Owners and operators of facilities subject to Environment Canada’s National Pollutant Release Inventory (NPRI) must submit their 2016 reporting data to the ministry by June 1, 2017. Environment Canada requires affected facilities to submit data concerning the manufacture, processing, and otherwise use (MPO) of NPRI listed substances, and document any associated waste disposal and recycling activities, as well as perform detailed monitoring and analysis in order to quantify releases of listed substances to environmental media. Though NPRI reporting requirements can be a big challenge for businesses, having the right technology solutions in place can make compliance quick and easy.
Who is required to report?
If your facility manufactured, processed or otherwise used one or more NPRI listed substances in an amount that exceeds the substance’s reporting threshold, and the total number of man-hours worked at your facility within the calendar year exceeded 20,000, you are subject to NPRI reporting requirements. Calculation of your facility’s total worker hours must also account for temporary employees and contractors at your facility, as well as any paid time-off (PTO) received. Reporting threshold amounts are dependent upon which “threshold category” the individual substance is listed under (1A, 1B, 2, 3, 4, 5), and may be determined by the MPO amount, the amount disposed or transferred off-site, or by the amount released to environmental media. Therefore, it is imperative that affected facility owners and operators maintain accurate chemical inventory and consumption data, and continuously monitor any environmental releases throughout the reporting year.
Some exceptions exist to these reporting criteria. For example, if any of the following activities took place at your facility, including waste or sewage sludge incineration, wood preservation, fuel terminal operations, municipal wastewater collection and/or treatment, or pit or quarry operations, you must perform NPRI reporting regardless of the total employee hours worked that year. In addition, any facilities operating stationary combustion equipment must report any Part 4 criteria air contaminants (CACs) if the corresponding release thresholds are exceeded, regardless of employee hours worked.
NPRI changes for 2016
Several changes have been made to NPRI reporting requirements for reporting year (RY) 2016. Owners and operators of affected facilities must be aware of these changes to ensure NPRI data submitted is in compliance with the revised reporting requirements. These changes include:
- Modification of reporting threshold for cobalt
Cobalt and cobalt-containing compounds have been removed from the Part 1A threshold category, and added to the Part 1B category. As a result, the reporting threshold was lowered to 50 kilograms, with a 0.1% concentration threshold for quantities that are manufactured, processed or otherwise used.
- Removal of twenty-one substances from Part 1A threshold category
A complete list of these substances is available on Environment Canada’s website.
- Reporting of surface water discharge concentrations
When a direct discharge to surface waters is reported, the average annual concentration (ppm) of the NPRI substance in the effluent must be reported beginning in RY 2016. Facilities must also document the methods and calculations used to obtain these concentrations, as well as the method detection limit (MDL) used in making threshold determinations. Further guidance on these methods is available here.
Reporting NPRI Data
NPRI data is submitted through Environment Canada’s Single Window Information Manager (SWIM) system. SWIM is the online reporting interface used for numerous Canadian federal and provincial environmental programs, thus eliminating the need to report data separately to various federal and provincial agencies. A complete guide to accessing and managing information using the SWIM system is available on Environment Canada’s website. Once logged into the NPRI reporting module of the SWIM system, you’ll be guided through the various NPRI report sections that must be completed for each listed substance. Be prepared with information including:
- Company details (name, address, preparer’s and certifying official’s contact information, number of employees, NAICS #, NPRI ID, etc.)
- Parent company details (if applicable)
- Activity data (disposal, transfer, recycling and treatment amounts of each NPRI reportable substance)
- Amounts of on-site environmental releases
- Emission factors and other estimation parameters
- Documentation of data collection methodologies
- Applicable conversion factors
- Procedures used to measure emissions, including sampling procedures, equipment calibration and maintenance
- Contact information for any receivers of off-site transfers or disposals
Violations of the Canadian Environmental Protection Act (CEPA), including NPRI reporting requirements can be costly for owners and operators of affected facilities. A single violation for providing false or misleading NPRI reporting data can carry a fine of up to $100,000 (CAD). It is also worth noting that Environment Canada holds both facility owners and operators (including parent organizations that hold a greater than 10% interest in the facility) equally liable for any violation of NPRI reporting requirements. It is therefore absolutely critical that your facility’s NPRI data is accurate, and submitted on-time.
VelocityEHS Can Help!
NPRI compliance starts with efficient and precise chemical inventory management. Without it, you lack the ability to make accurate threshold determinations for the vast majority of NPRI listed substances you manufacture, process or otherwise use. You may not even be aware if listed substances are present in your facilities. Over-reporting or under-reporting creates unnecessary costs, and puts your organization at high risk for fines and penalties.
VelocityEHS, with our award-winning MSDSonline chemical management solutions, offers the industry’s leading chemical inventory management software. The MSDSonline HQ RegXR Account even gives you the ability to cross-reference your facility’s chemical inventory against NPRI listed substances, and more than 70 other international restricted chemical lists in real-time.
For more information on how the MSDSonline HQ RegXR Account can simplify chemical inventory management tasks for your facility, visit www.MSDSonline.com or give us a call at 1.888.362.2007.