|
Guidance document for
responding to the Questionnaire
that forms part of the
Challenge
The following document provides guidance for responding
to the Challenge questionnaire. The questionnaire has been issued in order to
provide organizations the opportunity to supply new information about how it is
managing the 193 chemical substances that have been prioritized, due to their
potential hazard to the environment or human health, following the
categorization exercise. The hazard potential was determined based upon
criteria that they may present to individuals in Canada, the greatest risk for
exposure (GPE) or are “inherently toxic” to humans, and/or have
properties of persistence, bioaccumulation and aquatic toxicity (PBiT). A need
for action was identified as a result of the properties exhibited by these
substances. The
purpose of the Challenge is to collect new information from stakeholders
manufacturing, importing or using the substances, including information on the
sectors using the substances, the use patterns, existing management practices,
release and exposure pathways, potential substitution options, substance
analysis methods and financial implication of elimination of the
substances. This
information will then be used to identify industrial best practices, in order to
set benchmarks for risk management and product stewardship. Information for Completion of
the Challenge Questionnaire
- How do I know if I am subject to the Challenge
questionnaire?
- How do I respond if I have more than one
facility?
- How do I fill this questionnaire out?
- Information you may reasonably be expected to have access
to
- Confidentiality requests
- What is the deadline for response and where do I send the
completed questionnaire?
- Inquiries?
- Section by section explanations of the information being
requested in the questionnaire
| 1. How do I know if I am subject
to the Challenge Questionnaire? |
This Challenge is aimed at organizations that have
manufactured, imported, exported, or used, whether alone, in a mixture or in a
product, including manufactured items the substances as identified in the
Challenge as announced in the December 9, 2006 Notice of Intent. The full list of substances is available on
the Government of Canada’s chemical portal: http://www.chemicalsubstanceschimiques.gc.ca/en/index.html.
Definitions:
For
the purpose of this questionnaire, the definitions are provided below.
“calendar year” means a period of 12
consecutive months commencing on January 1st.
“import” includes movement into Canada,
including internal company transfers across the Canadian border, but does not
include transit through Canada. “Import” then relates specifically
to the movement into Canada of any of the substances or any mixture, product or
manufactured item that contains such a reportable substance. Your activities do not meet the definition of “import” if you, your company
or other body purchased or received the substance or a mixture, product or
manufactured item containing the substance that was already located in
Canada.
“manufacture” includes to produce or prepare
a substance; and also includes the incidental production of a substance at any
level of concentration as a result of the manufacturing, processing or other
uses of other substances, mixtures, or products.
“manufactured item” means an item that is
formed into a specific physical shape or design during manufacture and has, for
its final use, a function or functions dependent in whole or in part on its
shape or design, including clothing, empty storage containers, electrical gear
and appliances or parts thereof, office and consumer electronics or parts
thereof, tapes, tiles, electrical wire, fabric, fibres, empty containers, foam
slabs or shapes and plastic film, pipes, tubes or profiles, plywood, brake
linings, fibres, leather, paper, yarns, dyed fabric, matches, flares,
photographic films, and batteries.
“mixture” means a combination of substances
that does not produce a substance that is different from the substances that
were combined, including a prepared formulation, hydrate, and reaction mixture
that are fully characterized in terms of their constituents (e.g. paints,
coating, solvent mixtures, azeotropic and zeotropic refrigerants, mixture that
is under pressure and that is used for personal care, pharmaceutical, medical,
household, laboratory, commercial or industrial.).
"release" - means the emission or discharge of a
substance from the facility site to air, land, or surface water, including
discharges to municipal wastewater treatment plants.
“transit” means the portion of an
international transboundary movement through the territory of a country that is
neither the country of origin nor the country of destination of the
movement.
If your organization has not
manufactured, imported, exported, or used, whether alone, in a mixture or in a
product, including manufactured items, the substances (as published on the
chemical portal http://www.chemicalsubstanceschimiques.gc.ca/en/index.html),
then complete the facility information (sections 1.0 and 1.1) and the
certification (section 10.0) and mail these to the address provided in
question 6.
| 2. How do I respond if I have
more than one facility? |
Responses to the questionnaire should be submitted
on an organization-wide basis. Individual facility data should be consolidated
into one questionnaire and submitted on behalf of the entire organization. For
each substance listed in the Challenge, that your organization manufactured,
imported, exported, or used, whether alone, in a mixture, or in a product,
including manufactured items, complete sections 2.0 through 9.0 separately and
include data representing each of your organization’s facilities. Each of
the facilities submitting data to this questionnaire should be listed in section
1.1 along with the facility name, address, etc. The first column of section 1.1
provides a Facility ID letter that will correspond to the (facility) information
entered on that line. This Facility ID should be carried forward for the
remaining questions in the questionnaire should be used for the questions asking
for individual facility data. That is - the facility listed on the first line
has been assigned Facility ID “A” and this facility should enter its
data for the applicable sections on the lines for Facility ID “A” throughout the questionnaire.
| 3. How do I complete the questionnaire?
|
Start on the first page of the questionnaire, at
section 1.0, and proceed to answer the questions in order, following the
directions provided at each question. If the question is not applicable to your
facility, it will direct you to the next appropriate sections to complete.
| 4. Information you may reasonably
be expected to have access to. |
You are requested to provide information that your
organization possesses or to which you may reasonably be expected to have
access. For example, when importing a substance, mixture or product, you may
reasonably be expected to have access to the relevant Material Safety Data Sheet
(MSDS). An MSDS is an important source of information on the composition of a
purchased product. Note that the goal of the MSDS is to protect the health of
the workers, not the environment. Therefore, an MSDS may not list all product
ingredients that the Government is requesting information on. You can contact
your supplier for more detailed information on product composition. Also, a facility may reasonably be expected to
have access to its parent organization’s information regarding substances,
mixtures or products. Information
regarding substance release, manufacture, import and export is being requested
for the calendar year(s) for which your organization has data and information
available. Financial data is being requested for a five year period
(2002-2006).
| 5. Confidentiality Requests
|
The Government of Canada is predisposed to be open
and transparent; however, if you wish to have sections of your data remain
confidential you must complete section 10.0 for each substance, listing the
section of data for which you are requesting confidentiality and providing
justification for each section requested. Pursuant to section 313 of CEPA 1999,
any person who provides information in response to the Questionnaire may submit,
with the information, a written request that it be treated as confidential. A request for confidentiality may be submitted
for any information item provided on a particular substance in response to the
Questionnaire. When requesting confidential treatment by Environment Canada of
information provided under the Questionnaire, you must provide some
justification for your request. Justification may be provided, for example,
based upon the following considerations:
- The information is confidential to your
organization;
- Your organization has taken, and intends to
continue to take, measures that are reasonable in the circumstances to maintain
the confidentiality of the information;
- The information is not, and has not been,
reasonably obtainable by third persons by use of legitimate means, except with
the consent of your organization;
- The information is not available to the
public;
- Disclosure of the information may reasonably be
expected to cause substantial harm to the competitive position of your
organization;
- Disclosure of the information may reasonably be
expected to result in a material financial loss to your organization or a
material financial gain to your organization’s
competitors.
Upon receipt of a request for
confidentiality under section 313 of CEPA 1999, in relation to information
submitted pursuant to the section 71 Questionnaire of CEPA 1999, the Minister of
the Environment will not disclose that information, except in accordance with
section 315, 316 or 317 of CEPA 1999.
| 6. What is the deadline for response
and where do I send the completed questionnaire? |
The Government of Canada will be moving forward with
risk management activities six months after batch publication dates, based on
the information received. Completed questionnaires should be sent
to:
Environment
Canada
DSL Surveys
Coordinator
Place Vincent Massey, 20th
Floor
351 Saint Joseph
Boulevard
Gatineau, QC K1A
0H3
Email: DSL.surveyco@ec.gc.ca
| 7. Who do I contact if I have
questions related to the Challenge questionnaire? |
If you have an inquiry, please contact the DSL
Surveys Coordinator at the following numbers or email address: 1-888-228-0530
/ 819-956-9313 email: DSL.surveyco@ec.gc.ca
| 8. Section by section explanation
of the information being requested in the questionnaire |
The following tables provide detailed explanations
for each of the questions being asked, in addition to definitions of the terms
used in the questions. The table layout begins at section 1.0 and continues in
order, corresponding to the questionnaire layout. If you are providing
information in paper format, and do not have enough space to fully answer the
question, please do not hesitate to attach further documentation or explanation
for required sections as necessary. In the
following tables, the left hand column corresponds to the column names in the
questionnaire.
| Section 1.0 Information
on the Person or Class of Persons Subject to the Challenge |
|
The information requested in this section is to be completed by
the parent organization for each substance the organization and its
facilities has manufactured, imported or used, whether alone in a mixture
or in a product, including manufactured items.
|
| Name of the Organization Subject
to the Challenge |
Enter the organization name. If you
own or operate more than one reporting facility, provide the parent
organization information in section 1.0 and list all subsidiaries in
section 1.1. If your parent organization is the only facility, complete
section 1.0 and enter your organization information as Facility “A”
in section 1.1. |
| Street Address of Facility, City,
Province/Territory, Postal Code |
Enter the street name and number
and other identifiers such as suite number or building designation (for
example, Building A). For rural addresses, where a street address is
not available, enter the lot and concession numbers. Enter also city,
town, village, district or township, the province or territory, and
the postal code where the organization is located. Do not use
a post office box or mailing address (if different from the street address)
as the street address. |
| Member of Association(s) |
If you are a member of an association
(Chemical Association, etc) please provide the name. This information
will help direct efforts if there are consultations on the management
of the substance. |
| Number of years Organization has
been in operation |
Indicate the number of years the
organization (not individual facility) has been in operation. |
| Business Size |
The information is based on the number
of full-time workers employed by the organization. The purpose of the
question is to ascertain if any one business size dominates the industry.
This could influence the choice, as well as the design of the risk management
instrument. The question also has important implications for understanding
the economic impact of regulations. |
| Contact Information |
Enter the name, title, mailing address
and telephone number (with area code) of the organization’s contact.
If available, enter the e-mail address and facsimile number (with the
area code) also. It is recommended that the contact you provide be a
representative who can be contacted by Environment Canada for clarification
of information submitted in the questionnaire. This person should be
familiar with and able to answer questions about the information provided.
|
| Section 1.1 All
facilities covered by this questionnaire |
Indicate all facilities
operated by the parent organization, submitting data on this questionnaire.
|
| Facility ID |
The Facility ID assigned in this column
is to be used in the questionnaire when differentiating data for different
facilities |
| Facility Name |
Enter the name of the facility. If
your parent organization is the only facility, then re-enter your facility
name on the line for Facility “A” . |
| Facility Lat/Long |
Provide the Latitude and Longitude
coordinates for each facility listed. |
| NPRI #
(National Pollutant Release Inventory Identification Number) |
Facilities that submit a National
Pollutant Release Inventory (NPRI) report are assigned a permanent
NPRI ID. If this facility has an NPRI ID number, enter it here. The
NPRI ID is specific to the facility and does not change, even if the
ownership of the facility has changed. If you do not have an NPRI ID
number, leave this field blank. |
| NAICS Code
(North American Industry Classification System) |
Enter the six-digit NAICS code for
this facility. Statistics Canada provides complete details of NAICS
Canada on its website at http://www.statcan.ca/english/Subjects/Standard/naics/2002/naics02-menu.htm.
|
| Business Registration # |
This information is requested in
order to obtain exact legal titles of facilities, if required during
the implementation of risk management strategies. |
| Section 2.0 Substance
|
The information provided in this section identifies the Challenge
substance and the calendar year you are reporting on. Sections 2.0 through
9.0 should be completed (as applicable) for each substance selected.
A full list of Challenge substances can be found on the chemical portal:
http://www.chemicalsubstanceschimiques.gc.ca/en/index.html.
|
| Substance Name for which information
is being provided |
Enter the chemical name of substance
as listed in the Challenge. |
| CAS No |
Enter the Chemical Abstract Services
Number (CAS#) for the substance as listed in the Challenge. |
| Commercial Name of Substance or product
containing the Substance for which information is being provided |
Provide the commercial or trade name
of the substance or product containing the substance. |
| Calendar Year |
Indicate the calendar year for which
your organization has data and information on this substance and is
submitting to the Challenge. |
| Section 3.0 Submission
of Data to Other Sources or for Other Purpose |
| The information provided
in this section will allow the Government of Canada to determine if
there are programs that include these substances that may facilitate
benchmarking of the substance use and release. |
| If yes, provide name of program |
If you report releases to another
program list the programs here. Examples include: NPRI, a survey (section
71 under CEPA, 1999), provincial permitting programs, point of impingement
limits, NERM (National Emissions Reduction Masterplan). |
| Section 4.0 Management
Stewardship Information |
| The information provided
in this section will help the Government of Canada understand the current
risk management regimes already in place and the potential for duplication
of regulatory burden. Information on programs and practices already
in place would inform the instrument choice process. Alternatively,
if industry can demonstrate that the substance is being managed effectively;
this will guide the need for government action. |
| Current Programs, Practices, Technologies,
etc
|
Check off all that are currently
in place in your facility.
Occupational H&S – An illness, injury
and accident prevention initiative within an organization, as directed
under Part II of the Canada Labour Code, with specific requirements
outlining employee, employer duties and responsibilities, legislation,
rights, and codes.
Emergency Plans –The
details section for emergency plans should stipulate the controls in
place to manage the exposure of substances to workers, the general population
and the environment. Some companies may already have existing emergency
plans at their sites. However, the Environmental Emergency Regulations
require four components to an environmental emergency plan. The plan
must address the prevention of, preparedness for, response to and recovery
from an environmental emergency in respect of a substance.
ISO Certification – Certification
of international standards (International Organization for Standardization)
for quality management, environmental management, auditing management
and quality assurance.
Environmental Management System –
An organization’s management system used to develop and implement
its environmental policy and manage its environmental aspects. An EMS
is part of the overall management system that includes organizational
structure, planning activities, responsibilities, practices, procedures,
processes and resources for developing, implementing, achieving, reviewing
and maintaining the environmental policy.
Code of Practice/ guidelines –
Rules established by regulatory bodies or trade associations, which
are intended as a guide for acceptable practices in the industry.
Process Safety Management – The
application of management principles and systems to the identification,
understanding and control of process hazards to prevent process-related
injuries and accidents. The process safety management system suggested
by the Canadian Society for Chemical Engineering (CSChE) consists of
12 main elements – http://psm.chemeng.ca/help_guide_e.htm.
Best Management Practices – Methods
or practices that have been determined to be the most effective, practical
means of preventing or reducing pollution from non-point sources.
Best Available Technology – The
best economically achievable technology that reduces negative impacts
on the environment.
|
| Details (all) |
If the program or practices etc apply to
the substance identified in section 2.0, provide additional details including
but not limited to: name of regulations or permits, voluntary industry
practices or program, environmental management (treatment) system, code
of practice, etc. |
| Section 4.1 Potential
Action(s) |
| The information in
this section provides an indication of the feasibility of various risk
management approaches while also highlighting possible challenges for
the substance’s effective management. The details provided on
the programs and practices may enable the Government of Canada to project
a substitution strategy, control measures, or the virtual elimination
of the substance. For example, if there is a management decision to
phase-out the substance in question, information on the status of a
substitute (e.g. Research & Development, testing, registration of
substitute) would indicate how long before the objective could be achieved.
|
| Action(s) currently implemented
|
Select all Programs, Practices, Technologies
or Controls already in place in your facility.
Phase Out of Substance – Gradually reducing
the substance until it is no longer in use.
Substance Replacement / Substitution –
Replacing substances or materials used in a process or a product with
non-toxic or less toxic substances, materials and feedstock (for example,
using aqueous-based cleaners rather than solvent-based cleaners; using
a non-toxic detergent to clean glassware rather than chromic acid).
Product design or reformulation –
Reducing or eliminating the use of the substance by changing product
specifications or modifying the design or composition of products.
Equipment or process modifications –
Introducing new technologies or approaches to existing operating systems,
processes and practices to improve production efficiencies and reduce
or eliminate the substance use (for example, changing to mechanical
stripping/cleaning devices from solvents; using more efficient spray-paint
systems; instituting re-circulation within a process).
Spill and leak prevention or Containment
– Using measures to prevent accidental
and chronic releases such as leaks of a substance (for example, installing
splash guards and drip trays around equipment, such as solvent sinks,
hot tanks and jet-spray washers, to collect and return drainage and
contain leaks and spills).
On-site reuse, recycling or recovery –
Reusing, recycling and/or recovering the substance within the property
boundaries of where an activity has taken place (for example, using
a small distillation unit to reclaim solvents; recovering metals by
ion exchange or reverse osmosis).
Inventory management or purchasing techniques
– Integration of environmental considerations
into inventory management systems and into existing and new purchasing
practices (for example, avoiding the unnecessary generation of waste
by ensuring that materials do not stay in inventory beyond their shelf
life; instituting a clearinghouse to exchange materials that would otherwise
be discarded).
Extended Producer Responsibility or Take Back Program –
Environmental management approaches where the producers’ physical
and/or financial responsibility for a product is extended to the post-consumer
stage of a product’s life cycle. These initiatives can target
all stages in the lifecycle of the products and packaging materials
and may be voluntary, negotiated and/or regulated.
Other – Any
other methods that result in preventing or avoiding the use or release
of this substance. |
| How long to implement this action?
|
For each of the Program, Practice,
Technology or Control options chosen in the previous column, indicate
or estimate how long it would take to implement at your facility. |
| Details column |
Provide details on what would be
required to implement these things – such as name of the substance
replacement, name of process change, equipment modification, reformulation,
timeline for action on implementation, feasibility, issues, etc |
| Section 5.0 Import
Manufacture or Use |
| List of Customers |
Provide a list of customers (at wholesale
level only). If you supply to more than 20 customers, provide an indication
of the customer or industry sector(s) or groups. This information is
being requested to gain information on the chain of distribution of
the substance. |
| Section 5.1.1 Import
of the Substance |
| The information in
this section will allow the Government of Canada to determine potential
exposure pathways to humans and the environment. |
| Quantity of Substance |
Provide a numerical value for the
quantity of the substance imported in kilograms (kg). |
| Expected Use |
Explain the functional use of the
substance. Ex. flame retardants, additives, polymers, polymerization
inhibitors, cross linking agents, surfactants, biocides, to be distributed
to industry/consumers, used in formulation of another product etc. |
| Country of Origin |
Indicate what country this substance
was imported from. This information will allow Environment Canada to
understand potential trade implications, and assess the quantity of
the substance being imported as compared to domestic supplies. |
| Section 5.1.2 Import
of the Substance in a Product |
| Name of Product |
Provide the name of the product containing
the substance. |
| Quantity of Substance (kg) |
Provide, in kilograms, the amount
of the substance imported in a product. |
| Expected Use |
Explain the functional use of the
product. Ex. Colorants, pigments, stains, dyes, inks, pesticides, herbicides,
biocides, disinfectants, repellents, attractants, etc. |
| Concentration of Substance in product
OR Product Specification |
Enter the concentration of the substance
(with the metric units specified) imported in a product OR, if applicable,
the product specification for the substance (ie minimum concentration,
maximum allowable limit, etc.). |
| Analytical Method, MDL |
Provide the analytical method and
the method detection limit if the substance concentration (in the product)
is measured. If the method used has been published, please provide the
reference of this method. If the method used is an unpublished method,
please provide phone numbers, email and website address of the authors
and its organization.
MDL (method detection limit) is the lowest concentration of a substance
that can be measured and reported with 99% confidence and is determined
from analysis of a sample in a given matrix containing the analyte.
|
| Frequency of Analysis |
Indicate how often the concentration
analysis is conducted (ie yearly, with every shipment, etc.) and provide
the last date of analysis. |
| Country of Origin |
As explained in section 5.1.1. |
| Section 5.2.1 Manufacture
– For Sale or Distribution of the Substance |
| The information provided
in this section will allow the Government of Canada to understand where
and how the substance is entering the Canadian market so that risk management
can be properly targeted. |
| Name or type of chemical process
used to mfr Substance |
Provide the name of the chemical process
or describe the process used to manufacture the substance. Alternative
processes may exist or could be developed that are less harmful to the
environment. |
| Quantity of Substance (kg) |
Provide the amount of substance that is
sold or distributed in kilograms. This question provides an order of magnitude
of the substance which is a factor when considering management actions.
|
| Expected Use |
As explained in sections 5.1.1 and 5.1.2
|
| Customer Industry Sector |
List the industrial sector(s) or types
of companies that the substance is sold or distributed to. Group products
or product lines for consumer items. |
| Final Substance Specifications (Concentration)
|
Provide final substance specifications
(ie percentage (%), concentration per weight, maximum or minimum concentration
limits, etc). |
| Section 5.2.2 Manufacture
– For Sale or Distribution as a Part of a Product |
| Name of the manufactured item, mixture
or product |
Provide the name of the final product
or the item line (ie lipstick, household cleaner, etc.) in which the
substance is found. |
| Conc. Of substance OR final specifications
|
Enter the concentration of the substance
(with the metric units specified) sold or distributed in a product OR,
if applicable, the product specification for the substance. |
| Analytical Method & MDL |
As explained in section 5.1.2 |
| Frequency of Analysis of Conc. |
As explained in section 5.1.2 |
| Name of Chemical Process Used to
Manufacture Product |
Provide the name of the chemical
process or describe the process used to manufacture the product containing
the substance. Alternative processes may exist or could be developed
that are less harmful to the environment. |
| Price/Unit |
Provide the mixture, manufactured
item or product price per unit. Response could be in Canadian or US
dollars per kilogram or tonne or average unit size (specify the unit
size). For example, a mfr item containing the substance may be available
in the market in three different sizes small (100 g for $5); medium
(150 g for $6.50) and large (250 g for $10). In this case, the
average unit size and price would be 167 g for $7. Pricing information
combined with information on raw materials and substitute costs identifies
the impact of risk management actions on costs as a percentage of the
mfr item price. If the risk management costs are a significant percentage
of the price, this could translate into price increases, and lead to
impacts on Canadians and small and medium sized businesses. |
| HS Code |
Harmonized Commodity and Description and
Coding System (HS), provides information on component material, use and
function, stage of fabrication, and to a certain extent, industrial origin.
Statistics Canada provides a searchable database of HS Codes on its website
at: http://www.statcan.ca/trade/scripts/trade_search.cgi.
A list of HS Codes is available at: http://www.vassl.com/hscode.htm.
|
| Expected Use |
As explained in section 5.1.2. |
| Section 5.2.3 Incidental
Production of the Substance / By-product |
| Name of the By-product Containing
the Substance |
Provide the name of the by-product
containing the substance. For incidental production of the substance,
leave this column blank and complete the remainder of table. |
| Conc. of Substance in By-Product
|
Provide the concentration of the substance
or by-product containing the substance (with the metric units specified)
produced. |
| Analytical Method and MDL |
As explained in section 5.1.2. |
| Frequency of Analysis of Conc. |
As explained in section 5.1.2. |
| Name of Chemical Process Used to
Mfr Substance as a by- product |
Provide the name of the chemical process
or describe the process that has manufactured (mfr) the substance as a
by-product. |
| By-Product Price/Unit |
As explained in section 5.2.2. |
| Quantity of Substance (kg) |
Provide the amount of substance, in kilograms,
that is produced incidentally or as a by-product. |
| Expected Use |
Explain the expected use (if any) of the
substance or by-product containing the substance. If the by-product is
considered as “waste”, sections 6.0 to 8.0 should also be
completed. |
| Section 5.2.4 Substance
Cost Information |
| The information provided
in this section will allow the Government of Canada to perform a trend
analysis of total recurring costs to industry, and the contribution
of the substance costs to total costs. Combined with substitution costs,
this information enables estimation of the cost to industry as a result
of risk management action. |
| Substance Recurring Cost /Year |
The substance recurring costs is
the cost per year incurred by industry for the substance identified
in section 2.0. Costs could be in Canadian or US dollars. The unit of
measurement should be specified. This information, when combined with
substitute cost information, enables the calculation of recurring costs
to industry resulting from the risk management action. |
| Total Recurring Cost / Year |
Total recurring costs per year includes
cost of materials and supplies, cost of fuel and electricity, and salaries
and wages. This information enables estimation of the percentage contribution
of substance costs to total recurring costs. |
| Section 5.3.1a Uses
|
| The information provided
in this section will allow the Government of Canada to understand the
risks posed by the substance. |
| Process |
Indicate how the substance is used,
more than one process may be selected. A definition for each process
is provided below:
Substance used as a reactant — Substance
was used in chemical reactions for the manufacture or processing of
another substance. This includes, but is not limited to, feedstock,
raw materials, intermediates, catalysts and nutrients added to wastewater
systems.
Substance used as a physical or chemical processing aid
— Substance was added to a mixture to aid in the manufacture or
synthesis of another substance but was not intended to remain in or
become a component of or ingredient in the product or product mixture.
Examples include, but are not limited to, process solvents, catalysts,
inhibitors, initiators, reaction terminators and buffers.
Substance used as a manufacturing aid —
Substance aided the manufacturing process but did not become a component
of or ingredient in the resulting product and was not added to the mixture
during the manufacture of a product or during synthesis of another substance.
Examples include, but are not limited to, process lubricants, metal-working
fluids, coolants, refrigerants and hydraulic fluids.
Substance used as a formulation
component — Substance was added to a product (or
product mixture) before further distribution of the product. Examples
of substances used in this capacity include, but are not limited to,
additives, dyes, reaction diluents, initiators, solvents, inhibitors,
emulsifiers, surfactants, lubricants, flame-retardants and rheological
modifiers.
Substance used as an article component
— Substance became an integral component of an article distributed
for industrial, trade or consumer use. An example is ethylene glycol
added to vehicle radiators during assembly.
Substance used for repackaging only —
Substance or mixture containing the substance was processed or prepared
for distribution in commerce. This also includes transferring the substance
to and from bulk containers.
Substance used for other use — Any use
not covered in processes listed above
|
| Quantity of Substance (kg) |
Provide, in kilograms, the amount
of substance that is used in the process. This question provides an
order of magnitude of the substance which is a factor when considering
management actions. |
| Weight percent of Substance |
Provide the percent by weight of
the substance an element in a compound, or the percent by weight of
the substance in a mixture. This information will provide the order
of magnitude or whether the substance is an important component (as
far as quantity) in a reaction or formulation. |
| Weight percent (or concentration)
remaining in product after reaction |
Provide the weight percent (or concentration)
remaining in the mixture, manufactured item or product after the reaction.
This will provide an indication of how much of the substance is un-reacted
and therefore still available to be released to the environment |
| Name or use of final product. |
Provide the name or use of the final
product. |
| Section 5.3.1b
|
| Provide reaction and final end product
|
If the substance is consumed in a
reaction, provide the reaction and final end product name. |
| Section 5.3.2 Substance
Storage |
| The information requested
in these questions relate to the potential for an organization to require
an environmental emergency plan, and the potential for respiratory distress
from a spill of the substance. |
| Largest Capacity container |
Indicate, in kilograms, the capacity of
the largest single container on site, containing the substance. Indicate
the metric units (ie m3, tonne, etc.). |
| Maximum quantity on site/year |
Indicate, in kilograms, the maximum expected
quantity of the substance on site in a calendar year (with the metric
units specified) |
| Storage temperature (oC) |
Indicate, in degrees Celsius, the normal
storage temperature of the substance. |
| Section 5.3.3 Use
in Products |
| Product Type or Name |
Indicate the type of product (ie
infant toy) or name of the product. |
| HS Code |
As explained in section 5.2.2. |
| Section 5.4 Substitutes
|
| The information provided
in this table will be used to assess the substitutes that could potentially
be used to replace the substance identified in section 2. Information
on price, substitution ratios, and reformulation, re-registration and
production/process changes helps identify the potential incremental
costs that the industry could face from a risk management action.
|
| Substitute Name |
Provide the name (chemical or product
name) of the substitute |
| CAS No. |
Enter the Chemical Abstract Services
Number of the substitute. |
| Price / Unit of Measure |
As explained in 5.2.2. |
| Substitution Ratio |
Substitution ratio should take into
account technical characteristics imparted to products in which it is
used as well as re-engineering or reformulation consideration, |
| Section
5.4.1 Barriers to Substance Substitution
|
Outline the barriers to the elimination
of this substance (ie no substitution exists, substitute is also toxic,
etc.), provide estimate of cost, outline requirements for production
changes, etc.
|
| Section 6.0 On-Site
Releases |
|
The Government of Canada is asking you to provide information on
all of your facility’s releases to the environment in addition
to an estimation of the how this amount was determined / calculated.
Whenever a release quantity is reported (in sections 6.0 through 8.0)
a Method of Estimation code must be provided. The “Method of estimation”
codes provide information about how you determined the quantity of a
substance that was used, released, transferred or disposed. Explanations
of the codes are provided below, and are listed in declining order of
expected accuracy:
Method of Estimation Codes:
M1 Continuous
Emission Monitoring System
M2 Predictive
Emission Monitoring
M3 Source
Testing
C Mass
Balance
E1 Site-specific
and Published Emission Factors
E2 Emission
Models
O Engineering
estimates
|
| Section 6.1 Releases
to Air
Note: Both routine releases, such as fugitive releases to air, and
accidental or non-routine releases, such as a relief valve opening due
to process upset, should be included in your estimate of the quantity
released. |
| Type of Releases to Air |
Stack or point releases – Releases from stack or
point sources, including stacks, vents, ducts, pipes or other confined
streams. Releases to air from pollution control equipment generally
fall into this category.
Storage or handling releases – Releases
to air from storage or handling of the Substance
Fugitive releases – Releases to air
that are not released through confined streams. These releases include:
- fugitive equipment leaks from valves, pump seals, flanges, compressors,
sampling connections, open-ended lines, etc.;
- releases from building ventilation systems; and
- any other fugitive or non-point air emissions from land treatment,
mine tailings, storage piles, etc.
Spills – Accidental releases of the
substance that result in releases of the Substance to air that do not
qualify as point or non-point air releases.
Other non Point – Any other releases
to air not estimated in one of the above air-related release types
|
| Facility ID |
This column provides a letter which
corresponds to the facility listed in section 1.1 beside the same letter.
|
| Quantity (kg) |
Provide, in kilograms, the amount
of substance that is released to the air, in the appropriate row(s).
|
| Method of estimation |
Indicate how each release quantity
was determined by entering the code for the appropriate Method of Estimation.
Definitions of each of the codes is provided below: |
| M1
– Continuous
Emission Monitoring Systems (CEMS) Continuous
Emission Monitoring Systems (CEMS) record emissions/releases over an
extended and uninterrupted period. Various methods are employed to measure
the concentration of contaminants in the effluent or gas stream. Once
the contaminant concentration and the flow rate have been determined,
release or emission rates can be calculated by multiplying the contaminant
concentration by the discharge flow rate or volumetric stack gas flow
rate. Annual releases of the contaminant can then be estimated by multiplying
the contaminant concentration by the annual flow rate of the discharged
effluent or gases in the stack or duct.
M2 – Predictive
Emission Monitoring (PEM) Predictive Emission
Monitoring (PEM) is based on developing a correlation between contaminant
release/emission rates and process parameters (e.g., fuel usage, steam
production, furnace temperature). PEM may be considered a hybrid of
continuous monitoring, emission factors and stack tests. A correlation
test must first be performed to determine the relationship between contaminant
emission rates and process parameters. Releases/emissions can then be
calculated or predicted using process parameters to predict release/emission
rates based on the results of the initial source test.
M3 – Source
Testing Source testing involves collecting a sample of the emission
or effluent, then determining the concentration of one or more substances
in the sample. The concentration of the substance(s) of interest is
then multiplied by the volumetric flow rate to determine the amount
of the substance(s) emitted over time. Source testing of air emissions
generally involves inserting a sampling probe into the stack or duct
to collect a volume of exhaust effluent isokinetically. The contaminants
collected in or on various media are subsequently analyzed. For liquid
effluents, grab samples or 24-hour composite samples are extracted from
the effluent stream.
C – Mass
Balance Mass balance applies the law of conservation of mass
to a facility, process or piece of equipment. If there is no accumulation,
then all the materials that go into the system must come out. Releases
are determined from the difference in the input and output of a unit
operation where the accumulation and depletion of a substance are included
in the calculations.
The general equation for a mass balance is: Min = Mout
+ Maccumulated/depleted
Where:
Min = Mass of compound
in the raw material feed
Mout = Mass of compound in the finished product and released
to air, land and water
(Mout = Mproduct + Memitted)
Maccumulated/depleted = Mass of compound accumulated or
depleted in the system
The reliability of release estimates based on mass balances is dependent
on the source type considered. Mass balance methods may be preferred
for some releases, such as solvent loss from coating applications and
solvent use. This method may not be suitable for many other sources,
such as cases where chemical transformation of the input streams occurs
in the process.
Mass balance methods may or may not account for emission controls,
depending on the system, process or operation to which the mass balance
is applied. Pollution-control equipment should be accounted for when
mass balance calculations are performed.
E1 – Site-specific
and Published Emission Factors Emission factors are available
for many emission-source categories and are generally based on the results
of source-sampling tests performed at one or more facilities within
a specific industry. Generally, emission factors relate the quantity
of substances emitted from a source to some common activity associated
with those emissions. Government agencies and industry associations
publish emission factors to be applied to emission sources in their
particular jurisdiction or industrial sector. Industrial facilities
may also develop their own site-specific emission factors using emission-testing
data and source-activity information. For a particular piece of equipment,
specified emission factors may be available from the manufacturer or
sales centre. When completing the report, you must specify whether a
site-specific emission factor or published emission factor was used.
The basic equations for determining emissions from emission factors
are as follows:
Ex = BQ x CEFx OR Ex = BQ x EFx
x ((100 – CEx)/100)
Where:
Ex = Emission of contaminant x in kg
BQ = Activity rate or base quantity (BQ), base quantity unit
CEFx = Controlled emission factors of contaminant x, kg/BQ
unit (value is dependent on the external control device installed)
EFx = Uncontrolled emission factors of contaminant x, kg/BQ
unit
CEx = Overall emission control efficiency of contaminant
x, %
The U.S. EPA Factor Information Retrieval (FIRE) database and Compilation
of Air Pollutant Emission Factors (AP-42) are comprehensive
depositories of process-specific emission factors., When making use
of emission factors, ensure that you note the units and convert if necessary.
E2 – Emission
Models Emission estimation models, also known as emission estimation
tools, are equipment-specific and may be available from process developers
and designers, Government agencies or others.
Emission models generally require detailed input such as equipment
specifications, process and environmental conditions and other factors
that affect emissions. Generally, these models also have default input
parameters, such as meteorological data, which can be used when site-specific
information is not available. Review all the default data carefully
to ensure that they apply to local conditions. The resulting estimates
should also be reviewed to ensure their accuracy. The U.S. EPA’s
TANKS software, used to estimate VOC releases from storage tanks, is
an example of an emission model.
O – Engineering
Estimates In many cases, sound engineering assessment is the
most appropriate approach to determining process factors and base quantity
values. Releases can be estimated from engineering principles and judgment,
by using knowledge of the chemical and physical processes involved,
the design features of the source and an understanding of the applicable
physical and chemical laws. The reliability of these estimates depends
on the complexity of the process and the level of understanding of its
physical-chemical properties. To apply an engineering assessment method,
follow these four basic principles:
- Review all data pertaining to the specific source and to the industrial
sector in general.
- Use this data to provide gross approximations and refine these using
sound engineering principles as data become available to provide more
accurate estimations.
- Whenever possible, alternate methods of calculation should be followed
to cross-check each level of approximation.
- Employ good record keeping by documenting all related information
for further emission refinement when more accurate data become available.
|
| Routine Release |
Indicate if the release is routine
or not, as per the description in the Section 6.1 header bar. |
| Section 6.2 Releases
to Surface Waters
Note: Do not include discharges to a municipal sewage treatment
plant or other off-site water treatment facility as these are covered
in Section 7.3 Off-Site Transfers for Disposal. |
| Type of Releases to Surface Waters
|
Direct discharges
- Releases directly to a receiving body of water.
Spills - Accidental releases to surface waters
that may have occurred at the facility
Leaks - Leaks to surface waters differ from
spills in terms of the time required for an event. Spills normally occur
over a period of hours or days, whereas a leak is a chronic event that
occurs over periods of days or months.
|
| Facility ID |
Each letter in this column corresponds
to a facility that you have listed in section 1.1. The Facility ID indicates
what line each individual facility data should be entered on. |
| Quantity (kg) |
Provide, in kilograms, the amount
of substance that is released to the surface waters, in the appropriate
row(s). |
| Method of estimation |
As explained in section 6.1. |
| Routine Release? |
As explained in section 6.1. |
| Section 6.3 Releases
to Land
Note: Do not include land disposal (i.e., landfill) at any off-site
locations, as this is considered an off-site transfer for disposal.
|
| Types of Releases to Land |
Landfill –
Releases to land on-site (ie, on-site landfill).
Land treatment – Releases to land by
applying a waste onto, or incorporating a waste into soil.
Spills – Accidental releases to land
at the facility.
Leaks – Leaks to land differ from spills
in terms of the duration of the event. Spills often occur over a period
of hours or days, whereas a leak is a chronic event that often occurs
over a longer period of days or months. An example is a leak from an
underground storage tank.
Other – Any other releases to land not
estimated in one of the above land-related release types (ie, encapsulation
prior to on-site landfill).
|
| Facility ID |
As explained in section 6.1. |
| Quantity (kg) |
Provide, in kilograms, the amount
of substance, which is released to land in the appropriate row(s). |
| Method of estimation |
As explained in section 6.1. |
| Routine Release? |
As explained in section 6.1. |
| Section 7.0 On-Site
and Off-Site Waste Transfers and Disposals |
| Section 7.1 On-Site
Waste Disposal |
| Types of On-Site Disposal |
Landfill – On-site
disposal toland (ie, on-site landfill).
Land Treatment – On-site disposal to
land by applying a waste onto, or incorporating a waste into soil.
Underground Injection – Underground
injection on-site for disposal.
Storage – Storage on-site for disposal.
|
| Facility ID |
As explained in section 6.1. |
| Quantity (kg) |
Provide, in kilograms, the amount
of substance that is disposed of on-site, in the appropriate row(s).
|
| Method of estimation |
As explained in section 6.1. |
| Routine Release? |
As explained in section 6.1. |
| Section 7.2 Off-Site
Waste Disposal |
| Types of On-Site Disposal |
Landfill
– Off-site disposal to land (ie, off-site landfill).
Land Treatment – Off-site disposal to
land by applying a waste onto, or incorporating a waste into, soil.
Underground Injection – Underground
injection off-site for disposal.
Storage – Storage off-site for disposal.
|
| Facility ID |
As explained in section 6.1. |
| Quantity (kg) |
Provide, in kilograms, the amount
of substance that is disposed of off-site, in the applicable row(s).
|
| Method of estimation |
As explained in section 6.1. |
| Routine Release? |
As explained in section 6.1. |
| Section 7.3 Off-Site
Waste Transfers Prior to Final Disposal
Note: Report the quantity of the Substance that was sent off-site
for disposal and not the total weight of the mixture containing the
substance. Report transfers to the first off-site location only and
not any subsequent transfers by the waste disposal organization or by
any other entity. Do not include transfers sent off-site for recycling;
they are reported in section 8.0 of the questionnaire. |
| Types of Off-Site Waste Transfers
prior to Final Disposal |
Physical treatment
- Examples include drying, evaporation, encapsulation and vitrification.
Chemical treatment - Examples include precipitation,
stabilization and neutralization.
Biological treatment - Examples include bio-oxidation
and composting.
Incineration/thermal - This differs from energy
recovery. Incineration occurs when the Substance or the mixture containing
the Substance does not have sufficient fuel value to contribute towards
energy recovery.
Containment - For example, two forms of containment
are:
-
- landfill; or
- other storage
Municipal sewage treatment plant - Report
releases of the Substance to a municipal sewer system, regardless of
the level of treatment provided by the treatment plant.
Underground injection - Report the quantity
injected underground at an off-site location
Land treatment - Report the quantity transferred
off-site for the purpose of application onto or incorporation into soil.
|
| Facility ID |
As explained in section 6.1. |
| Quantity (kg) |
Provide, in kilograms, the amount
of substance that is transferred off-site in waste in the appropriate
row(s). |
| Method of estimation |
As explained in section 6.1. |
| Routine Release? |
As explained in section 6.1. |
| Section 8.0 Off-Site
Transfers for Recycling
Note: Report the quantity of the substance that was sent off-site
for recycling and not the total weight of the mixture containing the
substance. Report transfers to the first off-site location only and
not any subsequent transfers by the recycling facility or by any other
entity. |
|
Energy recovery
– The substance or the mixture containing the substance has sufficient
energy content (BTU value) to allow its use as a fuel for energy recovery.
If there had been no attempt to recover energy from the substance or
mixture containing the substance, report it as an off-site transfer
for incineration.
Recovery of solvents – The recovery
or regeneration of the substance or materials containing the substance
that have been used as solvents (for example, distillation of methanol
after solvent extraction to recover pure solvent methanol).
Recovery of metals and metal compounds – Choose
this recycling activity when a pure metal or a metal compound is being
recovered.
Recovery of organic Substances (except for solvents)
– Recovery of other organic substances that are not used as solvents.
Recovery of inorganic materials (except for metals)
– Choose this recycling activity when inorganic material is being
recovered.
Recovery of acids or bases – Choose
this recycling activity when acids or bases are being recovered.
Recovery of catalysts – Choose this
item if a catalyst containing the substance was transferred off-site
to be recovered, reactivated, regenerated or otherwise refurbished for
reuse as a catalyst. Recovery of catalysts does not include the destruction
of the catalyst to recover separate components.
Recovery of pollution abatement residues –
This includes the recycling of residues from pollution control or site
remediation activities.
Refining or reuse of used oil – Choose
this recycling activity if used oils containing the substance(s) were
transferred off-site for refining or reuse. If used oil was used as
a fuel, choose energy recovery.
Other – Any other recovery, reuse and
recycling activities not described above. |
| Facility ID |
As explained in section 6.1. |
| Quantity (kg) |
Provide, in kilograms, the amount
of substance that is transferred off-site for recycling, in the appropriate
row(s). |
| Method of estimation |
As explained in section 6.1. |
| Destination |
Provide the name and /or location
of the destination site for recycling. |
| Section 9.0 Off-Site
Transfers for Export |
| Types of Off-Site Transfers for Export
|
Export for disposal –
Export of the substance or product containing the substance
for disposal (landfill, incineration, etc).
Export for recycling –Export of the
substance or product containing the substance for recycling.
Export for use – Export of the substance
or product containing the substance for use in another process, product,
etc. |
| Facility ID |
As explained in section 6.1. |
| Quantity (kg) |
Provide, in kilograms, the amount
of substance that is transferred off-site for export in the appropriate
row(s). |
| Method of estimation |
As explained in section 6.1. |
| Destination |
Provide the name / location of the
destination site for recycling. |
| Section 10.0 Certification
|
| The following section
should be completed for each substance submitted by each organization.
|
| Confidentiality Requests |
Requests for confidentiality can
be made in this section by specifying which section(s) you wish to remain
confidential and providing the reason(s) for each request. Data cannot
be made confidential without proper justification.
See question 5 of this document for further guidance on submitting requests
for confidentiality. |
Disclaimer: Although care has been
taken to ensure that the information found on this website accurately reflects
the requirements prescribed in the Canadian Environmental Protection Act (1999), you are advised that, should any inconsistencies
be found, the legal documents, printed in the Canada Gazette, will prevail.
|
