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Iron, steel and ilmenite: Instructions for completing the schedules

Notice reference code: P2STEEL

Note: This document is intended to provide guidance only. It does not in any way supersede or modify the Canadian Environmental Protection Act, 1999 (CEPA 1999) or any Notice issued by the Minister of Environment under Section 56 of the Act requiring the preparation and implementation of a pollution prevention (P2) plan. In the event of an inconsistency between this document and CEPA 1999 or the P2 Notice issued by the Minister and published in the Canada Gazette, the Act and the P2 Notice prevail.

A. General instructions

These instructions are designed to accompany the notice requiring the preparation and implementation of pollution prevention plans in respect of specified toxic substances released from the Iron, steel and ilmenite sector, referred to as "the notice" throughout this document. For additional information please see section J. "Useful links" at the end of this document.

Certain forms must be submitted to the Minister of the Environment by the deadlines specified in the notice. These forms are:

Online reporting

Forms referred to in the notice (schedules 1 to 5) should be filled out electronically using the Environment and Climate Change Canada’s single window information manager (SWIM).

For guidance on how to access SWIM and on submitting schedules electronically, please refer to the following:

Important!

Your reporting requirements are not considered complete until Environment and Climate Change Canada receives your certified schedule through the CEPA pollution prevention planning online reporting tool. Once you have successfully submitted your schedule, an email confirmation message will be sent to person submitting the schedule via the SWIM account.

Amendments

Amendments to a previously submitted schedule should be filled out electronically using the CEPA pollution prevention planning online reporting tool where you initially entered your schedule.

Once you are in the reporting dashboard, a list of all your submitted schedules will appear in the reports section at the bottom of the screen. Select the schedule that you would like to amend and click on the pencil at the end of the line to edit your schedule. You will then be asked to specify the part(s) of the schedule that you are amending as well as the reason(s). After you have updated the relevant parts of your schedule, you will need to resubmit your schedule by going into the certification page and clicking the proceed to submit and submit buttons. 

Public disclosure of information

For all pollution prevention planning notices, the submitted schedules 1, 4 and 5, and amendments to such schedules (where applicable) will be posted on the P2 planning section of the government of Canada’s website. (See related section I. Confidential business information).

Information within the certification, general contact and technical contact sections will not be made publicly available.

As much of the information required in the schedules 1, 4 and 5 is common or similar, these instructions provide part-by-part rather than form-by-form guidance. The beginning of each section of these instructions outlines those schedules to which the information in that part of the schedule applies.

B. Contact information

The information described in this part will be collected when you access SWIM for the first time. Your contact information will be transferred from SWIM into your schedule  when you start reporting. However, once you are in your schedule, you will have the opportunity to update your contact information, if it has changed, and then save it into SWIM by choosing the save to SWIM button at the bottom of the screen.

Contact information

Company name

Enter the company name. If you own or operate more than one reporting facility, please ensure that the same name is used consistently for all facilities.

Canadian federal business number

Enter the canadian dederal business number provided by the Canada Revenue Agency

Facility nameFootnote1

Enter the name of the facility. If the company name alone completely identifies the facility, reenter it. If you own or operate more than one facility that is subject to the notice, please ensure you specify the unique name for that facility and file a separate schedule for each individual facility.

Physical address of facility, city, province/territory, postal code

Enter the street name and number, street type, street direction, and other identifiers such as unit number, suite number or building designation (for example, building A). For rural addresses, where a street address is not available, enter the lot and concession numbers. Enter the name of the city, town, village, district or township, the province or territory, the postal code and country where the facility is located. Because this is a location identifier, do not use a post office box or mailing address.

Telephone number (with area code)

Enter a telephone number for the facility.

E-mail address

Enter an e-mail address for the facility.

Mailing address of facility, city, province/territory, postal code

A checkbox will be provided if the physical address of the facility is the same as the mailing address. If the facility’s mailing address is different from the facility’s street address, enter the post office box or mailing address information, as well as the name of the city, town, village, district or township, the province or territory, the postal code and country in the appropriate fields.

National pollutant release inventory identification (ID): optional

Facilities that submit a national pollutant release inventory (NPRI) report are assigned a permanent NPRI identification (ID) number. If this facility has an NPRI ID number, enter it here. The NPRI ID is specific to the facility and does not change, even if the ownership of the facility has changed. If you do not have an NPRI ID number, leave this field blank.

North american industry classification system (NAICS) code: optional

Enter the six-digit NAICS code for this facility. Statistics Canada provides complete details of NAICS Canada on its website.

Facility technical contact

Enter the name, position\job title, telephone number (with area code) and email of the facility’s technical contact. If available, enter the facsimile number (with the area code) of the facility’s technical contact. It is recommended that the technical contact be a representative who can be contacted by Environment and Climate Change Canada for clarification of information submitted in the schedule(s). This person should be familiar with and be able to answer questions about the information provided. The technical contact will receive all information, mailings and inquiries from Environment and Climate Change Canada. The name and contact information for the technical contact will not be posted electronically.

General contact information

A checkbox will be provided if the general contact information is the same as the facility technical contact, you will not need to reenter the information. Please enter the name of a general contact name and information. This information could be used by Environment and Climate Change Canada to correspond with a consultant or association that has filled your schedule on your behalf. This information will not be posted online.

For schedule 1 only: Use of plans prepared or implemented for another purpose

A pollution prevention plan prepared or implemented for purposes other than to comply with this notice may be used as long as it fulfills all the requirements of this notice. If the existing plan does not meet all the requirements, it can either be updated so that it meets the requirements or a new pollution prevention plan that meets the requirements can be prepared and implemented.

Indicate if you are satisfying the requirements of this notice using a pollution prevention plan previously prepared voluntarily or to comply with other legal requirements, such as for another government or another Act of Parliament. If yes, identify the legal requirement(s). Examples of other legal requirements for which a pollution prevention plan may have been prepared are municipal by-laws, provincial regulations, court orders and EPAM (environmental protection alternative measures).

C. Facility and activity information

The information described in this part is collected in schedules 1, 4 and 5.

Note a): Reporting period

Each schedule requires reporting of data for a full calendar year (January 1 to December 31).

Reference is made to different reporting years throughout these instructions:

  1. The preparation year refers to January 1 to December 31, 2017. When you are completing a schedule 1, the data you are reporting corresponds to the preparation year.

  2. The reporting year refers to the previous calendar year for which you are reporting the interim progress reports (schedule 4). When you are completing schedule 4, the data you are reporting corresponds to the reporting year for either the interim progress report no.1 or any subsequent interim progress report (refer to the table below).

  3. The implementation year refers to January 1 to December 31, 2027. When you are completing schedule 5, the data you are reporting corresponds to the implementation year.

Reporting deadlines
Interim progress report (schedule 4) Reporting period Reporting year Submission deadline
No. 1 Jan. 1 to Dec. 31, 2018 2018 June 1, 2019
No. 2 Jan. 1 to Dec. 31, 2019 2019 June 1, 2020
No. 3 Jan. 1 to Dec. 31, 2020 2020 June 1, 2021
No. 4 Jan. 1 to Dec. 31, 2021 2021 June 1, 2022
No. 5 Jan. 1 to Dec. 31, 2022 2022 June 1, 2023
No. 6 Jan. 1 to Dec. 31, 2023 2023 June 1, 2024
No. 7 Jan. 1 to Dec. 31, 2024 2024 June 1, 2025
No. 8 Jan. 1 to Dec. 31, 2025 2025 June 1, 2026
No. 9 Jan. 1 to Dec. 31, 2026 2026 June 1, 2027

If you became subject after the date of publication of the notice or have applied for and received a time extension that subsequently affects the year for which you must report, indicate the new year for which you are reporting. All references to the calendar year in the schedules correspond to the new year that you have identified.

Note b): On-site emissions and total releases

This note applies to the 2 following sub-sections: for each activity and for each type of fuel, describe the quantification method used to determine the emissions such as description of the method used, type of equipment used, frequency of testing, period of time for testing, accuracy of method, reference conditions, assumptions, emission factors and conversion factors used, equations used and other relevant information. Please provide all the necessary information so that results can be re-produced by Environment and Climate Change Canada during internal review.

On-site emissions

Report the quantities of each type of release of the substances to air, by sources and by fuel, indicating all the necessary information used to derive those values. The sum of these releases to obtain the total amount released to air on-site from this facility will be calculated automatically.

Total releases

The sum of all on-site releases of NOx will be automatically calculated from each medium reported to obtain the total amount released on-site from this facility in the reporting year(s).

Additional information on intensity

For integrated mills

For mini-mills

For ilmenite smelting facility

D. Actions and results

The instructions for this part are designed to provide direction for completing all three forms (schedule 1, 4 and 5).  Headings however may be slightly different from schedules  to reflect the type of data required in that schedule (e.g., anticipated results, results achieved to date and results achieved).

Actions

This part summarizes the actions that you plan to take or have already taken in implementing the pollution prevention plan in order to work towards achieving the risk management objective as specified in the Canada Gazette notice. Please add and complete for each action that is in your plan. Actions reported in schedule 1 will be carried over to schedule 4 and 5 where you will be asked for updates or have the opportunity to report new actions. The following is a description of the information required in each field.

Describe the current status of the action taken to date in implementing the pollution prevention plan. That is, indicate if the action is:

If the action is "discontinued", please provide the reason why you will no longer be carrying out this action for the activity. (Note: the "discontinued" option applies to schedule 4 and 5 only).

Describe the action that you plan to implement or have already implemented in the pollution prevention plan. A minimum of one action must be reported for each substance (NOx and SO2 for integrated mills; NOx for mini-mills and SO2 for ilmenite smelting) to demonstrate how the target will be met and maintained. If the facility is already meeting the target, please explain how conformance with the target will be maintained.

You must select at least one type of pollution prevention or environmental protection method. If you select "other", please specify.

Types of pollution prevention methods

If the action previously identified utilizes a pollution prevention (P2) method, indicate the type of method used, choosing from the list provided. More than one P2 method can be used. Alternatively, no P2 method may be applicable in which case, you must identify an environmental protection method. P2 methods are described in the box below.

Materials or feedstock substitution

Materials or feedstock substitution deals with the substances and products you use. It involves replacing them with more environmentally friendly alternatives. Materials or feedstock substitution completely eliminates the use of a given substance or product.

Product design or reformulation

Product design or reformulation deals with improving the overall environmental impact of your product. It involves looking at the whole life cycle of your product (from cradle to grave) and then either designing a new product or reformulating an existing one to prevent pollution.

Equipment or process modifications

Equipment or process modification deals with how you make whatever it is you make or do whatever it is you do, whether it be manufacturing chemicals or simply running a household. It involves using new equipment or processes, or altering existing equipment or processes to:

  • improve efficiency
  • reduce or eliminate pollution
  • reduce material, water or energy use
Spill and leak prevention
Spill or leak prevention deals with making sure you do not pollute accidentally. It involves trying to limit spills and leaks from happening in the first place, and having measures in place to limit the damage if there is a spill or leak.
On-site reuse, recycling or recovery

Sometimes waste is unavoidable. On-site reuse, recycling or recovery (ORRR) deals with what you do with your waste and waste by-products. It involves using your waste and waste by-products instead of just throwing them away (often at a cost) or otherwise losing them.

Note: Reuse, recycling or recovery that takes place off site is not considered P2. While collecting your recyclable materials and having them recycled (by the city or another recycling company) is definitely a good thing to do, it is not P2 because it transfers your pollutants elsewhere.

Inventory management or purchasing techniques
Inventory management or purchasing techniques (IMPT) deals with how you store your goods/materials and how you buy your goods/materials. It involves having a strategy in place to reduce the amount of stock you have to throw out because it is expired, damaged or no longer needed. It also involves having a strategy in place to ensure you take the environment into account when buying goods.
Good operating practices or training
Good operating practices or training deals with the human element of your operations. It does not matter how state-of-the-art your equipment is if you or your employees do not know how to use it properly or in the most efficient manner. It involves using best practices and training to minimize waste and increase efficiency.
Other (specify)
Other methods that result in preventing or avoiding the creation of pollutants and waste. If you select other, please specify.

Please visit the pollution prevention techniques web page for more information and examples of these P2 methods.

Types of environmental protection methods

If the action identified utilizes an environmental protection method rather than a P2 method, indicate the type of method used, choosing from the list provided. More than one environmental protection method can be used to describe the action. Alternatively, no environmental protection method may be applicable. Descriptions of the types of environmental protection methods are listed in the box below.

Energy recovery
Using a waste with sufficient energy content as a fuel for energy recovery to offset the need for additional energy (for example, recovery of methane from landfills).
Off-site recycling
Recycling of materials at a place outside the property boundaries of where an activity has taken place (for example, transfer of paper products to another facility for recycling into new paper products).
Incineration with energy recovery
Thermal treatment of wastes and recovery and use of the resulting energy to offset the need for additional energy (for example, incinerating waste and using the resulting heat to heat building air and/or water).
Waste treatment
Processing of waste to render it less harmful or harmless to the environment (for example, bio-oxidation, evaporation, precipitation, neutralization).
Pollution control
Addition of equipment to the end of a system to collect pollutants prior to their release into the environment (for example, addition of filters to collect dust prior to release).
Disposal
Final disposal in such a way as to cause the least amount of harm to the environment (for example, landfill of biodegradable materials, containment of wastes containing the substance).
Other (specify)
Other methods that result in environmental protection. If you select other, please specify.

Anticipated / achieved changes

Report the anticipated/achieved annual increase or decrease in the intensity of NOx, SO2 or other substance from this facility resulting from implementation of the action described. Note that predicting a quantitative change for some actions, such as employee training, may not be possible. In such cases, report whether the action anticipated/achieved an increase ("+") or decrease ("-") for the substance affected, without specifying the quantity.

Planned completion date

Provide the date on which the action is anticipated to be or was fully implemented.

Total results anticipated / to date / achieved

This part requires reporting results based on preparation year information.

Total changes must be reported in units specified and as a percentage using a negative sign ("-") before the reported total to denote a decrease or a positive sign ("+") to denote an increase.

E. Monitoring and reporting, risk management objectives and factors to consider

The information described in this section is collected in schedules 1, 4 and 5.

Monitoring and reporting

Describe the monitoring and reporting used to track progress in implementing the pollution prevention plan. This may include:

Risk management objective

The risk management objective is the desired environmental aim, goal or outcome to reduce the risk to the environment and human health. Environment and Climate Change Canada’s risk management objectives for the P2 plan are stated in section 4 of the notice as follows.

In schedule 1, 4 and 5, briefly describe how the pollution prevention plan will meet/has met the risk management objectives. If the plan does not meet the risk management objectives, explain why.

Factors to consider

The notice states the factors that you must consider while preparing and deciding which actions to take in your pollution prevention plan. You must report on the following factors to consider:

For integrated and mini-mills

Fill out the table on recommendations for fugitive VOCs. For each recommendation, specify if you considered it, if you implemented it and provide current status. Provide a description of the factors leading to a decision to not implement recommendations if this is the case.

If applicable, describe any additional details or changes in how these factors were taken into account, except those factors for which a waiver has been granted by the Minister of the Environment.

Refer to section G of these instructions for information on applying for a waiver of the requirement to consider a factor to consider.

F. Certification

The information described in this section is collected in all schedules.

Certification

If applicable, a comment box is provided to specify the parts that you requested confidentiality as well as the reasons for your request (for more information on confidentiality, refer to section I.).

All schedules submitted to Environment and Climate Change Canada must be certified by an appropriate authority, a duly authorized official, who will be required to verify that the information being reported is true, accurate, and complete. The name, title and email address of that person need to be provided before submission to Environment and Climate Change Canada.

A comment box is also provided for general comments.

G. Waiver of the requirement to consider a factor or factors

The information described in this section is collected in schedule 2. Information submitted in schedule 2 will not be made available to the public.

The notice states factors that you are to consider while developing and deciding which actions you anticipate taking in your pollution prevention plan. If you do not think it is reasonable or practicable to consider one or more of the factors specified in the notice, you may apply for a waiver of the requirement to consider factor(s). Such a request will only be considered if it is received on or before the deadline to prepare the plan as specified in the notice (or before the expiry of any extended period), not the deadline to submit the schedule 1.  Persons submitting requests for waivers of the requirement to consider a factor will receive a written response informing them of the Minister’s decision to grant or deny the request.  Unless you submit schedule 2 and are granted a written waiver by the Minister of the Environment and Climate Change, you must consider all factors identified in the notice.

Factor(s) for which a waiver is being requested

Identify exactly those factors specified in the notice for which you are requesting a waiver for the requirement to consider.

Rationale for request

Explain the reason(s) that you are applying for a waiver (for example, why you believe the factor(s) specified in the notice are not reasonable or practicable to consider).

Explain how the outcome of your pollution prevention plan will be affected if the factor(s) for which you are requesting a waiver of the requirement to consider is(are) not taken into account when preparing your pollution prevention plan.

You have the option to identify other alternative factors, if any, that were not specified in the notice that you propose to consider in your plan.

H. Time extension to prepare or implement a pollution prevention plan

The information described in this section is collected in schedule 3.  Information submitted in schedule 3 will not be made available to the public.

The Canada Gazette notice states the time period within which your pollution prevention plan must be prepared, implementation begun, and implementedFootnote2.

If you do not think it is reasonable or practicable to prepare or implement your pollution prevention plan in the time allotted, you may request an extension of the time period specified in the notice using schedule 3.

Such a request will only be considered if it is received on or before the deadline to prepare (or implement) the plan as published in the notice (or before the expiry of any extended period), not the deadline to submit the schedule 1 (or schedule 5). Persons submitting such requests will receive a written response informing them of the Minister’s decision to grant or deny the request.

Note that the Minister of the Environment and Climate Change publishes in the Canada Gazette the name of any person for whom an extension is granted, the duration of the period of the extension, and whether the extension is for the preparation or implementation of the plan.

Request for time extension

Indicate which time period you are requesting to be extended (period to prepare a pollution prevention plan, or period to implement a pollution prevention plan). Specify the new date to which you wish the time period to be extended.

Rationale for request

Explain the reasons that you are applying for an extension (for example, why you believe the time period specified in the notice is not reasonable or practicable). The Minister of the Environment and Climate Change will evaluate the request for a time extension based on the reasons or rationale provided in the request.

I. Confidential business information

All persons submitting information to the Minister of the Environment Climate Change are entitled to submit a request under section 313 of CEPA 1999 that some or all of the information reported in the schedule(s) be treated as confidential.

Please note that facility technical contact and general contact information as well as the certification information will not be publicly posted.

To request that information be treated as confidential, click on the padlock icon displayed beside the appropriate part(s) of the schedule. Once clicked, the padlock icon will appear closed. At the end of the schedule, at the beginning of the certification page, you will be required to provide a justification for each part that you are requesting confidentiality.

All such requests will be reviewed under the provisions of sections 315 to 321 of CEPA 1999 and section 20 of the Access to Information Act. Persons submitting such requests will receive a response letter from ECCC either asking for additional information to evaluate the request or to confirm the acceptance or denial of the request. No information that is requested to be kept confidential will be made available to the public until a decision has been made by ECCC and a response letter is sent to the reporter.

For more information on the type of information that might be considered confidential business information, please refer to section 20 of the Access to Information Act.

J. Useful links

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