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Assessing mercury health risks and federal mercury management

Petition: No. 183

Issue(s): Human health/environmental health, natural resources, toxic substances, and waste management

Petitioner(s): Pollution Probe

Date Received: 15 December 2006

Status: Completed

Summary: This petitioner would like to know if the government has undertaken any recent studies on the risks of mercury to human health and the environment. The petition asks if specific decisions have been made regarding health risks in vulnerable human and/or wildlife populations to low-level mercury exposure. It also requests a copy of Canada's plan for "full life-cycle management" of mercury as described in the federal Toxic Substances Management Policy and asks how the Canadian Environmental Protection Act is used to reduce mercury in Canada.

Federal Departments Responsible for Reply: Environment Canada, Health Canada, Natural Resources Canada

Petition

Environmental Petition
Office of the Auditor General of Canada
Commissioner of the Environment and Sustainable Development
240 Sparks Street
Ottawa, Ontario
K1A 0G6
petitions@oag-bvg.gc.ca

December 12, 2006

This petition is being submitted by Pollution Probe in accordance with the Auditor General Act for response by the Departments noted below.

Yours truly,

[Original signed by Quentin Chiotti]

Dr. Quentin Chiotti, Senior Scientist


Title of petition

Assessing Mercury Health Risks and Federal Mercury Management

Background information

Mercury emissions and releases continue to pose health risks to Canadians, particularly northern residents and those reliant on aquatic species for protein. Recent determinations from the US National Academy of Sciences and the Centre for Disease Control suggest that up to 300,000 American children are at risk from early exposure to mercury. Levels of mercury in the environment and exposures may be considerably higher in parts of Canada.

Specific questions

  1. Has Health Canada or Environment Canada undertaken any epidemiological/risk research in the past five years using recent research findings (e.g. NAS Study, Faroe Islands research) together with deposition and exposure patterns to determine whether mercury poses "unacceptable risks to the environment or human health?"
  2. Has a specific determination of health risks of chronic low level exposure to mercury been made in Canada for vulnerable human and/or wildlife populations and what scientific evidence has led to this determination?
  1. Please provide Canada's plan for "full life-cycle management" of mercury as described in the Toxic Substances Management Policy including long term targets for mercury reduction and domestic policies to achieve those targets, with specific reference to mercury in consumer products including thermostats, electrical switches and fever thermometers.
  2. How is CEPA being used to advance mercury reductions in Canada?

Federal departments and agencies that need to respond

Environment Canada
Health Canada

Contact information
Dr. Quentin Chiotti
Senior Scientist
Pollution Probe
qchiotti@pollutionprobe.org
416 926-1907

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Joint Response: Environment Canada, Health Canada, Natural Resources Canada

17 April 2007

Dr. Quentin Chiotti
Senior Scientist
Pollution Probe
qchiotti@pollutionprobe.org

Dear Dr. Chiotti:

Thank you for your environmental petition No. 183, to the Commissioner of the Environment and Sustainable Development, concerning the Government of Canada's actions on assessing and managing the environmental and health risks associated with mercury. Your petition was received in Environment Canada on December 21, 2006.

Due to the nature of the issues raised in the petition, I am providing a joint response, on behalf of the Honourable Tony Clement, Minister of Health and the Honourable Gary Lunn, Minister of Natural Resources. We have considered your questions and responded to them in the order in which they were presented.

I appreciate the opportunity to respond to your petition and trust that you will find this information helpful.

Sincerely,

[Original signed by John Baird, Minister of the Environment]

John Baird, P.C., M.P.

c.c.:

Mr. Ron Thompson, Interim Commissioner of the Environment and
Sustainable Development
The Honourable Tony Clement, P.C., M.P.
The Honourable Gary Lunn, P.C., M.P.


JOINT RESPONSE FROM THE DEPARTMENTS OF ENVIRONMENT,
HEALTH, AND NATURAL RESOURCES

PETITION SUBMITTED BY

POLLUTION PROBE

CONCERNING THE ASSESSMENT OF MERCURY
HEALTH RISKS AND FEDERAL MERCURY MANAGEMENT

Introduction

This document provides detailed answers to the questions raised in the petition received from Pollution Probe.

Question 1: Has Health Canada or Environment Canada undertaken any epidemiological/risk research in the past five years using recent research findings (e.g. NAS Study, Faroe Islands research) together with deposition and exposure patterns to determine whether mercury poses "unacceptable risks to the environment or human health?"

Response:

Any new data that is available and properly vetted is evaluated to determine if this new information can be used to amend the provisional Tolerable Daily Intake (pTDI) for methyl mercury. A provisional Tolerable Daily Intake (pTDI) of 0.47 microgram per kilogram of body weight per day for methyl mercury was established in 1972 by the Food and Agriculture Organization/World Health Organization Joint Expert Committee on Food Additives (JECFA). This level of dietary exposure was adopted by Health Canada, and was reaffirmed in 1989 for the general population. However, through further studies, JECFA cautioned that pregnant women and nursing mothers were likely to represent a greater risk from the adverse effects of methyl mercury (WHO, 1989). This concern was shared by the bureau of Chemical Safety in the Foods Directorate of Health Canada and, in 1998, the Foods Directorate of Health Canada reviewed the new studies and lowered the maximum pTDI for methyl mercury to 0.2 microgram per kilogram of body weight per day for pregnant women, women of childbearing age and young children. A recent evaluation by JECFA (WHO, 2003) derived a similar value (pTWI of 1.6 microgram per kilogram of body weight per week or 0.23 microgram per kilogram of body weight per day) to the Health Canada pTDI.

In addition, Health Canada is involved in the assessment of the health effects research in the Seychelles and Faroe Islands, and co-funds human health research in arctic Canada on the possible effects of environmental levels of contaminants such as PCBs, mercury and other contaminants with the Department of Indian Affairs and Northern Development under the federal Northern Contaminants Program (NCP). An Inuit infant cohort study in arctic Quebec is led by Dr. Eric Dewailly and colleagues at Laval University and is co-funded by the NCP, the province of Quebec and the United States National Institute of Environmental Health Sciences. The initial research results have confirmed higher exposures to PCBs, mercury and other environmental contaminants among Inuit and their children. Health effects research among the Inuit children is ongoing. These results from Arctic Canada / Quebec when integrated with the health effects research from other infant / child cohort studies in the Seychelles / Faroes Islands will allow for the best assessment of the impact of environmental exposures to contaminants such as mercury.

From a human health perspective, the main route of exposure to methyl mercury is in the diet, and more specifically from the consumption of certain species of fish and marine mammals. The Food Directorate of Health Canada has established a guideline level of 0.5 parts per million (ppm) for total mercury in domestically produced and imported fish considered to be the major source of dietary exposure. This guideline is enforced by the Canadian Food Inspection Agency (CFIA).

Health Canada gives the following advice concerning fish consumption:

  • Based on the health benefits of fish consumption, Canada's Food Guide recommends that Canadians eat at least two Food Guide Servings of fish each week. Choose fish such as char, herring, mackerel, salmon, sardines or trout.
  • Health Canada also provides the following advice for limiting exposure to mercury from certain types of fish:
    • Consumers are advised to limit consumption of shark, swordfish and fresh or frozen tuna to a maximum of no more than one meal per week for children, pregnant women and women of childbearing age, consumption of these fish should be limited to no more than one meal per month.
    • Women who are or who may become pregnant, or who are breastfeeding can eat up to four Food Guide Servings of canned albacore tuna each week. Children between one and four years old can eat up to one Food Guide Serving of albacore tuna each week. Children between five and eleven years old can eat up to two Food Guide Servings of albacore tuna each week. One Food Guide Serving is 75g, 2 ½ oz, 125 mL, or ½ cup.
    • All shipments of canned tuna (both albacore/white and light) are regularly tested and usually found to be well below the Health Canada guideline of 0.5 ppm. However, since canned albacore tuna (which is the same as canned white tuna) in particular contains on average more mercury than canned light tuna, and since canned tuna as a convenient source of protein may be consumed more often than other types of fish, consumption advice is provided.
    • For sport fish caught in local waters, consumers should be aware of any fish advisory from provincial and territorial authorities, and in some cases, the federal Department of Fisheries and Oceans, and Parks Canada.
    • Additional information on these levels may be obtained at:
      Canada's Food Guide - fish consumption:
      http://hc-sc.gc.ca/fn-an/food-guide-aliment/choose-choix/meat-viande/index_e.html
      Advice on canned albacore tuna:
      http://hc-sc.gc.ca/ahc-asc/media/advisories-avis/2007/2007_14_e.html

These levels of exposure to methyl mercury are considered to be an acceptable risk to the Canadian public based on current scientific knowledge.

Question 2: Has a specific determination of health risks of chronic low level exposure to mercury been made in Canada for vulnerable human and/or wildlife populations and what scientific evidence has lead to this determination?

For human populations, as stated in the previous question, the pTDI for methyl mercury are considered protective of human health based on current scientific knowledge. Levels of exposure to sensitive (vulnerable) sub-populations is based on dietary exposure to methyl mercury. In the majority of vulnerable sub-populations in Canada, dietary intake for methyl mercury is well within the Health Canada guideline for protection of pregnant women, women of childbearing age and young children (vulnerable populations) at 0.2 microgram per kilogram of body weight per day. As indicated previously, Health Canada's evaluation of this guideline was supported by the evaluation undertaken by the Joint Expert Committee on Food Additives (JECFA) World Health Organization (WHO) in 2003. Both of these evaluations included the most recent exposure and effects data from the Faroe Islands and other studies.

A comprehensive nation-wide biomonitoring program which will include a large suite of contaminants (including mercury) will be launched in 2007, with the desired goal to provide up to date information on current exposures of these substances to the Canadian public.

With respect to wildlife populations, Environment Canada has been and continues to conduct research on assessing the levels and risks of exposure of fish and other wildlife populations to methylmercury. This includes:

  • Measuring and estimating mercury concentrations in fish and their food webs (for example, in arctic char, marine mammals (seals), loons, etc.);
  • Assessing the exposure to, and adverse effects of, methylmercury on the behaviour, reproduction and survival of some wildlife populations (for example, reproduction of loons in Nova Scotia); and
  • Producing datasets and reviews on methylmercury levels and adverse effects in fish and wildlife for use by international colleagues in wildlife risk assessments.

In addition, Environment Canada researchers have been working with others to show how modeling can be used to demonstrate that mercury emissions reductions may have real benefits to certain wildlife populations that are currently exposed to higher levels of methylmercury.

Some references from recent years which include further detail on this work include:

    An assessment of the toxicological significance of anthropogenic contaminants in Canadian arctic wildlife, Aaron T. Fisk, Cynthia A. de Wit, Mark Wayland, Zou Zou Kuzyk, Neil Burgess, et al., Science of the Total Environment 351–352 (2005) 57–93

    Bioaccumulation of mercury in yellow perch (Perca flavescens) and common loons (Gavia immer) in relation to lake chemistry in Atlantic Canada, Neil M. Burgess & Keith A. Hobson, Hydrobiologia 567 (2006) 275–282

    Biological mercury hotspots in the Northeastern United States and Southeastern Canada, David C. Evers, Young-Ji Han, Charles T. Driscoll, Neil C. Kamman, M. Wing Goodale, et al., BioScience, 57(1) (2007) 29-43

    Contaminant Levels, Trends and Effects in the Biological Environment. Fisk, A.T., Hobbs, K and Muir, D.C.G. (Eds). 2003. In: Canadian Arctic Contaminants Assessment Report II, Indian and Northern Affairs Canada, Ottawa.

    Effects of environmental methylmercury on the health of wild birds, mammals, and fish, Anton M. Scheuhammer, Michael W. Meyer, Mark B. Sandheinrich and Michael W. Murray, Ambio, in press

    Elevated mercury levels in a declining population of ivory gulls in the Canadian Arctic, Birgit M. Braune, Mark L. Mallory, H. Grant Gilchrist, Baseline / Marine Pollution Bulletin 52 (2006) 969–987

    Mercury and other Contaminants in Common Loons Breeding in Atlantic Canada, Neil M. Burgess, David C. Evers, Joseph D. Kaplan, Ecotoxicology 14 (2005) 241–252

    Mercury in biota and its effects, Neil Burgess, Mercury: Sources, Measurements, Cycles and Effects Mineral Assoc. Canada, Short Course 34 (2005) 235-258

    Mercury in Freshwater Fish of Northeast North America – A Geographic Perspective Based on Fish Tissue Monitoring Databases, Neil C Kamman, Neil M. Burgess, Charles T. Driscoll, Howard A. Simonin, Wing Goodale, et al., Ecotoxicology 14 (2005) 163–180

    Mercury in brook trout, white perch, and yellow perch in Kejimkujik National Park, Clifford Drysdale, Neil M Burgess, Andre D'entremont, Jennifer Carter, Guy Brun, Mercury Cycling in a Wetland Dominated Ecosystem: A Multidisciplinary Study, Society of Environ Toxicol Chem (SETAC) (2005) 323-348

    Patterns and Interpretation of Mercury Exposure in Freshwater Avian Communities in Northeastern North America, David C. Evers, Neil M. Burgess, Louise Champoux, Bart Hoskins, Andrew Major, et al., Ecotoxicology, 14, 193–221, 2005

2. a) Please provide Canada's plan for "full life-cycle management" of mercury as described in the Toxic Substances Management Policy including long term targets for mercury reduction and domestic policies to achieve those targets, with specific reference to mercury in consumer products including thermostats, electrical switches and fever thermometers.

The Government of Canada is involved in the development and implementation of several initiatives to help reduce mercury releases and manage risks associated with exposure to mercury throughout its life-cycle. The Government also continues to track and report on mercury reductions. Canada, through use of a number of legislative authorities by all levels of government, has achieved emissions reductions of about 80 percent since 1990 which is on a par with other Organisation for Economic Co-operation and Development (OECD) countries. It is important to note that mercury is regulated at the federal level by the Canadian Environmental Protection Act, 1999 (CEPA 1999), the Hazardous Products Act, the Pest Control Products Act, the Food and Drug Act, and the Fisheries Act.

Some recent examples of initiatives to reduce releases of mercury to the environment, which include targets and objectives, are the Canada-wide Standard (CWS) for Mercury Emissions from Coal-fired Electric Power Generation Plants, the Proposed Pollution Prevention Planning Notice Requiring the Preparation and Implementation of Pollution Prevention Plans in Respect of Mercury Releases from Mercury Switches in End-of-life Vehicles Processed by Steel Mills, and the Risk Management Strategy for Mercury-containing Products. These initiatives are described in more detail below.

Environment Canada has worked with the provinces and territories through the Canadian Council of Ministers of the Environment (CCME) to establish a Canada-wide Standard (CWS) for Mercury Emissions from Coal-fired Electric Power Generation Plants. Agreed to on October 11, 2006, the CWS is set to achieve by 2010 a 45 percent reduction of mercury emissions from existing plants, relative to 2003 emissions.

On December 9, 2006, Environment Canada published a Proposed Notice Requiring the Preparation and Implementation of Pollution Prevention Plans in Respect of Mercury Releases from Mercury Switches in End-of-life Vehicles Processed by Steel Mills in Part I of the Canada Gazette for a 60-day comment period. Comments received are being considered and a Final Notice is expected to be published in 2007. It is proposed that this action will require vehicle manufacturers and steel mills that process end-of-life vehicles to develop and implement pollution prevention plans to address mercury releases from switches found in cars. This measure will prevent the release of up to 10 tonnes of mercury into the environment over the next 10 years.

In addition, on December 20, 2006, Environment Canada published a Risk Management Strategy for Mercury-containing Products (RMS). The RMS proposes the development of a mix of risk management instruments to reduce mercury releases to the environment from products to the lowest possible levels. Although the RMS applies to mercury-containing products in general, it specifically addresses the use of mercury in dental amalgam, thermostats, switches/relays, lamps, batteries, measuring devices, thermometers and tire balancing products.

This RMS considers prohibition or limits for existing products and new products, labelling requirements, waste management and extended producer responsibility. Development of the proposed instrument(s) is scheduled to begin in fall 2007, following public consultations and a formal cost-benefit analysis of the proposed initiatives. The RMS is attached and is also available for comment until March 31st, 2007 on the web at: http://www.ec.gc.ca/ceparegistry/documents/part/Merc_RMS/index.cfm

Although domestic measures will continue to reduce the risk of mercury in Canada, efforts must also be made on a regional and global scale because a portion of the mercury in our lakes and soil originates from other countries via long-range atmospheric transport. Therefore, Canada continues to play a leadership role in the development and implementation of international mercury management initiatives including the Aarhus (Heavy Metals) Protocol under the United Nations Economic Commission for Europe Convention on Long-range Transboundary Air Pollution, the Arctic Council, the Great Lakes Binational Toxics Strategy, the North American Regional Action Plan on Mercury and various national and bilateral monitoring programs.

2. b) How is CEPA being used to advance mercury reductions in Canada?

Under CEPA 1999, the Government of Canada has carried out a number of risk management activities that target priority industrial and natural resource sectors and other sources of mercury. Risk management activities put in place for mercury under CEPA 1999 and through the CCME include:


Regulations in force under CEPA 1999

http://www.ec.gc.ca/CEPARegistry/regulations/

Chlor-Alkali Mercury Release Regulations

The Regulations limit the release of mercury to air. The release regulations limit the release of mercury on a "per 1000 kg of rated capacity" from the following sources:

5 g mercury per day - ventilation gases exhausted from the cell room

0.1 g mercury per day - hydrogen gas stream from the denuders

0.1 g mercury per day - ventilation gases exhausted from end boxes and tanks

0.1 g mercury per day - exhaust gases from retorts

The Regulations set a limit to the total amount of mercury released into the ambient air by a plant from the above sources to 1.68 kg of mercury per day.

The Regulations specify plant operating conditions under which the measurement of mercury releases will be conducted and the duration of sampling; specifies the number of measurements for each source; and specifies the standard reference for source testing.

Where Minister requests information, the regulation requires: that measurements be conducted four times per year and that at least one of these measurements be conducted in the presence of an inspector; the submission of written reports in the event that air pollution control equipment or process equipment malfunctions or breaks down; and submission of written reports to EC.

The industry also compiles on a yearly basis for each facility a "Mercury Disposition Report" as part of a CCPA requirement. This report is submitted to EC.

Since promulgation of the Chlor - Alkali Release Regulations, there is now (in 2007) only a single operating mercury cell plant in Canada.

Export and Import of Hazardous Waste and Hazardous Recyclable Material Regulations

The purpose is to protect Canada's environment and the health of Canadians from the risks posed by the transboundary movement of hazardous wastes and hazardous recyclable materials through exports from and imports into Canada and to implement Canada's international obligations. The Regulations repealed and replaced the former Export and Import of Hazardous Wastes Regulations (EIHWR) adopted in 1992 under the authority of the former Canadian Environmental Protection Act. The Regulations include provisions with respect to prior informed consent through notification, and tracking of such movements.

Export Control List Notification Regulations

The Regulations require exporters to provide notice to the Minister of Environment of the proposed exports of substances on the Export Control List, Schedule 3 of CEPA 1999 and to submit annual reports. The Regulations are instrumental in the implementation of subsection 101(1) and section 103 of the Act.

Disposal at Sea Regulations

CEPA 1999 prohibits disposal at sea, except for low risk materials, subject to individual environmental assessment, and controlled under permit conditions. Each year in Canada, two to three million tonnes of material are disposed of at sea. Most of this is dredged material that must be moved to keep shipping channels and harbours clear for navigation and commerce. Only those substances listed in CEPA 1999 may be considered for disposal at sea, including dredged material, fisheries waste, ships, inert matter, uncontaminated organic matter and bulky substances. The requirements set out a permit system controlling the disposal of waste and other matter at sea. Discharges from land or from normal ship operations (such as bilge water) are not considered disposal at sea, but are subject to other controls.

Mercury is a contaminant of concern for dredged material that is specifically identified at the global and national levels as requiring assessment and control. The Disposal at Sea Regulations set lower action levels for mercury in dredged and excavated material. Disposal of dredged material containing mercury below this amount are considered to be of little concern for disposal at sea. Above these levels, applicants must conduct a battery of toxicity and bioaccumulation tests to determine if the waste is acceptable for disposal at sea. Mercury is also one of the contaminants of concern which is measured during representative disposal site monitoring to ensure that there is no accumulation or impact over time. Based on monitoring results since 1999, no accumulation of mercury at Canadian disposal sites is being observed.

Environmental Emergency Regulations

The goal of these Regulations is to enhance the protection of the environment and human health in environmental emergency situations by promoting prevention and ensuring preparedness, response and recovery. The Regulations require persons who own or manage specified toxic and hazardous substances at or above the specified thresholds to provide required information on the substance(s), their quantities and to prepare and implement environmental emergency plans.

Notice of Intent

Notice of intent to develop and implement regulations and other measures to reduce air emissions

On October 21, 2006, the Government of Canada published in the Canada Gazette its Notice of Intent to regulate air emissions, including mercury, from industrial sectors. Consistent with the Notice of Intent, Environment Canada intends to propose regulations to reduce air emissions from key industrial sectors including fossil-fuel fired electricity generation. As the Notice of Intent states, the Government of Canada is currently in consultation to establish the framework that these regulations will be based upon.

Canada-wide Standards under Part 1 of CEPA 1999

http://www.ec.gc.ca/MERCURY/MM/EN/mm-cws.cfm?SELECT=MM

Mercury-Containing Lamps

Takes a pollution prevention approach by calling for a reduction in the average mercury content of lamps sold in Canada. From a 1990 baseline, the numeric target is a 70% reduction by 2005 and a total reduction of 80% by 2010. This CWS also includes a commitment for jurisdictions to assess the feasibility of recycling/recovery of lamps and to implement initiatives to encourage these types of activities, when appropriate.

According to the 2005 progress report on implementation of the Canada-wide Standards, in 2004 industry reported that the average mercury content of all mercury-containing lamps sold in 2003 was 73.5% lower than the 1990 baseline of 43 mg per lamp, exceeding the 2005 CWS target of 70% reduction. The Report on Progress is available at http://www.ccme.ca/assets/pdf/joint_hg_progress_rpt_e.pdf.

Mercury Emissions (base metal smelting and incineration)

Applies to two sectors: base metal smelting and waste incineration. For base metal smelting facilities, a two-part standard has been put forth to deal with both existing and new/expanding operations. New and expanding facilities should be equipped to meet a guideline of 0.2 g mercury per tonne of finished zinc, nickel, or lead or 1 g mercury per tonne of finished copper. Existing facilities are to make a determined effort to reach a guideline of 2 g Hg per tonne of finished metal by 2008.

Under the CWS, limits for the concentration of mercury in exhaust gas have been established for various types of waste incinerators.

The 2005 Report on Progress is available at
http://www.ccme.ca/assets/pdf/joint_hg_progress_rpt_e.pdf.

A report in 2007 will address compliance by all incineration sectors and progress by base metal smelters.

Dental Amalgam Waste

Goal is to reduce national mercury releases from dental amalgam waste by 95% by 2005 from a 2000 baseline. This CWS promotes the use of best management practices, such as the installation of ISO certified amalgam traps, in order to achieve the target.

According to the 2005 progress report on implementation of the Canada-wide Standards, a 2003 national survey funded by Environment Canada to assess the use and fate of dental amalgam waste in Canada estimated that as of 2003, 27% of dentists had ISO certified amalgam separators. New information on progress is expected to be released in 2007. The Report on Progress is available at http://www.ccme.ca/assets/pdf/joint_hg_progress_rpt_e.pdf.

Coal-fired Electric Power Generation Plants

Set to achieve by 2010 a 45% reduction of mercury emissions from existing plants, relative to 2003 emissions. The CWS is set to control emissions from existing plants using province specific caps; emissions from new plants will be controlled by strict emission rates. The CWS was endorsed by Ministers on October 11, 2006

Environmental Codes of Practice with industry

Environmental Code of Practice for Integrated Steel Mills

Both codes identify good environmental protection practices for various production processes and operations of an integrated steel plant, with air emission and water effluent considerations as the highest priorities. They also include other considerations consistent with a comprehensive and life-cycle approach to environmental protection. The guideline for mercury in effluent within both codes of practice is 0.01 milligrams per litre.

Environmental Code of Practice for Non-Integrated Steel Mills

Memorandum of Understanding with an industry association

Memorandum of Understanding between Environment Canada and The Canadian Dental Association

The CWS for Dental Amalgam Waste led to the signing of a Memorandum of Understanding (MOU) by Environment Canada and the Canadian Dental Association, committing each to actions towards the voluntary implementation of the Canada-wide Standard on Mercury for Dental Amalgam Waste (CWS).

Pollution Prevention Plans

Pollution Prevention Planning Notice for Base Metals Smelters and Refineries and Zinc Plants

On April 29, 2006, the Minister of the Environment published a Final Notice under Part 4 of the Canadian Environmental Protection Act, 1999 (CEPA 1999). This Notice outlines the requirements to prepare and implement pollution prevention plans for base metals smelters and refineries and includes the Canada-wide Standard for release of mercury from base metals smelters as a factor to consider in developing and implementing the P2 Plan. In addition, the Notice includes a specific target and schedule for the only facility not currently meeting the standard. This annual air release limit target for mercury was derived from the associated Canada wide Standards (CWS). The Final Notice is available at http://canadagazette.gc.ca/partI/2006/20060429/html/notice-e.html#i5

Pollution Prevention Planning Notice for Mercury Releases from Mercury Switches in End-of-Life Vehicles Processed by Steel Mills

On December 9, 2006, Environment Canada published a "Proposed Notice Requiring the Preparation and Implementation of Pollution Prevention Plans in Respect of Mercury Releases from Mercury Switches in End-of-life Vehicles Processed by Steel Mills" in Part I of the Canada Gazette for a 60-day comment period. Comments received are being considered and a Final Notice is expected to be published in 2007. This action will require vehicle manufacturers and steel mills that process end-of-life vehicles to develop and implement pollution prevention plans to address mercury releases from switches found in cars. This measure will prevent the release of up to 10 tonnes of mercury into the environment over the next 10 years.

Risk Management Strategy

Risk Management Strategy (RMS) for Mercury-containing Products

The risk management objective for this strategy is to reduce mercury releases to the environment from consumer products to the lowest possible level. The extent of the reduction of mercury in each product category will be based on the technical and economic feasibility of reducing or substituting mercury, the environmental impact of alternative products and current actions addressing mercury in products (e.g. Canada-wide Standards).

The tool deemed most appropriate for managing mercury releases from mercury-containing products, to a level consistent with the risk management objective, is a regulation under section 93 of CEPA 1999.

For more information, the RMS is attached and is also available for comment until March 31st, 2007 on the web at: http://www.ec.gc.ca/ceparegistry/documents/part/Merc_RMS/index.cfm

Reporting Tool

National Pollutant Release Inventory

The National Pollutant Release Inventory (NPRI) provides Canadians with access to information on the releases and transfers of key pollutants in their communities. It is the only national, legislated, publicly accessible inventory of its kind in Canada.

Mercury (and its compounds) has been on the NPRI substance list since the program's inception, at the 10-tonne manufacture, process and otherwise use reporting threshold. In the year 2000, the NPRI reporting threshold for mercury was reduced from 10 tonnes to five kilograms.