Harbour Authority Manual

5. Environmental Management

Table of Contents

Back
Introduction
Administration
Finance
Harbour Operations
Environmental Management
PDF Version

5.1	Environmental Management Plan
5.2	Responsibilities in Environmental Management
5.3	Environmental Inspections
5.4	Environmental Management Tasks
5.5	Environmental Record Keeping
5.6	Best Management Practices

5.1 - Environmental Management Plan

Harbour Authorities assisted by Small Craft Harbours (SCH) are required to create and implement an Environmental Management Plan (EMP) to ensure that its activities are carried out in an environmentally friendly manner. The EMP should be based on the Department of Fisheries and Oceans (DFO), Small Craft Harbours EMS Reference Manual. The information provided in this Environmental Management portion of the Harbour Authority Manual describes the environmental policies and procedures that would normally be contained in an EMP.

This section briefly summarizes the rules and legislative requirements enacted by various levels of government that must be taken into account in environmental decision making.

5.1.1	Environmental legislation and legal requirements
5.1.2	Enforcing legal requirements

5.1.1 Environmental legislation and legal requirements

The federal, provincial, and municipal environmental legislation, regulations, or by-laws that apply to a Harbour Authority are summarized below. A Harbour Authority should acquire and keep a complete set of environmental legislation and guidelines, for reference purposes, in its main environmental filing system.

Key federal requirements

1. No harmful substances of any type may be deposited (i.e., from ships, sewers, run-off, etc.) in waters frequented by fish. (Fisheries Act)
2. The discharge of garbage, oil and oily mixtures, ballast and bilge, and pollutants listed in the Pollution Substance Regulations is prohibited. (Canada Shipping Act)
3. The direct discharge of sanitary wastes into certain bodies of water is prohibited. The discharge of galley or washing wastes is not prohibited. (Canada Shipping Act)
4. Permits are required for dumping contaminated and harmful substances (including dredged sediments) into Canadian waters. (Canadian Environmental Protection Act)
5. The discharge of any waste or material that would impair navigation in navigable waters is prohibited. Certain material-such as rock, gravel, soil, or ash-can be discharged where water depth exceeds 20 fathoms. (Navigable Water Protection Act)
6. Petroleum storage tanks on federal lands must be registered. (This requirement is currently managed by DFO-SCH.) (Canadian Environmental Protection Act)
7. All necessary precautions to avoid accidental spills should be taken; in the event of a spill, an emergency spill response should proceed. A list of hazardous substances that are used on site and that are likely to contaminate the environment if spilled should be created. The release of a toxic substance to the environment must be reported. (Canadian Environmental Protection Act)
8. The Workplace Hazardous Materials Information System (WHMIS) requires that information on hazardous materials used in the workplace be provided.
   • Containers for hazardous material must have cautionary labels affixed.
   • Material Safety Data Sheets (MSDSs) must be supplied for all hazardous materials.
   • All employees must be educated on WHMIS. (Hazardous Products Act)
9. The storage of, and emergency response to, spills of flammable and non-flammable hazardous liquids must meet the requirements of the National Fire Prevention Code. The requirements apply to the storage of hazardous liquids by both the Harbour Authority and tenants.
10. Aboveground and underground storage tanks for flammable or combustible liquids (fuels) must meet specific design requirements and requirements for tank location, operating procedures, protection devices, signage, spill collection, fire protection equipment, and so on. (Fire Code Regulations made under the National Fire Code of Canada)
11. Building construction or fixed assets (e.g., lockers, bait sheds, parking lots) should meet national building codes. (National Building Code of Canada)

Key provincial requirements

Individual Harbour Authorities must comply with applicable provincial legislation.

Key municipal by-laws

Individual Harbour Authorities must comply with applicable municipal legislation.

Other important legislation

Canadian Environmental Assessment Act (CEAA)

The CEAA requires that the environmental impact of a project be considered before a commitment is made to carry out the project. The Act applies to all projects on federal property that are undertaken or financially supported by the federal government or other federal agencies. A CEAA Screening Form must be completed and submitted to DFO-SCH for review. (Contact your regional Small Craft Harbours office to obtain a copy of the screening form.)

Fisheries Act

Under the Fisheries Act, the use of explosives that can kill fish or marine animals is prohibited. Blasting near or in watercourses requires authorization from DFO.

No work can be undertaken that may result in the harmful alteration, disruption, or destruction of fish habitat. A project involving the alteration or destruction of fish habitat such as dredging and ocean disposal, and wharf, breakwater, and containment construction and removal requires authorization from DFO.

Navigable Water Protection Act

Under the Navigable Water Protection Act, construction of works for activities below the high-water mark in navigable waters must be approved in advance by the DFO Coast Guard.

Examples of projects subject to this Act include bridges, causeways, culverts, dams, wharves, floating docks, jetties, breakwalls, retaining walls, tunnels, rafts, marina facilities, log-boom mooring, fishways, and so on. Other examples include: excavating, dredging, dumping, laying cable, wiring, installing gas or oil pipelines, and placing stationary drilling equipment.

Permits are required for the removal of sunken ships..

Management of Hazardous Waste

The hazardous waste generator is responsible for ensuring that hazardous wastes are properly classified, handled, transported, and disposed of in compliance with federal and provincial guidelines and regulations (Transportation of Dangerous Goods Acts and Regulations, Storage of PCB Materials Regulation).

Hazardous Waste Transportation

Special permits are required to transport hazardous wastes, such as fuel, used oil, batteries containing acid, and so on. Also, special precautions must be taken, as defined in this regulation.

Migratory Birds Convention Act

The Migratory Birds Convention Act is intended to protect birds, nests, and breeding sites. Should harbour activities affect any of these, the Canadian Wildlife Service must be contacted.

Oceans Act (as of January 31, 1997)

The Oceans Act recognizes Canada's jurisdiction over its oceans.

The Act provides the legislative framework for a new strategy to manage the oceans. The strategy is grounded in the principles of ecosystem-based integrated management, sustainable development of ocean resources, and a precautionary approach. The Act also identifies the Minister of Fisheries and Oceans as the lead federal authority responsible for oceans, identifies the minister's ocean-related powers, duties, and functions, and re-groups key federal ocean-related statutes under the Oceans Act.

Harbour Authority lease with DFO-SCH

In the Harbour Authority's lease with DFO:

• The Harbour Authority agrees to comply with all federal, provincial, and municipal environmental legislation, as well as with rules or guidelines that affect the leased area.
• The Harbour Authority agrees to clean up, at its own expense, any part of the leased area that is contaminated during the term of the lease. The clean-up will meet existing government standards and regulations.

5.1.2 Enforcing legal requirements

A Harbour Authority must ensure that its employees and users, and contractors working at a harbour site, respect environmental regulations and policies, and harbour rules, thereby minimizing the environmental liabilities of the Harbour Authority. The environmental regulations, policies, and rules should be listed in the Harbour Authority's Environmental Management Plan.

Policies

The Harbour Authority, assisted by Small Craft Harbours, must develop and communicate EMP policies to all staff and clients. The policies should be made available to the public. EMP policies should include:

• Keeping the harbour clean for all harbour users, staff, and the local community.
• Identifying, documenting, prioritizing, and addressing potential environmental hazards associated with harbour operations. Regular monitoring of activities that may have an environmental impact is an essential part of operations.
• Setting and reviewing environmental objectives and targets.
• Continuously improving measurable environmental performance.
• Investing resources in effective communication, education, and training for harbour staff and users, with the aim of preventing pollution.
• Complying with all environmental rules and regulations and conditions that apply to harbour operations.
• Giving full consideration to the expectations of interested parties who contact the Harbour Authority.

EMP policies are to be shown on a form that the Harbour Authority must approve and sign.

Directors should set a good example to harbour users by:

• Respecting environmental rules and regulations and best management practices (BMPs). (See Section 5.6, Best Management Practices.)
• Communicating environmental rules and regulations and BMPs to other directors and to harbour users, when appropriate.
• Supporting the harbour supervisor in the task of enforcing environmental rules and regulations and best management practices.

Environmental rules for harbour users and contractors

Harbour users and contractors should conduct their activities in ways that minimize effects on the environment and that respect environmental rules and regulations. To this end, harbour users and contractors should abide by these rules:

• Independent contractors and self-employed boat workers must register with the harbour supervisor before beginning any work on Harbour Authority property.
• Only routine maintenance of vessels is permitted on the lease property. New or substantial exterior work (more than 25 per cent of the hull surface) must be reviewed by the harbour supervisor.
• All harbour users and contractors must follow environmental rules and regulations and best management practices. (See Section 5.1.1, Environmental legislation and legal requirements and Section 5.6, Best Management Practices.)

Infractions

The harbour supervisor must communicate environmental rules and regulations to all harbour users. Harbour staff or directors who notice an environmental offence must immediately notify the harbour supervisor and describe the situation.

Environmental offences include breaches of any contract clauses, harbour environmental rules, or federal or provincial environmental rules and regulations.

When confronted with inappropriate behaviour, the following approaches should be considered:

• Meet with the person committing the offence and hear that individual's side of the story.
• Clearly communicate to the person committing the offence that lack of respect for the harbour's environmental rules and regulations carries potential consequences (i.e., fines or loss of berthage privileges, as defined by applicable rules and regulations).
• Give the person committing the offence a copy of the harbour environmental rules and regulations.
• Give a second-time offender a written warning. Third-time offenders should be served with an appropriate Notice of Vessel Removal to remove their vessel from the harbour. A copy of the Notice is sent to the local RCMP or police detachment and the local DFO-SCH office.
• Seek the support of the Board of Directors or the Harbour Authority membership in finding workable solutions or arrangements. (Such an initiative must be recorded in the minutes of the meeting.)
• Use legal recourse as a last alternative (owing to the cost and time required to solve a problem in this way).

5.2 - Responsibilities in Environmental Management

A Harbour Authority must ensure that the Environment Management Plan (EMP) policies and procedures, once established, are supported, and will be implemented and maintained by Board members and staff. This section summarizes the roles and responsibilities of the Board president, the harbour supervisor, and Harbour Authority employees with respect to environmental management. Such roles and responsibilities should also be outlined in the EMP.

5.2.1	Acknowledging and accepting policy
5.2.2	Running an Environmental Program
5.2.3	Running an Environmental Awareness Program
5.2.4	Communicating policy and action
5.2.5	Ensuring staff competence
Also:	Appendix 5-A - Sample EMP Responsibility Form for Harbour Authority Board of Directors
	Appendix 5-B - Sample Environmental Program Table

5.2.1 Acknowledging and accepting policy

President

Within a reasonable timeframe of the EMP start-up date, the president should:

• Review and sign the EMP policy. (See Policies under Section 5.1.2.)
• Review and sign the appropriate environmental responsibility form. (See Appendix 5-A at the end of this section for a sample form.)
• Keep copies of the signed documents.
• Distribute the EMP policy to all directors of the Harbour Authority, who must also sign the EMP responsibility form.
• Ensure that the harbour supervisor signs the appropriate EMP responsibility form (each new incumbent).

Harbour supervisor

Within two months of the EMP start-up date, the harbour supervisor should:

• Insert copies of the signed EMP policy into all copies of the EMP and the EMS Reference Manual.
• Discuss EMP responsibility forms with the harbour staff, and have the staff members sign the appropriate forms.

Harbour Authority employees (If applicable)

Within two months of the EMP start-up date, all Harbour Authority employees should:

• Review the EMP responsibility form provided by the harbour supervisor.
• Discuss their concerns regarding their environmental responsibilities with the harbour supervisor.
• Sign the appropriate form and keep a copy.

5.2.2 Running an Environmental Program

An Environmental Program, which should be described in the EMP, systematically identifies, prioritizes, and manages harbour activities that have (or may have) a significant impact on the environment. The Program also ensures that important environmental issues and available resources are considered in setting environmental targets. The Program must be maintained, and regularly revised and updated as required.

President

The president should:

• At each Board meeting, inform Board members of the progress of the Environmental Program in meeting its targets.
• Approve and sign the Environmental Program at the time of the budget review (i.e., at least annually).

Harbour supervisor

The harbour supervisor should:

• Finalize and obtain Board approval for the Environmental Program.
• Sign the Environmental Program table (see Appendix 5-B at the end of this section) with the president.
• Distribute the Environmental Program to employees and directors within two months of starting the EMP.

For an ongoing EMP, the harbour supervisor should:

• Update the Environmental Program and obtain Board approval of the updates every six months.
• Set new targets in the Environmental Program and obtain Board approval of the targets.
• Sign the new Environmental Program with the president.
• Distribute the program to employees and directors every six months.

Harbour Authority employees (If applicable)

Employees of the Harbour Authority should review the Environmental Program table and help the harbour supervisor carry out the tasks described.

5.2.3 Running an Environmental Awareness Program

An Environmental Awareness Program, which should be described in the EMP, ensures that harbour users, employees, and contractors are aware of environmental rules and regulations, best management practices (BMPs) that prevent pollution, and emergency procedures in case of spills and fires. An Environmental Awareness Program also helps to ensure that environmental policy is visible to harbour users, visitors, and the local community.

Harbour supervisor

The harbour supervisor should:

• Include a summary of the BMPs (see Section 5.6, Best Management Practices) in the berthage contracts and contractor agreements.
• Post copies of the environmental policy in key locations.
• Provide copies of the environmental policy and BMPs to anyone who requests them.
• Distribute environmental news as part of a periodical newsletter.
• Post environmental rules, BMPs, the EMP policy, environmental regulations, newspaper clippings relevant to environmental management at harbours, and other such material in the front office (monthly).
• Post the following signs (and check them annually):
  • Environmental policy and BMPs at the head of each wharf.
  • Waste disposal instructions at the head of each wharf and near waste containers.
• Label the following locations (and check the labels annually):
  • Solid and liquid waste disposal containers.
  • Recycling facilities.
  • Storm drains (include clear instructions not to dispose of waste at this location).

Harbour Authority employees

Employees of the Harbour Authority should:

• Lead by example (i.e., respect BMPs when working on the site).
• Talk with users about environmental BMPs.
• Support the harbour supervisor's efforts to communicate and enforce environmental rules and regulations, and BMPs.

5.2.4 Communicating policy and action

Clear lines of communication in regard to EMP policy and action taken should exist between the various levels and functions of the Harbour Authority.

President

At every Board of Directors meeting, the Board president should:

• Ensure that environmental issues (tasks and deadlines, targets, new procedures, required funding, etc.) are discussed.
• Ensure that minutes are prepared and distributed to all directors and the harbour supervisor, and that they are posted for harbour users.

Harbour supervisor

Within one month of the EMP start-up date, the harbour supervisor should:

• Distribute the EMP to all harbour employees and directors.

Monthly, the harbour supervisor should:

• Ensure that environmental information (i.e., the Environmental Program) is incorporated into monthly operational and financial reports.

Quarterly, the harbour supervisor should:

• Organize environmental meetings with employees to discuss the process of the Environmental Program.
• Prepare minutes of the meetings held with employees. Action items and responsibilities should be clearly defined in the minutes, which are to be distributed to Board members and employees.

Annually, the harbour supervisor should:

• Summarize the results of all environmental inspections of the harbour in the year-end Environmental Inspection Report and distribute the Report to all directors.

Harbour employees (If applicable)

Within one month of the EMP start-up date, harbour employees should:

• Read the EMP and pose questions to the harbour supervisor, as required.

Quarterly, employees of the Harbour Authority must:

• Attend environmental meetings to discuss how the EMP is working.

5.2.5 Ensuring staff competence

Employees of a Harbour Authority must be competent to carry out responsibilities in regard to the EMP.

Recruiting and hiring

When recruiting a harbour supervisor, the Board president must ensure that the candidate is qualified for the duties assigned to him/her such as:

• Possesses at least ( ) years' experience in harbour management, including knowledge of environmental issues.
• Is familiar with environmental regulations and issues.
• Is familiar with procedures for handling emergency situations.
• Has experience in enforcing environmental rules and regulations.
• Shows a proven record of effective staff management and customer liaison.

When hiring new employees and assigning environmental responsibilities, the harbour supervisor should ensure that candidates meet the following criteria:

• A minimum of a high school or technical college education.
• A familiarity with environmental issues and emergencies related to harbours.
• Good communication skills (for conveying environmental information to harbour users).
• Good organizational skills and a systematic approach to conducting harbour inspections.

Training (If applicable)

All harbour employees must receive related training. Within one year of the EMP start-up date (or when hiring new employees) and every three years thereafter, the harbour supervisor must ensure that employees involved in daily operations receive training in:

• Environmental awareness.
• EMP procedures (using BMPs, conducting inspections).
• Emergency response procedures (for spills, fires, boat sinkings, etc.).
• Workplace Hazardous Materials Information System (WHMIS).

To accommodate the necessary training, the president must allocate a budget at the time of the annual budget review..

Appendix 5-A - Sample EMP Responsibility Form for Harbour Authority Board of Directors

Date:

Name:

Position:

Environmental Responsibilities

The Harbour Authority Board of Directors is committed to making appropriate resources available to ensure that the Harbour Authority Environmental Management Plan is implemented and maintained within the framework of our financial capability.

We, the Directors of Harbour Authority have read the above paragraph and understand the meaning of our responsibilities within the Environmental Management Plan in place at the . We will address the above responsibilities to the best of our capabilities.

Signed:

President

Directors

 

Appendix 5-B - Sample Environmental Program Table

Site Activity or Issue	(**year**) Environ-mental Target	Estimated Person-Hours (**year**)	Estimated Funds Needed	Who?	Priority 1=High 2=Low	Deadline
Litter on harbour property	Reduce the visible amount of litter	20	0	RR	2	N/A
Oil sheens on water	Reduce the occurrence	20	$700	RR	1	N/A
Paint, solvents entering water	Reduce the occurrence	30	0	RR	1	N/A

Signed: Harbour Supervisor/President

5.3 - Environmental Inspections

Environmental inspections help to monitor and measure indicators of environmental performance so that the Harbour Authority can track the progress of its Environmental Program. Environmental inspections of the harbour should be conducted routinely and systematically to identify hazards and any new environmental issues at the harbour. Such inspections and the applicable checklists should be outlined in the Environmental Management Plan (EMP).

5.3.1	Roles and responsibilities of conducting inspections
5.3.2	Guidelines for prioritizing findings of environmental inspections
5.3.3	Environmental Auditing
Also:	Appendix 5-C - Sample Environmental Inspection Checklists

5.3.1 Roles and responsibilities of conducting inspections

Harbour supervisor

The harbour supervisor is responsible for:

• Training harbour employees to conduct daily, monthly, and yearly environmental inspections of the harbour property and buildings, using environmental inspection checklists.
• Reviewing the completed inspection checklists and prioritizing the findings.
• Looking for patterns and chronic problems, and addressing them as part of the Environmental Program.
• Preparing a year-end Environmental Inspection Report that summarizes the results of the environmental inspections.
• Presenting the report to the Board of Directors.

Harbour employees

Employees of the Harbour Authority are responsible for:

• Using environmental inspection checklists to conduct visual inspections of the harbour facilities and its operations.
• Recording all observations in writing.
• Signing the inspection checklist and submitting it to the harbour supervisor after the inspection.

See Appendix 5-C at the end of this section for examples of daily, monthly, and yearly inspection checklists.

5.3.2 Guidelines for prioritizing findings of environmental inspections

The following guidelines will assist in prioritizing the findings of a site inspection or an EMP compliance audit. (See Section 5.3.3, Environmental auditing.)

EMP findings

Environmental Management Plan findings are not compliance issues. However, failing to follow good management practices may result in non-compliance with regulations.

• Priority M1: Findings are in direct opposition to written environmental policies, procedures, and best management practices.
• Priority M2: Environmental Management Plan needs improvement and, if not improved, could result in a violation of company policies, procedures, and best management practices.

Compliance audit findings

A compliance audit may produce real or potential non-compliance situations (i.e., situations that fail to conform to applicable regulations). The following categories can help to prioritize such findings:

• Priority C1: Findings of non-compliance that are likely to result in significant environmental damage.
• Priority C2: Findings of non-compliance that could potentially result in significant environmental damage.
• Priority C3: Findings of non-compliance that do not represent an actual danger to the environment, but are paper infractions.
• Priority C4: Findings of non-compliance that could potentially result in paper infractions.

5.3.3 Environmental auditing

The plans and actions of an EMP should be audited every three years. Auditors conducting the EMP Compliance audit must be competent.

Arranging for an audit

Every three years, the president should:

• Retain an external consulting firm to conduct an intensive EMP Compliance audit of harbour operations.

Refer to the EMS Reference Manual for harbours for detailed audit protocol.

One month before the audit

One month before the audit, the harbour supervisor should:

• Inform all staff of the upcoming audit and assign staff to assist the auditors.
• Review the previous audit and compile a status report on its findings.
• Supply all documentation requested by the auditor.

During the audit

During the audit, the harbour supervisor should:

• Ensure that the auditor can access the entire harbour site.
• Meet with the auditor at the end of each day to discuss findings and to clarify issues.

Appendix 5-C - Sample Environmental Inspection Checklists

Sample Daily Environmental Inspection Checklist Date:________

Description of Area to Be Inspected	Status	*Comments
PROBLEM	DONE
General Site Inspection
Walk the shoreline and site. Look for evidence of oil slicks: oil coating on rocks, floating debris, turbulence, and so on. If something looks out of the ordinary, investigate it immediately. Note stray garbage: barrels, empty tanks, and so on. Note their locations. (Is there litter on the ground?) Consider visiting tourists. Is the site clean and acceptable, or dirty, with garbage on the ground?
Waste-Oil Tanks
Is there evidence of leakage? Is the area clean and orderly? Is the soil around the tanks stained? (What type of surface is the waste-oil tank sitting on? Soil, sand, concrete?) Are containers, rags, oil filters, buckets, and so on, left around or on the tanks? Are there containers of products other than waste oil? (What type of products?) Is waste oil migrating along the ground towards the water? Has an effort been made to absorb small spills (i.e., with absorbent material)?
Hazardous Materials and Wastes
For each hazardous waste container check that: The container is emptied before it becomes full. The area around the container is clean and orderly. The container is covered. Walk the docks/floats and ensure that no materials or wastes (e.g., flammables, batteries, paints, solvents, antifreeze) are located near the water.
Wastewater Discharges
Ensure that users properly dispose of sanitary sewage. Is there evidence that users are disposing of sanitary sewage in the harbour?
Stormwater Discharges
Check the storm sewer outfall for evidence of contamination (e.g., oil slick, floating debris). Has it rained in the past 24 hours? Is the town's sanitary sewer overflowing into the harbour?
Other Issues
Is dust being produced from cars driving on the gravel road? Is dust blowing towards the neighbouring houses and businesses? Is garbage being stored behind businesses? Check behind local businesses along the main road. Is garbage falling or leaking into the water? What kind of garbage is being stored behind businesses? Is excessive noise coming from the harbour area? If so, where is it coming from?

Sample Monthly Environmental Inspection Checklist Date:________

Description of Area to Be Inspected	Status	*Comments
PROBLEM	DONE
General Site Inspection
Walk the property boundaries.  Check that the harbour site is clean and that no eyesores are presented to off-site neighbours. Ensure that all harbour property (used equipment, chemicals, etc.) remains on harbour property and is not placed on an adjacent property. Investigate foul odours, visible emissions (smoke), or noise that would be unpleasant to neighbours.
Fueling by Trucks
Observe fueling operations. How close is the fuel truck to the water? How close is the fuel truck to the edge of the dock? Is there room for people or vehicles to circulate easily? Is fishing gear (e.g., lobster traps) on the docks while fueling occurs?  Are vessel owners supervising the fueling of their vessels? Is any fuel being spilled on the vessel or in the water? If so, is it being cleaned up? How is it being cleaned up? Has the fuel-truck operator checked in with the harbour supervisor? Is the truck operator licensed and permitted to deliver fuel on harbour property? Does an agreement exist between the fuel company and the harbour regarding liability for environmental damage? Is the fuel-truck operator aware of spill and fire procedures? Does the fuel-truck operator carry spill equipment (absorbent pads)?

Sample Quarterly Environmental Inspection Checklist Date:________

Description of Area to Be Inspected	Status	*Comments
PROBLEM	DONE
Emergency Response and Fire Equipment
Verify that all spill response equipment is in good working order and that used material is immediately replenished. Verify that all fire response equipment is replenished and in good working order.
Waste-Oil Storage and Disposal
Check that the following procedures are posted in the vicinity of the waste-oil tank(s): Emergency response procedures in case of a leak or spill. Procedures for how and when to report a spill. Procedures for the proper disposal of waste oil. Information on where to find and how to use absorbent materials.
Hazardous Materials and Wastes
At each hazardous waste container check that:  The container is clearly labelled to indicate the kind of waste it contains.  The container is protected from vehicle traffic. The container is located on an impermeable surface. The container is not located near a sensitive receptor (e.g., watercourse, drinking-water well, storm sewer).
Wastewater Discharges
Check that clearly visible signs direct users to follow best management practices (e.g., no disposal of oily bilge and sanitary sewage in the harbour).
Indoor Storage Areas
Tour indoor storage areas (harbour and tenant). Check for flammable material and inappropriate storage of hazardous materials or wastes.

Sample Yearly Environmental Inspection Checklist Date:________

Description of Area to Be Inspected	Status	*Comments
PROBLEM	DONE
Waste-Oil Storage and Disposal
Check that the waste-oil storage tanks are: Easy for harbour users to find. Clearly labeled to indicate what can and cannot be disposed of in the tanks. Covered. Situated on an impermeable surface. Are containment facilities free of waste oil? Are there signs indicating: Procedures for cleaning up small spills. Procedures for reporting big spills. Location of spill response equipment. Consider the tank location. Could the tank be damaged by vehicular traffic? Is the tank well away from watercourses or storm sewers? Is the tank near any potential fire hazard?
Solid Waste Management
Are garbage containers easy for harbour users to find? Are garbage containers located in heavy traffic areas? Are recycling containers well marked and easy for users to find? Are recycling containers available for glass, metal, paper, and other recyclable wastes? Are recycling containers clearly labelled to indicate what they can and cannot accept for recycling?
Hazardous Materials and Wastes
Check that signs are posted to inform users about hazardous materials and wastes, and how those wastes must be disposed of at this property.   Hazardous materials and wastes include: Oils and fuels Paints, solvents, detergents, and antifreeze Strong acids and alkaline compounds Flammable materials Batteries Containers holding quantities of the above-mentioned materials

5.4 - Environmental Management Tasks

Procedures should exist for various environmental management tasks at a Harbour Authority. This section describes the steps involved in:

5.4.1	Dealing with contractors and consultants
5.4.2	Conducting construction projects
5.4.3	Conducting dredging projects
5.4.4	Managing waste
5.4.5	Reporting pollutant spills
5.4.6	Dealing with contaminated soil
5.4.7	Receiving, documenting, and responding to environmental communications

Such procedures should be outlined in the Environmental Management Plan (EMP).

5.4.1 Dealing with contractors and consultants

Contractors and consultants working for the Harbour Authority must be aware of environmental issues, must be appropriately trained, and must possess the necessary licences and permits.

The harbour supervisor should:

• Prepare a verbal agreement or written agreement to be signed by all contractors working on Harbour Authority property.
• Confirm that contractors possess the necessary permits to conduct their work and that they are covered by their respective workers' compensation board.
• Confirm that the contractor has adequate liability insurance. Also, the contract must state that the Harbour Authority is not liable for incidents occurring during the life of the contract.
• Ensure that, if welding is required, the contractor is familiar with welding restrictions.
• Ensure that, if hazardous waste is to be disposed of, the contractor is a certified waste hauler.

5.4.2 Conducting construction projects

Construction projects must be conducted in an environmentally responsible manner by contractors and workers who possess all necessary permits.

When planning major repair and construction work, such as wharf repair and building new structures, the harbour supervisor should:

• Contact Small Craft Harbours (SCH) for advice concerning project scope, engineering, and public liability issues.
• A project may be subject to the Canadian Environmental Assessment Act(CEAA).) Determine whether technical expertise in environmental management is required.
• Obtain the Department of Fisheries and Oceans (DFO) consent before commencing work. (Owing to the sensitive nature of the environment around the harbour area

5.4.3 Conducting dredging projects

Dredging projects require appropriate planning and must respect environmental regulations. During the planning phase of a dredging project, the harbour supervisor should:

• Discuss the project with SCH.
• Ensure that an Environmental Assessment (under the CEAA) is performed.
• Acquire a permit, when applicable, for ocean disposal of sediments. (Ocean disposal may be less expensive than land disposal.)
• Secure a provincial or municipal permit (where applicable) for a loading site and disposal site.

5.4.4 Managing waste

Environmental rules and regulations relating to the handling, storage, and disposal of hazardous and non-hazardous wastes must be respected.

The harbour supervisor is responsible for identifying all hazardous materials and wastes on Harbour Authority property. The supervisor should also:

• Ensure that hazardous waste and materials storage complies with applicable rules and regulations (i.e., for waste oil, combustible materials, compressed gas cylinders, etc.).
• Maintain a binder with all required Material Safety Data Sheets (MSDSs) for hazardous materials.
• Ensure that appropriate signs identify hazardous wastes and materials.
• Ensure that new products are screened and, if necessary, that MSDSs are obtained for them.
• Check that best management practices for solid waste management are being followed and that solid waste is being handled in accordance with legal and regulatory requirements.

5.4.5 Reporting pollutant spills

Legal requirements apply to reporting spills of hazardous materials in the water or on land.

Harbour directors and staff must ensure that:

• All accidental releases of a contaminant under the control of the Harbour Authority are reported as required by law and applicable regulations.
• A spill-reporting procedure is in place as required by provincial and federal regulations.
• The Board is immediately informed of reportable incidents.
• The reporting procedure is field-tested at least once annually to ensure that spills are addressed quickly and that the Harbour Authority's liability is minimized.

5.4.6 Dealing with contaminated soil

Contaminated soil must be characterized, removed, and disposed of, as applicable rules and regulations require. Qualified consultants and contractors should be hired for this work.

Dealing with contaminated soil requires that the harbour supervisor:

• Discuss the project with SCH.
• Contact the provincial ministry of the environment.
• Sample or monitor soil and ground water to determine the extent of the contamination.
• Select a remedial technique (in situ, or soil removal).
• Clean up soil and ground water.

5.4.7 Receiving, documenting, and responding to environmental communications

Procedures must be established regarding how to receive, document, and respond to relevant communication from government regulatory bodies and external interested parties.

In cases where a telephone call, letter, or verbal request is received regarding an environmental issue, the harbour supervisor should:

• Promptly return telephone calls and document telephone conversations.
• Promptly respond to letters and faxes.
• Immediately contact the Board of Directors if a call involves a non-compliance or potential non-compliance incident. (The Board is responsible for contacting legal counsel.)
• Never provide Harbour Authority environmental documents (e.g., inspections, audits) to any external party without the advice of an environmental legal counsel.
• Thoroughly investigate a matter before offering opinions or answering questions.

When giving a site tour to an external party or a government regulatory official, the harbour supervisor should:

• Describe the Harbour Authority's Environmental Management Plan.
• Provide a copy of the EMP policy to the official.
• Discuss potential environmental issues and how the Harbour Authority is addressing them.

5.5 - Environmental Record-Keeping

Proper identification, maintenance, and disposal of environmental records ensure that all harbour employees and directors have access to environmental documents. All environmental information that is distributed to directors and employees should be tracked. Records should be kept for a period of at least five years before they are discarded. Such record-keeping activities should be outlined in the Environmental Management Plan (EMP).

5.5.1	Rules and responsibilities
5.5.2	Current information
Also:	Appendix 5-D - Sample Document Control Form

5.5.1 Roles and responsibilities

Harbour supervisor

Within two months of the EMP start-up date, the harbour supervisor should:

• Issue a memo to harbour employees and directors, listing the locations of all environmental documentation.
• Establish a filing system for environmental documents. For more details, see the EMS Reference Manual for harbours.
• Maintain copies of the EMP and the EMS Reference Manual in the harbour supervisor's office and at the front desk for staff reference.
• Use the document control form when distributing environmental documents to directors and employees.
• Provide each director and staff member with an updated, numbered copy of the EMP.

See Appendix 5-D at the end of this section for a sample document control form.


Harbour employees (If applicable)

Employees of the Harbour Authority should:

• Complete the document control form whenever they receive, take, or return environmental documents.
• Read and understand the environmental documents that they receive, especially procedures and best management practices (BMPs), which are enforceable.

5.5.2 Current information

The legal requirements and environmental codes of practice to which the Harbour Authority subscribes should be available to staff at all times.

Annually, the harbour supervisor must ensure that all documents that help to determine regulatory compliance are updated. The currency of documents can be checked by contacting federal, provincial, and municipal agencies by telephone or by visiting available Web sites. The EMS Reference Manual contains telephone numbers, addresses, and other agency contact information.

Document revision, review, and approval

Environmental documentation must be periodically reviewed and revised, and the revisions approved so that new or revised procedures, including emergency response procedures and legal agreements between the Harbour Authority and contractors or harbour users, are identified, documented, and communicated. Obsolete documents should be removed, or if they are retained for specific reasons, they must be suitably identified.

Every two years, or following an accident or emergency, the harbour supervisor must revise the EMP or the EMS Reference Manual based on notes, comments, and records kept since the last revision (e.g., inspection forms; minutes of meetings; comments from employees, users, or directors; audit results).

Within one month of revising the EMP, the harbour supervisor should:

• Send the EMP and legal documents to the Board for approval.
• Collect and discard old versions of the documents and replace them with the revised versions.
• Ensure that each page of each document indicates the date, filename, and version number.

Appendix 5-D Sample Document Control Form

All employees and directors of the Harbour Authority who receive or borrow environmental files, records, and documents must complete and sign this sheet.

Date	Name of Document	Reference Number	Full Name	Initial	Date Returned

5.6 - Best Management Practices

Best management practices (BMPs) refer to techniques and practices for reducing and preventing pollution, and should be outlined in the Environmental Management Plan (EMP). BMPs help to ensure that the Harbour Authority complies with environmental regulations, minimizes environmental costs and liabilities, and maintains good relations with the public.

BMPs are designed for the harbour supervisor, for employees, and for contractors. They ensure that all activities that may impact the environment are carried out in an environmentally responsible manner that respects environmental policy.

This section describes the roles of the harbour supervisor and employees in:

5.6.1	Communicating BMP's
5.6.2	Oil and fuel management
5.6.3	Fueling
5.6.4	Engine and bilges
5.6.5	Sewage and greywater
5.6.6	Vessel surface preparation, painting, varnishing, and fibreglassing
5.6.7	Solid and liquid waste disposal
5.6.8	Chemical storage
5.6.9	Harbour cleanliness
Also:	Appendix 5-E - Best Management Practices (Sample Harbour)

An example of a handout that summarizes BMPs can be found in Appendix 5-E at the end of this section.

Unless special equipment is required, the capital cost of instituting most of the mentioned BMPs in this section is under $1,000. The annual maintenance cost for most BMPs is estimated at less than $500. These costs are justified when compared to the time, effort, and cost involved in cleaning up the contamination caused by poor environmental practices. The cost of remedying problems can easily range from $15,000 to $500,000, depending on the volume of contaminated material to be disposed of.

BMPs can be customized to suit local harbour conditions.

5.6.1 Communicating BMPs

Harbour supervisor

The harbour supervisor is responsible for ensuring that BMPs are communicated to harbour employees and users. To this end, the harbour supervisor should:

• Distribute handouts and test harbour users' knowledge of BMPs by engaging in personal conversations.
• Train employees to enforce BMPs among harbour users.
• Accept suggestions for new BMPs from users and employees.

Harbour Authority employees should:

• Become familiar with BMPs.
• Educate harbour users as much as possible about the use and importance of BMPs.

When confronted with behaviour that does not reflect best management practices, the harbour supervisor should consider using the approaches described under Infractions in Section 5.1.2.

A summary of BMPs appears below.

5.6.2 Oil and fuel management

• Disposing of oil in harbour waters is illegal.
• Waste oil must be disposed of in the waste-oil tanks on the harbour site. Do not leave containers around the waste-oil tank or on the screen.
• Do not dispose of any liquid waste other than oil in the waste-oil tanks.
• Use the separate containers provided on the harbour site for the collection of waste gasoline, diesel fuel, antifreeze, kerosene, and mineral spirits.
• Drain oil filters into the waste-oil tanks, then dispose of the drained filters in the oil-filter bins.
• Small spills that occur during the transfer of wastes to on-site waste collection tanks should be immediately absorbed using absorbent pads, cloths, or pillows

5.6.3 Fueling

• Follow the operational guidelines for fuel delivery published by the Department of Fisheries and Oceans, Small Craft Harbours (DFO-SCH).
• Do not allow fuel-dispensing vehicles to enter the harbour facilities without prior written authorization from the Harbour Authority.
• Oil-absorbent material should be kept on site. Although clean-up is the responsibility of the vessel owner, the equipment may permit rapid intervention that will minimize the adverse impact on the environment. The Harbour Authority may subsequently charge the cost of cleaning up the spill to the offender.
• Fuel drums that are nearly empty may contain vapours that are highly explosive. They should be handled with great care.
• Harbour users are not permitted to fuel their own boats. All fueling must be carried out by a licensed fuel-delivery company. The vessel captain should oversee the fueling process for a vessel, including ventilation of the bilge and all safety checks. Vessel owners should know approximately how many gallons of fuel are needed to refuel their vessels. (All other methods of fueling must be approved by SCH.)
• Fueling truck operators should be aware of harbour emergency procedures and of the location of fire and spill equipment.
• Do not conduct fueling operations near fishing gear or near fish or shellfish cargo that are destined for human consumption.

5.6.4 Engines and bilges

• Bilge water with an oily sheen must not be pumped into the harbour or the offshore waters.
• Use absorbent pads (small bilge booms or absorbent pads that are checked every six months) to soak up oil and fuel in the bilge compartment.
• Wring out oil-absorbent pads into the proper on-site container and re-use the pad.
• Dispose of used absorbent materials in the proper containers on site, or wrap the materials in newspaper and dispose of them in regular garbage bins.
• Use catch pans and absorbent pads to catch oil that drips during oil changes or while conducting engine work.
• If a large quantity of oil or fuel has been spilled into the bilge, pump the contaminated bilge water into a holding tank.

5.6.5 Sewage and greywater

• Do not discharge untreated sewage into the harbour. Vessels without holding tanks can discharge untreated sewage in offshore waters.
• Minimize the discharge of boat greywater (from sinks and showers) into the harbour.
• Use the harbour washrooms, showers, and sinks; they are clean and well lit.
• Use environmentally safe cleaning products, such as lemon juice, vinegar, baking soda, and so on to reduce the environmental impact of discharged greywater.
• Avoid cleaners containing phosphate, sodium hydroxide, butoxyethanol, and butylcellusolve; discharges containing these compounds are toxic to marine life.

5.6.6 Vessel surface preparation, painting, varnishing, and fibreglassing

• Sandblasting and spray painting a vessel is prohibited on the lease property.
• Always work over a tarp, drop cloth, or drip pan to catch scrapings and drips. Mix paints and epoxy or other hazardous materials over a re-usable tarp or plastic sheet.
• Dispose of waste collected on tarps in the garbage bins.
• Use of the tidal grid should be limited to mechanical tasks such as repairs and hull inspections, not scraping, sanding, washing, and painting.
• When working over water, stretch the tarp between the side of the boat and the water. Reverse the boat in the slip to work on the second side.
• Cover storm drains located near work areas to prevent waste from being carried into harbour waters.
• Plug scuppers and self-bailing drains to prevent the escape of pollutants.
• Use biodegradable cleaning agents.
• Use only small quantities of solvents and paints to avoid a big spill of these materials.
• Ensure that containers are tightly sealed when not in use.
• Re-use thinners and solvents: let particles settle, drain the clear liquid. Let the sludge dry, and dispose of it in the garbage.

5.6.7 Solid and liquid waste disposal

• Hazardous wastes that require special disposal include:
  
  • oils and fuels, paints, varnish, solvents, detergents, antifreeze, fibreglass resin, strong acid and alkaline compounds, flammable materials, and boat or flashlight batteries.
  • any container that has residue of the above-mentioned wastes.
• Do not dispose of hazardous wastes in harbour waters or in regular garbage bins. Specially labelled containers exist for each of these hazardous wastes.
• Do not throw garbage, trash, fish waste, or any other debris into harbour waters.
• Use garbage cans located throughout the harbour facility for typical domestic wastes.
• Use recycling bins according to the labels on them (e.g., cardboard, glass, metal).
• Allow empty paint cans to dry completely before disposing of them in the garbage bins or recycling them.
• Do not dispose of cigar or cigarette butts in harbour waters.
• Fish nets, engine blocks, hatch covers, and similar wastes must be disposed of off site. The harbour cannot accept these wastes. 

5.6.8 Chemical storage

• Do not store flammable products and hazardous wastes in lockers. Meet the recommendations resulting from inspections by the fire marshall.
• Keep lockers tidy to allow adequate walking space. Keep chemicals on shelves or in fireproof cabinets.
• Do not store batteries, fuels, and other flammable or hazardous materials on docks or finger floats. They may fall into the water, or leak, or both.
• Every six months, clean out paints, solvents, flammables, cleaners, and so on from lockers and properly dispose of old and unwanted products. 

5.6.9 Harbour cleanliness

• Schedule routine yard maintenance to minimize pollutants entering the water or storm sewers.
• To avoid overflows, always empty trash containers before they are full.

Pick up litter from the docks and ground or from the water, and properly dispose of it.
 

Appendix 5-E - Best Management Practices
(Sample Handout)

1. All self-employed boat workers and independent contractors must register with, and receive approval from, the harbour supervisor before beginning any work on harbour property. All contractors must comply with the environmental rules.
2. Work on vessels beyond routine maintenance is prohibited. Owners may undertake projects as required to maintain their vessels' safety, appearance, and utility. New or substantial exterior work encompassing more than 25 per cent of the hull's surface must be reviewed by the harbour supervisor.
3. Harbour management encourages all vessel owners to adhere to the environmental best management practices listed below.

Engines and bilges

• Do not discharge bilge water if it has an oily sheen. Discharging oil, diesel, and gas is against the law and incurs a fine. Use absorbent pads to soak up oil and fuel in bilge compartments.

Sewage

• Untreated sewage must not be discharged in the harbour. If your boat does not have a holding tank, please use the public washrooms provided by the Harbour Authority.

Surface preparation

• Use tarps to capture scrapings, debris, and drips. Stretch the tarp between the side of the boat and dock when working over water. Reverse the boat in the slip to work on the second side.
• Sandblasting is prohibited.
• Use biodegradable cleaning agents if possible.

Painting, varnishing, fibreglassing

• Spray painting is prohibited.
• Limit the amount of open solvents or paints on docks to one gallon. If a spill occurs, it won't be a big one.
• Mix paints or epoxy or other hazardous materials over a tarp to prevent toxic compounds from entering the water.
• Always use a drip pan and drop cloth.

Waste disposal

• No garbage, trash, or other debris may be thrown, placed, or discharged into the water, or left on the ground, wharves, and floats. All waste materials must be placed into the appropriate, marked containers on site.
• Use the recycling bins for all recyclable materials.
• Allow empty paint cans to dry thoroughly before disposing of them in the proper bins. Use up small quantities of paint by spreading it on an old board.

Use special containers for the following hazardous wastes:

• Flammable liquids and their containers
• Batteries
• Antifreeze, or corrosive materials
• Oil and fuel, oil filters (must be drained first)

Dispose of the following hazardous wastes off site:

• Household or other off-site waste
• Fish nets, engine blocks, hatch covers

Chemical storage

• Review the storage of paints and solvents every six months and properly dispose of old and unneeded products.
• Do not store batteries or fuels and other flammable materials on docks, finger floats, or in lockers.
• Purchase only the quantity of chemicals or paints needed for a project.