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Pollution Prevention Planning Handbook
- 1. I - Introduction to P2 and P2 Planning
- 2. II (Part 1) - What is Pollution Prevention Planning
- 3. II (Part 2) - Effective Pollution Prevention Planning, Implementation and Review
- 4. II (Part 3) - Integrating Pollution Prevention Planning Within an Environmental Management System
- 5. III - Glossary
- 6. IV - Appendix A: Model Pollution Prevention Plan
- 7. V - Appendix B: Key Elements of a Baseline Review
- 8. V - Appendix C: Assessing the Costs and Benefits of Pollution Prevention Options
- 9. VI - Appendix D: Product Design and Reformulation
- 10. VI - Appendix E: Equipment Modifications and Process Changes
- 11. VI - Appendix F: Materials and Feedstock Substitution
- 12. VI - Appendix G: Operating Efficiencies and Training
- 13. VI - Appendix H: Purchasing Techniques and Inventory Management
- 14. VI - Appendix I: On-site Reuse and Recycling
II (Part 1) – What is Pollution Prevention Planning
What is Pollution Prevention Planning?
Pollution prevention planning is a systematic, comprehensive method of identifying options to minimize or avoid the creation of pollutants or waste.
How do I know if I am subject to a P2 Planning Notice?
The Canadian Environmental Protection Act, 1999 (CEPA 1999) has provisions that allow the federal government to require the development and implementation of pollution prevention plans for specific toxic substances. Pollution prevention planning, however, can be more broadly applied to an entire production process or facility.
Pollution prevention plans (P2 Plan) can focus on a single pollutant or on multiple pollutants. Many P2 Plans also cover water and energy use. The more comprehensive it is in scope, the more likely it is that the planning process will focus on the root causes of the problem, identify the most cost effective pollution prevention opportunities and avoid inappropriate trade-offs (such as substituting one toxic substance for another). Plans can and should be tailored to the needs of the organization, forming an integral part of its existing business plan.
The P2 planning process itself also has its own results and benefits. For example:
- A careful planning process ensures the selection and implementation of the most cost-effective pollution prevention options.
- Systematic planning ensures that pollution prevention objectives and activities are consistent with the objectives and activities identified in the organization's broader planning processes.
- Effective pollution prevention planning informs and assists broader business planning investment analysis and decision making (such as capital budgeting and purchasing).
- A documented pollution prevention plan may be a condition for receiving financing or insurance at improved rates.
There are six key steps to developing and implementing a pollution prevention plan:
Step 1 – Commitment and Policy: Establish a commitment to pollution prevention and an overall pollution prevention policy.
Step 2 – Baseline Review: Conduct a baseline review. Take a close look and document current levels and sources of inputs (raw materials, energy and water), products and non-product outputs. Note any information gaps associated with a facility, specific product(s) or production line(s).
Step 3 – Planning: Develop the plan: set objectives and targets in your plan and identify, evaluate and select pollution prevention options to meet your selected objectives and targets.
Step 4 – Implementation: Implement the plan.
Step 5 – Monitoring and Reporting: Monitor implementation.
Step 6 – Review, Evaluate and Improve: Evaluate, review and improve the plan.
These steps are described in more detail in Section II (Part 2), "Effective Pollution Prevention Planning, Implementation & Review".
Commonly Applied Pollution Prevention Practices
There is a wide range of pollution prevention practices. Six of the most common and effective practices are described below along with co-operative P2action. More detail on each of these practices can be found in the corresponding appendices.
- Product Design and Reformulation
- Equipment Modifications and Process Changes
- Materials and Feedstock Substitution
- Operating Efficiencies and Training
- Purchasing Techniques and Inventory Management
- On-site Reuse and Recycling
- Co-operative P2 Action
Product Design and Reformulation
Product design and reformulation involves looking at the whole life cycle (i.e., resource extraction, production, use and disposal) of the product(s) and either designing (making) a new product or reformulating (changing how it is madethe old one to prevent pollution.
The product design stage is a crucial starting point for implementing pollution prevention. Addressing environmental concerns from the earliest stage is a cost-effective way to minimize pollution and waste throughout the product life cycle. "Design for environment" (DfE) is a method of integrating environmental criteria into the usual design considerations of performance, cost, quality, cultural, legal and technical criteria. In trying to reduce the environmental impacts of producing and consuming products and to improve efficiencies over the entire life cycle, DfE may reduce the toxicity of a product, reduce the amount of waste material, extend the life of a product, extend the life of the materials used, improve the selection of materials, and reduce the energy and material intensity required to produce, use and dispose of the product.
An example of Product Design and Reformulation:
Sani-Terre, a manufacturer of equipment-cleaning units, undertook the challenge of designing a prototype to considerably reduce both the greenhouse gases produced and the significant costs incurred for operating and maintaining a mobile unit. The ecological design principles of the new prototype machine produced 50% fewer greenhouse gas emissions (reduction of 3500 tons) compared to a conventional gas powered mobile unit. The redesign eliminated the gas generator and replaced the three other gas motors with hydraulic motors powered by the diesel motor of the mobile unit's truck. Also, the hydraulic motors used for washing and water treatment were replaced with electric motors.
For more information and guidance, please see Appendix D.
Equipment Modifications and Process Changes
Equipment modifications and process changes means changing or modifying equipment or processes within your facility to improve efficiency, reduce or eliminate pollution and reduce material, water or energy waste. The change may involve introducing new technologies or approaches to existing operating systems, processes and practices. This may include, for example, replacing solvents for paint or varnish removal with mechanical stripping; using ion-based painting systems; or integrating recirculation or countercurrent cleaning within a process.
An example of Equipment Modification and Process Change:
Cycles Devinci, an aluminum bicycle manufacturer, modified its paint application process to reduce the amount of paint lost during the paint application process. The new electrostatic application system involved modifying the paint nozzles, the paint chamber, and purchasing a natural gas oven for drying the parts. As a result of these changes, the company has reduced its solvent use by 80% and the quantity of paint by 32% which in turn has resulted in a 48% reduction in the entire cost of painting bicycles. The modification has reduced VOCemissions and costs and has resulted in significant air quality improvements. The return on investment was eight months with a recurring annual savings of $82 000.
For more information, examples and guidance, please see Appendix E.
Materials and Feedstock Substitution
Materials and feedstock substitution involves replacing polluting materials, used in the production process or embedded within a product, with non-polluting or less polluting materials and feedstock. Also referred to as source elimination, materials substitution should decrease or eliminate the quantity of toxic, hazardous or polluting materials used, as a result lowering the risks of harmful exposure to workers, consumers, communities and the environment. There are many opportunities for materials substitution; some examples include painting applications, parts cleaning, metal finishing, printing operations, building and grounds maintenance, among others.
An example of Materials Feedstock Substitution:
Pollution prevention activities have allowed Hafner, a manufacturer of furniture fabric and stretch knitted fabric, to reduce pollutant loads and concentrations in its effluent while improving operating efficiencies. The company identified potentially harmful substances and operations responsible for pollutant loads and concentrations by completing effluent characterizations and reviewing material safety data sheets. Product substitutes, that were equally effective and acceptably priced, replaced some of the toxics and reduced effluent pollutant concentrations and loads to the desired levels. Hafner reduced the nonylphenol and its ethoxylated derivatives load in its effluent by more than 97%, the chemical oxygen demand by 48% and the C10-C50 petroleum hydrocarbons loads by 87%. The reduction in chemical oxygen demand reduced the annual effluent disposal costs by $15 000.
For more information, examples and guidance, please see Appendix F.
Operating Efficiencies and Training
Operating efficiencies and training are important elements of most companies' ongoing activities. In many cases, an existing focus on improving operating efficiencies can provide a very cost-effective way to prevent pollution and reduce costs or improve quality. These multiple objectives can often be achieved through basic improvements in work procedures, such as changing production schedules to minimize equipment and feedstock changeovers, improving maintenance scheduling, segregating by-products at source, training and encouraging staff to improve materials handling and to recognize pollution prevention opportunities, and implementing good housekeeping practices. In many cases, operational efficiencies can be implemented relatively easily through the introduction of work procedures that target process control systems. The result is often improved productivity, increased reliability, more efficient resource and energy use, and reduced waste of financial and production materials and resources.
An example of Operating Efficiencies and Training:
Can-Lak, a paint, stain, and lacquer manufacturer modified its operating procedures to isolate tank-washing activities, minimize evaporation and optimize the collection of solvent vapours during the mixing and filling of finished products. These pollution prevention measures reduced VOC emissions by 4125 kg/year and greenhouse gases by 17 tonnes of CO2. The initial cost of implementation was $4500 however costs were recovered quickly through a yearly savings of $5000 and $3000 for raw materials and heating oil respectively. Therefore, Can-Lak Inc. received a return on its investment in less than seven months. The employees have been informed of the new measures and trained on how to integrate the new practices in their work procedures.
For more information, examples and guidance, please see Appendix G.
Purchasing Techniques and Inventory Management
Purchasing techniques and inventory management includes two distinct practices:
- Environmentally preferable purchasinginvolves the integration of environmental considerations into existing and new purchasing practice. By building environmental issues into the purchasing process, organizations can reduce material and energy consumption, avoid unnecessary use of toxic substances in their products, minimize waste generation, and in many cases reduce associated costs.
- Environmentally responsible inventory management entails the incorporation of environmental considerations into inventory management systems. Examples of these techniques include just-in-time delivery, avoidance of unnecessary waste generation by ensuring that materials do not stay in inventory beyond their shelf life, and quality control for feedstocks to prevent production of "off-spec" products.
An example of Purchasing Techniques and Inventory Management:
The Northumberland Hills Hospital management adopted an environmentally safe philosophy. The core of this philosophy holds that, wherever possible, environmental consideration must be given when making purchasing and operational decisions.
The purchasing philosophy states that "whenever there are items of equal value, the item that has the least impact on the environment will be selected".
For more information, examples and guidance, please see Appendix H.
On-site Reuse and Recycling
On-site reuse and recycling cover the processes of reusing and recycling at the same place where an activity has taken place. Reuse is the re-employment of products or materials in their original form or in new applications, with refurbishing to original or new specifications as required. Recycling is the extension of the effective life span of renewable and non-renewable resources through changes to processes or practices and the addition of energy inputs. When it is conducted in an environmentally sound manner, recycling is preferable to end-of-pipe treatment. Effective reuse and recycling requires a different perspective, which views non-product outputs (waste) as a loss of valuable process materials that, if reused or recycled, could have significant environmental and economic benefits. Materials that can typically be reused and recycled include raw materials, chemicals and treated and untreated wastewater. Specific examples of process changes include recovering metals by ion exchange or reverse osmosis; recycling cooling water; and reusing trim and cuttings from paper making or plastics moulding in on-site production, rather than sending the trim off-site for waste disposal.
An example of On-site Reuse and Recycling:
Bowne of Canada Ltd., specializing in document management and print solutions, underwent a pollution prevention assessment which identified numerous opportunities to recycle on-site wash water, fountain solution, and spent solution from the Pre-press (Computer-to-Plate Processor) and Press areas. Three new equipment systems for on-site recycling were installed eliminating 90% of the hazardous waste generated that previously had to be hauled off-site for disposal, reducing water consumption by over a thousand tonnes, and significantly reducing the quantities of chemicals and solvents that need to be purchased.
For more information and guidance, please see Appendix I.
Co-operative P2 Action
In some cases, pollution prevention can be enhanced by co-operative action among two or more facilities. For example, neighbouring facilities in unrelated businesses or activities can co-operate either by developing joint infrastructure or by arranging themselves so that one company uses the other's non-product output as an input. Known as "industrial ecology," these types of co-operative initiatives can be valuable, particularly where on-site pollution prevention options are not feasible. In many cases, however, organizations will have opportunities to implement pollution prevention through simple and cost-effective methods that are within the control of the plant manager.
An example of Co-operative P2 actions:
A partnership between the City of Edmonton and Petro-Canada involved pilot testing a membrane technology to enhance the quality of the city's wastewater effluent so that it could be used at the Petro-Canada refinery.
This partnership addressed both effluent discharge and water availability concerns.
For more details click here.
Get Technical – How do I know if I am subject to a P2 Planning Notice?
Officially, Environment Canada must inform people about prevention or control actions (regulations, P2 planning, standards, etc.) being proposed or taken with respect to CEPA-toxic substances by publishing them in the Canada Gazette.
For more information on the notification/consultation process for P2 Planning Notices consult the Frequently Asked Questions document.
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