The Canadian National Pollutant Releasing Inventory (NPRI), a federally funded program, aims to collect information on the release, transfer, and disposal of harmful pollutants throughout the country. The program was developed as part of the government’s Green Plan Initiative and mandated under the Canadian Environmental Protection Act of 1998. It requires owners and operators of all facilities that use these substances to annually report the amount they discharge or emit into the environment. The information collected is made public so that individuals can track pollution in their own backyards. It also empowers provincial and municipal governments by enabling them to monitor environmental performance and implement corrective measures.
It can be difficult to know what to do, how to do it, and if your facility has to submit a report. The Government of Canada website has a lot of information, but it is difficult to find the specific piece of data you are looking for.
ERA has compiled all the available information, including the 155-page Guide for Reporting the NPRI, to provide a comprehensive overview of the NPRI reporting requirements. You can read it along with our NPRI eBook, which you can download free of charge below.
This page is organized to correspond to the order you should ask questions to determine whether or not your facility needs to submit an NPRI report. However, you can jump directly to a specific topic by using the Table of Contents.
The three main NPRI reporting criteria
The NPRI status of a facility is determined by three criteria.
- Employee Count
- Use of the Facility
- Substances present
The employee count should be easy to calculate. You meet the requirements if your total annual labor hours are 20,000 or higher. Even facilities with less staff year-round can exceed this threshold by adding in the hours of the owner(s), part-time, term, and temporary employees, as well as contractors. Even if you include paid overtime, sick leave, and vacation time in your calculations, it can be enough to tip the balance!
There are some activities which may need to be reported regardless of the number of hours of work performed at the location where they occurred. You can find them listed in their entirety as Appendix at the bottom.
In short, if there are 10 or more full-time employees at your facility, or if there aren’t but your facility is engaged in an employee-threshold-exempt activity, it is most likely subject to NPRI reporting.
Who has to report to NPRI Canada – ECCC Facility Category?
For more information, read the highlights. The facilities were divided up into three categories: industrial (mines and sawmills), treatment (large municipal sewage treatment plants), and service. Waste incinerators, large municipal sewage treatment facilities, and stationary establishments such as airports and power stations were all included. 5472 (76%) facilities were in the oil and gas extraction and manufacturing industries. This makes the facilities that fall under this category a clear target for NPRI compliance monitoring.
Even if you have the highest polluting industrial facility, it must fall into one of these Environment and Climate Change Canada’s (ECCC) facilities categories before it is considered a likely reporter.
- Contiguous It is a facility that operates as one integrated site and is operated by the exact same person or business. This includes all the buildings, equipment, and structures on site, as well as stationery items.
- Owners/operators of adjacent facilities are generally required to report substances under one or more of the five sections (see below, “NPRI Chemical Substances”)
- You can also download the app. An installation that can be completely relocated to operate. In terms of NPRI data collection, this usually consists of PCB destruction equipment, asphalt plants and concrete batching plant.
- Owners/operators of portable equipment are required to submit reports on substances found in parts 2-5.
- Pipeline Installation : An installation at a single location that consists of the equipment required to operate a natural-gas transmission or distribution pipeline. This includes pipeline compressors and stations for storage along channels.
- Owners/operators of pipeline installations are generally only required to report CACs (Part 4) and VOCs that have been classified (Part 5).
- Offshore These include drilling units, production platforms, or ships for the extraction of oil and natural gas. To be required to file a report, these must be permanently anchored on the Canadian continental shelf or in Canada’s economic zones.
- Owners/operators of offshore installations are required to report substances that fall into one or more parts.
After determining that your facility meets one of the four criteria above and has more than the threshold for labor hours (employees), the next step is to study the exemption criteria, both for the facilities and the activities.
NPRI Exemptions for Facilities
If you are only conducting one of the activities listed above, then your facility does not have to report NPRI.
NPRI Exemptions for Activities
Your facility is exempted from reporting PARTS 1-3 if the only source or use is one of the listed activities.
Re-evaluation of Annual Performance
It is not possible to be exempt from NPRI reporting requirements, but staying up-to-date on the changes could make the difference between meeting reporting criteria and the easiest reporting season.
Consider the number of facilities reporting in 2020. As shown in the graph above, 8,411 facilities had reported to NPRI. In 2021, this number fell to 7,191. There were suddenly 1,067 sites that didn’t meet the criteria for reporting (and several hundred that had disappeared, probably due to closing operations). It is possible that COVID caused the downturn in these facilities, but the changes made to the list of substances can explain the decline. Certain facilities are either above or below the NPRI reporting thresholds. As the thresholds change, substances are added and removed, and the NPRI list is constantly updated, certain facilities (usually smaller ones) may not be required to submit an NPRI report in a particular year.
As a reporter, it is important to review the changes made to NPRI toxic substance lists each year and to re-evaluate your reporting quantities when significant changes are made to your facility, such as changes to production levels, expansion of plants, pollution prevention measures implemented, or accidental releases.
Facilities that do not meet NPRI reporting requirements but have filed a report the previous year are only required to submit “Doesn’t Meet Criteria.”