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Quebec's strategy for managing ozone-depleting substances and their replacement products

2. Problem overview

2. Problem overview

The stratospheric ozone layer: a natural atmospheric shield

The natural ozone layer is found in the stratosphere at an altitude of 10 to 50 km; the maximum concentration is reached at an altitude of 20 to 23 km. If all of the ozone found in the stratosphere were concentrated, it would occupy a space approximately 3 mm thick around the Earth. However, this small concentration of ozone is enough to filter out the ultraviolet rays that are detrimental to the plant kingdom and living beings on Earth. Indeed, the ozone layer serves as a sunscreen. Of the in-coming radiation penetrating the atmosphere, only low-energy ultraviolet radiation reaches the Earth’s surface. This remnant can be used and easily assimilated by living beings. Without the natural atmospheric shield, life on Earth would be difficult, if not impossible.

The alteration of the integrity of the ozone layer by halogenated substances, such as CFCs, halons and HCFCs, which have made their way up to the stratosphere, has serious consequences for the balance of terrestrial ecosystems, vegetation and the health of living beings. The number of cases of skin cancer in environments where ultraviolet radiation is intense has grown significantly. Already, the World Health Organization (WHO) has noted over the last fifteen years a rise in the skin cancer rate in northern countries. It is estimated that a 1 % decline in the quantity of stratospheric ozone corresponds to a 2 % increase in the incidence of non-melanomic skin cancer (NMSC). The immune system is also affected by ultraviolet radiation, which undermines the natural defences of living organisms. This radiation inhibits the mechanisms involved in the immune system process. In humans and animals, intense UV radiation affects eye health by promoting the appearance of cataracts. The deterioration of the ozone layer also has consequences for agriculture. The yield of certain plant species (cultivated oats, cucumbers, peppers and canola) may be reduced when the lighting has a high UV ray concentration. According to several scientists, there has been a decline in the populations of some aquatic species (shrimp and crab larvae as well as young fish) due to the deeper penetration of ultraviolet radiation. Indeed, because UV rays are being filtered out less, they have much more energy when they reach the Earth’s surface and the oceans.


State of the ozone layer

The depletion of the ozone layer is a global problem that extends beyond Québec’s borders. However, we are not immune to the medium- and long-term consequences. The condition of the ozone layer above Canada, and hence above Québec, can be evaluated with the help of the National Set of Environmental Indicators that Environment Canada publishes each year. The most recent indicators date back to 1997. In the spring of 1997, the ozone concentration in the stratosphere above Canada fell by 10.4 % in relation to the 1993 level. During the first six months of 1997, the total ozone concentration above Canada followed the downward trend of the last fifteen years. Since 1979, the general decline in the stratospheric ozone concentration has been from 4 to 6 % per decade at mid latitudes and from 10 to 12 % at higher latitudes. Since 1980, there has been a long-term downward trend in worldwide stratospheric ozone concentrations. Based on Environment Canada data, the stratospheric ozone above Montréal diminished by 4.1 % in 1996 and by 5.0 % during the first six months of 1997. Finally, following an analysis of data collected in Toronto since 1986, authorities have found that the ultraviolet radiation at 300 nanometres (nm) tends to increase by 1 % per year. This finding might be explained by a reduction in the stratospheric ozone, leading to a greater concentration of UVBs (290 to 315 nm), to the detriment of UVAs (315 to 400 nm), which are less harmful to life on Earth. It is imperative that we continue to take measures to reduce the chlorine load in the stratosphere.

World atmospheric concentrations of CFC-11 and CFC-12 have risen since 1977. However, their rate of increase has declined since 1989, reflecting the positive effects of the Montréal Protocol and its amendments. Atmospheric concentrations of CFCs were expected to peak in 2000 and to decline irreversibly thereafter. The replenishment of the ozone layer could be achieved by around 2050 if all signatories implement all amendments made to the protocol. It is important to pursue the measures to control these substances and to plan for their eventual destruction.


Halocarbon alternatives: an emerging concern

The implementation of the provisions of the Montréal Protocol in developed countries has resulted in a drastic reduction in the use of CFCs and halons in commercial and industrial applications. Initially, these applications use substances such as HCFCs as alternatives. HCFCs are transitional substances whose use must be discontinued progressively between now and 2020, as they have an ozone-depletion potential, albeit lower than that of CFCs. World ODS producers are currently focusing their efforts on the search for and the development of new substances that might eventually replace HCFCs and all ODS in general. Already, hydrofluorocarbons (HFCs) and perfluorocarbons (PFCs) are being used to replace ODS in industrial and commercial applications. HFCs and PFCs are chemical compounds which, like CFCs and HCFCs, fall under the name of "halocarbons". They will come into growing use over the next 25 years. Based on preliminary data from Environment Canada, annual HFC imports to Canada rose from approximately 3000 to 5000 tonnes between 1996 and 1998. HFC-134a accounts for the lion’s share of HFC imports. This trend is already well underway.

The elimination of ODS and their replacement represent an answer to the ozone depletion problem, but place added pressure on another major environmental issue, climate changes. In some cases, the replacement of ODS by halocarbons means replacing a greenhouse gas by another one that is even more powerful (see Tables 1 and 2). This aspect is not addressed in Québec at the present time. Indeed, the regulation in effect in Québec does not take into account an eventual contribution to the amplification of the natural greenhouse effect resulting from the increased use of halocarbon alternatives such as HFCs and PFCs. The European Environmental Agency (EEA)1 maintains that ODS (CFCs, HCFCs and halons) are responsible for an approximate 10 % amplification of the natural greenhouse effect on a global scale. According to estimates based on Canadian consumption, the contribution of Québec’s ODS consumption is equivalent to approximately 10 % of Québec’s total man-made greenhouse gas emissions in equivalent CO2, if the entire consumption were in the atmosphere2.

Table 1 - ODS are GHGs

Table 1 - ODS are GHGs
CFC/HCFC Ozone-depleting potential (ODP) Global warming potential (GWP)
CFC-11 1 4000
CFC-12 1 8500
CFC-113 0.82 5000
CFC-114 1 9300
CFC-115 0.6 9300
CFC-500 0.74 6310
CFC-502 0.33 5590
CFC-503 0.6 11860
HCFC-22 0.055 1700
HCFC-123 0.02 93
HCFC-124 0.022 480
HCFC-141b 0.11 630
HCFC-142b 0.065 2000

Source: UNEP

Table 2 - Halocarbon alternatives are GHGs

Halocarbon alternatives are GHGs
(PFC and HFC)
Ozone-depleting potential (ODP) Global warming potential (GWP)
trifluoromethane 0 9000
heptafluoropropane 0 2050
perfluorobutane 0 5500
HFC-236fa 0 6300
Halon 1211 3 0
Halon 1301 10 5600
HFC-134a 0 1300

Source: UNEP

The integration of the two problems is inevitable. In dealing with the problem of the depletion of stratospheric ozone by using HFCs and PFCs, there is a potential risk of amplifying the natural greenhouse effect if no control is exercised over the management of substances. There will be a major increase in replacement products in the years to come. HFC and PFC users do not differ from ODS and replacement product users. That is why it is important to establish, right away, guidelines to evaluate the relevance of employing such substances and determining if their use should be allowed or prohibited. When choosing among the various alternatives available, society should refrain from using greenhouse gases as replacement products when non-greenhouse gases are available. Québec’s new strategy must center on an integrated approach.


Assessment of Québec measures to protect the ozone layer

Québec has joined the world effort to protect the ozone layer. In June 1993, the government passed the Regulation respecting ozone-depleting substances. Through this regulation, the Ministry has obtained, among other things, statistics on annual CFC, HCFC and halon sales made in Québec since 1993.

Assessment of CFC, HCFC and halon sales3

The assessment for 1993 to 1996, the four years for which all data have been compiled, is now known. Total CFC sales fell by 94.5 % during the period in question. More specifically, total sales of CFC-11, 12 and 502, the three most widely used CFCs in Québec, dropped from 644.2, 861.5 and 240.5 tonnes respectively to 1.4, 498.1 and 31.0 tonnes. As for halons, total sales declined by 82.2 % during the same period. Total sales of Halon 1301 went from 3.8 tonnes to 0.2 tonnes. However, Halon 1211 is an exception given that its sales rose from 0.15 to 0.5 tonnes. This is partly due to the fact that Halon 1211 is used in portable fire extinguishers which still can be refilled in Québec. As for total sales of HCFCs, they increased by 36 % during the period under consideration. For example, total sales of HCFC-141b rose from 104.6 to 722.3 tonnes, whereas those of HCFC-22 remained stable at about 1000 tonnes per year from 1993 to 1996 inclusively. The following illustrations show the sales pattern for CFCs, HCFCs and halon from 1993 to 1996.

Illustration 1 - Sales pattern for halons

Illustration 1 - Sales pattern for halons

Illustration 2 - Sales Pattern for CFC and HCFC

Illustration 2 - Sales Pattern for CFC and HCFC

Source: QUÉBEC, MINISTÈRE DE L’ENVIRONNEMENT, 1998. Analyse et bilan des ventes au Québec de substances appauvrissant la couche d’ozone (ODS) de 1993 à 1996, Québec, Ministère de l’Environnement, December.

Assessment of regulatory actions4

The compiled data provide a precise portrait of the scope of the conversion of Québec’s industry to replacement substances, such as HCFCs or HFCs.

ODS have been a new field of intervention for the Ministry since 1993. Indeed, in June 1993, Québec adopted the Regulation respecting ozone-depleting substances. It covers eight CFCs (CFC-11, 12, 113, 114, 115, 500, 502 and 503), five HCFCs (HCFC-22, 123, 124, 141b and 142b), three halons (Halon 1211, 1301 and 2402), tetrachloromethane and methylchloroform. Let us begin by reiterating the main requirements of the Regulation respecting ozone-depleting substances. An initial requirement concerns the recovery and recycling of CFCs, HCFCs and halons when work is done on equipment containing these substances. A second requirement compels CFC, HCFC and halon distributors and wholesalers to submit a report on their annual sales to the Ministry. A third requirement prohibits the use of CFCs in plastic foams and aerosols. Finally, the regulation has banned, since June 1998, the use of CFCs or HCFCs in sterilizing gases.

An assessment of regulatory actions with respect to ozone-depleting substances was made for the period from 1994 to 1996. This three-year period allows us to identify the effectiveness of the control operations ensuing from this regulation. Here are the main observations made on the basis of the factual data provided by the regional offices. First of all, the rate of non-compliance with the regulation is 20 %, which is very good and even above-average for the first few years of application of a new regulation, particularly given the fact that the clientele is made up of approximately 2000 business firms. Only 5 % of the clientele contravened the regulation by reason of the absence of CFC or HCFC recovery and recycling equipment when refrigeration or air conditioning work was carried out. Moreover, Ministry inspectors carried out the first systematic inspection program in half the time anticipated.

In light of these data, we can say that the various clienteles subject to this regulation have accepted it and are happy to comply with it. Québec stakeholders seem to have understood the relevance of such an intervention tool and the need to protect the ozone layer.


Identification of shortcomings in Québec’s current commitment

Despite the undeniable success of the application of the Regulation respecting ozone-depleting substances and the growing conversion of Québec’s industry to replacement substances such as HCFCs and HFCs, certain shortcomings persist and are increasingly being underscored by Québec stakeholders. We will describe a few of the most important shortcomings.

The level of control over ODS is inadequate. The sale and use of these substances take place in the absence of an administrative or regulatory framework. We do not know who purchases these substances and for what purpose. Moreover, a black market for CFCs destined for the United States has developed in Canada, and Montréal seems to be a crossroads for this illegal trade. Better control over the flow of these substances and their use is required.

Workers using ODS, such as refrigeration technicians, automobile mechanics and fire protection mechanics, have received little or no training on the environmental impacts associated with the practice of their trade. All provinces, with the exception of Québec, have already put in place an environmental certification system allowing them to see to it that ODS are used, collected and recycled adequately to ensure respect for the environment. Awareness promotion activities intended for business firms and pertaining to the use and management of ODS stocks is a low priority activity in Québec. ODS may be used by persons who have the appropriate technical qualifications but who are unaware of the detrimental impacts that these substances may have on the environment.

The domestic sector of ODS use is not covered by Québec’s regulation, the scope of which is limited to the commercial and industrial sectors. It is illogical and unfair that the domestic sector should not be called upon to do its share to protect the ozone layer. This sector involves a multitude of small domestic refrigeration and freezer units containing small quantities of refrigerant (a few hundred grams). For the most part, the sector is made up of small family-run businesses having few employees. The craft and know-how are often handed down from generation to generation. It is imperative to make the labour force of this sector aware of the environmental considerations involved.

At the present time, Québec shows little concern for planning as it relates to existing ODS stocks that eventually will have to be eliminated. Authorities do not know the location of ODS storage sites or the quantities that will have to be destroyed. Some people claim that the Ministry’s decision to place emphasis on the recovery of ODS in 1993 has only prolonged their use and has contributed to their ultimate release in the atmosphere due to the leaks inherent to their use. Québec’s future strategy needs to provide clear indications as to whether stakeholders must stop or continue recovering ODS and, in particular, CFCs and halons. The Ministry will also have to choose, in cooperation with the federal government, a technology for destroying these substances.

Québec’s current approach does not address the management of replacement substances (HFCs and PFCs) employed by ODS users. The use of these substances will continue to grow over the next few decades as will their contribution to the amplification of the natural greenhouse effect. The depletion of the ozone layer and climate changes are two interrelated global problems. These are the main shortcomings of Québec’s interventions to ensure an effective protection of the ozone layer.

Québec firms are at somewhat of a disadvantage vis-à-vis their Canadian and international counterparts as Québec firms have no incentive to abandon technologies that employ ODS. This situation is attributable to the lack of a framework and orientation in Québec regarding the use of ODS. This absence is unjustifiable given that Québec is the second largest Canadian consumer and user of ODS after Ontario (see illustration 3). In summary, in matters pertaining to the protection of the ozone layer, Québec needs to catch up in relation to the amendments made to the Montréal Protocol and the initiatives of its Canadian partners. Already in 1993, its regulation lagged behind in certain regards, and this gap has grown over the years. Today, it is essential that Québec endeavor to attain a greater degree of harmonization with industrialized countries or, at the very least, with the other Canadian provinces when it comes to the protection of the ozone layer.

Illustration 3 - National Inventory of CFC & HCFC Installations in Canada (1994)

Illustration 3 - National Inventory of CFC & HCFC Installations in Canada (1994)

Source: Environment Canada

1 Climate Change in the European Union, EEA, 1996.
2 QUÉBEC, MINISTÈRE DE L’ENVIRONNEMENT ET MINISTÈRE DES RESSOURCES NATURELLES, 1995. Plan d’action québécois de mise en œuvre de la Convention-cadre des Nations Unies sur les changements climatiques (version détaillée corrigée), Québec, ministère de l’Environnement et ministère des Ressources naturelles, July.
3 QUÉBEC, MINISTÈRE DE L’ENVIRONNEMENT, 1998. Analyse et bilan des ventes au Québec de substances appauvrissant la couche d’ozone (ODS) de 1993 à 1996, Québec, Ministère de l’Environnement, December.
4 QUÉBEC, MINISTÈRE DE L’ENVIRONNEMENT, 1998. Bilan d’application du Règlement sur les substances appauvrisant la couche d’ozone, Québec, Ministère de l’Environnement.

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