Model Pollution Prevention Plan

Identification of possible pollution prevention or environmental protection actions which can be used to meet the Risk Management Objectives is the first step. Try to include, as a priority, the pollution prevention (P2) actions which provide the greatest ability to eliminate the substances of concern at the source, which will reduce your liability and further costs associated with managing these substances. P2 actions may be organized into the following categories:

• Material or feedstock substitution
• Product design or reformulation
• Equipment or process modifications
• Spill and leak prevention
• On-site reuse, recycling or recovery
• Inventory management or purchasing techniques
• Good operating practices or training

Different pollution prevention actions may be required to address different types of issues. For example, issues related to products are generally addressed through product redesign, or elimination and substitution of toxic substances. Additional information on Pollution Prevention methods is available in the P2 Planning Handbook Appendix D – I.

Where the facility has investigated P2 actions and still finds that other types of environmental protection actions may be more promising at this time, these also should be noted in the P2 Plan. The other types of environmental protection actions may include:

• Energy recovery
• Off-site recycling
• Incineration with energy recovery
• Waste treatment
• Pollution control
• Disposal
• Other

Information in this section may be required in the Declaration of Preparation, Anticipated Actions and Results.

Careful consideration and selection of your proposed actions will be a critical step of a successful P2 Plan. By identifying the most appropriate P2 or environmental protection actions for your facility you may be able to save money and/or reduce your liability. Section II (Part 1) of the P2 Planning Handbook, "What is Pollution Prevention Planning", describes relevant considerations when identifying, evaluating and selecting options. You may be required to report these actions in the Declaration of Preparation, Anticipated Actions and Results.

A detailed evaluation of costs to purchase and use the proposed actions identified is required as part of this evaluation process. A summary of the costs associated with each of the proposed actions being evaluated is presented in Table 13.

Information on the required resources identified for the implementation of the P2 Plan could be reviewed for funding by potential government agencies.

The resources which have been identified to implement this P2 Plan, and sources of funding, are outlined in Table 14.

In order to compare the proposed actions, each action is assessed according to criteria agreed upon by the P2 Planning team. These criteria can be weighted to allow a systematic ranking of the actions, and the selection of the preferred action(s).

Your criteria can include:

Technical Considerations

• P2 option is well established and accepted
• P2 option can be easily implemented
• P2 option achieves desired results
• Acceptance by stakeholders

Economic Considerations

• Capital cost of P2 action
• Operating cost

Environmental Considerations

• Potential to meet objective
• P2 option is compatible with other environmental objectives (province, municipality etc)

Social Considerations

• P2 option decreases health and safety risks to employees

Evaluate and rank the proposed actions, and then select the highest ranked action(s). 

The selected action(s) will be implemented to meet the Risk Management Objective in the P2 Planning Notice. Table 16 provides a summary of what the anticipated results would be if this/these action(s) was/were implemented.

This information may be required in the Declaration of Preparation, Anticipated Actions and Results.