Reduction in the Release of Volatile Organic Compounds (Storage and Loading of Volatile Petroleum Liquids) Regulations
Key findings from the strategic environmental assessment (SEA) conducted for the Reduction in the Release of Volatile Organic Compounds (Storage and Loading of Volatile Petroleum Liquids) Regulations (the Regulations), as published in the Canada Gazette, Part II on March 26, 2025.
The Government of Canada has finalized regulations to further reduce volatile organic compounds (VOCs) from a variety of petroleum sector facilities. These Regulations establish permanent national regulatory requirements for facilities of concern in communities across Canada.
The oil and gas sector is Canada’s largest source of VOC emissions. Sources of VOC emissions from petroleum and petrochemical facilities include leaks from process equipment, storage tanks, and loading activities. Total estimated VOC emissions from petroleum and petrochemical facilities covered by the Regulations are 55,841 tonnes, with approximately 63% (35,287 tonnes) from storage and loading of petroleum products.
The Regulations introduced a nationally consistent approach to reducing VOC emissions from these sources. Preexisting regulatory measures vary across the country, and jurisdictions with measures in place to control storage and loading emissions have significantly lower emissions than jurisdictions where no requirements are in place.
The Regulations require that petroleum liquid storage tanks and equipment that is used to load and unload petroleum liquids from pipelines, trains, trucks and ships (loading racks) be equipped with emissions control equipment. The operators of these facilities are required to install, inspect, maintain, and repair that equipment. The Regulations also include recordkeeping and reporting requirements for operators.
Facilities subject to the Regulations include petroleum refineries and upgraders; truck, rail, marine, and pipeline terminals; petrochemical facilities; bulk fuel facilities; and steel mills. It is estimated that about 434 facilities will be subject to the Regulations. These facilities are in every province and territory with many located in and around residential neighbourhoods.
The impacts of VOC emissions on human health are well understood. They lead to the formation of ground-level ozone and particulate matter, notably particulate matter less than 2.5 micrometres in diameter (PM2.5) that can travel deep into the human body. There is international consensus among leading health organizations including Health Canada that exposure to these pollutants increases the risks for a wide range of health problems, including asthma, lung cancer, heart and lung disease and heart failure, and contributes to premature deaths.
In addition, evidence shows that human exposure to certain VOCs, such as benzene, increases the risk of cancer. Benzene is included in the List of Toxic Substances under the Canadian Environmental Protection Act. The regulations will reduce emissions of benzene, a known human carcinogen.
Particulate matter and ozone are also known to negatively affect vegetation, soils, water, wildlife, materials, as well as the overall quality of ecosystems. Chronic exposure to ozone may result in crop yield losses, degradation of vegetation, reduced timber growth and premature livestock mortalities and illnesses.
SEA conclusions
The SEA conducted for the Regulations concluded that the direct outcome of the Regulations will be a reduction in releases of VOCs, including benzene, to the atmosphere. Reductions in releases of VOCs and improved air quality are expected to contribute to improvements in human health and quality of the environment. There will also be a small reduction in greenhouse gas (GHG) emissions, primarily methane that is present in some of the controlled VOC sources.
The Regulations will directly contribute to the 2022-2026 Federal Sustainable Development Strategy (FSDS) Goal 11 of “Improve Access to Affordable Housing, Clean Air, Transportation, Parks, and Green Space, as Well as Cultural Heritage in Canada” and Goal 13 of “Take Action on Climate Change and its Impacts.” The Regulations reduce fugitive VOC releases from the affected facilities and reduce emissions of GHGs, primarily methane, by 7,800 tonnes, providing better access to clean air and reducing the effects of climate change. Furthermore, by reducing emissions of GHGs, there will be a small contribution to the FSDS target of Canada achieving a 40-45% GHG emission reductions below 2005 levels by 2030 and achieving net-zero emissions by 2050. The Regulations will also support the related United Nations 2030 Agenda Sustainable Development Goals 11 - Sustainable Cities and Communities, particularly Target 11.6 to “By 2030, reduce the adverse per capita environmental impact of cities, including by paying special attention to air quality and municipal and other waste”, and 13 - Climate Action.
It is estimated that air quality improvements from the Regulations would result in 150 fewer premature deaths over the period of analysis (2024-2045), mainly associated with reduced exposure to fine particulate matter (PM2.5) and ground-level ozone. In addition, better air quality is expected to result in 31,000 fewer days of asthma symptoms among asthmatics aged 5 to 19, and 91,000 fewer days of restricted activity among non-asthmatics. The total present value of health benefits resulting from air quality improvements attributable to the Regulations is estimated at $1.1 billion (2022 Canadian dollars) for the 2025-2045 period. The provinces with the largest populations and the highest levels of population exposure will receive the greatest health benefits.
Stakeholder consultations
Proposed Regulations, along with a Regulatory Impact Analysis Statement describing the early and prepublication consultations, were published in the Canada Gazette, Part I on February 24, 2024. This was followed by a 60-day consultation period.
In general, comments on the proposed Regulations reflected a view that Environment and Climate Change Canada (ECCC) had addressed major comments from initial consultations held in 2021 after the publication of a discussion document entitled A proposed approach to control volatile organic compounds (VOC) emissions from the storage and loading of petroleum liquids. The majority of the comments were neutral or supportive and mostly focused on technical details as opposed to philosophical differences in approach, rationale or framework.
Feedback from Indigenous peoples, non-governmental organizations, consultants and technology providers focused on specific aspects of the proposal and sought changes to certain requirements and some applicability criteria. Members of the general public who submitted comments mostly expressed support for the proposed Regulations or requested further action on health and environmental issues.
Provincial and municipal governments made suggestions for more stringent measures, requested information sharing, and asked questions about managing potential overlap between federal and local requirements.
Industry representatives were generally supportive of the proposed regulatory approach but expressed concerns with the proposed implementation and repair timelines, test methods for vapour pressure, and the possibility of requirements overlapping or conflicting with other regulated requirements, including provincial regulations and initiatives to reduce methane emissions.
After consideration of the comments, ECCC made several modifications to the Regulations, including changing test methods, clarifying exemptions for upstream oil and gas facilities, adding an additional exemption for small bulk plants where emissions risks are low, removing some inspections that did not contribute significantly to emissions performance, and broadening allowable options for emissions control technology. These changes are not expected to significantly affect the achievement of the Regulations’ health and environmental objectives.
Implementation
ECCC will analyze the decrease in VOC emissions brought about by the Regulations and determine if there is variation from expected results. ECCC will also enforce the Regulations to ensure that the requirements are implemented.
ECCC will measure outcomes to determine if the Regulations are achieving the intended effects. Progress and results of the measures will be provided to Canadians in a variety of ways, including:
- Canadian Environmental Protection Act, 1999 Annual Report
- departmental performance reports
- federal or departmental sustainable development strategies
- internal and external publications, mail-outs, and websites