CDP 2024 Timeline: Essential milestones and what these mean for you
by Ashleigh Turner, Nicola Herschell
We’d like to remind our Canadian petroleum sector clients that Audit reports on your leak detection and repair (LDAR) programs are due to Environment and Climate Change Canada on or before June 30, 2024.
In 2020, the federal government of Canada published new regulations under the Canadian Environmental Protection Act, 1999 requiring petroleum refiners, upgraders and certain petrochemical facilities to implement leak detection and repair programs for volatile organic compounds (VOCs).
VOCs are gas-phase compounds that have a high vapor pressure and low water solubility. They include a variety of chemicals some of which are known to have short- and long-term adverse health effects. VOCs captured by the Regulation include Benzene, Ethylbenzene, Toluene, Xylenes and 1,3-Butadiene.
As part of a comprehensive leak detection and repair (LDAR) program, the Reduction in the Release of Volatile Organic Compounds Regulations (Petroleum Sector) (SOR/2020-231) requires the implementation of a fence line monitoring program for certain listed volatile organic compounds.
An associated requirement of the Regulation is the execution of an independent audit regarding the performance of the fence line monitoring program. The first audit report detailing a subject facility’s compliance with these Regulations during the preceding two calendar years must be submitted to Environment and Climate Change Canada on or before June 30, 2024.
This means that subject facilities need to be initiating their fence line monitoring program audits early in 2024.
This Regulation is wide reaching and applies to any facility that processes liquid petroleum products (crude oil or bitumen, derived products or mixtures thereof) by means distillation, or that produces petrochemical products in an integrated way with a crude oil or bitumen processor.
For more information, visit: Reduction in the Release of Volatile Organic Compounds Regulations (Petroleum Sector) (justice.gc.ca)
In addition to being independent and arm’s length from the facility, the Regulation requires that the auditor meet specific technical qualifications. These include: i) Experience in LDAR programs and fence line monitoring; ii) Registration with a professional engineering or science organization; and iii) Registration with a recognized professional auditing association.
SLR is experienced in the design, development, implementation and monitoring of LDAR programs. Practitioners in our Performance & Assurance practice have the credentials and qualifications to fulfill the independent audit requirements of the Regulation.