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Canadian EHS Management Update: New "D4" Pollution Prevention Plan

EHS Management: Pollution Prevention PlanAttention Canadian Manufacturers:

The Federal Government has recently published a new regulation on June 2, 2102 that may require you to prepare and implement a pollution prevention plan for Cyclotetrasiloxane, octamethyl- (siloxane D4). The goal of this regulation is to reduce the total quantity of released D4 in Canada by 80%.  This chemical is a schedule 1 chemical (List of Toxic Substances for CEPA).

You may be affected if...

You are required to create and implement a Cyclotetrasiloxane, octamethyl- (siloxane D4) plan if you meet all of the following criteria:

  • Your facility manufacturers or uses D4, or a mixture containing D4, and the total quantity of D4 manufactured or used is at least 100 kg per calendar year, and;
  • As a result of your D4 use, your processes release an effluent containing D4 at any discharge point.

However, you are exempt from this requirement if your effluent releases have a D4 concentration of no more than 17.3 µg/L, or you use D4 exclusively in a mixture with a D4 concentration of less than 1%, or if the D4 is exclusively  in solid materials like rubber or wire insulation.

The D4 Deadlines

The deadline for the creation D4 Pollution Prevention Plans is June 1, 2013. You will also need to begin the initial implementation of your plan by this deadline.

Your D4 plan must be fully implemented by June 1, 2017.

And if your facility did not begin operations until after the June 2, 2012 publication in the Canada Gazette, you have 12 months from the day you become subject to this regulation to create your D4 plan, and 60 months to have it fully implemented.  

You will also need to produce a Preparation Notification that you have made and have begun developing a plan within 30 days of your first 12 month deadline, and an Implementation Notification must be submitted within 30 days of your 60 month deadline.

The Responsibilities

Your Cyclotetrasiloxane, octamethyl- (siloxane D4) Pollution Prevention Plan must address your policy on reducing D4 in effluents due to the manufacture of D4 and the use of D4, including use in mixtures.

It must also include a description and location (mapped out) of each final discharge point, in addition to a description of the factors (like technology or accidental releases) that could increase the quantity or concentrations of D4 in your effluent.

You must keep a copy of your plan for 5 years, in each of your facilities that falls under the plan. You may decide to create a separate plan for each facility, or one comprehensive plan for each of your facilities, as long as a copy is available at each one.

It is up to you to determine what the actual content of your plan will be, however, whatever you decide is most appropriate for your facility must achieve at least one of these 2 primary goals:

  • Your total concentration of D4 in all effluents must be no more than 17.3 µg/L using methods other than dilution.
  • Your overall quantity of released D4 is no more than 3 kg/year.

As part of your D4 plan, you are required to perform routine testing and sampling of your effluents. These samples should be taken a minimum of four times a year at each final discharge point in your facility, and should be representative of the highest expected concentration of D4 at each final discharge point.  Your sampling and testing methodologies must conform with generally accepted standards of good scientific practice.

Once you have achieved the reduction goals laid out in your plan, you must also include an additional year of monitoring and analysis of your D4 releases.

Your plan should also include the use of alternatives to D4 in order to reduce environmental and human health risks.

Finally, you are also required to submit three Interim Progress Reports to the Minister of Environment:

  • The first report is due July 1, 2014 (or 25 months from the date of becoming subject to this regulation)
  • The second report is due July 1, 2015 (or 37 months from the date of becoming subject to this regulation)
  • The third report is due July 1, 2016 (or 49 months from the date of becoming subject to this regulation)

Getting an Extension

If you are unable to comply with any of the requirements of this regulation within the Canadian government’s timeframe, you may apply for an extension. You must apply for an extension before your applicable deadlines, and the length of your extension will be decided upon by the Minister of the Environment.


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Other ERA Resources for Canada:

4 Greenhouse Gas Reporting Lessons from Canada & Kyoto

Understanding Canadian Greenhouse Gas Emissions Reporting

EHS Systems: Canadian Environmental Assessments Slated for Updates

(Image credit: The Seafarer)

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This post was written by Alex Chamberlain

Alex Chamberlain is a writer for ERA Environmental Management Solutions.

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