Taking Stock Volume 16

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2 Feature Analysis: Off-site Transfers to Disposal in North America, 2014–2018

2.6 Conclusions

This feature analysis of off-site transfers to disposal by North American industrial facilities set out to answer questions relating to the reported substances and volumes, the sectors involved, and the nature of the disposal practices they employ. At the root of this examination are concerns about the potential environmental and human health risks associated with certain disposal methods—particularly when the responsibility for a facility’s waste is transferred to a third party and/or across international borders. Information about the relevant laws and regulations governing these waste disposal practices is presented with the aim of understanding how their risks can be minimized.

The data reported by facilities from 2014 through 2018 show that approximately 10 industrial sectors and the same number of pollutants (or pollutant groups) accounted for at least two-thirds of total off-site transfers to disposal each year. Many of these top sectors (e.g., metal ore mining, iron and steel mills, basic chemical manufacturing, oil and gas extraction, waste management) are common to the three countries; therefore, the data and information for these sectors could be used to better understand and address the needs and challenges facing facilities relative to preventing pollution and implementing more sustainable production practices.

However, this analysis also reveals important gaps in the regional picture of transfers to disposal, resulting from differences among national PRTR reporting requirements relative to these top sectors (for example, the sparse or non-existent data for oil and gas extraction facilities and public sewage treatment plants in the United States and Mexico), and to some of the pollutants that are typical of these industrial activities. As mentioned, only about 70 pollutants (or pollutant groups) are common to the three programs, with gaps in the reporting of key substances, such as zinc, manganese, and barium compounds, total phosphorous, and others—many of which have the potential to negatively impact human health and the environment if not managed properly.

This report provides recent examples of the risks associated with each of the six categories of off-site disposal discussed. It also highlights the difficulty of tracking pollutants from their point of origin to their ultimate disposition. Reasons for this include important differences among the three programs relative to the reporting of transfers to disposal (e.g., unique terminology and definitions, level of detail provided), along with the shared responsibility for the implementation of regulations and the monitoring of certain types of wastes and industrial management or disposal practices. The available data, particularly for cross-border transfers, indicate a need for enhanced coordination among relevant agencies and for more complete PRTR data and information about the management of pollutants, including accurate details relative to the source and recipient facilities.

This analysis has also provided examples of data quality issues, such as the reporting of erroneous industry sector codes, that can have important impacts on our ability to understand industrial activities in North America and the pollutants they generate or manage in some way. These issues are being addressed as part of the ongoing cooperative effort involving the CEC and the three PRTRs, based on the sharing of information and experiences to support greater comparability, quality, and completeness of data across the region.

In addition to highlighting the importance of PRTR data and information to track industrial pollutants, this discussion has shown that PRTRs can serve as important tools to support understanding and awareness, on the part of governments, industry, and other stakeholders, relative to sustainable production. For example, among the barriers impacting facilities’ ability to adopt more sustainable practices are lack of knowledge and funding. Adding to these challenges is a limited understanding on the part of governments about the needs of specific sectors and the best ways to support them in their transition toward sustainability. Recognizing the importance of such information, the three programs have made recent enhancements to reporting requirements with the objective of learning more about facilities’ pollution prevention and other efforts, along with the challenges they face—information that can be shared between industry sectors and across the region to support circular production processes that minimize waste generation and disposal.

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Commission for Environmental Cooperation

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