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Pinchin Environmental Newsletter (PEN #12)
Environmental Protection
Pollution Prevention (P2) versus Pollution Control, A Time for Change
In the 1970s, governments developed regulations to control pollution assuming that the environment was able to accommodate large quantities of waste without causing adverse environmental effects. Unfortunately, many of these wastes were persistent, cancerous and able to bioconcentrate in living organisms.
Sanitary sewer sampling for identification
of CEPA Toxics. |
It was soon realized that this pollution protection philosophy was not going to work considering environmental disasters such as the Union Carbide incident in India in 1984. Highly toxic Methylisocyanate gas leaked from a pesticide plant resulting in a death toll ranging from an estimated 10,000 to 20,000 people. Following this disaster and other incidents, "right-to-know" legislation was introduced in the U.S. Industry sources revealed that toxic chemicals were being released into the environment, demonstrating that pollution control legislation was inadequate.
Regulations and Standards
In 1988, the Canadian Minister of the Environment promulgated the Canadian Environmental Protection Act (CEPA) in response to growing public concerns regarding existing pollution control initiatives.
CEPA was subsequently revised in 2000 to give the Canadian government the authority to require industry to implement pollution prevention (P2) planning for substances declared CEPA-toxic. To invoke CEPA, notices are published in the Canada Gazette requiring industry to prepare and implement P2 plans for substances declared to be toxic. The Toxic Substances List (as of May 2001) comprises 52 substances. Some of the more familiar substances include: Chlorofluorocarbons (CFCs), Asbestos, Lead, Mercury, Vinyl Chloride, Benzene, Creosote, Arsenic and respirable particulate matter.
In 1996, the International Organization of Standardization (ISO) produced a standard ISO 14000: 1996 for organizations wishing to develop, implement and maintain environmental management systems (EMSs). The ultimate goal of this standard was to provide direction for organizations supporting environmental protection and avoidance of pollution in balance with socio-economic needs.
P2 opportunities in the health care sector provide
potential cost savings and reduction of solid
and hazardous wastes. |
Manitoba Conservation maintains an anti-regulatory philosophy that encourages a stewardship approach to pollution prevention. The Manitoba Waste Reduction and Prevention Act (1990), Multi-Material Stewardship (1995) and Tire (1995) and Used Oil (1997) Stewardship regulations are examples of Manitoba Conservation's commitment to pollution prevention through proponent stewardship.
The Government of Manitoba has made a commitment to fund waste reduction and pollution prevention practices under the Sustainable Development Innovations Fund (2001). Project eligibility criteria include the preparation of a plan to measure and report on project results. Under The Livestock Manure and Mortalities Management Regulation (1998), producers are required to submit Manure Management Plans on an annual basis and prior to the application of manure on fields.
On the municipal level, industries operating in the Cities of Toronto and Montreal now must meet the requirements of new P2 by-laws. Industries generating specific pollutants must implement P2 measures including the preparation of P2 plans. Some of the more familiar subject pollutants listed in Toronto's By-law No. 457-2000 include Arsenic, Benzene, Copper, Mercury, Nickel, Lead, DDT and PCBs.
Justification
Practicing P2 through the development and implementation of pollution prevention plans or EMSs can have the following benefits:
- Enhance corporate image and relations with government and community;
- Increase share value and access to capital;
- Minimize risks and insurance costs;
- Minimize operating costs by conserving energy and material usage;
- Reduce regulatory compliance costs; and
- Improved worker safety and morale.
CEPA P2 Plans
According to CEPA, P2 programs should include the following elements:
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MSDS are important considerations
for P2 plans. |
Endorsement by a senior official;
- Identification of the senior official responsible for the plan;
- The objectives of the plan and schedule of completion;
- A review of substance control activities (including acquiring, processing, generating, storing, handling, disposing);
- A review of substance control options, the implementation plan and schedule;
- A plan for tracking the performance of the options, implementing corrective actions and reporting; and
- A program for regular improvement.
ISO EMS
According to ISO, EMS should comprise the following elements:
- Definition of environmental policy and commitment from top management;
- Development of plan to expedite its environmental policy;
- Development of mechanisms to achieve its environmental policy, objectives and targets;
- Auditing of environmental performance; and
- Commitment to maintenance and continual improvement of EMS.
Manitoba Pollution Prevention Legislation
Some of the key elements of Manitoba's Waste Reduction and Prevention Act include:
- Promoting the reduction and prevention of the production and disposal of waste;
- Encouraging proponents to acknowledge their stewardship for wastes generated;
- Promoting waste minimization through reducing and recycling, including reuse and recovery;
- Promoting decisions with due regard for their environmental impact, including human health; and
- Encouraging waste management programs to anticipate, prevent or mitigate adverse environmental and economic impacts.
Toronto P2 Plans
The key elements for reducing subject pollutants according to Toronto's By-law are:
- Establish the Pollution Prevention Program;
- Organize the Pollution Prevention Plan;
- Preliminary Assessment - Material Balance;
- Define the Pollution Prevention Options;
- Complete a Feasibility Analysis;
- Prepare the Plan;
- Complete the P2 Plan Summary Report; and
- Submit Plan summary.
For additional information regarding Toronto P2 Plans, refer to PEN#9.
Conclusion
Today, the focus of regulations has changed from pollution control to pollution prevention, which involves avoiding or minimizing the production of a toxic substances instead of treatment, re-use, recycling or disposal. The use of P2 plans or EMSs will assist in the reduction or elimination of toxic substances currently being generated and minimization of other nontoxic wastes currently being land-filled.
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