Canada’s Chemical Management Plan Petroleum Sector Approach

1. Canada’sChemical Management PlanPetroleum Sector Approach Sound Management of Chemicals Working Group – Stakeholder Meeting April 1-2, 2009 Roger Keefe Imperial Oil

2. Background • CEPA’99 required prioritizing existing chemicals inventory, the Domestic Substances List (DSL) • 23,000 substances “Categorized” (1999-2006) • Criteria: greatest potential for human exposure, persistence, bioaccumulation and inherent toxicity • 4300 substances required further evaluation • CMP announced Dec/2006 • High priority substances assessments (2007-2010) • Medium priority substances assessments (2010-2018) • Low priority substances addressed by rapid screening • Many other CMP programs to assure risks are managed CEPA’99 is the Canadian Environmental Protection Act, renewed in 1999 CMP is the Chemicals Management Plan

3. Petroleum Sector Streams Approach • Rationale for sector approach • Large number of substances in the industry • Complex mixtures • Many substances mainly limited to sector • Used for blending • Captive use in extraction & refining • Consumed as feedstocks and fuels • Products & processes, when generic, allows: • One govt interface with upstream (exploration & production) • One govt interface with downstream (refining & distribution) • Industry can work together

4. High Priority Petroleum Substances in CMP • Challenge Program • ~60 / 200 Challenge substances for further assessment have been linked with the petroleum sector plus other sectors • Petroleum Sector Streams Approach • ~160 substances have been identified specifically with the Petroleum Sector for further assessment • Health Canada & Environment Canada have a team dedicated to the petroleum sector streams approach • High priority petroleum substances to be assessed in parallel to Challenge Program over 3 years

5. High Priority Petroleum Substances in CMP 1. Challenge Program(~60 / 200 substances): • Information Gathering • Challenge to industry to provide new information through a mandatory CEPA section 71 survey and a voluntary questionnaire • 12 batches of 15-30 substances published every 3 months (Feb/2007 – Dec/2009) • Screening Assessments • To determine if each substance is “Toxic” as defined by section 64, CEPA’99 • A draft screening assessment report issued (in 6 months) & final report (6 months later) • Risk Management • For substances recommended for addition to the List of Toxic Substances (Schedule 1) • Proposed risk management instrument must be proposed within 2 years and finalized within an additional 18 months • Petroleum Sector Streams Approach (~160 substances) • Information Gathering • Using Mandatory Survey, contracts and voluntary information submissions • Screening Assessments • To determine if each substance is “Toxic” as defined by CEPA 1999 • Risk Management • For substances recommended for addition to the List of Toxic Substances, identify additional risk management requirements and develop risk managements instruments as needed (same timeframe as above)

6. Petroleum Sector - Data Collection • Products in wide use (>16)- see slide 11 • These products from all producers are very similar • Hazard & exposure data, current risk management requirements & practices = largely in public domain • Contractors collecting information • Intermediate process streams (<145) • Downstream industry – sec 71 “triage”  detailed surveys • Canadian Petroleum Products Institute + upgraders + others • Upstream industry – voluntary information provided • Canadian Association of Petroleum Producers • CPPI drawing on other experience, e.g., API • Contractor providing generic process information For more on the Petroleum Sector Stream Approach, visit: www.chemicalsubstanceschimiques.gc.ca/plan/petroleum-petrole_e.html

7. Screening Assessment & Risk Management Approach may vary depending on fate of substance substance not in commerce ~160 high-priority petroleum substances Still in commerce? no yes manufactured or imported by the petroleum sector? manufactured or imported outside of the petroleum sector? yes yes no leaving facility? used by the petroleum sector? no yes yes used by the public? used in other industrial sectors? used elsewhere in the petroleum industry? used by other sectors? yes no substance of which petroleum sector is one of the users substance not manufactured or used by petroleum sector petroleum substance used by the public petroleum substance moved within petroleum sector petroleum substance used in other industry sectors substance made elsewhere but used only by the petroleum sector site limited petroleum substance Releases? Uses? Hazards? Existing RM? Additional RM needed? Alternatives? = Possible substance specific approach? = Possible Group-based Approach? = Integrated with other sector work?

8. Petrochemicals • Responsible Care® started in Canada, 1985 with ethic & principles evolving into 6 codes: • Community awareness & emergency response • Research & development • Manufacturing • Transportation • Distribution • Hazardous waste management • Verification • Improving performance • Emissions ... Injuries ... Transportation accidents • New: RC® “Our commitment to sustainability”

9. Petroleum Sector Streams Approach: Status • Working well – relationship & process for data collection • Information sharing about petroleum processes, controls, what industry can provide, and realistic timing • Identification of key information needs, practical sec 71 survey • Identify data sources, use of contractors • Wait ‘n’ see – data collection / risk assessment • Composition – variability • Drilling muds, additives (fuels, lubes) • “Mixtures” in screening assessments • Science based assessments vs precaution • Challenges - risk management • Gap identification • Risk trade-off’s

10. References • Chemicals Management Plan, Government of Canada • www.chemicalsubstanceschimiques.gc.ca • Canadian Petroleum Products Institute (CPPI) • www.cppi.ca (downstream petroleum industry association) • Canadian Association of Petroleum Producers (CAPP) • www.capp.ca (upstream petroleum industry association) • Canadian Chemical Producers’ Association (CCPA) • www.ccpa.ca (chemical industry association) The author gratefully acknowledges Environment Canada & Health Canada for their contributions to the information used in this presentation

11. Gasoline Diesel fuel Fuel oils no. 2, 4 & 6 Naphtha solvent, ligroine, Stoddard solvent Lubricating oils Petrolatum Asphalt Liquefied petroleum gases (LPG) Others, to be identified Petroleum Products in Wide Use

12. Questions to address through information collection 1. still in commerce? ~160 high-priority petroleum substances 2a. extracted, produced/manufactured, purchased/imported for use as feedstock by the petroleum sector? 7. manufactured or imported outside of the petroleum sector? 2b. which part of the petroleum sector? 2c. where in the facility/on the site does the substance exist? 8a. used by petroleum sector? 9. used in other sectors? 8b. by which part of the petroleum sector? 3. leaving facility / site? 8c. where in the facility does the substance exist? 4. used by the public? 5. used in other industrial sectors? 6. used elsewhere in petroleum industry? 13. existing RM? how are substances handled 10. releases? from where, to where, how much 11. hazards? properties of substances 12. exposure to the substance? 14. are there any RM gaps? 16. do alternatives exist ? 15. uses? for what purpose?