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Proposed changes in response to the National Pollutant Release Inventory Substance Review

Environment Canada (EC) proposed to change the reporting thresholds for five substances that were previously listed in Part 1A of the National Polluant Release Inventory (NPRI) substance list, add one substance to Part 1A, and delete five substances from Part 1A.

Consultations on these proposed changes were conducted with the NPRI Multi-Stakeholder Work Group (WG) from October through December of 2013. After considering the comments received, Environment Canada has decided to proceed with the changes, and they are reflected in the 2014-2015 NPRI Canada Gazette notice.

A) Summary of Proposal (October 2013)

B) Summary of Stakeholder Comments and Environment Canada’s Response (July 2014)

A) Proposal (October 2013)

The following is a summary of the proposal. Copies of the proposal and document tilted Approach Taken for the Review of the NPRI Substances List are available by contacting the NPRI.

1. Summary of Proposed Modifications

Environment Canada is proposing to change the reporting thresholds for five substances that are currently listed in Part 1A of the NPRI substance list (with a 10 tonne mass threshold), add one substance to Part 1A of the NPRI list, and delete five substances from the NPRI list.

2. Background

In order to continually improve the National Pollutant Release Inventory (NPRI) and meet both departmental priorities and data user needs, Environment Canada has been conducting a review of the NPRI substance list. This review involves verifying that the NPRI substance list is complete and relevant, and that reporting thresholds are appropriate for gathering data on pollutant releases in Canada.

The NPRI Substance Review is being conducted using a multi-phased approach. The first phase, which began in 2012, primarily involves substances on the List of Toxic Substances [Canadian Environmental Protection Act, 1999 (CEPA 1999), Schedule 1] with a single Chemical Abstracts Service Registry Number (CAS RNFootnote1 ). Changes based on the first phase are anticipated to be implemented for the 2014 reporting year. Public consultation, including consultations with the NPRI Multi-Stakeholder Work Group, on these proposed changes will be conducted in the fall of 2013. All comments received will be considered, according to the established process for considering changes to NPRI requirements.

Subsequent phases will involve reviewing the NPRI requirements for substances on the List of Toxic Substances that were not considered in the first phase (substances with multiple CAS RNs) and the remainder of the NPRI substance list. Changes resulting from subsequent phases may be implemented starting with the 2016 reporting year or later, with consultation on possible changes expected to be initiated during 2014.

3. Proposed Changes

The proposed changes as well as the rationales and impacts for the proposed changes are summarized in the following sections.

a) Proposed Threshold Changes

  1. Bisphenol A [Phenol, 4,4' -(1-methylethylidene)bis-] (CAS RN 80-05-7)

    Bisphenol A is an industrial chemical used as a monomer to make a hard, clear plastic known as polycarbonate, and is also used as a precursor for monomers of epoxy resins. This substance was assessed and was determined to meet the criteria of section 64 of Canadian Environmental Protection Act" (CEPA 1999). Bisphenol A was added to the List of Toxic Substances in 2010. Environment Canada is proposing to change the NPRI mass threshold for bisphenol A from 10 tonnes to 100 k Gram (g). The lowered mass threshold is expected to significantly increase National Pollutant Release Inventory (NPRI) reporting from the plastics and rubber manufacturing sector and is aligned with the mass threshold of the pollution prevention planning requirements for this substance.
  2. Hydrazine (CAS RN 302-01-2)

    Hydrazine is an industrial chemical which is primarily used as a corrosion inhibitor in boiler water at nuclear and fossil-fuel power generating plants. Hydrazine was added to the List of Toxic Substances in 2011. Environment Canada is proposing to change the NPRI mass threshold for hydrazine from 10 tonnes to 1 tonne. The proposed threshold is expected to significantly increase reporting from facilities in the electric power generation, transmission and distribution sector.
  3. Isoprene [1,3-Butadiene, 2-methyl-] (CAS RN 78-79-5)

    Isoprene is an industrial chemical used in the manufacture of rubbers and plastics, toys, tires and paints. Isoprene was added to the List of Toxic Substances in 2011. Environment Canada is proposing to change the NPRI mass threshold for isoprene from 10 tonnes to 100 kg. The lowered mass threshold is expected to significantly increase NPRI reporting by facilities in the non-conventional oil extraction and petroleum refining industries and is aligned with the mass threshold of the pollution prevention planning requirements for this substance.
  4. Nonylphenol and its Ethoxylates

    Nonylphenol and its ethoxylates have been used for over 40 years in detergents, wetting agents, dispersing agents and emulsifiers. Nonylphenol and its ethoxylates were added to the List of Toxic Substances in 2002. Environment Canada is proposing to change the NPRI mass threshold for nonylphenol and its ethoxylates from 10 tonnes to 1 tonne. Pollution prevention planning requirements have decreased the use of these substances to below the current NPRI 10 tonne threshold. TheNPRI threshold change is being proposed in response to these lower use quantities.
  5. Quinoline (CAS RN 91-22-5)

    Quinoline is a nitrogen-substituted polycyclic aromatic hydrocarbon that is naturally associated with coal and coal-derived compounds and may be formed as a trace pollutant during incomplete combustion of nitrogen-containing substances. Quinoline was added to the List of Toxic Substances in 2012. Environment Canada is proposing to change quinoline from a Part 1A substance (10 tonne mass threshold) to a Part 2 substance (50 kg mass threshold for total polycyclic aromatic hydrocarbons, including quinoline, and 5 kg mass threshold for reporting quinoline itself). The proposed change is expected to increase reporting from facilities in sectors that report for other polycyclic aromatic hydrocarbons but that but that are not currently required to report for quinoline (utilities, steel plants, wood preservation facilities, aluminum smelters, and waste incinerators).

b)Proposed Addition

  1. Ethanol, 2-(2-methoxyethoxy)- (CAS RN 111-77-3)

    (2-Methoxyethoxy)-ethanol (DEGME) is used as an additive in jet fuel; as a formulant in pest control products used in various applications, including in the pulp and paper industry; as a solvent in paints and in various products such as floor care products and brake fluid. This substance was added to the List of Toxic Substances in 2011. 2-(2-Methoxyethoxy)-ethanol meets the established criteria for addition to the NPRI. Environment Canada is proposing to add 2-(2-Methoxyethoxy)-ethanol to the NPRI substance list with a 10 tonne mass threshold.

c)Proposed Deletions

Environment Canada is proposing to delete the following substances from the NPRI substance list:

  1. Allyl chloride (CAS RN 107-05-1)
  2. C.I. Solvent Orange 7 (CAS RN 3118-97-6)
  3. 3-Chloro-2-methyl-1-propene (CAS RN 563-47-3)
  4. Ethyl chloroformate (CAS RN 541-41-3)
  5. 1-Bromo-2-chloroethane (CAS RN 107-04-0)

These substances are not expected to be manufactured, processed or otherwise used by industrial facilities in Canada, and have had no or very limited reporting to the NPRI. Although a small quantity of ethyl chloroformate was reported to the NPRI once, in 1996, this was not considered to be significant reason to keep the substance listed. The other four substances have never been reported to the NPRI.

B) Summary of Stakeholder Comments and Environment Canada's Response (July 2014)

The NPRI Multi-Stakeholder WG provided input on Environment Canada’s proposal to change the reporting thresholds for five substances that were listed in Part 1A of the NPRIsubstance list, add one substance to Part 1A, and delete five substances from Part 1A.

After considering stakeholder input, Environment Canada implemented the following changes commencing with the 2014 NPRI reporting year:

  1. The mass reporting threshold for bisphenol A has been lowered from 10 tonnes to 100 kg manufactured, processed or otherwise used (MPO);
  2. The threshold for hydrazine has been lowered from 10 tonnes to 1 000 kg MPO;
  3. The threshold for isoprene has been lowered from 10 tonnes to 100 kg MPO;
  4. The threshold for nonylphenol and its ethoxylates has been lowered from 10 tonnes to     1 000 kg;
  5. The threshold for quinoline is now 50 kg incidental manufacture of total polycyclic aromatic hydrocarbons including quinoline, and 5 kg incidental manufacture for quinoline itself. The 1% by weight concentration threshold no longer applies.
  6. Ethanol, 2-(2-methoxyethoxy)- (DEGME) has been added to Part 1A, with the standard mass threshold of 10 tonnes MPO and concentration threshold of 1%.
  7. Allyl chloride, solvent orange 7, chloro-2-methyl-1-propene, ethyl chloroformate, and bromo-2-chloroethane have been deleted from the NPRI substance list.

As a result of these changes, bisphenol A, hydrazine, isoprene and nonylphenol and its ethoxylates are listed as Part 1B NPRI substances instead of Part 1A substances. Quinoline is listed as a Part 2 substance, along with other polycyclic aromatic hydrocarbons, instead of a Part 1A substance. Ethanol, 2-(2-methoxyethoxy)- (DEGME) is listed as a Part 1A substance.

The tables below summarize the general and substance-specific comments received from stakeholders, and provide EC’s responses.

Comments were received from the following stakeholders:

  • Canadian Association of Petroleum Producers
  • Canadian Energy Partnership for Environmental Innovation and Canadian Gas Association (joint comment)
  • Canadian Environnemental Law Association
  • Canadian Vehicle Manufacturers’ Association
  • Cement Association of Canada
  • Chemistry Industry Association of Canada and Canadian Fuels Association (joint comment)
  • International Institute of Concern for Public Health and Citizens’ Network on Waste Management (joint comment)
  • Rivershed Society of British Columbia
Table 1 - Summary of Stakeholder General Comments and Environment Canada's Response
No./Topic Stakeholder Comment Environment Canada’s Response
1. NPRI Work Group Access to Data cited in Change Proposals The majority of the proposed threshold changes are based on information collected through section 71 of CEPA 1999 and risk management instruments, such as Pollution Prevention (P2) Planning requirements. This information was not provided to the NPRI Work Group (WG). For meaningful consultations, the WG needs access to these data to evaluate proposed changes to reporting thresholds. Environment Canada (EC) strives to employ the most applicable and available data sources to identify proposed changes to NPRI reporting requirements. Often, data collected under s.71 of CEPA 1999 (under which data on use, import and release of specific chemicals can be collected, to be used by EC mainly for the purposes of assessing the risks posed by those chemicals) and risk management instrument data are the most appropriate and accessible data sources. However,  restrictions on the public availability of this data, which in many cases was not collected with the intent of being published, may prevent sharing of these data with the NPRI WG. NPRI proposals include as much data as can be shared publicly.
2. Cost/Benefit Analyses Many of the proposals do not provide a sufficient understanding of incremental needs and benefits supporting proposed changes to reporting thresholds, balanced against resulting additional reporting burden, as well as potential for reduced accuracy and increased confusion.

EC agrees that alternate threshold proposals should include, where available, a cost-benefit analysis of potential reporting burden on facilities, balanced against benefits and user needs. However, data are not always available to address such questions.

Using the NPRI, an existing reporting instrument, to collect additional data on these substances will permit for these types of analyses, address reporting data gaps, and meet data user needs. For example, in some cases, new reporting thresholds are aligned with P2 Planning requirements. This will allow for comparison of NPRI and P2 Planning data to support data quality analyses and on-going data monitoring after P2 Planning requirements expire.

Although these changes increase the number of substances subject to alternate thresholds, the approach taken to implement these reduced thresholds will hopefully reduce the potential for confusion. These substances have been incorporated within the existing Parts 1B and 2, alongside substances that have already been subject to reduced thresholds for a number of years. For the 2014 changes to Part 1B, we have also used a limited number of defined threshold values (100 kg and 1 000 kg) and concentration thresholds (1% and 0.1%) to limit potential confusion and complexity in the requirements.
3. Reporting Threshold Alignment with P2 Planning Thresholds The major driver for proposed changes is alignment of reporting thresholds with P2 Planning requirements. However, these thresholds may have been set prior to compiling s. 71 survey results.  In addition, P2 Planning notices already require reporting of emissions.

P2 Planning thresholds are the level set by the department for which RM is considered appropriate. Alignment of NPRI reporting thresholds with P2 Planning thresholds is important to ensure adequate coverage of releases; to support RM activities; to allow for comparison of NPRI and RM data; and for on-going monitoring once P2 Planning requirements expire.

P2 Planning notices require reporting of emissions from key sectors (generally sectors with large releases) and serve a specific purpose (to reduce exposure to chemical substances). Facility-specific information is often treated as confidential and overall results are presented as summaries.

One of the key objectives of the NPRI is to provide data users (including the public) with comprehensive data on pollutant releases, and as such provide additional information beyond the more limited data submitted under risk management initiatives.
4. Cumulative Effects of Substances The cumulative effects of chemical substances should be considered when identifying an appropriate reporting threshold. Determining cumulative effects and impacts of various chemicals is a complex process. Since NPRI reporting requirements are substance-specific, substance-specific analyses must be performed when deciding on changes to NPRI reporting requirements.
5. Timing The tentative publication of March 2014 for the 2014-2015 NPRI Canada Gazette notice is too late. NPRI notices and accompanying guidance for a given year should be published by December preceding the reporting year to allow facilities sufficient time to gather data. EC recognizes that the publication of notices for the NPRI should occur as early as possible. However, under CEPA 1999, NPRI reporting is based on information in the possession of the facility or that can be reasonably accessed. If a facility genuinely has little or no information on this substance, they would be required to report only the information that they do have for 2014, and should take reasonable steps to gather the full required information for future years. In addition, the substances for which threshold changes are being implemented were listed on the NPRI in previous years, meaning that at least some facilities will already have information on the substances.

 

Table 2 - Summary of Stakeholder Substance-Specific Comments and Environment Canada's Response
No./Topic Stakeholder Comment Environment Canada’s Response
1. Bisphenol A (BPA) This proposed change is supported as it will increase reporting from the rubber and plastics manufacturing sectors. Support for the change proposal by Environment Canada (EC) is acknowledged. No response is required.  
2. BPA The proposed case for changing BPA’s reporting threshold is unfounded. The major argument appears to be alignment with the P2 Planning requirements. However, the basis of the P2 Planning threshold is not provided. P2 Planning thresholds are the level set by the department for which risk management is considered appropriate. Alignment of NPRI and P2 Planning thresholds is important to ensure adequate coverage of reporting of releases; to support risk management activities; to allow for comparison of NPRI and risk management data; and on-going monitoring once the P2 Planning requirements expire in 2016.  
3. BPA In terms of impacts on reporting by given sectors, what is the importance of increasing reporting from rubber and plastics manufacturing? How will this change affect other sectors such as pulp and paper?

Risk management has identified rubber and plastics manufacturing as a key sector in terms risk managing BPA releases. Therefore, it is important for releases from this sector to be adequately reported. This will ensure that data users have access to comprehensive data on this substance. It will also allow tracking and public communication of P2 Planning progress through the NPRI.

This change is suspected to impact BPA reporting from others sectors such as paper recycling sector and waste water treatment.  However, the magnitude of reporting from these other sectors cannot be estimated using available data.

  
4. Hydrazine Reconsidering the reporting threshold for hydrazine is supported. However, a mass reporting threshold of 100 kg manufactured, processed or otherwise used (MPO) is recommended instead of the proposed 1 000 kg. A 1 000 kg threshold will more than likely only capture additional information from nuclear power generation facilities, but not necessarily other facilities in the electric power generation, transmission and distribution sector.

According to data analyses, as outlined in the proposal, the majority of use and release of hydrazine will be captured at a 1 000 kg threshold. The estimated additional 4-11 power generation facilities that will have to report based on the new threshold are expected to provide sufficient coverage of reporting for this substance.

The intent of the NPRI is not to capture all release sources, but to capture significant industrial release sources in order to balance information needs and reporting burden on industry.

  
5. Hydrazine There is a gap between s. 71 data and NPRI data which is not explained in the proposal.  According to the proposal only two power plants reported hydrazine to the NPRI, while s. 71 data indicate that there are at least 20 power plants that use hydrazine and “could release significant quantities of hydrazine”.

According s. 71 data and other sector survey data, there are approximately 20 power plants that use hydrazine.  At the 10-tonne threshold, two power plants are required to report to the NPRI, representing an estimated 78% of hydrazine usage. The new reporting threshold of 1 000 kg is expected to increase reporting to capture about 95% of hydrazine use by requiring an additional 4-11 facilities to report. A threshold of 100 kg would increase the reported usage to 100% by requiring all 20 power plants to report. 

The intent of the NPRI is not to capture all release sources, but to capture significant industrial release sources in order to balance information needs and reporting burden on industry. Therefore, a reporting threshold of 1 000 kg has been implemented.

  
6. Hydrazine

The proposed threshold could inadvertently capture other sectors, in addition to power plants and inorganic chemical manufacturing, since other sectors use boiler water which may contain hydrazine.

If hydrazine usage and releases are concentrated in the power generating sector, an activity-based threshold could be more appropriate than an MPO threshold.

 One of the key objectives of the NPRI is to provide data users (including the public) with data that is as comprehensive as possible across sectors. As such, an activity-based threshold is only applied in cases where an MPO threshold is not suitable. If other sectors are using hydrazine above the 1 000 kg threshold, they should also be reporting to the NPRI since there is the same potential for release as in the power generating sector. Impacts on other sectors can be evaluated once the change has been implemented, to determine if further changes are warranted in the future.  
7. Isoprene This proposed change is supported as it will increase reporting from facilities in non-conventional oil extraction, petroleum refining, synthetic rubber manufacturing, and chemical sectors. Support for the change proposal by EC is acknowledged. No response is required.  
8. Isoprene

This proposed change will offer limited benefits. Only one facility has consistently reported high isoprene releases and accounts for 99% of combined total releases reported. Therefore, the proposed threshold change will increase reporting burden on industry by requiring additional evaluation by many companies, while capturing less than 1% additional releases.

The major argument to change the reporting threshold appears to be alignment with the reporting threshold for P2 Planning requirements. However, the basis of the P2 threshold is not provided.

Risk management instruments, like P2 Planning Notices, target key industrial sectors, such as those identified as posing risks in the Final Screening assessment of substances. One of the key objectives of the NPRI is to provide data users (including the public) with comprehensive data on pollutant emissions. Therefore, the NPRI applies more broadly than risk management instruments, as it includes all sectors.

The new reporting threshold is expected to have limited impact on coverage from plastics and rubber manufacturing sectors, which were the target of the P2 Planning requirements. However, recent data have shown an expansion in the use of this substance. A reduced threshold is expected to increase reporting coverage from a variety of other sectors, such as non-conventional oil extraction and refineries. Also, substance releases are not always proportional to production since smaller users may be releasing larger quantities compared to larger users.

P2 Planning thresholds are the level set by the department for which risk management is considered appropriate. Alignment of NPRI and P2 Planning thresholds is important to ensure adequate coverage of reporting on releases; to support risk management activities; to allow for comparison of NPRI and risk management data; and on-going monitoring once the P2 Planning requirements for isoprene expire in 2016.

  
9. Isoprene This proposed threshold will not address EC’s intention to track and manage risk associated with isoprene because very few industries would report releases at the decreased threshold.  EC should consider using targeted educational efforts and track improvements to determine if additional review is needed. The intent of lowering this reporting threshold is to track release trends over time. This will meet the NPRI objective of providing data users (including the public) with data on isoprene. It will also assist in defining the scope of any potential issues with this substance, and whether additional risk management or other activities are warranted.  
10. Isoprene The claim that lowering the reporting threshold will substantially increase isoprene releases reporting from petroleum refineries, fossil fuel electric power generation and petroleum product wholesaler-distributors is not supported by any data in the proposal.  Publicly available data indicates that this is highly unlikely and does not suggest that the proposed threshold reduction will address a reporting gap. Available information suggests that a lower reporting threshold will increase reporting from petroleum refineries, fossil fuel electric power generation and the petroleum product wholesaler-distributor sectors. This will be evaluated once data obtained with the reduced reporting threshold are received.  
11. Nonylphenol and its ethoxylates (NP and NPEs) The proposed change is supported. The lowered threshold will improve coverage by increasing the number of facilities that currently report, and has the potential to identify users that were not captured under the P2 Planning and NPRI requirements. Since NP and NPEs P2 Planning requirements have expired, a reduced threshold will permit continued monitoring of use levels and sector-based use patterns. Support for the change proposal by EC is acknowledged. No response is required.  
12. NP and NPEs

More information is required before recommending or justifying an appropriate threshold. For example, the proposal should include sector-specific analysis on differences in reporting these substances in terms of the various sectors if the threshold was lowered to 1 000 kg.

Information on the impacts of the proposed change on sectors that are not identified in the proposal, including chemical manufacturers, is needed.

EC agrees that alternate threshold proposals should include as much information as possible when recommending or justifying an appropriate threshold. However, data are not currently available to fully address sector-specific analysis on differences in reporting of these substances and impacts of the change on sectors not mentioned in the proposal.

It is important for NPRI to proceed with this change in order to support data user needs. Since the P2 Planning requirements for NP and NPEs have expired, a reduced threshold will permit on-going monitoring of releases of these substances through the existing reporting mechanism of the NPRI.

  
13. NP and NPEs Reconsidering the NP and NPEs reporting threshold is supported. However, a reporting threshold lower than the proposed 1 000 kg MPO is recommended. The reporting threshold for these substances should capture all sources of releases and transfers. For example, the proposed threshold is not expected to capture releases from textile mills. The NPRI should consider an activity-based threshold such as those that are applied to other toxic chemicals (e.g., dioxins and furans).

NPRI seeks to capture significant sources of industrial releases while balancing information needs with reporting burden on industry. The majority of significant releases are expected to be captured at the new threshold. Reporting from textile mills is not required to get an adequate picture of releases of NP and NPEs, since releases from this sector were significantly reduced due to successful implementation of risk management activities and are now much lower than other sources of releases of these substances.

One of the key objectives of the NPRI is to provide data users (including the public) with data that is as comprehensive as possible across sectors. As such, an activity-based threshold is only applied in cases where an MPO threshold is not suitable.  

  
14. Quinoline This proposed change is supported as it is expected to increase reporting from facilities in sectors that report for other polycyclic aromatic hydrocarbons (PAHs), but are not currently required to report for quinoline. Support for the change proposal EC is acknowledged. No response is required.  
15. Quinoline The rationale for the proposed change does not demonstrate a sufficient benefit as reported quantities would not change significantly. Adding quinoline, a substance on the List of Toxic Substances, to Part 2 will allow it to be reported with other PAHs. Tracking quinoline alongside other PAHs at the same threshold, instead of creating a separate alternate threshold for quinoline, is preferred because the sources of releases and quantities are expected to be similar to other Part 2 PAHs.  
16. Quinoline EC has not clearly demonstrated that lack of reporting from sectors known to “incidentally manufacture and release” quinoline is a result of the current mass threshold. A more targeted approach at these sectors is recommended to identify underlying reasons behind lack of reporting. The available information indicates that the lack of reporting is due to the 10 tonne MPO reporting threshold being too high to capture releases in lower quantities. Sectors known to incidentally manufacture and release quinoline (e.g. utilities, steel plants, wood preservation facilities, aluminum smelters and waste incinerators) are not being captured by the current NPRI threshold.  
17. Ethanol, 2-(2-methoxyethoxy)- (DEGME) Considering the addition of DEGME to the NPRI is supported. However, a threshold of 1 000 kg instead of the proposed 10 tonnes is recommended in order to capture all facilities in the pulp and paper and chemical manufacturing sectors. Available data are not sufficient to conclude that 10 tonnes is an appropriate threshold.

The available data suggests that DEGME is typically used in large quantities at industrial facilities. Although this substance was added to the List of Toxic Substances (Schedule 1 of CEPA 1999), the NPRI does not by default lower reporting thresholds for these types of substances. However, an alternate threshold may be considered, if a substance meets certain criteria such as alignment with risk management instruments (e.g., P2 Planning Notices), identified reporting gaps, data user needs, etc.

The primary concern for DEGME is chemical exposure through products, which are not subject to NPRI reporting. However, this substance is being added to the NPRI as there is a potential concern that large usage and releases could be of interest, in which case the 10-tonne default threshold for the NPRI is appropriate. Since there is no risk management instrument specific to industrial releases of DEGME, alignment with a risk management threshold is not a consideration for DEGME.

  
18. Ethanol, 2-(2-methoxyethoxy)- (DEGME) A Significant New Activity notice for DEGME permits use where there is an acceptable risk.  Future reporting of DEGME releases should distinguish between those sources/uses that have been deemed acceptable, and releases where reductions are being sought.

Significant New Activity Notices establish requirements for notification to Environment Canada if a substance is used above a specific quantity or for certain activities. In the case of the Significant New Activity notice for DEGME, it does not require the provision of information to Environment Canada when DEGME is used for specified activities.

One of the key objectives of the NPRI is to provide data users (including the public) with comprehensive data on pollutant emissions. It would not be in line with this objective to exempt certain sources or uses from reporting, if they meet the 10-tonne threshold for reporting on this substance, simply because they are listed in the Significant New Activity notice, while other sources or uses with the same quantities would be required to report. In general, NPRI requirements are broadly applicable across sectors for this reason.

Facilities are required to identify their sector when reporting to the NPRI. Users will be able to analyze data by sector, to distinguish between activities to which the Significant New Activity requirements apply and activities that are not subject to those requirements.

  
19. Deletions: Allyl Chloride, Solvent Orange 7, Chloro-2-methyl-1-propene, Ethyl Chloroformate, and Bromo-2-chloroethane The proposed deletion of these substances is supported.  There has been limited to no reporting on these substances. Protection is provided by Significant New Activity requirements and the Non-Domestic Substance List (NDSL) should these substances be re-introduced into the Canadian market.

Support for the change proposal by EC is acknowledged.

The points indicated are part of the rationale for deleting these substances. Should these substances re-enter commerce in Canada, Significant New Activity requirements and the Non-Domestic Substance List will result in notification to Environment Canada, allowing for their inclusion in the NPRI to be re-evaluated.

  
20. Deletions A cautionary approach to deleting these substances is recommended. For example, reporting thresholds for these substances should be reviewed and assessed to see if lower thresholds would result in submission of release data from facilities. Additional evidence to confirm that a substance is not used in Canada, such as through the Domestic Substance List Inventory Update should be sought. Significant New Activity notices for substances not found to be manufactured or imported in Canada for a specific reporting year are recommended.

EC aims to focus resources on priority issues. These substances are not a current priority for EC, as they are not in commerce in Canada and are not deemed of high concern under the Chemicals Management Plan.

In the event that usage or release of these substances occurs in Canada, EC will be notified under provisions of the New Substances Notification Regulations or Significant New Activity reporting requirements. EC can then re-evaluate if the substance should be reported to the NPRI.

  

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