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Pollution Prevention Planning Provisions of Part 4 of the Canadian Environmental Protection Act, 1999: Frequently Asked Questions

Section 3: Developing and Implementing a P2 Plan

23. What format should the P2 plan be in?

A P2 plan may be prepared in whatever format makes the most sense for an organization (or facility) as long as the plan meets all the requirements in the Notice and includes information required to complete the declarations and reports. The model plan that Environment Canada has prepared is posted on the Pollution Prevention Planning website in the Pollution Prevention Planning Handbook.

24. Where can I learn how to develop and implement a P2 plan?

Depending on the Notice, sample P2 plans or templates may have been developed. In addition, Environment Canada has developed a handbook which provides information on the P2 planning process, a model plan template, and detailed information on pollution prevention practices and analytical techniques.

Other sources of information include:

  • Pollution Prevention Planning website: This website contains information on P2 planning and tools such as a P2 Planning Tutorial. This site also contains the Environment Canada Pollution Prevention Planning Database. This is a searchable database; users can find the declarations that facilities have filed in accordance with specific Notices.
  • Canadian Pollution Prevention Information Clearinghouse (CPPIC): This site contains an online searchable database with over 1600 P2 resources as well as P2 planning handbooks.

25. Do I have to get a consultant to prepare and implement the P2 plan?

Using in-house resources to prepare and implement the P2 plan will create a knowledge base within your facility and promote learning about the P2 concept. This information can then be used to identify other opportunities to reduce pollution or address other issues of concern. However, the choice of whether to hire a consultant to assist in the preparation or implementation of a P2 plan is an individual choice. Environment Canada does not maintain a list of consultants. Persons are encouraged to do their own research for professional organizations, environmental consulting firms, or applicable industry associations.

26. I already have a P2 plan. Do I have to make another one?

Those subject to a Notice who already have a P2 plan or environmental management system (EMS) in place must evaluate the current plan or system to determine if it meets all the requirements set out in the Notice. If the plan does meet all the requirements of the Notice, it is not necessary to make a new plan; however, the required information (Schedules 1, 4 (if necessary), and 5 of the Notice) will need to be filed as usual.

If your current plan or system doesn't meet all the requirements of the Notice, it can be amended or an additional P2 plan that covers the remainder of the requirements of the Notice can be prepared. These provisions are set out in section 57 of CEPA 1999.

27. Can I use the same P2 plan to address more than one substance?

Yes. A facility may have a single P2 plan that addresses all potential pollutants and wastes.

28. What aspects of the operation do I have to include or reference in the P2 plan?

The scope of the activities to be included in the P2 plan is outlined in each Notice under section 3 – "Activities in relation to which the plan is to be prepared". An example is "...all activities involving manufacturing, storage and handling of substance X". Activities that are not outlined in the Notice do not need to be addressed in the plan. However, the person subject to a Notice may make a plan that is broader in scope than the factors to be considered and the risk management objective set out in the Notice. For more information on factors to be considered see question 7; for more information on risk management objectives see question 6.

29. When must the implementation of the P2 plan begin?

The implementation of the P2 plan should begin immediately after the P2 plan has been prepared. When a person files a Declaration That a P2 Plan Has Been Prepared and Is Being Implemented under Schedule 1 of the Notice, the person is declaring that the plan is being implemented. At a minimum, a P2 plan must be prepared and implementation of the plan must be started by the date specified in the Notice.

30. When is the implementation of the P2 plan considered complete?

A P2 plan will be considered fully implemented when all activities or elements listed in the P2 plan have been put into effect.