Guide for reporting to National Pollutant Release Inventory 2001: step 7

Step 7: sign the statement of certification and submit the report

Sign the statement of certification

When submitting your National Pollutant Release Inventory (NPRI) report, you must include a signed statement of certification. The statement should be signed by the same person identified as the "company official" for the facility in field A16.

Submitting an NPRI report by mail

Send the disk and the signed statement of certification to your regional NPRI office, postmarked or courier-dated no later than June 1, 2002.

It is not necessary to provide a printed copy of the report with your disk.

Where disks contain reports for facilities in different regions of Canada, company coordinators are reminded that they are only required to send one report to the NPRI office in their region. For example, a company coordinator in Montreal, reporting for facilities in Edmonton, Vancouver and Toronto, is asked to send the reports to the NPRI regional office in Montreal.

Although rare, computer viruses have been detected on report disks submitted to the NPRI. If your disk is infected, you will be required to resubmit your report.

After making a copy on disk, slide the tab to open the "write protect" window on the corner of your 3.5" disk.

Indicate on your disk the name of your facility, NPRI ID number (provided with the reporting package) and the date of submission. First-time reporters who have not received a permanent NPRI ID number can use the temporary ID number (for example, 9000000001) generated by the software.

If you need assistance, contact your regional NPRI office.

Submitting an NPRI report by e-mail

Reports submitted by e-mail and the signed statement of certification must be received by Environment Canada no later than June 1, 2002.

If you choose to submit your NPRI report by e-mail:

• Use the NPRI software to export the NPRI report to a floppy disk or a hard disk folder. Do not copy the files that are in the NPRI software directory. A complete NPRI report consists of a single file - expodata.mdb
• Send this file as an attachment to an e-mail to your regional NPRI office. In the subject line, clearly indicate that it is an NPRI report and include the NPRI ID number for your facility and the name of your company. Company coordinators are reminded that they are only required to send one report to the NPRI office in their region. In your e-mail message, include your name, address, telephone and facsimile numbers and e-mail address. Retain a copy of this e-mail for future reference.
• Your signed statement of certification must be sent by facsimile to the same NPRI office to which you sent the e-mail. Keep the original signed statement of certification on file for future reference. Your report is considered incomplete until the signed statement of certification has been received by Environment Canada.

If you need assistance, contact your regional NPRI office.

Retain a copy of the information on which your NPRI report was based

New for 2001, this is a legal requirement, pursuant to subsection 46(8) of the Canadian Environmental Protection Act, 1999 (CEPA), and the Canada Gazette notice. The owner or operator of a facility is required to keep copies of the required information, together with any calculations, measurements and other data on which the information was based. This information must be kept at the facility to which it relates or at the facility's parent company (as identified in field A3) for a period of three years.

Request for confidentiality

Reporting to the NPRI for 2001, is governed by the requirements of CEPA, as well as the Canada Gazette notice, published March 24, 2001.

Pursuant to sections 51 and 313 of CEPA, any person who provides information in response to the 2001 Canada Gazette notice may submit a written request that it be treated as confidential based on the reasons set out in section 52 of CEPA. For each facility and each substance reported, the request for confidentiality must clearly indicate each field for which a request is being made. The written request must accompany the report.

To be treated as confidential, the company must demonstrate that it treats the information as confidential and wishes to continue to do so. It must also demonstrate that this information is not available to the general public through legal means, such as obtaining a public copy of a provincial waste permit.

A request for confidentiality is not determinative. A determination of whether the information is confidential will be based on an objective analysis of the facts.

It is recommended that you include with your request for confidential treatment, documentation that would be required to justify that the information submitted should be confidential as per the criteria outlined in section 52 of CEPA.

If substantiation is not provided with the claim, or the substantiation provided doesn't support the claim, the Minister may follow the procedures with respect to publication of the information set out in section 53 of CEPA. Notwithstanding the above, the Minister may, in the appropriate circumstances, contact the person to inform them that the information may be disclosed as permitted under sections 315 through 317 of CEPA.

A request for confidentiality will be denied if the data are already in the public domain.

Necessary precautions should be taken when submitting an NPRI report for which a request for confidentiality is being made. This includes, but is not limited to, the following:

• confidential materials are to be sent in double envelopes, excluding the courier outer envelope
• the outside envelope should be unmarked except for mailing and return addresses, and postage
• the inside envelope should be stamped on both sides with wording such as "contains confidential information"

Should you have any questions concerning confidentiality requests, contact your regional NPRI office listed on the inside front cover.

section 52 of CEPA

With regards to information submitted to the NPRI, section 51 of CEPA, allows any person to submit with the information, a written request, setting out the reason(s) referred to insection 52 (see below), that the information be treated as confidential.

section 52 of CEPA, provides that:

52. Despite Part 11, a request under section 51 may only be based on any of the following reasons:

1. the information constitutes a trade secret;
2. the disclosure of the information would likely cause material financial loss to, or prejudice to the competitive position of, the person providing the information or on whose behalf it is provided; and
3. the disclosure of the information would likely interfere with contractual or other negotiations being conducted by the person providing the information or on whose behalf it is provided.

You now have completed your NPRI report for 2001. Ensure that you submit your report and signed statement of certification, postmarked, courier-dated or e-mailed, no later than June 1, 2002. Retain a copy of the report and information on which it was based at your facility or parent company. You will be able to upload the data from your 2001 report next year if you are required to report to the 2002 NPRI.