DAOD 4003-8, Environmental Emergency Preparedness and Response

Table of Content

1. Introduction
2. Definitions
3. Overview
4. Operating Principles
5. Planning
6. Implementation
7. Monitoring and Reporting
8. Release
9. Record Keeping
10. Oversight
11. Compliance and Consequences
12. Responsibilities
13. References

1. Introducion

Date of Issue: 2026-06-01

Application: This DAOD is a directive that applies to employees of the Department of National Defence (DND employees) and an order that applies to officers and non-commissioned members of the Canadian Armed Forces (CAF members).

Supersession: ED 4003-01/03 Spill Reporting

Approval Authority: Assistant Deputy Minister (Infrastructure and Environment) (ADM(IE))

Enquiries: Director Environment and Sustainable Management (DESM)

2. Definitions

due diligence (diligence raisonnable)

The reasonable standard of care for the environment and for the health and safety of others that individuals shall exercise in the course of their actions and duties. (Defence Terminology Bank record number 43051)

environmental emergency (urgence environnementale)

Means

(a) an uncontrolled, unplanned or accidental release, or release in contravention of regulations or interim orders made under this Part, of a substance into the environment; or

(b) the reasonable likelihood of such a release into the environment. (Subsection 193 of the Canadian Environmental Protection Act, 1999)

release (rejet)

Includes discharge, spray, inject, inoculate, abandon, deposit, spill, leak, seep, pour, emit, empty, throw, dump, place and exhaust. (Subsection 3(1) of the Canadian Environmental Protection Act, 1999)

risk assessment (analyse des risques)

The process which entails an examination of the assets of the system under study, system vulnerabilities and the threats which may exploit the vulnerabilities. (Defence Terminology Bank record number 1997)

simulation exercise (exercice de simulation)

Means an exercise simulating the response to an environmental emergency involving the release of a substance. (Subsection 1(1) of the Environmental Emergency Regulations, 2019)

3. Overview

Context

3.1 Environmental emergency preparedness and response (EEPR) in the DND and the CAF is:

1. identified as a key process in the environmental management system; and
2. overarching and aimed at ensuring the ability to minimize the impact of environmental emergencies that can occur from the release of regulated substances.

3.2 Substances identified by the Government of Canada under the Environmental Emergencies Regulations, 2019 pose an increased risk of causing environmental emergencies when stored in sufficient quantities. Likewise, other substances and circumstances may also cause environmental emergencies as identified by an environmental risk assessment (ERA) or legislation.

3.3 For EEPR, risk assessments focus on the potential environmental risks and must be referred to as ERA.

3.4 A robust EEPR process is a key component of environmental management system controls that supports prevention and mitigation of environmental emergencies, while:

1. improving engagement with the local community; and
2. reducing impacts to human health, property, environment and business continuity.

3.5 EEPR is one of many facets of site or system emergency response plans (ERPs), alongside other functional areas such as fire safety, nuclear safety and health and safety. Preparedness and response include planning, testing, responding, notifying, reporting, oversight and training.

Note – In this DAOD, ERPs are understood to be location-specific, based on the risk assessments and procedures for dealing with emergency situations.

3.6 Provincial, territorial, and municipal legislation such as laws, guidelines, and by-laws along with international and host-nation legislation for activities outside Canada define requirements for EEPR unless they are contrary to federal laws or regulations on the same subject or impair the fulfilment of the federal legislation and mandate.

3.7 The DND and the CAF must comply with the local laws that are considered more stringent than federal laws.

Purpose

3.8 The purpose of this DAOD is to provide direction on the obligation to prevent, prepare for, respond to and recover from environmental emergencies with the goal of reducing risk to the environment. 

Application

3.9 EEPR is required for substances identified as having an increased potential to cause environmental emergencies including:

1. Environmental Emergencies Regulations, 2019 Schedule 1 list of substances;
2. Petroleum, oils, and lubricants as defined by the Storage Tank Systems for Petroleum Products and Allied Petroleum Products Regulations;
3. Polychlorinated biphenyls (PCB) as defined in the PCB Regulations;
4. Hazardous products as defined by the Hazardous Products Act;
5. Dangerous goods as defined by the Transportation of Dangerous Goods Act, 1992;
6. Pest control product as defined by the Pest Control Products Act;
7. Substances deleterious to fish and fish habitat as defined by the Fisheries Act;
8. Per- and polyfluoroalkyl substances (PFAS) as identified by Ministerial notice in the Canada Gazette; and
9. Environment and Climate Change Canada contaminants of emerging concern.

3.10 Examples of identified substances used by the DND and the CAF include and are not limited to chlorine used for water treatment, propane for use in gas-burning appliances and fire fighting training, petroleum, oils, and lubricants in storage tank systems, products used in the maintenance and operation of vehicles, hazardous substances in storage lockers and buildings, natural gas for heating, hexavalent chromium used for electroplating and aircraft refinishing, PCB containing electrical transformers, hazardous substances used in operation or maintenance and hazardous waste must be stored prior to disposal.

Exclusion

3.11 Select Canadian Environmental Protection Act, 1999 regulations apply:

1. further controls on a subset of substances and related equipment, such as storage tank systems, and refrigeration, air conditioning and fire extinguishing systems; and
2. more comprehensive requirements are defined in separate DND and CAF policy documents.

Legal Implications

3.12 The following are some examples of legislation, which broadly include various federal

• requirements applicable to the management and implementation of EEPR and related substances:
• Canadian Environmental Protection Act, 1999
• Environmental Emergency Regulations, 2019
• PCB Regulations
• Storage Tank Systems for Petroleum Products and Allied Petroleum Products Regulations
• Chromium Electroplating, Chromium Anodizing and Reverse Etching Regulations
• Tetrachloroethylene (Use in Dry Cleaning and Reporting Requirements) Regulations
• Fisheries Act
• Migratory Birds Convention Act, 1994
• United Nations Declaration on the Rights of Indigenous Peoples Act
• Species at Risk Act
• Transportation of Dangerous Goods Act, 1992

3.13 Relevant guidance documents and fact sheets are also available from Environment and Climate Change Canada (see Section 13).

4. Operating Principles

4.1 The DND and the CAF are committed to preparing for, and responding to, environmental emergencies by adhering to legislative requirements as well as best management practices. Integrating EEPR across existing emergency response planning prevents and mitigates the impacts of environmental emergencies while maintaining operational readiness. Resources applied to planning, implementation, monitoring and reporting must be proportional to the level of risk of actual or potential environmental emergencies.

4.2 If environmental emergencies may impact Indigenous peoples, DND and the CAF are committed to undertaking engagement and consultation to fulfil applicable obligations, including legal and policy obligations such as Aboriginal and treaty rights and those under the United Nations Declaration on the Rights of Indigenous Peoples, Articles 29 and 30.

4.3 Among other key outcomes, integrated management helps provide for the:

1. mechanisms for minimizing risk, loss and damage by considering risks to the environment and human health;
2. protection of assets, resources and services;
3. preservation of water, soil, and air quality;
4. identification of potential hazards;
5. establishing of systems for preventing releases; and
6. guidance for a timely and effective response to owners, operators and emergency response personnel, in the event of releases.

5. Planning

5.1 The planning of EEPR management must adhere to applicable ADM(IE) policies.

5.2 Effective planning:

1. demonstrates due diligence and reduces potential impacts on the environment;
2. involves maintaining inventories along with quantities of substances and hazardous waste, accessible to relevant stakeholders, as part of determining applicable requirements, ensuring safe handling, storage, transport and managing risk;
3. defines preparedness and response measures, including training, simulation exercises, public notification and Indigenous engagement and consultation to be implemented in line with an ERA; and
4. integrates environmental considerations into emergency response planning.

Environmental Risk Assessment

5.3 An ERA is part of the planning process to determine where environmental emergencies might take place. A new or existing and up-to-date ERA:

1. defines substances, their use, and related risks;
2. identifies the nature and sensitivity of the receiving environment and considers the impacts to specific receiving environments;
3. assesses resources available during a response;
4. provides a quantified risk level based on established criteria; and
5. results in identifying where measures are needed in an ERP to protect the environment and human health.

Emergency Response Plan

5.4 An ERP provides personnel with the operational guideline to follow in the event of emergencies that includes:

1. identifying local Indigenous peoples and communities that must be engaged or consulted in the event of an environmental emergency that may impact them; and
2. environmental considerations implemented into the ERP to reduce the impacts, losses and damages caused by environmental emergencies, while also meeting legislative requirements.

6. Implementation

6.1 Simulation exercises are a pivotal component of ensuring environmental emergencies can be effectively managed. Results are then used to update and track improvements to ERPs.

6.2 Individuals are required to have the necessary training, resources and equipment to carry out their tasks as described in the ERP. The DND and the CAF must ensure validity of related training and qualifications.

6.3 Proactive disclosure to the public of potential risks from environmental emergencies must adhere to DAOD 2008-0, Public Affairs Policy and meet legislative requirements.

7. Monitoring and Reporting

Monitoring

7.1 Monitoring the integration and implementation of the EEPR process is essential to ensure compliance with legislative requirements and ongoing performance for environmental protection.

7.2 Monitoring for EEPR includes, at a minimum:

1. ensuring compliance with legislative and policy requirements, as well as ongoing performance for environmental protection;
2. reviewing all EEPR policy and procedures for ongoing validity; and
3. auditing of policy-driven activities and reporting trends as compared against key performance indicators (KPI).

Reporting

7.3 The DND and the CAF are responsible for internal and external reporting on various aspects of EEPR that include, release reporting and the registration of prescribed facilities. Reporting on Indigenous engagement and consultation is completed by using the Indigenous Initiatives Tracker.

8. Release

Criteria

8.1 Determination that an environmental emergency has occurred includes assessing whether the release meets certain criteria. Criteria vary based on the substance released and its quantity, concentration, location and statutes. In case it is unclear whether a release constitutes an environmental emergency, reporting should proceed. 

Prevention

8.2 Environmental emergencies due to releases must be prevented through:

1. diligent implementation of the technical planning, designing, operation and maintenance, including standard operating procedures; and
2. eliminating or mitigating, if possible, risk sources identified through ERAs by swapping substances for less harmful alternatives, amending procedures or implementing other controls.

Environmental Emergency

8.3 If there is an imminent or potential danger to the public because of an environmental emergency, and following such an event:

1. public notification measures must be undertaken in accordance with DAOD 2008-0; and
2. care must be taken in the awareness and engagement with Indigenous communities that could be adversely impacted by environmental emergencies.

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9. Record Keeping

9.1 Record keeping:

1. is an important element of demonstrating compliance to environmental enforcement officers;
2. allows for analysis of data to determine trends, identify challenges, and define improvements;
3. aligns with the DND and CAF Data Management Strategy whereby data is managed as a shared asset; and
4. allows data to be leveraged in all aspects of DND and CAF programs by:
   1. enhancing capabilities and decision-making; and
   2. providing an information advantage during military operation.

9.2 At minimum, the following types of records regarding EEPR must be maintained and accessible as per the DND Data Management Strategy:

1. ERAs;
2. ERPs and procedures;
3. simulation exercise records and evaluation;
4. training records that demonstrate users are appropriately instructed/qualified for the implementation of EEPR; and
5. notification and reporting records (e.g., notices to local community and environmental regulator, and reportable environmental emergencies).

10. Oversight

10.1 Effective oversight must:

1. promptly identify non-compliance with environmental requirements;
2. ensure appropriate corrective steps are recommended; and
3. ensure mitigative measures to prevent similar occurrences are implemented.

10.2 At minimum, oversight must include:

1. assessing compliance with environmental requirements and related KPIs;
2. reviewing ERPs and related ERAs and testing records and, where appropriate, defining and implementing needed improvements to correct and prevent issues; and
3. providing risk-based status reporting for senior management.

11. Compliance and Consequences

Compliance

11.1 DND employees and CAF members must comply with this DAOD. Should clarification of the policies or instructions set out in this DAOD be required, DND employees and CAF members may seek direction through their channel of communication or chain of command, as appropriate. Managers and military supervisors have the primary responsibility for and means of ensuring the compliance of their DND employees and CAF members with this DAOD.

Consequences of Non-Compliance

11.2 DND employees and CAF members are accountable to their respective managers and military supervisors for any failure to comply with the direction set out in this DAOD. Non-compliance with this DAOD may result in administrative action, including the imposition of disciplinary measures, for a DND employee, and administrative or disciplinary action, or both, for a CAF member. Non-compliance may also result in the imposition of liability on the part of His Majesty in right of Canada, DND employees and CAF members.

Note – In respect to the compliance of DND employees, see the Treasury Board Framework for the Management of Compliance for additional information.

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12. Responsibilities

Responsibility Table

12.1 The following table identifies responsibilities associated with this DAOD:

13. References

Acts, Regulations, Policies and Policy DAOD

• Canadian Environmental Protection Act, 1999
• Fisheries Act
• Hazardous Products Act
• Migratory Birds Convention Act, 1994
• Pest Controls Products Act
• Species at Risk Act
• Transportation of Dangerous Goods Act, 1992
• United Nations Declaration on the Rights of Indigenous Peoples Act
• Chromium Electroplating, Chromium Anodizing and Reverse Etching Regulations
• Environmental Emergency Regulations, 2019
• PCB Regulations
• Release and Environmental Emergency Notification Regulations
• Storage Tank Systems for Petroleum Products and Allied Petroleum Products Regulations
• Tetrachloroethylene (Use in Dry Cleaning and Reporting Requirements) Regulations
• Framework for the Management of Compliance, Treasury Board
• Technical Guidelines for the Environmental Emergency Regulation, 2019, Environment and Climate Change Canada
• DAOD 1000-11, Policy Framework for Infrastructure and Environment Management
• DAOD 4003-0, Environmental Protection and Stewardship

Other References

• DAOD 2008-0, Public Affairs Policy
• DAOD 3014-0, Fuels and Lubricants
• DAOD 4003-3, Environmental Inspections and Enforcement Measures
• DAOD 4004-0, Indigenous Affairs
• DAOD 4007-2, Emergency Fire Operations in Respect of DND and CAF Infrastructure
• DAOD 4007-5, Initial Response by Firefighters to Hazardous Material Incidents
• Interim Directive – Indigenous Consultation, Director General Indigenous Affairs
• Interim Directive – Indigenous Engagement, Director General Indigenous Affairs
• Interim Standard – Indigenous Engagement and Consultation, Director General Indigenous Affairs
• United Nations Declaration on the Rights of Indigenous Peoples
• CANUTEC, Transport Canada website
• Hazardous Materials Reference Application
• Defence Resource Management Information System (DRMIS) Resources
• IW21_Create a HX Notification for Spills and Water Quality Advisories IE
• Indigenous Initiatives Tracker

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