Practice is Sticking

April 9, 2007

Remember in school when you were taught in civics class on how a bill becomes a law? And then, later, you learned, just as you did about Santa Claus, that the truth is a bit different. Your sophisticated upper-grade teachers cynically equated making laws to making sausage, advising you to enjoy the end product but ignore the repulsive production process.

This account of a national effort to improve Canadian road salt management, I hope, will restore some of your faith in democracy. Caution: There’s still an element of sausage-making, but, overall, it’s a savory experience.

Remember in school when you were taught in civics class on how a bill becomes a law? And then, later, you learned, just as you did about Santa Claus, that the truth is a bit different. Your sophisticated upper-grade teachers cynically equated making laws to making sausage, advising you to enjoy the end product but ignore the repulsive production process.

This account of a national effort to improve Canadian road salt management, I hope, will restore some of your faith in democracy. Caution: There’s still an element of sausage-making, but, overall, it’s a savory experience.

In the news

Like “good-news, bad-news” jokes, this story has two distinct parts. It was clearly a “bad-news” process in defining the problem using an environmental assessment, but an exciting “good-news” effort to overcome poor salt management with risk-reducing management guidelines.

The story really begins after World War II, when highway agencies began using salt on winter roadways throughout the North American snow belt to preserve safety and maintain commercial and personal mobility on wintertime highways. For about 25 years, as construction of the U.S. Interstate Highway System stimulated the use of deicing salt, users experimented in its use while the salt industry scrambled to build a logistics system to meet the burgeoning demand.

By the early 1970s, however, examples of over-application of deicing salt led to concerns about environmental damage. In 1972, the Salt Institute launched its Sensible Salting program to train salt users to use the minimum amount of its product to keep roads safe and passable. Uneven progress, but progress nonetheless, was evident. In 1991, the Transportation Research Board (TRB) completed a comprehensive look at the environmental consequences of using sodium chloride on U.S. highways. After calculating the damage inflicted by road salt and comparing it with damage caused by calcium magnesium acetate, a popular alternative, the report concluded that salt would remain the deicer of choice for the foreseeable future. Unforeseen was an effort commenced in Ottawa three short years later in spring 1995 that threatened to unravel the balanced TRB decision.

Talk is toxic

Why did Canada reject the validity of the TRB study? Consider: Canada’s federalism is more robust than its southern neighbor. Provinces relinquish regulatory jurisdiction only for significant national problems. Thus, the Canadian Environmental Protection Act (CEPA) provides that unless a substance is deemed “toxic,” federal bureaucrats have to keep their hands off its regulation—an obvious incentive for Ottawa regulators to declare everything “toxic.” As they say, “if you’re a hammer, everything looks like a nail.”

Environment Canada completed a round of “priority substance” assessments under CEPA that had been enacted in 1989 and, in 1995, was seeking a new list of targets for environmental assessment in “PSL2,” the second list of priority substances. A panel of experts first identified calcium chloride for assessment, but changed its mind when it thought that target too narrow. It opted, instead, for “road salts” which it defined as the four chloride salts used for roadway maintenance, specifically rejecting the counsel that the problem was already well studied and an assessment could lead to a political quagmire.

Undaunted, Environment Canada launched its own road salts environmental assessment. That tortured tale is now being examined by the Canadian Parliament as the best case study on how CEPA assessments might be improved based on the road salts experience.

Ultimately, Environment Canada catalogued the same environmental concerns identified in the TRB report, but its policy recommendation was exactly opposite. In December 2001, the Canadian Cabinet was asked to add the four chloride salts to CEPA Schedule 1, Canada’s list of toxic substances. This was bad news indeed for roadway agencies and businesses and individuals who depend on winter roadway access.

There had been minor squabbles over earlier toxic listings, but this recommendation ignited fierce resistance by local and provincial transport agencies, shippers and the Canada Safety Council. So incendiary was this recommendation that the Cabinet on at least three occasions blocked its adoption. The politicians realized that the public would never accept that a food eaten every day could be considered poisonous.

That’s the bad-news story: a controversial assessment and rejection of its primary recommendation.

It’s up to code

Fortunately for all parties, CEPA wisely divided responsibilities within Environment Canada among those who conducted the assessment and those charged with managing and reducing the identified risks.

The sanguinary struggle over the toxic listing concealed the broad consensus of salt producers and salt-using roadway agencies that careful management was the key ingredient in environmental stewardship. Fully two years before the Schedule 1 listing recommendation was issued, the Transportation Association of Canada (TAC) culminated a several-year project to codify best-road-salts management practices, publishing in 1999 a code of practice, updating the Salt Institute’s Sensible Salting recommendations. Thus, by the time the assessment phase was over, implementing risk management initiatives was already well under way.

That’s the reason the road salts story in Canada is a good-news story: more civics class than sausage factory. Skeptical Environment Canada bureaucrats charged with implementing risk-reducing changes found a very different multistakeholder group than they had ever faced before. Salt-using agencies already accepted the harmful potential of their practices and had self-organized efforts to improve their salt management.

Environment Canada assembled a large Road Salt Working Group, managed it expertly and relatively transparently with trained facilitators and produced its own code of practice on schedule and to universal accolades (with the possible exception of one environmental group that has argued for a toxic listing and federal regulations). The consensus outcome incorporated TAC’s 1999 best practices as an appendix and established a voluntary federal road salts code of practice with requirements for salt management plans for any agency using 500 tons or more of road salts with annual reports to track improvements. After two years, the enterprise is a huge success.

What’s right

Protecting the environment is always a popular stance and salt users are, by and large, agencies responsible to usually local elected officials. Talk is cheap, but, combined with the sensitivity of Environment Canada’s implementation effort, the natural proclivity of public agencies to “do right” has prevailed. Environment Canada estimated based on population size that 301 agencies outside of Quebec province would be required to adopt the code. Quebec has worked out a separate reporting system in that province, a province that has a quarter of Canada’s population and an even greater percentage of its salt usage. Gratifyingly, 265 agencies have notified Environment Canada of their intent to embrace the voluntary program and more than 200 actually filed the required annual report. Significantly, Ontario, the largest salt-using province, has greater participation than forecast.

This success did not just happen, however; it was the product of clear vision and hard work—and some significant investments in upgrading snow-fighting practices.

Early in the process, the stakeholders coalesced behind a strategy of emphasizing operator training as the top priority. Sure, buying ground-control automatic spreaders was important; covering storage piles, essential. But without the commitment of an educated work force, salt-limiting controls would be sabotaged and storage pile covering done sporadically. Training is relatively low-cost, quick and high-impact.

But Canada has no snow-fighter training infrastructure. With vocal and financial encouragement from the Salt Institute, both TAC and the Ontario Good Roads Association (OGRA) created new training materials to train operators and supervisors—and to train more trainers. The TAC training materials are available free online. OGRA alone has trained thousands of operators over the past three years. OGRA worked with the American Association of State Highway & Transportation Officials (AASHTO) to customize its computer-based training program with metric measures and local maps. The aim from the beginning was sustainability.

Looking specifically at progress in salt management is to appreciate the comprehensive scope of the undertaking, combined with the varying requirements due to weather, topography, population density and service requirements. Across Canada, more than four of every five agencies have salt management plans in place, including all larger cities. Fully 89% of the agencies have roofed storage facilities. While only one-third of the agencies use automated spreaders, again these are the larger fleets and account for a solid majority of the salt being applied. And 81% of the agencies calibrate their equipment at least annually.

The code of practice calls for salt management plans to conduct an environmental survey for salt-vulnerable areas, and one-third of the reporting agencies have already completed their inventories and half of those have implemented specific salt management practices to protect these sensitive areas. About a quarter of the agencies have, or will soon have, environmental monitoring programs.

Victories begin to mount in Canada

Beyond the ongoing agency implementation steps, Environment Canada continues to drive further improvements. Joint research by TAC and Environment Canada is trying to develop a winter severity index so that Environment Canada and individual agencies can assess whether their “salt savings” are due to improved management or a light winter. Discussions are under way on research to document that the new code of practice delivers safe roadways.

Will it work? We won’t have to guess. With the reporting system and increased monitoring, Environment Canada should be able to gain valuable insights. Supplementing the annual reports, Environment Canada plans a series of closely monitored research installations of recommended technologies and implementation of such practices as pre-wetting, anti-icing and RWIS-driven decision support systems.

While we won’t have to guess, we can predict. It will work. The key is the strong buy-in by the roadway agencies. For three decades, the Salt Institute had been promoting sensible salting and giving Excellence in Storage Awards to agencies with environmentally sound salt storage programs.

But the city of Toronto did not have automated spreaders. No Canadian agency was among the first 100 Excellence in Storage Award winners.

That’s history now. Toronto has a world-class snow-fighting and salt-management program and every year more and more Canadian agencies earn Excellence honors. Clearly, the prospect of a “toxic” listing has awakened Canadian roadway agencies and given them a powerful imperative to secure resources from their city councils and provincial legislatures.

The success was achieved because the parties—would-be regulators and those engaged in producing and using road salts—all hewed to the civics class model rather than the butcher’s sausage-making model. Rather than grind everything up and force the product into a confined casing, Environment Canada deserves kudos for its sensitive handling of a super-sensitive situation. And rather than lamenting that you have to break some eggs to make an omelet, Environment Canada displayed exemplary listening skills and embraced a balanced diet, prodding local agencies to set their own priorities and make the most cost-effective use of their taxpayer resources.

Together we have learned that there is nothing inevitably destructive about using highway salt; it all comes down to how you use it. When people of shared commitment act in good faith, there is no limit to the progress they can achieve.

About The Author: Hanneman is president of the Salt Institute.

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