Fenceline Monitoring

Environment and Climate Change Canada has proposed the Regulations Respecting Reduction in the Release of Volatile Organic Compounds (Petroleum Sector) with a fenceline monitoring component, similar to the fenceline monitoring programs currently in place for the Ontario Technical Standards to Manage Air Pollution.

On May 27, 2017, Environment and Climate Change Canada published the proposed Regulations Respecting Reduction in the Release of Volatile Organic Compounds (Petroleum Sector) in the Canada Gazette, Part I, for a 60-day public comment period. As per Section 17 of the proposed regulation, affected facilities are required to establish a Fenceline Monitoring Plan within 6 months of its in-force date. It is anticipated that the regulation may be promulgated in July 2019.

Fenceline Monitoring Plan Specifications

Under the proposed regulation, a Fenceline Monitoring Plan must be submitted to the Minister 3 months prior to commencing the monitoring program. The parameters of interest will include benzene, 1,3 butadiene and the total concentration of all retainable VOCs. The proposed regulation refers to USEPA Method 325A Volatile Organic Compounds from Fugitive and Area Sources: Sampler Deployment and VOC Sample Collection and USEPA Method 325B Volatile Organic Compounds from Fugitive and Area Sources: Sampler Preparation and Analysis for direction and management of the Fenceline Monitoring plan. Facilities will be required to install, at minimum, 12 sampling monitoring stations around the perimeter of the facility. The monitoring stations hold passive sorbent sampling tubes that sample over a two week (14 day) period. At the conclusion of a sampling period, the tubes are replaced and then submitted to a laboratory to be analysed by TD-GCMS. The proposed regulation also mandates annual reporting requirements.

Anticipated Timeline

Based on the regulation as it is currently proposed and a possible promulgation timeframe of July 2019, the following are estimated dates that Fenceline Monitoring Plan administrators need to be aware of:

 April 30, 2020
 Fenceline Monitoring Plan submission to the Minister
 July 1, 2020  Commencement of the Fenceline Monitoring Sampling
 April 30, 2021  Submission of a Fenceline Monitoring Report for the period of July 1,
 2020 to December 31, 2020
 June 30, 2022  Submission of the first annual Fenceline Monitoring Report
 June 30, 2023  Annual submissions of the Fenceline Monitoring Report begin

How Can LEHDER Help?

LEHDER has significant experience gained through the implementation of Ambient Monitoring requirements in accordance with the Petroleum Refinery Industry Standard and Petrochemical Industry Standard issued by the Ontario Ministry of Environment, Conservation and Parks (MECP).   Our services include:

  • Collaboration with facility personnel to develop a site specific Property Line Monitoring Plan requirements to meet the regulation.
  • Preparation and Submission of the detailed Property Line Monitoring Plan.
  • Determination of appropriate siting of monitor locations and install monitoring stations.
  • Installation and removal of passive sample tubes for the two week sampling periods.
  • Compilation of applicable weather information data (temperature, pressure and wind speed).
  • Liaison with the laboratory for delivery of sampling media and sample submissions.
  • Data analysis.
  • Preparation of compliance grade summary reports.


For additional information, please contact:

Peter Pakalnis (519) 336-4101, Ext. 227 pakalnis@lehder.com

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