Guide for sampling and analysis of bisphenol A (BPA) in industrial effluent: chapter 1

Chapter 1

1.0 Introduction

• 1.1 Purpose
• 1.2 Scope
• 1.3 Intended Users

Bisphenol A (BPA) is an industrial chemical used in a wide variety of applications, including the investment-casting industry, the manufacture of polycarbonates, and as a lining for food cans. BPA was officially added to the List of Toxic Substances (Schedule 1 of the Canadian Environmental Protection Act, 1999 [CEPA 1999]) in October 2010 (Environment Canada, 2010a).

On April 14, 2012, the Minister of the Environment published a Notice Requiring the Preparation and Implementation of Pollution Prevention Plans with Respect to Bisphenol A in Industrial Effluents under Part 4 of CEPA 1999 (Environment Canada 2010b).

This Pollution Prevention (P2) Planning Notice applies to any person or class of persons who owns or operates an industrial facility that:

1. Manufactures BPA in a quantity greater than 100 kg and, as a result of manufacture, the effluent at the final discharge point of the facility contains BPA; or
2. Uses BPA in a quantity greater than 100 kg and, as a result of use, the effluent at the final discharge point of the facility contains BPA; or
3. Uses a mixture(s) containing BPA in a quantity greater than 100 kg and, as a result of use, the effluent at the final discharge point of the facility contains BPA.

The P2 Planning Notice outlines the requirements to prepare and implement pollution prevention plans, and includes the forms to be completed and submitted to the Minister within the required timelines by persons subject to the Notice.

As part of the P2 Planning Notice, facilities must consider effluent monitoring activities including sampling and analysis as described below:

1. Effluent samples are collected in such a way that they are representative of the effluent containing BPA release at the final discharge point under normal operating conditions;
2. Effluent samples are collected and analyzed at a minimum of four times per year;
3. Sampling and analysis of the samples should be performed in accordance with generally accepted standards of good scientific practice at the time of the analysis; and
4. Analysis of the samples should be performed by a laboratory that is accredited by a Canadian accrediting body under the International Organization for Standardization standard ISO/IEC 17025, entitled General Requirements for the Competence of Testing and Calibration Laboratories, as amended from time to time.

Table 1 provides a summary of the substance information.

Table 1: Substance Information

BPA is toxic to aquatic organisms and can accumulate in biological tissue. BPA is expected to break down under aerobic conditions, but it has a long half-life under anoxic or anaerobic conditions.

1.1 Purpose

This guidance document is to provide practical advice to facility operators on the sampling and analysis of industrial effluents for BPA. The methods and procedures identified in this guide may also be useful in helping facilities understand process-specific BPA contributions to their final effluent as part of their P2 activities.

This guide should be relied upon for general information purposes only, and should not be interpreted as legal advice and may not necessarily reflect all legal requirements of the pollution prevention planning provisions of Part 4 of CEPA 1999. Should a discrepancy arise between this document and Part 4 of the Act, the latter shall prevail.

1.2 Scope

This guidance document applies to water and effluent sampling, including:

• Effluent at the final discharge point;
• Industrial process waters; and
• Cooling waters.

This guidance document does not apply to groundwater sampling. It also does not provide detailed guidance on the interpretation of data.

1.3 Intended Users

This guidance document is intended for any individual who samples industrial effluents for the purposes of detecting and measuring BPA, whether conducted by the facility personnel or a third party on behalf of the facility operator.

Facilities subject to the P2 Planning Notice must have a thorough understanding of where and when BPA is introduced to their effluent, in order to select the appropriate sampling method, as described in Section 4 of this guidance document. For instance, BPA may be introduced by one specific process, several processes, at various times during the day, all day, only during maintenance activities, or only during cleaning activities. These activities should be captured as part of the sampling plan.