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Management of Chemicals

Canada is at the forefront of managing chemicals that are used in commerce. Since 1992, EHS advised public and private sector clients in this area and developed a strong expertise in this field.

Chemical substances are managed in Canada by all three levels of government: federal, provincial and municipal.

At the federal level, the primary authority for management of chemical substances stems from the Canadian Environmental Protection Act, 1999 (CEPA 1999). CEPA-toxic substances are those substances listed in Schedule 1 of CEPA 1999, http://www.chemicalsubstanceschimiques.gc.ca/about-apropos/index-eng.php.

At the provincial level, chemical substances are managed by numerous air, water and soil regulations. For example, in 2009, the Province of Ontario passed the Toxics Reduction Act (TRA). The Act requires regulated facilities (initially, manufacturing and mining industry sectors) to:

- Perform materials accounting, i.e., track and evaluate their current use and creation of toxics;

- Develop Toxics Reduction Plans, i.e. develop a plan to reduce the use and release of toxics;

- Report to the Ministry or a Designated Body; and

- Make a summary of the plan available to the public, i.e., Public Disclosure.

At the municipal level there is less regulatory activity compared to federal and provincial levels. Nonetheless, the City of Toronto’s Environmental Reporting and Disclosure Bylaw (Municipal Code 423) took effect January 1, 2010. The bylaw is part of ChemTRAC, which requires local business owners to track and report their use of toxic chemicals. ChemTRAC reporting requirements will be phased-in over 3 years.

- The first phase starts tracking toxic chemical use and release in 2010, and begins annual reporting in 2011. It includes: food and beverage manufacturing, printing and publishing, power generation, chemical manufacturing, wood industries and water treatment.

- Phase 2 business sectors are required to track their chemical use and release, and report in 2012 and include: chemical wholesale, dry cleaning, laundry services, funeral services, waste management and remediation, medical and diagnostic laboratories, auto repair and maintenance.

- Phase 3 captures all other business sectors. These sectors are required to begin tracking in 2012 and reporting in 2013.

EHS has many years of experience preparing Materials Accounting and Toxic Reduction Plans (Pollution Prevention Plans). Please contact EHS at info@ehstrategies.com to discuss assistance with Materials Accounting and with preparation of Toxics Reduction Plans.