Pollution Prevention (P2) Plans

Part 4 of the Canadian Environmental Protection Act, 1999 (CEPA 1999) gives the Minister of the Environment the authority to require the preparation and implementation of pollution prevention plans (P2 plans) for CEPA 1999 toxic substances (substances that have been added to Schedule 1 of CEPA 1999). To invoke these requirements, the Minister publishes Notices in the Canada Gazette, Part I, requiring persons to prepare and implement P2 plans for a substance or group of substances. Guidelines have been prepared to describe the circumstances under which the P2 planning provisions in Part 4 of CEPA 1999 will be implemented.

Pollution prevention is defined in CEPA 1999 as "the use of processes, practices, materials, products, substances or energy that avoid or minimize the creation of pollutants and waste and reduce the overall risk to the environment or human health." Pollution prevention planning is a systematic, comprehensive method of identifying and implementing pollution prevention options to minimize or avoid the creation of pollutants or waste. The plan would also identify recycling, treatment and other measures needed to meet environmental goals.

The Canada Gazette P2 Notices will not prescribe the form of P2 plans. Affected persons may prepare a plan in the form which makes most sense for their facility, so long as the plan:

• addresses the "factors to consider" identified in the P2 Notice;
• complies with the timelines in the P2 Notice; and
• contains all the information required to complete the declarations and other forms.

In order to be most effective, P2 plans could be expected to contain the following elements:

• a senior-level sign-off;
• the designation of an accountable senior manager for the plan;
• a clear statement of the risk management (and other) objectives for the plan;
• a schedule for meeting those objectives;
• a review of all significant aspects of the management of the substance (including purchasing, processing, producing, generating, distributing, treating, disposing, storing, or releasing of the substance);
• an identification, review and selection of options;
• a plan and schedule for implementing the selected options;
• a plan for measuring, tracking and evaluating the success of the selected options and for implementing corrective and preventative measures;
• a plan for reporting on progress towards the plan's objectives; and
• a continual improvement program.

A person subject to a P2 Notice requiring the preparation and implementation of P2 plans must submit the following according to the timelines set in the published Notice.

• Declaration of Preparation
• Declaration of Implementation
• Interim Progress Reports (as required)

A person subject to such a Canada Gazette Notice does not submit the P2 plan itself, unless the Minister requests that P2 plans be submitted for the purposes of determining and assessing further preventive or control actions (Section 60 of CEPA 1999).

Persons subject to the Canada Gazette Notice may also apply for:

• Time Extensions
• Waivers for "Factors to Consider"

Published Canada Gazette Notices requiring P2 plans

Notice Requiring the Preparation and Implementation of Pollution Prevention Plans for Inorganic Chloramines and Chlorinated Wastewater Effluents.

• More Pollution Prevention Planning Notices

You can also search for posted documents related to these Notices in the Notices section of the CEPA Registry.

Many information support tools have been developed to assist persons that are subject to a Canada Gazette Notice requiring P2 plans:

• Instructions for completing the Schedules related to each P2 planning Notice and additional information to support each Notice are available on the National Office of Pollution Prevention website.
  
  
• Guidelines for the Implementation of the Pollution Prevention Planning Provisions of Part 4 of the Canadian Environmental Protection Act, 1999 (CEPA 1999)
  This document describes the circumstances under which the P2 planning provisions in Part 4 of CEPA 1999 will be implemented. Included are a sample Canada Gazette Notice and templates for submissions to Environment Canada of declarations and other documents from persons subject to a notice.
  
  
• Frequently Asked Questions
  This document is designed to help facilities understand their obligations under CEPA 1999 when subject to a requirement to prepare and implement a P2 plan. It describes, in a question and answer format, how the provisions under Part 4 of CEPA are administered and what affected parties must do.
  
  
• Pollution Prevention Planning Handbook
  This handbook provides an overview of pollution prevention (P2), information on the P2 planning process, a model plan template, and detailed information on pollution prevention practices and certain analytical techniques for preparing a P2 plan.
  
  
• Pollution Prevention Planning Fact Sheet Series
  Several pollution prevention(P2) fact sheets have been developed covering topics including the basics of P2 planning and CEPA 1999 Part 4, as well as P2 activities and best practices.

For more information about pollution prevention in general, browse through the Canadian Pollution Prevention Information Clearinghouse.

Contact:
CEPA Implementation and Innovation Division
National Office of Pollution Prevention
Environment Canada
351 St. Joseph Blvd.
Gatineau, QC K1A 0H3
Phone Number: (819) 994-0186
Facsimile: (819) 953-7970
e-mail: CEPAP2Plans@ec.gc.ca
Website: National Office of Pollution Prevention