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Environmental Compliance Tips and Insights

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Environmental Compliance Tips and Insights

  If you have a question about an environmental compliance issue, or would like us to address a specific environmental compliance issue in the future, contact Christopher Paré, P.Geo., Q.P. at 519-948-7300, ext. 114. Environmental Compliance Tips and Insights 2024 March: Documenting Waste Shipments Do I submit Part C of my movement document (MD) when the waste shipment arrives at the facility or when it is disposed? Part C of an MD is used to track the information about the waste shipment received by the receiving facility. The permit holder...

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Guidance: Environmental Claims and the Competition Act

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Guidance:  Environmental Claims and the Competition Act

  In our July 15, 2024, blog, we discussed Bill C-59 and the substantial changes to Greenwashing under the Competition Act.  On December 23, 2024, the Competition Bureau released draft guidelines: “Environmental Claims and the Competition Act.”  Comments close on February 28, 2025. Competition Act: Six Principles As stated in the draft guidance, while the Bureau does not tell businesses what they can or cannot say, “The Bureau has developed six high-level principles that together can help your business stay onside of the law when it comes to...

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Changes to Ontario’s Records of Site Condition May Help Redevelopment

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Changes to Ontario’s Records of Site Condition May Help Redevelopment

  Developing property in Ontario can, at times, be time-consuming and expensive, especially if the project involves filing a Record of Site Condition (RSC).  There may be some relief as The Ontario Ministry of the Environment, Conservation, and Parks (MECP) is proposing amendments to Ontario Regulation 153/04.  These proposed changes will prohibit the submission of an RSC for filing in specified circumstances and expand an exemption from RSC filing requirements for changes in the use of buildings from commercial or community use to mixed-use,...

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Summary of Environmental Regulatory Developments in 2024

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Summary of Environmental Regulatory Developments in 2024

  In 2024, we noted several environmental regulatory developments. In our final blog for the year, we are providing some reminders regarding regulatory changes and some quickly approaching reporting requirements.  We begin with the news of a new Federal Environmental Agency. New Standalone Water Agency The Canada Water Agency (Agency) was on an interim basis within the Environment and Climate Change Canada. They are now a standalone agency, headquartered in Winnipeg with five regional offices across Canada. Once fully staffed, the Agency will...

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Plastics Registry Reporting Begins in 2025

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Plastics Registry Reporting Begins in 2025

  Environment Minister Steven Guilbeault said he was disappointed that the recent meeting in Busan, Republic of Korea, which included 170 nations, did not reach a conclusion regarding a global treaty to address plastic pollution.  Global talks will resume in 2025. Global efforts notwithstanding, Canada continues to move forward on the federal and provincial levels to address plastics in the environment. Provinces and Territories (with the exception of Prince Edward Island, Newfoundland and Labrador, Nunavut, and Northwest Territories)...

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Additional GHG Regulations for the Oil and Gas Sector

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Additional GHG Regulations for the Oil and Gas Sector

  The federal government continues to develop additional regulatory framework surrounding sustainability and climate-related issues.  The most recent focus is on the Oil and Gas sector.  We also cover a new voluntary sustainability program and new commitments made by the Canadian Government at the Conference of Parties (COP) 29. Oil and Gas Sector GHG Cap The Government of Canada recently (Canada Gazette, November 9, 2024) released the proposed “Oil and Gas Sector Greenhouse Gas (GHG) Emissions Cap Regulations.”  The proposed regulations set...

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Environmental Enforcement Across Canada

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Environmental Enforcement Across Canada

  Enforcement of environmental laws can result in penalties and fines ranging from a few-thousand dollars up to seven figures or more.  In 2020, Volkswagen paid a $196.5 million fine for the class action settlement in what became known as “dieselgate” or “emissionsgate.” This was on top of the agreement to provide benefits and buyback options to Canadian consumers of the non-compliant vehicles up to a maximum of nearly $2.4 billion Regardless of the amount of the fine, enforcement can be aggravating for the companies on the receiving end of...

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Amendments to Ontario’s Excess Soil Regulations

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Amendments to Ontario’s Excess Soil Regulations

  The next phase of Ontario’s excess soils regulations is set to take effect on January 1, 2025, (limiting soils that may be landfilled).  Ahead of this deadline, there are (additional) proposed amendments to Ontario Regulation 406/19. You may recall that in January 2022, contractors were scrambling to comply with the more stringent soil management requirements.  By April 21, 2022, these new requirements were officially paused by the Ministry of Environment, Conservation and Parks (MECP).  This temporary pause was followed by a November 4,...

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The Federal Government Announces Framework to “Modernize” CEPA

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The Federal Government Announces Framework to “Modernize” CEPA

  On October 2, 2024, Steven Guilbeault, Ministry of Environment and Climate Change Canada (ECCC) and Mark Holland, Minister of Health Canada (HC) announced a framework to “protect the right to a healthy environment through the modernization and administration of the Canadian Environmental Protection Act” (CEPA). In the announcement, they state that the public will have an opportunity to comment on several initiatives including the following: A Draft Implementation Framework on the Right to a Healthy Environment under the Canadian...

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Six-Figure Environmental Fines in the News

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Six-Figure Environmental Fines in the News

  While issues such as per- and polyfluoroalkyl substances and managing excess soils are often the topic of discussions at conferences and meetings, it’s still “routine” environmental compliance issues that get the attention of the public, as well as provincial and federal regulators. Below we provide some recent environmental enforcement news, all of which are six-figure fines. Six-Figure Recycling Violation On July 1, 2023, the Blue Box program under the Ontario Resource Productivity and Recovery Authority (RPRA) was modified.  This change...

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