Siloxane D4: P2 notice legal obligations

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Information regarding the notice requiring the preparation and implementation of pollution prevention plans in respect to Cyclotetrasiloxane, octamethyl (siloxane D4) in industrial effluents

What is Siloxane D4?

Siloxane D4 (D4) refers to cyclotetrasiloxane, octamethyl- [Chemical Abstracts Service (CAS)Footnote 1 Registry Number 556-67-2]. This industrial chemical is currently imported into Canada and is mainly used in the manufacture of silicone polymers and copolymers. D4 is also used in personal care products and can be found in a variety of other products including defoamers, lubricants, cleaning products, adhesives, sealants and coatings.

Why do we need to manage D4?

Environment and Climate Change Canada and Health Canada assessed D4 and concluded that this substance is entering or may be entering the environment in a quantity or concentration or under conditions that have or may have an immediate or long-term harmful effect on the environment or its biological diversity. The assessment report also concluded that D4 meets the criteria of persistence in the environment as set out in the Persistence and Bioaccumulation Regulations. D4 was assessed for all environmental media including air, water and soil, and it was determined that the presence of this substance in the aquatic environment is a source of concern. 

In order to manage the risk posed by D4, Environment and Climate Change Canada published a Pollution Prevention (P2) Planning Notice to prevent or minimize the releases of D4 to the aquatic environment from manufacturers and industrial users of D4 in the Canada Gazette, Part I, on June 2, 2012.

Are you subject to the P2D4 Notice?

If yes, some legal requirements may apply to you. The flowchart below is intended to help you determine whether you are subject to the P2D4 Notice.

Flow chart. See description below.
Are you subject to the P2D4 Notice? Description

Did a facility that you own or operate manufacture or use 100 kg or more of D4 (as a pure substance or in a mixture) during the 2011 calendar year or during any other subsequent calendar year?
[Paragraph 2(1)(a) of the P2D4 Notice]

  • No: If the answer is negative, your facility is not subject to the P2D4 Notice
  • Yes: If the answer is positive, the following question needs to be answered

As a result of manufacture or use of D4 or a mixture containing D4, did your facility release an effluent containing D4 at any final discharge point? [Paragraph 2(1)(b) of the P2D4 Notice]

  • No: If the answer is negative, your facility is not subject to the P2D4 Notice
  • Yes: If the answer is positive, the following question needs to be answered

Does your facility:

  • Release, at any time, an effluent containing D4 in a concentration that is less than or equal to 17.3 µg/L at all final discharge points? [Paragraph 2(3)(a) of the P2D4 Notice], or
  • Use D4 exclusively as contained in a mixture in a concentration of less than 1%? [Paragraph 2(3)(b) of the P2D4 Notice], or
  • Use D4 exclusively as contained in a solid material? [Paragraph 2(3)(b) of the P2D4 Notice]?
  • No: If the answer is negative, your facility is subject to the P2D4 Notice and its requirements
  • Yes: If the answer is positive, your facility is not subject to the P2D4 Notice

For more information, please see section 2 of the P2D4 Notice.

What are the requirements of the P2D4 Notice?

The P2D4 Notice was published in the Canada Gazette,Part I, on June 2, 2012. The P2D4 Notice requires all persons subject to the Notice to prepare and implement a pollution prevention plan to address D4 releases in industrial effluent and meet the requirements of the P2D4 Notice. Outlined below are the key milestones for the preparation and implementation of P2 plans for D4.

Key milestones for the preparation and implementation of P2 plans for D4
Task DeadlineFootnote a
Prepare a pollution prevention plan, ensure that the plan addresses all the factors to consider and initiate implementation of the plan June 1, 2013
Submit Schedule 1: Declaration that a Pollution Prevention Plan Has Been Prepared and Is Being Implemented July 1, 2013
Submit Schedule 4: Interim Progress Report 1 July 1, 2014
Submit Schedule 4: Interim Progress Report 2 July 1, 2015
Submit Schedule 4: Interim Progress Report 3 July 1, 2016
Complete implementation of the pollution prevention plan June 1, 2017
Submit Schedule 5: Declaration that a Pollution Prevention Plan Has Been Implemented July 1, 2017
Keep a copy of the pollution prevention plan on site Ongoing

How to report?

If you are subject to the P2D4 Notice, you must fill out the required forms (schedules). These forms can be filled out online using the P2 Planning Online Reporting Tool.

If the Notice does not apply to you, please send an email to ec.planp2-p2plan.ec@canada.ca for a Notification of non-engagement form.

How to stay informed?

Additional information and guidance on pollution prevention and preparing P2 plans can be found on the Pollution Prevention Planning section of Environment and Climate Change Canada's website and the Canadian Pollution Prevention Information Clearinghouse.

For questions regarding P2 plans in general or reporting, please contact the Innovative Measures Section of Environment and Climate Change Canada by email ec.planp2-p2plan.ec@canada.ca at or by phone at 1-844-580-3637.

For specific questions about the P2D4 Notice, please contact the Chemical Production Division of Environment and Climate Change Canada by email at ec.pgpc-dppc-cmp-cpd.ec@canada.ca or by phone at 819-938-4487.

Disclaimer:

This document is issued for guidance on the Notice requiring the preparation and implementation of pollution prevention plans with respect to cyclotetrasiloxane, octamethyl- (Siloxane D4) in industrial effluents (P2D4Notice), and is intended to be complementary to the P2D4 Notice.

If there is any discrepancy between the information contained in this document and the Canadian Environmental Protection Act, 1999 (Act) or the P2D4 Notice, the Act and the P2D4 Notice will prevail.

 

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