Model Pollution Prevention Plan

Introduction

Purpose

This model pollution prevention (P2) plan is one of a series of documents that complement  the Pollution Prevention Planning Handbook. The handbook describes methods that may be used to prepare a pollution prevention plan consistent with this model plan. It is an important companion document to this model plan.

This model pollution prevention plan provides an example of the types of information that should be included in an effective pollution prevention plan. It has been structured to help organizations develop and document an effective P2 plan, and help those who are responding to a P2 Planning Notice under the Canadian Environmental Protection Act, 1999 (CEPA 1999).

This model plan does not represent the only method for preparing and documenting a pollution prevention plan, and is intended for illustrative purposes only. The advice presented here represents generic advice on “best practices.” While pollution prevention can provide significant benefits to organizations regardless of their size and nature of operations, the precise sequence, level of effort, scope of analysis and options reviewed will vary from facility to facility. Each organization should therefore adapt the advice to its own circumstances and, where appropriate, seek advice from other companies that have implemented pollution prevention, from one of the many Internet-based resources supporting pollution prevention, from government officials or from qualified consultants.

Getting Started

You can use this model plan to help you begin developing your P2 Plan. We recommend using the MS Word version of the model plan (MS Word; 330 KB), where possible. The MS Word version can be modified to suit your facility/organization’s specific requirements, while the structure and tables of the HTML version are fixed in place and unalterable.  If you choose to use the HTML version, print each page after you complete it. Your information will not be saved online: if you do not print your pages, you will lose all your inputted information. 

Please note that:

• Italicized text provides instruction and clarification at the beginning of most sections. This text should be removed from your final plan once you have read the information and entered the required information for each section. Note: in the HTML version, this explanatory text is in a box under most of the section headers.  
• Examples are provided for many sections to give you an idea of the type of information or statements that should be included. You may use these examples tailoring them to your P2 plan and facility or organization. The examples should be removed from your final plan once you have entered the required information for each section.
• Sample tables allowing you to summarize the information for your P2 plan have also been developed. Tailor the tables as required using data for your own plan. Examples of measurements on an annual basis and in metric units of mass and volume have been provided in a number of different tables and figures. It is expected that organizations referring to this template will adopt the units and use the tables that make the most sense for their operations.
• While this plan presents material in a logical order, the sequence of the sections does not necessarily represent the order in which work will be performed during the planning process. For example, objectives and targets will likely only be set following collection and analysis of baseline data.
• Throughout the document we have written in bold font the terms Declaration of Preparation or Interim Progress Report to help you easily identify where your P2 plan data may be used when you are completing and submitting your Declarations or Interim Progress Reports to Environment Canada.

Now that you are aware of some of the aids that has been provided in this model plan, you should also ensure you have the following documents on hand to assist you in developing your P2 plan:

1. P2 Planning Handbook – the handbook provides an overview of pollution prevention; outlines the steps of the P2 planning process and for preparing your P2 plan, and provides detailed information on pollution prevention practices.
2. P2 Planning Fact sheets – the fact sheets provide concise information regarding pollution prevention practices, techniques and the preparation of a P2 plan.
3. P2 Planning Notices (for which you are subject) – the Notice will clearly state who is subject to the Notice; the deadlines for preparing and implementing your P2 plan; the on-line reporting deadlines for the Declarations; and examples of the on-line Schedules that you are required to complete.

This pollution prevention (P2) model plan was prepared, pursuant to section 61 of the Canadian Environmental Protection Act, 1999 (CEPA 1999), for the purpose of providing guidance to persons subject to Pollution Prevention Planning Notices, published by the federal Minister of the Environment (Environment Canada). Additional background information and considerations have been included in the model plan for guidance purposes and are not necessarily explicit requirements of the P2 Planning Notice. As such, the length, content and layout of the P2 model plan should not be construed as an expectation of the requirements of the P2 Planning Notice. The model plan is not intended to provide legal advice, nor is it intended to replace expert legal or environmental advice. As you reference this model plan, please also refer to the Schedules in the relevant P2 Planning Notice to see samples of the reporting forms.

Every attempt has been made to ensure that the information in the P2 model plan is accurate. However, this model plan has been prepared for convenience and guidance purposes only; the information may not be transferable to all situations. For all purposes of interpreting and applying the P2 Planning Notice requirements, refer to the P2 Planning Notice and CEPA 1999. In the event of discrepancies between the model P2 plan and CEPA 1999 or the P2 Planning Notice, CEPA 1999 and the P2 Planning Notice will prevail.

Table 1: Summary of Facility Information

Persons or Class of Persons Subject to the P2 Planning Notice:
Name:

Facility Subject to the P2 Planning Notice:
Name:
Street Address of Facility:
City: Province/Territory: Postal Code:

Contact Information at Facility:
Telephone Number:
Email (if available):
Mailing Address (if different from Street Address):

Contact Information of Persons with Signing Authority for the Declarations:
Name:
Position at Facility:
Telephone: Fax:
Email:

Accountable Manager for the P2 Plan:
Name:
Position at Facility:
Telephone: Fax:
Email:

Technical Contact:
Name:
Position at Facility:
Telephone: Fax:
Email:
North American Industry Classification System (NAICS) 2002:
National Pollutants Release Inventory Identification Number (NPRI ID):

2.1 Statement of Support from Management
2.2 Corporate Policy, Principles and Commitments
2.3 Status of Environmental Management System
2.4 Use of Plans Prepared or Implemented for Another Purpose
2.5 Pollution Prevention (P2) Planning Team

2.1 Statement of Support from Management

is committed to preventing or reducing adverse environmental impacts of its operation.

We will achieve this objective by:

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

Signature of CEO ____________________________ 

Facility Name ____________________________

Date ______________________________

2.2 Corporate Policy, Principles and Commitments

The is committed to integrating environmental considerations into its through adherence to the following policy/principles:

_________________________________________________________________

_________________________________________________________________

_________________________________________________________________

_________________________________________________________________

_________________________________________________________________

_________________________________________________________________

2.3 Status of Environmental Management System (EMS)

2.4 Use of Plans Prepared or Implemented for Another Purpose

has prepared and/or implemented a P2 plan for another purpose. The plan was prepared for on .

has not prepared and/or implemented a P2 plan for another purpose.

2.5 P2 Planning Team

In addition to the fulltime members of the P2 Planning team, additional personnel are brought in as needed. These advisors could include consultants, suppliers, purchasing department, and legal department etc. You may also be able to include members from a ‘green team’ if it exists at your facility.

3.1 Scope and Objectives of the Pollution Prevention (P2) Plan
3.2 Activities and Pollutants Covered by this P2 Plan
3.2.1 Pollution Prevention Targets
3.2.2 Other Initiatives
3.3 Milestones and Deadlines

3.1 Scope and Objectives of the Pollution Prevention (P2) Plan

The scope and objectives of this P2 Plan have been specified in the P2 Planning Notice published by Environment Canada. Information detailing how the P2 Plan will meet the Risk Management Objective of the P2 Planning Notice is required in the Declaration of Preparation.

The overall objective of this P2 Plan is to ______________________________________

_________________________________________________________________________

_________________________________________________________________________.

3.2 Activities and Substances Covered by this P2 Plan

This P2 Plan is developed in relation to ________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

3.2.1 Pollution Prevention Targets

3.2.2 Other Initiatives

supports the vision that an overall P2 approach for a facility is environmentally sound and potentially economically viable, and has initiated other pollution prevention activities in relation facility operations. These initiatives include:

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

3.3 Milestones and Deadlines

The P2 Planning Notice specifies the dates for which various activities are to be completed, objectives met, as well as Declarations submitted to Environment Canada with respect to the preparation and implementation of the P2 Plan.

The dates of specific concern for are listed in Table 3. is committed to meeting these deadlines.

4.1 Baseline Review
4.2 Identification of Information from Preparation Year
4.2.1 Process Flow Diagram
4.3 Inventory of Substances Used, Transferred by the Facility
4.3.1 Nature of Activity
4.3.2 Quantity of Substance Used
4.3.3 Quantity of Substance Released (Air, Water, Land)
4.3.4 Quantity of Substance Transferred (Product Distribution, Disposal, and Recycling)
4.4 Material Flow and Mass Balance
4.4.1 Material Flow Diagram
4.4.2 Mass Balance
4.5 Summary of Possible Stakeholder Concerns

4.1 Baseline Review

undertook a baseline review of . The following tables and diagrams summarize the data and information.

4.2 Identification of Information from Preparation Year

The P2 Planning team identified that sufficient information was available from our records during the period January 1 - December 31, 20__, to establish the Preparation Year as 20___ for the purposes of this P2 Plan.

4.2.1 Process Flow Diagram

4.3 Inventory of Substances Used, Transferred by the Facility  

4.3.1 Nature of Activity

4.3.2 Quantity of Substance Used

4.3.3 Quantity of Substance Released (Air, Water, Land)

4.3.4 Quantity of Substance Transferred (Product Distribution, Disposal, and Recycling)

4.4 Material Flow and Mass Balance

4.4.1 Material Flow Diagram

Material flow diagrams provide a summary of how the substance is used at your facility and will help to clarify the precise source, quantities, or causes of losses for each unit process.  The P2 Planning Handbook, Appendix B, "Key Elements of a Baseline Review” provides key advice on preparing a material flow diagram.

Insert or attach a material flow diagram for your facility or process. 

4.4.2 Mass Balance

4.5 Other Relevant Legal Requirements

has identified other potential legal requirements or government initiatives which may affect any business decisions related to responding to the P2 Planning Notice as follows:

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

4.6 Summary of Possible Stakeholder Concerns

has identified various stakeholders who may be affected by how responds to the P2 Planning Notice and their possible concerns. These are summarized as follows:

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

5.1 Identification of Pollution Prevention or Environmental Protection Methods
5.2 Evaluation and Selection of Actions
5.2.1 Summary of Costs to Implement the Proposed P2 Plan Actions
5.2.2 Summary of Proposed Resources and Funds to Implement the P2 Plan
5.2.3 Technical, Business and Environmental Considerations
5.2.4 Evaluation and Selection of Proposed Actions
5.3 Detailed Anticipated Results Using the New Method(s) to Address the Risk Management Objective in the P2 Planning Notice

5.1 Identification of Pollution Prevention or Environmental Protection Actions

5.2 Evaluation and Selection of Actions

As part of the evaluation process to assess the proposed methods, reviewed the economic, environmental, technical and social implications of each proposed action.

5.2.1 Summary of Costs to Implement the Proposed P2 Plan Actions

5.2.2 Summary of Proposed Resources and Funds to Implement the P2 Plan

5.2.3 Technical, Business and Environmental Considerations

5.2.4 Evaluation and Selection of Proposed Actions

The action(s) selected by to meet the Risk Management Objectives of the P2 Planning Notice is/are:

Action #1: ________________________________________________________________

__________________________________________________________________________.

Action #2: ________________________________________________________________

__________________________________________________________________________.

5.3 Detailed Anticipated Results Using the Selected Action(s) to Address the Risk Management Objective in the P2 Planning Notice

Repeat for each action selected to meet the Risk Management Objective and Factors to Consider of the P2 Planning Notice.

Action #1: _____________________________________________________________

Objective: _______________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

Target: _________________________________________________________________

_________________________________________________________________________

Measure: ________________________________________________________________

_________________________________________________________________________

Benefits: ________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

Repeat for each activity identified in your plan.

7.1 Monitoring and Reporting
7.2 Monitoring Program and Data
7.3 Reporting Progress on the Pollution Prevention (P2) Plan

7.1 Monitoring and Reporting

will undertake monitoring and reporting activities in relation to the P2 Plan. Monitoring and reporting will become integrated into the normal reporting practice at and the will be provided monthly updates.

7.2 Monitoring Program and Data

7.3 Reporting Progress on the P2 Plan

Reports to Environment Canada will be required as part of the P2 Planning Notice. The reporting timelineand information required by the P2 Planning Notice are presented in Table 4. is committed to these timelines.

8.1 Review and Evaluation
8.2 Review and Evaluation Plan
8.3 Record of Revisions Made

8.1 Review and Evaluation

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

8.2 Review and Evaluation Plan

Review and evaluation will be integrated into the current monthly reporting activities and will be shared with appropriate employees at .

8.3 Record of Revisions Made

A record of any revisions made will be detailed in the monthly report to the . Where the information in the Declarations have become false or misleading, an amended report will be filed to the Minister of the Environment within 30 days after the time that the information becomes false or misleading.

As per the requirements of the P2 Planning Notice, the plan will be implemented no later than . The actual date estimate for to finalize the implementation of this P2 Plan as required by the P2 Planning Notice is . Once the Plan is implemented, a Declaration of Implementation will be submitted to Environment Canada containing all the required information on or before .