Canadian Water and Wastewater Association eBulletin

ERAC posts E2 Plan Reminder

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In June 2020, Environmental Response Assistance Canada (ERAC) alerted its clients that a Schedule 4 notification, indicating that an Environmental Emergency (E2) plan has been fully implemented must be submitted by August 24, 2020.

An E2 plan is considered implemented when it has been written and is operational to the point where the regulate submitting the notice can expect to successfully deal with all aspects of an environmental emergency. Specifically:

  • all implicated staff are trained and aware of their roles;
  • a small-scale or tabletop exercise has been held; and
  • the plan has been reviewed and corrections/updates made.

E2 plans are required under the Environmental Emergencies Act for all industries that have large volumes of hazardous substances stored at their facilities. The E2 Regulations apply to any person who owns or has the charge, management or control of a listed substance that:

  • is at or above the quantity set out in column 3 of Schedule 1 of the E2 Regulations at any time during a calendar year; or
  • is at a quantity greater than zero and is stored in a container that has a maximum capacity equal to or exceeding the
  • threshold quantity for that substance (see subsection 3(1) of the E2 Regulations). Transport Canada has given a  deadline of January 31, 2021 to log in to their ERAP Online Services (EOS) to submit ERAPs.

Water and wastewater facilities may be required to submit Environmental Emergency plans for some chemicals used in treatment depending on the quantity stored onsite.