Pollution prevention planning in the Canadian Environmental Protection Act
Pollution Prevention Planning in Part 4 of the Canadian Environmental Protection Act, 1999
Part 4 of the Canadian Environmental Protection Act, 1999 (CEPA 1999) gives the Minister of the Environment the authority to require the preparation and implementation of Pollution Prevention plans (P2 Plans) to manage substances that have been added to the list of Toxic Substances in CEPA 1999.
What is Pollution Prevention?
CEPA 1999 defines Pollution Prevention as "the use of processes, materials, products, substances or energy that avoid or minimize the creation of pollutants and waste, and reduce the overall risk to the environment or human health."
What is a Pollution Prevention plan?
A pollution prevention plan (P2 Plan) documents how a facility will prevent or minimize the creation of pollutants and waste. It identifies cost-effective options and shows where investment in pollution prevention would lead to cost savings.
Key elements within a P2 Planning Notice
A P2 Planning Notice specifies the substance or group of substances to be covered in the P2 Plan, the persons or class of persons who are required to prepare and implement a plan, the activities that will be considered, and the deadlines for preparing and implementing the plan.
The P2 Planning Notice also outlines the factors that must be considered when preparing and implementing the plan. Factors to consider are issues or activities that must be addressed in preparing the P2 plan. They may include current best management practices, P2 techniques and available technologies. Also included as a factor to consider is the risk management objective to manage the environmental and human health risks posed by the substance.
Environment Canada may require P2 Plans under Part 4:
- To generate action that will contribute to the effectiveness and efficiency of the management of toxic substances listed under the Act and reduce overall risk to the environment and human health;
- To provide an opportunity for early action;
- To provide opportunities to develop and implement situation-specific solutions; and
- To encourage Pollution Prevention.
How are P2 Planning Notices developed?
The Minister of the Environment invokes the requirement to prepare and implement P2 Plans by publishing Notices in the Canada Gazette, Part I. In most cases, a working document, or draft of the Notice is developed by Environment Canada and is made available to stakeholders for feedback. After the feedback is received, the working document is updated and published in Part I of the Canada Gazette as a Proposed Notice. The Proposed Notice is subject to a 60 day public comment period. It is then updated and published in the Canada Gazette, Part I as a final Notice. All Notices open to public comment are posted on the CEPA Environmental Registry.
Complying with a P2 Planning Notice
In general, persons subject to a Notice are required to:
- prepare a P2 Plan;
- ensure that the "factors to consider" are adequately addressed in preparing the P2 Plan;
- submit a Declaration of Preparation;
- implement the P2 Plan;
- submit a Declaration of Implementation;
- submit Interim Progress Reports and amendments as required;
- respect all the deadlines published in the Notice;
- ensure that the information submitted is consistent with the P2 Plan; and
- keep a copy of the P2 Plan on-site
What information must be submitted?
Those subject to a Notice are not required to submit the P2 Plan itself, unless officially requested to do so. However, those subject to a P2 Planning Notice must submit two summary forms, the Declaration of Preparation and the Declaration of Implementation. In some cases Interim Progress Reports may be requested.
Declarations and Interim Progress Reports are filed online and are publicly posted on Environment Canada's Pollution Prevention Planning website.
Want to know more?
Here are some additional sources of information on P2 planning:
For further information, please contact
Innovative Measures Section
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