This week the Québec Minister of Sustainable Development, Environment, Wildlife and Parks, Yves-François Blanchet, announced a new program for inspection of PCB storage sites. The announcement was made at a site in Pointe-Claire where a company had been found to be storing PCBs illegally. In his comments to the media the Minister indicated that there are 60 licensed PCB storage sites in Quebec but may be as many as 1300 sites in total where PCBs are, or have been, stored. If the Minister’s estimate of a possible 1300 PCB locations in Québec is correct, there may be as many as 4,000 to 5,000 PCB locations across Canada.

Regulation of PCB management is primarily a federal government responsibility but the slow progress being made is an indicator of the problems that arise when deadlines are set too far into the future. The import, manufacture, and sale (for re-use) of PCBs were made illegal in Canada in 1977. Release of PCBs to the environment was made illegal in 1985. Between 1998 and 2008 Environment Canada implemented a number of regulations with respect to PCBs, including mandatory reporting of PCB inventories in use, in storage or destroyed. The objective is to eliminate all PCBs by 2025.

The annual data on PCBs reported by Environment Canada are extremely inconsistent. Reported quantities go up and down like a yoyo. There is no obvious trend towards elimination of PCBs. In acknowledging this problem. Environment Canada states that:

The gap between quantities of PCBs reported . . . can be explained by a number of possible reasons: a large number of persons subject to the Regulations were late in complying or are still not complying with use and storage deadlines due to the costs involved and are not reporting; other persons subject to the Regulations are not complying with these deadlines and reporting requirements due to a lack of knowledge of the Regulations; or Environment Canada’s files on PCBs in use and in storage for 2007 are not up to date. Environment Canada is investigating these possible reasons in order to improve compliance with the requirements of the Regulations.

This current PCB situation presents a potential risk to organizations having PCBs on their property. The Canadian public has come to regard PCBs as one of the most toxic products ever developed. Each time a PCB location is revealed the public in the area are likely to become outraged. This will cause the media and politicians to respond, further damaging the reputation of the PCB owning organization and increasing the probability of new government regulations. PCB owners will be the losers.

There are several reasons that management of PCBs is such a mess:

• in the early days of the PCB problem there were few if any proven technologies for destroying PCBs. That problem has now been solved and destruction technologies are available in Canada.
• transportation and environmentally sound destruction of PCBs is expensive.
• most PCB owners do not have a budget to pay for their disposal, particularly given that PCBs were once a legal and considered safe product.
• many PCB owners are small companies with little relevant expertise.
• PCB manufacturers have never been required to step up to the plate to help pay for destruction of PCBs, again because at the time they were being manufactured they were considered a legal and safe product.
• governments have put very little money into PCB removal and destruction, even though they approved use of PCBs during the period before the PCB ban.
• governments only see final destruction of PCBs to be a priority when some are found in an inappropriate place or when some are released to the environment.
• 2025 is so far away that it does not create a priority today.

Storage of PCBs is not a solution. The PCBs will not degrade and will not go away, except where they are illegally diluted with mineral oil and subsequently discharged to the environment. The costs of PCB destruction can only increase: it will cost more to destroy them in the future than it would cost today.

Organizations, mostly companies and municipalities, that have PCBs in storage or in use (generally in stationary transformers) should now give serious consideration to getting rid of them. Failure to do so poses a risk to the company from spills and from adverse PCB-related media attention. Also there will likely be many more regulations regarding PCB storage and destruction in future years than there are today, increasing the costs of PCB management. It will likely be cheaper to do it now than to postpone it to the future.

The Quebec announcement about increased inspection for PCB storage facilities is at http://www.mddefp.gouv.qc.ca/infuseur/communique.asp?no=2742

Environment Canada’s PCB statements are
at http://www.ec.gc.ca/bpc-pcb/default.asp?lang=En&n=442E2914-1
with the PCB Progress Report on PCB Regulations
at http://www.ec.gc.ca/bpc-pcb/default.asp?lang=En&n=CB9BB5D5-1