Saskatchewan plans move to results-based regulations

The Province of Saskatchewan has introduced a draft Environmental Code, part of its move towards results-based environmental regulation to replace its current permit-based system. This approach is one that has been long supported by Gallon Environment Letter. Instead of providing detailed instructions to industry on equipment and operations through environmental permits, industry will be able to operate without environmental permits but will be required to meet specified environmental performance criteria. This will allow much greater opportunity for technology innovation and efficiency in industry and should mean that the provincial environment ministry spends more time enforcing environmental performance rather than dealing with permit applications.

However, the success or failure of a results-based system depends on the adequacy of the performance standards set by the government. The draft document published by Saskatchewan Environment has standards for  industrial air sources, spills, management of hazardous materials, contaminated sites, water and sewer mains, many aspects of forest management, waste management, liquid waste, and other aspects of environmental management. Comments on the draft code are being solicited until March 16, 2012. Once approved, the Saskatchewan Environmental Code will have the full force of law.

Details of the new Code are available at  For the details, important to affected industries, click on the draft code link followed by the full text of the first edition of the code link. We provide this additional information on links because most other links lead only to the Code Summary which is useful but does not adequately explain the environmental performance standards that industries will be required to meet or exceed.

Rio +20 first draft outcome document released

The UN Conference on Sustainable Development, known as Rio + 20 in recognition of the 20th anniversary of the first Earth Summit, has released a “draft zero” of the outcomes document.

This draft zero contains the following material outcomes in addition to a multitude of aspirational goals:

  • a call for a global policy framework requiring all listed and large private companies to consider sustainability issues and to integrate sustainability information within the reporting cycle.
  • an international knowledge-sharing platform to facilitate countries’ green economy policy design and implementation,
  • establish a capacity development scheme to provide country-specific advice and, where appropriate, region and sector-specific advice to all interested countries and to assist them in accessing available funds.
  • transforming of the UN Commission on Sustainable Development into a Sustainable Development Council that will serve as the authoritative, high-level body for consideration of matters relating to the integration of the three dimensions of sustainable development.
  • establish a UN specialized agency for the environment with universal membership of its Governing Council, based on United Nations Environment Program (this is especially bracketed text which may yet change)
  • propose to build on the Sustainable Energy for All initiative launched by the Secretary-General, with the goals of providing universal access to a basic minimum level of modern energy services for both consumption and production uses by 2030; improving energy efficiency at all levels with a view to doubling the rate of improvement by 2030.
  • implement an international observing network for ocean acidification and to work collectively to prevent further ocean acidification
  • strengthening the Strategic Approach to International Chemicals Management (SAICM), to step up efforts towards a more robust, coherent, effective and efficient international regime for chemicals throughout their lifecycle.
  • establish a 10-Year Framework of Programmes on sustainable consumption and production

Several among the 128 paragraphs include such statements as  “We strongly encourage business and industry to show leadership in advancing a green economy in the context of sustainable development and poverty eradication.”

The Conference is being held from 20 – 22 June in Rio de Janeiro. A number of world leaders are expected to attend. A copy of the complete draft zero outcomes document, which may be subject to significant changes over the next five months, can be found at

UK industry asks government for more effective waste policy

In a just published report, the UK’s largest manufacturer association is asking government for more effective waste policy. Amongst the highlights of the report:

  • 80% of manufacturing executives regard a shortage of raw materials as a risk to their business.
  • 1 in 6 companies said that a shortage of raw materials is now a brake on growth
  • the legislative framework for waste is confusing, disjointed and can inadvertently act as a barrier to resource efficiency. We need a new cohesive policy framework centered on valuing waste as a resource, whilst ensuring the environment is protected.
  • regulators can stimulate resource efficiency by outlining what is permissible, rather than what is not.
  • where a materials market is functioning well, government should reduce packaging and producer responsibility regulation, and shift the focus to materials that need more market intervention.
  • resource efficiency can give our businesses and the UK a real competitive edge whilst securing essential environmental outcomes.

While packaging and material resources issues differ somewhat between the UK and Canada, GallonDaily is convinced that Canada’s manufacturing industry could benefit from following a similar environmentally aggressive approach as UK industry.

See the UK industry association analysis at

The Green Room: a social networking site from Walmart

Many companies have been reluctant to embrace true social networking where ordinary folks have a chance to ask questions and make comments. In our experience the reasons are:

  • legal, because companies are worried that employees may post something inappropriate; and
  • fear of being overwhelmed, because even existing media comment opportunities can frequently attract hundreds of comments.

GallonDaily, and many social networking gurus, believe these concerns are somewhat overblown. The vast majority of citizens are sensible and will only use social networking sites to pass on real comments and ask sensible questions. Companies can take simple measures to reduce legal liability risks associated with answers posted on their social networking sites. Simple moderation of comments can eliminate inappropriate comments from the few users that are seeking to create mayhem.

It seems that multinational Walmart has come to the same conclusions as GallonDaily. A new Walmart sustainability social networking site, The Green Room, provides ordinary people with an opportunity to engage in conversation with the Company about sustainability issues and topics, and vice versa. GallonDaily is impressed, though we will be watching closely to see how this experiment unfolds.

The Walmart Sustainability Green Room can be found at

Canadian Institute for Business and the Environment, GallonDaily’s parent, offers similar services to other companies interested in setting up a sustainability-based social networking site. CIBE has no connection with Walmart’s The Green Room.

Space debris at “tipping point”

Humans have always had a propensity to leave evidence of their presence but rarely has our littering posed as significant a risk to our future activities as the junk that now circulates in orbit around our planet. According to a report by the US National Research Council Committee for the Assessment of NASA’s Orbital Debris Programs, the amount of satellite and rocket debris orbiting the earth has now reached a “tipping point”, by which the Committee means that the debris will continually collide with itself, further increasing the population of orbital debris. The Committee states that “This increase will lead to corresponding increases in spacecraft failures, which will only create more feedback into the system, increasing the debris population growth rate.”

The report reviews measures to assess the risk of harm to humans from falling debris and in many areas it finds current programs inadequate. In particular, it finds that “Enhanced mitigation standards or removal of orbital debris are likely to be necessary to limit the growth in the orbital debris population.” However, the necessary economic, technology, testing, political, or legal considerations for removal of orbital debris have not been fully examined.

As we approach the uncontrolled return of the failed Russian Mars mission in a few days, this NRC report suggests that some of the risk assurances given by the media are not well grounded. It also provides numerous recommendations for more research, as well as technology development and deployment that is needed if we are to ensure that future risks from uncontrolled space junk are manageable.

For a copy of the full report visit

Dioxin exposure may be back on the agenda

The issue of dioxin exposure is returning to the public policy agenda as the US Environmental Protection Agency moves towards release of guidelines for maximum human exposure to this family of toxic substances. US EPA has stated that these guidelines will be released before the end of this month.

The US food industry is concerned that the guidelines may have the effect of declaring many foods toxic as a result of the dioxin concentration that they contain and has asked the US Administration to scale back the human exposure guideline. A media article describing the debate is available at

The EPA’s dioxin reassessment has been a long process that is still far from complete. A summary of current activities is available at and links to the draft dioxin reassessments are available through that page.

In general, dioxin releases are declining but chemicals in this family of persistent bioaccumulative and toxic substances are still ubiquitous in the global environment. Current background levels are likely not causing significant harm, though there is still some concern about the effects of long-term exposure, but we have no practical methods for removing or avoiding those background concentrations.  The greater concern relates to enhanced exposure arising from accidental releases and exposure to significantly contaminated sites.

Our monthly Gallon Environment Letter will review this topic further as final EPA reports are released. To subscribe please visit

US toxic substance releases increase dramatically

The US Environmental Protection Agency has just released its analysis of 2010 releases of toxic substances to the environment. Overall releases of toxic substances are up 16% over 2009.

Some of the analyses by substance are also somewhat disappointing. Total releases of carcinogenic chemicals increased 67% between 2009 and 2010 but decreased by 5% from 2001 to 2010. Releases of dioxins increased 18% from 2009 to 2010 but decreased by 65% from 2001 to 2010 with the chemicals and primary metals sectors being major contributors. Industry managed almost 1.2 billion pounds of persistent, bioaccumulative and toxic (PBT) substances in production-related waste in 2010, an increase of 19% over 2009 but
an overall reduction of 10% since 2001. Lead and lead compounds accounted for 97% (1.1 billion pounds) of the 2010 amount. Mercury and mercury compounds, polycyclic aromatic compounds (PACs), polychlorinated biphenyls (PCBs), certain pesticides, dioxin and dioxin-like compounds and other chemicals made up the remainder.

The detailed report, including analyses by industry sector, is available at  and click on National Analysis.

Antibiotics in animal feed likely a rising issue

US Food and Drug Administration has announced that it is scrapping its program to implement and enforce regulations on use of subtherapeutic levels of antibiotics in animal feed. This use of antibiotics is designed to increase weight gain in animals destined for human food but is widely seen as contributing to evolution of antibiotic resistant strains of organisms which cause sickness in human. As a result of the antibiotic resistance it will far more difficult, and potentially impossible, for doctors to cure people who become sick from ingesting these drug-resistant organisms.

Farm groups and FDA officials seem not to have noticed that when government withdraws from regulatory plans the issue, whatever it is, usually becomes much more widely promoted by environmental and health critics, much more visible in the media, and much more hostile to the involved industry. GallonDaily confidently predicts that the issues surrounding use of antibiotics in meat production will become much more high profile in the United States, and by news spillover in Canada, in the months ahead.

An excellent discussion of the reasons behind the FDA announcement, which is seen as political rather than science-based, can be found in an International Business Times article at

A good discussion of environmental groups position on subtherapeutic use of antibiotics in food animals can be found on the Natural Resources Defense Council website at

Canada’s Opposition and the Environment

In the last three or four years Canada’s late NDP leader seemed to be speaking less about the environment than in previous years. Maybe that was because he thought everyone knew of his environmental commitment; maybe because his advisors felt that environment was not the issue on which to win a lot of votes. The result has been a slight rise in the fortunes of the Green Party, not yet enough to take many seats from the NDP but certainly enough to set some warning bells ringing.

Some of the current NDP leadership campaigns seem to have recognized the weaknesses in the party’s environment platform and are addressing it with their own proposals. If any one of Thomas Mulcair, Nathan Cullen, Peggy Nash, or Paul Dewar wins the title of Leader of the Official Opposition, we can expect that the Conservative Government will be under renewed pressure on the environment in the House of Commons, with resulting implications, both good and bad, for Canadian business. Andrew Reeves has written a good analysis of the NDP Leadership candidate’s positions on the environment in Huffington Post. It’s worth a quick read and can be found at

Dinosaur of the Year: Cruise Lines

Environmentalists have argued for years against non-essential air travel because of the atmospheric effects of aeroplanes but now a major German environmental group, Nature and Biodiversity Conservation Union (NABU) has published a report slamming cruise ships. According to NABU, which awarded two German cruise ship companies its Dinosaur of the Year Award, a cruise ships emits particulate matter equivalent to 5 million cars driving the same distance. In fact, according to NABU data which GallonDaily has not verified, the 15 largest cruise ships emit as much particulate air pollution as all 760 million automobiles in the world.

Two of the biggest problems are that most cruise ships are fueled with some of the dirtiest fuel oils in the world and that the huge engines of cruise ships generally have little or no pollution control included in their exhaust systems.

Just as much of the airline industry in developed countries has responded to critics by selling carbon offsets, so GallonDaily expects that the cruise ship industry will soon develop tools to reduce, or appear to reduce, its air pollution impacts. It’s not rocket science!

Green good wishes for 2012 to all our readers.

More information on the NABU study is available in German at