Implementation Guidelines for the Environmental Emergency Regulations 2011
- 1.0 Purpose of the Implementation Guidelines
- 2.0 Environmental Emergency Authorities under Part 8 of CEPA 1999
- 3.0 Benefits of E2 Planning
- 4.0 E2 Regulations - Am I Regulated?
- 5.0 E2 Plans
- 6.0 Notification of Environmental Emergencies
- 7.0 Access to Submitted Notices
- 8.0 Compliance and Enforcement
- 9.0 Summary of the Risk Evaluation Framework
- Appendix 1 - Suggested References for Environmental Emergencies Prevention, Preparedness and Response Measures and the Development of E2 Plans
- Appendix 2 - Notices of Identification of Substance and Place, of Implementation and Testing of E2 Plans, and of Closure and Decommissioning and Report on the Preparation of E2 Plans and Certification
- Appendix 3 - Schedule 1 of the Environmental Emergency Regulations
- Appendix 4 - Regional Contact Information
- Appendix 5 - Determination of Container Capacity and Substance Quantity
- Appendix 6 - Flow Chart for the Propane Exception
- Appendix 7 - Notification and Reporting of Environmental Emergencies Under Section 201 of CEPA 1999
- Appendix 8 - Checklist to Prepare an E2 Plan
- Appendix 9 - Summary of Risk Evaluation Framework Methodology for Determining Thresholds for Environmental Emergency Plans
3.0 Benefits of E2 Planning
Environmental emergency planning is not just about compliance with the E2 Regulations. For today’s modern enterprise, effective planning for emergency events is an essential part of good business management.
When E2 planning is properly developed and implemented, benefits to the environment, human health and industry ensue. An industry-wide study2 conducted by the Center for Chemical Process Safety (CCPS) of the American Institute of Chemical Engineers confirms that E2 planning provides measurable benefits by
- saving lives and reducing human injury;
- reducing property damage costs, preventing the sometimes extreme costs of a major industrial incident;
- shortening business interruptions, which can be four times as costly as the property damage mentioned above;
- lessening loss of market share, which continues after an incident until the company’s production and reputation are restored;
- lowering litigation costs, which are unavoidable after an incident and can total five times the cost of the regulatory fines;
- reducing incident investigation costs, as well as corrective actions can cost millions of dollars; and
- reducing regulatory penalties.
E2 planning also provides non-measurable benefits by
- greatly reducing the risk of catastrophic events, resulting in less severe incidents, which
- engages employees at all levels by increasing morale, loyalty and retention;
- reduces concerns within the local community; and
- helps regulators understand your facility’s credibility and unique considerations; and
- improving your corporate image; and
- enhancing your lenders’ confidence, thus promoting capital expansion.
An important step in E2 planning is the analysis of all kinds of risks found during the handling, storage, production process use or disposal of any hazardous materials. When the proper measures to eliminate or mitigate these risks are implemented, other benefits follow:
- Productivity increases while production and maintenance costs decrease, due to the correction of unproductive processes and the adherence to effective and well-timed maintenance procedures.
- Lower insurance premiums may be obtained when meticulous emergency planning is implemented to prevent minor incidents and greatly reduce major incidents.
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