Environmental compliance can seem like a race without a finishing line; you are never quite there. And as you, no doubt, are aware, it’s time again to make sure you have your National Pollutant Release Inventory (NPRI) completed so you can meet your June 1st reporting deadline.
While there have been some changes, the starting point is still to ask yourself if you have NPRI reporting obligations. For that, we turn to Environment and Climate Change Canada (ECCC):
“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.”
If it appears that you are required to submit an annual NPRI report, you need to be aware of the most recent changes. ECCC has published the following changes for NPRI reporting this year.
- The mass threshold for cobalt (and its compounds) has been reduced from 10 tonnes to 50 kilograms, and the concentration threshold has been reduced from 1% to 0.1%.
- The requirement to report the concentration of substances released to surface waters has been added. When a direct discharge to surface waters is reported, the average annual concentration (parts per million) of the NPRI substance in the effluent is also required to be reported.
In addition to the changes above, 21 substances have been removed from the Part 1, Group A list. NPRI reporting requirements no longer apply to these substances:
- C.I. Acid Green 3 (CAS RN 4680-78-8)
- C.I. Basic Red 1 (CAS RN 989-38-8)
- C.I. Direct Blue 218 (CAS RN 28407-37-6)
- C.I. Food Red 15 (CAS RN 81-88-9)
- Calcium cyanamide (CAS RN 156-62-7)
- Chlorendic acid (CAS RN 115-28-6)
- Dimethyl phenol (CAS RN 1300-71-6)
- 2,6-Dinitrotoluene (CAS RN 606-20-2)
- Dinitrotoluene (mixed isomers) (CAS RN 25321-14-6)
- Hexachloroethane (CAS RN 67-72-1)
- Isosafrole (CAS RN 120-58-1)
- p-Nitrophenol (and its salts) (CAS RN 100-02-7)
- Paraldehyde (CAS RN 123-63-7)
- Pentachloroethane (CAS RN 76-01-7)
- o-Phenylphenol (and its salts) (CAS RN 90-43-7)
- Propargyl alcohol (CAS RN 107-19-7)
- p-Quinone (CAS RN 106-51-4)
- Safrole (CAS RN 94-59-7)
- Styrene oxide (CAS RN 96-09-3)
- Tetracycline hydrochloride (CAS RN 64-75-5)
- Vinylidene chloride (CAS RN 75-35-4)
If you have questions about NPRI reporting or any other environmental compliance issues, please feel free to contact me (cpare@dragun.com) or my colleague, Andrew Tymec, P.Eng. (atymec@dragun.com), at 519-979-7300.