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Legal Notes: CRD regulatory absence leaves Canada’s waste in a vacuum

John Bleasby
Legal Notes: CRD regulatory absence leaves Canada’s waste in a vacuum

The mountain of waste created through construction, renovation and demolition (CRD) continues to rise at landfill sites across Canada. Unlike plastic and paper, the issue of CRD waste continues to elude meaningful federal or provincial regulation to redirect, repurpose or recycle.

“CRD waste has been relatively untouched by regulation in either its generation or its disposal,” Jonathan Cocker, a partner with Borden Ladner Gervais in Toronto, wrote back in 2019.

The situation remains unchanged in late 2022. Furthermore, Cocker says it’s a topic often overlooked in conversations of green building and sustainable growth here in Canada.

There should be no reason for Canada or the provinces to keep CRD waste on the back burner. As Cocker pointed out at the time, the Canadian Council of Ministers of the Environment (CCME) produced a 150-page report in 2019 after a three-year consultation and policy development process. It was brimming with policy options that provinces and territories could adopt.

Cocker described the report’s objective as an effort “to return CRD waste to the policy forefront with a much broader and more robust set of policy requirements to reduce and improve the recovery of CRD waste.”

All that is seen of the CCME report today are references in various footnotes and citations, not a part of any substantive discussion, says Cocker. That’s possibly attributable to delays caused by the COVID pandemic and matters related to energy transition that have taken priority.

“The opportunity for the construction industry to develop ways to capture value from CRD waste, while meeting a regulated standard to recycle their waste remains to be implemented,” he recently told the Daily Commercial News.

Tackling construction waste need not be achieved solely by regulations but through better informed design, notably by giving more consideration to reuse and repurposing instead of simple end-of-life demolition. This would reduce significant amounts of carbon associated with new projects by minimizing new material production and transportation.

In fact, CRD waste is an issue in other countries too. The UK Green Building Council says initiatives to better measure carbon savings through material reuse are inconsistent. Other reports from Europe suggest current efforts run in conflict with modern construction techniques.

Many designers fail to fully consider material reuse in their designs today, if at all, according to industry experts in the U.K.

It’s particularly evident in composite components that are glued together, or when regulations for high energy efficiency dictate assembly processes that defy disassembly.  

It’s led Howard Button, chief executive of the U.K.’s National Federation of Demolition Contractors, to comment that modern construction composites are “nowhere near as recoverable as traditional materials.”

In response, an industry initiative called Facilitating the Circulation of Reclaimed Building Elements aims to increase the use of reclaimed building elements across north-western Europe to 50 per cent from the current 1.0 per cent.

In his 2021 thesis presented to Ryerson University, Haley Andersen writes that CRD waste is a 60/40 mix between residential and non-residential. Furthermore, 40 per cent of landfill waste is wood, nearly 75 per cent of which is “clean” or engineered wood that is untreated or unpainted.

In another academic paper detailing Vancouver’s approach to CRD, Nicholas Lynch of the Faculty of Humanities and Social Science at Memorial University of Newfoundland, addresses the matter of entrenched industry practice.

“Deconstruction remains a relatively marginal practice in the CRD sectors across North America, especially as traditional demolition continues to offer rapid cost-effective removal of the built environment.”

It needn’t be that way. Cocker points to the City of Victoria’s 2021 report titled “Zero Waste Victoria” that attempts to encourage architects, builders and developers to support greener construction waste policies.

The Ontario Ministry of the Environment, Conservation and Parks did not respond to requests outlining its position regarding either the CCME report specifically or CRD in general. However, Cocker is hopeful that once Ontario completes its framework covering curbside plastics programs, regulators will next turn their attention to tackling the province’s CRD waste.

John Bleasby is a Coldwater, Ont.-based freelance writer. Send comments and Legal Notes column ideas to

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