Guidelines to Reduce Dyes from Pulp Mills

Summary#

The federal government published final Guidelines for the Reduction of Dyes Released from Pulp and Paper Mills (2024) under the Canadian Environmental Protection Act, 1999. The Guidelines set targets and good practices for how mills should retain, treat, store and report the release of certain basic (cationic) dyes. The Minister signed the Guidelines on March 16, 2024 and the notice appeared in the Canada Gazette on April 6, 2024.

What it does#

• Sets retention targets for dyes in finished paper:
  • MAPBAP acetate: 90% minimum retention.
  • Malachite Green, Basic Violet 3 (BV3), Basic Violet 4 (BV4), Basic Blue 7 (BB7): 95% minimum retention.
• Sets a solids-removal benchmark for primary wastewater treatment: 75% solids removal for all listed dyes (so dye that sticks to solids is removed with them).
• Requires a containment plan for dye storage and handling:
  • Secondary containment sized at 110% of the tank if there is only one tank; or 100% of the largest tank plus 10% of the total capacity of the other tanks.
  • Steps to collect or recirculate dye before purging equipment to avoid releases to water.
• Requires mills (operators) to notify the Minister about their intent to implement the Guidelines:
  • For MAPBAP acetate: within six months after first use.
  • For the other dyes: within six months after the Guidelines’ final publication or within six months after first use.
• Monitoring, reporting and record-keeping:
  • Annual checks to confirm conformity and to record any incidental releases.
  • A conformity report is required three years after final publication for MG, BV3, BV4 and BB7; after that, annual reports only if standards were not met or incidental releases occurred. (No initial three‑year reporting requirement for MAPBAP acetate.)
  • Keep test results and related records for at least five years.
• Notes the Guidelines are complementary to the Pulp and Paper Effluent Regulations (PPER) under the Fisheries Act and recommends regulators use these Guidelines as baseline standards, while allowing for stricter local rules.

Who's affected#

• Primarily pulp and paper mills that use any of these dyes: MAPBAP acetate, Malachite Green, Basic Violet 3 (BV3), Basic Violet 4 (BV4), Basic Blue 7 (BB7).
• Mill operators and plant managers who buy, store, handle or treat dyes and mill wastewater.
• Suppliers of paper additives and dyes, because mills may change purchases to meet retention targets.
• Provincial or federal regulators and permitting authorities, who may adopt the Guidelines into permits or local requirements.
• It is unclear from the notice whether the Guidelines will automatically become enforceable rules or will only be used as recommended standards by regulators.

Why it matters#

• The Guidelines aim to reduce coloured dye pollution in waterways by pushing mills to keep more dye in the paper and out of wastewater. That can improve water clarity and reduce potential ecological and aesthetic impacts of coloured effluent.
• Mills may need to change practices, buy different supplies, update storage and containment, or add monitoring and reporting — which can mean new costs or operational changes.
• Regulators can use the Guidelines when setting permit conditions. That could make the expectations binding in specific permits even though the Guidelines themselves are not automatically a regulation.
• For nearby communities and downstream water users, the Guidelines could mean less visible dye in local waters and fewer accidental releases from storage or handling.