below for each program.

Managing halocarbon refrigerants (characteristic (a) in the P2 notice)

The P2 notice requires persons subject to consider managing the halocarbon refrigerants to prevent the immediate or long-term harmful effects or dangers to the environment or to human health that would result from their release into the environment

The RMC stewardship program, the United Refrigeration of Canada Recovered Refrigerant Management Program and the AGas Canada P2 Plan Refrigerant Management Program all aim to avoid releases of halocarbon refrigerants to the atmosphere throughout the lifecycle of the refrigerants.

Both RMC and the United Refrigeration of Canada Recovered Refrigerant Management Program require the technicians to follow certain procedures for the handling, collection and transport of refrigerants to avoid emissions escaping into the atmosphere. They also offer training and literature resources for wholesalers, contractors and technicians in the refrigeration and air conditioning sector.

Establishing acceptance criteria and accepting halocarbon refrigerants (characteristics (b)(c)(d) in the P2 notice)

The P2 notice requires persons subject to consider:

Refrigerant Management Canada

Recovered halocarbons must meet certain criteria to be accepted into the RMC stewardship program for reclamation or destruction (for example, the proportion of refrigerant contents, the quantity of impurities or hydrocarbons, etc.). All CFCs, HCFCs and HFCs from commercial refrigeration and stationary air-conditioning systems that meet these criteria may be accepted by the program. The program also accepts refrigerants from other sectors for a fee to cover additional costs, which goes beyond the obligations under the P2 notice, as long as the maximum impurity thresholds are not exceeded. The RMC stewardship program is available everywhere in Canada. The P2 notice does not apply to hydrocarbon refrigerants which are highly flammable. However, the program is currently evaluating the possibility of accepting hydrocarbon refrigerants to ensure they are not vented to the atmosphere. Different procedures will be needed to ensure safety during handling of hydrocarbons due to their flammability.

United Refrigeration of Canada Recovered Refrigerant Management Program

This program also accepts HCFCs and HFCs for reclamation, and CFCs for destruction. There are limits for the dye, oil, water and hydrocarbons contents, as well as limits for pH. The acceptance criteria determine if a refrigerant can be recovered or if it must be destroyed or returned to the customer. The program is available through a number of collection points in the Province of Ontario, where United Refrigeration of Canada Ltd operates.

AGas Canada Pollution Prevention Plan Refrigerant Management Program

AGas uses separation technologies that will allow them to accept a broad range of mixed refrigerants and return them to usable blends. This separation technology is designed to enable the recovery of refrigerants that contain various amounts of oil, water, acids and dyes. Agas stated that they use a technology approved by the Technology and Economic Assessment Panel of the Montreal Protocol on substances that deplete the ozone layer for destruction of halocarbons.

Accepting halocarbons refrigerants within 12 months of becoming subject to the notice (characteristic (e) in the P2 notice)

The P2 notice requires persons subject to consider accepting halocarbon refrigerants within 12 months of becoming subject to the notice.

Refrigerant Management Canada and United Refrigeration of Canada Recovered Refrigerant Management Program

Both RMC and the United Refrigeration of Canada Recovered Refrigerant Management Program were established before the publication of the P2 notice, in 2000 and 1991, respectively. These programs have been accepting halocarbon refrigerants since they were established, well in advance of the notice requirement to accept halocarbon refrigerants within 12 months of becoming subject to the notice.

AGas Canada Pollution Prevention Plan Refrigerant Management Program

AGas stated that it intends to accept refrigerant within timelines noted in the notice.

Providing access to collection facilities and collection services (characteristic (f) in the P2 notice)

The P2 notice requires persons subject to consider providing access to collection facilities and collection services for recovered halocarbon refrigerants in at least all the provinces and territories where the person or class of persons subject to this notice sells and/or distributes halocarbon refrigerants.

Refrigerant Management Canada

The RMC Program is available across Canada. Currently, there are facilities that are collection service providers for the RMC program: one located in Ontario and one in Nova Scotia. Both service providers offer transport of substances from all provinces and territories to these 2 facilities, where the refrigerants are managed.  

United Refrigeration of Canada Recovered Refrigerant Management Program

This program provides 14 collection locations in Ontario, the only province where they operate.

AGas Canada Pollution Prevention Plan Refrigerant Management Program

AGas reported that it offers a recovery network in the provinces where they operate.

Taking into account codes of practice (characteristic (g) in the P2 notice)

The P2 notice requires persons subject to consider taking into account and promoting the Environmental Code of Practice for Elimination of Fluorocarbon Emissions from refrigeration and Air Conditioning Systems (the Code of Practice).

Refrigerant Management Canada

All RMC Collection Service partners follow the Environmental code of practice for elimination of fluorocarbon emissions from refrigeration and air conditioning systems (the code of practice, published in April 2015 by the Government of Canada), as required by the RMC Guidelines and audit protocol:

Environmental code of practice for elimination of fluorocarbon emissions from refrigeration and air conditioning systems

United Refrigeration of Canada Recovered Refrigerant Management Program

This program promotes the code of practice. It is accessible from their website.

AGas Canada Pollution Prevention Plan Refrigerant Management Program

The code of practice is part of the AGas Canada P2 Plan Refrigerant Management Program pollution prevention documentation distributed within the company. AGas Canada promotes best practices when training their technicians and plant personnel.

Developing and implementing a communication and education plan (characteristic (h) in the P2 notice)

The P2 notice requires persons subject to consider developing and implementing a communication and education plan to increase awareness of the stewardship program among heating, ventilation and air conditioning and refrigeration contractors in Canada.

Refrigerant Management Canada

The communication strategy for RMC targets wholesalers and contractors. Messages through written documentation, webinars and tradeshow presence include facts about the risks related to leaks and venting of ozone-depleting substances and greenhouse gases to the atmosphere.

United Refrigeration of Canada Recovered Refrigerant Management Program

This program offers tools, literature and training regarding the management of refrigerants, and targets contractors more specifically.

AGas Canada Pollution Prevention Plan Refrigerant Management Program

AGas Canada is a member of the Heating, Refrigeration and Air Conditioning Institute of Canada. Once implemented, information about AGas Canada P2 Plan Refrigerant Management Program will be disseminated through participation in industry trade shows, trade training programs and trade press advertising.

Developing annual targets (characteristic (i) in the P2 notice)

The P2 notice requires persons subject to consider developing annual targets (for calendar years) for halocarbon refrigerants recovered in Canada that are accepted in the stewardship program in order to be reclaimed or destroyed. Annual targets are established for 5-year periods.

Refrigerant Management Canada

RMC has developed annual targets based on the 16 years of data they have on volumes collected, destroyed and reclaimed. Industry trends were also considered.

United Refrigeration of Canada Recovered Refrigerant Management Program

Annual targets were developed for this program.

AGas Canada Pollution Prevention Plan Refrigerant Management Program

AGas Canada has developed annual targets for refrigerant recovery for their first 5 years of operations. These targets are based on their experience in other jurisdictions, their forecasted sales in Canada, and on industry norms for the percentage of refrigerant imports that are recovered and reclaimed in similar programs.

Conducting environmental compliance audits (characteristic (j) in the P2 notice)

The P2 notice requires persons subject to consider conducting an environmental compliance audit of the stewardship program’s operations in accordance with ISO 19011:2011 to verify conformity with national, provincial and local laws and regulations, and with the plan.

Refrigerant Management Canada

For RMC, an independent party audits collection service providers annually. The audit performed in 2018 confirmed that “the activities of both collection service providers were found to be generally in compliance with applicable regulatory and RMC criteria, with some deviations from these requirements”, and that “in general, staff at each facility has shown commitment in meeting regulatory obligations as well as RMC requirements.”

United Refrigeration of Canada Recovered Refrigerant Management Program

The independent party that was retained by United Refrigeration of Canada Ltd for auditing conducted the audit after one full year of operation of the stewardship program. United Refrigeration of Canada Ltd stated that the independent audit report attested that their pollution prevention plan meets regulatory requirements. The next audit is scheduled for 2021.

AGas Canada Pollution Prevention Plan Refrigerant Management Program

AGas reported that they will be operating their P2 plan to honor their environmental commitments and regulations but that a full ISO audit at this stage of the program was not deemed to be appropriate.

Publicly reporting operations and performance (characteristic (k) in the P2 notice)

The P2 notice requires persons subject to consider publicly reporting the stewardship program’s operations and performance on a yearly basis.

Refrigerant Management Canada

RMC publishes its reports each year. The reports contain the names of the companies that are part of the program, the annual targets, and the quantities of halocarbons recovered. The reports also contain information about communications and activities that took place in the preceding year, operational modifications and results from audits.

United Refrigeration of Canada Recovered Refrigerant Management Program

United Refrigeration of Canada Ltd publishes their reports on operations on their website. Information from third parties is however kept confidential. A statement that the audit concluded they met regulatory requirements is also published.

AGas Canada Pollution Prevention Plan Refrigerant Management Program

AGas Canada will publicly report results each year.

Performing a review of the stewardship program (characteristic (l) in P2 notice)

The P2 notice requires persons subject to consider performing an internal review of the stewardship program every 5 years to improve its performance.

Refrigerant Management Canada

The RMC program review is conducted collectively for the 8 companies that are part of it. Since the RMC was established in 2000, reviews of the program have been undertaken to improve all aspects of refrigerant management, and to ensure ability to respond to industry needs as well as regulations. Reviews will continue on an as needed basis.

United Refrigeration of Canada Recovered Refrigerant Management Program

For United Refrigeration of Canada Ltd, performance targets for the collection of refrigerants have been established. They will be reviewed every 5 years or sooner if needed.

AGas Canada Pollution Prevention Plan Refrigerant Management Program

AGas Canada will conduct a 5-year review of their program to evaluate program performance against their objectives, which are consistent with the risk management objectives of the P2 notice.

Funding

The P2 notice requires persons subject to consider establishing and maintaining funding that supports the stewardship program.

Refrigerant Management Canada

The RMC program is funded through levies, applied by weight of refrigerant, and depending on the type of refrigerant. The levies are remitted by refrigerant manufacturers, importers and reclaimers on sales of HCFCs and HFC refrigerants.

United Refrigeration of Canada Recovered Refrigerant Management Program

This program is funded from the normal costs of operation, including cylinder service fees and destruction charges.

AGas Canada Pollution Prevention Plan Refrigerant Management Program

The funding of the AGas Canada P2 Plan Refrigerant Management Program will be similar to RMC and the program will be funded from the start of operations in Canada.

Conclusion and next steps

The P2 notice for halocarbons plays an important role in the reduction of emissions of halocarbon refrigerants, including ozone-depleting substances and greenhouse gases, to the atmosphere. The Government of Canada will continue to inform stakeholders of their obligations under the P2 notice on an as-needed basis, including when new companies become subject to the P2 notice. The notice remains in effect, and will continue to apply to any company that imports or manufactures more than 100kg halocarbons in any calendar year for the refrigeration and air-conditioning sector (with a number of exclusions).

Environment and Climate Change Canada will continue to gather data and information on the management of halocarbons through the monitoring of the companies’ websites.

Background

Canada is a party to the Montreal Protocol on Substances that Deplete the Ozone Layer (the Montreal Protocol), which requires Parties to gradually phase-out production and consumption of ozone-depleting substances, such as CFCs and HCFCs, as well as reduce and eliminate trade in these substances. Canada also ratified the Kigali Amendment to the Montreal Protocol to phase-down HFCs (a potent greenhouse gas).

The P2 notice is a complementary instrument to the Ozone-depleting Substances and Halocarbon Alternatives Regulations to manage the risks associated with these substances. For more information on ozone-depleting substances, hydrofluorocarbons, or the Ozone-depleting Substances and Halocarbon Alternatives Regulations, see the following webpages:

The P2 notice does not apply if the substances are to be used entirely in mobile air conditioning systems or in domestic appliances, or if they are to be exported. Other exclusions may apply. More information is available in the following notice and its erratum:

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