Risk Management Strategy for Road Salts

The Priority Substances List Assessment Report for Road Salts was published on December 1, 2001. The report concluded that Road Salts that contain inorganic chloride salts with or without ferrocyanide salts have adverse impacts on the environment and are therefore toxic under Section 64(a) and (b) of the Canadian Environmental Protection Act, 1999 (CEPA 1999). Since Road Salts are neither persistent nor bioaccumulative, they have been categorized as Track 2 under the Toxic Substances Management Policy.

The Road Salt assessment covered the chloride salts: sodium chloride (NaCl), calcium chloride (CaCl₂), magnesium chloride (MgCl₂), potassium chloride (KCl), brines used in road deicing/anti-icing, dust suppression, the salt portion of abrasive mixtures and additives commonly used in road salts (ferrocyanides).

It is estimated that approximately five million tonnes of chloride salts are released into the Canadian environment each year. This salt enters the surface water, soil and groundwater and there is clear indication of environmental impact.

The assessment documented adverse effects on soil properties, roadside vegetation, wildlife, groundwater, aquatic habitat, and surface water.

The following areas of concern have been identified in the assessment.

• Surface and groundwaters: Road Salt contamination of surface and groundwater is a concern in areas of high use on roadways and along major expressways as well as near point contamination from salt depots. There is clear indication of environmental impact in specific areas. Distance from sensitive areas will increase the time to reach concentrations of concerns. Ultimately all high use areas will be of concern. Many of the civil liability claims from property owners against transport authorities are related to contamination of well water from salt released into groundwater.

• Soils Characteristics - Abiotic Effects: Sodium may displace other metals from the soil depending on soil conditions, clay content and exchangeable sodium ratio (ESR). Areas with highest impact will be where there is a high percentage clay content, and high ESR and low precipitation. Hot spots include southern Ontario, southern Quebec, and Alberta.

• Vegetation: Plants can be exposed through the soil, air (salt mists from the road) and runoff water. Salt can be taken up by vegetation roots or deposited directly on foliage. In certain sensitive agricultural areas (e.g. orchard areas), contamination from road salt application has affected nearby crops and trees. In water drainage, salt is easily transported to surface waters such as creeks, rivers, lakes or oceans and can affect various populations of aquatic species.

• Sodium ferrocyanide: This chemical is used as an anti-caking agent. In aqueous solution when exposed to sun light, it breaks down into cyanide ions. Although only present in small amounts, it may be toxic to the aquatic environment.

The following sources have been identified:

• local contamination from improper salt storage and snow disposal resulting in contamination of groundwater and the discharge to surface water of high concentrations of chloride salts
• large scale contamination from general repeated heavy use in urban areas with high road density, examples are regions of southern Ontario, Quebec and the Atlantic provinces which have the highest rate of salt use
• roadway application, salt storage and snow disposal in close proximity to sensitive areas such as wetlands, endangered species, surface waters, groundwater, park land, etc.

1. There are no federal regulations in Canada which directly govern levels of salt use, or salt concentrations in various environmental media. The only relevant national environmental standards, which relate indirectly to road salt in the environment, are the Guidelines for Canadian Drinking Water Quality, March 2001. The aesthetic objective (taste) is a maximum of 200 ppm sodium and 250 ppm chloride.

2. Municipalities use 50-65% of road salts, provinces use 30-45% and the private sector (parking lots, private roads etc.) uses 5-10%.

3. The use of road salt along with plowing is recognized as the most efficient method of keeping roads and highways clear and safe in hazardous winter conditions.

4. The industry provides significant indirect benefits to the economy, including maintaining economic activity, reducing accidents, and reducing fuel use in storm events.

5. Programs are in place in the northern U.S. to promote more efficient use of sand/salt/de-icing chemicals. These programs began with reducing sand and improving salt use and have moved to pre-wetting and anti-icing. Extensive work was carried out in Sweden and Finland to identify and protect sensitive aquifers through salt management practices.

Environmental Objective

Environmental objectives are proposed for surface water, vegetation, soils, wildlife, groundwater, and ferrocyanides based on the assessment report. (Please refer to Annex I)

Risk Management Objectives

Environment Canada is considering a best management practices approach that will build on existing work that has been done by the Transportation Association of Canada (TAC) in its Salt Management Guide and Salt Management Action Plan.

1. Salt Storage: (Best Management Practices, significant reductions of impacts)
   • No further deterioration of site and for new sites no uncontrolled releases.
   
   
2. Snow Disposal: (Best Management Practices, significant reductions of impacts)
   • Effective practices reducing chlorides and other contaminants to acceptable levels.
   
   
3. Road Salt Use: General Areas (Best Management Practices, reductions of salt use in average winter)
   • New technologies for general use have shown significant reductions while improving road safety (in the area of 20-30%), however, the amount used in a season depends on the weather and severity of the winter. This reduction is supported by several studies.
   
   
4. Road Salt Use in Sensitive Areas (Definition of a sensitive area will be established in consultation with Provinces)
   • Establish what constitutes a sensitive area.
   • Identify approaches that can be used in addition to best management practices, such as use of alternative chemicals.
   
   
5. Ferrocyanide
   • Significant reduction or substitution of ferrocyanide salts.
   
   
6. Monitoring and Reporting
   • Establish a regular monitoring and reporting program to measure the implementation of best management practices and effects over a 5 year period. Determine if the risk management objectives are being met and the recommended controls are effective and reevaluate accordingly.
   
   
7. Consideration of alternative anti-icing / de-icing agents
   • Chemical alternatives to sodium chloride used in winter road maintenance and associated technical, environmental and economic issues.

The following factors were considered in the choice of a management instrument to achieve the risk management objectives:

• The management instruments must ensure the risk management objectives are met and road safety is not compromised.
• Expected environmental improvement from the achievement of the proposed risk management objectives must be demonstrated.
• Monitoring of the objective to measure progress
• Cost effectiveness of the measures
• Management instruments must allow a flexible approach based on local situations

The screening analysis has shown the most promising instruments for addressing the environmental concerns with salt use on roads (General and Near Sensitive Areas), salt storage, and snow disposal are Environmental Performance Agreements (EPAs), Pollution Prevention Plans (P2 Plans) and CEPA Guidelines or Codes of Practice. EPAs or P2 plans would be difficult to implement considering the number of users. Our approach is to build on work done by TAC and road authorities with the concept of salt management plans to implement best management practices described in a code or guideline.

For ferrocyanides, the screening has shown that EPAs, Input Controls and Pollution Prevention Plans are the most promising instruments. Our approach is to propose an EPA or use P2 plans depending on the level of cooperation that will be demonstrated by the salt producers.

As required under CEPA 1999, a preventive or control instrument for road salts must be proposed no later than December 1, 2003. The proposed CEPA Code of Practice or Guideline is targeted for publication in the Canada Gazette during November, 2003 and will be followed by a 60-day public comment period.

A compliance promotion strategy for this code of practice or guideline will be developed. The risk manager and regional counterparts will work together to provide information to the target community in order to promote compliance to this code of practice / guideline.

1. Create an advisory group that will provide comments on consultation process.

2. Identify Stakeholders and establish a Working/Consultation Group
   • Primary stakeholders - The involvement of the provinces and municipalities in the development and implementation of a control option is essential because they are in the best position to determine appropriate and effective risk management.
   • The road salt and alternative Industry, Associations (i.e. Federation of Canadian Municipalities, Canadian Public Works Association and TAC) and commercial users,
   • Stakeholders related to the indirect benefits of salt use (consumer group, health and safety group, etc.)
   • ENGOs
   • Targeting 35 to 40 member working group
   
   
   
3. Hold Stakeholder Meetings
   • expected: Meet regularly over the next year to define specifics and establish a balanced approach
   • use of a facilitator
   
   
   

Having published the Ministers' final decision under subsection 77(6) of CEPA 1999, Environment Canada has two years to develop control measures to reduce the impact of road salts on the environment and a further 18 months to finalize them. Environment Canada will form a working group to advise on selection and development of measures and begin stakeholder meetings in the winter (2002). The objective is to publish proposed control measures in the Canada Gazette, Part 1 by December 1, 2003.

Revised 3 May, 2002.

1

Phase 1 Report, Socio-Economic Background and options study on the Canadian Salt Industry

October, 1999

Complete

• assess risk management options for source(s) of concern related to the risk management of Road Salt based on established environmental objective(s) and criteria;
• recommend a preferred risk management option(s)
• identify what controls/guidelines/codes already exist at the Provincial and Municipal level
• establish who are the authorities at these levels (the main players)
• develop use studies (case studies municipalities using and not using salt etc.)
• asses level of information exchange between (Federal/Provincial/Municipal)
• identify the network related to road salt and snow removal
• estimate costs/damages or benefits related to salt use

• Primary stakeholders - Provinces and Municipalities - plan to get them informed and on-board
• The Road Salt and alternative Industry/Associations including TAC
• ENGOs

• Environmental Objectives, possible controls and timelines

• Provide design and implementation details and an assessment of the impact of the recommended risk management option(s) and implementation plan. etc.