National Environmental Management Plan

An environmental management plan (EMP) is a document that serves as a reference guide for harbour authorities (HAs) to ensure proper environmental management for everyone involved with harbour activities. This introduction section explain the purpose of this document and gives an overview of a typical small craft harbour (SCH) site.

On this page

• Purpose
• SCH Site description
• Characterization of Environmental Aspects and EBMPs
• Audits, Assessments and Inspections
• National Environmental Compliance Audit Program
• Environment and Climate Change Canada inspections
• Other audits, assessments and inspections
• Training Requirements and Recommendations
• Environmental Considerations for Planning Projects
• Site Roles and Responsibilities
• Appendix A : Toxic Cleaning Products Alternatives

Purpose

Many activities on a SCH site have the potential to impact the environment. These activities goes from storage tanks spills to air emissions to the usage of hazardous materials and even vessel maintenance. The EMP will act as a tool to ensure that these activities are managed in compliance with legal and other requirements. This includes implementing environmental best management practices (EBMP).  Following this EMP will therefore ensure the sustainable management of the site's operations and assets.

SCH Site description

SCH are usually small to medium-sized harbours. They serve as crucial hubs for the fishing industry. Numerous people, mostly fishers, use the harbours on a daily basis throughout different fishing seasons. Boats come in and out of these sites throughout the year, with many of the harbours acting as berthing locations.

Given the roles they play, these harbours are located in coastal regions. This means they are surrounded by sensitive ecosystems (ex. freshwater, beaches, wetland, marine, etc.). Being environmentally conscious in and around these sites is important since even a minor disturbance in the ecosystem, such as a small oil spill on land or in the water, can have a big impact on the environment. For example, just one litre of oil can contaminate one million litres of water and cause adverse effects on ecological and human receptors.

Hazardous materials can be found at these sites, including in equipment. This includes used oil tanks, diesel and gasoline fuelling dispensing systems, refrigerators containing halocarbons and fuel-based generators. This equipment is very important for daily activities that occur at SCH sites. Being aware of their presence on site and their potential dangers is important because they can cause environmental emergencies, such as leaks and spills of hazardous materials. Such emergencies can be caused by a lack of maintenance or regular inspection and misuse. It is also important to make sure that SCH site users are aware of the people who are allowed or trained to use these installations and their proper use. The site-specific Environmental Emergency Response Plan (EERP) provides a further explanation of environmental emergency planning and response.

Characterization of environmental aspects and EBMPs

Because SCHs are located in different types of environments and numerous activities occur in the area, many environmental aspects are affiliated with these sites. These aspects are operations, activities, products, assets, and services that can interact with the environment. Changes to the environment concerning these aspects are considered environmental impacts. These impacts not only affect the environment, but also impacts the longevity of equipment and installations. This in turn can impact the liability and even the reputation or community relations for HAs. This section provides an overview of theses environmental aspects and includes EBMPs. These recommended actions will aim to reduce the risk of these different aspects creating unwanted environmental impacts.

Contaminated sites

Over years of use and due to the many activities that take place at SCH sites, different areas can become contaminated sites. These sites are areas that contain a substance that has a higher concentration than normal and can be harmful to human health or the environment. This is typically the result of frequent environmental spills, such as from fuel spills, leaks, boat operations, treated timber, etc. Petroleum hydrocarbon, metals and volatile organic carbons are typical contaminants associated with petroleum storage tanks and industrial activities at SCH sites. This can result in a number of impacts, such as contamination of ground or surface waters, human health impacts, and potential effects on plant and animal life.

As part of the Federal Contaminated Sites Action Plan, the Office of Environmental Coordination (OEC) undertakes various levels of environmental assessment and remediation at Fisheries and Oceans Canada (DFO) sites. In cases where contamination is identified and exceeds applicable standards/guidelines, these areas would need to be remediated. If the contamination is to be managed in place, a Risk Management Plan is typically prepared. Please contact your SCH representative for additional details regarding contaminated sites information specific to your SCH, especially when it comes to digging activities.

Site remediation can be very costly and technically challenging since it's not an easy task to get rid of these contaminants. Be sure to follow the following EBMPs to avoid creating contaminated sites in the first place.

Air emissions

Many installations/activities, like generators, vehicles and burn piles, can produce air emissions, such as ozone, carbon monoxide, nitrogen oxide or sulphur dioxide. These gases are considered contaminants that can create smog, acid rain and even climate change. It is therefore important to be aware of the source of these emissions on site since they can create local pollution and be a nuisance. Being aware of their presence makes it is easier to identify and reduce their emissions. Also, according to the National Emission Guideline for Commercial/Industrial Boilers and Heaters, an inspection and maintenance program (developed by the manufacturer) for boilers and generators installed before March 2000 needs to be followed.

Halocarbons

Halocarbons are gases with a wide variety of uses, especially refrigeration and air conditioning. When released into the environment, these gases have a variety of impacts, but they are mostly known for their ability to deplete the ozone layer and act as a green house gas.

At SCH sites, halocarbons can be typically found in fridges, freezers, water coolers, air conditioners and some portable fire extinguishers.

Regardless of ownership, small equipment such as lunch fridges should be disposed of at a facility that will remove the halocarbons and recycle the appliance. If halocarbon-containing equipment is on site and owned by the HA, ensure a certified contractor purges the refrigerant prior to before disposal and a decommissioning form is filled out and attached to the equipment. If these types of equipment are being used on site, they must be properly managed under the Federal Halocarbon Regulations, 2003. For more information on halocarbons and their management, please contact your SCH representative.

Storage tanks (fuel or waste oil)

Storage tanks for fuel or waste oil are often found on SCH sites. A lot of machinery uses oil and fuel for daily activities, including boats, vehicles and generators. Due to the possibility of spills, users have to be aware of the presence of these tanks and their surroundings. Fuel and oil spills can have a significant impact on the environment, especially aquatic wildlife. As mentioned in the previous section, they can also lead to the creation of contaminated sites. This can be very costly to remediate and to risk manage.

The types of storage tanks typically found at SCH sites include:

• Used oil storage tanks, either located outside or inside a purpose-built building with secondary containment
• Diesel and/or gasoline storage tanks used for refueling vessels.

Storage tanks are one the riskiest environmental aspects for SCH sites because of their proximity to the water and their potential for spills. There are also many users for this equipment, which presents an inherent risk due to the potential for improper handling and use of the tanks. Properly managing these installations is important to decrease the risk of spills. Following these EBMPs will allow for a proper management. For more information on these measures, please contact your SCH representative.

Hazardous materials

Many hazardous materials (HAZMATs), such as paints, antifreeze and solvents, may be used for activities on site. These materials and their wastes present a danger, not only for the environment, but also for the health of users since they can spill in the environment and potentially cause adverse effects, such as corrosion of equipment, contaminated sites, etc. Some hazardous materials might require specific management practices, such as lead-acid batteries, used oil filters, oily rags or even Polychlorinated biphenyls (PCBs). Please contact your SCH representative for specific questions concerning these types of hazardous materials.

People handling these kinds of materials must be properly trained (such as Workplace Hazardous Materials Information System (WHMIS) training), and haulers and receivers must be authorized or licensed. All documents related to the transportation of HAZMATs must be kept on file for at least two years. This includes bills of lading, and movement documents/manifests for all shipments of hazardous waste over 5 L (liquids) and over 5 kg (solids), whether or not they are being shipped to another province. It is important to know that waste management regulations varies from one province to another. It is important to speak with your SCH representative for more information on the process for your area.

Handling HAZMATs

Handle hazardous materials with care and attention.

Storing HAZMATs

Hazardous materials should be stored in designated safe, well-ventilated areas that are protected from wildlife, the public and the weather or other atmospheric conditions. These areas must be inspected regularly to ensure they are properly maintained that the floor or the storage container is a waterproof membrane and that the temperature follows proper storage requirements.

Disposing of HAZMATs

Proper HAZMAT disposal is important since it decreases the chances of spills during transportation. This limits the risk of site contamination and other human health risks. It not only decreases the chances of spills during transportation, but it also facilitates future handling of these materials.

Non-Hazardous Solid waste

Non-hazardous solid waste (garbage and recycling) is a by-product of commercial and household activities. Garbage disposal costs have been rising steadily over the past decade. Since waste disposal is a contracted operation, most HAs pay for this service with funds collected through moorage fees. However, there are ways to reduce your solid waste and disposal costs. For example, you could complete a Solid Waste Audit to help identify current solid waste management practices, assess applicable regulations and identify goals. These assessments are also a great way to set up a recycling program at the harbour. When setting up such a program, remember that hazardous waste such as paints, varnish, solvents and batteries should be placed in a hazardous waste storage area. Ensure ample garbage bins are placed around the harbour so users always have a garbage receptacle close by.

Wastewater management

Wastewater has its share of environmental issues, especially when it comes to unwanted contamination. This can include storm water runoff, bilge water, sewage/sewage pump out and hull repairs, which can transport contaminants such as lead, solvents and pesticides. It is therefore important to be able to locate where wastewater is created, limit its release into the environment and limit its potential for contamination.

Storm water runoff

Storm water is rainwater that falls onto upland properties and eventually runs into the harbour basin, often through storm drains and overland flow. As this water travels across the surface of buildings, roads, parking lots and soil, it can pick up oily residues and sediment that can contaminate the harbour basin. Over time, deposits of sediment can build up and increase dredging costs. Also, even more significantly, it can harm the aquatic environment.

Cleanliness is an important aspect of operations for fishing vessels. However, abrasive or caustic cleaners can be toxic if they find their way into the marine environment. Power washing and steam blasting are popular cleaning methods because they are relatively cheap and effective. Careless use of these machines can mean that oily residues and other toxins are regularly introduced into the marine environment. Ensure harbour users are working with environmentally safe cleaners or degreasers.

The Fisheries Act states that placing any substance into water that is “deleterious to fish or fish habitat” is a criminal offence (subject to fines of $200,000 and/or six months in jail). It is important to know the location of storm drains that leads to fish-bearing waters in and around the site. This also means being aware of the surface water's potential effect on the basin and to manage it properly.

Bilge water

Bilge water can contain combinations of oil, fuel, solvents and other products. The use of bilge cleaners often only makes matters worse, as they tend to break down oils into smaller droplets and spread the contamination over a greater volume and into harbour sediments. Therefore, pumping untreated bilge water into the harbour or offshore should be avoided and will often constitute a violation of the Fisheries Act.

Sewage

Sewage is a natural by-product of household and commercial activities and its impact on the environment can be minimized, if properly managed. Grey and black water from harbour buildings and boat operations is a significant environmental, health and safety problem. Sewage can cause contamination of shellfish resources, contaminate tourist facilities (beaches) and create unhealthy working conditions for harbour users.

Federal regulations under the Canada Shipping Act that came into effect in 2012 prohibit sewage discharge in Canadian waters within three nautical miles of shore. Boats are to be fitted with a holding tank or an approved marine sanitation device (MSD) which treats the sewage. Vessels fitted with an MSD can discharge 1 nautical mile from shore if the effluent has a fecal coliform count equal to or less than 250/100 millilitres. Either way, discharge of sewage in a SCH site violates these regulations.

Hull maintenance and repair

Hull maintenance usually involves the removal and reapplication of materials to protect and seal a boat's hull. The problem is that many of these finishing materials are toxic. For example, many of the marine paints on vessels today contain high concentrations of lead, arsenic and even PCBs. Removal of these materials can be harmful to human health and the environment and can constitute a violation of the Fisheries Act. These operations must be carried out in a carefully controlled environment.

Climate change

Climate change is becoming an issue in many people's daily lives, especially for those living or working at environmentally sensitive sites. Its impact can transcend known issues to affect our daily activities. For example, due to the changing conditions of our oceans, fish stock might be affected. This is not only bad for the environment, but it also represents a direct threat to the fishing industry as a whole since these activities depend on the well-being of these environments. This is why SCHs needs to join efforts to decrease greenhouse gas (GHG) emissions and to be aware of the GHG targets for Canada (40%–45% below 2005 levels by 2030, net-zero emissions by 2050). These dates might seem well off in the future, but they are closer than they appear. Also, the reduction of GHG emissions is crucial to decreasing the effects of climate change and maintaining it at a manageable level. Users need to be conscious of their daily activities and try to reduce GHG emissions as much as possible. For more information on this, please refer to the Strategic Assessment of Climate Change, which is the Government of Canada's GHG emissions reduction plan.

Audits, Assessments and Inspections

Every SCH site are subject to audits, assessments and inspections. These are often done regularly with or without any warning. This section provides an overview of all the audits, assessments and inspections that SCH sites might have to undergo. These activities are the responsibility of the SCH program, not the HAs. In the case of site visits, the HAs will be notified in advance. The HAs might be contacted for further information in some cases.

National Environmental Compliance Audit Program

The National Environmental Compliance Audit Program (NECAP) is administered by the OEC. The NECAP uses a two-pronged approach to assess environmental regulatory compliance within the department. External NECAP audits are performed by third party certified environmental auditors on a rotational basis at select facilities that have been identified to present higher environmental risk.  Internal audits are performed by employees of the regional OECs at facilities not included in the external NECAP program that have been identified as having a lower environmental risk.Third-party certified environmental auditors can be hired by the OEC. These audits evaluate a site against federal environmental regulatory requirements, including the Canadian Environmental Protection Act and the Fisheries Act. However, the audit does consider provincial legislation, municipal by-laws, environmental codes of practice and standard environmental best management practices as well. Sites are audited every three to five years (depending on the region and the level of risk the site presents). Please contact your local SCH representative for more information on these environmental audits.

Environment and Climate Change Canada inspections

Environment and Climate Change Canada (ECCC) is the federal enforcement organization for environmental legislation. ECCC peace officers have a legal mandate to conduct enforcement visits in the form of inspections and investigations. These inspections can include looking at regulated fuel tanks, equipment containing halocarbons, deposit of polluting substances and even harm to migratory birds or species at risk.

ECCC inspections cannot be declined or postponed. It is important to note that ECCC inspectors showing credentials and acting on behalf of a federal authority can enter the SCH site and are not subject to consent, advance notice or judicial authorization. Public spaces should be made fully accessible to enforcement officers (duty to assist). Transportation accommodations, including access by boat, should be made for enforcement officers inspecting the SCH site. Officers inspecting a site may open containers, take samples, measurements, conduct tests, and take pictures. They are allowed to enter boats and vehicles during an inspection.

Adverse outcomes of an inspection may result in a warning letter, directions by enforcement officers, ministerial orders, environmental protection compliance orders, injunctions, environmental alternative measures or court orders. The site may be notified of a potential visit in advance. If a notification is received, the harbour manager is to contact their SCH representative. SCH will assist by providing advice and, if possible, be present during the site visit. The ECCC peace officers may also stop by unannounced. The site is required to provide an ECCC peace officer with whatever information they may request. Do not offer or supply any information that is not requested

Other audits, assessments and inspections

Other inspections can take place on-site, such as visits from SCH employees, assessments for a certain project under development or an inspection by another department. These kinds of activities may or may not happen regularly. This is why it is important to be in touch with your SCH representative, who will contact the HA in case of these kinds of events on site. Your SCH representative will also communicate in case of corrective actions that needs to be addressed after an audit finding.

Training Requirements and Recommendations

Many types of training can be offered on various environmental issues. This can include WHMIS, transportation of dangerous goods and environmental awareness training. Since these types of training differ from one region to another, contact your SCH representative to find out what training is required and what training is recommended.

Environmental Considerations for Planning Projects

When undertaking a project on site, many environmental laws and regulations may apply. These will be dependent on the size and scope of the project. These may include any or all of the following:

• Impact Assessment Act
• Fisheries Act
• Canadian Environmental Protection Act
• Migratory Birds Convention Act
• Species at Risk Act
• Canadian Navigable Waters Act

Becoming familiar with these laws and regulations is beneficial because they are an important part of environmental management. These laws are designed to ensure that everyone is environmentally vigilant when it comes to planning a project. It is important to note that often the regulatory processes to seek approval for projects near water can take a significant amount of time compared to the project duration. Prior to the start of any project, please contact your SCH representative to determine the applicability of any environmental legislation to your project. This should also be done as early as possible to avoid regulatory delays.

Site roles and responsibilities

Harbour properties are federally owned, and a lease defines the relationship between SCH and individual HAs. Although daily administration and operation of most SCH sites have been delegated to HAs, SCH retains overall responsibility for environmental stewardship.

SCH recognizes and respects each HA as a separate legal entity with the independence to make its own decisions and take responsibility for its actions. SCH permits HAs to seek business opportunities to further their interests, such as the ownership of petroleum storage tank systems. Such permission is subject to compliance with all federal, provincial and municipal laws, codes and by-laws.

The key personnel/entities involved in implementing this EMP include:

• Small Craft Harbours
• Harbour Authority
• Site users (HA members and other harbour users)

The roles and responsibilities of each of these persons/entities for the implementation of the EMP are as follows:

Appendix A : Toxic Cleaning Products Alternatives

This extensive list gives an alternative to more toxic cleaners. However, it is important to remember that these cleaners can still pose a threat to the health of the environment. Use these products safely and dispose of them correctly without excessive spilling into the environment.