By the time we are posting this blog, your National Pollutant Release Inventory (NPRI) reporting should have been completed and submitted for the year. These inventories are required (by federal law) to be reported each year on June 1st. Because there are still facilities that may be unaware of their reporting requirements, Environment Canada has made an effort to find those non-reporting facilities to help get them get into compliance.
Do You Need to Submit a NPRI Report?
Evaluating your reporting obligations will require your close review of the legislation, as well as your chemical usage. Environment Canada’s website provides the following: “If one or more NPRI substances was manufactured, processed or otherwise used at the facility during the year, and the total number of hours worked at the facility exceeded the 20,000 hour employee threshold (approximately 10 full-time employees), you will need to determine the total amount of each NPRI substance at your facility during that calendar year.”
What are the NPRI Substances?
So, the next question you might have is, “What is a NPRI Substance?” The list of substances that are regulated has evolved over the years, so your reporting obligations may also change accordingly. Currently, there are over 300 substances with a variety of threshold reporting requirements. For example, if you manufacture, process, or otherwise use (MPO) as little as 5 kilograms of mercury, you may have to report on this substance to NPRI; however, it may require as much as 10 tonnes of aluminum MPO before you are required to report for aluminum. We suggest that you check Environment Canada’s List of NPRI Substances for 2014 and 2015. And, as we have previously reported, the data from the releases in the NPRI database are published for the public to review. It might be a good practice to check the published data for your facility to make sure it is accurate.
Penalties for Non-Compliance
There are, in some cases, significant penalties for failure to report. According to Environment Canada, “… owners or operators of facilities that meet published reporting requirements are required to report to the NPRI. Companies that meet reporting requirements but which fail to report, do not report on time, or knowingly submit false or misleading information, face penalties as listed under Section 272 and 273 of CEPA 1999.” These penalties range from $15,000 to $1,000,000 and imprisonment.
The NPRI reporting requirements affect thousands of companies across the country, and, with the list of NPRI substances constantly evolving, you should keep a watchful eye on this list and make sure you are in compliance. If you need help with evaluating NPRI reporting applicability at your facility, or if you have any questions, please feel free to contact me (atymec@dragun.com) at 519-979-7300, ext 118.