7/24/20
Biosolids Management in Quebec

In the big picture and for many years now, the province of Quebec has been more committed to recycling organics than anywhere in New England.  Quebec employs a significant tax on each ton of biosolids or other organic waste going to landfill, and they use those tax monies to support things like anaerobic digestion and composting.  Quebec also has an enviable program for independent, third party analysis/certification of biosolids and residuals products. 

Quebec recently proposed revisions to a large number of environmental regulations, including new standards impacting biosolids and residuals.  The comment period has closed and the environmental Ministry (Ministère de l’Environnement et de la Lutte contre les Changements Climatique, or MELCC) is reviewing and analyzing the public comments received several months ago now.  The new regulations are expected to be promulgated by the end of the year. 

The proposed new regulations tighten some management requirements that may discourage recycling of biosolids. Specific detailed changes include tightening field stockpiling setbacks and restrictions (e.g. flood-plain restrictions even during dry weather), record-keeping, and other compliance requirements.  These new restrictions are not applied to manures, which have been treated equitably in the past because they share the same nutrient control issues.  There are also large, over-arching regulatory structure and policy changes that could trickle down and affect the residuals recycling regulations. 

Marc Hébert, former biosolids coordinator for the Ministry and now a consultant, was concerned about the proposed regulations when they came out last winter.   But, in May, he noted that key stakeholders were providing comments and working with the Ministry to address problems in the proposed regulations.  One good sign is that the Ministry and RECYC-QUÉBEC (quasi-governmental recycling support organization) have published statistics and statements and measures about biosolids and residuals recycling that are positive and supportive.  Also there is a much-anticipated report coming soon from the Ministry setting forth an organics management strategy that will clarify the Ministry’s position on recycling biosolids.  Of course, as elsewhere, the COVID situation has slowed down regulation development.  With our members’ help, NEBRA will continue to monitor this significant regulatory effort.

There may be opportunities for U.S. biosolids management firms looking to export biosolids/residuals to Quebec for beneficial reuse during times of restricted options in the states (like COVID impacts on landfill capacity or if a large regional incinerator goes down for repairs).  Although COVID may have made things a little more complicated, the U.S./Canadian border remains open to commercial trucks.  Disposal outlets are considered essential services and continue to operate as usual for the most part.   However, like in the U.S., public perception of land application of biosolids has turned to whether or not the biosolids
contain the SARS-CoV-2 virus, especially if being imported from U.S. COVID hotspots like New York and Massachusetts.  Concord, New Hampshire biosolids are now being transported to Quebec because of concerns about low PFAS water and groundwater standards being adopted by the New Hampshire Department of Environmental Services.

U.S. companies would do well to understand the regulations in Quebec or work with a company that does. Third party accreditation is important for land-applied biosolids.  Federal regulations apply as well and require biosolids test negative for salmonella and contain less than 1,000 fecal coliforms, which eliminates Class B materials from being land applied in Quebec.  The end-use regulations are less stringent for biosolids/residuals if they have been composted. 

NEBRA has some members doing great work recycling biosolids and residuals in Quebec.  This includes Englobe, which has been taking some U.S. biosolids to composting and to use in revegetating a former asbestos mine (see https://www.nebiosolids.org/member-highlights#/englobe-reclamation-at-asbestos/) and similar projects. 

Marc Hébert is also a NEBRA member and is a huge proponent of beneficial reuse of biosolids.  His regular monthly newsletters (en français) are always full of facts and timely information related to biosolids/residuals recycling.  For more information, visit http://marchebert.ca/.