The National Pollutant Release Inventory (NPRI) serves as Canada’s mandated and publicly accessible record of pollutant releases, disposals, and recycling activities. As stated in Sections 46–53 of the Canadian Environmental Protection Act, 1999 (CEPA), these provisions empower the Department of Environment and Climate Change Canada to mandate the reporting of information on substances.
As an important resource, NPRI information plays a crucial role in identifying and monitoring pollution sources across Canada. It contributes significantly to the development of indicators evaluating the quality of air, land, and water. By offering insight into the annual releases and transfers from various facilities, the NPRI aids in assessing the need for regulatory interventions.
The NPRI reporting requirements for the 2023 calendar year was officially outlined in the “Notice with respect to substances in the National Pollutant Release Inventory for 2022, 2023, and 2024”, published in the Canada Gazette, Part I, on February 12, 2022.
There are many different reporting categories to NPRI, substances are categorized into five segments based on distinct reporting criteria as outlined below:
Part 1A – Core Substances:
Reporting is necessary for Part 1A substances if they were manufactured, processed, or utilized at a concentration equal to or exceeding 1% by weight and in quantities of 10 tonnes or more. There are no concentration thresholds for by-products and mine tailings for Part 1A substances.
Part 1B – Alternate Threshold Substances:
Reporting obligations for Part 1B substances arise when they are manufactured, processed, or otherwise used in quantities equal to or exceeding specific mass thresholds.
Part 2 – Polycyclic Aromatic Hydrocarbons (PAHs):
Reportable instances for Part 2 involve the incidental manufacturing or presence of PAHs in mine tailings, released, disposed of, or transferred for recycling in a combined quantity greater than or equal to 50 kilograms. Wood preservation facilities using creosote must report regardless of reaching the 50 kg reporting threshold.
Part 3 – Dioxins, Furans, and Hexachlorobenzene:
Mandatory reporting for Part 3 substances applies to facilities engaging in activities such as incineration, chlorinated solvent production, metal smelting, power generation, iron and steel manufacturing, pulp and paper manufacturing, titanium dioxide pigment production, cement manufacturing, magnesium production, and wood preservation using pentachlorophenol.
Part 4 – Criteria Air Contaminants (CACs):
All facilities must assess CACs released from stationary combustion equipment, with additional considerations for facilities with equal to or greater than 20,000 employee hours. Reporting is required if CACs were released to the air in quantities equal to or exceeding their release thresholds.
Part 5 – Speciated Volatile Organic Compounds (VOCs) – Additional Reporting Requirements:
Reporting for Part 5 substances is mandated if they were released to the air in quantities equal to or exceeding 1 tonne.
Facilities are required to assess all parts of the NPRI prior to submission.
It should be noted that submission/assessment for the NPRI is a mandatory federal requirement. Businesses meeting the reporting criteria but neglecting to fulfill their reporting obligations, submitting late reports, or knowingly providing inaccurate information, are subject to penalties outlined in section 272 of CEPA. Facilities exempt from reporting or not meeting criteria in prior years should reassess their status to determine their annual reporting obligations.
The three primary considerations to determine if a facility is required to submit an NPRI report:
- The activities that take place at the facility
- The total number of hours worked by full-time employees at the facility
- The substances manufactured, processed, otherwise used, or released to the environment at the facility
The reporting deadline for the 2023 calendar year is June 3, 2024.
In conclusion, facility owners and operators must evaluate each year independently to determine compliance with thresholds and determine the necessity of reporting. Quantities of substances released, disposed of, and recycled must be reported/assessed by the stipulated deadline of June 3, 2024.
Trinity is here to help! If you would like to assess for NPRI to evaluate how this may impact your facility, please email Suzy Sabanathan in Trinity’s Toronto Office or call us at 416.391.2527.
