Standards for Hazardous Material Storage
The draft Regulation under the Environment Quality Act proposes several amendments to improve the regulatory framework governing activities based on their environmental impact. The amendments aim to reduce administrative burdens and improve efficiency for applicants, particularly where professional services are used to prepare projects or applications. Specifically, the draft Regulation modifies the information requirements for authorization applications, limiting the details needed to identify professionals involved in project preparation. It also extends certain provisions of the Environment Quality Act to the renewal of authorizations, clarifying the information and documents that must be provided and the factors the Minister can consider when assessing environmental impacts.
The draft introduces new declarations of compliance and authorization exemptions for certain agricultural operations. These include systems used to wash fruit or vegetables on raising or spreading sites. Three new exemptions specify conditions under which such systems may operate without ministerial authorization. For example, washing cucurbitacea on large sites or certain fruits on smaller sites can qualify for simplified declarations of compliance, provided wastewater is properly managed and does not directly enter water bodies or wetlands. Additional exemptions cover systems with minimal wastewater discharge or those discharging entirely on soil that is neither frozen nor snow-covered. Transitional provisions ensure that systems operating since September 2, 2020, may continue under existing practices until December 31, 2030, provided they meet specified conditions, including unchanged processes, equipment, and operational areas unless environmental improvements are made.
Adjustments are also proposed for the storage of hazardous residual materials, with new thresholds established for lithium batteries from electric vehicles, capping storage at 100,000 kilograms, while other hazardous materials are limited to 40,000 kilograms. This modification reflects the need to address specific risks associated with high-volume, high-risk materials. Similarly, a new declaration of compliance and authorization exemption is proposed for the storage of treated wood outside wholesale or retail establishments. These provisions define allowable volumes, required protections from the elements, distance from water sources, and the handling of runoff to mitigate environmental risks. Temporary storage of additional recovered wood is permitted under strict conditions, ensuring that small-scale storage does not pose environmental hazards.
The proposed amendments are expected to generate substantial cost savings. Annual savings are estimated at $0.3 million, primarily through reduced requirements for ministerial authorization, while one-time savings could reach approximately $5.3 million by improving project approvals and limiting regulatory obligations. Overall, the draft Regulation seeks to balance environmental protection with administrative efficiency, facilitating compliance for operators while maintaining safeguards for soil, water, and surrounding ecosystems.
Quebec (Draft) November 19, 2025
Disclaimer: Insights are for informational purposes only and does not reflect RRI’s official position or constitute legal opinion.
