BMP 4 – Hazardous Substances, Waste and Dangerous Goods
Planning the proper storage and handling of dangerous goods and hazardous waste products and developing spill mitigation plans will assist an individual or company in avoiding potential environmental issues that may occur during an exploration program.
Most information detailed in the following document may not apply to early exploration activities but is important to understand to minimize environmental risks as projects move into the advanced exploration stage and when seeking approval(s) for future mine site development.
NOTE: This document does not include the handling of solid and liquid domestic waste. For information related to handling of these materials, please see BMP–14 Temporary Work Camps.
In Manitoba, The Dangerous Goods Handling and Transportation Act sets out requirements for the handling and transportation of dangerous goods and hazardous waste and enables the provincial government to establish standards pertaining to the generation, storage, transportation, and disposal of hazardous waste.
In addition, the Dangerous Goods Handling and Transportation Regulation in conjunction with the Hazardous Waste Regulation adopts the federal Transportation of Dangerous Goods Regulations with criteria and lists to classify hazardous waste for use within Manitoba.
Examples of hazardous waste include used oil and used oil filters; waste paint; solvents; heavy metals; batteries; antifreeze and pesticides. Answers to frequently asked questions regarding hazardous wastes can be found in Manitoba’s FAQ document.
The Hazardous Waste Regulation provides:
- Criteria for determining whether a product, substance or organism is a hazardous waste;
- Hazardous waste registration and storage requirements for generators of hazardous wastes;
- Licence requirements for transporters of hazardous waste;
- A system to track hazardous waste from generation point to final disposal; and
- Annual reporting requirements for licensed hazardous waste disposal facilities
Hazardous Waste Generator Registration
In accordance with the Hazardous Waste Regulation, a generator of hazardous waste must register with Manitoba Environment and Climate Change when:
- Hazardous waste is generated at the premises in a quantity equal to or greater than the quantity specified in Schedule F of the Regulation – the reportable quantity is 5 L per month for liquid waste, or 5 kg per month for solid waste. Depending on the dangerous goods classification of the waste, it varies from 1 L or 1 kg to 50 L or 50 kg;
- Solid hazardous waste in a quantity of 5 kg or more, or liquid hazardous waste in a quantity of 5 L or more (or liquid or solid waste that contains more than 500 g of Polychlorinated Biphenyls mixture) is to be removed from the premises where it was generated; or
- Hazardous waste in quantities equal to or greater than the amount specified in Column 2 of Schedule G of the Hazardous Waste Regulation is to be transported off-site.
Hazardous Waste Generator Registration Form
Generators of hazardous waste must register with Manitoba Environment and Climate Change and report the types and quantities of hazardous wastes generated at each site. The Hazardous Waste Generator Registration Form is used for the initial registration, to update the registration, and/or provide a supplementary report (e.g.: to report additional wastes).
Application for a Licence to Transport Hazardous Waste
Carriers of hazardous waste must possess a Carrier Licence issued by Manitoba Environment and Climate Change by completing the Application for a Licence to Transport Hazardous Waste. A support Guide is available to assist with completing the application. The licence is issued to the company that is the transporter of the waste and each driver must have training in accordance with the federal Transportation of Dangerous Goods Regulations.
Application for a Licence to Receive Hazardous Waste
In accordance with The Dangerous Goods Handling and Transportation Act, a facility that receives hazardous waste from offsite must be approved by Manitoba Environment and Climate Change. To apply for a licence for the construction and operation of a hazardous waste disposal facility, a Dangerous Goods Handling and Transportation Act Application Form must be completed and send with a cover letter and supporting information to the Director of the Environmental Approvals Branch.
Storage and Handling of Dangerous Goods and Hazardous Waste
There may be requirements under The Dangerous Goods Handling and Transportation Act to register and approve a storage facility based on the volumes, products, and storage receptacles. For additional information on petroleum storage and handling, refer to BMP – 3 Storage and Handling of Petroleum Products and Allied Products.
Applicants should follow the storage and handling procedures listed below for all volumes to minimize environmental risks and when storing dangerous goods, ensure that:
- Dangerous goods are stored in designated areas and secured to prevent unauthorized access;
- Containers are maintained in good condition and not damaged, rusting or leaking;
- Containers are properly labelled and sealed;
- Maintenance and operating procedures are established to prevent spills or fire hazards;
- Procedures are clearly outlined and posted where all operators can see them;
- All operators have been provided with awareness training in handling, storage, and procedures for dangerous goods;
- Soil type, terrain, ground water table, surface water and water wells in the storage area(s) are identified and assessed prior to site selection to limit the extent of contamination from any spills;
- A safe distance is maintained between storage areas and tents and/or buildings and consider the prevailing wind direction;
- Fire extinguishers are on site at fuelling areas as required by the Office of the Fire Commissioner and the National Fire Code;
- Inspect and maintain all storage tanks. There should be no signs of corrosion and tanks must be painted, if applicable;
- Each fuel storage tank should have two shut-off valves, one which may be the handle; one located near the tank;
- Dangerous goods are stored in approved secondary containment, as required under applicable regulations (construction requirements for secondary containment are available from the Department of Environment and Climate Change);
- For each storage area, secondary containment is required. For a storage area containing a single drum, containment must consist of 110 per cent of the volume. For a storage area containing multiple drums, containment must consist of 10 per cent of the cumulative volume plus 100 per cent of the volume of the largest container;
- Use drip pans and/or nozzle holders to contain drips or spills. Nozzles should be mounted above the drip catchments;
- Ensure slip tanks (tidy tanks) are secured into the vehicle. The intent is that in the event of a roll over, a full slip tank will stay secured in the truck;
- Inspection of fuel pumps and other equipment for worn hoses and leaks and repair equipment when required;
- Maintain spill kits on site. The number of spill kits depends on the program (e.g.: work camp, drill site, pump shacks). A large spill kit has an absorbent capacity of 120 L, and a small spill kit has an absorbent capacity of 20 L;
- Any water intake equipment must have secondary containment and spill kits for both the pump and pump fuel supply;
- When refuelling on ice or water, use secondary containment and spill kits;
- All toxic chemicals are stored securely;
- Neutralizing materials must be stored adjacent to acids;
- Lubricants and oily substances should be removed and properly disposed of prior to sump water disposal;
- Used oil containers must be taken to a receiver and not discarded in landfills;
- Used oil filters are hazardous waste and must not be discarded in landfills. Place in a drum and transport to an approved receiving site. Used oil consignees will also take filters and oil containers;
- Used oil or waste antifreeze must be disposed of at an approved receiver facility; and
- Any use of, storage of, or transportation of explosives requires a provincial permit and may also require federal approval (See BMP 2– Early Exploration for details).
Refer to the Compliance Guide to Manitoba’s Hazardous Waste Legislation for more information.
Spill Contingency Planning
It is important for an individual or company to establish and maintain a response plan with instructions that outline responsibilities and procedures for before, during, and after a potential spill and review the spill response plan with operators.
Additionally, it is important to have a spill kit capable of containing and absorbing fuel spills. An operator is required to have appropriate equipment/absorbent material on hand for the cleanup. Containment and storage of contaminated materials and this equipment/absorbent material shall be readily available in areas where spills could potentially occur.
If a spill occurs, personnel must take the following steps when safe to do so:
- Prevent further spillage;
- Contain the spilled material;
- Minimize the effects of the spill; and
- Restore the area affected as near as possible to its previous condition.
All spills of any quantity are to be documented by recording the date, location, type of spill, reason for spill, and cleanup action taken.
Mandatory reporting of environmental accidents in Manitoba is required by the Environmental Accident Reporting Regulation. The requirements for reporting an environmental accident and a Schedule of Reportable Quantities can be found in the regulation. Spills of reportable quantities must be immediately reported by calling the 24-hour Environmental Emergency Reporting Line (204-944-4888).
The Manitoba Environmental Emergency Response Team operates under the authority of The Dangerous Goods Handling and Transportation Act, which gives Environment Officers and Inspectors special powers in emergencies to enter any land or building, control and clean up releases, and take any emergency actions required to protect persons, property, and the environment. The active team consists Environment Officers from Manitoba Environment and Climate Change located throughout the province who are trained to be part of the Department’s response system. The Emergency Response Team responds to releases or potential releases of contaminants that may have a detrimental effect on the physical environment or public health.
Manitoba’s Emergency Plan identifies Manitoba Environment and Climate Change as the lead provincial agency for dangerous goods incidents. When necessary, specialized expertise from any of the Department’s program areas may be called out to assist in the response to an environmental accident. The response team has access to all the resources of the provincial government and, through agreement, the resources of the federal government as well.
If a spill occurs, the Department of Environment and Climate Change may request soil samples from the contaminated site and analysis of the samples following cleanup activities.
Contaminated soils and clean up materials must be safely stored on site and then sent to an appropriate or approved disposal facility.
Contacts
Department of Environment and Climate Change
Environmental Compliance and Enforcement Branch
Winnipeg Office
204-945-5305
EnvCEWinnipeg@gov.mb.ca
For areas outside of Winnipeg, see Listing for Regional Office Contacts
Department of Environment and Climate Change
Environmental Approvals Branch
204-945-8321
EABDirector@gov.mb.ca
Related Acts and Regulations
D12 – The Dangerous Goods Handling and Transportation Act
M.R. 55/2003 – Dangerous Goods Handling and Transportation Regulation
M.R. 195/2015 – Hazardous Waste Regulation
M.R. 439/87 – Environmental Accident Reporting Regulation
M.R. 188/2001 – Storage and Handling of Petroleum Products and Allied Products Regulation
Canada:
Transportation of Dangerous Goods Act, 1992
Transportation of Dangerous Goods Regulations
Cross-border Movement of Hazardous Waste and Hazardous Recyclable Material Regulations
Canadian Environmental Protection Act