The photographic imaging sector provides a service to local residents and businesses. As part of the normal operation of a photographic imaging operation, liquid and solid wastes are generated. Generating waste products is not necessarily an environmental issue. However, how we manage the waste can have significant impact on our natural resources, public and private infrastructure, and human and environmental health associated with stormwater, wastewater and septic systems. The following resources are specific to the photographic imaging sector.

Common Regulations and BMP for stormwater, wastewater and septic systems use

Waste generators are required to comply with all federal, provincial, municipal and regional regulations for proper waste disposal.

Under the Provincial Environmental Management Act and the Federal Fisheries Act, a waste generator may be held liable for any contamination or harm created as a result of the deposition or discharge of that waste. Proper disposal and management of wastes significantly reduces risks of environmental contamination and the requirement for remediation.

Proper storage, inventory of products and wastes, spills response plans and employee education on managing photographic imaging wastes are important factors in keeping our receiving waters clean.

Requirements and BMP specific to sanitary sewer

All industrial, commercial or institutional facilities that discharge non-domestic wastewater to the sanitary sewer system operated by the CRD must follow the requirements of CRD Bylaw 2922 - Sewer Use Bylaw. The photographic imaging sector, as with many other sectors, have specific requirements under a code of practice within the Sewer Use Bylaw.

Code of Practice for Photographic Imaging Operations prescribes the requirements and conditions for preventing or limiting the discharge of prohibited and restricted wastes into the sanitary sewer system.

The following is a summary of the key requirements under the Bylaw and Code of Practice (Schedule "K").

Regulations prohibit photographic imaging facilities from:

  • Discharging of waste which has in excess of 5 milligrams per litre of silver
  • Discharging prohibited waste into the sewer system
  • Discharging wastewater which contain restricted wastes such as:
    • iron, solvents and chloride
    • BOD and COD

Photographic imaging operators must also:

  • Install silver recovery technology
  • Perform inspections and maintenance of treatment works
  • Create a spill response plan
  • Keep written records of treatment works maintenance 

Please submit a Waste Discharge Assessment Form if you are unsure whether this code of practice applies to your business.

Although compliance with Sewer Use Bylaw may help you meet other municipal, provincial or federal conditions, other agencies may have additional requirements. Use BizPaL to help you identify additional permits and licenses required to operate your business.

Requirements and BMP specific to septic system

Wastewater pre-treatment is not specifically required under CRD Bylaw 3479 - Onsite Sewage System Maintenance Bylaw. However, photographic waste should not be discharged to a septic system as this can create a contaminated site. At minimum, the discharge of photographic waste can impact the treatment process, significantly increase maintenance costs of the septic system and reduce its useful life span.

Requirements and BMP specific to stormdrains and catch basins

Prevent stormwater contamination and protect our aquatic environment by ensuring that photographic imaging waste does not enter the storm drain network (which includes ditches, catch basins and roadways, etc.).

  • Educate staff about the spill prevention and response
  • When hosing or washing equipment or surfaces outside, do not let the runoff water enter the storm drain
  • Regularly inspect and maintain any parking lot catch basins
  • Store waste products under covered areas with appropriate spill containment

If you operate on the Saanich Peninsula (North Saanich, Central Saanich and Sidney) then you need to know about Bylaw 4168 requirements.

Requirements and BMP specific to trucked liquid wastes

Liquid waste haulers can be hired to responsibly manage any fluids associated with photographic imaging.

It is important to note that the waste generator retains ownership of the waste even after it has been turned over to a waste hauler. This means the generator can be held responsible for the consequences of a spill or improper disposal of waste.

For that reason it is important to ensure that the hauler you hire can demonstrate that they are:

  • Properly licensed;
  • Have properly trained staff and;
  • Will deal with your waste in a safe, responsible, legal and diligent manner.

Why wastes from photographic imaging operation are a concern in our stormwater, wastewater and septic systems

Studies from other jurisdictions show that silver from photo processors contributes significantly to the total silver loading in municipal wastewater. Through leaks in damaged sewer laterals, silver accumulations in soils may, over time, exceed levels specified under provincial contaminated site regulations.

Free silver ions are very toxic to aquatic organisms. Although photographic imaging industries have significantly reduced the amount of process chemicals being discharged to sanitary sewers over the past 20 years, silver recovery remains and important step in waste reduction programs, in order to conserve a valuable and non-renewable resource and to control silver presence in wastewater.

Some photographic imaging wastes are also corrosive and may contribute to leaks in sewer pipes if not properly managed.

What is considered a photographic imaging operations

Photographic imaging operations include any retail, commercial, institutional or corporate photographic film processing or printing facility that uses silver to develop film. Examples of facilities include:

  • Mini-labs, professional and commercial photo processors, portrait and commercial studios
  • Commercial printers, publishers and newspapers
  • Law enforcement photo imaging
  • Photo imaging at schools and military facilities
  • Public and private laboratories, including medical, dental and vet offices

With the advent of digital photography, many of these processes have become more specialized, however they are still in existence throughout the region. Film photography, common in x-ray use, is still used by a portion of the population.