As an initial step in the development of a Pollution Prevention Program for the Province of Nova Scotia, a discussion paper in which the concept of pollution prevention together with suggestions for program delivery, was developed and released in May, 1997. Copies of the paper wereforwarded for comment to approximately 1100 stakeholders of industry, small businesses, industry associations, community and environmental groups, and the three levels of government. Comments received by the Department covered such areas as: legislation, financial assistance, the definition of pollution prevention and the relationship between pollution prevention and environmental management systems.
The discussion paper committed the Department to the development of a strategy that would detail plans for the implementation of the Pollution Prevention Program. This plan, which specifies the pollution prevention initiatives to be introduced by the Department and identifies areas to be examined for future suitability to the program, is presented herein. It is based on comments that were received on the discussion paper.
2.0 Pollution Prevention Program
Environmental regulatory bodies have historically dealt with pollution problems through control or remediation, as opposed to the proactive pollution prevention approach. The Department of the Environment has and will continue to have an infrastructure that deals with pollution problems in this manner. With the introduction of a Pollution Prevention Program, however, the Department will be in a position to provide a comprehensive service that addresses the full spectrum of principles found in a typical Environmental Management Hierarchy.
2.1 Definition of Pollution Prevention
The following definition for pollution prevention has been adopted by Nova Scotia from The Canadian Council of Ministers of the Environment (CCME)(1):
The use of processes, practices, materials, products or energy that avoid or minimize the creation of pollutants and wastes, at the source.
Pollution prevention promotes continuous improvement through operational and behavioural changes. Pollution prevention is a shared responsibility among governments and individuals, industrial, commercial, institutional, and community sectors. It focuses on areas such as:
- substances of concern
- efficient use and conservation of natural resources
- operating practices
- clean production processes which create less waste
- equipment modifications
- process changes
- materials and feedstock substitution
- product design and reformulation
- product life-cycle
- purchasing practices
2.2 Pollution Prevention and Environmental Management
An Environmental Management System (EMS) is that aspect of an organization's overall management function that determines and implements it's environmental policy. It is all encompassing and may include pollution prevention programs, pollution control initiatives, remediation and/or disposal. An EMS is the organizational structure, responsibilities, practices, procedures, processes, and resources for implementing environmental management.
The Department recognizes the importance of EMS and encourages its use. Pollution prevention is the one proactive principle within an EMS and, as it is the one area in which the Department has not provided programs in the past, it is essential that it be the recipient of a dedicated effort in rder to ensure its success. For this reason the primary function of the newly formed pollution prevention section will be to promote pollution prevention in the private, public and community sectors. In some cases pollution prevention initiatives will develop as a component of an EMS. However, it is important to recognize that although pollution prevention is a possible reason for implementing an EMS, it is not the only one.
The very essence of pollution prevention is education and awareness at the manager, employee and public levels. Although, a separate educational package is not available at this time, elements of education and awareness are included in all aspects of the Department's pollution prevention program. The overall intent of the program will be to enhance environmental efficiency through all aspects of human activity.
2.3 The Regulatory Issue
The Department will implement the pollution prevention program through cooperative partnerships with industry, government, and communities. The program will be based upon voluntary agreements and not mandatory legislation. The effectiveness of a voluntary process will be monitored to determine whether some form of mandatory pollution prevention approach should be introduced in the future.
Meanwhile, the Department will move to have pollution prevention incorporated as a component of Environmental Assessments and Approvals under the Environment Act. Initially, this type of pollution prevention initiative will be voluntary for the private sector and mandatory for public sector activities.
In addition, the Department will consider having pollution prevention an explicit criterion in the environmental assessments of projects, programs and policies submitted to the Priorities and Planning Secretariat.
Environment Canada has also introduced a national program in Pollution Prevention this year. The Department will work closely with Environment Canada to ensure consistency between Federal and Provincial efforts. Components of the two programs may be integrated. A formal agreement is currently being developed between the Federal and Provincial Environment Departments.
2.4 Private Sector
Within the private sector, the Nova Scotia pollution prevention program will promote initiatives that are aimed at production efficiency, reduced operating costs, and reduced environmental liabilities, while at the same time improving community, employee, and environmental health. Moving away from the disposal of residuals in the environment and toward operating practices that minimize or avoid the formation of wastes or maximize the recycling of by-products within the production process is the desired outcome. To succeed, it will be necessary to differentiate between the needs and requirements of small business and large industry when working with this important sector.
2.4.1 Large Industry
The pollution prevention section will solicit interest from large industry to undertake pilot projects in the development of the pollution prevention planning process. The Department has an overall objective of establishing at least two large industry partnerships per year in each of the next three years. These long term cooperative arrangements will produce comprehensive pollution prevention plans for industry. This initiative will be used to establish a generic "large industry" pollution prevention planning guide, which will identify incentives, respective roles of government and industry, planning procedures, outcome measurement and the relationship to ISO 14000.
As part of these pollution prevention programs, industry will undertake comprehensive environmental reviews, identify and priorize the recommendations from the review and implement chosen pollution prevention initiatives. The programs will be designed to complement ISO 14000.
The Department will also introduce a more effective and efficient approach to environmental approvals that will streamline and possibly replace the existing command and control approval process. However, detailed community participation programs would be a requirement for any industry requesting exemption from an approval. This would ensure that important public issues would not be lost in any approval exemption process.
2.4.2 Small Business
The Department will enter into agreements with associations that represent small businesses in order to develop codes of practice and certification programs that meet pollution prevention standards. Upon completing codes of practice and certification programs, the department will work with non-association members in an attempt to ensure these programs are implemented throughout the business sector. One agreement will be established annually.
2.4.3 Product Stewardship
The Department plans to designate priority areas in which product stewardship agreements will be developed with manufacturers and/or distributors of affected products. These agreements will result in the distribution of these products and the management of associated wastes being addressed in one complete package. Efforts in this regard would be directed toward areas that are not currently covered in the Province's solid waste management strategy. It is the intention to develop one stewardship agreement annually.
2.5 Public Sector
The Nova Scotia Department of Environment has established a partnership with the Department of Transportation and Public Works to develop a pollution prevention program. This program will assess the design, construction, operation and maintenance of everything from roads to new and existing government facilities. Following this program the Department will approach other departments in an attempt to develop similar partnerships.
The Department will also establish a pollution prevention pilot program with a selected health care facility with the goal to introduce pollution prevention guidelines throughout health care facilities.
The Department will assist with the implementation of the provincial "Environmentally Responsible Procurement Policy" by providing education, periodic assessment, and training to ensure that government purchasing decisions comply with the procurement policy and pollution prevention standards.
The Department will enhance the existing solid waste reduction initiative of provincial departments to ensure the diversion goals of the provincial Solid Waste Resource-Management Strategy are met by the public sector.
The pollution prevention section will develop and maintain a database that identifies available environmental products. This service will be provided on the Department's Web Site of the Internet.
The community sector represents individuals, community groups and municipalities. The Department will encourage individuals and community groups to become involved in pollution prevention initiatives. Initially, the Department will use the services of the Nova Scotia Youth Conservation Corps and other recognized province wide environmental organizations as the primary avenue for community contact. Utilization of this well established and recognized community group infrastructure will facilitate the expeditious establishment of community level programs.
The pollution prevention section will develop a domestic pesticide and integrated pest management awareness program for homeowners in which alternative methods for the control of specific pests are included. Initially, this program will involve the Halifax Cape Breton Regional Municipalities. The program will eventually be expanded to cover the remainder of Nova Scotia.
A household pollution prevention audit and resource guide that will provide information on source reduction, recycling, composting, the safe storage and handling of household hazardous wastes, substitutes for toxic household chemicals, and available information sources and services will be developed. The development and distribution of the audit and guide would be coordinated with regional waste reduction coordinators and municipalities with household level initiatives.
The Department will develop a community pollution prevention guide that will assist individuals and community groups in establishing their own pollution programs.
The Department will develop a comprehensive incentives package as part of the pollution prevention program. As a start we will promote established pollution prevention initiatives through their recognition on the Department web site.
A pollution prevention awards program comprising four categories will be established. The program will be administered through the existing Environmental Awards Program of the Environmental Assessment Board. The categories will include private, public and community sectors as well as a category for innovative technology. The award selection committee will be comprised of Nova Scotia Department of the Environment pollution prevention staff, Assessment Board members, Environment Canada and Clean Nova Scotia Foundation. In addition, representation from small and large industry and municipal interests will be included.
The Department will evaluate pollution prevention based alternatives to the existing approvals process. As part of this evaluation the Department will also consider the use of environmental performance contracts or covenants from industry respecting environmental performance.
Also, the Department will consider the feasibility of incorporating the following incentives through integration of pollution prevention with Approvals:
- Providing flexibility to allow facilities to make pollution prevention oriented changes without the need for an approval modification.
- Providing information on ways to use pollution prevention for compliance with approval limits.
- Providing extended compliance time for facilities who use pollution prevention as a compliance method.
- Allowing alternative monitoring as an incentive for pollution prevention.
The Department will determine the feasibility of utilizing economic instruments to promote pollution prevention in the private and community sectors. These include:
- Offering financial assistance for the development of community based pollution prevention programs through the Nova Scotia Youth Corp and other recognized associations.
- Offering a capital purchase tax credit and accelerated depreciation for equipment specifically purchased for pollution prevention purposes.
- Offering tax relief to companies for the direct costs associated with their involvement in pollution prevention programs that have been approved by the Department.
4.0 Measurement of Success and State of the Environment Reporting
An important aspect of the pollution prevention program is ensuring that the program is achieving its purpose. In the immediate future the Department will establish goals and objectives and develop a protocol to measure the success of the program. In addition, the progress of the program will be reported in the State of Environment Reports.
Nova Scotia is determined to move into the next millennium with a more encompassing approach to environmental management. The Department wants all Nova Scotians to be more aware and proactive in the ways that we deal with our pollution. With the wise and efficient use of resources and the enhancement of economic opportunity for Nova Scotians, pollution prevention provides a firm link between the environment and the economy. To achieve this major objective will require significant cooperation and commitment of all Nova Scotians as well as strong government leadership with coordinated planning. In keeping with this commitment the Department will conduct an annual review of the Pollution Prevention Program to ensure that it continues to reflect current environmental standards/policies and addresses public concerns.
6.0 Action Plan
The Department's newly formed pollution prevention section is responsible to provide ongoing research, track individual project progress, prepare and distribute a wide range of information, administer the awards program, develop sectoral pollution prevention guides and codes of practice, monitor progress of the overall program and assist in the development of pollution prevention programs and pilot projects. The following action plan covers the Department's commitments to the program in the short term, the next two years.
- Develop the Pollution Prevention Awards Program. Feb 1999
- Review opportunities to include pollution prevention as a component of approvals and environmental assessments. Apr 1999
- Showcase pollution prevention achievements. Ongoing
- Evaluation of the utilization of economic instruments. End of 1999
- Develop protocol to measure success of program. End of 1999
Private Sector Programs
- Develop at least two partnerships per year with industry. Ongoing
- Develop sectoral based codes of practice for small business (at least one per year). Ongoing
- Develop Large Industry Planning Guide. End 1999
- Product stewardship agreements. End 1999
Public Sector Programs
- Develop a comprehensive pollution prevention program for the Department of Transportation and Public Works. End 1999
- Develop a second partnership with another provincial Department to establish a pollution prevention program. Apr 1999
- Develop program to ensure implementation of the
Environmentally Responsible Procurement Policyand the goals of the Solid Waste Resource-Management Strategy throughout provincial government departments. Apr 1999
- Develop pilot project with a selected health care facility. Apr 1999
- Facilitate the development of community level pollution prevention projects through the Nova Scotia Youth Conservation Corp. Ongoing
- Develop domestic integrated pest management awareness program for: Halifax Regional Municipality. Winter 1999
- Cape Breton Regional Municipality. Winter 1999
- Develop and distribute Household Pollution Prevention Audit and Resource Guide. Summer 1999
- Develop Community Pollution Prevention Guide. End of 1999