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- Part I: General Comments on the Instrument
- Part II: Application and Exemption
- Part III: Release Limits
- Part IV: Sampling and Analysis
- Part V: Reporting
- Part VI: Accidental release
- Part VII: Guidance Document
- Part VIII: Environmental Monitoring
- Part IX: Control and Capture Technology / Alternatives
- Part X: Economics
Siloxane D4 in Industrial Effluents
Response to Comments - Part II: Application and Exemption
It is suggested that Environment Canada develop and publish a rationale for the 100 kg/yr threshold for the application and establish how low a facility must search to establish involvement. It is also suggested to exclude incidental use or presence from the regulation.
The proposed threshold for the application of the P2 Planning Notice is 100 kg/year of D4; this threshold is estimated to cover about 93% of the industrial releases to water.
After consultation and further analysis, it is proposed that facilities that use D4 strictly as contained in any solid material and facilities that use a mixture that contains D4 in a concentration lower than 1% would not be subject to the Notice. These exemptions are proposed because of the low possibility of release to water from D4 contained in solid material. Furthermore, it takes into account the situation where a facility using a mixture containing less than 1% of the substance may not be aware of the presence of D4 in the substance or mixture they use.
There may be some stakeholders who may not be aware of the development of this particular regulation since the section 71 survey did not include 'use' at the low trigger of 100 kg/year. Also, for D4, only those who were required to complete the 2006 survey were required to complete the 2007 survey. The full range of affected industries might not have been considered in the development of the instrument
Information on industry obtained through the Section 71 reports and through discussion with associations and industries was considered during the development of the instrument.
Compliance promotion activities are intended to be delivered by Environment Canada staff in order to encourage the affected community to achieve compliance. These activities will be guided by the Compliance and Enforcement Policy implemented under the Canadian Environmental Protection Act, 1999 (CEPA 1999). The Policy outlines measures designed to promote compliance through information, education and other means. Promotional activities could include developing and distributing promotional materials (i.e., a fact sheet, web material), advertising in trade and association magazines, attending trade association conferences and presenting workshops/information sessions.
- Date Modified: