Journal of Cleaner Production 14 (2006) 629e635

www.elsevier.com/locate/jclepro

Canadian Federal Government requirements and supporttools for pollution prevention planning

Peter Fischer*

Canadian Centre for Pollution Prevention, 100 Charlotte Street, Sarnia, Ontario N7T 4R2, Canada

Available online 8 September 2005

Abstract

This paper reviews the Canadian federal government’s requirements and support tools for pollution prevention planning underPart 4 of the Canadian Environmental Protection Act, 1999 (CEPA 1999). It explains the requirements and provisions, theirstatutory basis and the means of invoking them, and notes the extent of their use to date. It outlines the existing support tools for

pollution prevention planning (including the model plan and guidelines) under CEPA 1999, their nature and where to get them. Thepaper concludes by identifying areas for future research.� 2005 Elsevier Ltd. All rights reserved.

Keywords: Environmental protection; Pollution prevention; P2; Planning; Statutory requirements

1. Introduction

In April 2000, the Canadian federal governmentenacted a renewed and strengthened Canadian Envi-ronmental Protection Act, 1999 (CEPA 1999) [1], withpollution prevention as the cornerstone of the revisedstatute. The CEPA 1999 gives the government newpowers to require pollution prevention planning forsubstances declared toxic under CEPA.1 Since environ-mental challenges, expectations, and legal and scientificknowledge are constantly evolving, the Act will bereferred to a Parliamentary Committee for review every5 years.2 The review covers both the operations and the

* Tel.: C1 519 337 3423; fax: C1 519 337 3486.

E-mail address: pfischer@interlog.com1 CEPA, 1999, section 64, states ‘‘a substance is toxic if it is entering

or may enter the environment in a quantity or concentration or under

conditions that (a) have or may have an immediate or long-term

harmful effect on the environment or its biological diversity; (b)

constitute or may constitute a danger to the environment on which life

depends; or (c) constitute or may constitute a danger in Canada to

human life or health.2 CEPA 1999, section 343.

0959-6526/$ - see front matter � 2005 Elsevier Ltd. All rights reserved.

doi:10.1016/j.jclepro.2005.07.012

provisions of the Act. Given that the Act came intoforce March 31, 2000, it must be referred to the Houseof Commons by March 31, 2005, and the review willbegin sometime thereafter. A Parliamentary committeewill undertake the review and submit a report to Parlia-ment on the changes it recommends to the Act and/or itsadministration.3

This paper reviews the new pollution preventionplanning requirements of CEPA 1999, in particularthose in Part 4, notes the extent of their use to date, andoutlines the support tools available to assist personssubject to those requirements and others who areinterested in pollution prevention planning. It concludesby identifying areas for future research. Every attempthas been made to ensure that the information in thispaper is accurate. However, the guidance contained hereshould be relied upon for information purposes only.This paper is not intended to provide legal advice; nor isit intended to replace expert legal or environmental

3 Information on the CEPA review is available electronically at

http://www.ec.gc.ca/CEPARegistry/review/default.cfm.

630 P. Fischer / Journal of Cleaner Production 14 (2006) 629e635

advice. For official legislative provisions, consult theCEPA 1999, particularly Part 4. CEPA is primarilyadministered by Environment Canada, a department ofthe Canadian federal government.

2. The requirement for pollution prevention planning

2.1. General

The CEPA 1999 provides the Federal Ministers of theEnvironment and of Health with new powers and toolsto protect the environment and human health and tocontribute to sustainable development through pollu-tion prevention (P2). The Canadian federal governmentdefines pollution prevention as,

the use of processes, practices, materials, products,substances or energy that avoid or minimize the creationof pollutants and waste and reduce the overall risk to theenvironment or human health.4

CEPA 1999 identifies pollution prevention as a prior-ity for Environment Canada.

The Minister of the Environment requires the prepa-ration and implementation of P2 plans under Part 4 ofCEPA 1999, in order to:

� generate action that will contribute to the effective-ness and efficiency of the management of toxic sub-stances (substances on Schedule 1 of CEPA, the Listof Toxic Substances5) and reduce overall risk to theenvironment and human health;

� provide an early opportunity to develop andimplement situation-specific solutions; and

� encourage pollution prevention.6

At the time of writing, Environment Canada hadreceived declarations that P2 plans have been preparedand are being implemented in respect of two Notices.Notices are explained in Section 2.2 of this paper.

CEPA 1999 contains other P2 planning provisions.Part 7 authorizes the Minister to require P2 plans insome circumstances for Canadian sources of interna-tional air and international water pollution. To date,this power has not yet been used. Part 9 (section 209(1)(b)) authorizes the Governor-in-Council to makeregulations respecting P2 planning by federal govern-ment operations. To date, no such regulations have beenmade. Part 10 (section 291(1) (c)) authorizes a judge

4 CEPA 1999, section 3(1).5 CEPA 1999, Schedule 1.6 Guidelines for the implementation of pollution prevention

planning provisions of part 4 of the Canadian Environmental

Protection Act, 1999. Ottawa, Canada: Environment Canada; 2001,

p. 2.

to require anyone in violation of CEPA 1999 toprepare and implement a P2 plan. To date, this powerhas not been used. This paper deals only with the P2planning provisions under Part 4 of CEPA 1999. The P2planning provisions in CEPA 1999 are summarized inTable 1.

2.2. Requirements under Part 4 CEPA 1999

Part 4 of CEPA 1999 gives the Minister of theEnvironment the authority to require the preparationand implementation of pollution prevention plans (P2plans) for toxic substances. P2 plans are one of severalinstruments that can be used to initiate the preventiveand control actions required by CEPA 1999. Authorityto use the full range of optionsdfrom regulations,through P2 plans, to guidelines, standards and non-legislative initiativesdremains with the Minister. P2planning may be used alone or together with otherinstruments.

Preparation and implementation of P2 plans can berequired for any substance on the List of Toxic Sub-stances, e.g., acrylonitrile, asbestos, dichloromethane,mercury, vinyl chloride. The P2 plan may be used aloneor in tandem with existing systems within a facility tomanage a substance, or it may be used in addition toexisting measures that do not adequately manage the riskposed by the substance.

To invoke these P2 planning requirements, theMinister uses the authority of section 56 to publishNotices in Part I of the Canada Gazette,7 requiringa person, or class of persons, to prepare and implementP2 plans for a substance or group of substances. TheseNotices may specify: who will be required to prepareand implement a P2 plan; who is exempt from theNotice; what factors are to be considered in preparing

Table 1

Pollution prevention planning provisions in the Canadian Environ-

mental Protection Act, 1999

CEPA part/section Circumstances for P2 planning Used

Part 4 Any substance on the List of

Toxic Substances

Yes

Part 7 Canadian sources of international

air and international water pollution

No

Part 9, section

209(1)(b)

Regulations respecting P2 planning

by federal government operations

No

Part 10 Judge may require of anyone in

violation of CEPA 1999

No

7 The Canada Gazette is the official newspaper of the Government of

Canada, published under the authority of the Statutory Instruments

Act. Subscription information and non-official alternate formats are

available electronically at: http://canadagazette.gc.ca/index-e.html.

631P. Fischer / Journal of Cleaner Production 14 (2006) 629e635

the P2 plan, e.g. risk management objectives, environ-mental and human health risks, and currently availabletechnology and practices; the time limits for preparingand implementing plans; and, any administrativematter, e.g. the type and format of the reporting formto be submitted to the Minister, necessary for thepurposes of Part 4 of CEPA. Section 56 Notices do notprescribe the form of P2 plans; those preparing the planmay use whatever form best suits them, provided theplan meets the requirements defined in the Notice andthe statute.

Under section 58, persons affected by a Notice toprepare and implement a P2 plan must make twowritten declarations to the Minister: first, a declarationthat the plan has been prepared and is being imple-mented; and, second, a declaration that the implemen-tation of the plan has been completed. (As noted earlier,at the time of writing, Environment Canada has receiveddeclarations that P2 plans have been prepared and arebeing implemented in respect of two Notices.) The form,manner and content of these declarations are included inthe Notice. Template declarations are provided in the‘‘Guidelines’’ documents outlined in the Support Toolssection (Section 3). Aspects of the reporting require-ments of these declarations have been aligned withpre-existing reporting requirements of the NationalPollutant Release Inventory to facilitate reporting byindustry. Environment Canada is in the process ofdeveloping a database that will allow persons subject toa P2 Notice to complete declarations and associatedforms on-line. At the time of writing, this data base wasnot yet available.

In some cases, the Minister may require regularinterim reports of the progress those persons subject toa Notice are making in implementing their P2 plans. Theschedule and content of such reports are provided in thesection 56 Notice. Notices have been developed whichwill require such interim reports, including the Dichloro-methane Notice and the Textile Mill Effluent Noticementioned in Section 3.

Interested parties are given opportunities for consul-tation and comment in the process of managing specifictoxic substances. There are typically two stages ofconsultation in the development of P2 planning Notices.The first consultation is on the working document,a document that lays out the key elements of proposedP2 planning requirements. The second consultation is onthe ‘‘Proposed’’ Notice which is published in Part I ofthe Canada Gazette to provide a 60-day commentperiod. Following this comment period the ‘‘final’’Notice, making it a legal requirement to prepare andimplement a P2 plan, is published. Both the ‘‘proposed’’and ‘‘final’’ Notices published in the Canada Gazette aremailed to the known target community. Also, theinformation submitted by persons subject to a P2planning Notice (e.g., Declarations, applications for

time extensions, waivers, etc.) will be publicly posted onthe National Office of Pollution Prevention website. Thepublic will be able to search this information electron-ically using specific criteria such as, company name,location, substance, and industry sector. The reportingdatabase currently under development will be themedium for making information publicly available andsearchable. At the time of writing, this data base was notyet publicly available.

2.3. Notices published to date

Five final Notices and one Proposed Notice, asoutlined below, have been published to date.

Notice Requiring the Preparation and Implementationof Pollution Prevention Plans in Respect of Acrylonitrile(published May 24, 2003). This Notice requires Cana-dian manufacturers of synthetic rubber to prepare a P2plan to reduce releases of acrylonitrile.

Notice Requiring the Preparation and Implementationof Pollution Prevention Plans in Respect of Dichloro-methane (published November 29, 2003). This Noticerequires the preparation and implementation of P2plans to reduce the release of dichloromethane. TheNotice targets five industrial sectors: aircraft paintstripping, flexible polyurethane foam blowing, pharma-ceutical and chemical intermediates manufacturing andtablet coating, adhesive formulations, and industrialcleaning.

Notice Requiring the Preparation and Implementationof Pollution Prevention Plans for Inorganic Chloraminesand Chlorinated Wastewater Effluents (published De-cember 4, 2004). This Notice outlines the requirementsto prepare and implement P2 plans for inorganicchloramines and chlorinated wastewater effluents. TheNotice targets persons involved in the use of chlorine orchlorine compounds in wastewater systems and therelease of chlorinated wastewater effluent to surfacewater. The primary source of inorganic chloraminesand chlorinated wastewater effluents is the disinfectionof the wastewater using chlorination. Alternative disin-fection techniques, such as ultraviolet light and ozone,can be evaluated to meet the effluent limits. The Noticeaffects persons who, in addition to other criteria,own a wastewater collection or treatment system (onetreating over 5000 m3/day, equivalent to a population of10,000e12,000). These systems are usually operated bymunicipalities, although this Notice may indirectly affectall those discharging to such systems, including in-dustries and institutions. In preparing and implementingtheir P2 plans, the treatment plant operators will lookfor ways to reduce the amounts of the namedcompounds entering their plant. One way is to restrictthe discharge to the sewage system of these compounds,or their precursors, through a municipal sewer use

632 P. Fischer / Journal of Cleaner Production 14 (2006) 629e635

by-law. Toronto, Ontario is one municipality that hasalready taken this approach. Its revised sewer use by-lawrequires any industry or sector that discharges subjectpollutants (ones named in the by-law) to submit a P2plan to the public works commissioner according to aset schedule. The P2 plan must show how the dischargedamount of the subject pollutant will be reduced oreliminated [2]. If particular products are a significantsource of such pollutants, a discharger would almostcertainly look at how to reduce or eliminate particularproducts, for instance by using less or switching to otherless or non-polluting products.

Notice Requiring the Preparation and Implementationof Pollution Prevention Plans in Respect of Effluents fromTextile Mills That Use Wet Processing (TMEs) andNonylphenol (NP) and its Ethoxylates (NPEs) (pub-lished December 4, 2004). This Notice outlines therequirements for textile mills involved in wet processingto prepare and implement a P2 plan addressing nonyl-phenol (NP) and its ethoxylates (NPEs) and textile millseffluents (TMEs). It targets persons involved in textilewet processing activities that discharge their effluentsproduced during wet processing to an off-site wastewa-ter treatment facility and have had a daily effluentdischarge greater than 30 m3 at least once between 1999and 2003.

Notice Requiring the Preparation and Implementationof Pollution Prevention Plans in Respect of Nonylphenoland its Ethoxylates Contained in Products (publishedDecember 4, 2004). This Notice outlines the require-ments to prepare and implement a P2 plan fornonylphenol (NP) and its ethoxylates (NPEs) containedin products. The Notice targets manufacturers andimporters of soap, cleaning products and processing aidsused in textile wet processing and pulp and paperprocessing aids.

Proposed Notice Requiring the Preparation andImplementation of Pollution Prevention Plans in Respectof Specified Toxic Substances Released from Base MetalsSmelters and Refineries and Zinc Plants (publishedSeptember 25, 2004). This Notice outlines the proposedrequirements to prepare and implement a P2 plan forspecified toxic substances released from base metalssmelters and refineries and zinc plants.

The Notices are summarized in Table 2. For moreinformation on any of these Notices and support toolsthat have been developed for these Notices, please visitthe National Office of Pollution Prevention website:http://www.ec.gc.ca/nopp.

2.4. Other provisions

The Minister may extend the time period for prepa-ring and implementing a plan for individual facilities, ifhe or she is of the opinion that more time is necessary.An extension would be considered by the Minister inresponse to a written request made by the person subjectto the Notice before expiration of the period referred toin the Notice. Where an extension is made, notice of itshall be published in the Gazette stating the name of theperson to whom the extension is granted, whether theextension is for the preparation or implementation ofthe plan, and the duration of the period of extension.Based on the Gazette, two time extensions have beengranted to date; one in regard to the AcrylonitrileNotice, the other in regard to the DichloromethaneNotice. The Gazette does not provide information onthe number of requests made, nor how many theMinister may have considered, but rejected.

Those who are subject to a Notice to prepare andimplement a P2 plan, may make a written request to the

Table 2

Notices under s. 56, Canadian Environmental Protection Act, 1999, requiring preparation and implementation of pollution prevention plans

Date Notice Substance Target

May 24, 2003 Final Acrylonitrile Canadian manufacturers of synthetic rubber

November 29, 2003 Final Dichloromethane Five industrial sectors: aircraft paint stripping,

flexible polyurethane foam blowing, pharmaceutical

and chemical intermediates, adhesive formulations,

and industrial cleaning

December 4, 2004 Final Inorganic chloramines and chlorinated wastewater

effluents

Persons involved in the use of chlorine or chlorine

compounds in wastewater systems and the release of

chlorinated wastewater effluent to surface water

December 4, 2004 Final Effluents from textile mills that use wet processing and

nonylphenol and its ethoxylates

Textile mills that use wet processing and nonylphenol

and its ethoxylates

December 4, 2004 Final Nonylphenol and its ethoxylates contained in products Manufacturers and importers of soap, cleaning

products and processing aids used in textile wet

processing and pulp and paper processing aids

September 25, 2004 Proposed Specified toxic substances released from base metals

smelters and refineries and zinc plants

Base metals smelters and refineries and zinc plants

633P. Fischer / Journal of Cleaner Production 14 (2006) 629e635

Minister outlining reasons to waive the requirement thatthe person consider a specified factor in their P2 plan.The Minister may waive the requirement where he or sheis of the opinion that it is not reasonable or practicableto consider the factor based on the reasons provided. Atthe time of writing, no requests for waivers have beenreceived.

Section 57 provides that, in some cases, a planprepared and implemented for other purposes may beused as a P2 plan under Part 4 of CEPA. A person whohas prepared and implemented a plan for pollutionprevention on a voluntary basis or for another govern-ment (most likely a provincial or municipal government)or under another Act of the Federal Parliament may usethat plan for meeting the requirements of Part 4 and theplan shall be considered a P2 plan under Part 4. However,the other plan must satisfy all or some of the require-ments specified in the Notice. Where the plan does notmeet all the requirements, the person shall amend theplan to meet the requirements or, prepare an additionalplan to meet those remaining requirements. The extent towhich persons have used other plans is unclear, since there-use of plans is not always acknowledged by personssubject to a Notice.

There are provisions in section 58 that requirea person to file an amended declaration where in-formation previously submitted has become false ormisleading. This filing must be done within 30 days ofwhen the information became false or misleading. At thetime of writing, no information on amendments waspublicly available.

Everyone required to prepare a P2 plan must keepa copy of the plan at the place in Canada for which theplan was prepared, as required by section 59.

The Minister may require, under section 60, a personto submit the P2 plan, or part of the plan, to theMinister for the purpose of determining and assessingpreventive and control actions for a substance or groupof substances. This requirement, including a specifiedtime period, is published in the Canada Gazette and inany other manner the Minister considers appropriate.This requirement has not been used to date.

The CEPA 1999, makes specific provision, undersection 61, for the Minister to publish pollution pre-vention model plans and guidelines (these are mentionedin Section 3). The purpose of the model plan or plans isto provide guidance in the preparation of a pollutionprevention plan. The model plan has been published andis referred to in the next section. Under section 62, theMinister shall develop guidelines explaining the circum-stances and conditions under which pollution preventionplanning is appropriate. The guidelines have beenpublished and are referred to in Section 3 of this paper.

The CEPA 1999, provides for other pollution pre-vention related initiatives under section 63. To encour-age and facilitate pollution prevention, the Minister may

set up and maintain a national pollution preventioninformation clearinghouse to collect, exchange anddistribute information. The Canadian Pollution Pre-vention Information Clearinghouse (CPPIC) exists andis referred to in Section 3. Also, the Minister mayestablish a program to publicly recognize significantachievements in pollution prevention. Although, atpresent, there is no federal awards program run byEnvironment Canada, the Department participates in,and contributes financially to, the Canadian Council ofMinisters of the Environment national awards programwhich recognizes pollution prevention excellence. Insetting up the information clearinghouse and therecognition program, the Minister may act alone or inco-operation with other governments, institutions orpersons.

There are significant penalties for not complying withthe provisions of the CEPA 1999 or for providing false ormisleading information. Penalties are described in sec-tions 272 and 273 and include fines of up toCN$1,000,000and imprisonment of up to 3 years, or both. As yet, therehave been no prosecutions undertaken, nor penaltiesissued regarding the P2 planning provisions.

Tools available in support of Part 4 of CEPA 1999are outlined in the next section.

3. Support tools for pollution prevention planning

Environment Canada has developed informationsupport tools to assist persons subject to a CanadaGazette Notice requiring the preparation and imple-mentation of P2 plans, or those interested in learningmore about P2 planning. Those support tools includethe following printed and electronically availablematerials.

� ‘‘Guidelines for the Implementation of the PollutionPrevention Planning Provisions of Part 4 of theCanadian Environmental Protection Act, 1999(CEPA 1999)’’ [3]. This document describes thecircumstances under which the P2 planning provi-sions in Part 4 of CEPA are to be implemented.Included are a sample Gazette Notice and templatesfor submissions to Environment Canada of declara-tions and other documents from persons subject toa Notice. A Gazette Notice announcing that theseGuidelines have been developed was published inthe Canada Gazette on February 17, 2001. Thisdocument is available in print or can be downloadedfrom http://www.ec.gc.ca/nopp/docs/p2p/gbook/en/index.cfm.

� ‘‘Frequently Asked Questions’’ [4]. This document isdesigned to help those responsible understand their

634 P. Fischer / Journal of Cleaner Production 14 (2006) 629e635

obligations under CEPA 1999 when they are re-quired by Notice to prepare and implement a P2plan. It describes, in a question and answer format,how the provisions under Part 4 of CEPA areadministered and what affected parties must do. Thisdocument is available in print or can be downloadedfrom http://www.ec.gc.ca/nopp/docs/p2p/faq/en/index.cfm.

� ‘‘Pollution Prevention Planning Handbook’’ [5]. Thishandbook provides an overview of pollution pre-vention (P2), information on the P2 planning process,a model plan template, and detailed information onpollution prevention practices and certain analyticaltechniques for preparing a P2 plan. This documentis available in print or can be downloaded fromhttp://www.ec.gc.ca/NOPP/DOCS/P2P/hbook/En/index.cfm.

� ‘‘P2 Planning On-line Tutorial’’. This tutorial showsquickly and easily the basics of developing a P2 plan.It is available at http://www.ec.gc.ca/NOPP/P2TUT/en/index_e.html.

� The Canadian Pollution Prevention InformationClearinghouse (CPPIC) is an electronic databasecovering more than 40 industrial sectors and 80different substances. Visitors and researchers canbrowse through and access more than 1500 P2references, ranging from fact sheets to case studies.CPPIC is located at http://www.ec.gc.ca/CPPIC.The current website is being redesigned. A newversion with new features is anticipated for spring2005.

� The Canadian Environmental Protection Act, 1999,‘‘A Guide to the Canadian Environmental Protec-tion Act, 1999’’ [6] and related documents, includ-ing official Canada Gazette Notices, are available atthe CEPA Registry website: http://www.ec.gc.ca/CEPARegistry/default.cfm.

� ‘‘Fact Sheet Series’’ The National Office of PollutionPrevention has developed several pollution pre-vention fact sheets. These fact sheets cover topicsincluding pollution prevention activities, best prac-tices, and activities that individual Canadians,companies, and government departments can in-corporate into everyday life. http://www.ec.gc.ca/NOPP/DOCS/FACT/En/index.cfm.

More information on CEPA pollution preventionprovisions and support tools and printed copies ofdocuments, are available from: CEPA Implementationand Innovation Division, 13th floor, 351 St. JosephBlvd., Hull, Quebec K1A 0H3, Canada; Tel.: C1 819994 0186; fax: C1 819 953 7970; or E-mail cepap2plans@ec.gc.ca; or visit the CEPA Registry website at: http://www.ec.gc.ca/CEPARegistry/default.cfm or theNationalOffice of Pollution Prevention’s website at http://www.ec.gc.ca/NOPP.

4. Areas for future research

In this paper, no attempt has been made to analysethe strengths and weaknesses of the P2 planningprovisions in CEPA 1999, and where appropriate,suggest improvements, or to evaluate the effectivenessof the provisions, or to compare them with otherlegislated and non-legislated approaches to P2 andcleaner production. However, these are clearly areasthat would benefit from future research, especially inlight of the anticipated 5-year review of the CEPA bya parliamentary committee. Although the P2 planningprovisions have existed for 5 years, there are still verylimited results and information available, either toanalyse how well the provisions work or, for overallprogram evaluation. There have been only five final P2Planning Notices published, two in 2003 and three inDecember 2004. It would be useful to compare andevaluate the P2 planning provisions in CEPA withsimilar provisions and programs for P2 and cleanerproduction both within Canada, e.g. Toronto’s Sewer-Use Bylaw and the Alberta Leaders EnvironmentalApproval Document (LEAD) Program,8 and also out-side Canada. Likewise, it would be useful to determineand evaluate the popularity, use and effectiveness of theinformation support tools, as well as promotion andawareness activities, and, where appropriate, suggestimprovements.

The renewed and strengthened Canadian Environ-mental Protection Act, 1999, contains requirements forpollution prevention planning for substances declaredtoxic under CEPA 1999. This paper has reviewed thoserequirements, noted the extent of their use to date,outlined the support tools available to assist personssubject to those requirements and others who areinterested in pollution prevention planning, and hasidentified related areas for future research.

Acknowledgements

The author thanks Catherine Ponsford, former PolicyAnalyst, and Kimberley Cameron, Program Officer,both with Environment Canada, for their valuablesupport, comments and suggestions.

8 In the province of Alberta, Canada, the Alberta Leaders

Environmental Approval Document (LEAD) Program provides an

alternative regulatory framework for dealing with industrial activities.

This framework is an option to the command and control approach

that Alberta Environment currently uses. The LEAD program offers

to good environmental performers recognition and regulatory

flexibility. Information about the program is available on Alberta

Environment’s website: http://www3.gov.ab.ca/env/protenf/approvals/

factsheets/lead.html.

635P. Fischer / Journal of Cleaner Production 14 (2006) 629e635

References

[1] Statutes of Canada, 1999, Chapter 33, The Canadian Environ-

mental Protection Act.

[2] City of Toronto Municipal Code, chapter 681 (By-law 457e2000).[3] Environment Canada. Guidelines for the implementation of

pollution prevention planning provisions of part 4 of the Canadian

Environmental Protection Act, 1999. Ottawa, Canada: Environ-

ment Canada; 2001.

[4] Environment Canada. Pollution prevention planning provi-

sions of part 4 of the Environmental Protection Act, 1999, fre-

quently asked questions. Ottawa, Canada: Environment Canada;

2001.

[5] Environment Canada. Pollution prevention planning handbook.

Ottawa, Canada: Environment Canada; 2001.

[6] Environment Canada. A guide to the Canadian Environmental

Protection Act, 1999. Ottawa, Canada: Environment Canada;

2000.