Environment Canada has circulated two documents for discussion among the Work Group on Substances. The first discusses ways of tracking the success of pollution prevention programs. The NPRI currently requires facilities to report their pollution prevention (P2) information at the facility level. However, P2 activities often apply to individual substances. As the data currently exists, it is nearly impossible to link the reported P2 activity to a specific substance, unless a facility provides the name of that substance in a comment field. It is difficult for data users to analyze and understand the impacts of P2 activities on releases of substances from the facility. ECCC is exploring how the reporting system could collect more specific pollution prevention information, when it’s targeting specific substances. The early engagement document does not identify how this information would be collected, but it would certainly add extra steps to reporting.
CWWA submitted comments supporting the overall concept of expanding the reporting on pollution prevention activities but encouraging Environment Canada to make this reporting easy and intuitive, to ensure that it doesn’t add to the already significant burden of reporting.
Canadian Water and Wastewater Association