Siloxane D4: how to fill P2 notice schedules in the reporting tool

Note: This document is intended to provide guidance only. It does not in any way supersede or modify the Canadian Environmental Protection Act, 1999 (CEPA or the Act) or any Notice issued by the Minister of Environment and Climate Change under Section 56 of the Act requiring the preparation and implementation of a pollution prevention (P2) plan. In the event of an inconsistency between this document and CEPA or the P2 Notice issued by the Minister and published in the Canada Gazette, the Act and the P2 Notice prevail.

A. General instructions

These instructions are designed to accompany the "Notice Requiring the Preparation and Implementation of Pollution Prevention Plans in respect of Cyclotetrasiloxane, octamethyl- (siloxane D4) in industrial effluents", referred to as "the Notice" throughout this document. For additional information, please see Section "I. Useful Links" at the end of this document.

Certain forms must be submitted to the Minister of Environment and Climate Change by the deadlines specified in the Notice. These forms are:

  • Schedule 1: Declaration That A Pollution Prevention Plan Has Been Prepared and Is Being Implemented [Subsection 58(1) of CEPA]

    Throughout these instructions, Schedule 1 is referred to as the Declaration of Preparation. Schedule 1 was due on July 1, 2013. However, any person meeting the requirements of the Notice after its date of publication is required to prepare their plan and begin its implementation within 12 months of becoming subject to the Notice.

  • Schedule 2: Request for Waiver of the Requirement to Consider a Factor or Factors [Subsection 56(5) of CEPA]

    In the event that a person subject to a Notice is of the opinion that it is not reasonable or practicable to consider one or more of the factors specified in the Notice, that person may request a waiver of the requirement to consider certain factors from the Minister of Environment and Climate Change by submitting Schedule 2. Such a request will only be considered if it is received on or before the deadline to prepare the plan as specified in the Notice (or before the end of an extended period), not the deadline to submit the Schedule 1. Persons submitting such requests will receive a response informing them of the Minister's decision to grant or deny the request.

  • Schedule 3: Request for Time Extension [Subsection 56(3) of CEPA]

    A person subject to a Notice may submit a request for an extension of the time specified in the Notice to prepare or implement a pollution prevention plan. In such cases, the person subject to the Notice must complete and submit Schedule 3 to the Minister of Environment and Climate Change. Such a request will only be considered if it is received on or before the deadline to prepare (or implement, depending on the case) the plan as published in the Notice, not the deadline to submit the Schedule 1 (or Schedule 5, depending on the case). Persons submitting such requests will receive a response informing them of the Minister's decision to grant or deny the request. Note that the Minister of Environment and Climate Change publishes in the Canada Gazette the name of any person for whom an extension is granted, the duration of the period of the extension, and whether the extension is for the preparation or implementation of the plan.

  • Schedule 4: Interim Progress Reports

    • Interim Progress Report #1 was due on July 1, 2014.
    • Interim Progress Report #2 was due on July 1, 2015.
    • Interim Progress Report #3 was due on July 1, 2016.

    However, any person meeting the requirements of the Notice after its date of publication is required to submit the Interim Progress Report #1 within 25 months of becoming subject to the Notice, the Interim Progress Report #2 within 37 months of becoming subject to the Notice and the Interim Progress Report #3 within 49 months of becoming subject to the Notice.

  • Schedule 5: Declaration That a Pollution Prevention Plan Has Been Implemented [Subsection 58(2) of CEPA)]

    Schedule 5 is due on July 1, 2017. Any person meeting the requirements of the Notice after its date of publication is required to submit the Schedule 5 within 60 months + 30 days of becoming subject to the Notice.

Online reporting

Forms referred to in the Notice (Schedules 1 to 5) should be filled out electronically using the Pollution Prevention Planning Online Reporting Tool found on Environment and Climate Change Canada's (ECCC) Single Window Information Manager (SWIM):

Please note that the numbering and section titles have remained consistent with those of the published Notice, and the Online Reporting Tool's section titles have been included in parentheses where they differ from those of the Notice. For guidance on how to access SWIM, as well as additional guidance on submitting Schedules electronically, please refer to the following:

Important!

Your reporting requirements are considered complete when ECCC receives your certified schedule through the Pollution Prevention Planning Online Reporting Tool. Once you have successfully submitted your Schedule, an email confirmation message will be sent to the person submitting the Schedule via the SWIM account.

Amendments

In the event that information submitted in any Declaration or Interim Progress Report becomes false or misleading, an amended Declaration or amended Interim Progress Report must be filed within 30 days of the time that the information has become false or misleading.

Amendments to a previously submitted Schedule should be filled out electronically using the Pollution Prevention Planning Online Reporting Tool where you initially entered your Schedule.

Once you are in the Reporting Dashboard, a list of all your submitted Schedules will appear in the Reports section at the bottom of the screen. Select the Schedule that you would like to amend and click on the pencil at the end of the line to edit your Schedule. You will then be asked to specify the part(s) of the Schedule that you are amending as well as the reason(s) on the Certification page. After you have updated the relevant parts of your Schedule, you will need to resubmit your Schedule by going into the Certification page and clicking the Proceed to Submit and Submit buttons.

Public disclosure of information

For all Pollution Prevention Planning Notices, the submitted Schedules 1, 4 and 5, and amendments to such Schedules (where applicable) will be posted on the P2 Planning online search tool. (See related section H. Confidential Business Information).

Information within the certification, general contact and technical contact sections will not be made publicly available.

As much of the information required in the Schedules 1, 4 and 5 is common or similar, these instructions provide part-by-part rather than form-by-form guidance. The beginning of each section of these instructions outlines those Schedules to which the information in that part of the Schedule applies.

B. Contact information

The information described in this Part will be collected when you access SWIM for the first time. Your contact information will be transferred from SWIM into your Schedule 1, 4 and 5 when you start reporting. However, once you are in your Schedule, you will have the opportunity to update your contact information, if it has changed, and then save it into SWIM by choosing the Save to SWIM button at the bottom of the screen.

1.0 Information on the Person or Class of Persons Subject to the Notice ("Contacts" page in reporting tool)

Company Name
Enter the Company name. If the company owns or operates more than one reporting facility, please ensure that the same name is used for all facilities.
Canadian Federal Business Number
Enter the Federal Business Number provided by the Canada Revenue Agency.
Facility Footnote1 Name
Enter the name of the Facility. If the Company Name alone completely identifies the Facility, re-enter it. If the company owns or operates more than one facility that is subject to the Notice, please ensure you specify the name that is unique to that facility and file a separate Schedule for each individual facility.
Street (Physical) Address of Facility, City, Province/Territory, Postal Code
Enter the street name and number, street type, street direction, and other identifiers such as unit number, suite number or building designation (for example, Building A). For rural addresses, where a street (physical) address is not available, enter the lot and concession numbers. Enter the name of the city, town, village, district or township, the province or territory, and the postal code where the facility is located. Because this is a location identifier, do not use a post office box or mailing address.
Telephone Number (with area code)
Enter a telephone number (with the area code) for the facility.
E-mail Address
Enter an e-mail address for the facility.
Mailing Address of Facility, City, Province/Territory, Postal Code
A checkbox will be provided if the Street (physical) address of the facility is the same as the Mailing address. If the facility's Mailing address is different from its street (physical) address, enter the post office box or mailing address information, as well as the name of the city, town, village, district or township, the province or territory, and the postal code in the appropriate fields.
National Pollutant Release Inventory Identification (ID) (optional)
Facilities that submit a National Pollutant Release Inventory (NPRI) report are assigned a permanent NPRI identification (ID) number. If this facility has an NPRI ID number, enter it here. The NPRI ID is specific to the facility and does not change, even if the ownership of the facility has changed. If the facility does not have an NPRI ID number, leave this field blank.
North American Industry Classification System (NAICS) Code (optional)
Enter the six-digit NAICS code for this facility. Statistics Canada provides complete details of NAICS Canada on its website.
Facility Technical Contact
Enter the name and telephone number (with area code) of the facility's technical contact. If available, enter the e-mail address and facsimile number (with the area code) of the facility's technical contact. It is recommended that the technical contact be a representative who can be contacted by Environment and Climate Change Canada for clarification of information submitted in the Schedule(s). This person should be familiar with and be able to answer questions about the information provided. The technical contact will receive all information, mailings and inquiries from Environment and Climate Change Canada. The name and contact information for the technical contact will not be posted electronically.
General Contact Information
Please enter the name of a General Contact and information. A checkbox will be provided if the General Contact Information is the same as the Facility Technical Contact; you will not need to re-enter the information. This information could be used by Environment and Climate Change Canada to correspond with a consultant or association that has filled your Schedule on your behalf. This information will not be posted online.

2.0 Use of Plans Prepared or Implemented for Another Purpose ("Use of Existing Plans" page in reporting tool)

Note: This section applies for Schedule 1 only.

A pollution prevention plan prepared or implemented for purposes other than to comply with this Notice may be used as long as it fulfills all the requirements of this Notice. If the existing plan does not meet all the requirements, it can either be updated so that it meets the requirements or a new pollution prevention plan that meets the requirements can be prepared and implemented.

Indicate if you are satisfying the requirements of this Notice using a pollution prevention plan previously prepared voluntarily or to comply with other legal requirements, such as for another government or another Act of Parliament. If yes, identify the legal requirement(s). Examples of other legal requirements for which a pollution prevention plan may have been prepared include municipal by-laws, provincial regulations, court orders and EPAM (environmental protection alternative measures).

C. Substance and Activity Information

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

3.0 Substance and Activity ("Type of Activity" page in reporting tool)

Indicate all the activities that apply to your facility [i.e. (a) manufacture of D4; (b) use of D4 or a mixture that contains D4].

The term "manufacture" means to produce, prepare or compound the Substance. This also includes the incidental production of the Substance as a by-product as the result of the manufacture, process, and use of other substances.

The term "use" refers to the use of the Substance or use of any mixture containing the Substance having a function or purpose in the production of products or as an intermediate used to manufacture products.

4.0 Baseline Information Prior to Implementation of the Pollution Prevention Plan ("Baseline Information" page in reporting tool)

Note a): Reporting Period

Reference is made to different types of reporting years throughout these instructions:

  1. The Preparation Year refers to the first year of reporting. If you are completing Schedule 1, the data you are reporting corresponds to the Preparation Year.
  2. The Reporting Year of Progress refers to the year you are reporting data for the Interim Progress Reports (Schedule 4). If you are completing Schedule 4, the data you are reporting corresponds to the Reporting Year for either the Interim Progress Report #1, #2 or #3.
  3. The Implementation Year refers to the final year of reporting. If you are completing Schedule 5, the data you are reporting corresponds to the Implementation Year.
Instrument milestones
Instrument Milestones Deadlines for a person subject at the date of publication Deadlines for a person subject after the date of publication
Publication of the Notice June 2, 2012 June 2, 2012
The person become subject to the Notice June 2, 2012 Date the facility meets the criteria to be subject to the Notice (Date)
Preparation of the Plan June 1, 2013 Date + 12 months
Declaration of Preparation (Schedule 1) July 1, 2013 Date + 12 months + 30 days
Interim Progress Report 1 July 1, 2014 Date + 25 months
Interim Progress Report 2 July 1, 2015 Date + 37 months
Meet the risk management objective and start the additional one year of sampling / analysis when the reduction target is met. June 2, 2016 Date + 48 months
Interim Report 3 July 1, 2016 Date + 49 months
Implementation of the Plan June 1, 2017 Date + 60 months
Declaration of Implementation (Schedule 5) July 1, 2017 Date + 60 months + 30 days

If you became subject after the date of publication of the Notice or have applied for and have been granted a time extension that subsequently affects the year for which you must report, indicate the new year for which you are reporting. All references to the reporting year in the Schedules correspond to the new year that you have identified.

Note b): Estimation Methods Codes

Estimation Methods codes provide information about how you determined the quantity of a substance that was used, released or transferred. Whenever a quantity is reported in a Schedule, an Estimation Methods code must be provided. The codes for the methods of estimating uses, releases or transfers are listed below (Note: the same codes are used for NPRI reporting. For more information, see the NPRI Reporting Guide).

M1: Continuous Emission Monitoring Systems
Record emissions over an extended and uninterrupted period. Once the concentration and the flow rate have been determined, emission rates can be calculated by multiplying the concentration by the discharge flow rate or volumetric stack gas flow rate. Annual emissions of the substance can then be estimated by multiplying the concentration by the annual flow rate of the discharged effluent or gases in the stack or duct.
M2: Predictive Emission Monitoring (PEM)
PEM is based on developing a correlation between substance emission rates and process parameters (e.g., fuel usage, steam production, furnace temperature). PEM may be considered a hybrid of continuous monitoring, emission factors and stack tests. A correlation test must first be performed to determine the relationship between emission rates and process parameters. Emissions can then be calculated or predicted using process parameters to predict emission rates based on the results of the initial source test.
M3: Source Testing
Source testing involves collecting a sample of the emission or effluent, then determining the concentration of one or more substances in the sample. The concentration of the substance(s) of interest is then multiplied by the volumetric flow rate to determine the amount of the substance(s) emitted over time. Source testing of air emissions generally involves inserting a sample probe into the stack or duct to collect a volume of exhaust effluent isokinetically. The substances collected in or on various media are subsequently analyzed. For liquid effluents, grab samples or 24-hour composite samples are extracted from the effluent stream.
C: Mass Balance
Mass balance involves applying the law of conservation of mass to a facility, process or piece of equipment. If there is no accumulation, then all the materials that go into the system must come out. Releases are determined from the difference in the input, output, accumulation and depletion of a substance.
E1 and E2: Site-specific and Published Emission Factors
Generally, emission factors relate the quantity of substances emitted from a source to some common activity associated with those emissions. Emission factors may be published or developed by facilities using emission-testing data and source-activity information. For a particular piece of equipment, specific emission factors may be available from the manufacturer or sales centre. When completing the report, you must specify whether a site-specific emission factor (E1) or published emission factor (E2) was used.
O: Engineering Estimates
In many cases, sound engineering assessment is the most appropriate approach to determining process factors and base quantity values. Releases can be estimated from engineering principles and judgment by using knowledge of the chemical and physical processes involved, the design features of the source, and an understanding of the applicable physical and chemical laws. The reliability of these estimates depends on the complexity of the process and the level of understanding of its physical and chemical properties.
X: Other (please specify)
If none of the codes listed above describe the method for estimating uses, releases or transfers, please select " X: Other" and specify the method used in the field provided.

Note: If more than one Estimation Method is used to calculate a single quantity, enter the Estimation Method corresponding to the method that applies to the largest portion of the estimated use, releases or transfers.

Note c): National Pollutant Release Inventory (NPRI)

The NPRI is partially used as a basis for developing the requirements for the baseline information collected in Parts 4.1, 4.2, 4.3 and 4.4 of Schedules 1, 4 and 5. If you already report to the NPRI, you may find that data previously collected for NPRI reporting can be used to complete some or all of these Parts.

4.1 Nature of Activity ("Manufacture and Use Information" page in reporting tool)

Identify the nature of activity(ies) and quantity(ies) in kg for activity(ies) and substance(s) identified in Part 3.0 of the Declarations or Interim Progress Reports, and indicate the Estimation Methods code [see section 4.0, note b)] used to derive the value for the nature of activity(ies).

If the activity selected in Part 3.0 is "Manufacture of D4", please complete Part 4.1.1 by indicating the nature of the activity and the quantity in kg of the Substance manufactured for the year(s) you are reporting.

If the activity selected in Part 3.0 is "Use of D4 or a mixture that contains D4", please complete Part 4.1.2 by indicating the nature of activity and the quantity in kg for the year(s) for which you are reporting.

Note: more than one activity or nature of activity may be applicable.

4.1.1 Manufacture of Siloxane D4

If this facility manufactured the Substance, select at least one of the following natures of activity:

  • For on-site use/processing: Substance was manufactured and then further processed or used at the same facility.
  • For sale/distribution: Substance was manufactured specifically for sale or distribution outside the facility.
  • As a by-product: Substance was produced incidentally and released to the environment or transferred off-site for disposal.
  • As an impurity: Substance was produced incidentally and remained in the product destined to be distributed in commerce.
  • Other (please specify): Provide a description to further clarify the identified nature of activities.
4.1.2 Use of D4 or a mixture that contains D4

In section 4.1.2 (a), indicate the "nature of activity" related to the use of D4 or of a mixture that contains D4. In section 4.1.2 (b), indicate the type of product manufactured resulting from the use of the substance.

4.1.2 (a) Nature of Activity

Indicate the "nature of activity" in relation with the use of D4 or a mixture that contains D4 at the facility during the reporting year. Also indicate the quantity (kg) of D4 used during the year(s) for which you are reporting and the Estimation Methods code [see Part 4.0, Note b)]. Select at least one of the following:

  • As a reactant: Substance was used in chemical reactions for the manufacture or processing of another substance or product. This includes, but is not limited to, feedstock, raw materials, intermediates, catalysts and nutrients added to wastewater systems.
  • As a formulation component: Substance was added to a product (or product mixture) before further distribution of the product. Examples of Substances used in this capacity include, but are not limited to, additives, dyes, reaction diluents, initiators, solvents, inhibitors, emulsifiers, surfactants, lubricants, flame retardants and rheological modifiers.
  • As an article component: Substance became an integral component of an article distributed for industrial, trade or consumer use. An example is ethylene glycol added to vehicle radiators during assembly.
  • As a by-product: Substance was incidentally processed and was released to the environment or transferred off-site for disposal.
  • As a physical or chemical processing aid: Substance was added to a mixture to aid in the manufacture or synthesis of another substance but was not intended to remain in or become a component of or ingredient in the product or product mixture. Examples include, but are not limited to, process solvents, catalysts, inhibitors, initiators, reaction terminators and buffers.
  • As a manufacturing aid: Substance aided the manufacturing process but did not become a component of or ingredient in the resulting product and was not added to the mixture during the manufacture of a product or during synthesis of another substance. Examples include, but are not limited to, process lubricants, metal-working fluids, coolants, refrigerants and hydraulic fluids.
  • For repackaging only: Substance (or mixture containing the Substance) was processed or prepared for distribution in commerce. This also includes transferring the Substance to and from bulk containers.
  • Other: Provide a description the "nature of activities" at your installation.

4.1.2 (b) Manufactured Product

Indicate the type of products manufactured resulting from the use of D4 or a mixture that contains D4 at the facility for the year(s) for which you are reporting. Select at least one of the following types of manufactured products:

  • Silicone polymers or copolymers
  • Personal care products
  • Adhesives
  • Paints or coatings
  • Pharmaceutical products
  • Soaps or cleaning compounds
  • Other (please specify): If your installation uses D4 or a mixture that contains D4 to manufacture a different product than those listed in this section, indicate the type of product manufactured resulting from the use of D4 or of a mixture that contains D4.

4.3 On-Site Releases

Indicate if this facility released the Substance at the final discharge point(s) of the facility during the reporting year. If no, proceed to "Part 5.0 Actions and Results". If yes, report releases of D4 to water in Part 4.3.3.

4.3.3 Releases to Water ("On-site Releases to water" page in reporting tool)

Report the total quantity of the substance release to waters (surface water or wastewater system), indicating the Estimation Methods code [see part 4.0, note b)] for the method used to derive that value. The types of releases to water are described in the box below.

Surface waters
Releases directly to a receiving body of water
Wastewater System
Releases to an off-site wastewater system where "wastewater system" means any work or undertaking, at least part of which is located on land, that is used for the collection and deposit of wastewater, whether or not the wastewater is treated, and includes a site that contains a wastewater lagoon.

4.5 Additional Information

4.5.1 Sampling and Analysis

Report the results from at least four samples representative of the effluent at the final discharge point as described in subsection 4(3) of the Notice, collected during the reporting year. In the event that there is more than one final discharge point, a minimum of four samples should be taken at each final discharge point.

Report the following information for each sample collected:

  • The location where the sample was collected (final discharge point of facility or other location)
  • The date of the sample collection
  • The date of samples analysis by the laboratory
  • The concentration of D4 (µg/L) of the sample
  • The estimated concentration of D4 (µg/L) at the final discharge point, when the sample is collected at another location than the final discharge point of the facility
  • The laboratory information including the laboratory name, city and phone number

If an analytical result indicates a non-detectable concentration of D4 in the sample, report the sign "<" followed by the detection limit of the method.

Provide an explanation when less than four samples were collected for a final discharge point during the reporting year (e.g.: D4 was used to produce only two batches during the reporting year (2 days of production), one sample per day was collected when the highest expected concentration of D4 at the final discharge point(s) resulting from normal operating conditions was anticipated).

Provide an explanation when the samples were collected at another location than the final discharge point of the facility. Also, explain the relation between the location where the sample was collected and the final discharge point. For example, if sampling at the final discharge point is not possible (i.e. if the final discharge point is not accessible), samples can be collected earlier in the process but you should be able to estimate the concentration of D4 at the final discharge point.

4.5.2 Details on Final Discharge Point(s) of the Facility ("Final Discharge Point" page in reporting tool)

Indicate whether the industrial effluent at final discharge point(s) is released in surface waters or in an off-site wastewater system. When the effluent is released to surface waters, indicate the name of the streams, rivers, lakes, bays, inlets, etc. and the geographical coordinates (longitude and latitude) where the effluent is discharged in the surface waters.

For an effluent released in an off-site wastewater system, indicate the name of the wastewater system, the type of treatment of the wastewater system (e.g.: lagoon, primary, secondary or tertiary) if known and the address of the wastewater treatment plant.

5.0 Actions and Results

The instructions in this part are designed to provide direction for completing Schedules 1, 4 and 5. Also, titles and headings in this part of the instructions correspond to those found in Schedules 1, 4 and 5. Therefore, headings in a particular Schedule may be slightly different from those found in these instructions to reflect the type of data required in that Schedule (i.e.: anticipated results, results achieved to date and results achieved).

  • In Schedule 1, Part 5.0 requires you to report the "anticipated" changes to uses and releases that you intend to achieve through implementing a pollution prevention plan.
  • In Schedule 4, Part 5.0 requires you to report the changes you have achieved during the reporting year, to illustrate the progress you have made in implementing the plan.
  • In Schedule 5, Part 5.0 requires you to report the final changes to uses and releases achieved by the pollution prevention plan, after completing the implementation of the plan.

Parts 5.1.1 through 5.1.6 must be completed separately for each individual action identified in the P2 plan, i.e. Part 5.1 will be completed as many times as there are actions to report.

5.1 Anticipated Action/Action(s) Taken to Date/Actions Taken ("List of Anticipated Actions/List of Actions Taken to Date/ List of Actions" page in reporting tool)

This Part summarizes the actions that you plan to take or have already taken in implementing the pollution prevention plan in order to work towards achieving the risk management objective specified in the Canada Gazette Notice. Please add and complete for each action that is in your plan. Actions reported in Schedule 1 will be carried over to Schedule 4 and 5 where you will be asked for updates or have the opportunity to report new actions. The following is a description of the information required in each field.

Describe for the activity identified in Part 3.0 of this schedule, the current status of the actions taken to date in implementing the Pollution Prevention Plan. That is, indicate if each action is:

  • "Planned/To be initiated"
  • "In progress"
  • "Completed"
  • "Discontinued"

If the action is "Discontinued", please provide the reason why you will no longer be carrying out this action for the activity. (Note: the "Discontinued" option applies to Schedules 4 and 5 only).

5.1.1 Anticipated Action/Action(s) Taken to Date/Actions Taken

Describe each action that you plan to implement or have already implemented in the pollution prevention plan (for example, Action 1: "implemented ‘first-in-first-out' stock management," Action 2: "installed overflow alarms and relief valves", etc.). If the anticipated action includes the use of alternative substances, please include the chemical name, the common name of the substance or the CAS Registry Number within the description of the action. If the anticipated action includes the use of a pollution control method, please, include the type of equipment used.

If you are required to file multiple Interim Progress Reports you are required to report new actions taken since your last report and any updates to actions previously reported on. For example; when completing the second Interim Progress report you must report actions taken since you submitted the first Interim Progress Report and not all actions taken to date in implementing your plan.

Similarly, in Schedule 5 you must report those actions taken since your last Interim Progress Report. However, you must report updates, if there are any, on all actions taken to date.

For each anticipated action, identify whether it represents a pollution prevention method(s) in Part 5.1.2 or an environmental protection method(s) in Part 5.1.3.

5.1.2 Types of Pollution Prevention Methods

If the action identified in 5.1.1 utilizes a pollution prevention (P2) method, indicate the type of method used, choosing from the list provided. More than one P2 method can be used. Alternatively, no P2 method may be applicable, in which case you must identify an environmental protection method in Part 5.1.3. P2 methods are described in the box below.

Material or feedstock substitution
Material or feedstock substitution consists in eliminating the toxic substances with more environmentally friendly alternatives. Material or feedstock substitution can completely eliminate the use of a given substance or product.
Product design or reformulation
Product design and reformulation deal with reducing the overall environmental impact of a product. It involves looking at the whole life cycle of the product (from cradle to grave) and then either designing a new product or reformulating an existing one while observing pollution prevention principles all along the process.
Equipment or process modification
Equipment or process modification consists in changing the way chemicals are made or used, through a transformation of a number of manufacturing or handling operations, in order to achieve any of the following results:
  • improve efficiency
  • reduce or eliminate pollution
  • reduce material, water or energy loss
Spill and leak prevention
Spill and leak prevention consists in not polluting accidentally, i.e. in preventing spills and leaks from happening and in having measures in place to limit the damage if ever there is a spill or leak.
On-site reuse, recycling or recovery

When waste is unavoidable, on-site reuse, recycling or recovery consists in using the waste and waste by-products instead of throwing them away (often at high cost) or otherwise disposing of them.

Note: Reuse, recycling or recovery that takes place off site is not considered P2. While collecting recyclable materials and having them recycled (by the city or another recycling company) is definitely an adequate measure, it is not P2 because pollutants are then only transferred elsewhere.

Inventory management or purchasing techniques
Inventory management or purchasing techniques deals with how goods/materials are stored, bought and managed. It involves having a strategy in place to reduce the amount of stock to be disposed of because it is expired, damaged or no longer needed. It also involves having a strategy in place to ensure that the environment is taken into account when buying goods.
Good operating practice or training
Good operating practice or training deals with the human element of operations. It does not matter how state-of-the-art the equipment is if the personnel does not know how to use it properly or in the most efficient manner. It consists in minimizing waste and increasing efficiency.
Other (specify)
Other methods that result in preventing or avoiding the creation of pollutants and waste. If you select Other, please specify.

Please visit the Pollution Prevention Techniques web page for more information and examples of these P2 methods:

5.1.3 Types of Environmental Protection Methods

If the action identified in 5.1.1 utilizes an environmental protection method other than a P2 method, indicate the type of method used, choosing from the list provided. More than one environmental protection method can be used. Alternatively, no other environmental protection method may be applicable. Descriptions of the other environmental protection methods are listed in the box below.

Energy recovery
Energy recovery involves using waste with sufficient energy content to allow for its use as a fuel for energy recovery (for example, recovery of methane from landfills).
Off-site recycling
Off-site recycling involves recycling of materials at a place outside the property boundaries of where an activity has taken place (for example, transfer of paper products to another facility for recycling into new paper products).
Incineration with energy recovery
Incineration with energy recovery involves thermal treatment of wastes and recovery and use of the resulting energy to offset the need for additional energy (for example, incinerating waste and using the recovered energy to heat building air or water).
Waste treatment
Waste treatment involves processing of waste to render it less harmful or harmless to the environment (for example, bio-oxidation, evaporation, precipitation, neutralization).
Pollution control
Pollution control involves addition of equipment to the end of a system to collect pollutants prior to the release of the effluent into the environment (for example, addition of filters to collect dust prior to release).
Disposal
Disposal involves having final disposal in such a way as to cause the least harm to the environment (for example, landfill of biodegradable materials and containment of wastes containing the Substance).
Other (please specify)
Other methods that result in environmental protection.

5.1.4 Anticipated or Achieved Change(s)

Report the anticipated (Schedule 1) or achieved (Schedule 4 and 5) annual increase or decrease in the quantity (kg) and concentration (µg/L) of D4 released from this facility resulting from implementation of the action described in Part 5.1.1, if possible. Note that predicting a quantitative change for some actions, such as training, may not be possible. In such cases, report whether the action anticipated or achieved an increase ("+") or decrease ("-") in the Substance released, without specifying the quantity.

5.1.5 Baseline Elements Affected

Describe which baseline elements are affected by the changes reported in the previous Part (Anticipated or Achieved Changes). More than one baseline element may be chosen, as many actions will affect more than one baseline element. Baseline elements are listed in the box below.

  • Total quantity manufactured on-site
  • Total quantity used on-site
  • Total quantity released to water (surface waters or wastewater system)
  • Effluent concentration at final discharge point
  • Other (If other is selected, please provide a short description)

5.1.6 Completion Date

Provide the date on which the action is anticipated to be or was fully implemented.

5.3 Total Results Anticipated/Achieved To Date/Achieved

Reporting results are based on a Preparation Year.

Total changes must be reported in units specified (kg or µg/L) and as a percentage (%). Use a negative sign ("-") before the reported total to denote a decrease and a positive sign ("+") to denote an increase.

Schedule 1

Report in the appropriate columns, the total anticipated change in concentration (µg/L) and quantity (kg) of D4 released, by final discharge point, from implementing all the anticipated actions set out in Part 5.1. Also, in the appropriate columns, indicate the anticipated concentration and quantity change as a percentage of the Preparation Year.

If there is more than one final discharge point, report the total anticipated change in the quantity (kg) of D4 released for all final discharge points in the line "Total". Also report this anticipated change in percentage (%) based on the Preparation Year.

Schedules 4 and 5

Report, in the appropriate columns, the total obtained change in concentration (µg/L) and quantity (kg) of D4 released, by final discharge point, from implementing all actions taken since initiating the implementation of the pollution prevention plan. Also, in the appropriate columns, indicate the obtained concentration and quantity change as a percentage of the Preparation Year.

If there is more than one final discharge point, report the total obtained change in the quantity (kg) of D4 released for all final discharge points in the line "Total". Also report this obtained change in percentage (%) based on the Preparation Year.

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, number of sample collected and analyzed per year; number of training on handling of the substance)
  • performance indicators to track progress (for example, trend in quantity and concentration released in the industrial effluent, implementation of new procedures at the installation)
  • how monitoring will be/has been performed
  • 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 corresponds to the aimed outcome in terms of reducing the risk to the environment and human health. The reduction target is set out in subsection 4(2) of the Notice. This reduction target was established in order to protect the environment and to achieve the risk management objective set out in the preamble of the Notice.

In Schedules 1, 4 and 5, briefly describe how the pollution prevention plan allows or will allow meeting the reduction target specified in the Notice.

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 to that effect in the appropriate space.

8.0 Factors to Consider

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

  • Factor 4(3) states that a person subject to the Notice should consider sampling and analysis activities. Prior to developing a sampling plan, the production process and wastewater discharge process should be considered and understood. Sampling considerations may include: location where the samples are collected, frequency of sampling, sampling method; and type of process (e.g. batch or continuous process). Laboratory analysis consideration may include: analytical method (Method detection limit, precision, accuracy) and Quality assurances and controls.
  • Factor 4(4) states that a person subject to the Notice should give priority to the use of pollution prevention methods (see part 5.1.2 of these Instructions for a description of pollution prevention methods). Considerations may include: cost, feasibility of implementation and technological obstacles.
  • Factor 4(5) states that a person subject to the Notice should consider the use of alternative products/substances to D4 to reduce or minimize environmental and human health risks. Considerations may include: the analysis of various alternatives, including cost or technological obstacles of switching to the alternative.
  • Factor 4(7) states that a person subject to the Notice should keep a number of documents with the plan. Facilities should include: information on all final discharge points of the facility and a description of the factors (e.g. type of technology, human factor, accidental releases, type of manufacturing, and daily use) that could increase the quantity or concentration of D4 in the effluent.
  • Factor 4(8) states that a person subject to the Notice should conduct monitoring for one year after meeting the reduction target. Monitoring considerations 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 Environment and Climate Change. Refer to Section F of these instructions for information on applying for a waiver of the requirement to consider a factor or factors.

E. Certification

The information described in this section is collected in all Schedules.

9.0 Certification

If applicable, a comment box is provided to specify the parts that you requested confidentiality as well as the reasons for your request (for more information on Confidentiality, refer to Section H).

All schedules submitted to Environment and Climate Change Canada must be certified by an appropriate authority, i.e. a duly authorized official, who will be required to verify that the information being reported is true, accurate, and complete. The name, title and email address of that person need to be provided before submission to Environment and Climate Change Canada.

A comment box is also provided for general comments.

F. Waiver of the Requirement to Consider a Factor or Factors

The information described in this section is collected in Schedule 2. Information submitted in Schedule 2 will not be available to the public.

The Notice states factors that you are to consider while developing and deciding which actions you anticipate taking in your pollution prevention plan. If you do not think it is reasonable or practicable to consider one or more of the factors specified in the Notice, you may apply for a waiver of the requirement to consider factor(s). Such a request will only be considered if it is received on or before the deadline to prepare the plan (or before the expiry of any extended period) as specified in the Notice, not the deadline to submit the Schedule 1. Persons submitting requests for waivers of the requirement to consider a factor will receive a written response informing them of the Minister's decision to grant or deny the request. Unless you submit Schedule 2 and are granted a written waiver by the Minister of Environment and Climate Change, you must consider all factors identified in the Notice.

2.0 Factor(s) for Which a Waiver Is Being Requested

Identify exactly those factors specified in the Notice for which you are requesting a waiver for the requirement to consider.

3.0 Rationale for Request

Explain the reason(s) that you are applying for a waiver (i.e., why you believe the factor(s) specified in the Notice are not reasonable or practicable to consider).

Explain how the outcome of your pollution prevention plan will be affected if the factor(s) for which you are requesting a waiver of the requirement to consider is(are) not taken into account when preparing your pollution prevention plan.

You may also identify other alternative factors, if any, that were not specified in the Notice that you propose to consider in your plan. This is optional.

G. Time Extension to Prepare or Implement a Pollution Prevention Plan

The information described in this section is collected in Schedule 3. Information submitted in Schedule 3 will not be available to the public.

The Canada Gazette Notice states the time period within which your pollution prevention plan must be prepared and its implementation begun, and the time period within which your pollution prevention plan must be implementedFootnote2.

If you do not think it is reasonable or practicable to prepare or implement your pollution prevention plan in the time allotted, you may request an extension of the time period specified in the Notice using Schedule 3.

Such a request will only be considered if it is received on or before the deadline to prepare (or implement) the plan (or before the expiry of any extended period), as specified in the Notice, and not the deadline to submit the Schedule 1 (or Schedule 5). Persons submitting such requests will receive a written response informing them of the Minister's decision to grant or deny the request.

Note that the Minister of Environment and Climate Change publishes in the Canada Gazette the name of any person for whom an extension is granted, the duration of the period of the extension, and whether the extension is for the preparation or implementation of the plan.

2.0 Request for Time Extension

Indicate which time period you are requesting to be extended (period to prepare a pollution prevention plan, or period to implement a pollution prevention plan). Specify the new date to which you wish the time period to be extended.

3.0 Rationale for Request

Explain the reasons that you are applying for an extension (i.e., why you believe the time period specified in the Notice is not reasonable or practicable). The Minister of Environment and Climate Change will evaluate the request for a time extension based on the reasons or rationale provided in the request.

H. Confidential Business Information

All persons submitting information to the Minister of Environment and Climate Change are entitled to request confidentiality under section 313 of CEPA for some or all of the information reported in the Schedule(s).

Please note that Facility Technical Contact and General Contact Information as well as the Certification information will not be publicly posted.

To request that information be treated as confidential, click on the padlock icon displayed beside the appropriate part(s) of the Schedule. Once clicked, the padlock icon will appear locked. At the end of the Schedule, at the beginning of the Certification page, you will be required to provide a justification for each part that you are requesting confidentiality.

All such requests will be reviewed under the provisions of sections 315 to 321 of CEPA and section 20 of the Access to Information Act. Persons submitting such requests will receive a response letter from ECCC either asking for additional information to evaluate the Request, confirming the acceptance or denial of the request. No information that is requested to be kept confidential will be made available to the public until a decision has been made by ECCC and a response letter is sent to the reporter.

For more information on the type of information that might be considered confidential business information, please refer to section 20 of the Access to Information Act.

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