Instructions for completing schedules of bisphenol A pollution prevention planning notice: chapter D

D. Achievement of risk management objectives and accounting of factors to consider

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

6.0 Monitoring and Reporting

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

• activities monitored (for example, effluent sampling)
• performance indicators to track progress (for example, progressive decrease in substance in effluent, increase or decrease in number of sampling events)
• how monitoring will be/has been performed (for example, according to specific guidelines, internal/external review, type of sampling (grab vs composite), type of analysis)
• frequency of monitoring (for example, weekly or monthly)
• reporting mechanism and frequency (for example, reporting to the Environmental Manager at six-month intervals)

7.0 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 objective is stated in subsection 4(2) of this Notice.

In Schedule 1, Schedule 4 and Schedule 5, briefly describe how the pollution prevention plan will meet/has met the risk management objective.

If it is anticipated that the prepared plan will not meet the risk management objective, or if the implemented plan did not meet the risk management objective, please provide an explanation in the appropriate space.

8.0 Factors to consider

The Notice states 8 factors that must be considered while developing/deciding which actions to use in your pollution prevention plan. Briefly describe what has been done to take into account factors 4(3), 4(4), 4(5), 4(6) and 4(7) during the preparation/implementation of the plan.

• Factor 4(3) states that facilities should consider the use of pollution prevention. Consideration may include: cost, feasibility of implementation or technological obstacles.
• Factor 4(4) states that facilities should consider the use of alternatives to reduce or minimize environmental and human health risks. Consideration may include the analysis of various alternatives (e.g. level of risk, cost or technological obstacles).
• Factor 4(5) states that facilities should consider sampling and analysis activities. Prior to developing a sampling plan, the facility should consider and understand their production process and wastewater discharge process. Sampling consideration may include: information on the type, frequency and method used for sampling and analysis, and the type of production or operating process (e.g. Intermittent operation or continuous). Laboratory analysis consideration may include: accreditation under ISO/IEC 17025 entitled General Requirements for the Competence of Testing and Calibration Laboratories; type of analytical method (e.g. detection limit, precision, exactitude), and Quality assurances and controls (e.g. contamination, holding time, equipment blanks).
• Factor 4(6) states that facilities should consider keeping additional documentation with the plan. These documents should include information on sampling locations and facture that contribute to an increase BPA in effluent at the final discharge points (e.g. type of technology, human factor, accidental releases, type of manufacturing, daily uses, etc.). For sampling at a site other than the final discharge point, facilities should consider the site location in relation to final discharge point, the rationale for the site location, and the predicted concentration of BPA at the final discharge point as a result of any removal or treatment of BPA by the facility.
• Factor 4(7) states that facilities should consider monitoring after meeting the Risk Management Objective. Monitoring consideration may include: frequency, type, results and duration of monitoring activities.

Note: You are not required to describe a "factor to consider" for which a waiver has been granted by the Minister of the Environment. Refer to Section F of these instructions for information on applying for a waiver of the requirement to consider a factor or factors.