In recognition of the compliance challenges many companies are
encountering during the COVID-19 pandemic, the federal Minister of
Environment and Climate Change Canada (the
"ECCC") has recently announced the
ECCC's intended approach during the crisis. While companies are
expected to continue to comply with all applicable laws and
regulations, and to operate in a manner that is safe and protects
human health and the environment, ECCC will exercise discretion and
take into account any challenges that regulated parties are facing
when considering enforcement action.
Expectation of Compliance
The announcement is clear that regulated companies are expected
to continue to comply with all environmental laws, regulations,
operating permits and approvals. This includes compliance with all
obligations to notify public authorities of an unauthorized release
of pollutants, particularly where such release may cause risk to
human health or the environment. At all times,