With a Focus on Releases to Air 

and Water from Pulp, Paper and 

Paperboard Mills

Exploring Changes in PRTR Reporting, 

2005–2010

North American Pollutant 

Releases and Transfers

 Taking 

 St ck 14

2005

2010
For more information:

Commission for Environmental Cooperation

393, rue St-Jacques Ouest, Bureau 200

Montréal (Québec) Canada H2Y 1N9

t (514) 350-4300 f (514) 350-4314

info@cec.org / www.cec.org

Publication Details

Publication type: Report

Publication date: [October 2014]

Original language: English

Review and quality assurance procedures:

Final Party review: [March – April 2014] 

QA207

Disclaimer

The national PRTR systems are constantly evolving, as facilities revise previous submissions to 

correct reporting errors or make other changes. For this reason, the three countries ‘lock’ their 

data sets on a specific date and use the ‘locked’ data for annual summary reports. Each year, the 

countries issue revised databases that cover all reporting years. The Commission for Environmental 

Cooperation (CEC) follows a similar process. For the purposes of this report, the Canadian NPRI 

and US TRI datasets of March 2012 and the Mexican RETC dataset of October 2012 were used. 

The CEC is aware that changes have occurred to the datasets, subsequent to the official release, that 

are not reflected in this report. Readers can visit the national PRTR websites to see if any changes 

to the data have occurred. This publication was prepared by the Secretariat of the CEC. The views 

contained herein do not necessarily reflect the views of the governments of Canada, Mexico, or 

the United States of America. Reproduction of this document in whole or in part and in any form 

for educational or nonprofit purposes may be made without special permission from the CEC 

Secretariat, provided acknowledgement of the source is made. The CEC would appreciate receiving 

a copy of any publication or material that uses this document as a source.

Please cite as: 

CEC. 2014. Taking Stock: North American Pollutant Releases and Transfers. Vol. 14. Montreal, 

Canada: Commission for Environmental Cooperation. 140 pp. 

This report was prepared by the Secretariat of the Commission for Environmental Cooperation. 

The information contained herein is the responsibility of the CEC and does not necessarily reflect 

the views of the governments of Canada, Mexico or the United States of America.

Reproduction of this document in whole or in part and in any form for educational or 

non-profit purposes may be made without special permission from the CEC Secretariat, 

provided acknowledgment of the source is made. The CEC would appreciate receiving a 

copy of any publication or material that uses this document as a source.

Except where otherwise noted, this work is protected under a Creative Commons Attribution 

Noncommercial–No Derivative Works License.

© Commission for Environmental Cooperation, 2014

ISBN: 978-2-89700-066-0 

Disponible en español – ISBN: 978-2-89700-067-7 

Disponible en français– ISBN: 978-2-89700-068-4 

Legal Deposit – Bibliothèque et Archives nationales du Québec, 2014

Legal Deposit – Library and Archives Canada, 2014
Exploring Changes in PRTR Reporting, 2005–2010

With a Focus on Releases to Air and Water from Pulp, Paper 

and Paperboard Mills

14

North American Pollutant 

Releases and Transfers

 Taking 

 St ck

Taking Stock North American Pollutant Releases and Transfers Vol. 14 v

Table of Contents

Preface ix

Acknowledgements xi

Abbreviations and Acronyms xii

Abstract xiii

Executive Summary xv

Introduction 1

Chapter 1 Overview of North American Pollutant Releases and Transfers, 2005–2010 5

1.1 Key Findings 5

1.2 Releases and Transfers Reported by North American Facilities, 2005–2010 6

1.3 Pollutants Reported to the North American PRTRs, 2005–2010 11

1.4 Industry Sectors Reporting to the North American PRTRs, 2005–2010 12

Chapter 2 Details of Reported Releases and Transfers, 2005–2010 21

2.1 Reported Releases to Air, 2005–2010 21

2.2 Reported Releases to Water, 2005–2010 30

2.3 Releases to Air and Water of Known or Suspected Carcinogens, Developmental or Reproductive Toxicants, 

Metals, and PBTs, 2005–2010 37

2.4 Reported Releases to Land, 2005–2010 43

2.5 Reported Releases to Underground Injection, 2005–2010 49

2.6 Reported Off-site Releases to Disposal, 2005–2010 54

2.7 Reported Off-site Transfers, 2005–2010 58

Chapter 3 Releases to Air and Water from North American Pulp, Paper and Paperboard Mills, 2005–2010 67

3.1 Key Findings 67

3.2 Overview of the Pulp and Paper Sector in North America 67

3.3 Processes and Technologies: Pulp, Paper and Paperboard Mills 68

3.4 Pollutants Associated with the Pulp and Paper Manufacturing Sector 71

3.5 Pollution Prevention and Control in the Pulp and Paper Manufacturing Sector 72

3.6 Pulp and Paper Manufacturing: Regulatory Environment 74

3.7 Reported Releases to Air and Water from Pulp, Paper and Paperboard Mills in North America, 2005–2010 76

Appendix 1 Using and Understanding Taking Stock 97

Features of the Three North American PRTRs 97

Overview of PRTR Reporting Requirements 97

Which Pollutants Must Be Reported? 97

Which Industries Report? 99

Taking Stock Terminology 100

Taking Stock Scope and Methodology 101

Limitations of PRTR Data 102

Appendix 2 Pollutants Common to at Least Two of the Three North American PRTRs 103

Appendix 3 Top Pollutants Released or Transferred by North American Facilities, 2005–2010 109

Appendix 4 Top Reporting Sectors in North America, 2005–2010 110

Appendix 5 Selected Pollutants: Industrial Sources, Uses and Chemical Properties 111

Appendix 6 Questionnaire Survey for Pulp, Paper and Paperboard Mills 115
vi Commission for Environmental Cooperation

Figures

Figure 1. Distribution of Facilities Reporting to the PRTRs of North America, 2010 7

Figure 2. Releases and Transfers Reported to the North American PRTRs, 2005–2010 8

Figure 3. Releases and Transfers Reported in Canada, Mexico and the United States, 2005–2010 9

Figure 4. Top Reporting Industry Sectors in Canada, Mexico and the United States, 2005–2010: Total Releases and Transfers 15

Figure 5. Releases to Air Reported in Canada, Mexico and the United States, and Top Reported Pollutants, 2005–2010 22

Figure 6. Top Reporting Industry Sectors for Releases to Air, North America, 2005–2010 23

Figure 7. Top Reporting Industry Sectors for Releases to Air in Canada, Mexico and the United States, 2005–2010 24

Figure 8. Releases to Air Reported by North American Electric Utilities, 2005–2010 27

Figure 9. Releases to Air Reported by North American Electric Utilities, by Year, 2005–2010 29

Figure 10. Releases to Water Reported in Canada, Mexico and the United States, and Top Reported Pollutants, 2005–2010 31

Figure 11. Top Reporting Industry Sectors for Releases to Water, North America, 2005–2010 32

Figure 12. Top Reporting Industry Sectors for Releases to Water in Canada, Mexico and the United States, 2005–2010 33

Figure 13. Releases to Air of Known/Suspected Carcinogens, Developmental/Reproductive Toxicants, Metals and PBTs: North American PRTRs, 2005–2010 38

Figure 14. Releases to Water of Known/Suspected Carcinogens, Developmental/Reproductive Toxicants, Metals and PBTs: North American PRTRs, 2005–2010 39

Figure 15. Releases to Land Reported in Canada, Mexico and the United States, and Top Reported Pollutants, 2005–2010 44

Figure 16. Top Reporting Industry Sectors for Releases to Land, North America, 2005–2010 46

Figure 17. Top Reporting Industry Sectors for Releases to Land in Canada, Mexico and the United States, 2005–2010 47

Figure 18. Releases to Underground Injection Reported in Canada and the United States, and Top Reported Pollutants, 2005–2010 50

Figure 19. Top Reporting Industry Sectors for Releases to Underground Injection in Noth America, 2005–2010 51

Figure 20. Top Reporting Industry Sectors for Releases to Underground Injection in Canada and the United States, 2005–2010 52

Figure 21. Releases to Disposal Reported in Canada, Mexico and the United States, and Top Reported Pollutants, 2005–2010 55

Figure 22. Top Reporting Industry Sectors for Releases Off-site to Disposal, North America, 2005–2010 56

Figure 23. Top Reporting Industry Sectors for Releases to Disposal in Canada, Mexico and the United States, 2005–2010 57

Figure 24. Transfers to Recycling and Other Transfers Reported in Canada, Mexico and the United States, 2005–2010 59

Figure 25. Top Reporting Industry Sectors for Transfers to Recycling and Other Transfers, North America, 2005–2010 61

Figure 26. Top Reporting Industry Sectors for Transfers to Recycling and Other Transfers, in Canada, Mexico and the United States, 2005–2010 61

Figure 27. Reported Cross-border Transfers in North America, 2006–2010 63

Figure 28. Production and Consumption of Pulp, Paper and Paperboard Products, North America, 2008 68

Figure 29. Schematic of a Typical Pulp and Paper Mill 69

Figure 30. Releases and Transfers Reported by North American Pulp, Paper and Paperboard Mills, 2005–2010 78

Figure 31. Releases to Air and Water Reported by Pulp, Paper and Paperboard Mills to PRTRs in North America, 2005–2010 80

Figure 32. Releases to Air and Water Reported by US Pulp Mills, 2005–2010 81

Figure 33. Releases to Air and Water Reported by Canadian and US Paper Mills, 2005–2010 82

Figure 34. Releases to Air and Water Reported by Canadian Paperboard Mills, 2005–2010 83

Figure 35. Distribution of Facilities Reporting Releases to Air to the North American PRTRs, 2010 86

Figure 36. Distribution of Facilities Reporting Releases to Water to the North American PRTRs, 2010 88

Figure 37. Reported Releases to Air of Known/Suspected Carcinogens, Developmental/Reproductive Toxicants, Metals and PBTs: 

Pulp, Paper and Paperboard Mills, 2005–2010 90

Figure 38. Reported Releases to Water of Known/Suspected Carcinogens, Developmental/Reproductive Toxicants, Metals and PBTs: 

Pulp, Paper and Paperboard Mills, 2005–2010 91

Figure A-1. Pollutant Releases and Transfers in North America 101
Taking Stock North American Pollutant Releases and Transfers Vol. 14 vii

Tables

Table 1. Overview of North American PRTR Data, 2005–2010 10

Table 2. Pollutants Reported to the North American PRTRs, 2005–2010 11

Table 3. Top Pollutants Reported to the North American PRTRs, 2005–2010 13

Table 4. Top Industry Sectors Reporting to the North American PRTRs, 2005–2010: Total Releases and Transfers 14

Table 5. Industry Sectors with the Largest Decreases in the Number of Reporting Facilities, US TRI and Canadian NPRI, 2005–2010 17

Table 6. Industry Sectors with the Largest Increases in the Number of Reporting Facilities, US TRI and Canadian NPRI, 2005–2010 17

Table 7. Industry Sectors with the Largest Changes in the Number of Reporting Facilities, Mexican RETC, 2005–2010 18

Table 8. Releases and Transfers from Mexican Facilities Reporting in 2005 or 2010, but Not Both Years 19

Table 9. Releases to Air Reported to the North American PRTRs, 2005–2010 21

Table 10. Top Reporting Industry Sectors for Releases to Air, and Top Reported Pollutants, North America, 2005–2010 25

Table 11. Top Reporting Industry Sectors for Releases to Air of Pollutants Common to NPRI, RETC and TRI, 2005-2010 26

Table 12a. Releases to Air Reported by North American Electric Utilities, 2005–2010: Top Pollutants, by Volume 28

Table 12b. Releases to Air Reported by North American Electric Utilities, 2005–2010: Top Pollutants, by TEP 28

Table 13. Releases to Water Reported to the North American PRTRs, 2005–2010 30

Table 14. Top Reporting Industry Sectors for Releases to Water, and Top Reported Pollutants, North America, 2005–2010 34

Table 15. Top Reporting Industry Sectors for Releases to Water of Pollutants Common to NPRI, RETC and TRI, 2005–2010 35

Table 16. Reported Releases of C, D, M, P* Common to the North American PRTRs, 2005-2010 40

Table 17. Reported Releases of Pollutants of Special Concern Common to the Three PRTRs, 2005-2010 41

Table 18. Releases to Land Reported to the North American PRTRs, 2005–2010 43

Table 19. Top Pollutants Released to Land, Canadian NPRI, 2005–2006 45

Table 20. Top Reporting Industry Sectors for Releases to Land, and Top Reported Pollutants, North America, 2005–2010 48

Table 21. Releases to Underground Injection Reported to the Canadian NPRI and US TRI, 2005–2010 49

Table 22. Top Reporting Industry Sectors for Releases to Underground Injection, and Top Pollutants, Canada and the United States, 2005–2010 53

Table 23. Releases Off-site to Disposal Reported to the North American PRTRs, 2005–2010 54

Table 24. Top Reporting Industry Sectors for Releases to Disposal, and Top Reported Pollutants, North America, 2005–2010 58

Table 25. Transfers to Recycling and Other Transfers Reported to the North American PRTRs, 2005–2010 59

Table 26. Top Reported Pollutants, Transfers to Recycling and Other Transfers, North America, 2005–2010 60

Table 27. Top Reported Pollutants Transferred from US Facilities to Mexico, 2010 64

Table 28. Pulp, Paper and Paperboard Mills Reporting to the North American PRTRs, 2005–2010 76

Table 29a. Top Pollutants Released to Air by Pulp, Paper and Paperboard Mills in North America, 2005–2010 85

Table 29b. Top Pollutants Released to Water by Pulp, Paper and Paperboard Mills in North America, 2005–2010 85

Table 30. Top Reporting Facilities in the Pulp, Paper and Paperboard Mills Sector: Releases to Air, 2005–2010 87

Table 31. Top Reporting Facilities in the Pulp, Paper and Paperboard Mills Sector: Releases to Water, 2005–2010 89

Table 32. Pulp, Paper and Paperboard Mills: Releases to Air of C, D, M, P Common to the Three PRTRs, 2005–2010 91

Table 33. Pulp, Paper and Paperboard Mills: Releases to Water of C, D, M, P Common to the Three PRTRs, 2005–2010 92

Table 34. Reasons for Changes in Reported Releases to Air and Water, 2005–2010: Canadian NPRI and US TRI 95

Table A-1. Features of the Three North American PRTRs 97

Table A-2. Pollutants Common to at Least Two of the Three North American PRTRs 103

Table A-3. Top Pollutants Released or Transferred by North American Facilities, 2005–2010 109

Table A-4. Top Reporting Sectors in North America, 2005–2010 110

Taking Stock North American Pollutant Releases and Transfers Vol. 14 ix

Preface

As we celebrate the 20th anniversary of the North American Free Trade Agreement (NAFTA) and the North 

American Agreement on Environmental Cooperation (NAAEC), it gives me great pleasure to present a special 

edition of the Taking Stock report, a flagship series of the Commission for Environmental Cooperation (CEC) 

whose development has mirrored the growth of trilateral collaboration on North American environmental issues. 

This particular report marks a significant achievement for the CEC, but more importantly, it represents a milestone 

for North American pollutant release and transfer register (PRTR) reporting. Much progress has been made under 

the CEC’s North American PRTR Project since the first report, published in 1994—including the establishment of 

a mandatory PRTR in Mexico, collaboration on data quality, completeness and access issues, increased stakeholder 

engagement, and the achievement of comparable data publication schedules. This progress has made it possible 

for Taking Stock to present, for the first time, a detailed examination of the changes in pollutant releases and 

transfers reported over a six-year period by industrial facilities in North America—covering more than 500 

pollutants and approximately 35,000 facilities in over 200 industrial sectors across the region. 

This year’s report also presents a special focus on releases to air and water reported between 2005 and 2010 by 

North American pulp, paper and paperboard mills. An examination of PRTR data from this important North American 

industrial sector reveals that reported releases to air and water have decreased. Through insights obtained from a 

survey of mills in the three countries and from industry representatives, Taking Stock is able to offer information about 

the possible drivers of these decreases and about environmental sustainability efforts within the sector. 

The report also explores reported releases of pollutants considered to be of special concern because of their 

significant potential to cause harm to human health or the environment. Many of these pollutants have the 

potential to cause cancer, developmental or reproductive toxicity, and so on; however, of the hundreds of 

pollutants reported across the region, only a small subset are covered by the three PRTR programs. The Taking 

Stock report sheds light on the gaps in our picture of North American industrial pollution resulting from national 

differences in PRTR reporting requirements and other factors, and points to actions that can be taken to 

enhance data comparability—actions that are currently the focus of trinational collaboration under the CEC’s 

Action Plan to Enhance the Comparability of PRTRs in North America. This ongoing effort is an essential step 

towards improving our understanding about North American industrial pollution and how to address it.

As an important complement to the report, we continue to enhance public access to PRTR information through 

the Taking Stock Online website and searchable database, allowing users to explore and visualize different 

aspects of the data. Taking Stock Online supports the CEC’s objective of providing optimal access to North 

American PRTR data and additional context to enable readers to better interpret the information, thereby 

improving the utility of the data. These and other initiatives, such as the public meeting of the North American 

PRTR Project, seek to engage all stakeholders and to promote increased dialogue and collaboration across 

borders and industrial sectors. 

Through Taking Stock, the CEC strives to provide information for decision-making at all levels of society, promote 

reductions in industrial pollution, and support the integration of PRTR data into an overarching framework for 

managing pollutants in North America. Taking Stock thus remains a cornerstone of the CEC’s efforts to protect 

human health and enhance environmental sustainability across North America. We welcome your suggestions on 

how Taking Stock and the North American PRTR Project can evolve in order to achieve this goal.

Irasema Coronado, Ph.D.

Executive Director

Taking Stock North American Pollutant Releases and Transfers Vol. 14 xi

Acknowledgements

This report was made possible by the efforts of members of the Commission for Environmental Cooperation (CEC) 

Secretariat and, in particular, the Air Quality and Pollutant Releases Program team of Orlando Cabrera-Rivera, 

Program Manager; Danielle Vallée, Project Coordinator; Marilou Nichols, Program Assistant; and Zakir Jafry, 

resident GIS and mapping specialist. The publications staff of Douglas Kirk, Jacqueline Fortson, Johanne David 

and Joanne Padulo carried out the demanding job of editing, translating and publishing the report in three 

languages. Catherine Hallmich, Project Coordinator for the Healthy Communities and Ecosystems Program, 

and Lucie Robidoux, Project Coordinator for the Sound Management of Chemicals Program, also played a role 

in reviewing certain portions of the report. The graphic design of this report was done by Gray Fraser.

The CEC also wishes to recognize the valuable contributions of the following individuals who worked in a consulting 

capacity on the development of the pulp and paper facility survey, including the design and preparation of the 

survey questionnaire, contacts with facilities, and analyses of survey results: from Washington State University, 

Dr. Mark Stephan, Associate Professor, and Lynn Finley; from Western Washington University, Ben Kane, and in 

a supervisory capacity, Dr. Troy Abel, Associate Professor; and in Mexico, Dr. Luisa Manzanares Papayanopoulos 

and Dr. Arturo Keer Rendón. The CEC wishes to thank the individuals from the North American facilities who 

generously gave of their time to respond to our survey.

The CEC gratefully acknowledges the following experts for their invaluable input during the preparation of 

this report: Bob Larocque, Director, Environment, Forest Products Association of Canada (FPAC); Pedro Silva 

Rodríguez, Director, Cámara Nacional de las Industrias de la Celulosa y del Papel (National Pulp and Paper 

Industry Association [Mexico]); Michelle Turner, Director, Generation and Environment, Canadian Energy 

Association (CEA); Luis Carlos Hernández Ayala, Director of Operations, Comisión Federal de Electricidad

(CFE—Federal Electricity Commission [Mexico]); and Archie Beaton, Executive Director, Chlorine Free Products 

Association (CFPA). Special thanks go to Kirsten Vice, Vice-President, Canadian Operations, National Council for 

Air and Stream Improvement, Inc. (NCASI), for her thorough review of the report and her additional insights. 

The CEC also thanks the following national pollutant release and transfer register (PRTR) officials for 

providing advice and feedback on the report: from Canada’s National Pollutant Release Inventory (NPRI), 

Karen Mailhiot and Jody Rosenberger; from the United States’ Toxics Release Inventory (TRI), Steve DeVito; 

and from Mexico’s Registro de Emisiones y Transferencia de Contaminantes (RETC), Maricruz Rodríguez 

Gallegos and Floreida Paz Benito.

And finally, the CEC wishes to recognize the invaluable support provided by Pangaea Information Technologies, 

Ltd, along with the CEC’s IT (information technology) staff, who were instrumental in the development of the 

Taking Stock Online website, <www.cec.org/takingstock/>. In the spirit of right-to-know, this integrated and 

searchable North American PRTR database provides access to valuable information that enables governments, 

individuals, NGOs and communities to act in an informed manner to protect our shared environment. The 

enhanced access to these data greatly facilitated the task of preparing the analyses for this report. 
xii Commission for Environmental Cooperation

Abbreviations and Acronyms

AOX Adsorbable Organic Halogens

ATSDR Agency for Toxic Substances and Disease Registry (US)

BOD biological oxygen demand

CAC criteria air contaminant

CAS Chemical Abstracts Service

CEA Canadian Energy Association

CEC Commission for Environmental Cooperation

CFE Comisión Federal de Electricidad (Federal Electricity Commission [Mexico])

EC Environment Canada

FPAC Forest Products Association of Canada

GHG greenhouse gas

IARC International Agency for Research on Cancer

kg kilogram

NAICS North American Industry Classification System

NCASI National Council for Air and Stream Improvement, Inc. 

NGO nongovernmental organization

NOM Norma Oficial Mexicana (Mexican Official Standard)

NPRI National Pollutant Release Inventory (Canada’s PRTR)

PBT persistent, bioaccumulative and toxic substance

POTW publicly owned treatment works (US public water and wastewater treatment facilities)

Prop 65 California’s Office of Environmental Health Hazard Assessment (OEHHA) Proposition 65 list

PRTR pollutant release and transfer register

RETC Registro de Emisiones y Transferencia de Contaminantes (Mexico’s PRTR)

Semarnat Secretaría de Medio Ambiente y Recursos Naturales (Secretariat for the Environment 

and Natural Resources [Mexico])

TEP toxicity equivalency potential

TRI Toxics Release Inventory (US PRTR)

TRS total reduced sulfur

US EPA United States Environmental Protection Agency
Taking Stock North American Pollutant Releases and Transfers Vol. 14 xiii

Abstract

This edition of the Taking Stock report examines the data on pollutant releases and transfers reported by 

industrial facilities from 2005 through 2010 to the three pollutant release and transfer registers (PRTRs) 

of North America: Canada’s National Pollutant Release Inventory (NPRI); Mexico’s Registro de Emisiones y 

Transferencia de Contaminantes (RETC); and the US Toxics Release Inventory (TRI). It provides details about 

specific pollutants, how they were managed, and the sectors and facilities reporting them over time and 

across North America. This year’s edition places additional emphasis on reported releases to air and water, 

particularly of those substances considered to be of special concern because of their significant potential to 

cause harm to human health or the environment. 

The report also presents a special focus on releases to air and water reported by North American pulp, paper 

and paperboard mills. From 2005 through 2010, this industry consistently ranked among the top sectors in 

North America, but PRTR data show decreases over time in its releases to air and water. Through analyses 

of these data and related information, a small survey of pulp and paper mills, and feedback from North 

American pulp and paper industry associations, the report explores the possible drivers of these decreases 

and offers additional insights about the environmental sustainability efforts within the sector. 

Taking Stock seeks to enhance the understanding of the sources, locations and types of pollutant releases and 

transfers across North America. It also promotes greater comparability of PRTR data among the three countries, 

and increased dialogue and collaboration across borders and industrial sectors. Through these efforts, the 

report furthers the goals of the CEC to provide information for decision-making at all levels of society, promote 

reductions in industrial pollution, and support the integration of PRTR data into an overarching framework for 

managing pollutants in North America.
xiv Commission for Environmental Cooperation

Zakir Jafry
Taking Stock North American Pollutant Releases and Transfers Vol. 14 xv

Executive Summary

This edition of Taking Stock examines the data on pollutant releases and transfers reported by North American 

industrial facilities from 2005 through 2010 to their respective pollutant release and transfer registers 

(PRTRs), namely: 

•	 Canada’s National Pollutant Release Inventory (NPRI);

•	 Mexico’s Registro de Emisiones y Transferencia de Contaminantes (RETC); 

•	 the US Toxics Release Inventory (TRI).

Taking Stock 14 shows that over this six-year period, reported releases and transfers increased by 14 percent (from 

over 4.83 billion kilograms to more than 5.53 billion kilograms). Releases to land increased by 108 percent, while 

off-site releases to disposal increased by 42 percent. These increases were driven primarily by the metal ore mining 

and oil and gas extraction sectors, with changes in Canadian NPRI reporting requirements playing a key role. Over 

this same period, reported releases to air decreased by 36 percent, largely due to reductions by the US electricity 

generation sector. Changes in regulations for fossil fuel–based power plants were a main driver, but factors such 

as changes in fuels and technologies, as well as facility closures, also played a role. Other reported releases and 

transfers declined between 2005 and 2010. 

However, there were important differences among the three countries in terms of total reported releases and 

transfers; the number of reporting facilities and pollutants; and the direction of changes over this period. For 

example, an analysis of reported releases to air and water of substances of special concern—including known 

or suspected carcinogens; developmental or reproductive toxicants; persistent, bioaccumulative and toxic (PBT) 

substances; and certain metals—reveals that in 2010, approximately 74.4 million kilograms of such pollutants 

were released to air and more than 7.34 million kilograms were released to water (representing decreases of 38 

percent and 5 percent, respectively, from 2005 levels). However, of the hundreds of reported pollutants, only a 

small number are common to the three PRTR programs. The report thus illustrates the gaps in the North American 

picture of industrial pollution created by varying national PRTR reporting requirements for pollutants and sectors, 

incomplete reporting, and other factors.

This report also presents a special focus on releases to air and water reported by North American pulp, paper 

and paperboard mills. From 2005 through 2010 this industry consistently ranked among the top reporting 

sectors in North America. Through analyses of PRTR data, a survey of pulp and paper mills, and insights from 

pulp and paper industry associations, the report explores the possible drivers of decreases in releases to air and 

water (of 19 percent and 6 percent, respectively) from this sector. 

It reveals that in Canada and the United States (the countries accounting for the largest proportions reported 

by this sector), the total number of reporting facilities decreased, largely due to the shutdown of manufacturing 

operations. The report also illustrates how differences among the three countries’ PRTR reporting requirements 

had an impact on the amounts and types of pollutants reported—including certain pollutants that are typical of 

this sector, such as methanol, that were reported in large proportions in only one or two of the three countries. 

These gaps were especially evident in Mexico, where mills reported relatively small proportions of total releases 

to air and water. 
xvi Commission for Environmental Cooperation

The results of the CEC’s survey of North American pulp and paper mills reveal that more than one factor 

accounted for changes implemented by these facilities between 2005 and 2010; factors included changing 

government regulations and environmental management practices, economic considerations, PRTR data 

estimations, and production levels. The survey also yields information about how mills use their PRTR 

data—for example, to comply with facility permitting requirements, and in external communications with the 

public. A number of mills also noted that customer demand for non-toxic inputs played a role in the facilities’ 

environmental management decisions; this suggests that PRTR data have impacts that go beyond compliance 

with reporting requirements, and that they are a useful tool not only for industrial facilities, but for external 

stakeholders as well.

Through these analyses, the report seeks to enhance the understanding of the sources, locations and types of 

pollutant releases and transfers over time, and across the region. By highlighting important gaps in the North 

American picture of industrial pollution, Taking Stock promotes greater comparability of PRTR data among the 

three countries, and increased dialogue and collaboration across borders and industrial sectors. In this way, 

the report furthers the goals of the CEC to provide information for decision-making at all levels of society, 

promote reductions in industrial pollution, and support the integration of PRTR data into an overarching 

framework for managing pollutants in North America.
Taking Stock North American Pollutant Releases and Transfers Vol. 14 1

This edition of the Taking Stock report examines changes in 

the releases and transfers reported by industrial facilities to 

the three pollutant release and transfer registers (PRTRs) of 

North America from 2005 through 2010.1

 It provides details 

of reporting by pollutant, release and transfer category, and 

location. This year’s edition places additional emphasis on 

reported releases to air and water of four categories of pollutants: known or suspected carcinogens; developmental or 

reproductive toxicants; metals; and persistent, bioaccumulative and toxic substances (PBTs). Some of the pollutants 

in these categories are considered to be of special concern 

because of their persistence in the environment and/or significant potential to cause harm to human health or the environment, even when released in relatively small amounts. 

This report also presents a special focus on reported releases 

to air and water from North American pulp, paper and 

paperboard mills. From 2005 through 2010, this industry 

consistently ranked among the top sectors in North America; however, PRTR data for this sector also show decreases 

over time in reported releases to air and water. A key objective of this feature analysis is to identify the drivers of these 

decreases. Chapter 3 provides information about the sector, 

including pulp and papermaking processes and the pollutants typically associated with them; pollution prevention and 

control technologies in the sector; and the changing situation with regard to environmental regulations. Results from 

a survey of pulp and paper mills are presented, as are insights 

from pulp and paper industry associations, which add invaluable context about the economic, technical and environmental challenges facing this sector in North America. 

Through these analyses, Taking Stock sheds light on questions 

about industrial pollution in North America; for example:

•	 How have pollutant releases and transfers changed 

over time and across the region?

•	 What are the potential impacts on human health and 

the environment of these industrial pollutants and 

especially, of certain substances released directly to the 

environment?

•	 What were the drivers of the reported changes?

•	 What can we learn about industrial efforts towards 

environmental sustainability?

Taking Stock seeks to enhance the understanding of the 

sources, locations and types of pollutant releases and transfers across North America, in order to promote reductions 

in releases of pollutants with the greatest potential risk to 

human health and the environment. It is based primarily 

on publicly available data reported to the three national 

pollutant release and transfer registers (PRTRs) of North 

America:

•	 Canada’s National Pollutant Release Inventory (NPRI);

•	 Mexico’s Registro de Emisiones y Transferencia de 

Contaminantes (RETC); 

•	 the US Toxics Release Inventory (TRI).

Comparing pollutant releases and transfers from North 

American facilities presents challenges, due to differences 

among the three countries in PRTR reporting requirements 

for pollutants, sectors and facilities; variations in emission 

estimation methodologies; and other issues of data quality 

and completeness. However, this report demonstrates the 

usefulness of PRTR data for enhancing our understanding 

of industrial pollution in North America and the potential 

impacts on human health and the environment. Analyses of 

releases of specific pollutants also support the development 

of sector-specific baseline data and related pollution prevention and reduction activities. 

This publication supports the goal of the Commission for 

Environmental Cooperation (CEC) to provide information 

for decision-making at all levels of society. Specifically, Taking 

Stock aims to:

•	 provide a picture of the industrial releases and 

transfers of pollutants in North America and serve as 

an information source for governments, industry and 

communities in analyzing such data and identifying 

opportunities to reduce pollution;

•	 promote greater comparability of PRTR data among 

the three countries;

•	 raise awareness of the important health and 

environmental issues associated with industrial 

releases of toxic substances in North America;

•	 increase dialogue and collaboration across borders 

and industrial sectors; and

Introduction

1. Because facilities can submit revisions to their data at any point, the data presented in the Taking Stock report might differ from national datasets. For this report, 

the Canadian NPRI and US TRI datasets of March 2012 and the Mexican RETC dataset of October 2012 were used. Readers can visit the national websites to view 

changes to data.
2 Commission for Environmental Cooperation

•	 support the integration of PRTR data into an 

overarching framework for managing pollutants in 

North America.

It is important to remember that North American PRTR 

data represent only part of the pollution picture and do not 

cover other sources of pollution such as motor vehicles, agricultural practices, and other human activities (see Appendix 1). When exploring PRTR data, readers should keep in 

mind that the risks to human health and the environment 

associated with releases of pollutants reported by industrial 

facilities depend on a variety of factors, including a pollutant’s physical and chemical characteristics, the nature of its 

release, and so on. North American PRTR data are limited 

in that they do not provide information on the environmental fate of or risks from the pollutants released or transferred, 

nor levels of exposure of human or ecological populations to 

the pollutants. In addition, the amounts reported to a PRTR 

are usually based on estimates, which are often derived from 

different methods, including mass balance, engineering calculations, and emission factors. Each of these approaches 

results in varying levels of accuracy. 

Thus, PRTR data alone cannot provide enough information 

to assess the potential harm from a pollutant; however, the 

data, in combination with other information about a pollutant, can serve as a starting point for learning more about its 

potential impacts. Readers may wish to consult other sources 

for more information, including:

•	 ToxFAQs, from the US Agency for Toxic Substances 

and Disease Registry, <www.atsdr.cdc.gov/toxfaqs/

index.asp>; and

•	 Right-to-Know Hazardous Substances Fact Sheets, 

from the State of New Jersey’s Department of Health, 

<http://web.doh.state.nj.us/rtkhsfs/indexFs.aspx>.

Because of the large amount of data involved, readers are 

encouraged to visit the Taking Stock Online integrated, 

North American PRTR database, at <www.cec.org/takingstock>, to search the data by facility, industry sector, pollutant, or location. Data reported in the three countries from 

2005 through 2011 can be explored. Cross-border transfer 

data, starting with the 2006 reporting year, are also accessible through the database. The data can be downloaded for 

use in spreadsheets or formatted for certain mapping applications. A guide to making queries follows herein.

What Is a Pollutant Release and Transfer Register?

PRTRs provide annual data on the amounts of pollutants released from a facility to the air, water and land 

and injected underground, as well as transferred off-site for recycling, treatment or disposal. PRTRs are an 

innovative tool that can be used for a variety of purposes—that is, they track certain chemicals, thereby helping 

industry, governments and citizens identify ways to reduce the release and transfer of these substances, increase 

responsibility for chemical use, prevent pollution and cut back on waste generation.

Corporations use the data to report on their environmental performance and to identify opportunities for 

reducing or preventing pollution. Governments use the data to guide program priorities and evaluate results. And 

communities, nongovernmental organizations and citizens use the data to gain an understanding of the sources 

and management of pollutants and to support dialogue with facilities and governments.

PRTRs collect data on individual pollutants rather than on the volume of waste streams containing mixtures of 

substances, because this approach allows the tracking of releases and transfers of specific substances. Reporting 

by facility is central to locating where releases occur and who or what generated them. Much of the power of a 

PRTR lies in public disclosure of the data and their dissemination in both raw and summarized form to a wide 

range of users. The public availability of pollutant- and facility-specific data allows interested persons and groups 

to identify local industrial sources of releases and support regional and other geographically-based analyses.
Taking Stock North American Pollutant Releases and Transfers Vol. 14 3

Do you want to know the total amount of releases and transfers reported by country?

Step 1: Under “Report Type,” select “country”

Step 2: Under “Year,” select one or more years

Step 3: Under “Country,” select one or more country 

Step 4: Click on “Submit”

Note: On this page, you also have the option of selecting a pollutant or category of pollutants, a specific industry sector, and a type of release or transfer.

Once on the Results Page, click on the country total to get a breakdown of total releases and transfers by facility, 

industry sector, and pollutant. You have the following options:

n Select the medium of release or transfer type from the media buttons (the default is “Total Releases and Transfers”)

n Ungroup your results by pollutant or industry sector 

n Sort the data in order of decreasing amounts reported

n View the facility locations on the map inset 

n Download the data from this page in an Excel spreadsheet, or as a .kml or .kmz file to be displayed in Google Earth

Do you want to know which pollutants were released to air, water or land, and in what amounts?

Step 1: Under “Report Type,” select “pollutant”

Step 2: Under “Year,” select one or more years

Step 3: Under “Country,” select one or more country (and one or more state, province or territory, if desired) 

Step 4: Click on “Submit”

Note: On this page, you also have the option of selecting a category of pollutant (e.g., “known or suspected carcinogens”), or only those pollutants that are 

common to the countries selected. You can also select a specific industry sector and the type of release or transfer.

Once on the Results Page, you have the following options:

n Click the media button (e.g., air) to see all pollutants released to that medium

n For releases to air or water only, you can also check the “TEP score” box to obtain calculated risk scores for cancer and non-cancer effects 

(e.g., developmental or reproductive toxicity) 

n Sort the data in order of decreasing amounts reported, or by TEP score

n Click on a pollutant name to get a breakdown of reported releases to that medium by facility, state/province/territory, and industry sector 

n View the facility location on the map inset 

n Download the data from this page in an Excel spreadsheet, or as a .kml or .kmz file to be displayed in Google Earth

Other sample queries that may be of interest:

n Do a Facility search for one or more countries, then export the query results as kml or kmz file, to map in Google Earth 

n Use the “Summary Charts” tab in the side bar to get an overview of reporting in one or more countries by top pollutants or sectors 

n Use the “Cross-border Transfers” tab in the side bar to see details of the pollutant transfers among the three countries.

In addition to the analyses found in this report, 

you can use the integrated, North American 

PRTR database on Taking Stock Online, 

www.cec.org/takingstock, to answer your 

questions about pollutant releases and transfers 

by year, facility, location, pollutant, or industry 

sector. For instance:

Using Taking Stock Online
4 Commission for Environmental Cooperation
Taking Stock North American Pollutant Releases and Transfers Vol. 14 5

1.1 Key Findings

	From 2005 through 2010, releases and transfers 

reported by North American industrial facilities 

increased by 14 percent (from over 4.83 billion 

kilograms to more than 5.53 billion kilograms).

	Reported releases to land and off-site disposal 

increased over this period by 108 percent and 42 

percent, respectively (with releases to land accounting 

for over 32 percent of total releases and transfers 

in 2010, and off-site disposal for about 17 percent). 

These increases were driven primarily by two sectors, 

metal ore mining and oil and gas extraction. Changes 

in NPRI reporting requirements during this 6-year 

period affected the increases in reporting from these 

sectors in Canada, and illustrate the impacts of 

improved accounting within industry.

	Reported releases to air decreased by 36 percent from 

2005 through 2010, particularly from the electricity 

generation sector in the United States. Changes in 

regulations for fossil fuel–generated power plants were a 

main driver of this decrease; however, other factors such 

as changes in fuels and technologies, as well as facility 

closures, also played a role. Other types of releases and 

transfers, including releases to water and underground 

injection, and transfers to recycling and other treatment, 

saw decreases from 2005 through 2010. 

	There were important differences among the three 

countries in the reported amounts and the direction 

of changes over this period, due in part to key 

differences in national PRTR reporting requirements 

for pollutants and sectors. The data also reveal that a 

small number of facilities played a major role in some 

of the increases or decreases between 2005 and 2010. 

	Apparent changes in reported releases from certain 

facilities in the oil and gas extraction sector in 

Canada were the result of reassignments in industry 

classification codes, and possible double-counting 

of two related substances—total reduced sulfur 

compounds and hydrogen sulfide.

	In 2010, reported releases and transfers of four 

categories of pollutants (known or suspected 

carcinogens; developmental or reproductive toxicants; 

metals; and PBTs) accounted for just over 3 billion 

kilograms (or more than 55 percent) of all pollutants 

reported. About 74.4 million kilograms were released 

to air (a decrease of about 38 percent from 2005); 

and more than 7.34 million kilograms were released 

to water (a decrease of about 5 percent from 2005). 

Of the 275 pollutants in these categories that were 

released to air and water throughout this period, only 

42 are common to the three PRTR programs. 

	Among all sectors reporting to the PRTRs of North 

America between 2005 and 2010, pulp, paper 

and paperboard mills consistently ranked second 

for releases to air, and third for releases to water. 

Facilities in this sector reported more than 92.6 

million kilograms in releases to air in 2005, and 

about 75 million kilograms in 2010 (a decrease of 19 

percent). They also reported releases to water of about 

16.6 million kilograms in 2005, with these releases 

declining to about 15.7 million kilograms in 2010 (a 

decrease of 6 percent).

	Of over 500 active mills in North America, between 

352 and 429 reported to the North American PRTRs 

each year, from 2005 through 2010. In Canada and the 

United States, the countries accounting for the largest 

proportions reported by this sector, the total number 

of reporting facilities decreased, largely due to the 

shutdown of manufacturing operations. This decrease 

played a key role in the reductions in releases to air 

and water reported over this period. In Mexico, the 

number of reporting mills increased.

	Differences among national PRTR reporting 

requirements for pollutants, as well as incomplete 

reporting, had an impact on the amounts and types 

of pollutants reported released to air and water. For 

example, some of the typical pollutants for this sector, 

such as methanol, were often reported in only one 

country. These gaps were especially evident in Mexico, 

where mills reported very small proportions of total 

releases to air and water. 

Chapter 1

Overview of North American Pollutant Releases and Transfers, 2005–2010
6 Commission for Environmental Cooperation

	The majority of respondents to the CEC’s survey 

of mills mentioned more than one driver of the 

changes implemented at their facilities between 2005 

and 2010. These included changes in government 

regulations, environmental management practices, 

economic considerations, corrections or changes in 

PRTR data estimations, and decreases in production. 

The survey also revealed that mills use their PRTR 

data for internal information about environmental 

performance, as well as to comply with facility 

permitting requirements. 

	A number of mills noted that PRTR data are used 

in external communications with the public, with 

comments also indicating that customer demand plays 

a role in their environmental management decisions, 

such as the choice of chemicals used at their facilities. 

This suggests that PRTR data have wider impacts 

and that they are a useful tool not only for industrial 

facilities, but for external stakeholders as well.

1.2 Releases and Transfers Reported by North American 

Facilities, 2005–2010

In 2010, industrial facilities reporting to the pollutant release 

and transfer registers (PRTRs) of Canada, Mexico and the 

United States reported a total of 5,530,710,253 kilograms in 

pollutant releases and transfers, an increase of almost 700 

million kilograms (or 14 percent) from 2005 levels.2

The following map shows the locations of the 28,456 facilities that reported releases and transfers of at least 0.0001 

kilograms to the North American PRTRs in 2010. Among 

these facilities are 5,844 that reported releases of either criteria air contaminants (CACs) to Canada’s NPRI, or greenhouse gases (GHGs) to Mexico’s RETC, but no other PRTR 

pollutants. Because of major differences in the reporting 

and availability of data on CACs and GHGs in each country3

these substances are excluded from Taking Stock. 

The gaps created by differences among the three countries 

in PRTR reporting requirements for pollutants, sectors and 

facilities are the subject of ongoing work under the CEC’s 

Action Plan to Enhance the Comparability of PRTRs in 

North America4

, which is in the process of being updated, 

with the revised plan expected to be published in 2014.

The stacked bars in Figure 2 illustrate the releases and 

transfers reported each year from 2005 through 2010, and 

the horizontal line represents the number of reporting 

facilities. There was an increase of 14 percent (or almost 

700 million kilograms) in reported releases and transfers 

over this period. On-site releases (to air, water, land and 

underground injection) accounted for almost 2.9 billion 

kilograms (or 54 percent of the reported total), an increase 

of 24 percent from approximately 2.3 billion kilograms 

reported in 2005. There were notable increases in reported 

releases to land (108 percent) and off-site releases to disposal (42 percent), and a major decrease (of 36 percent) 

in reported releases to air. Reported releases to water and 

underground injection also declined, as did transfers to 

recycling and other off-site transfers. 

2. The amounts in the tables and figures presented in this report have been rounded.

3. For links to information on facility reporting of CACs and GHGs, see Appendix 1.

4. CEC. 2005. Action Plan to Enhance the Comparability of Pollutant Release and Transfer Registers in North America. Montreal, Canada: Commission for 

Environmental Cooperation.

Comparing PRTR data from Canada, the United 

States and Mexico

Taking Stock presents PRTR data from Canada, 

Mexico and the United States, thereby providing 

the most complete picture currently available 

of reported industrial releases and transfers of 

pollutants in North America. This picture includes 

data that might be reported differently in each 

country because of variations among national 

reporting requirements, as well as differences in 

the methods used by facilities to estimate their 

releases. The features unique to each PRTR are 

described in Appendix 1, and this information 

provides the context needed for a better 

understanding of the North American picture of 

pollutant releases and transfers. 
Taking Stock North American Pollutant Releases and Transfers Vol. 14 7

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± 0 250 500 1,000 km

Projection: Lambert Azimuthal Equal Area

Figure 1. Distribution of Facilities Reporting to the PRTRs of North America, 2010

Note: Among the Canadian and Mexican facilities shown on this map are 5,844 that reported releases only of criteria air contaminants or greenhouse gases, two 

pollutant groups that are excluded from the analyses in this report because of differences in national reporting requirements. Differences among the three countries in 

PRTR reporting requirements affect the North American picture of industrial pollution.

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± 0 250 500 1,000 km

PProjection: Lambert Azimuthal Equal Area rojection: Lambert Azimuthal Equal Area

0 250 500 1,000 km
8 Commission for Environmental Cooperation

However, there were important differences among the three 

countries in the total amounts reported, how the pollutants 

were handled, and changes over time (see Figure 3). For 

instance, the increase in reported releases to land was primarily driven by facilities in Canada, largely due to changes 

in NPRI reporting requirements. In the United States, overall reported amounts declined from 2005 through 2010, but 

the relative proportions of releases and transfers each year 

remained fairly consistent (with the exception of releases to 

air, which decreased at a greater rate). 

In Mexico, releases to air accounted for almost 53 percent of the reported country total in 2010. Meanwhile, offsite releases to disposal reported in that country fluctuated 

greatly over this period. The variability in reported releases 

and transfers in Mexico reflects fluctuations in the number of 

reporting facilities between 2005 and 2010 (see Table 1) and 

the fact that, similarly to the early years of PRTR reporting in 

Canada and the United States, there has been a steep learning 

curve for Mexico’s RETC program. Factors including changes 

in facility identification, sector designations, and guidance 

relative to the reporting of substances have contributed to the 

variability in PRTR data for that country. 

The data in Figure 3 also reflect differences among the 

three countries’ PRTR reporting requirements. For example, releases to underground injection accounted for about 

10 percent and 3 percent of Canadian and US reporting 

Figure 2. Releases and Transfers Reported to the North American PRTRs, 2005–2010

Other Transfers

Transfers to Recycling

Releases to Disposal

Releases to Underground Injection

Releases to Land

Releases to Water

Releases to Air

Number of Facilities

2005 2006 2007 2008 2009 2010

Year

6,000

5,000

4,000

3,000

2,000

1,000

25,000

20,000

Millions of Kilograms

Number of Facilities

Total 

Releases and 

Transfers (kg)

Releases 

to Air (kg)

Releases to 

Water (kg)

Releases to 

Underground 

Injection (kg)

Releases to 

Land (kg)

 Releases to 

Disposal (kg)

Transfers to 

Recycling (kg)

All Other 

Transfers (kg)

2005 4,833,498,433 807,172,052 234,003,770 412,296,802 866,151,548 653,288,663 1,259,727,734 600,652,254

2010 5,530,710,253 514,173,851 221,806,836 340,822,984 1,802,531,538 930,493,737 1,182,757,774 536,970,141

Difference 697,211,821 -292,998,200 -12,196,935 -71,473,819 936,379,989 277,205,074 -76,969,961 -63,682,114

Change (%) 14 -36 -5 -17 108 42 -6 -11
Taking Stock North American Pollutant Releases and Transfers Vol. 14 9

in 2010, respectively; however, similar Mexican data are 

not available because underground injection is not subject to reporting under RETC. Readers are reminded that 

differences in national PRTR reporting requirements are an 

important factor to consider when interpreting the data in 

this report.

Figure 3. Releases and Transfers Reported in Canada, Mexico and the United States, 2005–2010

Other Transfers

Transfers to Recycling

Releases to Disposal

Releases to Underground Injection

Releases to Land 

Releases to Water

Releases to Air

Number of Facilities

Mexico RETC

2005 2006 2007 2008 2009 2010

Year

80

70

60

50

40

30

20

10

2,000

1,800

1,600

1,400

1,200

Millions of Kilograms

Number of Facilities

Other Transfers

Transfers to Recycling

Releases to Disposal

Releases to Underground Injection

Releases to Land 

Releases to Water

Releases to Air

Number of Facilities

Canada NPRI

2005 2006 2007 2008 2009 2010

Year

2,500

2,250

2,000

1,750

1,500

1,250

1,000

750

500

250

3,500

3,000

2,500

Millions of Kilograms

Number of Facilities
10 Commission for Environmental Cooperation

Other Transfers

Transfers to Recycling

Releases to Disposal

Releases to Underground Injection

Releases to Land 

Releases to Water

Releases to Air

Number of Facilities

US TRI

2005 2006 2007 2008 2009 2010

Year

4,000

3,500

3,000

2,500

2,000

1,500

1,000

500

20,000

17,500

Millions of Kilograms

Number of Facilities

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.

Table 1. Overview of North American PRTR Data, 2005–2010 

Country 2005 2006 2007 2008 2009 2010

Difference 

2005–2010

% Change 

2005–2010

Total Releases 

and Transfers 

(kg)

Canada NPRI 1,228,841,372 1,891,885,324 2,028,051,891 2,203,986,243 2,091,768,875 2,474,610,253 1,245,768,881 101

Mexico RETC 65,226,620 27,961,007 35,873,024 57,814,032 74,559,916 35,053,206 -30,173,414 -46

US TRI 3,539,430,441 3,538,776,360 3,375,535,764 3,130,289,912 2,663,106,958 3,021,046,795 -518,383,646 -15

North America 4,833,498,433 5,458,622,690 5,439,460,679 5,392,090,187 4,829,435,749 5,530,710,253 697,211,821 14

Number of 

Facilities 

Reporting 

Canada NPRI 3,101 3,103 3,072 3,003 2,820 2,717 -384 -12

Mexico RETC 1,608 1,790 1,621 1,359 1,521 1,736 128 8

US TRI 20,810 20,141 19,743 19,480 18,403 18,159 -2,651 -13

North America 25,519 25,034 24,436 23,842 22,744 22,612 -2,907 -11

Number of 

Pollutants 

Reported 

Canada NPRI 182 189 202 196 194 191 9 5

Mexico RETC 69 67 67 68 65 67 -2 -3

US TRI 441 456 433 427 425 428 -13 -3

North America 484 503 491 486 483 486 2 0.4

Note: The number of reporting facilities shown in this table includes those reporting total releases and transfers of at least 0.0001 kilograms, but excludes Canadian and Mexican facilities that reported 

only releases of criteria air contaminants (CACs) or greenhouse gases (GHGs). These two groups of pollutants are excluded from Taking Stock due to differences in national PRTR reporting requirements. 

Differences among the three countries in PRTR reporting requirements affect  the North American picture of industrial pollution.
Taking Stock North American Pollutant Releases and Transfers Vol. 14 11

Table 1 provides a snapshot of PRTR reporting in each 

country from 2005 through 2010, including the number 

of reporting facilities, as well as the number of pollutants 

and total amounts reported each year. It shows that approximately 80 percent of all reporting facilities each year were 

located in the United States, which saw a decrease of 13 

percent in the number of reporting facilities over time. This 

table also reveals an increase in total releases and transfers 

from 2005 through 2010 in Canada. As shown throughout 

this document, this increase occurred largely as a result of 

changes in NPRI reporting requirements. 

1.3 Pollutants Reported to the North American PRTRs, 

2005–2010

Table 2 presents the reported releases and transfers in 2005 

and 2010, as well as the number of pollutants reported. 

It reveals some interesting contrasts—for example, the 

number of pollutants released to air in 2010 remained 

almost the same as in 2005, but total reported releases to 

air decreased by almost 300 million kilograms (36 percent) over this period. In terms of releases to land, facilities 

reported 33 fewer pollutants between 2005 and 2010, but 

reported amounts increased by 108 percent. 

A number of the pollutants reported by North American 

industrial facilities are considered to be of special concern 

because of their persistence in the environment and/or 

their significant potential to cause harm to human health 

and the environment, even when released in relatively small 

quantities. Some of them belong to one or more of the following four categories of pollutants: known or suspected carcinogens; developmental or reproductive toxicants; persistent, 

bioaccumulative and toxic substances (PBTs); and metals. 

Table 2 reveals that reported releases and transfers of such 

pollutants accounted for just over 3 billion kilograms (or 

more than 55 percent of total reported releases and transfers 

of all pollutants in 2010)—an increase from the 2.6 billion 

kilograms reported in 2005. This increase was mainly driven 

by reported releases to land. 

While there was a small increase in the number of pollutants 

reported by North American facilities over this period, the 

number reported in each country varied considerably (see 

Table 1). The pollutants reported each year can change due 

to a number of reasons: for example, a facility’s use or release 

of a pollutant in a given year might decrease to just below 

reporting thresholds; a change in PRTR reporting requirements might result in reporting of a pollutant for the first 

time; or new or revised emission estimation methodologies 

can yield more accurate reporting. 

Differences among the three countries’ PRTR reporting 

requirements for pollutants, sectors and facilities have significant impacts on the picture of industrial pollution obtained 

through PRTR data. For instance, of the hundreds of pollutants subject to PRTR reporting in North America, only 60 

are common to the three countries. Approximately 350 pollutants5

 are subject to reporting under Canada’s NPRI; 104 

pollutants are subject to reporting under Mexico’s RETC; and 

Table 2. Pollutants Reported to the North American PRTRs, 2005–2010 

Reported Releases 

and Transfers

All Pollutants Known or Suspected Carcinogens, Developmental 

or Reproductive Toxicants, Metals, and PBTs*

2005 2010 2005 2010

Kg # of Pollutants Kg # of Pollutants Kg # of Pollutants Kg # of Pollutants

Releases to Air 807,172,052 446 514,173,851 445 119,970,649 219 74,425,550 220

Releases to Water 234,003,770 276 221,806,836 247 7,756,161 142 7,347,276 130

Releases to Underground Injection 412,296,802 170 340,822,984 151 35,273,441 90 41,995,619 82

Releases to Land 866,151,548 245 1,802,531,538 212 844,883,772 139 1,522,069,757 116

Releases Off-site to Disposal 653,288,663 355 930,493,737 366 346,729,130 197 226,872,131 184

Transfers to Recycling 1,259,727,734 199 1,182,757,774 204 1,082,098,106 102 1,043,936,495 107

Other Transfers 600,652,254 413 536,970,141 402 165,133,480 206 158,026,744 201

Total Releases and Transfers** 4,833,498,433 484 5,530,710,253 486 2,601,914,922 245 3,075,257,545 240

* PBTs: Persistent, bioaccumulative and toxic substances. ** The sum of individual Reported Releases and Transfers categories might differ slightly from Total Releases and Transfers because in NPRI, 

On-site Releases of less than 1 tonne (1,000 kilograms) may be reported as an aggregate amount. 

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.

5. “Pollutants” also refers to pollutant groupings (e.g., lead and its compounds).
12 Commission for Environmental Cooperation

about 650 pollutants are subject to the US TRI. In addition, 

each country has set certain reporting thresholds for pollutants, which can differ from the other countries’ (see Appendices 1 and 2). The data presented in Taking Stock reflect these 

differences in national PRTR reporting requirements. In 

order to facilitate the reader’s interpretation of the data in this 

report, the countries in which the mentioned pollutants are 

subject to reporting are indicated next to the pollutant names.

1.3.1 Changes in PRTR Reporting Requirements for Pollutants, 

2005–2010

The national PRTR pollutant lists changed very little from 

2005 through 2010, with the only modifications being to 

Canada’s NPRI. Three polycyclic aromatic hydrocarbons 

(PAHs) were added to the list in 2006, and another nine were 

added in 2007. PAHs are organic substances that are formed 

from the incomplete combustion of hydrocarbons such as 

fossil fuels and organic matter. Canadian facilities must 

report if PAHs were incidentally manufactured or present 

in mine tailings and released, disposed of or transferred 

from a facility in a combined quantity of 50 kilograms or 

more (with certain exceptions). Facilities in a small number 

of sectors, including oil and gas extraction, basic chemical 

manufacturing, and iron and steel mill and ferroalloy manufacturing, reported relatively small releases and transfers 

of these PAHs in 2010. A number of PAHs are also subject to 

TRI reporting in the United States (where they are referred 

to as polycyclic aromatic compounds, or PACs).

In 2007, total reduced sulfur (TRS) was also added to the NPRI 

substance list. This change had a major impact on Canadian 

PRTR reporting, particularly from the oil and gas extraction 

sector (which accounted for 97 percent of total releases and 

transfers of this pollutant in 2010). TRS is subject to PRTR 

reporting in Canada, but not Mexico or the United States.6

TRS represents the total amount, in a gaseous mixture, of 

compounds containing reduced sulfur, which are restricted 

on the NPRI list to the compounds hydrogen sulfide (which 

is found in the largest proportion), carbon disulfide, carbonyl 

sulfide, dimethyl sulfide, dimethyl disulfide, and methyl mercaptan. Three of these pollutants, hydrogen sulfide, carbon 

disulfide, and carbonyl sulfide, are also reported separately 

under NPRI. As shown throughout this report, the magnitude of reported releases and transfers of TRS compounds in 

Canada since 2007 provides a good example of the impacts of 

improved accounting within industry, and highlights gaps in 

the picture of North American industrial pollution created by 

differences in national PRTR reporting requirements. 

1.3.2 Pollutants Released and Transferred in Largest 

Proportions, 2005–2010 

Of the 567 substances reported by North American facilities 

over this period, the 10 shown in Table 3 accounted for 70 

percent and 65 percent, respectively, of total reported releases 

and transfers in 2005 and 2010. In fact, the top 31 pollutants 

(see Appendix 3) accounted for 92 percent and 91 percent, 

respectively, of total reported releases and transfers in 2005 

and 2010. These data thus provide a snapshot of the quantities 

and types of industrial pollutants needing to be managed by 

industrial facilities in North America.

It is important to note that of the substances presented in 

Table 3, the majority are subject to reporting under Canada’s 

NPRI and the US TRI, with only lead (and its compounds) 

common to all three PRTR programs. 

1.4 Industry Sectors Reporting to the North American 

PRTRs, 2005–2010

In 2010, North American facilities in 225 industry sectors 

reported to their respective PRTRs. These industry sectors 

are classified according to North American Industry Classification System (NAICS) codes, with six levels of detail 

available (e.g., code 325 for Chemical Manufacturing; 3251 

for Basic Chemical Manufacturing; and 32511 for Petrochemical Manufacturing).7

However, as mentioned, there are differences among the three 

countries in the industrial sectors or activities subject to PRTR 

reporting, and these differences affect the North American 

picture of industrial pollution. In Canada, all sectors are subject to reporting, with exceptions for certain activities, such 

as research laboratories. In Mexico, 11 industry sectors under 

federal jurisdiction are subject to RETC reporting, as well as 

any facility that handles hazardous waste, or discharges pollutants to national water bodies (which means most water 

bodies in that country). For the mining sector, only beneficiation activities (i.e., extraction and refining of a mineral or 

metal from ore, but not the initial exploration and extraction 

of the ore) are subject to the RETC.

6. As of the 2012 reporting year, US facilities have to report their releases and transfers of hydrogen sulfide.

7. Throughout this report the NAICS-4 level is used, as it usually provides a sufficient level of detail about the industrial activities in question. In the United States, 

individual facilities can report up to five NAICS codes (with each code applying to a specific activity at the facility). The assignment of NAICS codes can vary 

from country to country. For more information, see: Statistics Canada. 2007. NAICS 2007, <www.statcan.gc.ca/subjects-sujets/standard-norme/naics-scian/2007/

list-liste-eng.htm>. US Department of Commerce. 2007. US Census Bureau. NAICS 2007, <www.census.gov/cgi-bin/sssd/naics/naicsrch?chart=2007>. Instituto 

Nacional de Estadística y Geografía. 2007. SCIAN 2007. <www.inegi.org.mx/est/contenidos/espanol/metodologias/censos/scian2007_1.pdf>. 
Taking Stock North American Pollutant Releases and Transfers Vol. 14 13

In the United States, some of the key industrial activities 

that are not subject to TRI reporting include:

•	 the oil and gas extraction sector, 

•	 iron ore mining, and 

•	 municipal- or state-owned water and sewage 

treatment facilities (called publicly-owned treatment 

works, or POTWs).

For additional information, see Appendix 1.

1.4.1 Changes in PRTR Reporting Requirements for Sectors, 

2005–2010

Changes during this period in Canadian reporting requirements relative to certain industry sectors had an impact 

on the releases and transfers reported in that country. In 

2006, NPRI removed a reporting exemption for mining 

extraction and crushing activities, resulting in the requirement for mining facilities to report their releases 

and transfers of many NPRI substances. Because of this 

change in reporting requirements, Canadian coal mines 

started reporting in 2006, with other types of mining facilities in that country also reporting additional releases 

and transfers. This change in NPRI reporting requirements thus resulted in improved accounting from mining 

activities in Canada.

There was another change to NPRI reporting requirements 

during this period. In 2009, NPRI introduced the requirement for mining facilities (including oil and gas extraction 

operations) to report their tailings and waste rock, retroactive to the 2006 reporting year. Tailings are the waste (such 

as sand, clay, water, bitumen, and chemicals) that remains 

after the processing of ore and other mined materials (e.g., 

oil sands); and waste rock is rock removed during mining 

extraction operations to provide access to the ore. This 

change in reporting requirements, along with the aforementioned addition of TRS to the NPRI list of pollutants, played 

a role in the 2005–2010 increases in reporting from mining 

and oil and gas extraction activities in Canada. 

1.4.2 Industry Sectors Reporting the Largest Proportions of 

Releases and Transfers, 2005–2010 

Table 4 presents the 10 industry sectors that accounted for 

between 64 percent and 72 percent of total releases and 

transfers reported from 2005 through 2010. It shows that 

most of these sectors reported reductions over this period, 

but that there was a net increase of 14 percent overall, with 

oil and gas extraction and metal ore mining activities being 

key drivers of this increase. A total of 30 industry sectors 

accounted for between 89 percent and 92 percent of total 

reported releases and transfers in North America over this 

period (see Appendix 4).

Table 3. Top Pollutants Reported to the North American PRTRs, 2005–2010 

Total Releases and Transfers On-site Releases*

Off-site Releases 

to Disposal Total Transfers**

Pollutant 2005 (kg) 2010 (kg)

% Change 

2005-2010 2010 (kg)

% Change 

2005-2010 2010 (kg)

% Change 

2005-2010 2010 (kg)

% Change 

2005-2010

Zinc (and compounds) (CA, US) 641,233,326 728,410,100 14 359,657,700 32 78,427,592 -42 290,216,625 25

Hydrogen Sulfide (CA, MX) 549,418,432 632,563,242 15 152,867,297 -49 479,650,431 91 41,241 13

Lead (and compounds) (CA, MX, US) 454,007,439 467,277,324 3 278,044,395 37 16,424,428 -72 172,808,501 -10

Copper (and compounds) (CA, US) 423,077,058 414,654,953 -2 130,518,101 73 12,715,615 5 271,417,257 -19

Nitric acid/Nitrate compounds (CA, US) 282,522,125 261,770,018 -7 186,440,364 -2 6,194,076 -40 69,133,880 -15

Hydrochloric Acid (CA, US) 278,784,924 106,476,066 -62 100,709,277 -62 618,974 25 5,141,870 -61

Methanol (CA, US) 235,980,973 181,871,475 -23 82,718,244 -23 8,602,919 42 90,392,584 -26

Manganese (and compounds) (CA, US) 201,483,436 520,948,260 159 390,269,583 424 36,360,643 -16 94,295,640 13

Ammonia, Total (CA, US) 168,634,168 166,025,660 -2 146,010,710 -3 5,197,391 1 14,800,877 17

Sulfuric Acid (CA, US) 167,319,200 137,997,148 -18 61,167,004 -26 1,751,106 -80 75,047,148 0

Total, Top 10 Pollutants 3,402,461,081 3,617,994,246 16 1,888,402,676 22 645,943,177 43 1,083,295,622 -8

Total, All Pollutants 4,833,498,433 5,530,710,253 14 2,879,335,208 24 930,493,737 42 1,719,727,915 -8

%, Top Pollutants, of All Pollutants 70 65 66 69 63

*Sum of On-site Releases to Air, Water, Land, and Underground Injection. 

**Sum of Transfers to Recycling and Other Transfers. 

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.
14 Commission for Environmental Cooperation

decrease in reporting from the sector that provides support 

services to mining and oil and gas extraction. In fact, these 

data are related: a few of the top facilities reported their 

releases and transfers through 2009 under the NAICS code 

for support activities for mining and oil and gas extraction; 

however, on the basis of guidance provided by NPRI, these 

facilities reported under the NAICS code for oil and gas 

extraction in 2010. One of these facilities, Spectra Energy 

Transmission’s Kwoen gas plant in British Columbia, 

accounted for almost one-third of the total reported by the 

sector that year. 

North American electric utilities saw a decrease of 33 percent in total reported releases and transfers from 2005 

through 2010. Figure 4 reveals that this was a top sector in 

Mexico and the United States, but not in Canada. This can 

be attributed to the fact that in Canada, approximately 60 

percent of the electricity produced is from hydroelectric 

power plants, while in the United States and Mexico about 

half of the electric power is derived from the combustion 

of coal and petroleum, respectively.8

 Total reported releases 

and transfers from this sector increased by 176 percent in 

Mexico (mainly due to reporting by one electric utility in 

Baja California), but decreased by 36 percent in the United 

States and 22 percent in Canada.

Table 4. Top Industry Sectors Reporting to the North American PRTRs, 2005–2010: 

Total Releases and Transfers 

Industry Sector

NAICS-4 

Code

Total Releases 

and Transfers 

2005 (kg)

Total Releases 

and Transfers 

2006 (kg)

Total Releases 

and Transfers 

2007 (kg)

Total Releases 

and Transfers 

2008 (kg)

Total Releases 

and Transfers 

2009 (kg)

Total Releases 

and Transfers 

2010 (kg)

% Change 

2005-2010

Metal Ore Mining 2122 579,082,564 959,468,670 891,780,223 963,602,162 946,806,807 1,209,414,482 109

Electric Power Generation, 

Transmission, Distribution 2211 527,061,796 507,666,843 502,207,870 455,438,263 369,374,147 352,112,292 -33

Basic Chemical Manufacturing 3251 350,468,597 358,451,753 331,395,331 316,779,254 269,178,727 291,320,541 -17

Iron and Steel Mills 

and Ferroalloy Manufacturing 3311 312,281,935 326,250,943 335,333,978 324,699,283 234,061,306 307,514,746 -2

Oil and Gas Extraction 2111 299,959,066 352,648,093 425,045,364 519,514,573 521,838,245 975,143,329 225

Support Activities for Mining 

and Oil and Gas Extraction 2131 275,449,433 291,148,385 350,015,825 436,929,233 430,632,041 1,704,958 -99

Nonferrous Metal (except 

Aluminum) Product/Processing 3314 264,792,816 354,836,292 317,299,626 315,491,899 274,146,732 362,220,896 37

Waste Treatment and Disposal 5622 228,270,716 213,420,808 212,877,357 198,627,485 169,597,797 198,450,011 -13

Pulp, Paper, and Paperboard Mills 3221 144,571,800 137,973,131 133,797,656 127,707,178 119,378,035 124,141,452 -14

Water, Sewage and Other Systems 2213 129,606,665 126,646,951 130,512,863 137,716,716 132,559,661 131,651,071 2

Total, Top 10 Sectors 3,111,545,388 3,628,511,869 3,630,266,092 3,796,506,046 3,467,573,498 3,953,673,778 27

Total, All Sectors 4,833,498,433 5,458,622,690 5,439,460,679 5,392,090,187 4,829,435,749 5,530,710,253 14

%, Top Sectors, of All Sectors 64 66 67 70 72 71

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.

However, there were differences among the three countries 

in the top reporting sectors (see Figure 4). For example, 

while releases and transfers reported by the North American metal ore mining sector increased dramatically from 

2005 through 2010, this increase reflects reporting in 

Canada and the United States but not Mexico (where this 

sector saw a 99 percent decrease in reported releases and 

transfers). The notable increase in Canada can be attributed 

in part to the change in NPRI reporting requirements for 

mining activities mentioned above. In the United States, 

metal ore mining remained the top reporting sector during 

this period, with reported releases and transfers increasing 

by 30 percent.

Similarly, the 225 percent increase in releases and transfers 

in the oil and gas extraction sector was driven by Canadian 

facilities, which accounted for 99.9 percent of the total for 

this sector each year (with Mexican facilities reporting relatively minor amounts). US data for oil and gas extraction 

activities, a large sector in that country, are absent due to the 

fact that this sector is not subject to TRI reporting. Table 4 

shows that there was a gradual increase, from 2005 through 

2009, in reported releases and transfers from the Canadian oil and gas extraction sector, followed by a substantial 

increase in 2010. That same year, there was a significant 

8. CEC. 2011. North American power plant air emissions. Montreal, Canada: Commission for Environmental Cooperation.
Taking Stock North American Pollutant Releases and Transfers Vol. 14 15

Canada NPRI

Oil and Gas Extraction 

(+225%)

Support for Mining/ 

Oil & Gas Extraction 

(-99%)

Water, Sewage and 

Other Systems 

(+3%)

Metal Ore Mining 

(+13,139%)

Coal Mining 

(+)

Nonferrous Metal (except Alum.) 

Production and Processing 

(+187%)

1,000,000,000

800,000,000

600,000,000

400,000,000

200,000,000

2005 299,919,154 275,449,400 124,929,544 73,805,420 3,911,707 0

2010 974,659,355 1,634,640 129,188,055 211,921,905 517,883,420 104,375,023

Kilograms

Figure 4. Top Reporting Industry Sectors in Canada, Mexico and the United States, 2005–2010: 

Total Releases and Transfers

Mexico RETC

Metal Ore Mining 

(-99%)

Electric Power Generation, 

Transmission and 

Distribution (+176%)

Other Electrical 

Equipment/Component 

Manufacturing (-15%)

Motor Vehicle Parts 

Manufacturing 

(+30%)

Foundries 

(+794%)

Plastics Product 

Manufacturing 

(-77%)

45,000,000

40,000,000

35,000,000

30,000,000

25,000,000

20,000,000

15,000,000

10,000,000

5,000,000

2005 43,179,839 6,102,060 6,029,412 3,379,851 1,847,018 369,879

2010 260,372 16,868,339 5,098,791 765,252 2,408,444 3,307,202

Kilograms
16 Commission for Environmental Cooperation

In Mexico, the plastics product manufacturing sector, which 

ranked fourth for total releases and transfers in that country 

in 2005, reported a decrease of 77 percent over this period—

due mainly to one facility, which reported a large amount in 

2005 but did not report in 2010. Other Mexican industry sectors reporting large increases in releases and transfers over 

this period included foundries and waste collection services. 

1.4.3 Changes in the Number of Facilities Reporting to the North 

American PRTRs, 2005–2010

From 2005 through 2010, the number of facilities reporting9

 to the North American PRTRs decreased (Table 1). In 

2010, a total of 22,612 facilities across North America (80 

percent of them located in the United States) reported to the 

three PRTRs, as compared with 25,519 facilities in 2005—a 

decrease of almost 3,000 facilities, with most of this decrease 

(2,651 facilities) occurring in the United States. An examination of the industry sectors with the largest changes in the 

number of reporting facilities can provide insight into the 

impacts of these changes on reported releases and transfers 

over this period.

The United States and Canada 

Both Canada and the United States saw decreases in the total 

number of reporting facilities between 2005 and 2010. The 

ten industry sectors in both countries with the largest such 

decreases are shown in Table 5. These sectors accounted for 

just over half of the total decrease in the number of reporting facilities in the two countries.

This table shows that there were reductions in releases 

and transfers reported by each of these industry sectors. 

The data for certain sectors suggest that a relatively small 

number of facilities were drivers of these decreases. For 

example, the cement and concrete product manufacturing sector had a small decrease in the number of reporting facilities, but a 72 percent reduction in releases and 

transfers. In 2005, three US cement plants, the Buzzi 

Unicem facility in Indiana and two Holcim plants in 

Missouri and Michigan, reported a combined total of 

approximately 9.5 million kilograms (or 58 percent of the 

total for this sector). By 2010 the Holcim facility in Missouri had closed and the Buzzi Unicem plant reported 

about 570,000 kilograms. 

US TRI

Metal Ore Mining 

(+30%)

Electric Power Generation, 

Transmission, Distribution 

(-36%)

Basic Chemical 

Manufacturing 

(-12%)

Waste Treatment 

and Disposal 

(-27%)

Nonferrous Metal 

(except Alum.) Production 

and Process. (-21%)

Iron and Steel Mills and 

Ferroalloy Manufacturing 

(-3%)

800,000,000

700,000,000

600,000,000

500,000,000

400,000,000

300,000,000

200,000,000

100,000,000

2005 531,991,018 501,667,073 319,599,662 284,640,394 195,258,945 190,608,625

2010 691,270,690 320,192,562 280,699,601 275,999,851 142,663,519 149,900,020

Kilograms

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.

9. Note that “reporting facilities” refers to those reporting at least 0.0001 kilograms in total releases and transfers.
Taking Stock North American Pollutant Releases and Transfers Vol. 14 17

The motor vehicle parts manufacturing sector reported 

the largest proportions of releases and transfers in both 

2005 and 2010, but saw a 47 percent decrease in these 

amounts, with almost one-third fewer reporting facilities. 

However, as with the cement sector, a small number of 

facilities accounted for much of the reported decrease by 

this sector—including a couple of Canadian facilities that 

reported the largest proportions in 2005, but no releases 

and transfers in 2010. 

While there was a net decrease in reporting facilities in 

these two countries, certain industry sectors saw increases. 

The ten sectors with the largest such increases are shown in 

Table 6. 

Table 5. Industry Sectors with the Largest Decreases in the Number of Reporting Facilities, US TRI 

and Canadian NPRI, 2005–2010

Industry Sector (NAICS-4 Code) 

Number of 

Reporting 

Facilities 2005

Number of 

Reporting 

Facilities 2010

Difference 

2005–2010

Total Releases 

and Transfers 

2005 (kg)

Total Releases 

and Transfers 

2010 (kg)

% Change 

2005-2010 

Plastics Product Manufacturing (3261) 1,240 1,027 -213 48,867,077 47,384,513 -3

Coating, Engraving, Heat Treating& Allied Activities (3328) 1,057 874 -183 57,611,459 37,905,152 -34

Motor Vehicle Parts Manufacturing (3363) 888 627 -261 104,401,166 55,389,761 -47

Semiconductor & Other Electronic Component Mfg (3344) 856 646 -210 33,927,682 22,450,784 -34

Foundries (3315) 739 583 -156 53,024,387 37,645,384 -29

Paint, Coating, and Adhesive Manufacturing (3255) 713 571 -142 39,013,111 22,488,193 -42

Other Chemical Product/Preparation Mfg (3259) 704 572 -132 44,696,169 32,587,609 -27

Cement and Concrete Product Manufacturing (3273) 687 599 -88 16,291,297 4,633,081 -72

Household/Instit'l Furniture & Kitchen Cabinet Mfg (3371) 242 145 -97 8,218,724 3,720,411 -55

Motor Vehicle Body and Trailer Manufacturing (3362) 215 131 -84 6,730,858 5,171,531 -23

Total, Top 10 Sectors with Decreases 7,341 5,775 -1,566 412,781,931 269,376,419 -35

%, Top Sectors, of Total Releases and Transfers 9 5

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.

Table 6. Industry Sectors with the Largest Increases in the Number of Reporting Facilities, US TRI 

and Canadian NPRI, 2005–2010

Industry Sector (NAICS-4 Code)

Number of 

Reporting 

Facilities 2005

Number of 

Reporting 

Facilities 2010

Difference 

2005–2010

Total Releases 

and Transfers 

2005 (kg)

Total Releases 

and Transfers 

2010 (kg)

% Change 

2005–2010

Basic Chemical Manufacturing (3251) 1,055 1,139 84 349,808,622 290,724,530 -17

Dairy Product Manufacturing (3115) 370 383 13 17,466,685 19,566,429 12

Machine Shops, Turned Product & Screw, Nut, Bolt Mfg (3327) 235 247 12 21,895,382 21,808,879 0

Agriculture, Construction, & Mining Machinery Mfg (3331) 234 240 6 10,091,755 44,790,625 344

Defence Services/National Security & Internat'l Affairs (9111/9281)* 204 298 94 13,173,252 16,254,943 23

Metal Ore Mining (2122) 113 166 53 535,902,725 1,209,154,110 126

Coal Mining (2121) 49 71 22 8,675,395 109,080,080 1,157

Remediation and Other Waste Management Services (5629) 27 58 31 6,055,107 91,797,630 1,416

Nonmetallic Mineral Mining and Quarrying (2123) 17 56 39 258,465 54,842,914 21,119

Warehousing and Storage (4931) 8 25 17 83,676 131,002 57

Total, Top 10 Sectors with Increases 2,312 2,683 371 963,411,064 1,858,151,142 93

%, Top Sectors, of Total Releases and Transfers 20 34

* NAICS codes for Defence Services and National Security differ between the United States and Canada. 

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.
18 Commission for Environmental Cooperation

Table 7. Industry Sectors with the Largest Changes in the Number of Reporting Facilities, Mexican 

RETC, 2005–2010

Industry Sector (NAICS-4 Code)

Number of 

Reporting 

Facilities 2005

Number of 

Reporting 

Facilities 2010

Difference 

2005–2010

Total Releases 

and Transfers 

2005 (kg)

Total Releases 

and Transfers 

2010 (kg)

% Change 

2005–2010

Motor Vehicle Parts Manufacturing (3363) 177 145 -32 1,847,018 2,408,444 30

Pipeline Transportation of Crude Oil (4861) 76 78 2 34,581 40,642 18

Pharmaceutical and Medicine Manufacturing (3254) 71 86 15 511,453 425,087 -17

Basic Chemical Manufacturing (3251) 67 69 2 659,975 596,011 -10

Foundries (3315) 60 63 3 369,879 3,307,202 794

Other Chemical Product and Preparation Manufacturing (3259) 60 58 -2 154,571 139,949 -9

Semiconductor and Other Electronic Component Manufacturing (3344) 60 33 -27 263,280 109,817 -58

Electric Power Generation, Transmission and Distribution (2211) 46 69 23 6,102,060 16,868,339 176

Coating, Engraving, Heat Treating, and Allied Activities (3328) 45 65 20 418,744 277,759 -34

Other Electrical Equipment and Component Manufacturing (3359) 40 28 -12 6,029,412 5,098,791 -15

Resin, Synthetic Rubber, Artificial Synthetic Fibers/Filaments Mfg (3252) 33 32 -1 175,723 139,180 -21

Plastics Product Manufacturing (3261) 31 44 13 3,379,851 765,252 -77

Beverage Manufacturing (3121) 29 42 13 43,688 35,656 -18

Metal Ore Mining (2122) 28 39 11 43,179,839 260,372 -99

Waste Collection (5621) 26 38 12 4,094 1,473,352 35,885

Total, Top 15 Sectors with Changes 849 889 40 63,174,169 31,945,855 -49

%, Top Sectors, of Total Releases and Transfers 97 91

For most of the sectors shown in this table, there was a wide 

variation in the changes in reported releases and transfers 

between 2005 and 2010. As with the preceding table, the 

data for certain sectors suggest that a small number of 

facilities were drivers of these changes. For example, the 

number of facilities in the agriculture, construction and 

mining machinery manufacturing sector increased slightly 

over this period, while total reported releases and transfers increased by 344 percent. One Texas facility, Baker 

Hughes Rankin, which provides services to the oil and gas 

industry, reported a notable increase in 2010—with over 

24 million kilograms of metals and other pollutants transferred for recycling that year (or more than half of the total 

reported by that sector). 

Similarly, the coal mining sector saw an increase of about 

45 percent in the number of reporting facilities, but a 1,157 

percent increase in reported releases and transfers. Thirteen 

Canadian facilities reported over 100 million kilograms, 

or about 95 percent of the total for this sector in 2010. As 

mentioned earlier, Canadian coal mines began to report in 

2006, the year in which NPRI removed the reporting exemption for mining extraction and crushing activities. This new 

requirement had a significant impact on the increase in 

reported amounts for this sector. One facility, the Coal Valley 

Resources–Obed mine in Alberta, reported more than 80 

million kilograms in 2010 and accounted for most of the 

increase for this sector shown in Table 6.10 A small number of 

facilities in Canada also accounted for most of the substantial 

increase in reported releases and transfers by the nonmetallic 

mineral mining and quarrying sector. They included phosphate and potash mines in Ontario and Saskatchewan that 

supply manufacturers of fertilizer and agricultural products; 

and three diamond mines in the Northwest Territories.

The metal ore mining sector accounted for the largest 

releases and transfers in both 2005 and 2010, reporting a 126 

percent increase over this period. There was also an increase 

in the number of reporting metal ore mining facilities, and 

a small number of mines in Canada that did not report in 

2005 were among the top reporting facilities in 2010, with 

much of this change also due to the removal of the NPRI 

exemption for mining activities in 2006.

Mexico

The number of reporting facilities in Mexico saw wide yearto-year fluctuations over the 2005–2010 period (see Table 1) 

and therefore it is difficult to obtain a consistent picture of 

the direction of changes that occurred in PRTR reporting in 

that country. As mentioned earlier, the steep learning curve 

for Mexico’s RETC (with many facilities not reporting in 

the first year or two of the program) has contributed to the 

PRTR data variability for that country. 

Table 7 shows the sectors in Mexico with the largest number 

of reporting facilities over this period, and the changes from 

10. NPRI has flagged this as a likely reporting error (with the actual amount being orders of magnitude lower).
Taking Stock North American Pollutant Releases and Transfers Vol. 14 19

2005 to 2010 (disregarding the fluctuations in the interim 

years). These 15 sectors represented 97 percent and 91 percent, respectively, of total releases and transfers reported by 

all sectors in that country in 2005 and 2010. 

This table reveals that the net number of reporting facilities in these 15 Mexican industry sectors increased by about 

5 percent, while their total reported releases and transfers 

decreased by 49 percent, indicating that a relatively small 

number of facilities played a major role in the changes in 

releases and transfers over this period. Indeed, of total 

releases and transfers reported by the top 15 sectors, metal 

ore mining accounted for over 68 percent in 2005, but less 

than 1 percent in 2010. Two facilities, Compañίa Fresnillo 

in Chihuahua, and Compañίa Minera Nuevo Monte in 

Hidalgo, involved primarily in the extraction of lead, zinc 

and silver, accounted for almost all reported releases and 

transfers reported by this sector in 2005. Compañίa Fresnillo did not report after 2005, and is currently examining 

the possibility that it overestimated its reported data for that 

year; while Compañίa Minera Nuevo Monte did not report 

after 2007 and has since ceased to operate.11 

Changes in releases and transfers from other industry sectors in Mexico also showed the impacts of reporting by a 

small number of facilities. For example, the foundry sector 

showed a small increase in the number of reporting facilities, 

but a 794 percent increase in reported releases and transfers. 

Relatively few facilities accounted for a large proportion of 

this increase, with many of the facilities that reported in 

2005 no longer reporting in 2010, and vice versa. Similarly, 

one electric utility—a Comisión Federal de Electricidad

(CFE) facility located in Baja California—accounted for 

much of the increase reported by the electricity generation 

sector over this period. The facility reported more than 73 

percent of all releases and transfers by this sector in 2010, 

but did not report in 2005. 

Table 8 presents some of the facilities in Mexico that 

reported large releases and transfers in either 2005 or 

2010, but not both years. It illustrates the impact of certain facilities on total reported releases and transfers in 

that country, with just five facilities accounting for 77 percent of total releases and transfers reported by all sectors 

in 2005, and another five facilities accounting for 53 percent of total releases and transfers reported by all sectors in 

2010.12 There can be a number of reasons for inconsistent 

reporting by facilities, such as the aforementioned learning 

curve in relation to PRTR reporting; changes in estimation methodologies; a start-up, slowdown, or shutdown of 

operations at some point during the period in question; 

changes in industrial processes that can affect the amounts 

or the pollutants reported; and a lack of compliance with 

reporting requirements. 

Table 8. Releases and Transfers from Mexican Facilities Reporting in 2005 or 2010, but Not Both Years

Facility Name PRTR ID State Industry Sector

Total Releases 

and Transfers 

2005 (kg)

Total Releases 

and Transfers 

2010 (kg)

Compañia Fresnillo, S.A. de C.V. FRE140806211 Chihuahua Metal Ore Mining 36,235,208 –

Compañía Minera Nuevo Monte MNMMK1308411 Hidalgo Metal Ore Mining 6,774,926 –

Flextronics Plastics, S.A. de C.V. FPLMA1412011 Jalisco Plastics Product Manufacturing 3,206,344 –

Enertec Mexico, S. de R.L. de C.V. - Planta Monterrey EMC8Z1903911 Nuevo León Other Electrical Equipment and Component Mfg 2,345,644 –

Morestana, S.A de C.V MOR8I0100111 Aguascalientes Motor Vehicle Parts Manufacturing 1,476,444 –

Com. Federal de Electricidad, Campo y Central Geoterm. 

Cerro Prieto CFEAD0200212 Baja California Electric Power Generation, Transmission, 

Distribution – 12,443,000

Monterrey Extrusions, S. de R.L. de C.V. MEX9M1901211 Nuevo León Motor Vehicle Parts Manufacturing – 2,079,946

Hornos de Fundición, S.A. de C.V. HFUTF2804011 Tamaulipas Waste Collection – 1,463,172

Lbq Foundry, S.A. de C.V LFOLJ2201411 Querétaro Foundries – 1,376,500

Enertec Exports, S. de R.L. de C.V. EEX8Z1901211 Nuevo León Other Electrical Equipment and Component Mfg – 1,321,078

Total, Top 5 Facilities Reporting in Either 2005 or 2010, Not Both Subtotal, 5 facilities 50,038,567 18,683,696

Total, All Facilities Reporting Total, all Mexican facilities 65,226,620 35,053,206

%, Top 5 Facilities, of Total Releases and Transfers 77 53

12. As mentioned earlier, Compañίa Fresnillo is looking into probable reporting errors for 2005. Similarly, the CFE–Campo y Central Geotérmico Cerro Prieto 

facility in Baja California is examining a possible issue involving reporting under two different PRTR identification numbers between 2005 and 2010 (personal 

communication with RETC officials, 2013).

11. Semarnat. 2013. Registro de Emisiones y Transferencia de Contaminantes (RETC). Personal communication with RETC officials, December 2013.
20 Commission for Environmental Cooperation
Taking Stock North American Pollutant Releases and Transfers Vol. 14 21

This chapter examines, in greater detail, the changes in pollutant releases and transfers reported by North American 

industrial facilities over the 2005–2010 period, including 

on-site releases (to air, water, land, and underground injection); off-site releases to disposal; transfers to recycling; and 

other transfers. The industrial sectors and facilities reporting the largest proportions of these releases and transfers, 

and their distribution among the three countries, are presented—often revealing gaps in the picture of North American industrial pollution resulting from national differences 

in PRTR reporting requirements, and other factors. 

In some cases, the data reveal notable changes in reporting 

by an industrial facility from one year to the next. These 

can be due to a variety of factors, including increases or 

decreases in production, or changes in waste management 

activities; implementation of pollution prevention or mitigation strategies; and so on. A major increase in reported 

data might also reflect reporting of an activity for the 

first time (for example, as a result of changes in reporting 

requirements), and not necessarily a change in the actual 

releases or transfers from a facility. While the reasons for 

important year-to-year changes in reporting are often not 

provided, readers should keep these considerations in mind. 

This chapter also presents data on releases to air and water 

of known or suspected carcinogens, developmental or reproductive toxicants, metals, and persistent, bioaccumulative and 

toxic substances (PBTs). Some of the pollutants in these four 

categories are considered to be of special concern because of 

their persistence in the environment, and/or their significant 

potential to cause harm to human health or the environment 

even when released in relatively small amounts. Taking Stock

provides toxicity-based information, in the form of toxicity 

equivalency potential (TEP) scores,13 for releases to air and 

water of some of these pollutants. Information about their 

chemical properties and how these substances are used or 

produced in industry is also provided. 

2.1 Reported Releases to Air, 2005–2010 

Releases to air accounted for 9 percent of total reported 

releases and transfers in 2010, with North American facilities reporting 514,173,851 kilograms (a decrease of 36 

percent from 2005 levels). Readers are reminded that the 

releases to air presented in this document exclude reporting 

of criteria air contaminants (CACs) to Canada’s NPRI, and 

greenhouse gases (GHGs) to Mexico’s RETC. Information 

about how to obtain data on releases of GHGs and CACs in 

the three countries is available in Appendix 1. 

Table 9 presents the releases to air reported by North American facilities every year from 2005 through 2010. It reveals differences among the three countries in the amounts reported 

and the direction of the 2005–2010 changes. For example, 

the decrease in releases to air over this period was driven 

by reporting in the United States (43 percent decrease) and 

to a lesser extent, Canada (7 percent decrease). In Mexico, 

reported releases to air increased by 204 percent. 

Of the total releases to air reported in 2005, Canadian facilities accounted for 14 percent, Mexican facilities for 0.7 

percent, and US facilities for 85 percent. By 2010 these proportions had changed, with Canadian facilities reporting 

almost 21 percent of the total, Mexican facilities reporting 

3.6 percent, and US facilities reporting 76 percent. 

Figure 5 illustrates the reported releases to air in each country in 2005 and 2010, as well as the top 20 reported pollutants and changes in their releases over the 6-year period. 

Chapter 2

Details of Reported Releases and Transfers, 2005–2010

13. For information on TEP scores, see section 2.3 and Appendix 1.

Table 9. Releases to Air Reported to the North American PRTRs, 2005–2010

PRTR

Releases to 

Air 2005 (kg)

Releases to 

Air 2006 (kg)

Releases to 

Air 2007 (kg)

Releases to 

Air 2008 (kg)

Releases to 

Air 2009 (kg)

Releases to 

Air 2010 (kg)

% Change 

2005–2010

Number of Reported Pollutants

2005 2010

Canada NPRI 113,025,812 108,863,320 115,196,383 113,966,665 107,318,775 105,473,559 -7 160 158

Mexico RETC 6,085,570 19,629,156 17,650,031 22,644,705 20,153,686 18,471,151 204 52 48

US TRI 688,060,669 643,276,983 605,320,375 522,750,666 419,098,466 390,229,141 -43 409 398

Total, 

North America 807,172,052 771,769,460 738,166,789 659,362,037 546,570,927 514,173,851 -36 446 445

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.
22 Commission for Environmental Cooperation

Figure 5. Releases to Air Reported in Canada, Mexico and the United States, and Top Reported 

Pollutants, 2005–2010 

 2005 

 2010 800,000,000

700,000,000

600,000,000

500,000,000

400,000,000

300,000,000

200,000,000

100,000,000

Kilograms

Canada NPRI

113,025,812 105,473,559

Mexico RETC

6,085,570 18,471,151

US TRI

390,229,141

688,060,669

Pollutant Releases to Air 2005 (kg) Releases to Air 2010 (kg) % Change 2005–2010

Hydrochloric Acid (CA, US) 264,854,293 99,871,342 -62

Methanol (CA, US) 86,891,338 59,539,501 -31

Sulfuric Acid (CA, US) 82,789,123 60,956,268 -26

Ammonia, Total (CA, US) 73,633,167 71,556,982 -3

Hydrogen Fluoride (CA, US) 37,592,308 20,406,613 -46

Toluene (CA, US) 29,113,207 17,367,509 -40

Styrene (CA, MX, US) 25,885,073 11,866,513 -54

n-Hexane (CA, US) 21,751,390 20,497,067 -6

Xylenes (CA, US) 21,305,370 11,793,636 -45

Carbonyl Sulfide (CA, US) 14,334,916 11,195,247 -22

Carbon Disulfide (CA, US) 11,851,707 8,399,476 -29

Ethylene (CA, US) 11,273,822 8,100,105 -28

Certain Glycol Ethers (US) 8,898,150 5,941,647 -33

Hydrogen Sulfide (CA, MX) 8,635,730 19,244,496 123

n-Butyl Alcohol (CA, US) 8,007,344 5,097,160 -36

Acetaldehyde (CA, MX, US) 7,273,669 4,730,047 -35

Formaldehyde (CA, MX, US) 7,135,349 3,572,996 -50

Propylene (CA, US) 6,511,391 4,700,635 -28

Zinc (and compounds) (CA, US) 3,915,861 3,500,678 -11

Total Reduced Sulfur (TRS) (CA) – 15,522,608 50*

Total, Top 20 Pollutants Released to Air 731,653,208 463,860,527 -37

Total, All Pollutants Released to Air 807,172,052 514,173,851 -36

%, Top Pollutants, of Total Releases to Air 91 90

*

 Percent change calculated from 2007 (first year of TRS reporting in Canada).

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.
Taking Stock North American Pollutant Releases and Transfers Vol. 14 23

These pollutants accounted for 91 percent and 90 percent, 

respectively, of total reported releases to air in 2005 and 

2010. Almost all of them saw decreases over this period, 

with the exception of hydrogen sulfide and TRS (with the 

latter only subject to reporting as of 2007). Releases to air 

of hydrochloric acid accounted for the largest proportion 

(almost 33 percent) of the total in 2005, but by 2010 releases 

of this pollutant had declined and accounted for just over 

19 percent of the total. This figure also reveals that of the 

pollutants shown, only acetaldehyde, formaldehyde and styrene are subject to the PRTRs of all three countries.

2.1.1 Top Sectors Reporting Releases to Air in North America, 

2005–2010 

The five North American industry sectors reporting the 

largest proportions of total releases to air from 2005 through 

2010 are shown in Figure 6. These sectors accounted for 

335,413,595 kilograms, or 65 percent of the total in 2010, 

with electric utilities alone reporting 32 percent. 

However, there were differences among the three countries 

in the sectors reporting the largest releases to air. Figure 

7 shows that the notable decrease in releases to air from 

electric utilities can be attributed to power plants in the 

United States (56 percent decrease) and Canada (29 percent 

decrease), while releases to air from this sector in Mexico 

increased by about 196 percent. As mentioned earlier, one 

electric utility, the CFE–Campo y Central Geotérmico 

Cerro Prieto facility in Baja California accounted for much 

of the reported increase. Electric utilities accounted for the 

largest proportions (i.e., between 80 percent and 92 percent) 

of total releases to air reported in that country every year 

between 2005 and 2010. 

The oil and gas extraction sector, which by 2010 had 

replaced pulp, paper and paperboard mills as the topranked sector for releases to air in Canada, was not among 

the top reporting sectors in the other countries. It reported 

a 154 percent increase in releases to air over this period 

(see Fig. 7), partly due to the addition in 2007 of TRS 

compounds to the NPRI list of substances. The oil and 

gas extraction sector, along with TRS, is not subject to 

reporting under the US TRI; while in Mexico, the lack of 

reported data from this sector suggests incomplete reporting, since it is not exempt from the RETC.

350

300

250

200

150

100

50

Millions of Kilograms

Electric Power Generation, 

Transmission and Distribution 

(-51%)

Pulp, Paper, and 

Paperboards Mills 

(-19%)

Basic Chemical 

Manufacturing 

(-25%)

Oil and Gas Extraction 

(+157%)

Pesticide, Fertilizer, 

and Other Agricultural 

Chemical Manufacturing 

(-1%)

Sector (percent change between 2005 and 2010)

 2005 

 2006

 2007 

 2008

 2009 

 2010

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.

Figure 6. Top Reporting Industry Sectors for Releases to Air, North America, 2005–2010
24 Commission for Environmental Cooperation

Mexico RETC

18,000,000

16,000,000

14,000,000

12,000,000

10,000,000

8,000,000

6,000,000

4,000,000

2,000,000

Kilograms

2005 5,554,760 120,042 42,402

2010 16,419,094 65,073 430,022

Resin, Synthetic Rubber, 

Artificial Fibers Manufacturing (-46%)

Electric Power Generation, 

Transmission, Distribution (+196%) 

Plastics Product 

Manufacturing (+914%)

US TRI

350,000,000

300,000,000

250,000,000

200,000,000

150,000,000

100,000,000

50,000,000

Kilograms

2005 324,741,379 73,805,730 40,121,615

2010 141,759,342 57,897,138 31,085,976

Pulp, Paper, and 

Paperboard Mills (-22%)

Electric Power Generation, 

Transmission, Distribution (-56%)

Basic Chemical Manufacturing 

(-23%)

Figure 7. Top Reporting Industry Sectors for Releases to Air in Canada, Mexico and the United States, 

2005–2010

Canada NPRI 

35,000,000

30,000,000

25,000,000

20,000,000

15,000,000

10,000,000

5,000,000

Kilograms

2005 18,842,150 12,193,949 9,893,416

2010 17,197,471 30,979,096 7,063,583

Pulp, Paper, and Paperboard Mills 

(-9%) 

Electric Power Generation, 

Transmission, Distribution (-29%)

Oil and Gas Extraction 

(+154%)

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.
Taking Stock North American Pollutant Releases and Transfers Vol. 14 25

Table 10 presents the top pollutants released to air by the 

top five North American industry sectors, which together 

accounted for 65 percent of total releases to air in 2010; the 

distribution of reporting among the three countries; and the 

changes in these releases from 2005 through 2010. The data 

illustrate the impacts of differences among national PRTR 

reporting requirements, with hydrogen sulfide being the 

only pollutant in this table that is subject to PRTR reporting 

in Mexico.

Electric utilities—the majority of them located in the United 

States—accounted for the largest proportions of releases to 

air of hydrochloric acid and sulfuric acid. These pollutants 

are associated with the combustion of fossil fuels such as 

coal, oil and natural gas, which are used more extensively in 

the United States and Mexico for the production of electricity. In contrast, more than half of Canada’s power is derived 

from hydroelectricity. By 2010, electric utilities had cut their 

releases of hydrochloric acid and sulfuric acid by 67 percent 

and 20 percent, respectively. These two substances are subject to PRTR reporting in Canada and the United States, but 

not Mexico. Hydrochloric acid and sulfuric acid can react in 

the atmosphere to create acid rain, and can cause respiratory 

problems. A number of factors, including regulations for air 

pollutants from the burning of fossil fuels, contributed to 

the decreases in releases by this sector in both Canada and 

the United States (see section 2.1.2). 

Mexican electric utilities accounted for almost 100 percent of all reported releases to air of hydrogen sulfide, with 

these releases increasing by about 196 percent from 2005 

through 2010 (see Figure 7). A CFE facility in Baja California accounted for most of this increase (see Table 9). It is a 

geothermal facility and hydrogen sulfide is one of the gases 

contained in the geothermal stream. This pollutant has the 

characteristic odor of rotten eggs and occurs naturally in 

crude petroleum, natural gas and volcanic gases; it is also a 

byproduct of industrial activities (e.g., petroleum refining). 

Certain Canadian electric utilities (especially one co-generation facility in Sarnia, Ontario) reported relatively small 

amounts of this pollutant, which is not subject to reporting 

under the US TRI.

Pulp, paper and paperboard mills (with most reporting facilities located in the United States and Canada) 

accounted for 14 percent of total air releases in 2010. 

This sector reported a 19 percent decrease in releases to 

air from 2005 through 2010 (see Table 28), including substantial decreases of methanol, the top reported pollutant. 

Substances typically released to air during the wood pulping and bleaching processes, such as methanol and ammonia, have been the subject of regulatory controls in both 

countries (see Chapter 3). Methanol, a volatile organic 

compound (VOC), can contribute to the formation of photochemical smog when it reacts with other volatile organic 

Table 10. Top Reporting Industry Sectors for Releases to Air, and Top Reported Pollutants, 

North America, 2005–2010 

Industry Sector (NAICS-4 Code)

Releases to 

Air 2010 (kg) Pollutant

Releases to 

Air 2010 (kg)

% Change 

2005–2010

Canada 

NPRI (%)

Mexico 

RETC (%)

US 

TRI (%)

Electric Power Generation, Transmission 

and Distribution (2211) 165,242,019

Hydrochloric Acid (CA, US) 77,951,337 -67 4 -- 96

Sulfuric Acid (CA, US) 48,342,390 -20 3 -- 97

Hydrogen Sulfide (CA, MX) 16,254,130 197 0.01 99 --

Pulp, Paper, and Paperboard Mills (3221) 75,094,700

Methanol (CA, US) 46,608,814 -23 19 -- 81

Hydrochloric Acid (CA, US) 7,993,865 -12 22 -- 78

Ammonia, Total (CA, US) 7,811,700 -17 20 -- 80

Basic Chemical Manufacturing (3251) 33,092,402

Ethylene (CA, US) 4,796,351 -29 10 -- 90

Ammonia, Total (CA, US) 4,265,469 4 3 -- 97

Carbonyl Sulfide (CA, US) 3,953,646 -32 0 -- 100

Oil and Gas Extraction (2111) 31,376,515

Total Reduced Sulfur (TRS) (CA) 10,765,681 212* 100 -- --

Carbon Disulfide (CA, US) 4,356,566 136 100 -- --

Xylenes (CA, US) 3,308,466 323 100 -- --

Pesticide, Fertilizer, and Other Agricultural 

Chemical Mfg. (3253) 30,607,959

Ammonia, Total (CA, US) 27,023,573 0 32 -- 68

Methanol (CA, US) 1,125,870 -39 34 -- 66

Hydrogen Fluoride (CA, US) 682,277 20 7 -- 93

Total, Top 5 Sectors 335,413,595 Total, Top Pollutants 265,240,134

%, Top 5 Sectors, of Total Releases to Air 65

*

 Percent change calculated from 2007 (first year of TRS reporting in Canada).

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution. 
26 Commission for Environmental Cooperation

substances in air. It is also used in the production of formaldehyde and other chemicals, as a solvent or antifreeze, 

and is present in other products. 

Table 10 also reveals that ammonia accounted for approximately 88 percent of total annual releases to air reported by 

the pesticide, fertilizer and other agricultural chemical manufacturing sectors, with most reporting facilities located in 

the United States. Releases to air of ammonia are associated 

with a number of health and environmental effects, including respiratory illnesses, damage to vegetation and the formation of acid rain. This industry sector also reported a 20 

percent increase in releases to air of hydrogen fluoride, a 

by-product released during the manufacturing of phosphate 

fertilizer. As mentioned, of the top 20 reported pollutants 

released to air between 2005 and 2010, only acetaldehyde, 

formaldehyde and styrene are common to the three North 

American PRTRs. These substances are all known or suspected carcinogens.

Table 11 provides information about the industry sectors 

in each country that reported the largest releases to air 

of these three pollutants, and the 2005–2010 changes. It 

reveals similarities, as well as differences—for example, 

the pulp, paper and paperboard mills sector reported 

the largest releases to air of acetaldehyde in both Canada 

and the United States, with reductions in these releases 

between 2005 and 2010. Trace quantities of acetaldehyde 

may be coincidentally manufactured by pulp, paper and 

paperboard mills during the chemical pulping process, 

after which it may be released to air. In Mexico, the resin 

and synthetic rubber manufacturing sector reported the 

largest releases to air of this pollutant. Acetaldehyde is 

used in the synthesis of other chemicals (e.g., resins), and 

is formed as a product of incomplete combustion, coal refining, and waste processing.  

In Canada and the United States, releases to air of formaldehyde were reported in largest proportions by the veneer, 

plywood and engineered wood product manufacturing 

sector, with reductions in these releases from 2005 through 

2010. By contrast, this pollutant was reported released to air 

in largest proportions by Mexican electric utilities, which 

reported an increase of 107 percent in these releases. Formaldehyde is used in urea-formaldehyde resins and glues that 

are sometimes used in wood panel production; as a preservative in some foods; and in household products such as 

antiseptics and cosmetics. It is also formed from the combustion of fossil fuels and other materials.

The plastics product manufacturing sector accounted for 

the largest proportions of total air releases of styrene in the 

three countries, with the largest amounts reported by US 

facilities. There was a large increase in releases to air of styrene from this sector in Mexico, mainly from one facility in 

Nuevo León which started reporting to RETC in 2008. Plastics product manufacturers in Canada and the United States 

reported large decreases in releases to air of styrene between 

2005 and 2010. Styrene is used mainly in the production of 

polystyrene plastics and resins.

Table 11. Top Reporting Industry Sectors for Releases to Air of Pollutants Common to NPRI, RETC 

and TRI, 2005–2010 

Pollutant PRTR Top Contributing Sectors, 2005 Releases to Air 2005 (kg) % Change 2005–2010 

Acetaldehyde

Canada NPRI Pulp, Paper, and Paperboard Mills 595,841 -35

Mexico RETC Resin, Synthetic Rubber, Artificial Synthetic Fibers Mfg 19,260 -56

US TRI Pulp, Paper, and Paperboard Mills 3,462,118 -32

Total Acetaldehyde, Top Sectors 4,077,219

Formaldehyde

Canada NPRI Veneer, Plywood, and Engineered Wood Prod. Mfg 1,734,235 -62

Mexico RETC Electric Power Generation, Transmission, Distrib. 76,140 107

US TRI Veneer, Plywood, and Engineered Wood Prod. Mfg 1,996,911 -70

Total Formaldehyde, Top Sectors 3,807,286

Styrene

Canada NPRI Plastics Product Manufacturing 1,995,760 -62

Mexico RETC Plastics Product Manufacturing 33,281 1,153

US TRI Plastics Product Manufacturing 11,703,435 -54

Total Styrene, Top Sectors 13,732,476

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.
Taking Stock North American Pollutant Releases and Transfers Vol. 14 27

2.1.2 Spotlight: Releases to Air from Electric Utilities, 2005–2010

The important decrease in reported releases to air in North 

America between 2005 and 2010 was largely driven by electric utilities, which reported a 51 percent decrease in such 

releases. Figure 8 illustrates this decrease and also reveals 

important differences among the three countries. For example, US utilities accounted for the majority of air releases from 

this sector between 2005 and 2010, and the largest decrease. 

Unlike Canada and the United States, Mexican power plants 

reported increases in releases to air over this period. 

Each country has a unique electricity generation profile 

involving different technologies and fuels (for example, about 

60 percent of Canada’s power is generated by hydroelectricity, 

while fossil fuels such as coal, oil and natural gas are more predominant in Mexico and the United States). Fossil fuel–based 

power plants are among the largest contributors of important 

air pollutants such as greenhouse gases, particulate matter, 

and mercury.14 Tables 12a and 12b present the reported pollutants released to air by North American electric utilities 

between 2005 and 2010. The pollutants in Table 12a are the 

top-reported substances by volume of release, while those 

14. CEC. 2011. North American power plant air emissions. Montreal, Canada: Commission for Environmental Cooperation.

Canada NPRI, Mexico RETC and US TRI

350,000,000

300,000,000

250,000,000

200,000,000

150,000,000

100,000,000

50,000,000

Kilograms

2005 9,893,416 5,554,760 324,741,379

2010 7,063,583 16,419,094 141,759,342

Canada NPRI (-29%) Mexico RETC (+196%) US TRI (-56%)

North America

Figure 8. Releases to Air Reported by North American Electric Utilities, 2005–2010

400,000,000

350,000,000

300,000,000

250,000,000

200,000,000

150,000,000

100,000,000

50,000,000

Kilograms

2005 2006 2007 2008 2009 2010

Year

340,189,556 330,691,086

314,965,271

265,973,822

201,817,581

165,242,019
28 Commission for Environmental Cooperation

in Table 12b are pollutants belonging to one or more of four 

categories (known or suspected carcinogens; developmental 

or reproductive toxicants; PBTs; and metals) and ranked by 

the highest TEP scores—in this case, for non-cancer risk. The 

TEP scores provide an indication of the potential toxicity of 

these pollutants, which accounted for less than 1 percent of 

the total volume of air releases in both 2005 and 2010, but 

almost 100 percent of the toxic loadings to air associated with 

health impacts of these emissions. 

The North American energy landscape has changed in the past 

decade, with fossil fuel–based electric utilities affected by new 

environmental regulations and rising fuel costs. In Canada, 

existing provincial regulations for criteria air contaminants and 

greenhouse gases and the Canada Wide Standards for mercury 

have played a major role in the decreases in releases to air from 

power plants. The Province of Ontario’s ongoing coal phaseout plan (to end the use of coal at Ontario’s electricity-generating facilities by 2014) has also had impacts. Most of Ontario’s 

coal-fired power plants have shut down or are in the process of 

doing so, and the remaining plants are considering converting 

to other fuel sources (e.g., biomass, natural gas). Under the new 

federal Reduction of Carbon Dioxide Emissions from Coal-fired 

Generation of Electricity Regulations, all Canadian coal-fired 

plants will be required, by the end of their useful life, to reduce 

emissions by installing carbon capture and storage technology, 

Table 12a. Releases to Air Reported by North American Electric Utilities, 2005–2010: 

Top Pollutants, by Volume

Pollutant Releases to Air 2005 (kg) Releases to Air 2010 (kg) % Change 2005–2010 

Hydrochloric Acid (CA, US) 237,819,753 77,951,337 -67

Sulfuric Acid (CA, US) 60,596,971 48,342,390 -20

Hydrogen Fluoride (CA, US) 29,645,060 15,335,709 -48

Hydrogen Sulfide (CA, MX) 5,474,617 16,254,130 197

Ammonia, Total (CA, US) 2,456,634 4,576,201 86

Barium (and compounds) (US) 795,843 623,686 -22

Zinc (and compounds) (CA, US) 671,614 353,473 -47

Vanadium (and compounds) (CA, US) 484,836 109,482 -77

Aluminum (fume or dust) (CA, US) 343,950 342,830 0

Nickel (and compounds) (CA, MX, US) 291,829 114,227 -61

Total, Top 10 Pollutants to Air 338,581,106 164,003,465

Total, All Pollutants to Air 340,189,556 165,242,019

%, Top Pollutants, of Total Sector Releases to Air 99 99

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.

Table 12b. Releases to Air Reported by North American Electric Utilities, 2005–2010: 

Top Pollutants, by TEP 

Pollutant

Releases to Air 

2005 (kg)

Releases to Air 

2010 (kg)

% Change 

2005–2010

Cancer Risk 

Score for Air 

(TEP) 2010

Non-cancer Risk 

Score for Air 

(TEP) 2010

Mercury (and compounds) (CA, MX, US) 45,832 31,736 -31 -- 444,300,261,677

Dioxins and Furans (CA, MX, US) 0.5663 0.4341 -37 520,945,141 382,026,436,811

Lead (and compounds) (CA, MX, US) 82,833 47,437 -43 1,328,237 27,513,488,365

Thallium (and compounds) (US) 2,671 1,555 -42 -- 18,656,308,636

Arsenic (and compounds) (CA, MX, US) 43,382 29,970 -31 479,526,627 2,517,514,790

Copper (and compounds) (CA, US) 87,346 57,237 -34 -- 744,083,885

Cadmium (and compounds) (CA, MX, US) 212 209 -1 5,437,331 397,343,396

Nickel (and compounds) (CA,MX, US) 291,829 114,227 -61 319,836 365,527,295

Cobalt (and compounds) (CA, US) 15,582 9,980 -36 -- 309,388,529

Chromium (and compounds) (CA, MX, US) 74,032 57,916 -22 7,529,040 179,538,645

Total, Top 10 Pollutants to Air 643,719 350,268 1,015,086,212 877,009,892,030

Total, All Pollutants to Air 340,189,556 165,242,019 1,016,650,145 877,879,947,256

%, Top Pollutants, of Total Sector Releases to Air 0.19 0.21 99 99

A “--” in place of a TEP score means that either the pollutant has a score of 0, or it has not been evaluated. 

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.
Taking Stock North American Pollutant Releases and Transfers Vol. 14 29

switching to lower-emitting fuel sources, or closing. It is estimated that by 2035, approximately half of all coal-generated 

electricity will be eliminated.15

In Mexico, electric utilities are regulated under the General 

Law of Ecological Equilibrium and Environmental Protection 

(Ley General de Equilibrio Ecológico y Protección al Ambiente—

LGEEPA), with maximum permissible limits for releases to air 

and water and disposal of solid and hazardous waste defined 

under official standards called Normas Oficiales Mexicanas

(NOMs). Electric utilities are also regulated under the Reglamento de la LGEEPA en Materia de Prevención y Control de la 

Contaminación de la Atmósfera (Regulation of the LGEEPA 

Concerning Prevention and Control of Atmospheric Pollution). It requires utilities to obtain operating licenses indicating 

details of regular monitoring and sampling activities for specific air pollutants, equipment and conditions to prevent and 

control air pollution, and so on. 

In the United States, the Clean Air Act and the National Emissions Standards for Hazardous Air Pollutants (NESHAPs), 

which place limits on releases of 183 pollutants, have incited 

many fossil fuel–based power plants to install pollution control technologies, or to shift to other fuel sources. This has 

resulted in significant decreases in releases to air of pollutants 

such as hydrochloric acid and sulfuric acid, the top-reported 

pollutants for fossil fuel–generated electric utilities in that 

country. In 2011, the US EPA finalized the Mercury and Air 

Toxics Standards (MATS) to reduce mercury and other toxic 

air pollution from coal- and oil-fired power plants.16

The maps in Figure 9 depict the diminishing intensity of 

releases to air reported by North American power plants 

between 2005 and 2010. In 2005, a total of 703 power plants 

reported releases to air (44 in Canada, 13 in Mexico, and 646 

in the United States). In 2010, 685 power plants reported: 53 

in Canada, 22 in Mexico, and 610 in the United States. 

15. Environment Canada. 2012. Reduction of carbon dioxide emissions from coal-fired generation of electricity regulations (SOR/2012-167). Online at: <www.ec.gc.ca/

lcpe-cepa/eng/regulations/detailreg.cfm?intReg=209>. Government of Ontario. 2013. Ending Coal for Cleaner Air Act, 2013. Online at: <www.ebr.gov.on.ca/ERSWEB-External/displaynoticecontent.do?noticeId=MTIxMDQ3&statusId=MTgxMTk5&language=en>.

16. US Environmental Protection Agency. 2011. Mercury and Air Toxics Standards (MATS). Online at: <www.epa.gov/mats/basic.html>.

Figure 9. Releases to Air Reported by North American Electric Utilities, by Year, 2005–2010

Note: The data used to create these maps exclude reported releases in Canada and Mexico of criteria air contaminants (CACs) and greenhouse gases (GHGs), which are not included in Taking Stock due to 

differences in national PRTR reporting requirements. Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.

2005

2008 2009

2006

2010

2007
30 Commission for Environmental Cooperation

2.2 Reported Releases to Water, 2005–2010 

Releases to water accounted for 4 percent of total reported 

releases and transfers in 2010, with North American facilities reporting 221,806,836 kilograms—a decrease of 5 percent from 2005 levels. 

Table 13 presents the releases to water reported by North 

American facilities every year from 2005 through 2010. Of 

total reported releases to water in 2005, Canada and the 

United States each accounted for over 49 percent, while Mexican facilities accounted for less than 1 percent. By 2010, the 

proportion reported by Canadian facilities had increased to 

almost 54 percent of the total, while the proportion reported 

by US facilities had dropped to just over 46 percent. An 

important consideration with respect to releases to water 

is that a key reporting sector in Canada, public water and 

wastewater treatment plants, is not subject to the US TRI. 

As shown below, this difference in national PRTR reporting 

requirements has a significant impact on the picture of industrial releases to water in North America. 

Figure 10 illustrates the reported releases to water in each 

country in 2005 and 2010, revealing the notable difference in 

the proportion reported by Mexican facilities, in comparison 

with Canada and the United States. In 2010 the proportion 

of releases to water reported by Mexican facilities remained 

almost the same as in 2005 (albeit with notable fluctuations 

in reported volumes in the intervening years). One reason 

for the relatively small volumes reported by Mexican facilities 

is that, of the top pollutants released to water shown in this 

figure, only six are subject to the RETC. This figure also shows 

that the top 20 pollutants accounted for more than 99 percent 

of total reported releases to water in 2005 and 2010, with two 

of them—nitric acid/nitrate compounds and ammonia—representing approximately 91 percent of the total. 

Table 13. Releases to Water Reported to the North American PRTRs, 2005–2010

PRTR

Releases 

to Water 

2005 (kg)

Releases 

to Water 

2006 (kg)

Releases 

to Water 

2007 (kg)

Releases 

to Water 

2008 (kg)

Releases 

to Water 

2009 (kg)

Releases 

to Water 

2010 (kg)

% Change 

2005-2010

Number of 

Reported Pollutants

2005 2010

Canada NPRI 116,942,451 114,787,399 117,849,702 123,617,457 119,281,087 119,144,134 2 85 87

Mexico RETC 171,752 442,353 544,461 2,224,441 255,694 140,153 -18 16 14

US TRI 116,889,567 114,758,518 109,661,271 113,344,183 94,338,147 102,522,550 -12 249 210

Total, North America 234,003,770 229,988,270 228,055,434 239,186,081 213,874,929 221,806,836 -5 276 247

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.
Taking Stock North American Pollutant Releases and Transfers Vol. 14 31

Figure 10. Releases to Water Reported in Canada, Mexico and the United States, 

and Top Reported Pollutants, 2005–2010

Pollutant Releases to Water 2005 (kg) Releases to Water 2010 (kg) % Change 2005–2010 

Nitric Acid and Nitrate Compounds (CA, US) 156,090,931 152,163,831 -3

Ammonia, Total (CA, US) 55,392,953 50,658,575 -9

Phosphorous, Total (CA) 7,016,983 5,548,071 -21

Manganese (and compounds) (CA, US) 4,268,432 3,798,677 -11

Methanol (CA, US) 3,964,939 3,158,471 -20

Sodium Nitrite (CA, US) 1,569,366 626,810 -60

Ethylene Glycol (CA, US) 819,066 955,498 17

Zinc (and compounds) (CA, US) 778,545 918,020 18

Barium (and compounds) (US) 521,014 598,194 15

Chlorine (CA, US) 513,630 249,478 -51

Copper (and compounds) (CA, US) 295,308 446,874 51

Formaldehyde (CA, MX, US) 208,093 122,103 -41

Vanadium (and compounds) (CA, US) 204,806 216,104 6

Nickel (and compounds) (CA, MX, US) 201,061 171,722 -15

Acetaldehyde (CA, MX, US) 182,652 174,523 -4

Formic Acid (CA, US) 138,252 229,773 66

Arsenic (and compounds) (CA, MX, US) 129,217 129,375 0

Phenol (CA, MX, US) 125,890 67,372 -46

Benzene (CA, MX, US) 114,416 127,501 11

Total Reduced Sulfur (TRS) (CA) – 208,448 99*

Total, Top 20 Pollutants Released to Water 232,535,554 220,360,972

Total, All Pollutants Released to Water 234,003,770 221,806,836

%, Top 20 Pollutants, of All Releases to Water 99.4 99.3

 2005 2010

140,000,000

120,000,000

100,000,000

80,000,000

60,000,000

40,000,000

20,000,000

Kilograms

Canada NPRI

116,942,451 119,144,134

Mexico RETC

171,752 140,153

US TRI

102,522,550

116,889,567

*

 Percent change calculated from 2007 (first year of TRS reporting in Canada).

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.
32 Commission for Environmental Cooperation

2.2.1 Top Sectors Reporting Releases to Water in North America, 

2005–2010

The five North American industry sectors reporting the largest proportions of total releases to water from 2005 through 

2010 are shown in Figure 11. These industry sectors accounted 

for 173,187,048 kilograms (or 78 percent of total reported 

releases to water by all sectors in 2010), with the water and 

sewage sector alone reporting almost 48 percent of the total.

As mentioned, the reported data for releases to water by North 

American industry sectors reflect key differences in national 

PRTR reporting requirements, especially for public water and 

wastewater treatment plants. These differences are illustrated 

in Figure 12, which presents the top industry sectors in each 

country for reported releases to water from 2005 through 2010.

Figure 12 shows that releases to water from the water and 

wastewater treatment sector were driven by reporting in 

Canada. In 2010, 176 of the 3,700 such facilities in that 

country (mainly municipal wastewater treatment plants in 

large metropolitan areas) reported releases to water of more 

than 103 million kilograms, or 98 percent of all releases by 

this sector in North America. In Mexico, a total of 13 facilities in this sector (most of them privately owned) reported 

releases to water in 2010; while in the United States, a total 

of five water and wastewater treatment plants reported about 

2 million kilograms in releases to water that year (most of 

which corresponded to one meat-processing facility). 

It is important to note, however, that in the United States, 

municipal or state-owned water and wastewater treatment 

facilities (called publicly-owned treatment works, or POTWs) 

are not subject to TRI reporting; and while facilities discharging to national water bodies in Mexico are subject to RETC 

reporting, very few wastewater treatment plants reported in 

the 2005-2010 period. There are an estimated 16,000 POTWs 

in the United States and 1,600 public wastewater treatment 

plants in Mexico.17 Considering the data reported by such 

facilities in Canada, there would likely be a substantial 

increase in the data for releases to water if facilities in this 

sector reported in all three countries.

The animal slaughtering and processing sector was the second-ranked industry for releases to water in North America, with Figure 12 showing these data driven by reporting 

in the United States. In 2010, approximately 100 US facilities in this sector reported releases to water, with many of 

them reporting decreases over the 2005–2010 period. US 

and Canadian animal slaughtering and processing facilities 

are subject to PRTR reporting, while in Mexico most facilities in this sector are under state jurisdiction and/or do not 

meet federal reporting requirements relative to discharges 

to national water bodies. 

Figure 11. Top Reporting Industry Sectors for Releases to Water, North America, 2005–2010 

120

100

80

60

40

20

Millions of Kilograms

Water, Sewage 

and Other Systems 

(-2%)

Animal Slaughtering 

and Processing 

(-14%)

Pulp, Paper 

and Paperboard Mills 

(-6%)

Iron and Steel Mills and 

Ferroalloy Manufacturing 

(+4%)

Basic Chemical 

Manufacturing 

(-24%)

Sector (percent change between 2005 and 2010)

 2005 

 2006

 2007 

 2008

 2009 

 2010

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.

17. CEC. 2011. Taking Stock: North American Pollutant Releases and Transfers 13. Montreal, Canada: Commission for Environmental Cooperation.
Taking Stock North American Pollutant Releases and Transfers Vol. 14 33

Mexico RETC

30,000

25,000

20,000

15,000

10,000

5,000

Kilograms

2005 28,151 16,305 10,841

2010 680 15,849 19,524 

Motor Vehicle Parts Manufacturing

(-98%) 

Electric Power Generation, 

Transmission and Distribution (+80%)

Water, Sewage and Other 

Systems (-3%)

US TRI

35,000

30,000

25,000

20,000

15,000

10,000

5,000

Kilograms

2005 30,870,989 13,518,900 13,052,294

2010 26,804,107 13,986,870 9,894,658 

Animal Slaughtering and Processing

(-13%) 

Basic Chemical Manufacturing 

(-24%)

Iron and Steel Mills and Ferroalloy 

Manufacturing (+3%)

Figure 12. Top Reporting Industry Sectors for Releases to Water in Canada, Mexico and the 

United States, 2005–2010

Canada NPRI

120,000,000

100,000,000

80,000,000

60,000,000

40,000,000

20,000,000

Kilograms

2005 102,827,730 7,471,181 1,960,900

2010 103,662,502 7,972,689 2,308,073 

Water, Sewage and Other Systems 

(+1%) 

Oil and Gas Extraction 

(+18%)

Pulp, Paper and Paperboard Mills 

(+7%)

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.
34 Commission for Environmental Cooperation

Figure 12 reveals notable changes in reported releases to 

water from some of the top reporting sectors in Mexico, 

such as a 98 percent decrease from the motor vehicle parts 

manufacturing sector—with about 100 facilities in this 

sector reporting releases to water in 2005, but only 25 facilities reporting such releases in 2010. The 80 percent increase 

from the Mexican electric power sector can be mainly 

attributed to one private utility in Tamaulipas that reported 

about 59 percent of total releases to water for this sector in 

2010, but did not report in 2005. Although fewer pollutants 

are subject to PRTR reporting in Mexico than in the United 

States and Canada, one might expect to see more reporting of releases to water in that country since, as mentioned 

earlier, any facility discharging into national water bodies is 

subject to the RETC.

Table 14 presents the top pollutants released to water by the 

top five North American sectors, which together accounted 

for 78 percent of total releases to water in 2010.

Water and wastewater treatment plants handle pollutants 

generated by a wide range of residential, commercial and 

industrial sources. This sector accounted for the largest 

releases to water of nitric acid and nitrate compounds, with 

these releases increasing between 2005 and 2010. It also 

reported large proportions of ammonia and phosphorous 

(with releases to water of both pollutants declining over 

this period). It should be noted that total phosphorous (a 

measure of all forms of phosphorus found in a sample) is 

only subject to PRTR reporting in Canada. These pollutants 

are often the result of organic matter, fertilizers and other 

pollutants in the waste stream which, when discharged to 

waterways, can lead to nutrient enhancement, a primary 

cause of excessive eutrophication (during the natural aging 

of aquatic systems)—which in turn contributes to the creation of areas of depleted oxygen that can kill fish and other 

aquatic organisms (often called “dead zones”).18

Nitric acid and nitrate compounds and ammonia were the 

top reported pollutants for each of the sectors shown in this 

table, including the US animal slaughtering and processing 

sector, which reported decreases between 2005 and 2010. 

Nitrates are associated with processes such as meat packing 

and preparation in the food manufacturing sector. Reported 

releases to water of chlorine by this sector increased by 

over 2,500 percent, mainly due to one facility in Kentucky.

In Canada, a total of five facilities in the animal slaughtering and processing sector reported over this period, with 

releases to water of approximately 732,000 kilograms in 

2005 and 422,000 kilograms in 2010. 

Table 14. Top Reporting Industry Sectors for Releases to Water, and Top Reported Pollutants, 

North America, 2005–2010

Industry Sector 

(NAICS-4 Code)

Releases to 

Water 2010 (kg) Pollutant

Releases to 

Water 2010 (kg)

% Change 

2005–2010

Canada 

NPRI (%)

Mexico 

RETC (%)

US TRI 

(%) 

Water, Sewage and 

Other Systems (2213) 105,776,036

Nitric Acid and Nitrate Compounds (CA, US) 57,151,544 10 96 -- 4

Ammonia, Total (CA, US) 43,707,196 -12 100 -- 0

Phosphorous, Total (CA) 4,297,181 -11 100 -- --

Animal Slaughtering 

and Processing (3116) 27,227,048

Nitric Acid and Nitrate Compounds (CA, US) 27,139,413 -14 1 -- 99

Ammonia, Total (CA, US) 43,134 4 51 -- 49

Chlorine (CA, US) 34,643 2,576 -- -- 100

Pulp, Paper, and 

Paperboard Mills 

(3221)

15,683,803

Nitric Acid and Nitrate Compounds (CA, US) 4,629,247 -6 37 -- 63

Ammonia, Total (CA, US) 4,105,726 58 83 -- 17

Manganese (and compounds) (CA, US) 2,952,440 -9 35 -- 65

Iron and Steel Mills 

and Ferroalloy 

Manufacturing (3311)

14,236,669

Nitric Acid and Nitrate Compounds (CA, US) 13,378,193 7 0 -- 100

Sodium Nitrite (CA, US) 354,361 -53 0 -- 100

Ammonia, Total (CA, US) 148,131 7 63 -- 37

Basic Chemical 

Manufacturing (3251) 10,263,491

Nitric Acid and Nitrate Compounds (CA, US) 8,747,811 -25 3 -- 97

Ammonia, Total (CA, US) 537,280 18 3 -- 97

Manganese (and compounds) (CA, US) 199,007 -48 7 -- 93

Total, Top 5 Sectors 173,187,048 Total, Top Reported Pollutants 167,425,308

%, Top 5 Sectors, of 

Total Releases to Water 78

Note: A “--” means the pollutant has not been reported. 

Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.

18. CEC. 2011. Taking Stock: North American Pollutant Releases and Transfers 13. Montreal, Canada: Commission for Environmental Cooperation.
Taking Stock North American Pollutant Releases and Transfers Vol. 14 35

The basic chemical manufacturing sector (mainly in the 

United States) reported substantial decreases in releases to 

water of nitric acid and nitrate compounds. Two chemical 

manufacturers, BASF Corporation in Texas (which manufactures acrylic and styrene dispersions used as binders in 

coatings and adhesives) and the Dupont Belle plant in West 

Virginia (which produces chemicals for dyes, perfumes 

and fabric softeners, etc.), accounted for large decreases in 

releases to water of these compounds. 

Releases to water of nitrates and of manganese and its compounds from Canadian and US pulp, paper and paperboard 

mills decreased between 2005 and 2010, while releases of 

ammonia increased by 58 percent. Ammonia can be released 

as a result of the treatment of wastewater at pulp and paper 

mills. A number of metals, including manganese compounds, 

are present in the fuels used in mill boilers, as well as are 

released from wood through various pulp and papermaking 

processes (see Chapter 3).

US iron and steel mills and ferroalloy manufacturers reported 

a 53 percent decrease in releases to water of sodium nitrite 

over this period. Reported releases to water of all pollutants 

from this US sector increased slightly between 2005 and 2010, 

but only five of the 100 facilities reported releases of sodium 

nitrite in 2005, with only one reporting in 2010. Sodium 

nitrite is often used as a cleaning and degreasing agent for 

metals, and is an effective rust inhibitor. 

Table 15. Top Reporting Industry Sectors for Releases to Water of Pollutants Common 

to NPRI, RETC and TRI, 2005–2010 

Pollutant PRTR Top Contributing Sectors, 2005

Releases to 

Water 2005 (kg)

% Change 

2005–2010

Acetaldehyde

Canada NPRI Pulp, Paper, and Paperboard Mills 21,816 -39

Mexico RETC – -- –

US TRI Pulp, Paper, and Paperboard Mills 150,683 3

Total Acetaldehyde, Top Sectors 172,499

Arsenic (and compounds)

Canada NPRI Metal Ore Mining 40,935 -96

Mexico RETC Motor Vehicle Parts Manufacturing 10,355 -100

US TRI Electric Power Generation, Transmiss/Distrib. 45,580 -60

Total Arsenic (and compounds), Top Sectors 96,870

Benzene

Canada NPRI Oil and Gas Extraction 107,178 17

Mexico RETC – -- –

US TRI Petroleum and Coal Products Mfg. 3,557 -74

Total Benzene, Top Sectors 110,735

Formaldehyde

Canada NPRI Pulp, Paper, and Paperboard Mills 59,182 -41

Mexico RETC Motor Vehicle Manufacturing 96 –

US TRI Pulp, Paper, and Paperboard Mills 121,509 -43

Total Formaldehyde, Top Sectors 180,787

Nickel (and compounds)

Canada NPRI Metal Ore Mining 29,807 -64

Mexico RETC Motor Vehicle Parts Manufacturing 7,635 -97

US TRI Electric Power Generation, Transmiss/Distrib. 49,900 -50

Total Nickel (and compounds), Top Sectors 87,342

Phenol

Canada NPRI Oil and Gas Extraction 72,450 -31

Mexico RETC Grain and Oilseed Milling 222 –

US TRI Petroleum and Coal Products Mfg. 28,554 -85

Total Phenol, Top Sectors 101,226

Note: A “--” means the pollutant has not been reported. 

Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.
36 Commission for Environmental Cooperation

Of the top 20 reported pollutants released to water between 

2005 and 2010 (see Figure 10), only six are subject to all 

three PRTR programs. They are phenol, acetaldehyde, benzene, formaldehyde, and nickel and arsenic (and their compounds). Table 15 shows the reported releases to water of 

these six pollutants in each country in 2005, and the sectors 

reporting them. It reveals both similarities and differences 

among the three countries in terms of reporting sectors, 

amounts released to water, and the magnitude and direction 

of 2005–2010 changes. 

For example, in Canada and the United States, pulp, paper 

and paperboard mills reported the largest proportions of 

releases to water of acetaldehyde and formaldehyde, with 

these releases generally decreasing between 2005 and 2010. 

In the United States, there was a noticeable increase in 

releases to water of acetaldehyde in 2008 from two mills. 

Trace quantities of acetaldehyde and formaldehyde may be 

coincidentally manufactured during pulp and paper manufacturing processes. Releases to water of acetaldehyde were 

not reported by Mexican facilities, while relatively small 

amounts of formaldehyde were reported released to water 

in that country by the motor vehicle manufacturing sector, 

only through 2008. 

Different sectors in each country accounted for the top 

releases to water of arsenic and its compounds, with each 

reporting decreases in these releases from 2005 through 

2010. Arsenic is a naturally occurring metal found in the 

environment, especially as an impurity in metal ores. Arsenic compounds are commonly used to preserve wood, as 

metal alloys, and in pesticides.

Known or Suspected Carcinogens, Developmental or Reproductive Toxicants, Metals, and PBTs

In order to provide more information about PRTR pollutants, the Taking Stock report and Taking 

Stock Online database also categorize them as follows (with many of the pollutants reported to the 

North American PRTRs falling into one or more of these categories)19:

• Known or suspected carcinogens, based on the World Health Organization’s International 

Agency for Research on Cancer (IARC) and California’s Office of Environmental Health Hazard 

Assessment (OEHHA) Proposition 65 list.

• Developmental or reproductive toxicants, based on California’s Proposition 65 list. These 

substances adversely affect reproductive capabilities and/or the development of the fetus. Metals, 

solvents, and pesticides have been widely implicated in reproductive and/or developmental 

impacts. Endocrine disruptors have also been added to this category.

• Persistent, bioaccumulative and toxic substances (PBTs). These pollutants have properties that 

render them a long-term environmental and health threat, even in small quantities. When PBTs 

are released into the environment, they persist over long periods of time and do not break down 

easily into other compounds; they can be transported in the atmosphere over long distances, 

ending up far from the sources of their release; and they bioaccumulate in the food chain 

(increasing in concentration at higher levels). They are also toxic, often causing damage to 

humans, plants and wildlife.

• Metals. Metals occur naturally, but human activities such as mining and smelting increase the 

proportions of metals in the environment. The toxicity of certain metals and their compounds 

depends on the forms they take in the environment. 

Assessing potential harm to human health or the environment from particular releases of a pollutant 

is a complex task, because the potential of a substance to cause harm arises from various factors, 

including its inherent toxicity and the nature of the exposure to the substance (e.g., the potential 

risk posed by asbestos sent to a secure landfill is considered to be much lower than the risk posed 

by asbestos released to air). However, the reported data and information about a pollutant’s chemical 

properties and toxicity can serve as a starting point for learning more about its potential impacts.

19. For more information about the references for these categories of pollutants, see Appendix 1.
Taking Stock North American Pollutant Releases and Transfers Vol. 14 37

Releases to water of benzene and phenol were reported by 

the oil and gas extraction sector in Canada and the petroleum and coal products manufacturing sector in the United 

States (perhaps reflecting the fact that in the United States, 

the oil and gas extraction sector is not subject to the TRI). 

Benzene, a component of crude oil and gasoline, is a flammable liquid that evaporates into the air and dissolves 

slightly in water. It is used widely to make other chemicals 

for the production of plastics, resins, fibers, lubricants, and 

so on. Phenol is used mainly in the production of resins, 

nylon and other synthetic fibers. In Mexico, no releases to 

water of benzene, and relatively small quantities of phenol 

(from the grain and oilseed milling sector) were reported 

during this period. 

The largest releases to water of nickel and its compounds 

were reported by different industry sectors in each country, 

with these releases declining between 2005 and 2010. Nickel 

is a metal found in the environment, and can be released 

into the atmosphere by fossil fuel–burning power plants, as 

well as through mining activities and the forging of metal 

alloys for the production of coins, jewelry, batteries, stainless steel, and so on. 

2.3 Releases to Air and Water of Known or Suspected 

Carcinogens, Developmental or Reproductive 

Toxicants, Metals, and PBTs, 2005–2010

The preceding analyses of releases to air and water highlighted the top reported pollutants—that is, those released 

in largest proportions by North American industrial facilities between 2005 and 2010. This section examines reported 

releases to air and water over this period of pollutants 

belonging to one or more of four categories of pollutants: 

known or suspected carcinogens; developmental or reproductive toxicants; metals; and persistent, bioaccumulative 

and toxic substances (PBTs). A number of the pollutants 

in these categories are considered to be of special concern 

because of their significant potential to cause harm to 

human health and the environment, even when released in 

relatively small amounts. 

Between 2005 and 2010, North American industrial facilities reported total releases and transfers of more than 

200 pollutants belonging to one or more of these four 

categories (see Table 2). Of these substances, only 42 are 

common to the three PRTR programs. Some of these pollutants were among those reported in largest proportions 

by North American facilities; however, many others were 

reported in relatively small amounts. As a result, these substances might not appear in a table of “top” releases, even 

though the potential for some of them to cause harm when 

released directly to the environment (i.e., to air or water) is 

significant. Therefore, Taking Stock provides additional toxicity-based information for certain pollutants, in the form of 

toxicity equivalency potentials (TEPs). This chemical ranking system takes into account both a substance’s toxicity and 

its potential for human exposure.

2.3.1 Releases to Air of Known or Suspected Carcinogens, 

Developmental or Reproductive Toxicants, Metals, and 

PBTs, 2005–2010 

In 2010, facilities in North America reported a total of 

over 74.4 million kilograms in releases to air of 220 pollutants belonging to one or more of these four categories, 

compared to almost 120 million kilograms in 2005—a 

decrease of 38 percent. These pollutants accounted for 

about 15 percent of total releases to air reported in both 

2005 and 2010. 

Toxic Equivalency Potentials (TEPs)

TEPs indicate the relative human health risk 

associated with the release of one unit of a 

pollutant, compared to the risk posed by the 

release of one unit of a reference substance. The 

reference chemical for carcinogens is benzene and 

the reference chemical for pollutants that produce 

non-cancerous health effects (e.g., developmental 

or reproductive toxicity, acute respiratory effects) is 

toluene. TEPs provide a chemical ranking system 

that takes into account both a pollutant’s toxicity 

and its potential for human exposure. However, 

this analysis is limited in that a release does not 

directly correlate to actual exposures, nor to levels 

of risk. In addition, TEPs are only available for 

air and water releases, and not all of the PRTR 

pollutants have an assigned TEP (information 

on their toxicity or exposure potential may be 

missing). Nonetheless, they should not be assumed 

to be without risk. The TEPs used in Taking Stock

are one of many different screening tools, each 

based on a series of assumptions and, therefore, 

possibly yielding different results. Taking Stock

provides TEPs for air and water releases of known 

or suspected carcinogens and other substances 

with potential non-cancerous health effects. The 

TEP is multiplied by the amount of release and 

the result is used to rank the pollutants. For more 

information, see Appendix 1.
38 Commission for Environmental Cooperation

Figure 13 illustrates the impacts of differences in national PRTR 

reporting requirements on our understanding of pollutant 

releases to the environment by industrial facilities. Reported 

releases of pollutants in these four categories that are common 

to the three PRTRs are represented by the brightly-colored, 

bottom portions of the bars in this graph, while reported 

releases of all such pollutants are represented by the upper, 

gray portions. Particularly notable is the difference among 

reported releases of all developmental and reproductive toxicants, compared to releases of those that are common to the 

three PRTRs. Some of the pollutants in this category that were 

released to air in large proportions over this period include 

toluene (with about 17.3 million kilograms reported in 2010) 

and carbon disulfide (with 8.4 million kilograms reported 

in 2010). These substances are subject to PRTR reporting in 

Canada and the United States, but not Mexico. 

Figure 13. Releases to Air of Known/Suspected Carcinogens, Developmental/Reproductive 

Toxicants, Metals and PBTs: North American PRTRs, 2005–2010

60

50

40

30

20

10

Millions of Kilograms

Persistent, Bioaccumulative

and Toxic Compounds

Metals Known or Suspected 

Carcinogens

Developmental or 

Reproductive Toxicants

 2005 

 2006

 2007 

 2008

 2009 

 2010

Note: Color columns refer to pollutants common to the 3 PRTRs; grey columns refer to pollutants in these categories subject to PRTR reporting in at least one country. Some pollutants belong to more than one 

category. Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.

Pollutant Category

Petr Kratochvil
Taking Stock North American Pollutant Releases and Transfers Vol. 14 39

2.3.2 Releases to Water of Known or Suspected Carcinogens, 

Developmental or Reproductive Toxicants, Metals, and 

PBTs, 2005–2010 

In 2010, facilities in North America reported releases to 

water of more than 7.34 million kilograms of pollutants 

belonging to one or more of these four categories, a decrease 

of about 5 percent in comparison with 2005 levels. These 

pollutants accounted for three percent of total releases to 

water reported in both 2005 and 2010, with metals accounting for the largest proportions. 

As in the preceding figure, reported releases to water 

of pollutants in these four categories that are common 

to the three PRTRs are represented by the brightly-colored, bottom portions of the bars in Figure 14, while 

reported releases of all such pollutants are represented 

by the upper, gray portions. This graph reveals a very 

notable difference between reported releases to water 

of all metal compounds and those that are common to 

the three PRTRs. Some of the metals released to water in 

largest proportions over this period include manganese, 

zinc and copper and their compounds. These pollutants 

are subject to PRTR reporting in Canada and the United 

States, but not Mexico. In fact, 18 metals are common to 

Canada’s NPRI and the US TRI, while only six are subject 

to reporting under Mexico’s RETC. 

The 42 pollutants in these categories that are common to 

the three North American PRTRs are featured in Table 16. 

This table presents their reported releases to air and water 

in 2010, and the percent change in these releases from 2005. 

It also provides each pollutant’s corresponding cancer and 

non-cancer risk (TEP) scores, if available. The TEP score is 

obtained by multiplying the volume of air or water release of 

a pollutant by its assigned TEP weight.

This table reveals notable decreases between 2005 and 2010 

in reported releases to air or water of pollutants that have very 

high cancer or non-cancer TEP scores, including lead and mercury compounds. It also shows increases for some pollutants, 

such as chromium and its compounds. In some cases, releases 

to air declined substantially while releases to water increased, 

or vice-versa (e.g., cadmium and its compounds).

Millions of Kilograms

Figure 14. Releases to Water of Known/Suspected Carcinogens, Developmental/Reproductive 

Toxicants, Metals and PBTs: North American PRTRs, 2005–2010 

10

9

8

7

6

5

4

3

2

1

Persistent, Bioaccumulative

and Toxic Compounds

Metals Known or Suspected 

Carcinogens

Developmental or 

Reproductive Toxicants

 2005 

 2006

 2007 

 2008

 2009 

 2010

Note: Color columns refer to pollutants common to the 3 PRTRs; grey columns refer to pollutants in these categories subject to PRTR reporting in at least one country. Some pollutants belong to more than one 

category. Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.

Pollutant Category
40 Commission for Environmental Cooperation

Table 16. Reported Releases of C, D, M, P Common to the North American PRTRs, 2005–2010 

Pollutant C D M P*

Releases 

to Air 

2010 (kg)

 % Change 

2005–2010

Cancer Risk 

Score for Air 

(TEP) 2010

Non-cancer Risk 

Score for Air 

(TEP) 2010

Releases 

to Water 

2010 (kg)

 % Change 

2005–2010

Cancer Risk 

Score for Water 

(TEP) 2010

Non-cancer 

Risk Score for 

Water (TEP) 2010

1,1,2,2-Tetrachloroethane X 6,713 359 59,743 6,041 135 4,867 852 176

1,1,2-Trichloroethane X 8,691 16 18,252 42,588 106 -3 253 1,478

1,2,4-Trichlorobenzene X 4,932 -80 592 47,345 0 -- -- --

1,2-Dichlorobenzene X 18,024 -64 -- 147,800 121 -76 -- 1,206

1,2-Dichloroethane X 214,725 -7 536,813 901,846 391 -71 1,133 1,875

1,3-Butadiene X X 632,593 -26 335,274 1,391,704 321 200 1,542 2,410

1,4-Dichlorobenzene X X 17,962 -64 25,147 39,517 5 -99 4 6

1,4-Dioxane X 59,221 -19 4,738 2,961 15,776 -57 1,420 789

2,4-Dinitrotoluene X X 4,735 -70 20,832 473,464 0 -- -- --

2-Ethoxyethanol X 44,979 16 -- 58,473 38,793 155 -- 3,103

2-Nitropropane X 16,950 12 372,908 98,312 0 -- -- --

Acetaldehyde X 4,730,047 -35 47,300 43,989,441 174,523 -4 1,099 890,068

Acrylamide X 6,649 8 864,376 13,298,099 462 200 738 11,538

Acrylonitrile X 187,531 -18 731,369 7,126,162 56 -99 89 1,059

Aniline X 44,202 -40 442 4,022,372 1,321 19 9 75,297

Arsenic (and compounds) X X X X 100,012 -28 1,600,184,124 8,400,966,650 129,375 0 517,499,597 2,587,497,987

Asbestos X 3,273 304 -- -- 0 -- -- --

Benzene X X 2,673,221 -22 2,673,221 21,653,094 127,501 11 96,901 1,275,009

Bromomethane X 231,994 13 -- 371,190,081 569 2,750 -- 511,924

Cadmium (and compounds) X X X X 22,227 -43 577,892,679 42,230,618,839 12,936 8 24,578,707 1,811,062,631

Carbon Tetrachloride X 49,923 -42 13,479,084 114,821,830 207 18 53,766 475,623

Chloroform X X X 273,049 -29 436,878 3,822,681 4,701 -66 7,052 75,222

Chloromethane X 909,936 -11 600,558 51,866,333 1,065 100 415 36,210

Chromium (and compounds) X X X X 660,678 56 85,888,129 2,048,101,549 116,635 40 -- 51,319,524

Cyanides X 137,884 -34 -- -- 29,360 -40 -- --

Dibutyl Phthalate X X 5,356 -49 -- 58,912 65 -75 -- 118

Dichloromethane X 2,273,625 -27 454,725 15,915,377 1,047 -60 136 4,608

Dioxins and Furans X X X 0.03 -39 36,604,320 26,843,168,000 0 -21 415,242 294,882,000

Epichlorohydrin X X 51,095 -9 56,205 10,730,050 3,077 -76 1,385 255,392

Formaldehyde X 3,572,996 -50 71,460 57,167,936 122,103 -41 98 35,410

Hexachlorobenzene X X X 130 -68 285,538 2,725,592 41 30 138,430 1,343,583

Hexachloroethane X 536 131 139,366 2,948,130 0 -- -- --

Hydrazine X 1,891 68 41,598 737,420 937 -64 2,249 131,201

Lead (and compounds) X X X X 523,674 -29 14,662,879 303,731,071,594 75,972 -30 151,944 3,190,824,850

Mercury (and compounds) X X X X 50,771 -27 -- 710,796,430,922 2,215 -85 -- 28,789,247,625

Nickel (and compounds) X X X X 704,364 -28 1,972,220 2,253,966,102 171,722 -15 -- 4,464,777

Phenol X 2,625,841 -7 -- 997,820 67,372 -46 -- 310

Pyridine X 17,785 -50 -- 1,316,100 434 -9 -- 3,469

Styrene X 11,866,513 -54 -- 949,321 1,445 -43 -- 491

Toluenediisocyanate 

(mixed isomers) X 14,351 -2 -- -- 0 -- -- --

Trichloroethylene X 1,191,881 -62 59,594 750,885 334 38 43 401

Vinyl Chloride X 234,773 -21 446,069 16,199,355 176 -62 811 24,693

Total, Reported C, D, M, P Pollutants 

Common to the 3 PRTRs 34,195,732 221,806,836 1,101,298 221,806,836 221,806,836 221,806,836

Total, All Reported C, D, M, P Pollutants 74,425,550 221,806,836 7,347,276 221,806,836 221,806,836 221,806,836

Total, All Reported Pollutants 514,173,851 221,806,836 221,806,836 221,806,836 221,806,836 221,806,836

*C = known/suspected carcinogen; D = developmental/reproductive toxicant; M = metal; P = persistent, bioaccumulative, toxic (PBT) substance. 

Note: A “--” in place of a TEP score means that either the pollutant has a score of 0, or it has not been evaluated. 

Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.
Taking Stock North American Pollutant Releases and Transfers Vol. 14 41

2.3.3 Reported Releases to Air and Water of Selected Pollutants 

of Special Concern 

The six pollutants in Table 17 belong to at least three of the 

four pollutant categories. They were selected because they 

are subject to PRTR reporting in all three countries, and 

because of the contrast between their reported volumes (in 

kilograms) and their associated cancer and/or non-cancer risk (TEP) scores, which illustrate their potential toxicity even when released to air or water in relatively small 

amounts. These substances are therefore considered to be 

pollutants of special concern. 

Information about the sectors and facilities reporting 

releases to air and water of these six pollutants is presented 

below. Additional information about their typical industrial 

uses or production, as well as their chemical properties and 

potential to cause harm to human health or the environment, is provided in Appendix 5. 

Arsenic and its compounds: The nonferrous metal (except 

aluminum) production and processing sector accounted for 

about one-third of all releases to air of arsenic and its compounds in 2010. Among the 40 reporting facilities in this 

sector, two Canadian facilities accounted for a large part of 

Table 17. Reported Releases of Pollutants of Special Concern Common to the Three PRTRs, 2005–2010 

Pollutant

Category*

of 

Pollutant

Medium 

of 

Release 

Total 

Releases 

2010 (kg)

Cancer 

Risk Score 

(TEP) 2010

Non-cancer 

Risk Score 

(TEP) 2010

Top Contributing 

Industry Sectors

Releases 

2010 (kg)

 % Change 

2005–2010

Canada 

NPRI 

(%)

Mexico 

RETC 

(%)

US

TRI 

(%)

Arsenic 

(and compounds) CDMP

Air 100,012 1,600,184,124 8,400,966,650

Nonferrous Metal 

(except Alum.)

Production/Processing

35,554 -48 78 2 20

Water 129,375 517,499,597 2,587,497,987 Metal Ore Mining 94,709 120 2 0 98

Cadmium 

(and compounds) CDMP

Air 22,227 577,892,679 42,230,618,839

Nonferrous Metal 

(except Alum.)

Production/Processing

13,216 -60 91 4 5

Water 12,936 24,578,707 1,811,062,631

Electric Power Generation, 

Transmission and 

Distribution

2,976 445 0 99 0

Lead 

(and compounds) CDMP

Air 523,674 14,662,879 303,731,071,594

Nonferrous Metal 

(except Alum.)

Production/Processing

146,836 -41 48 17 35

Water 75,972 151,944 3,190,824,850 Water, Sewage 

and Other Systems 16,684 27 72 28 –

Mercury 

(and compounds) CDMP

Air 50,771 - 710,796,430,922

Electric Power Generation, 

Transmission and 

Distribution

31,736 -31 5 – 95

Water 2,215 - 28,789,247,625

Electric Power Generation, 

Transmission and 

Distribution

1,358 917 0 74 25

Hexachlorobenzene CDP

Air 130 285,538 2,725,592 Basic Chemical 

Manufacturing 85 258 0 – 100

Water 41 138,430 1,343,583 Basic Chemical 

Manufacturing 21 26 0 – 100

Chromium 

(and compounds) CDMP

Air 660,678 85,888,129 2,048,101,549 Motor Vehicle Body and 

Trailer Manufacturing 389,159 5,925 0 – 100

Water 116,635 - 51,319,524 Basic Chemical 

Manufacturing 33,034 544 0 12 88

Total, Releases of 6 Pollutants 

of Special Concern to Air 1,357,491 2,278,913,349 1,067,209,915,146 Total, Releases from Top 

Contributing Sectors to Air 616,585

Total, Releases of 6 Pollutants 

of Special Concern to Water 337,173 542,368,678 36,431,296,200 Total, Releases from Top 

Contributing Sectors to Water 148,782

*C = known or suspected carcinogen; D = developmental or reproductive toxicant; M = metal; P = persistent, bioaccumulative and toxic (PBT) substance. 

Note: A “--” means that either the pollutant has not been reported or in the case of TEP, it has a score of 0 or has not been evaluated. 

Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.
42 Commission for Environmental Cooperation

the 48 percent decrease from 2005 through 2010: the Vale 

Canada Copper Cliff smelter in Ontario, and the Hudson 

Bay Mining and Smelting complex in Manitoba (which was 

in the process of shutting down during this period). The 

metal ore mining sector was the top reporter of releases to 

water of arsenic and its compounds, with the number of 

facilities increasing from 37 in 2005 to 55 in 2010. One US 

facility, the Jerritt Canyon mine in Nevada, accounted for 98 

percent of the releases reported by this sector in 2010. 

Cadmium and its compounds: The nonferrous metal 

(except aluminum) production and processing sector was 

also the top industry sector for releases to air of cadmium 

and its compounds, accounting for about 58 percent of all 

such releases in 2010. This sector reported a 60 percent 

decrease in releases of this pollutant from 2005 through 

2010, with one facility, the Hudson Bay Mining and Smelting complex in Manitoba, accounting for much of this 

decrease (as mentioned above, this facility was shutting 

down during this period). Facilities in the electric power 

generation, transmission and distribution sector reported 

almost one-quarter of total releases to water of cadmium 

and its compounds in 2010, with most of these releases 

reported in Mexico. Three utilities, two Iberdrola Energía 

facilities in Tamaulipas and the Promotora Ecológica San 

Pedro Mártir facility in Querétaro, reported most of these 

releases to water, and accounted for the large increase from 

this sector.

Lead and its compounds: The nonferrous metal (except aluminum) production and processing sector also accounted 

for the largest proportion (28 percent) of releases to air of 

lead and its compounds in 2010, with reporting facilities 

located in the three countries. A small number of facilities 

accounted for much of the decrease in these releases, including the above-mentioned Hudson Bay Mining and Smelting 

complex in Manitoba; the Xstrata Canada–Kidd Metallurgical Site in Ontario; the Doe Run Herculaneum Smelter in 

Missouri; and the Nacional de Cobre, S.A. de C.V.–Planta 

Cobrecel facility in Guanajuato. Facilities in the water and 

wastewater treatment sector in both Canada and Mexico 

accounted for approximately 22 percent of total releases to 

water of lead and its compounds in 2010, an increase of 27 

percent from 2005 through 2010. Of 106 reporting facilities 

(87 in Canada and 19 in Mexico), a small number of public 

utilities accounted for much of this increase, including the 

Fideicomiso del Sistema de Aguas Residuales del Alto Río 

facility in Veracruz, Mexico; and four Canadian utilities: 

two City of Toronto treatment plants; the City of Montreal 

treatment plant; and the Greater Vancouver Regional District–Iona treatment plant. 

Mercury and its compounds: Fossil fuel–based electric 

utilities reported large proportions of total releases to air 

and water of mercury and its compounds in 2010. Releases 

to air of this pollutant (most of them reported in the United 

States) decreased by 31 percent from 2005 through 2010. 

Mexican electric utilities accounted for about 74 percent of 

the reported releases to water of mercury and its compounds 

by this sector. From 2005 through 2010, releases to water of 

this pollutant increased notably, mainly due to reporting by 

two Mexican utilities, Electricidad Águila de Tuxpan and 

Electricidad Sol de Tuxpan, both located in Veracruz; and 

two US utilities, Dominion Resources’ Yorktown Power Station in Virginia, and the US TVA Cumberland Fossil Plant 

in Tennessee.

Hexachlorobenzene: Approximately 65 percent of all releases 

to air of hexachlorobenzene in 2010 were reported by the 

US basic chemical manufacturing sector, with an increase 

of 347 percent in these releases between 2005 and 2010. 

Two facilities, accounting for almost 85 percent of all such 

releases in 2010 but not reporting in 2005, were Dow 

Chemical facilities: the Louisiana Operations facility in 

Louisiana and the Freeport facility in Texas. These same 

facilities also accounted for 86 percent of all releases to 

water of hexachlorobenzene in 2010, and for most of the 

increase over this period.

Chromium and its compounds: The motor vehicle body 

and trailer manufacturing sector accounted for 59 percent 

of all releases to air of chromium and its compounds in 

2010, with an important increase in these releases from 2005 

through 2010. Almost 100 percent of all such releases were 

reported by US facilities, with two of them, both Hutchens 

Industries facilities in Missouri, accounting for most of the 

total reported in 2010. The basic chemical manufacturing 

sector was the top reporter of releases to water of chromium 

and its compounds in 2010, accounting for 28 percent of the 

total. These releases also increased notably from 2005. Two 

facilities, the PCS Nitrogen Fertilizer facility in Louisiana, 

and a Dupont facility in Tamaulipas, Mexico, accounted for 

most of the reported total in 2010.

2.3.4 PRTR Reporting Thresholds

As mentioned, of the hundreds of pollutants reported by 

North American facilities from 2005 through 2010, a relatively 

small number are common to the three PRTR programs. The 

differences among national PRTR reporting requirements 

thus create gaps in our picture of North American industrial 

pollution, particularly with respect to releases of pollutants of 

special concern. 
Taking Stock North American Pollutant Releases and Transfers Vol. 14 43

Each PRTR sets thresholds for the pollutants subject to 

reporting in that country. The Canadian NPRI and the US 

TRI have a standard “manufacture, produce, or otherwise 

use” (MPO) threshold of approximately 10,000 kilograms 

(in the United States, it is 25,000 pounds, or 11,340 kilograms), while Mexico’s RETC has both MPO and “release” 

thresholds for its list of 104 pollutants. For certain pollutants, the PRTR programs have set stricter reporting requirements and very low reporting thresholds (or in some cases, 

reporting of any amount, however small). These requirements have been developed on the basis of assessments of 

chemical toxicity and the potential for risk to human health 

and the environment. For some pollutants, such as dioxins, furans and hexachlorobenzene, the need for very low 

reporting thresholds and units in order to capture releases 

of concern has been widely recognized. Similarly, lead and 

mercury and their compounds are reported under lower 

thresholds to all three PRTRs. 

However, while the three PRTR programs have generally set 

lower thresholds for pollutants of special concern, these thresholds can still vary considerably. For example, the Canadian 

NPRI threshold for arsenic and its compounds is 50 kilograms; 

under Mexico’s RETC, the MPO threshold is 5 kilograms, and 

the release threshold is 1 kilogram; and the US TRI threshold 

for arsenic and its compounds is 11,340 kilograms. In fact, only 

one of the 60 pollutants common to the three PRTRs has fairly 

similar reporting thresholds: mercury and its compounds (with 

a 5-kilogram threshold under NPRI; a 5-kilogram MPO and 

1-kilogram “release” threshold under RETC; and a 4.5-kilogram—or 10-pound—threshold under TRI).

Recently, Canada’s NPRI conducted a review of industrial-sector reporting of certain pollutants, such as selenium 

compounds. Selenium is generally present in raw materials at very low concentrations and in small quantities often 

below standard NPRI reporting thresholds. Because of this, 

many facilities have not been required to report on this 

substance. However, levels of selenium that are potentially 

hazardous to human health and the environment have been 

detected downstream from facilities and therefore it was 

deemed necessary to lower the reporting threshold to 100 

kilograms instead of the standard 10,000 kilograms, effective as of the 2011 reporting year. Selenium is also subject to 

reporting under the US TRI (at a threshold of 11,340 kilograms), but is not subject to Mexico’s RETC. 

More information about reporting requirements and thresholds for specific pollutants is provided in Appendices 1 and 2. 

2.4 Reported Releases to Land, 2005–2010

Releases to land20 accounted for almost one-third of total 

reported releases and transfers in 2010, with North American 

facilities reporting 1,802,531,538 kilograms—an increase of 

108 percent from 2005 levels. 

Table 18 presents the releases to land reported by North 

American facilities every year from 2005 through 2010. It 

reveals significant differences among the three countries in 

the amounts reported and in the changes that occurred over 

this period. For example, the significant increase in releases 

to land over this period was driven by reporting in Canada, 

where facilities reported increases of more than 2,200 percent, due to changes in reporting requirements. In the United 

States, facilities reported a 15 percent increase in releases to 

land. In Mexico, facilities also reported a substantial increase, 

but that country’s proportion of the North American total was 

very small (i.e., less than 1 percent in both 2005 and 2010). 

Figure 15 illustrates the reported releases to land in each 

country in 2005 and 2010, and also presents the top reported 

pollutants in 2005 and the changes in their releases. These 

pollutants accounted for 99 percent of total releases to land 

in both 2005 and 2010, with many of them seeing substantial increases over this period.

Table 18. Releases to Land Reported to the North American PRTRs, 2005–2010

PRTR

Releases 

to Land 

2005 (kg)

Releases 

to Land 

2006 (kg)

Releases 

to Land 

2007 (kg)

Releases 

to Land 

2008 (kg)

Releases 

to Land 

2009 (kg)

Releases 

to Land 

2010 (kg)

% Change 

2005–2010

Number of 

Reported Pollutants

2005 2010

Canada NPRI 35,948,597 606,606,640 594,923,183 634,009,535 596,527,117 847,934,205 2,259 77 90

Mexico RETC 82,981 64,970 274,185 563,697 208,625 513,137 518 41 12

US TRI 830,119,970 864,578,518 811,258,930 815,119,661 781,845,861 954,084,195 15 215 183

Total, North America 866,151,548 1,471,250,127 1,406,456,298 1,449,692,894 1,378,581,603 1,802,531,538 108 245 212

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.

20. The term “releases to land” used in Taking Stock combines a variety of methods, due to differences in the terminology used by each PRTR program. Releases to land 

can include spills, leaks, or incidental releases; underground injection; land irrigation and land treatment/farming; and disposal on-site.
44 Commission for Environmental Cooperation

Figure 15. Releases to Land Reported in Canada, Mexico and the United States, and Top Reported 

Pollutants, 2005–2010

 2005 2010 

1,000,000,000

800,000,000

600,000,000

400,000,000

200,000,000

Kilograms

Canada NPRI

35,948,597

847,934,205

Mexico RETC

82,981 513,137

US TRI

954,084,195

830,119,970

Pollutant Releases to Land 2005 (kg) Releases to Land 2010 (kg) % Change 2005–2010

Zinc (and compounds) (CA, US) 263,090,340 347,235,371 32

Lead (and compounds) (CA, MX, US) 198,596,842 273,136,758 38

Arsenic (and compounds) (CA, MX, US) 82,534,116 117,629,339 43

Barium (and compounds) (US) 81,895,976 94,436,409 15

Copper (and compounds) (CA, US) 73,937,220 128,833,333 74

Manganese (and compounds) (CA, US) 65,201,853 379,759,801 482

Vanadium (and compounds) (CA, US) 21,315,594 29,746,058 40

Chromium (and compounds) (CA, MX, US) 14,390,959 35,231,655 145

Asbestos (CA, MX, US) 10,576,147 35,784,638 238

Nickel (and compounds) (CA, MX, US) 10,393,366 47,780,000 360

Nitric Acid and Nitrate Compounds (CA, US) 8,574,678 8,448,995 -1

Aluminum (fume or dust) (CA, US) 6,154,897 4,489,317 -27

Antimony (and compounds) (CA, US) 4,008,847 6,800,756 70

Phosphorous, Total (CA) 3,473,330 161,036,509 4,536

Ethylene Glycol (CA, US) 2,479,978 6,241,522 152

Cobalt (and compounds) (CA, US) 2,423,284 6,360,392 162

Ammonia, Total (CA, US) 2,113,536 5,340,296 153

Mercury (and compounds) (CA, MX, US) 1,877,839 2,225,147 18

Aluminum Oxide (fibrous forms) (CA, US) 519,382 57,317,164 10,936

Calcium Fluoride (CA, US) 114,200 28,810,147 25,128

Total, Top 20 Pollutants Released to Land 853,672,386 1,776,643,606

Total, All Pollutants Released to Land 866,151,548 1,802,531,538

%, Top 20 Pollutants, of Total Releases to Land 99 99

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.
Taking Stock North American Pollutant Releases and Transfers Vol. 14 45

This figure reveals that the large increase in reported 

releases to land from 2005 through 2010 was driven 

by reporting in Canada and, especially, by changes in 

NPRI reporting requirements for mining and oil and gas 

extraction operations as of 2006—including the requirement to report tailings and waste rock, and the removal 

of the reporting exemption for mining extraction and 

crushing activities. The impact of these changes in NPRI 

reporting requirements on pollutant accounting is shown 

in Table 19, which reveals notable increases from 2005 

to 2006 in releases to land of the top 15 reported pollutants in Canada. These pollutants accounted for about 4 

percent of total reported releases to land in North America in 2005, but 40 percent of the total in 2006—with 

the large majority reported by the Canadian mining and 

extractive sectors.

Table 19. Top Pollutants Released to Land, Canadian NPRI, 2005–2006

Pollutant Releases to Land 2005 (kg) Releases to Land 2006 (kg) % Change 2005–2006

Zinc (and compounds) 9,854,818 75,368,384 665

Asbestos 6,354,377 11,847,411 86

Manganese (and compounds) 5,331,181 197,522,419 3,605

Phosphorous, Total 3,473,330 84,273,678 2,326

Lead (and compounds) 3,039,718 29,075,962 857

Vanadium (and compounds) 1,289,762 10,228,328 693

Chromium (and compounds) 963,506 37,034,374 3,744

Copper (and compounds) 899,895 55,397,107 6,056

Nickel (and compounds) 576,158 54,354,071 9,334

Ammonia, Total 421,232 9,006,103 2,038

Arsenic (and compounds) 247,279 13,000,973 5,158

Nitric Acid and Nitrate Compounds 182,282 11,176,993 6,032

Cobalt (and compounds) 40,996 4,087,332 9,870

Antimony (and compounds) 17,002 495,838 2,816

Aluminum (fume or dust) 112 2,118,555 1,891,467

Total, Top 15 Pollutants Released to Land (NPRI) 32,691,648 594,987,526

Total, All Pollutants Released to Land (North America) 866,151,548 1,471,250,127

%, Top 15 Pollutants (NPRI), of Total Releases to Land (NA) 4 40
46 Commission for Environmental Cooperation

2.4.1 Top Sectors Reporting Releases to Land in North America, 

2005–2010

The five North American industry sectors reporting the largest proportions of total releases to land from 2005 through 

2010 are shown in Figure 16. These sectors accounted for 

1,568,703,713 kilograms, or 87 percent of total reported 

releases to land in 2010, with the metal ore mining sector 

alone reporting 1.18 billion kilograms (or almost 66 percent 

of the total). 

This figure shows an important increase as of 2006 in 

reported releases to land for this sector, along with the 

coal mining sector, illustrating the impact of changes 

in NPRI reporting requirements that year. Indeed, the 

number of reporting facilities in these sectors in Canada 

jumped from six in 2005 to 59 in 2006. Another notable increase in releases to land from mining activities 

occurred from 2009 to 2010, primarily due to increases 

reported by a small number of facilities in both Canada 

and the United States.

The top reporting sectors in each country for releases to 

land between 2005 and 2010 are shown in Figure 17. By 

2010, releases to land in Canada by mining activities (and 

especially coal and metal ore mines) had displaced the waste 

treatment and disposal and iron and steel mill/ferroalloy 

manufacturing sectors, which in 2005 were the top reporting sectors for releases to land in that country. 

In the United States, the 30 percent increase in releases to land 

by the metal ore mining sector can be attributed to reporting 

by a small number of facilities that together accounted for over 

80 percent of all reported releases to land by this sector in 2010. 

They included a zinc mine in Alaska, two gold mines in Nevada 

and a copper mine in Utah. The US coal mining sector reported 

a decrease of 48 percent in releases to land over this period. 

This figure also shows a large increase in releases to land 

by Mexican electric utilities in 2010, while releases from the 

other sectors (the top reporters in 2005) were almost negligible that year. Most of the increase from the electricity generation sector was reported by one CFE facility in Sinaloa. 

Figure 16. Top Reporting Industry Sectors for Releases to Land, North America, 2005–2010 

1,200

1,100

1,000

900

800

700

600

500

400

300

200

100

Millions of Kilograms

Metal Ore Mining 

(+128%)

Electric Power Generation,

Transmission and Distribution 

(+2%)

Coal Mining 

(+1,267%)

Waste Treatment and Disposal 

(-17%)

Nonferrous Metal (except 

Aluminum) Production and 

Processing (+131%)

Sector (percent change between 2005 and 2010)

 2005 

 2006

 2007 

 2008

 2009 

 2010

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.
Taking Stock North American Pollutant Releases and Transfers Vol. 14 47

Figure 17. Top Reporting Industry Sectors for Releases to Land in Canada, Mexico and the United States, 

2005–2010

Canada NPRI

600,000,000

500,000,000

400,000,000

300,000,000

200,000,000

100,000,000

Kilograms

2005 0 13,888,614 6,270,875 285,770

2010 104,364,501 39,916,766 3,401,486 507,277,107

Coal Mining

(+)

Iron and Steel Mills and Ferroalloy 

Manufacturing (-46%)

Metal Ore Mining 

(+177,412%)

Waste Treatment and 

Disposal (+187%)

US TRI

800,000,000

700,000,000

600,000,000

500,000,000

400,000,000

300,000,000

200,000,000

100,000,000

Kilograms

2005 518,816,397 133,834,656 75,047,379

2010 674,746,440 138,420,530 33,712,232

Metal Ore Mining 

(+30%)

Waste Treatment and Disposal 

(-55%)

Electric Power Generation,

Transmission and Distribution (+3%)

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.

Mexico RETC

350,000

300,000

250,000

200,000

150,000

100,000

50,000

Kilograms

2005 0 24,550 12,182 25,822

2010 329,917 83 46 5

Electric Power Generation,

Transmission and Distribution (+)

Other Fabricated Metal

Product Manufacturing (-100%)

Pipeline Transportation 

of Crude Oil (-100%)

Oil and Gas Extraction 

(-100%)
48 Commission for Environmental Cooperation

Table 20 presents the top pollutants released to land by the 

top five North American industry sectors, which together 

accounted for 87 percent of total releases to land in 2010. It 

shows how these releases changed from 2005 through 2010, as 

well as their distribution among the three countries—revealing 

that there was very little reporting from Mexico. Mexican facilities in all sectors reported approximately 513,000 kilograms 

in releases to land in 2010, an increase from about 83,000 

kilograms reported in 2005. A few of the largest reporters 

accounted for most of this increase, including the aforementioned CFE electric utility in Sinaloa; a John Deere agriculture, 

construction and mining machinery manufacturer in Coahuila; and the Coeur Mexicana silver mine in Chihuahua.

In the United States, significant proportions of the releases 

to land in 2010 of zinc and lead and their compounds 

were reported by the Red Dog mine in Alaska, one of the 

world’s largest producers of zinc and lead concentrates, 

from ore extracted at the site. Zinc and its compounds 

were also reported by the Canadian and US nonferrous 

metal (except aluminum) production and processing sector, 

with these releases increasing from 2005. A few of the top 

reporting facilities in 2010 accounted for large proportions of this increase, including two Canadian facilities, the 

Xstrata Canada–Kidd Metallurgical Site in Ontario, and the 

Hudson Bay Mining and Smelting Complex in Manitoba; 

and a US facility, the Asarco LLC Ray Complex–Hayden 

Smelter and Concentrator in Arizona. These same facilities 

were also among the top facilities in this sector accounting 

for the large increase in releases to land of lead and copper 

and their compounds from 2005 through 2010. 

In Canada, the Iron Ore Company of Canada’s Carol Lake 

Project in Newfoundland and Labrador accounted for 

large proportions of reported releases of manganese and 

its compounds in 2010. This company operates an open-pit 

mine for the extraction of iron ore to be made into pellets 

for steelmaking plants. Manganese is a naturally occurring 

metal found in rocks. Releases to land of this pollutant from 

the metal ore mining sector increased dramatically between 

2005 and 2010.

Large proportions of barium and its compounds were 

released to land by US electric utilities, with these releases 

increasing from 2005 through 2010. Barium and its compounds are only subject to PRTR reporting in the United 

States. Barium, a metal that is found only in ores, can 

be released to air during the mining and production of 

Table 20. Top Reporting Industry Sectors for Releases to Land, and Top Reported Pollutants, 

North America, 2005–2010

Industry Sector 

(NAICS-4 Code)

Releases to 

Land 2010 (kg) Pollutant

Releases to 

Land 2010 (kg)

% Change 

2005–2010

Canada 

NPRI (%) 

Mexico 

RETC (%) 

US TRI 

(%) 

Metal Ore Mining 

(2122) 1,182,056,081

Zinc (and compounds) (CA, US) 278,560,622 48 12 – 88

Manganese (and compounds) (CA, US) 256,011,595 2,167 84 – 16

Lead (and compounds) (CA, MX, US) 246,200,103 39 8 0 92

Electric Power Generation, 

Transmission and Distribution 

(2211)

141,871,753

Barium (and compounds) (US) 87,617,103 19 – – 100

Manganese (and compounds) (CA, US) 14,237,303 -6 6 – 94

Vanadium (and compounds) (CA, US) 10,281,526 -31 9 – 91

Coal Mining 

(2121) 108,515,793

Phosphorous, Total (CA) 65,209,962 189* 100 – –

Manganese (and compounds) (CA, US) 35,236,649 2,475 98 – 2

Barium (and compounds) (US) 2,143,851 -46 – – 100

Waste Treatment 

and Disposal (5622) 73,628,998

Asbestos (CA, MX, US) 26,744,810 184 85 – 15

Lead (and compounds) (CA, MX, US) 9,206,775 1 37 – 63

Zinc (and compounds) (CA, US) 8,273,055 -78 53 – 47

Nonferrous Metal

(except Aluminum)

Production/Processing 

(3314)

62,631,087

Zinc (and compounds) (CA, US) 27,663,595 182 62 – 38

Copper (and compounds) (CA, US) 14,949,119 92 26 – 74

Lead (and compounds) (CA, MX, US) 6,478,015 36 25 0 75

Total, Top 5 Sectors 1,568,703,713 Total, Top Pollutants 1,088,814,084

%, Top 5 Sectors, 

of Total Releases to Land 87

* Prior to 2006, no releases or transfers were reported by the Canadian coal mining sector; this change calculation is based on 2006–2010.

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.
Taking Stock North American Pollutant Releases and Transfers Vol. 14 49

barium compounds, as well as during the burning of coal 

and oil. US coal mines also reported releases to land of 

barium and its compounds, with these releases declining 

between 2005 and 2010.

Canadian coal mines were the top reporters of releases 

to land of total phosphorous, a pollutant subject to PRTR 

reporting only in Canada. The large increase in these 

releases can be attributed mainly to a small number of facilities, including the Coal Valley Resources–Obed coal mine 

in Alberta, which accounted for almost 75 percent of total 

releases to land of this pollutant in 2010, but did not report 

in the preceding years. 

Large releases to land of asbestos were reported in 2010 by 

the waste treatment and disposal sector, with 85 percent of 

these releases reported in Canada. A number of the facilities 

in this sector reported increases between 2005 and 2010, with 

two of them—the BFI Canada Ridge landfill in Ontario and 

the Paintearth landfill in Alberta—accounting for more than 

half of all these releases in 2010. Asbestos refers to a group of 

mineral fibers that occur naturally in the environment. Because 

of its heat-resistant characteristics, asbestos has been used in 

a wide variety of products, particularly for the construction 

industry (e.g., roofing shingles, tiles, cement products). 

2.5 Reported Releases to Underground Injection, 

2005–2010

On-site releases to underground injection accounted for 6 

percent of total releases and transfers in 2010, with facilities in Canada and the United States reporting 340,822,984 

kilograms—a decrease of 17 percent from 2005 levels. 

Underground injection is not subject to reporting under 

Mexico’s RETC.

Table 21 presents the releases to underground injection 

reported by Canadian and US facilities every year from 

2005 through 2010. While both countries saw reductions in 

these releases, the decrease was more appreciable in Canada 

(a decrease of more than 22 percent). In 2010, Canadian 

facilities accounted for just over 69 percent of total reported 

releases to underground injection (compared with 74 percent of the total in 2005), and US facilities accounted for 

just over 30 percent. This table also shows that the number 

of pollutants reported released to underground injection 

declined over this period.

Figure 18 presents the top 21 pollutants released to underground injection from 2005 through 2010 (including TRS 

compounds, as a result of their addition to Canada’s NPRI 

in 2007). These pollutants accounted for 97 percent and 96 

Table 21. Releases to Underground Injection Reported to the Canadian NPRI and US TRI, 2005–2010

PRTR

Releases to 

Underground 

Injection, 

2005 (kg)

Releases to 

Underground 

Injection, 

2006 (kg)

Releases to 

Underground 

Injection, 

2007 (kg)

Releases to 

Underground 

Injection, 

2008 (kg)

Releases to 

Underground 

Injection, 

2009 (kg)

Releases to 

Underground 

Injection, 

2010 (kg)

% Change 

2005–2010 

Number of 

Reported Pollutants

2005 2010

Canada NPRI 305,320,598 275,573,878 331,393,025 379,401,822 339,662,982 236,735,932 -22 60 51

Mexico RETC N/A N/A N/A N/A N/A N/A N/A N/A N/A

US TRI 106,976,204 101,684,627 95,457,452 87,242,354 82,275,125 104,087,051 -3 148 132

Total, North America 412,296,802 377,258,505 426,850,477 466,644,176 421,938,107 340,822,984 -17 170 151

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.

Petr Kratochvil
50 Commission for Environmental Cooperation

Figure 18. Releases to Underground Injection Reported in Canada and the United States, 

and Top Reported Pollutants, 2005–2010

Pollutant

Releases to 

Underground Injection 2005 (kg)

Releases to 

Underground Injection 2010 (kg)

% Change

2005–2010 

Hydrogen Sulfide (CA, MX) 289,746,824 133,484,005 -54

Nitric Acid and Nitrate Compounds (CA, US) 24,846,936 25,012,591 1

Ammonia, Total (CA, US) 19,628,595 18,454,856 -6

Methanol (CA, US) 15,258,090 18,988,100 24

Acetonitrile (CA, US) 7,802,994 8,647,998 11

Zinc (and compounds) (CA, US) 5,244,585 8,003,631 53

Formaldehyde (CA, MX, US) 5,205,312 5,997,854 15

Formic Acid (CA, US) 4,884,996 6,582,334 35

Acrylamide (CA, MX, US) 3,982,023 3,211,170 -19

Acrylonitrile (CA, MX, US) 3,661,761 3,707,954 1

Manganese (and compounds) (CA, US) 3,599,440 5,287,010 47

Lead (and compounds) (CA, MX, US) 2,792,670 4,307,991 54

Acrylic Acid (CA, US) 2,470,638 1,537,303 -38

Cyclohexanol (CA, US) 1,576,962 660,867 -58

Hydrogen Cyanide (CA, US) 1,397,500 61,930 -96

Cyanides (CA, MX, US) 1,319,546 948,183 -28

Phosphorous, Total (CA) 1,296,185 1,490 -100

Ethylene Glycol (CA, US) 1,196,509 867,408 -28

N-Methyl-2-Pyrrolidone (CA, US) 1,110,273 1,366,346 23

Toluene (CA, US) 894,759 521,445 -42

Total Reduced Sulfur (TRS) (CA) – 79,325,490 38*

Total, Top 21 Pollutants Released to Underground Injection 397,916,600 326,975,956 -18

Total, All Pollutants Released to Underground Injection 412,296,802 340,822,984 -17

%, Top Pollutants, of Total Releases to Underground Injection 97 96

 2005 2010

350,000,000

300,000,000

250,000,000

200,000,000

150,000,000

100,000,000

50,000,000

Kilograms

Canada NPRI Mexico RETC (N/A)

0 0

US TRI

106,976,204 104,087,051

236,735,932

305,320,598

*

 Percent change calculated from 2007 (first year of TRS reporting in Canada).

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.
Taking Stock North American Pollutant Releases and Transfers Vol. 14 51

percent, respectively, of the total in 2005 and 2010. This 

figure shows that releases of about half of these pollutants 

decreased over this period, with some (e.g., hydrogen sulfide) decreasing notably. Releases to underground injection of other substances increased, some notably (e.g., zinc, 

manganese and lead and their compounds). 

Of the substances shown in this figure, only five are subject to 

PRTR reporting in all three countries. Perhaps more importantly, given that underground injection is only reported in 

Canada and the United States, three of these pollutants are 

subject to PRTR reporting in Canada but not the United 

States, including two pollutants reported in very large proportions, hydrogen sulfide and TRS. 

2.5.1 Top Sectors Reporting Releases to Underground Injection 

in Canada and the United States, 2005–2010

Figure 19 presents the top five sectors in Canada and the 

United States reporting releases to underground injection from 2005 through 2010. These sectors accounted for 

325,903,515 kilograms, or almost 96 percent of the total in 

2010, with the oil and gas extraction sector alone reporting 

226.8 million kilograms (over 66 percent of the total). As 

mentioned earlier, the oil and gas extraction sector is not 

subject to the US TRI.

Figure 20 illustrates the predominance of the oil and gas 

extraction sector for releases to underground injection in 

Canada, even with a 15 percent decline in these releases 

between 2005 and 2010. Only ten sectors in Canada reported 

releases to underground injection throughout this period. 

In the United States, the top reporting sector for releases to 

underground injection was the basic chemical manufacturing sector, which reported a decline of 5 percent in these 

releases from 2005 through 2010. The number of reporting 

facilities in this sector remained about the same in both 

years. The waste treatment and disposal sector in this country also reported a decrease over this period, of 54 percent. 

Only five facilities in this sector reported releases to underground injection in 2005 and of these, a couple of Texas 

facilities accounted for most of this decrease. There was a 49 

percent increase in reported releases to underground injection by the US metal ore mining sector, due to reporting 

by the Hecla Greens Creek silver mine in Alaska (the top 

reporter among six US metal ore mining facilities reporting 

releases to underground injection over this period).

Figure 19. Top Reporting Industry Sectors for Releases to Underground Injection in Noth America*, 

2005–2010 

400

350

300

250

200

150

100

50

Millions of Kilograms

Oil and Gas Extraction 

(-15%)

Basic Chemical Manufacturing

(-5%)

Pesticide, Fertilizer, and 

Other Agricultural Chemical 

Manufacturing (+24%)

Resin, Synthetic Rubber, and 

Artificial Synthetic Fibers and 

Filaments Manuf. (0%)

Metal Ore Mining 

(+49%)

Sector (percent change between 2005 and 2010)

 2005 

 2006

 2007 

 2008

 2009 

 2010

* Underground injection is not reported under Mexico’s PRTR program. 

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.
52 Commission for Environmental Cooperation

Figure 20. Top Reporting Industry Sectors for Releases to Underground Injection* in Canada 

and the United States, 2005–2010 

Canada NPRI

US TRI

300,000,000

250,000,000

200,000,000

150,000,000

100,000,000

50,000,000

70,000,000

60,000,000

50,000,000

40,000,000

30,000,000

20,000,000

10,000,000

Kilograms Kilograms

2005 265,452,557 32,029,912 5,484,034 2,112,126

2010 226,826,611 346,127 6,401,958 2,554,688

2005 59,522,746 14,597,234 10,213,591 12,122,105

2010 56,577,024 14,635,302 12,757,957 5,623,449

Oil and Gas Extraction

(-15%)

Basic Chemical 

Manufacturing 

(-5%)

Petroleum and Coal 

Products Manufacturing 

(+17%)

Pesticide, Fertilizer, Other 

Agricultural Chemical 

Manufacturing (+25%)

Waste Treatment 

and Disposal 

(-54%)

Pesticide, Fertilizer, Other 

Agricultural Chemical 

Manufacturing (+21%)

Support Activities for 

Mining/Oil and Gas 

Extraction (-99%)

Resin, Synthetic Rubber, 

Artificial Fibers 

Manufacturing (+0.3%)

* Underground injection is not reported under Mexico’s PRTR program. 

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.
Taking Stock North American Pollutant Releases and Transfers Vol. 14 53

Table 22 presents the top pollutants released to underground 

injection by the top five industry sectors, which together 

accounted for almost 96 percent of total releases to underground injection reported by Canadian and US facilities in 

2010. It shows how these releases changed from 2005 through 

2010, as well as their distribution between the two countries. 

The impacts of key differences in PRTR reporting requirements between the two countries are evident in this table—

especially the lack of reporting in the United States by the oil 

and gas extraction sector, and lack of reporting of hydrogen 

sulfide and TRS, two of the top-reported pollutants in Canada. 

In 2010, the Canadian oil and gas extraction sector reported 

more than 99 percent of total releases to underground injection of hydrogen sulfide, with these releases decreasing by 48 

percent between 2005 and 2010. Two gas processing plants 

accounted for large proportions of this decrease: the Husky 

Oil–Rainbow Lake Gas plant in Alberta, and the Canadian 

Natural Resources–Stoddart 02-34 Sour Gas Plant in British 

Columbia. Together, these facilities reported over 95 million 

kilograms of hydrogen sulfide, or about 37 percent of the total, 

to underground to underground injection in 2005, but none 

in 2010. However, these same facilities reported significant 

increases in hydrogen sulfide sent for off-site disposal in 2010.

The largest proportions of pollutants released to underground 

injection by the Canadian oil and gas extraction sector were 

of hydrogen sulfide and TRS. As mentioned earlier, these 

two pollutants are closely related: hydrogen sulfide makes up 

the largest proportion of all the reduced sulfur compounds 

that are reported as TRS and is also reported separately. In 

fact, the data from this sector as of 2007 (when TRS was 

added to the NPRI list of substances) show that certain facilities reporting the largest releases to underground injection 

reported the exact same amounts of both hydrogen sulfide 

and TRS—suggesting likely double-counting. As a result, the 

NPRI conducted a review of these data with the objective of 

providing additional reporting guidance to this sector and 

others reporting these pollutants. 

Reported releases to underground injection of methanol 

from this sector, and especially from gas-processing plants 

located in Alberta, increased between 2005 and 2010. This 

toxic substance is used in the production of a number of 

chemicals, and most commonly as a raw material for the 

production of methyl t-butyl ether (MTBE), a gasoline 

additive. It is also a common component of the fluids used 

in hydraulic fracturing, an activity that is not subject to 

reporting under any of the three PRTR programs.

Table 22. Top Reporting Industry Sectors for Releases to Underground Injection, and Top Pollutants, 

Canada and the United States, 2005–2010

Industry Sector (NAICS-4 Code)

Releases to 

Underground 

Injection 

2010 (kg) Pollutant

Releases to 

Underground 

Injection 

2010 (kg)

% Change 

2005–2010

Canada 

NPRI 

(%)

US TRI 

(%)

Oil and Gas Extraction (2111) 226,826,611

Hydrogen Sulfide (CA, MX) 132,870,129 -48 100 –

Total Reduced Sulfur (TRS) (CA) 78,737,513 37* 100 –

Methanol (CA, US) 12,284,369 129 100 –

Basic Chemical Manufacturing (3241) 56,663,807

Ammonia, Total (CA, US) 9,665,867 -16 – 100

Acetonitrile (CA, US) 8,630,673 14 – 100

Nitric Acid and Nitrate Compounds (CA, US) 7,737,925 -16 – 100

Pesticide, Fertilizer, Other Agricultural 

Chemical Manufacturing (3253) 15,312,645

Formaldehyde (CA, MX, US) 4,581,591 27 – 100

Nitric Acid and Nitrate Compounds (CA, US) 3,988,795 50 6 94

Formic Acid (CA, US) 2,902,991 23 – 100

Resin, Synthetic Rubber, and 

Artificial Synthetic Fibers/Filaments 

Manufacturing (3252)

14,635,302

Nitric Acid and Nitrate Compounds (CA, US) 11,026,107 2 – 100

Formic Acid (CA, US) 2,596,341 60 – 100

n-Butyl Alcohol (CA, US) 231,271 -58 – 100

Metal Ore Mining (2122) 12,465,150

Zinc (and compounds) (CA, US) 7,711,070 55 – 100

Lead (and compounds) (CA, MX, US) 4,092,070 56 – 100

Arsenic (and compounds) (CA, MX, US) 635,029 54 – 100

Total, Top 5 Sectors 325,903,515 Total, Top Pollutants 287,691,742

%, Top 5 Sectors, of Total Releases 

to Underground Injection 96

*Percent change calculated from 2007 (first year of TRS reporting in Canada). 

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.
54 Commission for Environmental Cooperation

The majority of releases to underground injection by the other 

top industry sectors shown in this table were reported by 

facilities in the United States. As in Canada, a relatively small 

number of US sectors (i.e., a maximum of 25 between 2005 

and 2010) use underground injection as a waste management 

method. Unlike the other US sectors featured in this table, 

which reported releases to underground injection of chemicals 

such as ammonia and nitric acid/nitrate compounds, the metal 

ore mining sector reported large proportions of metals: zinc, 

lead and arsenic and their compounds (with these releases 

increasing notably from 2005 through 2010).

Underground injection is a waste management method 

used by certain sectors, such as chemical manufacturing 

and the oil and gas industry. There is debate about whether 

injection of metals and other waste into deep wells below 

fresh-water aquifers can be done in a way that prevents the 

contaminants from leaking or migrating upward into the 

fresh water and contaminating wells. 

2.6 Reported Off-site Releases to Disposal, 2005–2010

Reported off-site releases to disposal21 accounted for 17 

percent of total releases and transfers in 2010, with North 

American facilities reporting 930,493,737 kilograms—an 

increase of 42 percent from 2005 levels. 

Table 23 presents the off-site releases to disposal reported by 

North American facilities every year from 2005 through 2010. 

It reveals differences among the three countries in the amounts 

reported, as well as the direction of the 2005–2010 changes. For 

instance, the data show that the large increase in these releases 

was driven by Canadian reporting, while reported releases in 

Mexico and the United States declined. Of the North American total for 2005, Canadian facilities accounted for almost 

49 percent, Mexican facilities for 7 percent, and US facilities for just over 44 percent; by 2010, Canadian facilities 

accounted for almost 78 percent, Mexican facilities for 0.5 

percent, and US facilities for almost 22 percent.

Figure 21 presents the top pollutants released off-site for disposal, and the changes in their reported amounts between 

2005 and 2010. The list includes TRS, which Canadian facilities began reporting in 2007 as a result of its addition to 

the NPRI. These 21 substances accounted for 96 percent and 

97 percent, respectively, of total reported off-site releases to 

disposal in 2005 and 2010. 

Releases to disposal of eight of these pollutants declined 

between 2005 and 2010, some of them notably (e.g., lead 

and arsenic and their compounds, aluminum), while others 

saw very large increases over this period. Two pollutants, 

TRS compounds and hydrogen sulfide, were reported in 

very large proportions in 2010, but as indicated in this 

figure, these are not subject to reporting in all three countries. In fact, of the top pollutants shown in the table, only 

five are subject to the three PRTRs.

21. The term “off-site releases to disposal” used in Taking Stock combines a variety of methods, due to differences in the terminology used by each PRTR program. It includes 

some of the same methods used on-site, such as underground injection and disposal in either confined or unconfined conditions. 

Table 23. Releases Off-site to Disposal Reported to the North American PRTRs, 2005–2010

PRTR Releases to 

Disposal, 

2005 (kg)

Releases to 

Disposal, 

2006 (kg)

Releases to 

Disposal, 

2007 (kg)

Releases to 

Disposal, 

2008 (kg)

Releases to 

Disposal, 

2009 (kg)

Releases to 

Disposal, 

2010 (kg)

% Change 

2005-2010

Number of 

Reported Pollutants

2005 2010

Canada NPRI 318,253,547 369,967,875 434,038,888 559,369,315 539,594,725 724,086,696 128 111 120

Mexico RETC 45,996,161 2,632,089 11,250,368 19,747,212 43,248,981 4,695,794 -90 51 49

US TRI 289,038,956 299,370,770 306,643,881 259,694,181 178,018,104 201,711,247 -30 318 321

Total, North America 653,288,663 671,970,735 751,933,138 838,810,708 760,861,811 930,493,737 42 355 366

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.
Taking Stock North American Pollutant Releases and Transfers Vol. 14 55

Figure 21. Releases to Disposal Reported in Canada, Mexico and the United States, and Top 

Reported Pollutants, 2005–2010

 2005 2010

800,000,000

700,000,000

600,000,000

500,000,000

400,000,000

300,000,000

200,000,000

100,000,000

Kilograms

Pollutant Releases to Disposal 2005 (kg) Releases to Disposal 2010 (kg) % Change 2005–2010 

Hydrogen Sulfide (CA, MX) 250,948,839 479,650,431 91

Zinc (and compounds) (CA, US) 135,864,414 78,427,592 -42

Lead (and compounds) (CA, MX, US) 58,976,550 16,424,428 -72

Manganese (and compounds) (CA, US) 43,267,132 36,360,643 -16

Barium (and compounds) (US) 26,230,890 26,770,845 2

Aluminum (fume or dust) (CA, US) 17,222,123 3,962,937 -77

Chromium (and compounds) (CA, MX, US) 15,998,823 12,814,868 -20

Copper (and compounds) (CA, US) 12,081,462 12,715,615 5

Nitric Acid and Nitrate Compounds (CA, US) 10,349,008 6,194,076 -40

Arsenic (and compounds) (CA, MX, US) 9,589,421 1,862,287 -81

Phosphorous, Total (CA) 9,445,774 11,744,136 24

Sulfuric Acid (CA, US) 8,882,662 1,751,106 -80

Nickel (and compounds) (CA, MX, US) 8,597,411 9,371,894 9

Methanol (CA, US) 6,060,544 8,602,919 42

Ammonia, Total (CA, US) 5,161,660 5,197,391 1

Vanadium (and compounds) (CA, US) 4,023,761 6,344,130 58

Asbestos (CA, MX, US) 2,665,951 8,485,430 218

Aluminum Oxide (fibrous forms) (CA, US) 1,308,665 1,900,450 45

Ethylene Glycol (CA, US) 893,379 1,753,120 96

n-Hexane (CA, US) 98,888 1,513,498 1,431

Total Reduced Sulfur (TRS) (CA) – 173,146,179 551*

Total, Top 21 Pollutants Released to Disposal 627,667,356 904,993,977 -37

Total, All Pollutants Released to Disposal 653,288,663 930,493,737 -36

%, Top 21 Pollutants of Total Releases to Disposal 96 97

*

 Percent change calculated from 2007 (first year of TRS reporting in Canada).

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.

Canada NPRI

318,253,547

724,086,696

Mexico RETC

45,996,161

4,695,794

US TRI

201,711,247

289,038,956
56 Commission for Environmental Cooperation

2.6.1 Top Sectors Reporting Off-site Releases to Disposal in 

North America, 2005–2010

The five North American industry sectors reporting the 

largest proportions of total off-site releases to disposal 

between 2005 and 2010 are shown in Figure 22. These sectors accounted for 816,323,493 kilograms, or almost 88 percent of all such releases, in 2010. 

This figure shows the significant increase in 2010 in reported 

releases to disposal from the oil and gas extraction sector, 

with this sector alone reporting more than 71 percent of 

the North American total for releases to disposal that year. 

Almost all of these releases were reported by Canadian 

facilities and much of the increase can be attributed to four 

facilities which together accounted for about 645 million kilograms in releases to disposal in 2010 (or almost 97 percent 

of the total for this sector). Of these four facilities, three did 

not report in 2005. The top reporter for this sector in 2010, 

the Spectra Kwoen gas plant in British Columbia, reported 

under the NAICS code for support activities for mining and 

oil and gas extraction in the preceding years; however, on 

the basis of guidance provided by NPRI, the facility changed 

its sector designation as of 2010. 

Figure 23 presents the top sectors reporting off-site releases 

to disposal in each country. It reveals that the Mexican 

metal ore mining sector (the top sector for off-site releases 

to disposal in that country in 2005) reported an important 

decrease over the 2005–2010 period. Much of this decrease 

can be attributed to two facilities: the Compañía Fresnillo 

silver mine in Chihuahua, and the Compañía Minera Nuevo 

Monte lead and zinc mine in Hidalgo. Together, these facilities accounted for almost all of the reported off-site releases 

to disposal from this sector in 2005; however, the first facility 

did not report after 2005 (and, as mentioned previously, is 

looking into data reporting errors for 2005); and the second 

did not report after 2007 and has since ceased to operate 

(see Table 8). 

The decrease in reported off-site releases to disposal in the 

United States was driven by the iron and steel mills and 

ferroalloy manufacturing sector, whose releases declined 

by over 50 percent from 2005 through 2010. Among the 

top reporters in this sector were the Nucor Steel and Steel 

Dynamics facilities located in Indiana, which reported similarly large amounts in both 2005 and 2010; however, in 

2010 the pollutants were transferred for recycling, instead 

of being released to disposal.

Figure 22. Top Reporting Industry Sectors for Releases Off-site to Disposal, North America, 

2005–2010 

700

650

600

550

500

450

400

350

300

250

200

150

100

50

Millions of Kilograms

Oil and 

Gas Extraction

(+4,505%)

Iron and Steel Mills and 

Ferroalloy Manufacturing 

(-47%)

Electric Power Generation, 

Transmission and Distribution 

(0%)

Waste Treatment 

and Disposal 

(+34%)

Basic Chemical

Manufacturing (-29%)

Sector (percent change between 2005 and 2010)

 2005 

 2006

 2007 

 2008

 2009 

 2010

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.
Taking Stock North American Pollutant Releases and Transfers Vol. 14 57

Figure 23. Top Reporting Industry Sectors for Releases to Disposal in Canada, Mexico and 

the United States, 2005–2010

Canada NPRI

700,000,000

600,000,000

500,000,000

400,000,000

300,000,000

200,000,000

100,000,000

Kilograms

2005 241,071,897 14,441,254 11,604,375

2010 6,449 664,953,818 12,501,888 

Support Activities for Mining/Oil 

and Gas Extraction (-100%) 

Iron and Steel Mills and Ferroalloy 

Manufacturing (+8%)

Oil and Gas Extraction 

(+4,505%)

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.

Mexico RETC

50,000,000

45,000,000

40,000,000

35,000,000

30,000,000

25,000,000

20,000,000

15,000,000

10,000,000

5,000,000

Kilograms

Metal Ore Mining

(-100%) 

Coating, Engraving and Heat Treating 

and Allied Activities (-57%)

Basic Chemical Manufacturing 

(-54%)

2005 43,178,942 558,713 406,625

2010 174,442 255,185 176,193 

US TRI

140,000,000

120,000,000

100,000,000

80,000,000

60,000,000

40,000,000

20,000,000

Kilograms

Iron and Steel Mills 

and Ferroalloy Manufacturing (-53%)

Basic Chemical Manufacturing 

(-3%)

Electric Power Generation, 

Transmission/Distribution (-1%)

2005 116,818,824 36,556,293 20,638,658

2010 55,030,094 36,129,071 19,922,604 
58 Commission for Environmental Cooperation

Table 24 presents the top pollutants released off-site to disposal by the five North American industry sectors, which 

together accounted for about 88 percent of all such releases 

in 2010. It shows how these releases changed from 2005 

through 2010, as well as their distribution among the three 

countries. This table illustrates the impacts of differences 

in national PRTR reporting requirements, for both pollutants and sectors, on the releases to disposal reported by 

North American facilities. For example, only four of the 

top pollutants are subject to reporting in Mexico, where 

reported off-site releases to disposal were sparse. Less than 

1 percent of the releases of hydrogen sulfide from the oil 

and gas extraction sector were reported in that country. 

Except for about 106,000 kilograms in 2009, this Mexican 

sector reported a maximum of 60,000 kilograms per year in 

releases and transfers of all substances over the 2005–2010 

period (with the majority reported released to air). 

In Canada, the largest proportions released off-site to disposal 

by the oil and gas extraction sector were of hydrogen sulfide 

and TRS. As with reported releases to underground injection 

by this sector, certain facilities reporting the largest off-site 

releases to disposal reported the exact same amounts of both 

hydrogen sulfide and TRS, indicating likely double-counting. 

The NPRI conducted a review of these data with the objective 

of providing additional reporting guidance to this and other 

sectors handling these two pollutants. 

In addition to the aforementioned releases off-site to disposal by the iron and steel mills and ferroalloy manufacturing sector, mainly in the United States, US electric 

utilities also accounted for large releases to disposal of 

metals, including more than 22 million kilograms of barium 

and its compounds (which are not subject to PRTR reporting in Canada and Mexico). 

This table also shows a notable increase in reported off-site 

releases to disposal of asbestos by the waste treatment and 

disposal sector, much of it reported by Canadian facilities. In 

fact, most of this increase can be attributed to one facility in the 

province of Ontario, which began reporting in 2007. It reported 

the majority of all off-site releases to disposal of this pollutant. 

Table 24. Top Reporting Industry Sectors for Releases to Disposal, and Top Reported Pollutants, 

North America, 2005–2010

Industry Sector 

(NAICS-4 Code)

Releases to 

Disposal 2010 (kg) Pollutant

Releases to 

Disposal 2010 (kg)

 % Change 

2005–2010

Canada 

NPRI (%) 

Mexico 

RETC (%) 

US TRI 

(%) 

Oil and Gas Extraction 

(2111) 664,974,765

Hydrogen Sulfide (CA, MX) 479,624,522 4,439 100 0 –

Total Reduced Sulfur (TRS) (CA) 173,140,605 551* 100 – –

Methanol (CA, US) 6,083,249 90 100 – –

Iron and Steel Mills and 

Ferroalloy Manufacturing 

(3311)

67,735,221

Zinc (and compounds) (CA, US) 42,879,313 -56 16 – 84

Manganese (and compounds) (CA, US) 14,022,430 -22 21 – 79

Lead (and compounds) (CA, MX, US) 2,435,632 -56 19 0 81

Electric Power Generation, 

Transmission and 

Distribution (2211)

38,626,043

Barium (and compounds) (US) 22,376,547 4 – – 100

Manganese (and compounds) (CA, US) 4,231,980 -1 21 – 79

Vanadium (and compounds) (CA, US) 3,521,065 10 16 – 84

Waste Treatment and 

Disposal (5622) 23,901,978

Zinc (and compounds) (CA, US) 6,396,020 90 13 – 87

Asbestos (CA, MX, US) 3,129,075 23,005 98 – 2

Copper (and compounds) (CA, US) 1,971,182 8 38 – 62

Basic Chemical 

Manufacturing (3251) 21,085,487

Manganese (and compounds) (CA, US) 4,299,221 -11 8 – 92

Copper (and compounds) (CA, US) 4,103,569 294 0 – 100

Nickel (and compounds) (CA, MX, US) 1,993,484 237 0 0 100

Total, Top 5 Sectors 816,323,493 Total, Top Pollutants 770,207,896

%, Top 5 Sectors, of Total 

Off-site Releases to Disposal 88

*Percent change calculated from 2007 (first year of TRS reporting in Canada). 

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.
Taking Stock North American Pollutant Releases and Transfers Vol. 14 59

2.7 Reported Off-site Transfers, 2005–2010

Off-site transfers to recycling, as well as other transfers (i.e., 

for treatment, energy recovery or sewage)22 accounted for 

31 percent of total releases and transfers in 2010, with North 

American facilities reporting 1,719,727,914 kilograms—a 

decrease of 8 percent from 2005 levels. Of this amount, 

transfers to recycling accounted for almost 69 percent. These 

off-site transfers are presented in Table 25.

This table reveals that off-site transfers reported by Canadian facilities increased between 2005 and 2010, with transfers to treatment increasing notably. In Mexico and the 

United States, off-site transfers generally decreased over this 

period. The 8 percent decrease in reported off-site transfers 

in North America was driven by reporting in the United 

States, which accounted for 81 percent of the total in 2005, 

but almost 73 percent of the total in 2010. These proportions 

are shown in Figure 24.

Table 25. Transfers to Recycling and Other Transfers Reported to the North American PRTRs, 

2005–2010

PRTR Type of Transfer 2005 (kg) 2006 (kg) 2007 (kg) 2008 (kg) 2009 (kg) 2010 (kg)

% Change 

2005–2010

Canada NPRI

Transfers to Recycling 287,996,838 367,243,959 393,418,566 334,692,771 338,068,807 314,690,946 9

Other Transfers (except metals) 51,147,920 48,632,111 41,048,987 58,726,305 51,142,593 125,391,387 145

Treatment 27,131,167 23,960,688 20,477,911 36,674,798 33,043,522 106,736,551 293

Sewage/POTWs 12,918,998 13,080,557 11,987,838 14,305,327 12,178,100 13,239,389 2

Energy recovery 11,097,755 11,590,866 8,583,238 7,746,180 5,920,972 5,415,448 -51

Mexico RETC

Transfers to Recycling 12,250,860 4,301,382 5,740,531 12,062,700 10,454,526 11,030,455 -10

Other Transfers (except metals) 639,296 891,057 413,448 571,276 238,404 202,517 -68

Treatment 74,755 73,366 135,897 349,767 67,124 63,877 -15

Sewage/POTWs 242 507 19 46 362 436 80

Energy recovery 564,299 817,184 277,531 221,464 170,918 138,203 -76

US TRI

Transfers to Recycling 959,480,037 996,943,819 963,963,949 896,547,624 739,740,400 857,036,373 -11

Other Transfers (except metals) 548,865,038 518,163,124 483,229,907 435,591,243 367,790,854 411,376,237 -25

Treatment 152,693,617 147,733,066 129,737,835 115,186,424 102,671,292 112,308,269 -26

Sewage/POTWs 120,124,600 118,157,229 114,980,193 115,725,886 98,633,884 104,557,900 -13

Energy recovery 276,046,821 252,272,830 238,511,879 204,678,933 166,485,678 194,510,068 -30

Total, North 

America

Transfers to Recycling 1,259,727,734 1,368,489,160 1,363,123,046 1,243,303,095 1,088,263,733 1,182,757,774 -6

Other Transfers (except metals) 600,652,254 567,686,293 524,692,341 494,888,824 419,171,852 536,970,141 -11

Total, All Transfers 1,860,379,989 1,936,175,453 1,887,815,387 1,738,191,920 1,507,435,585 1,719,727,914 -8

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.

2005 2010 2005 2010 2005 2010

 Recycling Transfers (kg) Total Other Transfers (kg)

959,480,037

51,147,920 639,296

548,865,038

287,996,838

12,250,860

125,391,387

314,690,946 411,376,237

11,030,455

857,036,373

202,517

Canada NPRI Mexico RETC US TRI

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.

Figure 24. Transfers to Recycling and Other Transfers Reported in Canada, Mexico and the United 

States, 2005–2010

22. In order to harmonize data that are categorized differently among the three PRTR programs, “other transfers” exclude metals sent to treatment, energy recovery or 

sewage/sewage treatment plants. For more information, see Appendix 1.
60 Commission for Environmental Cooperation

Table 26 presents the top pollutants transferred to recycling 

and otherwise transferred between 2005 and 2010. 

The top ten pollutants transferred to recycling accounted for 

90 percent and 92 percent, respectively, of all such transfers 

in 2005 and 2010, with metal compounds accounting for 

close to 90 percent of the total each year. Most of the top 

pollutants saw decreases over this period, with the exception of zinc, manganese and chromium and their compounds. Many facilities choose to recycle metals because 

of their increased market value, and in order to recuperate 

some of the cost of these high-priced process inputs.23

Total amounts of the top ten pollutants otherwise transferred (for energy recovery, sewage, or other treatment) 

decreased somewhat between 2005 and 2010. Four of these 

top pollutants were the same as those sent for recycling, 

namely toluene, ethylene glycol, xylenes, and sulfuric acid; 

but while transfers to recycling of xylenes and sulfuric acid 

declined between 2005 and 2010, their transfers to other 

treatment increased notably. Of the top pollutants shown 

in this table, only five are subject to PRTR reporting in all 

three countries.

2.7.1 Top Sectors Reporting Off-site Transfers in North America, 

2005–2010

The five North American industry sectors reporting the 

largest proportions of total off-site transfers between 2005 

and 2010 are shown in Figure 25. These sectors accounted 

for just over 760 million kilograms, or about 41 percent of 

total reported transfers in 2010. 

This figure shows that off-site transfers from the nonferrous metal (except aluminum) production and processing 

sector and the iron and steel mills and ferroalloy manufacturing sector increased notably between 2005 and 2010, 

while transfers from the other top sectors declined over this 

period. However, there were differences among the three 

countries in the top reporting sectors for off-site transfers, 

as shown in Figure 26.

This figure shows that the increase in off-site transfers from 

the nonferrous metal production and processing sector was 

driven by reporting in Canada, with facilities reporting an 

increase of 163 percent. Much of this increase was due to 

reporting by the Xstrata Canada–Kidd Metallurgical Site in 

Pollutant

Recycling 

Transfers 

2005 (kg)

Recycling 

Transfers 

2010 (kg)

% Change 

2005–2010

Copper (and compounds) (CA, US) 335,537,034 271,417,257 -19

Zinc (and compounds) (CA, US) 232,333,621 290,216,625 25

Lead (and compounds)

(CA, MX, US) 192,799,213 172,808,501 -10

Manganese (and compounds)

(CA, US) 83,729,375 94,295,640 13

Chromium (and compounds)

(CA, MX, US) 73,951,815 82,440,520 11

Nickel (and compounds)

(CA, MX, US) 73,886,623 66,300,180 -10

Sulfuric Acid (CA, US) 72,339,458 60,399,729 -17

Ethylene Glycol (CA, US) 36,816,433 30,350,377 -18

Xylenes (CA, US) 19,369,014 8,872,640 -54

Toluene (CA, US) 16,005,048 9,801,089 -39

Total, Top 10 Pollutants 

Transferred to Recycling 1,136,767,634 1,086,902,559 -37

Total, All Pollutants 

Transferred to Recycling 1,259,727,734 1,182,757,774 -36

%, Top Pollutants, 

of Total Recycling Transfers 90 92

Pollutant

Other Transfers 

(except metals) 

2005 (kg)

Other Transfers 

(except metals) 

2010 (kg)

% Change 

2005–2010

Methanol (CA, US) 114,301,833 81,765,295 -28

Nitric Acid/Nitrate 

Compounds (CA, US) 80,496,753 67,223,219 -16

Toluene (CA, US) 69,446,138 51,124,205 -26

Xylenes (CA, US) 51,327,726 69,734,430 36

Ethylene Glycol (CA, US) 21,134,478 18,374,290 -13

Ethylene (CA, US) 12,276,047 14,022,033 14

Ammonia, Total (CA, US) 10,776,237 12,657,515 17

Sulfuric Acid (CA, US) 2,907,129 14,647,419 404

1,2-Dichlorobenzene 

(CA, MX, US) 530,760 17,026,422 3,108

1,1,2-Trichloroethane 

(CA, MX, US) 234,645 14,230,314 5,965

Total, Top 10 Pollutants, 

Other Transfers 363,431,745 360,805,143 -37

Total, All Pollutants, 

Other Transfers 600,652,254 536,970,141 -36

%, Top Pollutants, 

of Total Other Transfers 61 67

Table 26. Top Reported Pollutants, Transfers to Recycling and Other Transfers, North America, 2005–2010

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.

23. CEC. 2011. Taking Stock: North American Pollutant Releases and Transfers 13. Montreal, Canada: Commission for Environmental Cooperation.
Taking Stock North American Pollutant Releases and Transfers Vol. 14 61

Figure 25. Top Reporting Industry Sectors for Transfers to Recycling and Other Transfers, 

North America, 2005–2010 

300

250

200

150

100

50

Millions of Kilograms

Nonferrous Metal

(except Aluminum) 

Production and Processing 

(+33%)

Iron and Steel 

Mills and Ferroalloy 

Manufacturing 

(+40%)

Waste Treatment 

and Disposal (-14%)

Other Electrical Equipment 

and Component 

Manufacturing (-24%)

Basic Chemical 

Manufacturing

(-21%)

 2005 

 2010

Sector (percent change between 2005 and 2010)

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.

Figure 26. Top Reporting Industry Sectors for Transfers to Recycling and Other Transfers, 

in Canada, Mexico and the United States, 2005–2010

Canada NPRI

200,000,000

180,000,000

160,000,000

140,000,000

120,000,000

100,000,000

80,000,000

60,000,000

40,000,000

20,000,000

Kilograms

2005 65,636,819 51,387,028 2,514,762

2010 172,943,635 57,549,685 79,761,026

Nonferrous Metal (except Aluminum) 

Production/Processing (+163%) 

Remediation and Other Waste 

Management Services (+3,072%)

Petroleum and Coal 

Products Manufacturing (+12%)
62 Commission for Environmental Cooperation

northern Ontario, which comprises a copper smelter and 

refinery for metals extracted at its nearby mine. This facility 

accounted for over 70 percent of all reported off-site transfers 

to recycling from this sector in 2010. In contrast, reported offsite transfers from the nonferrous metal sector in the United 

States declined by 29 percent between 2005 and 2010. In that 

country, the iron and steel mills and ferroalloy manufacturing 

sector reported a 39 percent increase, with a number of top 

reporting facilities, including the Steel Dynamics facility in 

Indiana and about ten Nucor Steel facilities, accounting for 

this increase (mainly as transfers to recycling).

A notable increase was also seen in reported off-site transfers from the Canadian remediation and waste management 

services sector. Most of this can be attributed to reporting 

by the Envirosort Inc. facility in Red Deer, Alberta (owned 

by Clean Harbors Canada), which began reporting in 2009. 

It reported transfers to treatment of more than 75 million 

2005 5,666,643 1,711,947 303,242

2010 4,483,358 664,695 2,602,119 

2005 136,024,073 166,776,083 138,438,359

2010 188,445,837 138,454,147 98,004,190

Kilograms

US TRI

Iron and Steel Mills and 

Ferroalloy Manufacturing (+39%)

Nonferrous Metal (except Aluminum) 

Production/Processing (-29%)

Basic Chemical 

Manufacturing (-17%)

200,000,000

180,000,000

160,000,000

140,000,000

120,000,000

100,000,000

80,000,000

60,000,000

40,000,000

20,000,000

Mexico RETC

6,000,000

5,000,000

4,000,000

3,000,000

2,000,000

1,000,000

Kilograms

Other Electrical Equipment and 

Component Manufacturing (-21%)

Foundries

(+758%)

Motor Vehicle Parts 

Manufacturing (-61%)

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.
Taking Stock North American Pollutant Releases and Transfers Vol. 14 63

kilograms of the total 91.8 million kilograms reported by 

this sector in 2010. 

In Mexico, the top two reporting sectors saw decreases in 

reported off-site transfers over this period. These transfers were dominated by the other electrical equipment 

and component manufacturing sector, which reported a 

21 percent decrease between 2005 and 2010. Two of the 

facilities that accounted for the majority of off-site transfers to recycling from this sector in 2005 did not report in 

2010. They were Enertec facilities based in Guanajuato and 

Nuevo León. 

The Mexican foundry sector saw a large increase in off-site 

transfers. With no more than 11 facilities reporting, transfers 

to recycling reported by two of the top facilities in 2010—the 

LBQ Foundry in Querétaro and the Deacero–Celaya steel 

laminating facility in Guanajuato—accounted for almost 87 

percent of total off-site transfers by the sector that year. 

2.7.2 Reported Cross-border Transfers, 2006–2010

Some of the off-site transfers reported by industrial facilities 

were across national borders. They included pollutants transferred for disposal, recycling, treatment, or energy recovery. 

Integrated cross-border transfers data from the three PRTR 

programs are available starting with the 2006 reporting year. 

In 2010, almost 125 million kilograms of pollutants were 

transferred across North American borders, a decrease of 

approximately 46 percent from 2006 levels. These transfers 

are depicted in Figure 27. 

Figure 27. Reported Cross-border Transfers in North America, 2006–2010

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.

Total Canada to US, 2010:

78,346,332 kg Total US to Canada, 2010:

9,230,293 kg

Total Mexico to US, 2010:

687,532 kg

Total US to Mexico, 2010:

36,222,128 kg

2006–2010 Change

2006 2007 2008 2009 2010

2006–2010 Change

2006 2007 2008 2009 2010 2006 2007 2008 2009 2010

2006–2010 Change

2006–2010 Change

2006 2007 2008 2009 2010

 Recycling Transfers Disposal Transfers Other Transfers
64 Commission for Environmental Cooperation

This graphic shows that Canadian facilities transferred pollutants to the United States between 2006 and 2010, but not 

to Mexico; similarly, Mexican facilities transferred pollutants to US facilities, but not to Canada. This is understandable from a geographic perspective, since transfers between 

Canada and Mexico would involve greater time and cost. US 

facilities transferred pollutants to both Canadian and Mexican facilities over this period.

Transfers from Canadian facilities to US facilities accounted 

for 78.3 million kilograms, or about 63 percent of total 

cross-border transfers in 2010. Approximately three-quarters of these transfers consisted of sulfuric acid for recycling, 

mainly from the petroleum and coal products manufacturing 

sector. These transfers decreased notably between 2006 and 

2010, with the Irving Oil refinery in New Brunswick a main 

driver of this decrease. It reported more than 56 million kilograms in cross-border transfers of sulfuric acid to US facilities 

in 2006, but 46,151 kilograms in 2010. The Canadian chemical manufacturing sector also transferred just over 14 million 

kilograms of sulfuric acid to US facilities in 2006, but about 2 

million kilograms in 2010.

Mexican facilities transferred 687,532 kilograms to the 

United States in 2010, a decrease from the 1.77 million kilograms transferred in 2006. Two-thirds of the transfers in 

2010 were metals for recycling (especially lead and nickel 

and their compounds). The large decrease over this period 

can be attributed mainly to reductions in transfers of lead 

and its compounds from the Power Sonic electrical parts 

and accessories plant in Baja California, which transferred 

1.44 million kilograms of these compounds in 2006 and 

almost one million kilograms in 2007, but nothing in the 

subsequent years. 

Facilities in the United States transferred about 9.2 million 

kilograms of pollutants to Canada in 2010, a decrease from 

the 19.6 million kilograms reported in 2006. The US transportation equipment manufacturing sector and the chemical 

manufacturing sector together accounted for almost half of 

all these transfers. About 75 percent of the total consisted of 

metals for recycling (with copper and manganese and their 

compounds together accounting for 55 percent of the total). 

Another 1 million kilograms of various substances (e.g., toluene, tetrachloroethylene) were transferred to Canadian facilities for energy recovery or other treatment. 

US facilities also transferred more than 36 million kilograms 

to Mexico in 2010, a decrease from about 45.5 million kilograms in 2006. Most of this amount comprised metals for 

recycling, with zinc and its compounds accounting for over 

80 percent of the total. All of the zinc compounds transferred from US primary metal manufacturers were sent to 

the Zinc Nacional facility in the state of Nuevo León. However, zinc and its compounds are not subject to Mexico’s RETC. 

In fact, of the 14 pollutants transferred in 2010 from US 

facilities to Mexico, only five are subject to PRTR reporting 

in that country (see Table 27). Therefore, it is not possible 

to track the management of these pollutants once they have 

crossed the border.

Table 27. Top Reported Pollutants Transferred from US Facilities to Mexico, 2010

Pollutant Transfers for Disposal, 2010 (kg) Transfers for Recycling, 2010 (kg)

Zinc (and compounds) (CA, US) – 29,674,364

Manganese (and compounds) (CA, US) 120,109 3,219,645

Lead (and compounds) (CA, MX, US) 0 2,285,718

Copper (and compounds) (CA, US) 9,076 311,832

Chromium (and compounds) (CA, MX, US) 1,802 307,731

Di(2-Ethylhexyl) Phthalate (CA, US) – 107,664

Aluminum (fume or dust) (CA, US) – 81,800

Cadmium (and compounds) (CA, MX, US) – 37,404

Nickel (and compounds) (CA, MX, US) 1,802 31,717

N-Methyl-2-Pyrrolidone (CA, US) – 20,100

Barium (and compounds) (US) 1,228 1,843

Vanadium (and compounds) (CA, US) 832 2,167

Molybdenum Trioxide (CA, US) 1,117 1,724

Mercury (and compounds) (CA, MX, US) 12 331

Total, Top Pollutants Transferred, United States to Mexico 135,978 36,084,040

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.

 
Taking Stock North American Pollutant Releases and Transfers Vol. 14 65

Taking Stock North American Pollutant Releases and Transfers Vol. 14 67

This chapter provides additional information and analyses 

regarding pollutant releases reported over time to the North 

American PRTRs by facilities in the pulp, paper and paperboard mill sector (NAICS code 3221). This industry sector 

was selected for further analysis because from 2005 through 

2010 it consistently ranked among the top sectors in North 

America for reported releases to air (second rank) and releases 

to water (third rank). These releases decreased between 2005 

and 2010, by 19 percent and 6 percent, respectively.

The main objectives of this feature analysis are to undertake 

a closer examination of releases to air and water reported by 

this sector from 2005 through 2010, to identify the drivers 

of the changes in these releases, and to thus gain a better 

understanding of the potential links between PRTR data 

and corporate environmental sustainability efforts. 

This chapter also includes the results of a small CEC survey 

of pulp, paper and paperboard mills that reported fairly 

consistently to their respective PRTRs between 2005 and 

2010. Additional insight has been provided by pulp and 

paper industry associations, which provides invaluable context to the data, particularly with respect to the economic, 

technical and environmental challenges facing this sector in 

North America. 

3.1 Key Findings 

	Among all sectors reporting to the PRTRs of North 

America between 2005 and 2010, pulp, paper 

and paperboard mills consistently ranked second 

for releases to air, and third for releases to water. 

Facilities in this sector reported more than 92.6 

million kilograms in releases to air in 2005, and 

about 75 million kilograms in 2010 (a decrease of 19 

percent). They also reported releases to water of about 

16.6 million kilograms in 2005, with these releases 

declining to about 15.7 million kilograms in 2010 (a 

decrease of 6 percent).

	Of over 500 active mills in North America, between 

352 and 429 reported to the North American PRTRs 

each year, from 2005 through 2010. In Canada and the 

United States, the countries accounting for the largest 

proportions reported by this sector, the total number 

of reporting facilities decreased, largely due to the 

shutdown of manufacturing operations. This decrease 

played a key role in the reductions in releases to air 

and water reported over this period. In Mexico, the 

number of reporting mills increased.

	Differences among national PRTR reporting 

requirements for pollutants, as well as incomplete 

reporting, had an impact on the amounts and types 

of pollutants reported released to air and water. For 

example, some of the typical pollutants for this sector, 

such as methanol, were often reported in only one 

country. These gaps were especially evident in Mexico, 

where mills reported very small proportions of total 

releases to air and water. 

	The majority of respondents to the CEC’s survey 

of mills mentioned more than one driver of the 

changes at their facilities between 2005 and 2010. 

These drivers included changes in government 

regulations, environmental management practices, 

economic considerations, corrections or changes in 

PRTR data estimations, and decreases in production. 

The survey also revealed that mills use their PRTR 

data for internal information about environmental 

performance, as well as to comply with facility 

permitting requirements. 

	A number of mills noted that PRTR data are used 

in external communications with the public, with 

comments also indicating that customer demand plays 

a role in their environmental management decisions, 

such as the choice of chemicals used at their facilities. 

This suggests that PRTR data have wider impacts 

and that they are a useful tool not only for industrial 

facilities, but for external stakeholders as well.

3.2 Overview of the Pulp and Paper Sector in North America

The paper manufacturing industry has undergone a significant transformation in the past 20 years as a result of changing economic and market conditions, with technological 

advances aimed at addressing both productivity and environmental concerns. Traditionally, pulp and paper products were 

sold in the producing countries (in North America: Canada 

Chapter 3

Releases to Air and Water from North American 

Pulp, Paper and Paperboard Mills, 2005–2010
68 Commission for Environmental Cooperation

and the United States; and in Western Europe: Sweden, Germany and Finland); however, since the 1990s there has been a 

burgeoning international trade in pulp and paper and a shift 

in the patterns of production and consumption of paper and 

paperboard products, with much growth in Asia (particularly 

China and Japan), as well as Brazil.24

There has been a decline in pulp and paper production and 

consumption in North America since 2007, due to the financial crisis in the United States and the shift in news and media 

from print to digital formats, which has had a major impact 

on newsprint production. As a result, pulp and paper companies have adopted innovative and more efficient processes, and 

there has been a consolidation of the global pulp and paper 

industry and the disappearance of many small companies. As 

of 2010, there were approximately 90 active pulp, paper and 

paperboard mills in Canada, 370 mills in the United States, and 

64 mills in Mexico.25

At present, a relatively small number of transnational conglomerates are involved in sourcing fiber and producing pulp and 

paper products.26 In China, total paper consumption surpassed 

that of North America for the first time in 2009.27 To meet the 

growing demand in Asia, traditional pulp and paper producers 

have shifted a substantial part of their production to developing countries where raw materials and labor are cheaper. 

Figure 28 illustrates the production and consumption of pulp

and paper products in the three North American countries 

in 2008.

3.3 Processes and Technologies: Pulp, Paper and 

Paperboard Mills

Modern paper production basically involves the pulping of 

virgin or recycled fibers from trees, recycled paper, or agricultural residues such as straws derived from wheat, flax or rice; 

corn stalks; or sugar cane bagasse (or fibrous residue); followed by mechanical, chemical or semi-chemical processing 

of the fiber into pulp; then running the pulp through a paper 

machine to create large rolls of paper or paperboard; and 

finally, converting the paper into a variety of products such 

as office paper and cardboard boxes. The type of material (or 

mix of materials) used in pulp and paper production, the type 

of mills and technologies used (including pollution control 

and energy sources) have impacts on the amount and types 

of pollutants created and released from facilities in this sector. 

Figure 29 depicts the basic pulp and paper-making process. 

24. De la Madrid Cordero, E. 2009. La situación de la industria de la celulosa y el papel en el mundo. Department of Rural Finance. Government of Mexico.

25. Environment Canada. Forest Products and Fisheries Act Division (personal communication). US Bureau of Labor Statistics. 2013. Quarterly census of employment 

and wages. Table 2. Private industry by 6-digit NAICS industry and government by level of government, 2010 annual averages: Establishments, employment 

and wages, change from 2009. Online at: <www.bls.gov/cew/ew10table2.pdf> (accessed July 2013). National Council for Air and Stream Improvement, Inc. 

(NCASI-US). 2013. Personal communication, Nov. 2013. Instituto Nacional de Estadίstica y Geografίa (INEGI). 2012. « Principales caracterίsticas de la industria 

manufacturera por sector, subsector, rama y clase de actividad. Resultados integrados, 2009–2010 ». Encuesta Anual de la Industria Manufacturera 2009–2010, 

SCIAN 2007. En ligne : <HYPERLINK “http://www.inegi.org.mx/prod_serv/contenidos/espanol/bvinegi/productos/encuestas/establecimientos/indus_manu/

resumen_anual_09_10/EAIM09_10.pdf” www.inegi.org.mx/prod_serv/contenidos/espanol/bvinegi/productos/encuestas/establecimientos/indus_manu/resumen_

anual_09_10/EAIM09_10.pdf>.

26. De la Madrid Cordero, E. 2009. La situación de la industria de la celulosa y el papel en el mundo. Financiera Rural. Department of Rural Finance. Government of Mexico.

27. RISI. 2013. Annual historical data: World pulp, 2010. Online at: <www.risiinfo.com/pages/product/pulp-paper/>.

Figure 28. Production and Consumption of Pulp, Paper and Paperboard 

Products, North America, 2008

Canada Mexico United States

36,194,000

17,813,000

5,486,000 10,241,000

132,422,000 132,899,000

 Production (tonnes*) Consumption (tonnes*)

*1 tonne = 1,000 kilograms.

Data from: UN Food and Agriculture Organization (FAO). 2011. State of the World’s Forests. 2008 statistics. Rome: FAO. 

Online at: <www.fao.org/docrep/013/i2000e/i2000e.pdf> (accessed August 2013).
It shows wood as the main resource used, but currently, 

recovered paper accounts for more than 37 percent of fiber 

used to make new paper products in the United States,28 and 

in Canada about 87 per cent of the wood fiber used to make 

paper comes from a blend of sawmill residues (59 per cent) 

and recycled paper (28 per cent).29 In Mexico, the pulp and 

paper industry uses between 85 percent and 88 percent secondary fibers, mainly recycled paper and cardboard (much 

of it imported).30 Investment in new technologies has further enabled companies’ use of recovered paper in their 

production. However, while used paper is recovered at a 

rate of nearly 70 percent, a significant percentage of paper 

product is not suitable for recovery because it is contaminated (e.g., certain tissue papers, or food wrappers), thus 

significantly reducing the utilization rate of this recovered 

fiber. Also, cellulose fibers become shorter each time they 

are recycled, which limits their useful lifespan for the production of paper.31

3.3.1 Pulp Mills 

Pulp mills manufacture pulp from wood or other fibers, 

including recycled paper. Pulping facilities can include 

de-inking plants that process waste paper into pulp. To 

transform virgin wood into pulp, the cellulose fibers that 

are held together by a substance called lignin must be separated. Depending on the type and strength of paper desired, 

this can be done using mechanical or chemical processes. 

Mechanical pulping involves crushing logs that have been 

stripped of their bark with grinders and then soaking them 

with water. Generally speaking, mechanical pulps are used 

to manufacture short-lived products and those requiring 

less strength, such as newsprint. Chemical pulping involves 

cooking wood chips in huge vats, or digesters, with chemicals. The combination of heat and chemicals dissolves 

the lignin, releasing the long wood fibers without breaking them. Chemical pulp is therefore used to manufacture 

Pulping

Finished Product

Recycled Material

Paper for Recycling

De-inking

Fibre Washing/mixing

Wire Section

Press Section

Virgin Raw Material

Drying

Mechanical or Chemical Pulping

De-barking 

and Chipping

28. American Forest and Paper Association. 2013. Website, <www.afandpa.org> (accessed Aug. 2013).

29. Forest Products Association Canada. 2013. Website, <www.fpac.ca/index.php/en/> (accessed Aug. 2013).

30. De la Madrid Cordero, E. 2009. La situación de la industria de la celulosa y el papel en el mundo. Department of Rural Finance. Government of Mexico.

31. US EPA. 2013. Wastes/resource conservation / common wastes & materials/paper recycling. Online at: <www.epa.gov/osw/conserve/materials/paper/basics/papermaking.

htm> (accessed June 2013). US EPA. 2002. Profile of the pulp and paper industry. 2nd Edition. Office of Compliance Sector Notebook Project. November 2002. Online at: 

<www.epa.gov/compliance/resources/publications/assistance/sectors/notebooks/pulppasn.pdf> (accessed June 2013). 

Source: Modified from European Paper & Packaging Industries. 2013. Paper online. Website, <www.paperonline.org>.

Figure 29. Schematic of a Typical Pulp and Paper Mill

Taking Stock North American Pollutant Releases and Transfers Vol. 14 69
70 Commission for Environmental Cooperation

longer-lived products and those requiring greater strength, 

such as printing and writing papers. One common chemical 

pulping process is the “kraft” process, which uses a solution 

of sodium hydroxide and sodium sulfide to dissolve the 

non-fibrous materials, including lignin.32

Depending on the eventual use of the pulp, it can undergo 

a bleaching process. Bleaching is used to whiten paper 

products and to prevent them from becoming brittle and 

yellow with time. The bleaching chemicals, such as chlorine dioxide, are injected into the pulp to further dissolve 

the lignin and yield a whiter product. The impacts of pulp 

bleached with chlorinated compounds have been a subject of debate and regulations since the late 1980s, as discussed below. 

3.3.2 Paper Mills 

Paper mills manufacture paper and are sometimes also 

involved in producing pulp. After fillers and coloring materials have been added to the pulp (if desired), it is ready to 

be made into paper. The pulp is pumped onto wire screens 

that vibrate to allow water to drain out of the pulp and 

to help the fibers interlock into sheets. Different qualities 

and properties of paper can be produced by varying the 

amounts of pulp and additives used. The sheets then pass 

through a long series of rollers to remove remaining moisture, and are dried by heated drums. Finally, a process 

called calendaring can be used to further compress and 

polish the sheets. Large sheets of paper are wound onto 

rolls and can then be cut for a variety of paper products. 

Paper mills can manufacture both newsprint and other 

types of paper. Newsprint is made from mechanical wood 

pulp containing all components of the wood. Other types 

of paper can include those for the construction industry 

(e.g., asphalt paper); paper stock for conversion into paper 

products; “fluff pulp” for use in personal hygiene products 

such as disposable diapers, facial tissues, sanitary napkins 

and tampons; fine paper stock and a variety of office papers 

(e.g., printer, photocopy, loose-leaf, and kraft paper); and 

treated, laminated or coated papers.

3.3.3 Paperboard Mills 

Paperboard mills manufacture paperboard and, as in the 

case of paper mills, can also be involved in the production 

of pulp—whether from virgin or recycled feedstock. 

32. Statistics Canada. 2007. North American Industry Classification System (NAICS). Online at: <http://stds.statcan.gc.ca/naics-scian/2007/cs-rc-eng.

asp?criteria=3221> (accessed Aug. 2013). US EPA. 2013. Wastes/resource conservation / common wastes & materials/paper recycling. Online at: <www.epa.gov/osw/

conserve/materials/paper/basics/papermaking.htm> (accessed June 2013). US EPA. 2002. Profile of the pulp and paper industry. 2nd Edition. Office of Compliance Sector 

Notebook Project. November 2002. Online at: <www.epa.gov/compliance/resources/publications/assistance/sectors/notebooks/pulppasn.pdf> (accessed June 2013). 

Steffen Thoma
Taking Stock North American Pollutant Releases and Transfers Vol. 14 71

33. The information in this section is taken from: US EPA. 1997. The pulp and paper industry, the pulping process, and pollutant releases to the environment. Fact sheet. 

Online at: <http://water.epa.gov/scitech/wastetech/guide/pulppaper/upload/1997_11_14_guide_pulppaper_jd_fs2.pdf> (accessed June 2013). Environmental 

Paper Network (EPN). 2011. The state of the paper industry 2011: Steps toward an environmental vision. Available at: <http://environmentalpaper.org/> (accessed Aug. 

2013). Ince, B.K., Z. Cetecioglu and O. Ince. 2011. Pollution prevention in the pulp and paper industries. In Environmental management in practice, ed. Elzbieta 

Broniewicz. Rijeka, Croatia: InTech. National Council for Air and Stream Improvement, Inc. (NCASI). 2013. Personal communication, Dec. 2013.

3.4 Pollutants Associated with the Pulp and Paper 

Manufacturing Sector

There are a variety of attendant environmental issues in pulp 

and paper manufacturing. They include water consumption, 

energy use, sustainable forest management, chemical use, 

air and water releases (including thermal pollution), and 

disposal or beneficial use of manufacturing residuals. This 

section of the report focuses on the pollutants released to 

air and water by various stages of the production of pulp, 

paper and paperboard. These stages include wood preparation, mechanical and chemical pulping, washing, screening, 

and bleaching; papermaking and coating operations; fuel 

combustion for energy (the boiler); the recovery furnace 

(evaporation, concentration, and combustion of “spent 

pulping liquor”—the liquid resulting from chemical pulping—enabling re-use of chemicals for pulping); and the lime 

kiln (used for recovering lime from spent pulping liquor for 

use in chemical pulping).33

The majority of the pollutants released to air and water as 

a result of pulp and paper manufacturing are generated as 

follows: 

•	 Wastewater: The vastly greater part of spent pulping 

liquor and soluble wood materials is usually recovered 

(for chemical pulp mills), but wastewater can include 

a small amount of “weak” spent pulping liquor and 

effluents from the bleaching process.

•	 Air emissions: While predominantly released from 

stationary combustion equipment such as boilers 

and recovery furnaces, they can be emitted from 

other operations at the mill (e.g., pulping digesters, 

lime kiln, bleach plant, and wastewater treatment). 

They can include reduced sulfur compounds; volatile 

organic compounds (VOCs); odor from sulfides 

in spent pulping liquor and condensates from the 

kraft process; sulfuric acid and hydrochloric acid; 

particulates; and, from combustion units, sulfur and 

nitrogen oxides. 

•	 Solid waste (manufacturing residuals): This results 

from the pulp manufacturing process, wastewater 

treatment, and chemical recovery process.

The following are some of the pollutants typically generated 

from pulp and paper manufacturing processes. Additional 

information about these pollutants’ industrial uses, chemical 

properties, and their potential to cause harm to human health 

or the environment is provided in Appendix 5. As mentioned 

earlier in this report, in the absence of other information such 

as route and length of exposure, it is difficult to determine the 

actual risk posed by a substance. Readers are encouraged to 

refer to the sources used in this report for additional information, including the US ATSDR (ToxFAQs), and the New 

Jersey Right-to-Know Hazardous Substance Fact Sheets.

Volatile Organic Compounds (VOCs) are a category of 

organic compounds that are gases at room temperature 

(e.g., solvent vapors). Methanol is one of the VOCs emitted 

in largest proportions during pulp and paper manufacturing 

(as an inadvertent by-product of wood pulping, chemical 

recovery, and pulp bleaching). Other VOCs resulting from 

pulp and paper manufacturing include acetaldehyde, propionaldehyde, methyl ethyl ketone, phenols, and terpenes.

Reduced Sulfur Compounds (e.g., hydrogen sulfide, carbonyl sulfide) are associated with the distinct rotten egg 

odor emitted at chemical pulp mills. 

Chlorinated Compounds: Chlorine-based chemicals commonly used for bleaching pulp include chlorine dioxide and 

sodium hypochlorite. 

Dioxins and Furans: The discovery that dioxins and furans 

(a group of PBTs) were incidentally produced during the 

chlorination stage of bleaching, and especially with the use 

of elemental chlorine (Cl2

), led to the phase-out of the use 

of elemental chlorine for bleaching in North American 

chemical pulp mills. In areas where pulp mills use wood 

from logs transported in salt water, combustion of wood 

residuals (called “salty hog fuel”) can lead to low levels of 

dioxins released to the air.

Chloroform may be formed by the use of chlorine-based 

compounds for bleaching in pulp and paper manufacturing. 

Mercury is released from the combustion of fossil fuels. 

Other Heavy Metals, including lead, cadmium, chromium, 

arsenic, zinc and other metal compounds, can be found in 

small quantities in wood, and are also natural components 

of fuels (e.g., coal, oil) used to generate power and steam at 

pulp and paper mills. They may also be present in dyes used 

to add color or brightness to certain papers. 
72 Commission for Environmental Cooperation

Suspended Solids are solid material suspended in mill 

effluent, and are measured as total suspended solids (TSS).

Adsorbable Organic Halogens (AOX) is a measure of the 

quantity of chlorinated organic compounds in chemical 

pulp mill effluent.

Nitrogen Compounds (e.g., nitrates, nitrites, ammonia) 

and Phosphorus are added during the wastewater treatment process to help remove dissolved organic material 

from the effluent. 

Biochemical Oxygen Demand (BOD) is the amount of dissolved oxygen that is needed by the organisms living in water 

to break down organic material. It is affected by discharges of 

waste matter and is often used as an indicator of water quality. 

Criteria Air Contaminants (CACs): Due to differences 

among the three countries in PRTR reporting requirements, 

data on releases of CACs are not included in this report. 

However, CACs are typically released from the combustion 

of fuel (often fossil-based, such as coal, oil and natural gas) 

for generation of energy used during pulp and paper manufacturing. Common CACs include the following:

•	 Carbon monoxide is produced by incomplete 

combustion of fossil fuels. 

•	 Nitrogen oxides (NOx

) are products of the 

combustion of fuels. 

•	 Particulates are small particles that are dispersed 

into the atmosphere from combustion. They can be 

fine or coarse, and be composed of wood or chemical 

compounds created with carbon, metallic oxides and 

salts, acids, oils, lime, etc. 

•	 Sulfur dioxide (SO2

) is a chemical compound 

produced from the combustion of fuel containing 

sulfur (e.g., oil, coal). 

Greenhouse Gases (GHGs), such as carbon dioxide: GHGs 

(mainly from the boilers that generate energy for the pulp 

and paper mill) are typically released by this sector. GHG 

emissions data are excluded from this report, due to differences in national PRTR reporting requirements for these 

pollutants. 

3.5 Pollution Prevention and Control in the Pulp and 

Paper Manufacturing Sector

In terms of reducing the impacts of industrial processes 

on human health and the environment, as well as minimizing costs, pollution prevention is preferable over endof-pipe solutions, such as treatment and final disposal. A 

number of technologies and processes have been implemented by pulp, paper and paperboard mills over the past 

two decades to either prevent or minimize the generation 

of waste and the release of pollutants to the environment. 

And, just as certain groups of pollutants can jointly result 

from pulp and paper manufacturing processes (e.g., 

metals, sulfur compounds, volatile organic compounds), 

implementing pollution prevention and control processes or technologies can address multiple pollutants 

simultaneously.

3.5.1 Substitution of Toxic Inputs

The debate over elemental chlorine, which was commonly 

used 20 years ago in the pulp bleaching process, has led 

to its replacement with less toxic, or non-toxic, substitutes 

and the use of alternative processes for both pulping and 

bleaching. Some of these processes are described below. 

•	 Elemental chlorine–free (ECF) pulp bleaching: Mills 

have replaced elemental chlorine with other agents, 

such as chlorine dioxide and hydrogen peroxide, 

in their bleaching processes. ECF has become the 

industry standard, and studies show that dioxin levels 

in the tissue of fish downstream from pulp and paper 

mills have significantly declined. ECF bleaching also 

reduces a number of chlorophenols to non-detect 

levels, decreases chloroform formation, and decreases 

chlorinated organic compound formation (measured 

as AOX) formation by 90 percent.34

•	 Totally chlorine-free (TCF) pulp bleaching: 

TCF uses no chlorine compounds, but instead 

uses hydrogen peroxide and ozone to bleach the 

pulp. This type of bleaching does not result in the 

formation of dioxins and furans or AOX. However, 

it is not widely used by North American pulp and 

paper mills.

34. National Council for Air and Stream Improvement, Inc. (NCASI). 2003. Pulp mill process closure: A review of global technology developments and mill experiences in 

the 1990s. Technical Bulletin No. 860. Research Triangle Park, NC: National Council for Air and Stream Improvement, Inc.
Taking Stock North American Pollutant Releases and Transfers Vol. 14 73

35. Ibid.

•	 Extended delignification: This refers to the 

enhanced removal of lignin prior to the bleaching 

process, which can be achieved by extended cooking, 

oxygenation, ozonation, and/or addition of chemical 

catalysts. Given that extended delignification allows 

more lignin to be recovered and burned during 

pulping liquor recovery, these processes can have 

positive effects on the quality of the mill’s final 

effluent, especially on parameters such as BOD, 

color and AOX. 

3.5.2 Closed-loop Systems and Recycling

Closed loop systems involve chemical recovery and recycling, to prevent the release of pollutants into the environment. For example, the effluent from the kraft pulping 

process, known as black liquor, is captured, combusted, 

and ultimately reused in the manufacturing process while 

concurrently generating energy. Some mills also collect 

the steam produced during the cooking of the wood 

chips, which can be condensed in order to remove some 

of the liquid’s pollutants before it is released. Closed-loop 

systems can also have important economic benefits, given 

the cost of certain chemicals and other inputs used in 

pulp and paper manufacturing; however, there are significant technical challenges to achieving complete system 

closure for chemical pulping mills.35

There has been an ongoing effort to increase paper and 

paperboard recycling in North America, Western Europe 

and Japan. Increasing the recycled content of paper may 

result in benefits such as:

•	 less energy use, depending on the paper grade being 

manufactured; 

•	 lower greenhouse gas emissions, depending on the 

paper grade involved; 

•	 somewhat lower water use;

•	 lower air emissions, where less energy is used; and

•	 lower emissions to water.

3.5.3 Pollutant Control Technologies

Air Pollutants: Technologies have been installed on boiler 

systems in pulp and paper mills, as in other industries that 

generate their own power through fuel combustion, to prevent pollutants from being released to the environment. They 

include end-of-pipe air pollution control technologies, such 

as scrubbers, particulate “baghouses,” and electrostatic precipitators. These technologies remove pollutants (e.g., sulfur 

compounds, VOCs) by capturing them for treatment or 

disposal. 

Sludges: Various technologies and methods are used for 

the management and reduction of solid residuals and 

wastewater treatment sludges generated by pulp and paper 

mills, including the following:

•	 Composting: This method is well-suited to residuals that 

contain a fraction of paper fiber and/or other organic 

materials. The wastes are stabilized via microorganisms 

and the end product can be used for agriculture. 

•	 Land application/farming: This method is used in many 

areas, and consists of spreading sludge over the land 

and mixing with soil. Before the application, the sludge 

is dewatered in order to reduce volume. 

•	 Incineration or combustion: A common solution 

to wastewater treatment sludge, particularly when 

combined with other materials such as bark or wood 

residue—although the water content and ash content of 

most sludges do not make them a very efficient energy 

source. 

Wastewater: Installing or upgrading secondary wastewater treatment systems may result in reductions in releases 

of suspended solids, as well as reduction in biochemical oxygen demand, although there are practical limits 

in terms of the extent to which these reductions can be 

achieved for a given treatment system. In primary wastewater treatment systems, suspended solids such as organic 

materials (e.g., wood fiber, debris, coating materials) are 

removed from the effluent. Secondary treatment systems 

use bacteria to break down organic pollutants and reduce 

their concentrations. 

3.5.4 Pollution Prevention and Reduction: Looking Forward

Since the 1990s, the pulp and paper industry has shifted 

the focus from addressing many of the “conventional” pollutants or issues (e.g., methanol and chlorine, along with 

BOD and TSS), to conducting research on the potential 

effects on fish of natural wood extracts that are released 

into the environment during the preparation of cellulose 

fibers prior to bleaching. Issues such as these, along with 

regulatory requirements, customer demand, and industry commitment to minimizing environmental impacts 
74 Commission for Environmental Cooperation

are driving the development of minimum-impact mills. 

For instance, mills are weighing the use of non-toxic substitutes for the inputs and additives used in various processes, as in: 

•	 improving pulping liquor recovery to minimize 

releases of potentially harmful substances that may be 

present in lignin;

•	 using alternative paper dye formulations;

•	 changing paper wet-strength additives; and

•	 altering the use of de-foaming agents (used to 

counter the bubbles created from substances 

liberated from lignin).36

The industry is therefore looking to “green chemistry” to 

solve some of its current-day pollution challenges. For example, recent research by EPA scientists has yielded some promise relative to the issue of methanol releases. As an alternative 

to incineration, methanol may be captured and converted 

into methyl formate, a commodity chemical and environmentally-friendly blowing agent and solvent, and a precursor 

to formic acid, which is used as a preservative and antibacterial agent. Studies have shown that the new technology could 

remove about 98 percent of the sulfur compounds responsible 

for the odor from pulp and paper mills, and about 90 percent 

of the methanol gas from the waste stream. This technology 

uses no toxic inputs, but converts the existing waste into 

useful product. At the moment, the research does not transfer to an industrial-scale use, but future large-scale use of this 

green chemistry could significantly decrease environmental 

releases from pulp and paper mills, reduce the amount of 

energy used to dispose of waste, and minimize odor—while 

possibly increasing mills’ profits.37

In 2009, the Canadian government established the Pulp and 

Paper Green Transformation Program, which offered incentives to mills to improve their environmental performance. 

Eligible companies could earn credits for the “black liquor” 

(spent pulping liquor) produced at chemical pulping mills 

between January and May, 2009, and then invest those credits where doing so made the most environmental and economic sense for their mills. Projects had to be those that 

would achieve measurable environmental benefits through 

energy efficiency improvements, renewable energy production, emission reductions, and so on. The projects undertaken 

varied from boiler and turbine upgrades to the installation 

of energy-efficient motors and emission-control equipment.38

3.6 Pulp and Paper Manufacturing: Regulatory 

Environment

3.6.1 Canada

Two main pieces of federal environmental legislation regulate 

the Canadian pulp and paper sector. They are the Canadian 

Environment Protection Act (CEPA), and the Fisheries Act. 

In addition, the Clean Air Regulatory Agenda (CARA) was 

launched in 2006. It provides a framework to establish emission 

reduction targets for the major industrial sectors in Canada, 

including the pulp and paper sector, in order to improve air 

quality and decrease smog levels and acid deposition.39

In addition to federal legislation, pulp and paper mills are 

regulated by provincial pulp and paper regulations and/or 

site-specific operating permits.

In 1971, pulp and paper became the first regulated sector 

under the Fisheries Act. Under the Act, Pulp and Paper 

Effluent Regulations (PPER) were put in place to govern the 

discharge of deleterious substances (including acutely lethal 

effluent, BOD matter, and suspended solids) from pulp and 

paper mills and the deposit of limited quantities of those deleterious substances into waters frequented by fish. The PPER 

have the overall objective of protecting water quality in order 

to sustain fish, fish habitats and fisheries resources. The PPER 

were amended in 1992 to introduce enforceable effluent 

quality standards for all mills, based on standards achievable 

through the use of secondary wastewater treatment, in order 

to avoid effluent discharges that are acutely lethal to rainbow 

trout. The PPER were updated in 2004 and 2008 to improve 

their clarity while supporting compliance and enforcement, 

and to streamline requirements linked to environmental 

effects monitoring studies.40 Most recently (in 2010), Environment Canada conducted a review of industry sectors to 

determine compliance with existing PPER and concluded 

that facilities had high rates of compliance. 

36. National Council for Air and Stream Improvement, Inc. (NCASI). 2003. Pulp mill process closure: A review of global technology developments and mill experiences in 

the 1990s. Technical Bulletin No. 860. Research Triangle Park, NC: National Council for Air and Stream Improvement, Inc.

37. US EPA. 2011. Transforming paper mill pollution into commercial resource. Science Matters newsletter, June 2011. Online at: <www.epa.gov/sciencematters/

june2011/papermill.htm> (accessed 7 Dec. 2012).

38. Natural Resources Canada. 2013. Pulp and Paper Green Transformation Program: Mission accomplished. Online at: <www.nrcan.gc.ca/forests/federalprograms/13141> (accessed Sept. 2013).

39. Environment Canada. 2013. Backgrounder: Clean air regulatory agenda. Online at: <www.ec.gc.ca/default.asp?lang=En&n=56D4043B-1&news=295B1964-9737-

4F80-B064-B3088D9910BE> (accessed June 2013).

40. Environment Canada. 2012. Status report on the pulp and paper effluent regulations. June 2012. Online at: <www.ec.gc.ca/Publications/default.

asp?lang=En&xml=A231D61D-E897-4257-9E4B-F65CF5A8B5AD> (accessed June 2013).
Taking Stock North American Pollutant Releases and Transfers Vol. 14 75

41. Environment Canada. 2013. Equivalency agreements. Online at: <www.ec.gc.ca/lcpe-cepa/default.asp?lang=En&n=5CB02789-1> (accessed June 2013).

42. US EPA. 1997. EPA’s final pulp, paper, and paperboard “Cluster Rule”—Overview. Fact sheet. EPA-821-F-97-010. United States Environmental Protection Agency, 

Office of Water. November 1997. Online at: <http://water.epa.gov/scitech/wastetech/guide/pulppaper/upload/1997_11_14_guide_pulppaper_jd_fs1.pdf> (accessed 

July 2013).

43. US EPA. 2013. New Source Performance Standards—Kraft pulp mills. Rule and implementation information for pulp and paper production. Online at: www.epa.

gov/ttnatw01/pulp/pulppg.html (accessed July 2013).

compliance with air emission and water discharge permit 

limits. Under the air section of the Rule, pulp and paper 

mills must meet air standards to reduce emissions of toxic air 

pollutants occurring at various points throughout the mills. 

Specifically, EPA requires mills to capture and treat toxic air 

pollutant emissions that occur during the cooking, washing, 

and bleaching stages of the pulp manufacturing process. A key 

concept introduced with the 1990 amendments to the Clean 

Air Act was the determination of “maximum achievable control technology” (MACT), designed to encourage achieving 

the emissions level of the best-performing similar facilities. 

These emissions levels set a baseline for the new standard. At 

a minimum, a MACT standard must achieve a level of emissions control that is at least equivalent to this baseline. 

Under the water section of the Cluster Rule, new and existing 

facilities in the bleached paper-grade kraft and soda and sulfite subcategories must meet standards to reduce discharges of 

toxic and nonconventional pollutants. A key focus has been 

on the generation of toxic and bioaccumulative chlorinated 

organic compounds, including dioxins and furans (2,3,7,8-

TCDD and other chlorinated dioxins and dibenzofurans), 

trihalomethanes such as chloroform, and other compounds. 

EPA set effluent limits for toxic pollutants in the wastewater 

discharged during the bleaching process and in the final discharge from the mills. These limits are based on substituting 

chlorine dioxide for chlorine in the bleaching process. In the 

final Cluster Rule, EPA established the substitution of chlorine dioxide for chlorine—the elemental chlorine-free (ECF) 

process—as best available technology. In addition, the regulation addresses adsorbable organic halides (AOX), as well as 

biological and chemical oxygen demand, and total suspended 

solids in water. Mills in the affected subcategories must also 

follow best management practices to prevent spills of black 

liquor into wastewater sewers. 

Very recently, following a review of the New Source Performance Standards (NSPS), which control emissions of particulate matter and total reduced sulfur compounds from a number 

of points at kraft pulp mills, the US EPA proposed updates 

to the NSPS for these facilities. The proposed amendments 

would apply to newly-constructed or modified recovery furnaces, smelt dissolving tanks and lime kilns, and would involve 

changes to particulate matter (PM) emission limits to be consistent with the NESHAPs applying to these facilities; added 

testing, monitoring, and reporting requirements; and emission 

limits for periods of startup, shutdown and malfunction.43

Under CEPA, the Pulp and Paper Mill Effluent Chlorinated Dioxins and Furans Regulations require mills that 

use chlorine bleaching to implement process changes to 

prevent the formation of dioxin and furans, and to monitor 

dioxin and furan concentrations. The Regulations prohibit 

the discharge of measurable concentrations of 2,3,7,8-tetrachlorodibenzo-para-dioxin (TCDD) and 2,3,7,8-tetrachlorodibenzofuran (TCDF) in pulp and paper mill effluents. 

The Pulp and Paper Mill Defoamer and Wood Chip Regulations, also under CEPA, place restrictions on de-foamers 

and the use of polychlorinated phenol-treated wood chips.

Provinces and territories may enter into an equivalency agreement, under section 10 of CEPA, or section 4.2 of the Fisheries 

Act, to eliminate the duplication of environmental regulations. 

Only one province, Alberta, has entered into an equivalency 

agreement with the federal government.41 In addition to federal 

regulations, many provinces have also set standards limiting 

pollutants in pulp and paper mill discharges. 

3.6.2 United States

In the United States, the pulp and paper sector is regulated 

by numerous pieces of legislation. One of these is Executive 

Order (EO) Number 127873, from 1993, relating to the purchase of environmentally preferable products by the federal 

government and specifying a minimum percentage of recycled fiber in certain types of papers for federal purchases. 

This EO has had an important impact on the US pulp and 

paper market because the federal government is a major 

consumer of paper products.

The Environmental Protection Agency (EPA)’s “Cluster 

Rule” (1998) was the first effort aimed at combining regulatory criteria for industry sectors into a coherent system 

intended to reflect the operating characteristics of each 

industry, in contrast with the historical pattern of separately 

specifying regulations for each environmental medium 

(e.g., air, water, soil). The Cluster Rule sets baseline limits 

for releases of toxics and nonconventional pollutants into 

the air and water and is primarily concerned with setting 

National Emission Standards for Hazardous Air Pollutants 

(NESHAPs) under the Clean Air Act, and Effluent Guideline Limitations under the Clean Water Act.42

The Cluster Rule establishes a sampling methodology for 

mills relative to 12 chlorinated phenolics and AOX, to ensure 
76 Commission for Environmental Cooperation

3.6.3 Mexico

A number of pieces of legislation govern Mexico’s pulp and 

paper manufacturing plants.44 They fall under the umbrella 

of the General Law of Ecological Equilibrium and Environmental Protection (Ley General del Equilibrio Ecológico y la 

Protección al Ambiente—LGEEPA). Facilities are subject to 

maximum allowable limits established by official standards 

(Normas Oficiales Mexicanas, or NOMs) for emissions to 

air and water, and for solid waste and hazardous materials 

management and disposal. 

Under Article 5 of the LGEEPA, the rule for environmental impact assessment (Reglemento de la LGEEPA en Materia de Evaluación del Impacto Ambiental), new pulp and 

paper manufacturing plants must acquire operating permits and are subject to maximum air emission levels set 

by article 111 of the LGEEPA, the rule for the prevention 

and control of air pollution (Reglemento de la LGEEPA en 

Materia de Prevención y Control de la Contaminación de 

la Atmósfera). Facilities under federal jurisdiction (such as 

pulp and paper mills) are obliged to report their emissions 

to the national registry and follow best practices regarding emissions monitoring (at the plant and in the vicinity), treatment, and control systems (including in cases of 

equipment failure or accidents that can potentially result 

in environmental contamination).

Waste generated by the pulp and paper sector is regulated by 

the General Law for the Prevention and Integrated Management of Wastes (Ley General para la Prevención y Gestión Integral de los Residuos—LGPGIR), which requires waste product 

characterization and assessment by type and risk level, and the 

development of waste management plans. Under the LGEEPA 

rule for hazardous activities (Reglemento de la LGEEPA en 

Materia de Actividades Altamente Riesgosas), pulp and paper 

plants are also required to undertake risk assessment studies 

and develop contingency plans and accident-prevention programs. Official standards that apply to these activities include: 

•	 NOM-052-SEMARNAT-2005, which establishes the 

characteristics, procedures for identification, and 

classification and lists of dangerous substances; and

•	 NOM-133-SEMARNAT-2000, which establishes 

the environmental management specifications for 

polychlorinated biphenyls (PCBs).

Persistent organic pollutants (POPs), such as dibenzo-paradioxins and polychlorinated dibenzofurans, hexachlorobenzene, and PCBs, are unintentional by-products that can 

be released as the result of incomplete thermal combustion 

of organic matter where chlorine is present, or through specific chemical reactions in cases where chlorine-based substances are used. The LGPGIR establishes the requirement 

for facilities that are sources of such pollutants to develop 

action plans (to be included in the National Stockholm 

Convention Implementation Plan) aimed at eliminating or 

reducing unintentional releases of POPs.45

3.7 Reported Releases to Air and Water from Pulp, Paper 

and Paperboard Mills in North America, 2005–2010

In 2010, there were over 500 active pulp, paper and paperboard mills across North America: approximately 90 in 

Canada, 370 in the United States, and 64 in Mexico. Of the 

total number of mills, between 352 and 429 reported to the 

North American PRTRs over the 2005–2010 period (see 

Table 28).

44. The information on Mexican regulations is taken from: Semarnat. 2013. Reglamento de la LGEEPA en Materia de Registro de Emisiones y Transferencia de 

Contaminantes. Semarnat. 2013. Reglamento de la LGEEPA en Materia de Actividades Altamente Riesgosas. Semarnat. 2013. Reglamento de la LGEEPA en Materia 

de Impacto Ambiental. Semarnat. 2013. Reglamento de la LGEEPA en Materia de Prevención y Control de la Contaminación de la Atmósfera. Semarnat. 2003. 

NOM-105-SEMARNAT-1996 (antes NOM-105-ECOL-1996). Secretaría de Economía. 2010. Norma Mexicana NMX-N-107-SCFI-2010.

45. Arauco. 2005. Plan de manejo de residuos peligrosos. In Informe final: Planta Licancel. Arauco y Constitución, S.A. Semarnat. 2007. Regulación de los residuos 

peligrosos en México. Colección Técnica y Estadística. INE-SEMARNAT. 2007. La responsabilidad jurídico-penal asociada al manejo inadecuado de los residuos 

peligrosos en México. Online at: <www2.ine.gob.mx/publicaciones/libros/398/olvera.html> (accessed May 2013).

Table 28. Pulp, Paper and Paperboard Mills Reporting to the North American PRTRs, 2005–2010

Sector

Number of 

Reporting Facilities

Total Releases 

and Transfers (kg) Releases to Air (kg) Releases to Water (kg)

2005 2010 2005 2010 % Change 

2005–2010 2005 2010

% Change 

2005–2010 2005 2010

% Change 

2005–2010

Pulp, Paper and Paperboard 

Mills (NAICS 3221) 429 352 144,571,800 124,141,452 -14 92,650,349 75,094,700 -19 16,599,055 15,683,803 -6

All Reporting Sectors 25,519 22,612 4,833,498,433 5,530,710,253 14 807,172,052 514,173,851 -36 234,003,770 221,806,836 -5

Rank of NAICS Sector 3221 9 9 2 2 3 3

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.
Taking Stock North American Pollutant Releases and Transfers Vol. 14 77

A facility might not report to its respective PRTR for a number 

of reasons, including the following:

•	 The facility does not meet PRTR reporting thresholds, 

for various reasons (e.g., due to a slow-down of 

operations during part of the year, or because it does 

not employ the minimum number of employees, in 

hours/year).

•	 It does not manufacture, process or otherwise use 

pollutants subject to PRTR reporting in that country. 

•	 It is not in compliance with PRTR reporting 

requirements.

North American pulp and paper manufacturing facilities 

reported more than 144.5 million kilograms in total releases 

and transfers in 2005, and just over 124 million kilograms 

in 2010—a decrease of 14 percent. This industry sector 

ranked ninth among all reporting sectors in North America 

for total reported releases and transfers in both 2005 and 

2010. It ranked second, after electric utilities, for releases 

to air in both years; and third for releases to water, after 

wastewater treatment plants and the animal slaughtering 

and processing sector. While the rank of the pulp and paper 

manufacturing sector relative to other industry sectors did 

not change between 2005 and 2010, releases to air reported 

by this sector decreased by 19 percent, and reported releases 

to water decreased by 6 percent.

However, there were differences among the three countries 

in reporting by this industry sector, as shown in Figure 30.
78 Commission for Environmental Cooperation

Figure 30. Releases and Transfers Reported by North American Pulp, Paper and Paperboard Mills, 

2005–2010

2005 2006 2007 2008 2009 2010

Year

160

140

120

100

80

60

40

20

450

400

350

Millions of Kilograms

Reporting Facilities

 All Other Releases and Transfers Releases to Water Releases to Air Total Number of Reporting Facilities

2005 2010

Year

40

35

30

25

20

15

10

5

120

100

80

Millions of Kilograms

Reporting Facilities

Canada NPRI

(26% of 2010 North American Total)

2005 2010

Year

120

100

80

60

40

20

350

300

250

200

Millions of Kilograms

Reporting Facilities

US TRI

 (74% of 2010 North American Total)

40

35

30

25

Reporting Facilities

2005 2010

Year

16,000

14,000

12,000

10,000

8,000

6,000

4,000

2,000

Kilograms

Mexico RETC

 (0.1% of 2010 North American Total)

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.
Taking Stock North American Pollutant Releases and Transfers Vol. 14 79

Figure 30 reveals that in 2005, the United States accounted 

for over 76 percent, Canada for 23 percent, and Mexico for 

less than 1 percent of total releases and transfers reported 

by this sector. By 2010, the US proportion had decreased to 

about 74 percent, Canada’s had increased to 26 percent, and 

Mexico still accounted for less than 1 percent of the total. 

The overall decrease of 14 percent by this sector between 

2005 and 2010 reflects reporting in Canada and the United 

States, but not Mexico, where total releases and transfers 

increased by 70 percent. 

The main objective of this section of the report is to provide insight into possible reasons for decreases in reported 

releases to air and water from pulp, paper and paperboard 

mills between 2005 and 2010. A number of factors could 

have played a role in these decreases, including:

•	 a decline in the number of reporting facilities, due to a 

shutdown or slowdown in production; 

•	 installation or implementation of pollution prevention 

or control technologies or processes;

•	 changes in the methodologies used to estimate releases;

•	 shifts in the way pollutants were handled (e.g., sending 

pollutants for disposal rather than releasing them to 

air); and

•	 changes in PRTR reporting requirements for facilities 

or pollutants, or in regulations for the industry sector.

Some information relative to these factors can be obtained 

through facility PRTR reports. Additional information and 

insight were obtained through other sources, including:

•	 available facility-reported comments included with 

PRTR data reports, relative to pollution prevention or 

control efforts or reasons for year-to-year changes;

•	 a CEC survey of facilities in this sector; and

•	 pulp and paper industry associations in each of the 

three countries.

Figure 31 presents details of reporting from facilities in the 

three subsectors that make up the pulp, paper and paperboard 

mills sector, in each country. It shows that overall, paper 

mills made up the largest number of reporting facilities, in 

both 2005 and 2010, with this number decreasing in Canada 
80 Commission for Environmental Cooperation

Figure 31. Releases to Air and Water Reported by Pulp, Paper and Paperboard Mills to the North American 

PRTRs, 2005-2010

Note: Of all reporting mills, 25 US facilities and five Canadian facilities are combination mills. 

Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.

40,000,000

35,000,000

30,000,000

25,000,000

20,000,000

15,000,000

10,000,000

5,000,000

Kilograms

Canada NPRI Mexico RETC US TRI

2005 

(45 Facilities)

2010

(31 Facilities)

2005 

(14 Facilities)

2010

(21 Facilities)

2005

(154 Facilities)

2010

(118 Facilities)

All Other Releases and Transfers (kg) 2,895,002 2,148,893 1,403 4,762 7,712,956 7,798,652

Releases to Water (kg) 2,441,652 1,659,178 2,781 2,554 3,994,114 3,906,194

Releases to Air (kg) 4,580,372 3,262,776 2,449 17 26,308,296 20,929,573

Paper Mills

30,000,000

25,000,000

20,000,000

15,000,000

10,000,000

5,000,000

Kilograms

Canada NPRI Mexico RETC US TRI

2005 

(10 Facilities)

2010

(7 Facilities)

2005 

(14 Facilities)

2010

(14 Facilities)

2005 

(90 Facilities)

2010

(84 Facilities)

All Other Releases and Transfers (kg) 169,616 45,012 0 5,060 2,883,850 4,193,889

Releases to Water (kg) 176,909 90,835 1,715 1,268 1,136,709 1,419,543

Releases to Air (kg) 1,267,710 623,136 20 74 17,942,729 18,895,669

Paperboard Mills

60,000,000

50,000,000

40,000,000

30,000,000

20,000,000

10,000,000

Kilograms

Canada NPRI Mexico RETC US TRI

2005 

(45 Facilities)

2010

(36 Facilities)

2005 

(2 Facilities)

2010

(2 Facilities)

2005 

(55 Facilities)

2010

(39 Facilities)

All Other Releases and Transfers (kg) 4,213,596 4,857,766 0 0 17,445,972 14,308,916

Releases to Water (kg) 4,852,620 6,222,677 0 523 3,992,556 2,381,032

Releases to Air (kg) 12,994,068 13,311,558 0 0 29,554,705 18,071,896

Pulp Mills
Taking Stock North American Pollutant Releases and Transfers Vol. 14 81

and the United States, but increasing in Mexico. However, 

in terms of reported amounts, pulp mills accounted for the 

largest proportions of total releases and transfers, on average, 

in both years—including releases to air and water. This is to 

be expected, given the greater potential for the generation of 

pollutants from pulp manufacturing processes such as chemical pulping and bleaching, compared to papermaking. The 

exception is Mexico, where only two pulp mills reported (for 

a relatively small reported total).

3.7.1 Impacts of Fewer Reporting Facilities on the Decreases in 

Reported Amounts, 2005–2010

This section examines decreases in reported amounts 

between 2005 and 2010 for the subsectors shown in the following figures, in order to determine whether these decreases 

were driven by the decline in the number of reporting facilities. The data from consistently-reporting facilities (i.e., those 

reporting in both 2005 and 2010) are compared to the data 

from facilities reporting in 2005, but not 2010. 

a) US Pulp Mills

Although the number of reporting pulp mills decreased in 

both Canada and the United States, the decrease in reported 

amounts between 2005 and 2010 was driven by US pulp 

mills (with this subsector reporting an increase in Canada). 

However, as shown in Figure 32, large proportions of the 

US decrease can be attributed to the decline in the number 

of reporting facilities, with the 16 fewer pulp mills accounting for about 80 percent (or 13 million kilograms) of the 

decrease in reported amounts from 2005 through 2010. In 

the case of releases to water, US pulp mills reporting in both 

years actually reported a modest increase over this period.

Of the US pulp mills that did not report in 2010, three did 

not report because of a shut-down in operations. These 

three mills accounted for almost 965,000 kilograms in total 

releases and transfers in 2005. The majority of the mills for 

which there are no pulp-related data for 2010 did in fact 

report—but the data were related to their paper or paperboard manufacturing operations (they are combination 

mills). These facilities reported a total of just over 12 million kilograms in releases and transfers from pulp-making 

operations in 2005, but none in 2010; however, that year 

they reported more than 5.7 million kilograms from paperboard manufacturing operations, and more than 2.3 million 

kilograms from papermaking operations. Therefore, while 

these data still reflect an overall decrease for pulp mills, 

about two-thirds of this decrease was in reality due to a shift 

in reporting to other production categories, resulting in 

increases in reporting from the other two subsectors. 

Figure 32. Releases to Air and Water Reported by US Pulp Mills, 2005–2010

60,000

50,000

40,000

30,000

20,000

10,000

Kilograms

2005 2010 2005 2010 2005 2010

Total Releases and Transfers Releases to Air Releases to Water

37 Pulp Mills Reporting in 

Both 2005 and 2010 (kg) 37,906,196 33,669,397 20,436,813 17,209,128 2,263,557 2,285,293

All Pulp Mills (55 Reporting

in 2005; 39 Reporting 

in 2010) (kg) 50,993,233 34,761,844 29,554,705 18,071,896 3,992,556 2,381,032

US TRI
82 Commission for Environmental Cooperation

b) Canadian and US Paper Mills

Figure 33 reveals that, as with US pulp mills, the decreases 

reported by the Canadian and US papermaking subsector 

were also driven in large part by the decline in the number 

of reporting facilities. In Canada, the paper mills reporting in 

both 2005 and 2010 actually reported increases in their total 

releases and transfers, as well as their releases to air and water. 

In the United States, relatively smaller decreases in total 

releases and transfers, as well as releases to air, were reported 

by facilities reporting in both years; however, these facilities 

reported an increase in releases to water over this period.

Figure 33. Releases to Air and Water Reported by Canadian and US Paper Mills, 2005–2010

12,000,000

10,000,000

8,000,000

6,000,000

4,000,000

2,000,000

Kilograms

2005 2010 2005 2010 2005 2010

Total Releases and Transfers Releases to Air Releases to Water

28 Paper Mills Reporting in 

both 2005 and 2010 (kg) 5,578,441 6,870,612 2,086,031 3,138,150 1,346,192 1,617,049

All Paper Mills (45 Reporting 

in 2005; 31 Reporting 

in 2010) (kg)

9,917,026 7,070,847 4,580,372 3,262,776 2,441,652 1,659,178

Canada NPRI

US TRI

40,000,000

35,000,000

30,000,000

25,000,000

20,000,000

15,000,000

10,000,000

5,000,000

Kilograms

2005 2010 2005 2010 2005 2010

Total Releases and Transfers Releases to Air Releases to Water

106 Paper Mills Reporting in 

Both 2005 and 2010 (kg) 31,809,487 30,229,490 22,136,788 19,198,024 3,422,956 3,563,906

All Paper Mills (154 Reporting 

in 2005; 118 Reporting 

in 2010) (kg)

38,015,366 32,634,419 26,308,296 20,929,573 3,994,114 3,906,194

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.
Taking Stock North American Pollutant Releases and Transfers Vol. 14 83

Of the 36 US paper mills that had no data for 2010, seven 

did report that year, but the data related to their pulp or 

paperboard manufacturing activities. Similarly, two Canadian paper mills did not report data related to papermaking 

activities in 2010, but rather, on pulp-making or paperboard 

manufacturing. Of the approximately 40 remaining facilities 

in both countries that did not report in 2010, a number had 

shut down during this period, while others did not report 

for unknown reasons. 

c) Canadian Paperboard Mills

Figure 34 reveals that the 2005–2010 decreases in releases to 

air and water reported by Canadian paperboard mills were 

also primarily driven by the decline in the number of reporting facilities in this subsector. Releases to air and water from 

the group of facilities that reported in both 2005 and 2010 

increased over this period. Of the five Canadian paperboard 

mills that did not report in 2010, only one remained in full 

operation during this six-year period, with three having 

shut down.

3.7.2 Pollutants Released to Air and Water from Pulp, Paper and 

Paperboard Mills, 2005–2010

In all, 109 pollutants were reported46 by North American 

pulp, paper and paperboard mills from 2005 through 2010. 

Of these, 101 were reported released to air and 77 were 

released to water. Readers are reminded that releases of 

CAC and GHG are excluded from this analysis.

There were differences in the number of pollutants reported 

by mills in each of the three countries:

•	 In Canada, facilities in this sector reported 71 

pollutants released to air and 51 released to water 

between 2005 and 2010.

•	 In Mexico, mills reported a total of 12 pollutants 

released to air, and 11 released to water.

•	 In the United States, 60 pollutants were reported 

released to air, and 47 to water. 

Figure 34. Releases to Air and Water Reported by Canadian Paperboard Mills, 2005–2010

1,800,000

1,600,000

1,400,000

1,200,000

1,000,000

800,000

600,000

400,000

200,000

Kilograms

2005 2010 2005 2010 2005 2010

Total Releases and Transfers Releases to Air Releases to Water

5 Paperboard Mills Reporting 

in Both 2005 and 2010 (kg) 701,163 696,607 563,959 571,645 78,369 84,835

All Paperboard Mills 

(10 Reporting in 2005; 

7 Reporting in 2010) (kg)

1,614,235 758,983 1,267,710 623,136 176,909 90,835

Canada NPRI

46. “Reported” pollutants means those reported in amounts of at least 0.0001 kilograms.
84 Commission for Environmental Cooperation

The pollutants reported released to air and water in largest proportions by this sector, and the 2005–2010 changes 

in these releases, are shown in Tables 29a and 29b. Different factors can affect the amounts and types of pollutant 

reported by facilities, including the type and age of facilities, 

the fuels used, and the process technologies.

These tables reveal that the top six pollutants accounted for 

approximately 98 percent of all reported releases to air in 

both years, while for reported releases to water, the top five 

pollutants together accounted for 99 percent of the total 

each year. A majority of these substances saw decreases in 

releases over this period.

The data in these tables highlight the impacts of differences 

among the three countries in PRTR reporting requirements 

for pollutants. Of the top pollutants released to air and water, 

only four are subject to PRTR reporting in all three countries. In fact, of the 109 pollutants reported released to air 

and water by this sector, only 25 are common to the three 

PRTRs. Many of the substances that make up the typical pollutant profile of the pulp and paper manufacturing sector, and 

that were released to air and water in largest proportions (e.g., 

methanol to air, nitrates to water), are not subject to Mexico’s 

RETC. However, even the pollutants that are subject to PRTR 

reporting in Mexico (e.g., acetaldehyde) were not reported by 

Mexican pulp and paper manufacturing facilities.

Of total reported releases to air by this sector, methanol 

alone accounted for 65 percent in 2005 and 62 percent in 

2010. Reporting pulp mills, especially in the United States, 

accounted for the majority of these releases. Methanol is 

often emitted as a by-product in pulping and bleaching 

operations, as well as the pulping chemical recovery cycle. 

With respect to the latter, releases to air of methanol (and 

a number of other VOCs, as well as particulates, reduced 

sulfur compounds, and other pollutants) present ongoing 

challenges for pulp mills. The overall decrease of 23 percent 

in releases to air of this pollutant reflects decreases among 

US mills. 

Tables 29a and 29b also reveal differences in the proportions 

of the top pollutants reported by Canadian and US mills. 

However, differences between the two countries in PRTR 

reporting requirements would not appear to be the reason 

since, with the exception of a few, the top reported pollutants 

are subject to both Canada’s NPRI and the US TRI. Therefore, the data suggest the impact of other factors. These factors can include the choice of chemical inputs—for example, 

in the case of reported releases of chlorine dioxide, not all 

mills bleach their pulp and those that do might choose to use 

non-chlorinated compounds. Thus, the substances used, the 

industrial processes and the size of operations are some of the 

variables that can provide additional information about differences in facilities’ reported releases to air and water. 
Taking Stock North American Pollutant Releases and Transfers Vol. 14 85

Table 29a. Top Pollutants Released to Air by Pulp, Paper and Paperboard Mills in North 

America, 2005–2010

Pollutants

Releases to Air 

2005 (kg)

Releases to Air 

2010 (kg)

% Change 

2005–2010 

%, Canada 

NPRI, 2010

%, Mexico 

RETC, 2010

%, US TRI, 

2010

Methanol (CA, US) 60,265,731 46,608,814 -23 19 – 81

Ammonia, Total (CA, US) 9,367,690 7,811,700 -17 20 – 80

Hydrochloric Acid (CA, US) 9,131,233 7,993,865 -12 22 – 78

Sulfuric Acid (CA, US) 4,162,369 2,464,961 -41 7 – 93

Acetaldehyde (CA, MX, US) 4,057,959 2,754,719 -32 14 0 86

Hydrogen Sulfide (CA, MX) 1,197,959 538,271 -55 100 0 –

Formaldehyde (CA, MX, US) 865,464 733,914 -15 12 0 88

Chlorine Dioxide (CA, MX, US) 709,806 568,532 -20 68 0 32

Phenol (CA, MX, US) 551,304 920,156 67 19 0 81

Cresols (CA, US) 403,762 577,938 43 0 – 100

Total Reduced Sulfur (TRS) (CA) – 2,760,633 -13* 100 – –

Total, 11 Pollutants 90,713,276 73,733,501

Total, All Pollutants 92,650,349 75,094,700

%, Top Pollutants, of All Pollutants 98 98

* Percentage change calculated from 2007 (first year of TRS reporting in Canada). 

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.

Table 29b. Top Pollutants Released to Water by Pulp, Paper and Paperboard Mills in North 

America, 2005–2010

Pollutant

Releases to Water 

2005 (kg)

Releases to Water 

2010 (kg)

% Change 

2005–2010 

%, Canada 

NPRI, 2010

%, Mexico 

RETC, 2010

%, US TRI, 

2010

Nitric Acid/Nitrate Compounds (CA, US) 4,940,424 4,629,247 -6 37 – 63

Manganese (and compounds) (CA, US) 3,243,694 2,952,440 -9 35 – 65

Methanol (CA, US) 2,745,486 1,799,779 -34 20 – 80

Ammonia, Total (CA, US) 2,601,349 4,105,726 58 83 – 17

Phosphorous, Total (CA) 2,045,909 1,063,191 -48 100 – –

Zinc (and compounds) (CA, US) 220,144 183,632 -17 24 – 76

Formaldehyde (CA, MX, US) 180,691 104,142 -42 34 0 66

Acetaldehyde (CA, MX, US) 172,499 167,906 -3 8 0 92

Barium (and compounds) (US) 148,708 126,156 -15 – – 100

Formic Acid (CA, US) 62,235 149,091 140 0 – 100

Total Reduced Sulfur (TRS) (CA) – 193,919 113* 100 – –

Total, Top 11 Pollutants 16,361,140 15,475,229

Total, All Pollutants 16,599,055 15,683,803

%, Top Pollutants, of All Pollutants 99 99

* Percentage change calculated from 2007 (first year of TRS reporting in Canada). 

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.
86 Commission for Environmental Cooperation

Figure 35. Distribution of Facilities Reporting Releases to Air to the North American PRTRs, 2010

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.

Paper Mills

Paperboard Mills

Pulp Mills

On-site Releases to Air (kg)

 0-125,000

 125,000-400,000

 400,000-700,000

 700,000-1,300,000

 1,300,000-1,925,188 Projection: Lambert Azimuthal Equal Area

0 150 300 600 km

±

Releases to Air (kg)

Paper Mills

Paperboard Mills

Pulp Mills

0–125,000

125,000–400,000

400,000–700,000

700,000–1,300,000

1,300,000–1,925,118

Projection: Lambert Azimuthal Equal Area

0 150 300 600 km

Figure 35 shows the locations of the pulp, paper and paperboard mills that reported releases to air to their respective PRTRs 

in 2010, while Table 30 presents the top facilities for reported releases to air in 2005 and 2010.
Taking Stock North American Pollutant Releases and Transfers Vol. 14 87

Table 30. Top Reporting Facilities in the Pulp, Paper and Paperboard Mills Sector: Releases to Air, 

2005–2010

Facility Name PRTR ID City

State/Province/ 

Territory Country Industry Sector

Releases to 

Air 2005 (kg)

Releases to 

Air 2010 (kg)

% Change 

2005–2010

Catalyst Paper Corporation 

- Crofton Division 1266 Crofton British Columbia Canada Pulp Mills 951,729 978,791 3

AbiBow Canada Inc. 

- Thunder Bay Operations 930 Thunder 

Bay Ontario Canada Pulp Mills 911,526 468,850 -49

Eurocan Pulp and Paper 3171 Kitimat British Columbia Canada Paper Mills 742,398 0 –

Canfor Pulp - Prince George Pulp 

and Paper/Intercontinental Pulp 4063 Prince George British Columbia Canada Pulp Mills 722,824 1,228,569 70

Howe Sound Pulp & Paper Corporation 

- Howe Sound Pulp & Paper 1419 Port Mellon British Columbia Canada Pulp Mills 689,454 616,403 -11

Canfor Pulp Limited Partnership 

- Northwood Pulp Mill 1797 Prince 

George British Columbia Canada Pulp Mills 683,369 1,010,964 48

Catalyst Paper - Elk Falls 333 Campbell 

River British Columbia Canada Paper Mills 630,535 0 –

Terrace Bay Pulp Inc. 

- Terrace Bay Pulp 2607 Terrace Bay Ontario Canada Pulp Mills 615,765 82,095 -87

Twin Rivers Paper Company 

- Edmundston Pulp Mill 1221 Edmundston New Brunswick Canada Pulp Mills 585,107 591,361 1

Prince Albert Pulp Inc. 

- Prince Albert Pulp and Paper 3610 Prince 

Albert Saskatchewan Canada Pulp Mills 549,935 0 –

Total, Top 10 Mills, Canada NPRI 7,082,643 4,977,034

Total, All Reporting Mills, Canada NPRI 18,842,150 17,197,471

%, Top Mills, of All Reporting Mills, Canada NPRI 38 29

Copamex Industrias, S.A. de C.V. CIN561904611 San Nicolás 

de Los Garza Nuevo León Mexico Paper Mills 2,424 0 -100

Smurfit Cartón y Papel de México 

- Div. Molino Los Reyes SCP561510411 Tlalnepantla Mexico Estado Mexico Paper Mills 25 17 -34

Papelera Iruña, S.A. de C.V. PIR570900711 N/A Distrito Federal Mexico Paperboard Mills 17 17 0

Smurfit Carton y Papel de Mexico, 

S.A. de C.V. SCP561503311 Ecatepec Mexico Estado Mexico Paperboard Mills 4 58 1,546

Total, Top 4 Mills,* Mexico RETC 2,469 91

Total, All Reporting Mills, Mexico RETC 2,469 91

%, Top Mills, of All Reporting Mills, Mexico RETC 100 100

International Paper Co. - Mansfield Mill 71052NTRNTHWY50 Mansfield Louisiana United States Pulp and 

Paperboard Mills 2,206,027 1,842,790 -16

International Paper Co. Texarkana Mill 75504NTRNTPOBOX Queen City Texas United States Paper Mills 2,139,237 1,925,118 -10

International Paper Co. Riegelwood Mill 28456FDRLPRIEGE Riegelwood North Carolina United States Pulp Mills 2,103,977 1,781,085 -15

Rayonier Performance Fibers 

- Jesup Mill 31545TTRYNSAVAN Jesup Georgia United States Pulp Mills 1,907,041 1,526,722 -20

Evergreen Packaging 71611NTRNTFAIRF Pine Bluff Arkansas United States Pulp and 

Paper Mills 1,892,388 689,687 -64

Smurfit-Stone Container Corp. 29502STNCNOLDGE Florence South Carolina United States Paperboard Mills 1,805,624 548,182 -70

Meadwestvaco of Virginia 

- Covington Operations 24426WSTVCRIVER Covington Virginia United States Paperboard Mills 1,799,884 1,311,157 -27

Smurfit-Stone Container Enterprises Inc. 32034CNTNRNORTH Fernandina 

Beach Florida United States Pulp and Paperboard Mills 1,466,599 699,112 -52

International Paper Co. Franklin Mill 23851NNCMPHIGHW Franklin Virginia United States Paper Mills 1,438,627 163,944 -89

Wisconsin Rapids Pulp Mill 54494CNSLD950FO Wisconsin 

Rapids Wisconsin United States Pulp Mills 1,291,171 692,627 -46

Total, Top 10 Mills, US TRI 18,050,575 11,180,425

Total, All Reporting Mills, US TRI 78,805,730 57,897,138

%, Top Mills, of All Reporting Mills, US TRI 23 19

*Only four Mexican mills reported releases to air between 2005 and 2010. 

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.
88 Commission for Environmental Cooperation

Figure 36. Distribution of Facilities Reporting Releases to Water to the North American PRTRs, 2010

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.

Paper Mills

Paperboard Mills

Pulp Mills

On-site Releases to Water (kg)

 0-30,000

 30,000-100,000

 100,000-200,000

 200,000-300,000

 300,000-2,283,884

Projection: Lambert Azimuthal Equal Area

0 150 300 600 km

±

Releases to Water (kg)

Paper Mills

Paperboard Mills

Pulp Mills

0–30,000

30,000–100,000

100,000–200,000

200,000–300,000

300,000–2,283,884

Projection: Lambert Azimuthal Equal Area

0 150 300 600 km

Figure 36 shows the locations of the pulp, paper and paperboard mills that reported releases to water to their respective 

PRTRs in 2010, while Table 31 presents the top facilities for reported releases to water in 2005 and 2010.
Taking Stock North American Pollutant Releases and Transfers Vol. 14 89

Table 31. Top Reporting Facilities in the Pulp, Paper and Paperboard Mills Sector: Releases to Water, 

2005–2010 

Facility Name PRTR ID City

State/Province/ 

Territory Country

Industry 

Sector

Releases to 

Water 2005 (kg)

Releases to 

Water 2010 (kg)

% Change 

2005–2010 

Compagnie Abitibi Consolidated 

du Canada - Div. Alma 983 Alma Québec Canada Pulp Mills 809,866 231,562 -71

Catalyst Paper Corporation 

- Powell River Division 723 Powell River British Columbia Canada Pulp and 

Paper Mills 447,808 178,857 -60

Irving Pulp & Paper Ltd. 

- Irving Pulp & Paper 2604 Saint John New Brunswick Canada Pulp Mills 369,377 280,401 -24

Domtar Inc. - Kamloops Mill (SFO) 2924 Kamloops British Columbia Canada Pulp Mills 283,819 252,974 -11

Domtar Inc. - Cornwall Business Unit 1197 Cornwall Ontario Canada Paper Mills 253,996 0 –

Cariboo Pulp and Paper Company 479 Quesnel British Columbia Canada Pulp Mills 222,866 272,128 22

Western Pulp Limited 

- Squamish Operation 2872 New Westminster Dist. British Columbia Canada Pulp Mills 205,029 0 –

West Fraser Mills Ltd. - Hinton Pulp 2991 Hinton Alberta Canada Pulp Mills 193,895 180,784 -7

AbiBow Canada Inc. 

- Thunder Bay Operations 930 Thunder Bay Ontario Canada Pulp Mills 187,454 117,927 -37

Domtar Inc. - Domtar Windsor Mill 1195 Windsor Québec Canada Pulp Mills 181,927 96,889 -47

Total, Top 10 Mills, Canada NPRI 3,156,038 1,611,521

Total, All Reporting Mills, Canada NPRI 7,471,181 7,972,689

%, Top Mills, of All Reporting Mills, Canada NPRI 42 20

Kimberly Clark De Mexico, S.A. de C.V. KCM562201621 San Cayetano Querétaro Mexico Paper Mills 2,174 2,029 -7

Smurfit Carton y Papel de Mexico, 

S.A. de C.V. SCP561503311 Ecatepec Mexico Estado Mexico Paperboard Mills 961 882 -8

Empaques de Carton Titan, S.A. de C.V. ECT571903912 Monterrey Nuevo León Mexico Paperboard Mills 500 0 –

Smurfit Cartón y Papel de México 

- Div. Molino Los Reyes SCP561510411 Tlalnepantla Mexico Estado Mexico Paper Mills 203 0 –

Grupo Pipsamex, S.A. de C.V. 

Planta Veracruz GPI563020711 Tres Valles Veracruz Mexico Paper Mills 167 0 -100

Sonoco de Mexico, S.A de C.V. SME561503311 Santa Clara 

Coatitla Mexico Estado Mexico Paperboard Mills 133 10 -93

Industrias Centauro, S.A de C.V. ICE561000511 Durango Durango Mexico Paper Mills 102 0 –

Papeles Lozar, S.A de C.V. PLO561503911 N/A Mexico Estado Mexico Paper Mills 59 0 –

Papelera Iruña, S.A. de C.V. PIR570900711 N/A Distrito Federal Mexico Paperboard Mills 57 24 -57

Manufacturas Sonoco, S.A. de C.V. MSO571501211 Atizapan 

de Zaragoza Mexico Estado Mexico Paperboard Mills 40 323 702

Total, Top 10 Mills, Mexico RETC 4,396 3,268

Total, All Reporting Mills, Mexico RETC 4,496 4,345

%, Top Mills, of All Reporting Mills, Mexico RETC 98 75

Evergreen Pulp Enterprises 95564LSNPCLPDRI Samoa California United States Pulp Mills 691,465 0 –

Alabama River Cellulose LLC 36470LBMRVOFFHI Perdue Hill Alabama United States Pulp Mills 656,294 159,252 -76

Wausau Paper Corp. - Brokaw Mill 54417WSPPR2NDST Brokaw Wisconsin United States Paper Mills 373,054 52,979 -86

Georgia - Pacific Consumer 

Products LP 54307FRTHW1919S Green Bay Wisconsin United States Paper Mills 364,363 160,730 -56

Weyerhaeuser Pacific Veneer 98537WYRHS700EA Aberdeen Washington United States Pulp Mills 347,920 0 –

International Paper - Courtland Mill 35618CHMPNPOBOX Courtland Alabama United States Paper Mills 290,390 327,304 13

Temple-Inland 37134NLNDCCONAL Waverly Tennessee United States Pulp and 

Paperboard Mills 270,035 218,232 -19

Finch Paper LLC 12801FNCHP1GLEN Glens Falls New York United States Paper Mills 243,077 671,373 176

Domtar AW LLC - Ashdown Mill 71822NKSPPHIGHW Ashdown Arkansas United States Pulp Mills 218,499 202,928 -7

Meadwestvaco Texas LP 77656PLPPPPOBOX Evadale Texas United States Paperboard Mills 203,944 160,663 -21

Total, Top 10 Mills, US TRI 3,659,042 1,953,462

Total, All Reporting Mills, US TRI 9,123,378 7,706,768

%, Top Mills, of All Reporting Mills, US TRI 40 25

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.
90 Commission for Environmental Cooperation

3.7.3 Releases to Air and Water of Known or Suspected Carcinogens, 

Developmental or Reproductive Toxicants, Metals and PBTs 

Reported by Pulp, Paper and Paperboard Mills, 2005–2010

Many of the pollutants released directly to the environment 

every year by pulp, paper and paperboard mills belong to 

one or more of the following categories: known or suspected 

carcinogens; developmental or reproductive toxicants; PBTs, 

and metals. This section examines releases to air and water 

of such pollutants and especially those considered to be of 

special interest because of their significant potential risk to 

human health and the environment, even when released in 

relatively small amounts. 

Figures 37 and 38 present the reported releases to air and 

water of pollutants in these four categories by North American pulp and paper mills, from 2005 through 2010. In 2010, 

facilities reported releases to air of 46 such pollutants, for a 

total of almost 5.3 million kilograms—a decrease of about 

20 percent from 2005 levels. Facilities in this sector also 

reported releases to water of 35 pollutants in these categories, for a total of 3.6 million kilograms (a decrease of about 

12 percent from 2005 levels). 

The reported pollutants in these four categories that are 

common to the three PRTRs are represented by the colored portion of the bars in these graphs, while all reported 

pollutants in these categories are represented by the gray 

portion of the bars. Both of these figures reveal a notable 

difference in reported releases of common versus all metal 

compounds. Some of the metals released to water in largest 

proportions over this period include manganese and zinc 

and their compounds, which are subject to PRTR reporting 

in both Canada and the United States, but not Mexico; and 

barium and its compounds, which are subject to reporting 

only in the United States. In fact, of all the pollutants in 

these categories reported released to air or water by pulp, 

paper and paperboard mills, only 19 were common to the 

three PRTRs. 

Table 32 presents the sector’s reported releases to air of the 

top 10 pollutants belonging to at least one of these four categories and common to all three PRTRs. It compares the 

pollutants’ release amounts (in kilograms) with their cancer 

and non-cancer risk (TEP) scores, to illustrate their potential toxicity when released to air. Reported releases to air of 

these pollutants declined notably between 2005 and 2010. 

Figure 37. Reported Releases to Air of Known/Suspected Carcinogens, Developmental/Reproductive 

Toxicants, Metals and PBTs: Pulp, Paper and Paperboard Mills, 2005–2010

5,500,000

5,000,000

4,500,000

4,000,000

3,000,000

3,500,000

2,500,000

2,000,000

1,500,000

1,000,000

500,000

Persistent, Bioaccumulative

and Toxic Compounds

Metals Known or Suspected 

Carcinogens

Developmental or 

Reproductive Toxicants

 2005 

 2006

 2007 

 2008

 2009 

 2010

* Some pollutants belong to more than one category. 

Note: Color columns refer to pollutants common to the 3 PRTRs; grey columns refer to pollutants in these categories subject to PRTR reporting in at least one country. 

Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.

Pollutant Category*

Kilograms
Taking Stock North American Pollutant Releases and Transfers Vol. 14 91

 2005 

 2006

 2007 

 2008

 2009 

 2010

Kilograms

Figure 38. Reported Releases to Water of Known/Suspected Carcinogens, Developmental/Reproductive 

Toxicants, Metals and PBTs: Pulp, Paper and Paperboard Mills, 2005–2010

Persistent, Bioaccumulative

and Toxic Compounds

Metals Known or Suspected 

Carcinogens

Developmental or 

Reproductive Toxicants

* Some pollutants belong to more than one category. 

Note: Color columns refer to pollutants common to the 3 PRTRs; grey columns refer to pollutants in these categories subject to PRTR reporting in at least one country. 

Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.

Pollutant Category*

3,750,000

3,500,000

3,250,000

3,000,000

2,750,000

2,500,000

2,250,000

2,000,000

1,750,000

1,500,000

1,250,000

1,000,000

750.000

500,000

250,000

Table 32. Pulp, Paper and Paperboard Mills: Releases to Air of C, D, M, P Common to the Three 

PRTRs, 2005–2010 

Pollutant C D M P*

Releases 

to Air 

2005 (kg)

Releases 

to Air 

2010 (kg)

 % Change 

2005–2010 

Cancer Risk 

Score for Air 

(TEP) 2010

Non-cancer 

Risk Score for 

Air (TEP) 2010

%, Canada 

NPRI, 2010 

(# facilities)

%, Mexico 

RETC, 2010 

(# facilities)

%, US 

TRI, 2010 

(# facilities)

Mercury (and compounds) x x x x 788 785 0 - 10,984,584,401 8.5 (19) 0.5 (3) 91 (113)

Lead (and compounds) x x x x 14,697 12,067 -18 337,870 6,998,741,796 11 (46) 1 (4) 88 (188)

Cadmium (and compounds) x x x x 322 242 -25 6,281,012 458,997,038 97 (53) 0 (3) 3 (1)

Arsenic (and compounds) x x x x 265 368 39 5,886,512 30,904,190 83 (32) 0 (2) 17 (2)

Acetaldehyde x 4,057,959 2,754,719 -32 27,547 25,618,891 14 (25) 0 86 (106)

Chloromethane x 215,384 233,236 8 153,935 13,294,429 18 (3) 0 82 (12)

Nickel (and compounds) x x x x 4,308 3,886 -10 10,881 12,434,871 0 0 (3) 100 (8)

Formaldehyde x 865,464 733,914 -15 14,678 11,742,628 12 (17) 0 (3) 88 (93)

Chromium (and compounds) x x x x 731 1,400 91 182,001 4,340,028 14 (28) 0.1 (3) 86 (8)

Chloroform x x x 214,935 112,626 -48 180,202 1,576,765 38 (2) 0 62 (6)

Total, Top 10 Pollutants Common 

to the 3 PRTRs 5,374,853 3,853,242 13,074,639 18,542,235,037

Total, 19 Pollutants Common 

to the 3 PRTRs 6,020,064 4,805,996 15,640,322 20,415,413,273

* C = Known/Suspected carcinogen; D = Developmental/Reproductive toxicant; M = Metal; P = Persistent, bioaccumulative, toxic substance. 

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.
92 Commission for Environmental Cooperation

This table also reveals a notable absence of data from Mexican mills, with few facilities in that country reporting, and 

these reporting only very small proportions of releases to air 

of three common pollutants: mercury, lead and chromium 

and their compounds. The table shows that many of the pollutants were reported either mostly in Canada, or mostly in 

the United States, perhaps indicating differences between 

the two countries in the processes, fuels or other inputs used 

at pulp and paper mills. 

For example, among the pollutants common to the three 

PRTRs, the large majority of total releases to air of mercury and its compounds in 2010 were reported by US mills. 

These releases remained virtually unchanged between 2005 

and 2010. The high non-cancer risk (TEP) score for mercury provides a strong indication of its potential to cause 

harm when released to air. As mentioned earlier, mercury 

and other pollutants of special interest released by pulp 

and paper mills and other industrial sectors have been the 

subject of increased regulatory actions by North American 

environmental authorities.

The large majority of all releases to air of cadmium and 

its compounds in 2010 were reported by Canadian mills. 

Cadmium and other metals can be released to air through 

the combustion of sludge from the lime kiln and the spent 

liquor in chemical recovery furnaces, as well as from the 

boiler. A number of metals can also be found in the “alternative fuels” sometimes used for power at industrial facilities (most commonly, cement kilns). A review in 2010 of 

a proposal by the Corner Brook Pulp and Paper mill in 

Newfoundland, Canada, to use tire-derived fuel (TDF) to 

generate electricity for the plant raised concerns about the 

potential for releases of metals such as arsenic, zinc and 

their compounds.47

In terms of the common pollutants released to water, Table 

33 shows that releases declined by about 24 percent (from 

about 399,000 kilograms in 2005 to 304,000 kilograms 

in 2010). For the top 10 common pollutants, the release 

amounts (in kilograms) are compared with their cancer and 

non-cancer risk (TEP) scores, resulting in a very different 

picture of these releases to water when the potential toxicity 

of the substances is considered.

Reported releases to water of mercury and its compounds by 

this sector increased notably between 2005 and 2010, from 

about 79 kilograms to almost 338 kilograms—relatively 

small volumes in comparison with other pollutants released 

by pulp and paper mills. However, the high TEP score for 

non-cancer effects puts mercury compounds in first place. 

In 2010, 77 US mills accounted for about 48 percent of total 

47. Government of Newfoundland and Labrador. Department of Environment and Conservation. 2010. Corner Brook Pulp & Paper Tire Derived Fuel (TDF) Co-Firing Trial 

Project. Summary of environmental assessment process. Online at: <www.env.gov.nl.ca/env/env_assessment/projects/Y2010/1539/index.html> (accessed Nov. 2013).

Table 33. Pulp, Paper and Paperboard Mills: Releases to Water of C, D, M, P Common to the Three 

PRTRs, 2005–2010

Pollutant C D M P*

Releases 

to Water 

2005 (kg)

Releases 

to Water 

2010 (kg)

 % Change 

2005–2010

Cancer Risk 

Score for Water 

(TEP) 2010

Non-cancer Risk 

Score for Water 

(TEP) 2010

%, Canada 

NPRI, 2010 

(# facilities)

%, Mexico 

RETC, 2010 

(# facilities)

%, US 

TRI, 2010 

(# facilities)

Mercury (and compounds) x x x x 79 338 326 -- 4,392,487,263 24 (15) 28 (15) 48 (77)

Lead (and compounds) x x x x 16,156 14,520 -10 29,040 609,831,801 15 (40) 6 (15) 80 (129)

Cadmium (and compounds) x x x x 1,229 890 -28 1,691,650 124,647,871 79 (45) 21 (14) 0

Arsenic (and compounds) x x x x 3,726 3,139 -16 12,557,734 62,788,669 90 (28) 10 (14) 0

Chromium (and compounds) x x x x 2,921 3,297 13 -- 1,450,723 27 (25) 27 (18) 46 (6)

Acetaldehyde x 172,499 167,906 -3 1,058 856,320 8 (19) 0 92 (91)

Nickel (and compounds) x x x x 2,797 1,684 -40 -- 43,773 0 47 (20) 53 (6)

Formaldehyde x 180,691 104,142 -42 83 30,201 34 (13) 0 66 (80)

Chloroform x x x 10,761 1,131 -89 1,696 18,095 4 (2) 0 96 (4)

Chloromethane x 2 63 2,575 25 2,154 95 (2) 0 5 (4)

Total, Top 10 Pollutants Common 

to the 3 PRTRs 390,860 297,110 14,281,285 5,192,156,870

Total, 19 Pollutants Common 

to the 3 PRTRs 399,202 304,222 14,579,531 5,403,839,254

* C = Known/Suspected carcinogen; D = Developmental/Reproductive toxicant; M = Metal; P = Persistent, bioaccumulative, toxic substance. 

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.
Taking Stock North American Pollutant Releases and Transfers Vol. 14 93

releases of mercury to water, 15 Mexican mills accounted 

for 28 percent of the total, and 15 Canadian mills accounted 

for 24 percent. 

Compared with releases to air, where there was an absence 

of data from Mexico (Table 32), this table shows that Mexican mills reported releases to water of six metals—some 

of them in relatively large proportions, and from a majority of reporting facilities in this sector. For example, nickel 

and its compounds were reported by 20 mills in Mexico 

in 2010. Nickel compounds can be found in the fossil 

fuels used at pulp and paper mills. Nickel alloys are also 

used in mill equipment (e.g., black liquor digesters/heaters) because they can withstand highly corrosive environments better than other metals. However, wear and tear 

and corrosion do occur and nickel can be released to the 

environment.

3.7.4 Insights from North American Pulp, Paper 

and Paperboard Mills

In order to learn more about the reasons behind reported 

decreases in releases to air and water from this sector and 

especially, environmental sustainability initiatives, the CEC 

conducted a questionnaire survey of mills, to which a small 

number of facilities,48 representing the three subsectors (i.e., 

pulp, paper and paperboard mills), responded. The objective of this survey was to obtain additional information 

from facilities about their activities, and was not intended 

to be a verification of their reported PRTR data. Anecdotal 

comments provided by some of the Canadian and US facilities in their NPRI and TRI reports, relative to their pollution 

prevention efforts or other reasons for year-to-year changes 

in reporting, were also consulted. Finally, pulp and paper 

manufacturing associations in the three countries were contacted for additional comments. The following information 

is drawn from these sources. 

The five Canadian respondents included one facility from 

Alberta, one from Ontario, and three from Quebec. None 

was among the top reporting mills for releases to air or 

water, and their releases to air over the 2005–2010 period 

ranged from a few kilograms to approximately 23,000 kilograms. In terms of releases to water, reported amounts 

ranged from about 400 kilograms to 35,000 kilograms. Each 

of these facilities reported reductions in their releases to air 

and water between 2005 and 2010. 

The Mexican mills for which responses were received were 

located in the states of Mexico, Michoacán, Jalisco, Oaxaca, 

Nuevo León, Querétaro, Veracruz and Sonora. Two of the 

facilities had reported releases to water in the 2005–2010 

period: one of them reporting just under one kilogram, and 

only in 2010; and the other reporting a similar amount, and 

only in 2005. Thus, none of the respondents was among the 

top reporting facilities for releases to air and water.

Of the two US respondents, one was located in Michigan, the 

other from North Carolina. One mill reported releases to air 

of almost 100,000 kilograms in 2005, declining to approximately 60,000 kilograms in 2010; and releases to water 

of about 80 kilograms in 2010, down from 125 kilograms 

in 2005. The other mill reported releases to air of almost 

750,000 kilograms in 2005, and about 400,000 in 2010; and 

releases to water of approximately 22,000 kilograms in 2005 

and 11,000 kilograms in 2010. These two mills were therefore not among the top US reporters for releases to air and 

water over this period.

The respondents answered questions about their processes, 

fuels and material inputs, and their releases to air and water 

between 2005 and 2010, including the following:49

•	 What raw materials and fuels are used in the facility; 

and does the facility use technologies or processes to 

control air pollution, or for the treatment of water and 

waste water? 

•	 What are the main environmental concerns of the 

facility, especially relative to air and water releases?

•	 Did the facility undertake pollution prevention 

initiatives between 2005 and 2010, and what were the 

aims and main drivers?

•	 Did the facility report decreases in air and water 

releases between 2005 and 2010, and what were the 

primary causes?

In terms of the raw materials used, facilities mentioned 

wood chips; recycled and post-industrial fiber (including 

old newspapers and coated paper); and purchased pulp, 

including softwood kraft (bleached) pulp. One US facility 

mentioned the use of eucalyptus fiber, a fast-growing plant 

that has become more common in papermaking (although 

there are some drawbacks, including the fact that it is not 

grown in most areas of North America). Respondents 

also mentioned a wide variety of fuels used to generate 

48. In all, responses were submitted for seventeen mills, but two Mexican companies submitted responses on behalf of multiple mills. Therefore, there are eleven 

individual survey responses: five from Canada, two from the United States, and four from Mexico.

49. The survey questionnaire is provided in Appendix 6. With the exception of facilities that consented to have their names used, names of the responding facilities 

are not mentioned in this report.
94 Commission for Environmental Cooperation

electricity, including natural gas, fuel oil, coal, and landfill gas. A few paper and newsprint mills mentioned their 

de-inking processes, and one mentioned the use of sodium 

hydrosulfite for pulp bleaching. 

Seven out of the 11 respondents indicated that they have an 

environmental management system (EMS) in place: four 

claimed an ISO 14001 system; one the Forest Care certification system; and two claimed individual, unregistered systems. Ten of these respondents said they had implemented 

specific changes between 2005 and 2010, with the objective 

of preventing or reducing pollution: 

•	 8 facilities cited improvements made toward energy 

efficiency, including the substitution of fuels (no 

details were provided); 

•	 5 listed the implementation of new processing 

technologies;

•	 4 listed the renovation of existing technologies;

•	 4 listed the substitution or reformulation of raw 

materials, but provided no details;

•	 5 listed recycling, with one indicating it was 

researching alternate uses for some of its waste (a new 

product); and

•	 1 stated that it had joined a clean industry program.

Four facilities also provided details of new pollution control 

technologies, which included the following:

•	 Water and wastewater:

o use of sodium hypochlorite and a biocide for 

treating wastewater (via sand filtration);

o use of ion exchange technology to separate 

residual color and chloride from wastewater;

o clarifiers and activated sludge treatment, and 

primary and secondary wastewater treatment 

processes. 

•	 Residual sludge: sent to landfill, both on- and off-site; 

applied to land; or sent off-site for composting.

•	 Air pollutants: facilities mentioned the use of an 

electrostatic precipitator (which removes small particles 

by passing the flue gas through an electrically-charged 

screen to then be able to separate the charged particles). 

They also mentioned the use of flue gas scrubbers to 

remove pollutants that are then converted into a sludge 

for disposal or other treatment. 

When asked if these actions were taken to address specific 

environmental issues, five of the mills cited the need to 

reduce releases of criteria air contaminants (e.g., NOx

, particulate matter) and greenhouse gases. Two facilities mentioned management of solid waste, and one facility cited 

the prevention of fugitive dust, as objectives. None of the 

facilities listed releases of “other hazardous or toxic substances” as an objective. Nevertheless, the implementation 

of pollution control technologies aimed at reducing releases 

of specific substances (e.g., greenhouse gases) often results 

in reductions in releases of other pollutants contained in the 

same waste stream. 

In terms of the main drivers for the initiatives undertaken at 

these facilities, the majority of respondents mentioned more 

than one, as follows:

•	 7 facilities listed a corporate commitment to the 

environment;

•	 6 facilities listed other economic benefits (e.g., fuel, 

energy and raw materials costs, and a reduction in 

cost associated with fuel substitution; as well as a new 

product from waste);

•	 5 facilities cited the modernization of the facility;

•	 5 facilities cited compliance with regulations;

•	 3 facilities listed incentive programs;

•	 2 facilities listed community relations, including 

customer demand; and 

•	 1 facility listed access to international markets.

The majority of respondents stated that multiple factors 

accounted for the changes implemented at their facilities 

between 2005 and 2010. These included the need to comply 

with regulations (e.g. facility permitting requirements, a 

reason invoked for facilities’ use of PRTR data). Economic 

drivers (the price of raw materials and other economic benefits) appear to be among the strongest incentives for these 

facilities, and collectively were listed 10 times. The corporate 

commitment to the environment is significant (7 mentions), 

as well as the modernization of facilities (5 mentions), which 

in most cases can be understood to occur for non-environmental reasons. Community relations, customer demand, 

and access to international markets were mentioned less frequently, but remained part of the mix of drivers influencing 

the changes implemented within these mills.

In terms of PRTR reporting, there was not always a congruence between facility responses and the changes shown in 

the data for releases to air and water between 2005 and 2010 

(i.e., some respondents mentioned decreases when the data 

show increases). This might be the result of respondents’ 

inadvertently referring to releases that occurred before or 

after the 6-year time frame of this survey. Eight of the facilities cited a decrease in air and water releases from 2005 

to 2010. For air releases, one facility mentioned a decrease 

in production (resulting from a boiler shutdown) as the 

reason for the change; another cited a change in emission 
Taking Stock North American Pollutant Releases and Transfers Vol. 14 95

estimation techniques. For water releases, one facility cited 

improved effluent control as a reason for the decrease, and 

another facility cited fuel switching. 

The Alberta Newsprint Company, located in Whitecourt, 

Alberta, described reductions in releases to water that 

mirror the 2005–2010 changes in its reported PRTR data. 

This facility did not report releases to air over this period, 

but reported releases to water of almost 9,000 kilograms in 

2010, a reduction from about 11,110 kilograms reported in 

2005. The majority of these releases were of total phosphorous. The facility stated that during this period, it implemented multiple pollution prevention activities, including 

the installation of pollution control equipment, new processing technology, reductions in the chemicals used for 

waste treatment, and renovation of existing technology. The 

mill also participated in a phosphorus reduction program, 

which explains the decreases in reported releases to water of 

this pollutant. The facility mentioned regulations, economic 

benefits, and incentive programs as the drivers of its pollution prevention initiatives. 

During the process of conducting the questionnaire survey, 

certain errors in reporting by a small number of Mexican pulp 

and paper mills were identified, including errors in data estimations or calculations, and unit errors (e.g., reporting of tons 

instead of kilograms). The Mexican industry association, the 

Cámara Nacional de las Industrias de la Celulosa y del Papel, is 

reviewing the RETC data submitted by these member facilities 

and discussing possible corrections with Semarnat.

Table 34 presents comments included by some of the Canadian and US survey respondents in their PRTR reporting 

forms between 2005 and 2010—a useful source of information about the reasons for changes in reported releases 

to air and water over this period. While only a small percentage of facilities provide such comments (with comparable details not available through the RETC reporting 

form), the benefit of these comments is that they are submitted annually and are pollutant-specific. As such, they 

can provide a greater level of accuracy about changes in 

reported data. 

The results of this questionnaire survey suggest that, despite a 

certain disconnection between facility responses and changes 

in their PRTR data, decreases in releases to air and water from 

participating pulp and paper facilities were directly related to 

changes in environmental management practices. Nevertheless, facility comments also indicate that other factors were 

partly responsible for these decreases, including economic 

considerations, data corrections or changes in estimation 

methodologies, or a slowdown in production. 

A number of mills acknowledged that PRTR data are used 

in external communications with the public, with comments also indicating that customer demand played a role 

in their environmental management decisions, such as the 

choice of chemicals used at their facilities. This suggests that 

PRTR data have wider impacts and that they are a useful 

tool not only for industrial facilities, but for external stakeholders as well.

Table 34. Reasons for Changes in Reported Releases to Air and Water, 2005–2010: Canadian NPRI 

and US TRI 

Reasons for Changes in reported 

PRTR data

Example Statement (statements have been edited for length and clarity)

Change in production Due to downturn in the economy, there was significantly less production.

Changes in estimation techniques, 

calculation methods, or corrections 

of errors

Emissions testing in 2007 for phenol enabled more-precise quantification of the amount of phenol used, 

consumed, and emitted from the process. This testing indicated that, although based upon the best information 

available at the time, phenol emissions were significantly overestimated in previous years.

Customer/client demand Customer demand has increased for the production of Bisphenol A–free products.

Process change/closure/change of 

ownership

Coating of silver halide–based photographic product was completed in December. Silver emissions were a 

result of wastewater treatment during shutdown of operations (related to silver halide products). As of 2007, 

no further operations utilizing silver are planned (focusing on thermal and inkjet media production).

Economic incentives The facility can burn natural gas or #4 oil. In 2005, the facility shifted use to more oil and less gas, for 

economic reasons.

Change in medium of release or 

transfer for a particular pollutant

Scrap product that retains a small amount of this chemical is being diverted from the landfill to a recycler.

Facility surpasses (or no longer meets) 

reporting thresholds

Production grew during 2009 to the point where manufacturing of this aluminum fume exceeded the required 

reporting threshold of 25,000 pounds/year. This created the need for reporting.

Taking Stock North American Pollutant Releases and Transfers Vol. 14 97

For those new to pollutant release and transfer registers or 

to Taking Stock, this appendix describes the characteristics 

of the three national PRTRs, including the features that are 

unique to the system of each country. It also describes the 

scope of this report and the methodology and terminology 

used in it.

Features of the Three North American PRTRs

Taking Stock is based on information provided by North 

America’s three national PRTR programs:

•	 Canada’s NPRI 

(<www.ec.gc.ca/pdb/npri/npri_online_data_e.cfm>)

•	 Mexico’s RETC 

(<http://app1.semarnat.gob.mx/retc/index.php>)

•	 The US TRI (<www.epa.gov/triexplorer>).

Each country’s PRTR has evolved with its own list of pollutants, sector coverage, and reporting requirements. Table A-1 

compares features of the three PRTRs.

Overview of PRTR Reporting Requirements

Which Pollutants Must Be Reported?

The pollutants subject to national PRTR reporting requirements are listed because they meet certain criteria for 

chemical toxicity and the potential for risk to human 

health and the environment. Each PRTR system covers a 

specific list of substances: NPRI spans almost 350 pollutants, TRI approximately 600, and RETC 104.

Appendix 1

Using and Understanding Taking Stock

Table A-1. Features of the Three North American PRTRs

US Toxics Release Inventory (TRI)

Canada’s National 

Pollutant Release Inventory (NPRI)

Mexico’s Registro de Emisiones 

y Transferencia de Contaminantes (RETC)

First mandatory 

reporting year 1987 1993 2004

Industrial activities or 

sectors covered

Manufacturing and federal facilities, 

electric utilities (oil- and coal-fired), 

coal and metal mines, hazardous waste 

management and solvent recovery 

facilities, chemical wholesalers, and 

petroleum bulk terminals

Any facility manufacturing or using a 

listed chemical, except for exempted 

activities such as research, repair, retail 

sale, agriculture and forestry. Any facility 

releasing criteria air contaminants (CACs) 

to air in specified quantities

Facilities in 11 sectors under federal jurisdiction: petroleum, 

chemicals, paints and ink manufacturing, primary and fabricated 

metals, automotive, pulp and paper, cement/limestone, asbestos, 

glass, electric utilities, and hazardous waste management. 

Also, facilities undertaking specific activities subject to federal 

jurisdiction, such as handling hazardous wastes or discharging 

pollutants to national water bodies

Number of pollutants 

subject to reporting

593 individual pollutants and 30 

pollutant categories

346 pollutants or pollutant groups 104 pollutants

Employee thresholds 10 or more full-time employees (or 

equivalent number of hours)

Generally 10 employees or more. For certain 

activities, such as waste incineration and 

wastewater treatment, the 10-employee 

threshold does not apply

No employee threshold

Substance “activity” 

(manufacture, process or 

otherwise use) thresholds, 

or “release” thresholds

“Activity” thresholds of 25,000 lbs, or 

11,340 kg (with an “otherwise use” 

threshold of about 5,000 kg); lower 

thresholds for certain pollutants (e.g., 

persistent bioaccumulative and toxic 

[PBT] chemicals and dioxins and furans)

“Activity” thresholds of 10,000 kg for 

most chemicals. Lower thresholds for 

certain pollutants such as PBTs, polycyclic 

aromatic hydrocarbons, dioxins and furans, 

and criteria air contaminants

“Release” and “activity” thresholds for each pollutant (a facility 

must report if it meets or exceeds either threshold). Except for 

greenhouse gases, “release” thresholds range from 1 kg to 1,000 

kg. “Activity” thresholds range from 5 kg to 5,000 kg. Any release 

of polychlorinated biphenyls (PCBs) and sulfur hexafluoride, and 

any release or activity involving dioxins and furans, is reportable

Types of releases and 

transfers covered

On-site releases to air, water, 

land, and underground injection; 

off-site releases to disposal; off-site 

transfers to recycling, energy recovery, 

treatment, or sewage

On-site releases to air, water, land, and 

disposal, including underground injection; 

transfers off-site for disposal; treatment 

prior to final disposal (including sewage); 

recycling and energy recovery

On-site releases to air, water and land; transfers off-site for 

disposal, recycling, re-utilization, energy recovery, treatment, coprocessing (input from another production process) and sewage
98 Commission for Environmental Cooperation

As of April 2006, the Chemical Abstracts Service (CAS) 

listed more than 27 million chemical substances and identified more than 239,000 of them as regulated or covered by 

chemical inventories worldwide.

Facilities report the amounts of each pollutant they have 

released to the environment at their own location (on-site). 

They also report how much of the substance was sent offsite for disposal, or transferred for recycling or other waste 

management. Pollutant-based reporting thresholds exist, 

and certain pollutants have lower reporting thresholds due 

to their greater potential for risk to human health and the 

environment. In general, the PRTR pollutant thresholds are 

as follows:

•	 For Canada’s NPRI and the US TRI, a facility must 

report if it manufactures, processes, or otherwise 

uses (e.g., in cleaning industrial equipment) 10,000 

kilograms (NPRI) or 11,340 kilograms (TRI) of a 

listed pollutant.

•	 Mexico’s RETC has both an “activity” threshold and a 

“release” threshold. A facility must report if it meets 

or exceeds either threshold. The RETC “activity” 

threshold is typically either 2,500 kilograms or 5,000 

kilograms, depending on the substance; the typical 

“release” threshold is 1,000 kilograms.

For more information, see Appendix 2: Pollutants Common 

to at Least Two of the Three North American PRTRs.

Assessing potential harm to human health or the environment from particular releases of a pollutant is a complex task, 

because the potential of a substance to cause harm arises from 

various factors, including its inherent toxicity and the nature 

of the exposure to the substance (e.g., the potential risk posed 

by asbestos sent to a secure landfill is considered to be much 

lower than the risk posed by asbestos released to air). However, the reported data and information about a pollutant’s 

chemical properties and toxicity can serve as a starting point 

for learning more about its potential impacts.

Ranking Pollutants by Toxic Equivalency Potential (TEP)

To put pollutant releases into context, Taking Stock includes 

a chemical ranking system that takes into account both a 

pollutant’s toxicity and its potential for human exposure, 

using toxic equivalency potentials (TEPs). TEPs indicate 

the relative human health risk associated with a release of 

Known or Suspected Carcinogens, Developmental or Reproductive Toxicants, Metals, and PBTs

In order to provide more information about PRTR pollutants, the Taking Stock report and Taking Stock Online

database also categorize them as follows (with many of the pollutants reported to the North American PRTRs 

falling into one or more of these categories):

• Known or suspected carcinogens, based on the World Health Organization’s International Agency for 

Research on Cancer (IARC) and California’s Office of Environmental Health Hazard Assessment (OEHHA) 

Proposition 65 list.50

• Developmental or reproductive toxicants, based on California’s Proposition 65 list. These substances 

adversely affect reproductive capabilities and/or the development of the fetus. Metals, solvents, and 

pesticides have been widely implicated in reproductive and/or developmental impacts. Endocrine disruptors 

have also been added to this category.

• Persistent, bioaccumulative and toxic substances (PBTs). These pollutants have properties that render them 

a long-term environmental and health threat, even in small quantities. When PBTs are released into the 

environment, they persist over long periods of time and do not break down easily into other compounds; 

they can be transported in the atmosphere over long distances, ending up far from the sources of their 

release; and they bioaccumulate in the food chain (increasing in concentration at higher levels). They are 

also toxic, often causing damage to humans, plants and wildlife.

• Metals. Metals occur naturally, but human activities such as mining and smelting increase the proportions 

of metals in the environment. The toxicity of certain metals and their compounds depends on the forms they 

take in the environment. 

50. International Agency for Research on Cancer (IARC). 2013. Classification. Online at: <http://monographs.iarc.fr/ENG/Classification/index.php>. State of 

California. Office of Environmental Health Hazard Assessment (OEHHA). 2013. Proposition 65 list. Online at: <www.oehha.org/prop65.html>.
Taking Stock North American Pollutant Releases and Transfers Vol. 14 99

one unit of a pollutant, compared to the risk posed by the 

release of one unit of a reference substance. TEP weights 

are calculated using the CalTOX model developed by California regulatory agencies. TEPs are one of many different screening tools, each of which is based on a series of 

assumptions, thus yielding different results.

Readers should note that the TEP analysis is limited, in that a 

release does not directly correlate to actual exposures or levels 

of risk. In addition, not all of the substances have an assigned 

TEP (information on their toxicity or exposure potential 

may be missing). However, these pollutants should not be 

assumed to be without risk. Also, TEPs are available only for 

air and water releases and it should not be assumed that other 

types of pollutant releases (e.g., to land) present no risk.

The TEP reference chemical for carcinogens is benzene and 

the reference chemical for non-carcinogens is toluene. The 

TEP weights used in the Taking Stock report and online database have been taken from the Scorecard website (<http://

scorecard.goodguide.com/env-releases/def/tep_gen.html>), 

June 2013. The TEP weight is multiplied by the amount of 

release, to provide a score for each pollutant.

Which Industries Report?

Each country requires PRTR reporting by facilities in specific industrial sectors or undertaking specific industrial 

activities.

•	 In Canada, all facilities that meet reporting thresholds 

and requirements report to the NPRI, with the 

exception of a few resource-based sectors and certain 

activities such as research laboratories.

•	 In Mexico, all industrial sectors regulated under 

federal law are required to report to the RETC, along 

with facilities in other sectors that engage in activities 

subject to federal regulation. These include facilities 

that handle hazardous wastes, or discharge pollutants 

into national water bodies.

•	 In the United States, TRI requires reporting by federal 

facilities, most manufacturing facilities and industries 

that service manufacturing facilities (e.g., electric 

utilities and hazardous waste management facilities). 

A few resource-based sectors, such as oil and gas 

extraction, are exempt from reporting.

Reporting of Criteria Air Contaminants and Greenhouse Gases 

Data for releases of criteria air contaminants (CACs) and greenhouse gases (GHGs) are not included in Taking Stock, 

due to differences in national reporting requirements for these pollutants. CACs—including carbon monoxide, 

nitrogen oxides, particulate matter, sulfur oxides and volatile organic compounds—are a group of chemicals 

associated with environmental effects such as smog, acid rain and regional haze, and health effects such as 

respiratory illnesses. Major sources of CACs are the burning of fossil fuels, as well as natural resource extraction 

and a variety of manufacturing activities. GHGs contribute to climate change by trapping heat within the earth’s 

atmosphere. They are the subject of the international Kyoto Protocol, which came into force in 2005. The major 

GHGs include carbon dioxide, methane, nitrous oxide and three groups of fluorinated gases. Some of the main 

anthropogenic sources of GHGs are the burning of fossil fuels, deforestation and agricultural activities. CACs are 

reported to Canada’s NPRI and GHGs are reported to Mexico’s RETC, but these pollutants are not subject to US TRI 

reporting. However, there are other sources of information on emissions of these pollutants in all three countries: 

Criteria Air Contaminants:

• Canada’s National Pollutant Release Inventory: <www.ec.gc.ca/inrp-npri/Default.asp?lang=En&n=4A577BB9-1> 

• US National Emissions Inventory: <www.epa.gov/air/emissions/> 

• Inventario Nacional de Emisiones de México (National Emissions Inventory of Mexico): <www.inecc.gob.mx/

dica/547-calaire-inem> 

Greenhouse Gases:

• Canada’s Greenhouse Gas Reporting Program and National Inventory Report: <www.ec.gc.ca/ges-ghg/default.

asp?lang=En&n=1357A041-1> 

• US Greenhouse Gas Reporting Program: <http://www.epa.gov/ghgreporting/> 

• US Greenhouse Gas Emissions website: <www.epa.gov/climatechange/ghgemissions/index.html> 

• Mexico’s RETC (facility-specific GHG data): <http://app1.semarnat.gob.mx/retc/index.html>
100 Commission for Environmental Cooperation

North American Industry Classification System

Canada, Mexico and the United States have adopted the 

North American Industry Classification System (NAICS), 

whose codes are used to categorize the industrial activities 

of a facility. NAICS codes were established in 1997 and since 

2006 they have been incorporated into PRTR reporting to 

replace the standard industrial classification (SIC) codes 

used by each country. Although there is some variation 

among the three countries in the subsector categorizations 

and codes used, the breakdown of industrial sectors into 

general categories is the same (see the text box). For more 

information about the implementation of the NAICS system 

in each country, see:

•	 Canada: <www.statcan.gc.ca/subjects-sujets/standardnorme/naics-scian/2007/list-liste-eng.htm>

•	 Mexico: <www.inegi.org.mx/est/contenidos/espanol/

metodologias/censos/scian2007_1.pdf>

•	 United States: <www.census.gov/cgi-bin/sssd/naics/

naicsrch?chart=2007>

PRTR reporting requirements are based in part on the 

industrial activity undertaken within a facility, and not 

only the industry code assigned to that facility. Therefore, 

not all facilities within a given sector might have to report. 

For example, within the economic sector that includes 

dry-cleaning, only those facilities undertaking the actual 

dry-cleaning process, and not clothing drop-off points, 

might be required to report. Another example is a food processing plant that is required to report because it has its own 

power plant to generate electricity.

Employee Thresholds

Both NPRI and TRI have an employee threshold, generally 

corresponding to the equivalent of 10 full-time employees (with some exceptions for pollutants or certain types 

of facilities). Mexico’s RETC does not have an employee 

threshold. More information on reporting instructions is 

available on the NPRI, RETC and TRI websites (see above).

Taking Stock Terminology

Taking Stock uses the following categories for presenting information on pollutant releases and transfers (see Figure A-1).

Releases

•	 On-site releases describes releases that occur at a facility—that is, pollutants that are released into the air or 

water, injected into underground wells, or put in landfills “inside the fence line.”

•	 Off-site releases describes pollutants sent off-site for 

disposal. Waste sent off-site to another facility for 

disposal may be disposed of on land, in landfills or by 

underground injection. These methods are the same as 

on-site releases, but they occur at locations other than 

at the originating facility.

Transfers

•	 Transfers to recycling describes substances sent offsite for recycling.

•	 Transfers for further management describes pollutants (other than metals; see figure A-1) sent off-site for 

treatment, energy recovery, or to sewage.

North American Industry Classification System

NAICS code Industry

11 Agriculture, Forestry, Fishing and 

Hunting

21 Mining, Quarrying and Oil and Gas 

Extraction

22 Utilities (Electricity, Water and Gas 

Distribution)

23 Construction

31/32/33 Manufacturing

41/42/43 Wholesale Trade

44/45/46 Retail Trade

48/49 Transportation and Warehousing

51 Information and Cultural Industries

52 Finance and Insurance

53 Real Estate and Rental and Leasing

54 Professional, Scientific and 

Technical Services

55 Management of Companies and 

Enterprises

56 Administrative and Support, Waste 

Management and Remediation 

Services

61 Educational Services

62 Health Care and Social Assistance

71 Arts, Entertainment and Recreation

72 Accommodation and Food Services

81 Other Services (except Public 

Administration)

91/92/93 Public Administration
Taking Stock North American Pollutant Releases and Transfers Vol. 14 101

Taking Stock Scope and Methodology

Data from the three countries’ PRTRs were obtained by the 

CEC from the three governments or retrieved from their publicly accessible websites. For this edition of Taking Stock, the 

CEC received the latest dataset (from 2005 through 2010) from 

Canada and the United States in March 2012, and Mexico in 

October 2012.51 With the exception of criteria air contaminants 

(CACs) and greenhouse gases (GHGs), all reported data from 

the three countries are accessible through the Taking Stock 

Online integrated North American PRTR database.

The methodology used in preparation of the annual Taking 

Stock report and online database includes the following:

•	 The PRTR data from each country are compiled for 

the Taking Stock integrated, North American PRTR 

database. This involves standardizing data fields used 

in the three countries—for example, aggregating 

reported off-site transfers to disposal (NPRI) into 

an “off-site releases” category (see Taking Stock 

Terminology, above or online).

•	 Certain individual reported substances, including 

many metals, are aggregated into pollutant groups 

or categories (e.g., lead and its compounds, xylene 

isomers). In these cases, no specific CAS number for 

the pollutant group is assigned.

•	 The data are submitted to a general review in order to 

identify inconsistencies or possible errors, which are 

then communicated to the national PRTR programs. 

Although the CEC cannot be responsible for erroneous 

reporting by facilities, the goal of the North American 

PRTR project is to use the best data possible.

•	 Data for each reporting year (going back to 2005) are 

refreshed at least annually—a fact readers are urged 

to remember, particularly when they attempt to use 

the data to analyze time trends. Users can visit the 

national websites to view changes to the data.

Figure A-1. Pollutant Releases and Transfers in North America

On-site Releases

are pollutants released to air, surface water, 

underground injection or land at the facility

A facility reports each year 

on amounts of listed pollutants released 

on- and off-site and transferred off-site

Off-site Releases

are all pollutants sent off-site 

for disposal, as well as metals sent to 

treatment, sewage or energy recovery ? cec

.org ? cec ? .org cec

.org ? cec

.org

? cec

.org

? cec

.org

Transfers to Disposal:

n Transfers of metals

n Transfers of other substances

Off-site Transfers

include pollutants sent for recycling as well 

as other transfers for further management

Other Transfers for Further 

Management (excludes metals):

n Energy recovery 

n Treatment 

n Sewage

? cec ? .org

cec

.org

Transfers to Recycling:

n Recycling of metals

n Recycling of other substances

Air

Surface Water

Underground 

Injection

Land

Source: CEC. 2011. Taking Stock: North American Pollutant Releases and Transfers 13. Figure A-1. Montreal: Commission for Environmental Cooperation. Online at: <www3.cec.org/islandora/en/item/4303-

taking-stock-13-north-american-pollutant-releases-and-transfers-en.pdf>.

*A note about metals: Metals sent off-site for disposal or to sewage, treatment, or energy recovery are included in the off-site releases category. This mirrors the US TRI practice of classifying all transfers 

of metals as “transfers to disposal,” because metals sent to energy recovery, treatment or sewage treatment may be captured and removed from waste and disposed of in landfills or by other disposal 

methods. This approach recognizes the physical nature of metals, and acknowledges that metals sent to disposal, sewage, treatment or energy recovery are not likely to be destroyed, and therefore they may 

eventually enter the environment. Because this terminology is specific to Taking Stock, the terms release and transfer as defined here may differ from their use in NPRI, RETC and TRI.

51. The data sets of the national PRTR systems are constantly evolving as facilities revise previous submissions to correct reporting errors or make other changes. To get 

the most recent data for specific facilities of interest, readers are encouraged to consult the national PRTR websites.
102 Commission for Environmental Cooperation

Limitations of PRTR Data

Because of national PRTR reporting requirements, including thresholds for pollutants and facilities, only a portion 

of all industrial pollution is being captured. Also, industrial facilities are not the only sources of pollution in North 

America. North American PRTR data do not provide information on the following:

•	 All potentially harmful substances. The data provide 

information only on the pollutants reported to each 

country’s PRTR.

•	 All sources of contaminants. The report includes only 

those facilities in the countries’ industrial sectors, 

or undertaking specific industrial activities, that 

are subject to reporting to each national PRTR 

program. The North American PRTRs do not include 

emissions from automobiles or other mobile sources, 

from natural sources such as forest fires, or from 

agricultural sources. For some pollutants, these 

mobile, natural and agricultural sources can be large 

contributors to the overall amounts.

•	 Releases and transfers of all pollutants from a facility. 

Only those pollutants for which reporting thresholds 

are met are included.

•	 All facilities within required reporting sectors. In 

Canada and the United States, only facilities with 

the equivalent of 10 full-time employees must report 

(with certain exceptions). Mexico has no employee 

threshold.

•	 Environmental fate of or risks from the pollutants 

released or transferred.

•	 Levels of exposure of human or ecological populations 

to the pollutants.

•	 Legal limits of a pollutant from a facility. The data do 

not indicate whether a facility is in compliance with 

permits and other regulations.

Substances released or transferred by industrial facilities 

have physical and chemical characteristics that influence 

their ultimate disposition and consequences for human and 

ecological health. Assessing the potential harm from particular releases of a pollutant to the environment is a complex task because the potential of a substance to cause harm 

arises from various factors, including its inherent toxicity 

and the nature of the exposure to the substance (e.g., the 

potential risk posed by asbestos sent to a secure landfill is 

considered to be much lower than the risk posed by asbestos released to air). PRTR data alone cannot provide enough 

information to assess the potential harm from a pollutant; 

however, the data in combination with other information 

about a pollutant can serve as a starting point for learning 

more about its potential impacts. Readers may wish to seek 

other sources for more information, such as:

•	 US Agency for Toxic Substances and Disease Registry, 

ToxFAQs,:<www.atsdr.cdc.gov/toxfaqs/index.asp>;

•	 State of New Jersey, Department of Health, Right-toKnow Hazardous Substance Fact Sheets (information 

also available in Spanish): <http://web.doh.state.nj.us/

rtkhsfs/indexFs.aspx>.
Taking Stock North American Pollutant Releases and Transfers Vol. 14 103

Appendix 2

Pollutants Common to at Least Two of the Three North American PRTRs 

Table A-2. Pollutants Common to at Least Two of the Three North American PRTRs 

Pollutant CAS No. 

NPRI Threshold 

(kilograms/year)

RETC Threshold 

(kilograms/year)

TRI Threshold 

(kilograms/year)

Reporting of 

Pollutant Mandatory 

Manufacture, process, 

or otherwise use 

Manufacture, process, 

or otherwise use Emission 

Manufacture, process, 

or otherwise use NPRI RETC TRI

1,1,1,2-Tetrachloroethane 630-20-6 10,000 11,340 x x

1,1,1-Trichloroethane 71-55-6 2,500 1,000 11,340 x x

1,1,2,2-Tetrachloroethane 79-34-5 10,000 5,000 1,000 11,340 x x x

1,1,2-Trichloroethane 79-00-5 10,000 5,000 1,000 11,340 x x x

1,1,2-Trichlorotrifluoroethane (CFC-113) 76-13-1 2,500 1,000 11,340 x x

1,1-Dichloro-1-fluoroethane (HCFC-141b) 1717-00-6 10,000 5,000 1,000 11,340 x x x

1,1-Methylenebis (4-isocyanatocyclohexane) 5124-30-1 10,000 11,340 x x

1,2,4-Trichlorobenzene 120-82-1 10,000 5,000 1,000 11,340 x x x

1,2,4-Trimethylbenzene 95-63-6 10,000 11,340 x x

1,2-Butylene oxide 106-88-7 10,000 11,340 x x

1,2-Dichlorobenzene 95-50-1 10,000 5,000 1,000 11,340 x x x

1,2-Dichloroethane 107-06-2 10,000 5,000 1,000 11,340 x x x

1,2-Dichloropropane 78-87-5 10,000 11,340 x x

1,3-Butadiene 106-99-0 10,000 5,000 100 11,340 x x x

1,3-Dichloro-1,2,2,3,3-pentafluoropropane (HCFC-225cb) 507-55-1 2,500 1,000 11,340 x x

1,4-Dichlorobenzene 106-46-7 10,000 5,000 1,000 11,340 x x x

1,4-Dioxane 123-91-1 10,000 5,000 100 11,340 x x x

1-Chloro-1,1-difluoroethane (HCFC-142b) 75-68-3 10,000 5,000 1,000 11,340 x x x

2,2,4-Trimethylhexamethylene diisocyanate 16938-22-0 10,000 11,340 x x

2,4,4-Trimethylhexamethylene diisocyanate 15646-96-5 10,000 11,340 x x

2,4,5-Trichlorophenol 95-95-4 2,500 1,000 11,340 x x

2,4,6-Trichlorophenol 88-06-2 2,500 1,000 11,340 x x

2,4-Diaminotoluene 95-80-7 10,000 11,340 x x

2,4-Dichlorophenol 120-83-2 10,000 11,340 x x

2,4-Dichlorophenoxyacetic acid 94-75-7 2,500 100 11,340 x x

2,4-Dinitrotoluene 121-14-2 10,000 5,000 1,000 11,340 x x x

2,6-Dinitrotoluene 606-20-2 10,000 11,340 x x

2-Ethoxyethanol 110-80-5 10,000 2,500 100 11,340 x x x

2-Mercaptobenzothiazole 149-30-4 10,000 11,340 x x

2-Methoxyethanol 109-86-4 10,000 11,340 x x

2-Methylpyridine 109-06-8 10,000 11,340 x x

2-Naphthylamine 91-59-8 50 100 11,340 x x

2-Nitropropane 79-46-9 10,000 2,500 100 11,340 x x x

2-Phenylphenol 90-43-7 10,000 11,340 x x

3,3-Dichloro-1,1,1,2,2-pentafluoropropane (HCFC-225ca) 422-56-0 2,500 1,000 11,340 x x

3,3'-Dichlorobenzidine dihydrochloride 612-83-9 10,000 11,340 x x

3-Chloro-2-methyl-1-propene 563-47-3 10,000 11,340 x x

3-Chloropropionitrile 542-76-7 10,000 11,340 x x
104 Commission for Environmental Cooperation

Table A-2. Pollutants Common to at Least Two of the Three North American PRTRs 

Pollutant CAS No. 

NPRI Threshold 

(kilograms/year)

RETC Threshold 

(kilograms/year)

TRI Threshold 

(kilograms/year)

Reporting of 

Pollutant Mandatory 

Manufacture, process, 

or otherwise use 

Manufacture, process, 

or otherwise use Emission 

Manufacture, process, 

or otherwise use NPRI RETC TRI

4,4'-Methylenebis(2-chloroaniline) 101-14-4 10,000 11,340 x x

4,4'-Methylenedianiline 101-77-9 10,000 11,340 x x

4,6-Dinitro-o-cresol 534-52-1 10,000 2,500 100 11,340 x x x

4-Aminobiphenyl 92-67-1 2,500 1,000 11,340 x x

4-Nitrophenol 100-02-7 10,000 11,340 x x

7H-Dibenzo(c,g)carbazole 194-59-2 50* 45* x x

Acetaldehyde 75-07-0 10,000 2,500 100 11,340 x x x

Acetonitrile 75-05-8 10,000 11,340 x x

Acetophenone 98-86-2 10,000 11,340 x x

Acrolein 107-02-8 10,000 2,500 100 11,340 x x x

Acrylamide 79-06-1 10,000 2,500 100 11,340 x x x

Acrylic acid 79-10-7 10,000 11,340 x x

Acrylonitrile 107-13-1 10,000 2,500 100 11,340 x x x

Aldrin 309-00-2 50 100 45 x x

Allyl alcohol 107-18-6 10,000 11,340 x x

Allyl chloride 107-05-1 10,000 11,340 x x

Aluminum (fume or dust) 7429-90-5 10,000 11,340 x x

Aluminum oxide (fibrous forms) 1344-28-1 10,000 11,340 x x

Ammonia -- 10,000 11,340 x x

Aniline 62-53-3 10,000 5,000 1,000 11,340 x x x

Anthracene 120-12-7 10,000 11,340 x x

Antimony (and compounds) -- 10,000 11,340 x x

Arsenic (and compounds) -- 50 5 1 11,340 x x x

Asbestos (friable form) 1332-21-4 10,000 5 1 11,340 x x x

Benzene 71-43-2 10,000 5,000 1,000 11,340 x x x

Benzidine 92-87-5 5,000 1,000 11,340 x x

Benzo(a)anthracene 56-55-3 50* 45* x x

Benzo(a)phenanthrene 218-01-9 50* 45* x x

Benzo(a)pyrene 50-32-8 50* 45* x x

Benzo(b)fluoranthene 205-99-2 50* 45* x x

Benzo(g,h,i)perylene 191-24-2 50* 45* x x

Benzo(j)fluoranthene 205-82-3 50* 45* x x

Benzo(k)fluoranthene 207-08-9 50* 45* x x

Benzoyl chloride 98-88-4 10,000 11,340 x x

Benzoyl peroxide 94-36-0 10,000 11,340 x x

Benzyl chloride 100-44-7 10,000 11,340 x x

Biphenyl 92-52-4 10,000 5,000 1,000 11,340 x x x

Bis(chloromethyl) ether 542-88-1 2,500 1,000 11,340 x x

Bisphenol A 80-05-7 10,000 11,340 x x

Boron trifluoride 7637-07-2 10,000 11,340 x x

Bromine 7726-95-6 10,000 11,340 x x

Bromochlorodifluoromethane (Halon 1211) 353-59-3 10,000 5,000 1,000 11,340 x x x

Bromoform 75-25-2 2,500 1,000 11,340 x x

Bromomethane 74-83-9 10,000 5,000 1,000 11,340 x x x
Taking Stock North American Pollutant Releases and Transfers Vol. 14 105

Table A-2. Pollutants Common to at Least Two of the Three North American PRTRs 

Pollutant CAS No. 

NPRI Threshold 

(kilograms/year)

RETC Threshold 

(kilograms/year)

TRI Threshold 

(kilograms/year)

Reporting of 

Pollutant Mandatory 

Manufacture, process, 

or otherwise use 

Manufacture, process, 

or otherwise use Emission 

Manufacture, process, 

or otherwise use NPRI RETC TRI

Bromotrifluoromethane (Halon 1301) 75-63-8 10,000 5,000 1,000 11,340 x x x

Butyl acrylate 141-32-2 10,000 11,340 x x

Butyraldehyde 123-72-8 10,000 11,340 x x

C.I. Acid Green 3 4680-78-8 10,000 11,340 x x

C.I. Basic Green 4 569-64-2 10,000 11,340 x x

C.I. Basic Red 1 989-38-8 10,000 11,340 x x

C.I. DiRETC Blue 218 28407-37-6 10,000 11,340 x x

C.I. Disperse Yellow 3 2832-40-8 10,000 11,340 x x

C.I. Food Red 15 81-88-9 10,000 11,340 x x

C.I. Solvent Orange 7 3118-97-6 10,000 11,340 x x

C.I. Solvent Yellow 14 842-07-9 10,000 11,340 x x

Cadmium (and compounds) -- 5 5 1 11,340 x x x

Calcium cyanamide 156-62-7 10,000 11,340 x x

Carbon disulfide 75-15-0 10,000 11,340 x x

Carbon tetrachloride 56-23-5 10,000 5,000 1,000 11,340 x x x

Carbonyl sulfide 463-58-1 10,000 11,340 x x

Catechol 120-80-9 10,000 11,340 x x

Chlordane 57-74-9 5 100 4.5 x x

Chlorendic acid 115-28-6 10,000 11,340 x x

Chlorine 7782-50-5 10,000 11,340 x x

Chlorine dioxide 10049-04-4 10,000 5,000 100 11,340 x x x

Chloroacetic acid 79-11-8 10,000 11,340 x x

Chlorobenzene 108-90-7 10,000 5,000 1,000 11,340 x x x

Chlorodifluoromethane (HCFC-22) 75-45-6 10,000 5,000 1,000 11,340 x x x

Chloroethane 75-00-3 10,000 11,340 x x

Chloroform 67-66-3 10,000 5,000 1,000 11,340 x x x

Chloromethane 74-87-3 10,000 5,000 1,000 11,340 x x x

Chlorotrifluoromethane (CFC-13) 75-72-9 10,000 5,000 1,000 11,340 x x x

Chromium (and compounds) -- 10,000 5 1 11,340 x x x

Cobalt (and compounds) -- 10,000 11,340 x x

Copper (and compounds) -- 10,000 11,340 x x

Creosote 8001-58-9 10,000 11,340 x x

Cresol (all isomers and their salts) -- 10,000 11,340 x x

Crotonaldehyde 4170-30-3 10,000 11,340 x x

Cumene 98-82-8 10,000 11,340 x x

Cumene hydroperoxide 80-15-9 10,000 11,340 x x

Cyanides -- 10,000 5,000 100 11,340 x x x

Cyclohexane 110-82-7 10,000 11,340 x x

Cyclohexanol 108-93-0 10,000 11,340 x x

Decabromodiphenyl oxide 1163-19-5 10,000 11,340 x x

Di(2-ethylhexyl) phthalate 117-81-7 10,000 11,340 x x

Dibenz(a,j)acridine 224-42-0 50* 45* x x

Dibenzo(a,h)anthracene 53-70-3 50* 45* x x

Dibenzo(a,i)pyrene 189-55-9 50* 45* x x
106 Commission for Environmental Cooperation

Table A-2. Pollutants Common to at Least Two of the Three North American PRTRs 

Pollutant CAS No. 

NPRI Threshold 

(kilograms/year)

RETC Threshold 

(kilograms/year)

TRI Threshold 

(kilograms/year)

Reporting of 

Pollutant Mandatory 

Manufacture, process, 

or otherwise use 

Manufacture, process, 

or otherwise use Emission 

Manufacture, process, 

or otherwise use NPRI RETC TRI

Dibutyl phthalate 84-74-2 10,000 5,000 100 11,340 x x x

Dichlorodifluoromethane (CFC-12) 75-71-8 10,000 5,000 1,000 11,340 x x x

Dichloromethane 75-09-2 10,000 5,000 1,000 11,340 x x x

Dichlorotetrafluoroethane (CFC-114) 76-14-2 10,000 5,000 1,000 11,340 x x x

Dicyclopentadiene 77-73-6 10,000 11,340 x x

Diethanolamine 111-42-2 10,000 11,340 x x

Diethyl sulfate 64-67-5 10,000 11,340 x x

Dimethyl phthalate 131-11-3 10,000 11,340 x x

Dimethyl sulfate 77-78-1 10,000 11,340 x x

Dimethylamine 124-40-3 10,000 11,340 x x

Dinitrotoluene (mixed isomers) 25321-14-6 10,000 11,340 x x

Dioxins and furans -- * * * * x x x

Diphenylamine 122-39-4 10,000 11,340 x x

Epichlorohydrin 106-89-8 10,000 5,000 1,000 11,340 x x x

Ethyl acrylate 140-88-5 10,000 11,340 x x

Ethyl chloroformate 541-41-3 10,000 11,340 x x

Ethylbenzene 100-41-4 10,000 11,340 x x

Ethylene 74-85-1 10,000 11,340 x x

Ethylene glycol 107-21-1 10,000 11,340 x x

Ethylene oxide 75-21-8 10,000 11,340 x x

Ethylene thiourea 96-45-7 10,000 11,340 x x

Fluoranthene 206-44-0 50* 45* x x

Fluorine 7782-41-4 10,000 11,340 x x

Formaldehyde 50-00-0 10,000 5,000 100 11,340 x x x

Formic acid 64-18-6 10,000 11,340 x x

Gamma-hexachlorocyclohexane (lindane) 58-89-9 5 100 11,340 x x

HCFC 124 (and all isomers) -- 10,000 5,000 1,000 11,340 x x x

HCFC-123 (and all isomers) -- 10,000 5,000 1,000 11,340 x x x

Heptachlor 76-44-8 5 100 4.5 x x

Hexachlorobenzene 118-74-1 * * * * x x x

Hexachlorobutadiene 87-68-3 2,500 1,000 11,340 x x

Hexachlorocyclopentadiene 77-47-4 10,000 5,000 1,000 11,340 x x x

Hexachloroethane 67-72-1 10,000 5,000 1,000 11,340 x x x

Hexachlorophene 70-30-4 10,000 11,340 x x

Hydrazine 302-01-2 10,000 5,000 100 11,340 x x x

Hydrochloric acid 7647-01-0 10,000 11,340 x x

Hydrogen cyanide 74-90-8 10,000 11,340 x x

Hydrogen fluoride 7664-39-3 10,000 11,340 x x

Hydrogen sulfide 7783-06-4 10,000 5,000 1,000 x x

Hydroquinone 123-31-9 10,000 11,340 x x

Indeno(1,2,3-c,d)pyrene 193-39-5 50* 45* x x

Iron pentacarbonyl 13463-40-6 10,000 11,340 x x

Isobutyraldehyde 78-84-2 10,000 11,340 x x

Isophorone diisocyanate 4098-71-9 10,000 11,340 x x
Taking Stock North American Pollutant Releases and Transfers Vol. 14 107

Table A-2. Pollutants Common to at Least Two of the Three North American PRTRs 

Pollutant CAS No. 

NPRI Threshold 

(kilograms/year)

RETC Threshold 

(kilograms/year)

TRI Threshold 

(kilograms/year)

Reporting of 

Pollutant Mandatory 

Manufacture, process, 

or otherwise use 

Manufacture, process, 

or otherwise use Emission 

Manufacture, process, 

or otherwise use NPRI RETC TRI

Isopropyl alcohol 67-63-0 10,000 11,340 x x

Isosafrole 120-58-1 10,000 11,340 x x

Lead (and compounds) -- 50 5 1 45 x x x

Lithium carbonate 554-13-2 10,000 11,340 x x

Maleic anhydride 108-31-6 10,000 11,340 x x

Manganese (and compounds) -- 10,000 11,340 x x

Mercury (and compounds) -- 5 5 1 4.5 x x x

Methanol 67-56-1 10,000 11,340 x x

Methoxychlor 72-43-5 50 100 45 x x

Methyl acrylate 96-33-3 10,000 11,340 x x

Methyl iodide 74-88-4 10,000 11,340 x x

Methyl isobutyl ketone 108-10-1 10,000 11,340 x x

Methyl methacrylate 80-62-6 10,000 11,340 x x

Methyl tert-butyl ether 1634-04-4 10,000 11,340 x x

Methylenebis(phenylisocyanate) 101-68-8 10,000 11,340 x x

Michler's ketone 90-94-8 10,000 11,340 x x

Molybdenum trioxide 1313-27-5 10,000 11,340 x x

Monochloropentafluoroethane (CFC-115) 76-15-3 10,000 5,000 1,000 11,340 x x x

Naphthalene 91-20-3 10,000 11,340 x x

n-Butyl alcohol 71-36-3 10,000 11,340 x x

n-Hexane 110-54-3 10,000 11,340 x x

Nickel (and compounds) -- 10,000 5 1 11,340 x x x

Nitric acid and nitrate compounds -- 10,000 11,340 x x

Nitrilotriacetic acid 139-13-9 10,000 11,340 x x

Nitrobenzene 98-95-3 10,000 11,340 x x

Nitroglycerin 55-63-0 10,000 11,340 x x

N-methyl-2-pyrrolidone 872-50-4 10,000 11,340 x x

N-methylolacrylamide 924-42-5 10,000 11,340 x x

N,N-dimethylaniline 121-69-7 10,000 11,340 x x

N,N-dimethylformamide 68-12-2 10,000 11,340 x x

N-nitrosodimethylamine 62-75-9 2,500 100 11,340 x x

N-nitrosodiphenylamine 86-30-6 10,000 11,340 x x

Paraldehyde 123-63-7 10,000 11,340 x x

Parathion methyl 298-00-0 5 100 11,340 x x

PCBs (polychlorinated biphenyls) 1336-36-3 5 4.5 x x

Pentachloroethane 76-01-7 10,000 11,340 x x

Pentachlorophenol 87-86-5 2,500 1,000 11,340 x x

Peracetic acid 79-21-0 10,000 11,340 x x

Phenanthrene 85-01-8 50* 11,340 x x

Phenol 108-95-2 10,000 5,000 1,000 11,340 x x x

Phosgene 75-44-5 10,000 11,340 x x

Phosphorus (yellow or white) 7723-14-0 10,000 11,340 x x

Phthalic anhydride 85-44-9 10,000 11,340 x x

p-Nitroaniline 100-01-6 10,000 11,340 x x
108 Commission for Environmental Cooperation

Table A-2. Pollutants Common to at Least Two of the Three North American PRTRs 

Pollutant CAS No. 

NPRI Threshold 

(kilograms/year)

RETC Threshold 

(kilograms/year)

TRI Threshold 

(kilograms/year)

Reporting of 

Pollutant Mandatory 

Manufacture, process, 

or otherwise use 

Manufacture, process, 

or otherwise use Emission 

Manufacture, process, 

or otherwise use NPRI RETC TRI

P-Nitrobiphenyl 92-93-3 2,500 1,000 11,340 x x

Polychlorinated alkanes (C10-C13) -- 10,000 11,340 x x

Polymeric diphenylmethane diisocyanate 9016-87-9 10,000 11,340 x x

Potassium bromate 7758-01-2 10,000 11,340 x x

p-Phenylenediamine 106-50-3 10,000 11,340 x x

Propargyl alcohol 107-19-7 10,000 11,340 x x

Propionaldehyde 123-38-6 10,000 11,340 x x

Propylene 115-07-1 10,000 11,340 x x

Propylene oxide 75-56-9 10,000 11,340 x x

Pyridine 110-86-1 10,000 5,000 1,000 11,340 x x x

Quinoline 91-22-5 10,000 11,340 x x

Quinone 106-51-4 10,000 11,340 x x

Safrole 94-59-7 10,000 11,340 x x

sec-Butyl alcohol 78-92-2 10,000 11,340 x x

Selenium (and compounds) -- 10,000 11,340 x x

Silver (and compounds) -- 10,000 11,340 x x

Sodium nitrite 7632-00-0 10,000 11,340 x x

Styrene 100-42-5 10,000 5,000 1,000 11,340 x x x

Styrene oxide 96-09-3 10,000 11,340 x x

Sulfur hexafluoride 2551-62-4 10,000 5,000 x x

Sulfuric acid 7664-93-9 10,000 11,340 x x

tert-Butyl alcohol 75-65-0 10,000 11,340 x x

Tetrachloroethylene 127-18-4 10,000 11,340 x x

Tetracycline hydrochloride 64-75-5 10,000 11,340 x x

Thiourea 62-56-6 10,000 11,340 x x

Thorium dioxide 1314-20-1 10,000 11,340 x x

Titanium tetrachloride 7550-45-0 10,000 11,340 x x

Toluene 108-88-3 10,000 11,340 x x

Toluene-2,4-diisocyanate 584-84-9 10,000 11,340 x x

Toluene-2,6-diisocyanate 91-08-7 10,000 11,340 x x

Toluenediisocyanate (mixed isomers) 26471-62-5 10,000 5,000 1,000 11,340 x x x

Toxaphene 8001-35-2 5 100 4.5 x x

Trichloroethylene 79-01-6 10,000 5,000 1,000 11,340 x x x

Trichlorofluoromethane (CFC-11) 75-69-4 10,000 5,000 1,000 11,340 x x x

Triethylamine 121-44-8 10,000 11,340 x x

Vanadium (and compounds) -- 10,000 11,340 x x

Vinyl acetate 108-05-4 10,000 11,340 x x

Vinyl chloride 75-01-4 10,000 5,000 1,000 11,340 x x x

Vinylidene chloride 75-35-4 10,000 11,340 x x

Warfarin 81-81-2 5 100 11,340 x x

Xylene (all isomers) -- 10,000 11,340 x x

Zinc (and compounds) -- 10,000 11,340 x x

* See national PRTR websites for details.
Taking Stock North American Pollutant Releases and Transfers Vol. 14 109

Appendix 3

Top Pollutants Released or Transferred by North American Facilities, 2005–2010

Table A-3. Top Pollutants Released or Transferred by North American Facilities, 2005–2010

Pollutant

Total Releases and Transfers On-site Releases*

Off-site Releases 

to Disposal Total Transfers**

2005 (kg) 2010 (kg)

% Change 

2005–2010 2010 (kg)

% Change 

2005–2010 2010 (kg)

% Change 

2005–2010 2010 (kg)

% Change 

2005–2010 

Zinc (and compounds) (CA, US) 641,233,326 728,410,100 14 359,657,700 32 78,427,592 -42 290,216,625 25

Hydrogen Sulfide (CA, MX) 549,418,432 632,563,242 15 152,867,297 -49 479,650,431 91 41,241 13

Lead (and compounds) (CA, MX, US) 454,007,439 467,277,324 3 278,044,395 37 16,424,428 -72 172,808,501 -10

Copper (and compounds) (CA, US) 423,077,058 414,654,953 -2 130,518,101 73 12,715,615 5 271,417,257 -19

Nitric Acid/Nitrate Compounds 

(CA, US) 282,522,125 261,770,018 -7 186,440,364 -2 6,194,076 -40 69,133,880 -15

Hydrochloric Acid (CA, US) 278,784,924 106,476,066 -62 100,709,277 -62 618,974 25 5,141,870 -61

Methanol (CA, US) 235,980,973 181,871,475 -23 82,718,244 -23 8,602,919 42 90,392,584 -26

Manganese (and compounds)

(CA, US) 201,483,436 520,948,260 159 390,269,583 424 36,360,643 -16 94,295,640 13

Ammonia, Total (CA, US) 168,634,168 166,025,660 -2 146,010,710 -3 5,197,391 1 14,800,877 17

Sulfuric Acid (CA, US) 167,319,200 137,997,148 -18 61,167,004 -26 1,751,106 -80 75,047,148 0

Toluene (CA, US) 117,578,961 81,953,570 -30 19,487,839 -36 1,374,087 -6 60,925,295 -29

Barium (and compounds) (US) 111,095,302 123,588,149 11 96,004,623 15 26,770,845 2 812,681 -38

Chromium (and compounds)

(CA, MX, US) 105,716,301 132,763,501 26 37,497,942 138 12,814,868 -20 82,440,520 11

Xylenes (CA, US) 94,385,816 93,634,927 -1 13,960,096 -38 1,034,846 -6 78,607,070 11

Nickel (and compounds)

(CA, MX, US) 94,384,820 124,507,807 32 48,832,141 310 9,371,894 9 66,300,180 -10

Arsenic (and compounds)

(CA, MX, US) 93,957,936 121,258,405 29 118,589,939 42 1,862,287 -81 806,179 -14

Ethylene Glycol (CA, US) 64,959,022 59,641,334 -8 9,161,085 50 1,753,120 96 48,724,668 -16

Hydrogen Fluoride (CA, US) 40,908,356 26,139,364 -36 23,303,486 -39 518,487 128 2,317,386 -4

n-Hexane (CA, US) 38,793,968 33,702,311 -13 22,426,054 2 1,513,498 1,431 9,756,412 -42

Styrene (CA, MX, US) 38,442,671 19,915,865 -48 12,172,663 -54 1,113,266 -15 6,545,668 -39

Aluminum (fume or dust) (CA, US) 37,112,781 19,769,397 -47 5,462,040 -24 3,962,937 -77 10,316,986 -19

Vanadium (and compounds)

(CA, US) 33,748,986 44,374,086 31 30,941,836 35 6,344,130 58 7,087,561 3

Dichloromethane (CA, MX, US) 31,275,542 13,317,896 -57 2,302,892 -29 152,119 11 10,861,007 -61

Phosphorous, Total (CA) 27,390,800 183,372,769 569 166,700,954 1,300 11,744,136 24 4,855,008 -20

Ethylene (CA, US) 24,197,018 22,737,718 -6 8,103,171 -28 24 -73 14,634,484 13

Certain Glycol Ethers (US) 21,407,701 16,253,775 -24 5,992,423 -33 759,793 -27 9,501,559 -17

n-Butyl Alcohol (CA, US) 20,177,537 12,452,743 -38 5,417,250 -38 121,980 257 6,912,065 -39

N-Methyl-2-Pyrrolidone (CA) 18,031,259 16,278,572 -10 2,047,373 -10 771,672 131 13,387,425 -13

Methyl Isobutyl Ketone (CA, US) 16,865,069 9,627,080 -43 1,873,483 -53 67,826 -4 7,682,767 -40

Acetonitrile (CA, US) 16,821,993 15,922,337 -5 8,848,026 9 32,921 155 7,040,715 -19

Total Reduced Sulfur (TRS) (CA) -- 270,113,955 170† 96,958,553 32† 173,146,179 551† 6,902 39†

Total, Top 31 Pollutants 4,449,712,921 5,059,319,809 16 2,624,486,544 22 901,174,092 43 1,532,818,160 -8

Total, All Pollutants 4,833,498,433 5,530,710,253 14 2,879,335,208 24 930,493,737 42 1,719,727,915 -8

%, Top 31 Pollutants, of All Pollutants 92 91 91 97 89

*Sum of On-site Releases to Air, Water, Land, and Underground Injection. **Sum of Transfers to Recycling and Other Transfers.

†

 Percent change calculated from 2007 (first year of TRS reporting in Canada).

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.
110 Commission for Environmental Cooperation

Appendix 4

Top Reporting Sectors in North America, 2005–2010

Table A-4. Top Reporting Sectors in North America, 2005–2010

Industry Sector

NAICS-4 

Code

Total Releases 

and Transfers 

2005 (kg)

Total Releases 

and Transfers 

2006 (kg)

Total Releases 

and Transfers 

2007 (kg)

Total Releases 

and Transfers 

2008 (kg)

Total Releases 

and Transfers 

2009 (kg)

Total Releases 

and Transfers 

2010 (kg)

% Change 

2005–2010

Metal Ore Mining 2122 579,082,564 959,468,670 891,780,223 963,602,162 946,806,807 1,209,414,482 109

Electric Power Generation, Transmission, Distribution 2211 527,061,796 507,666,843 502,207,870 455,438,263 369,374,147 352,112,292 -33

Basic Chemical Manufacturing 3251 350,468,597 358,451,753 331,395,331 316,779,254 269,178,727 291,320,541 -17

Iron and Steel Mills and Ferroalloy Manufacturing 3311 312,281,935 326,250,943 335,333,978 324,699,283 234,061,306 307,514,746 -2

Oil and Gas Extraction 2111 299,959,066 352,648,093 425,045,364 519,514,573 521,838,245 975,143,329 225

Support Activities for Mining and Oil and Gas Extraction 2131 275,449,433 291,148,385 350,015,825 436,929,233 430,632,041 1,704,958 -99

Nonferrous Metal (except Aluminum) Product/Processing 3314 264,792,816 354,836,292 317,299,626 315,491,899 274,146,732 362,220,896 37

Waste Treatment and Disposal 5622 228,270,716 213,420,808 212,877,357 198,627,485 169,597,797 198,450,011 -13

Pulp, Paper, and Paperboard Mills 3221 144,571,800 137,973,131 133,797,656 127,707,178 119,378,035 124,141,452 -14

Water, Sewage and Other Systems 2213 129,606,665 126,646,951 130,512,863 137,716,716 132,559,661 131,651,071 2

Petroleum and Coal Products Manufacturing 3241 122,938,595 182,615,184 207,026,327 173,018,676 167,453,335 116,358,264 -5

Other Electrical Equipment/Component Manufacturing 3359 122,452,169 114,987,627 141,390,477 129,183,266 102,324,610 93,254,407 -24

Resin, Synthetic Rubber, Artificial Synthetic Fibers Mfg 3252 120,724,754 119,875,869 112,839,715 97,004,435 83,622,391 89,902,761 -26

Motor Vehicle Parts Manufacturing 3363 106,248,184 97,337,168 94,787,662 68,104,136 48,490,034 57,798,205 -46

Other Fabricated Metal Product Manufacturing 3329 95,730,498 89,333,824 71,248,549 69,230,151 54,314,912 59,522,147 -38

Pharmaceutical and Medicine Manufacturing 3254 88,424,517 71,287,337 61,227,976 49,624,927 43,958,251 44,115,336 -50

Steel Product Manufacturing from Purchased Steel 3312 72,027,290 84,274,730 68,703,611 59,678,512 40,817,553 46,045,099 -36

Pesticide, Fertilizer, Other Agricultural Chemical Mfg 3253 65,676,743 65,243,321 63,225,303 62,711,422 74,201,666 73,861,639 12

Coating, Engraving, Heat Treating, and Allied Activities 3328 58,030,203 56,579,812 54,093,324 56,789,219 48,562,023 38,182,911 -34

Forging and Stamping 3321 55,259,683 53,212,057 49,883,154 44,402,399 31,003,868 33,548,650 -39

Alumina and Aluminum Production and Processing 3313 53,468,689 58,790,872 47,046,778 35,937,612 26,438,091 30,087,047 -44

Foundries 3315 53,394,266 50,918,368 58,191,323 61,708,817 62,220,715 40,952,586 -23

Plastics Product Manufacturing 3261 52,246,929 48,176,705 46,002,835 43,499,883 31,852,148 48,149,766 -8

Other Chemical Product and Preparation Manufacturing 3259 44,850,740 46,150,913 45,345,418 40,657,296 32,752,590 32,727,558 -27

Motor Vehicle Manufacturing 3361 43,193,482 41,933,296 42,604,437 31,105,034 23,055,939 22,529,193 -48

Animal Slaughtering and Processing 3116 40,590,751 38,638,546 37,285,399 42,142,895 37,528,091 34,099,903 -16

Paint, Coating, and Adhesive Manufacturing 3255 39,067,257 39,456,209 33,078,507 27,783,805 22,378,428 22,508,492 -42

Semiconductor/Other Electronic Component Mfg 3344 34,190,962 32,216,401 27,239,386 26,471,328 19,961,990 22,560,601 -34

Grain and Oilseed Milling 3112 23,552,436 22,589,298 24,188,769 21,593,022 19,936,169 24,065,602 2

Machine Shops; Turned Product; Screw, Nut, & Bolt Mfg 3327 21,950,937 25,635,327 25,264,048 25,530,666 18,453,344 21,860,876 0

Total, Top 30 Sectors 4,425,564,475 4,967,764,733 4,940,939,092 4,962,683,547 4,456,899,646 4,905,804,822 11

Total, All Sectors 4,833,498,433 5,458,622,690 5,439,460,679 5,392,090,187 4,829,435,749 5,530,710,253 14

%, Top 30 Sectors, of All Sectors 92 91 91 92 92 89

Note: Differences among the three countries in PRTR reporting requirements affect the North American picture of industrial pollution.
Taking Stock North American Pollutant Releases and Transfers Vol. 14 111

Information about the typical industrial uses or production 

of some of the pollutants mentioned in this report, as well 

as their chemical properties and potential to cause harm, is 

provided below. Readers are reminded that PRTR data alone 

cannot provide enough information to assess the potential 

harm from a pollutant; however, the data in combination 

with other information about a pollutant can serve as a 

starting point for learning more about its potential impacts. 

Readers may wish to consult other sources, including those 

used as a basis for the information below: ToxFAQs, developed by the US Agency for Toxic Substances and Disease 

Registry (ATSDR), and New Jersey’s Right-to-Know Hazardous Substance Fact Sheets.

Arsenic is a naturally occurring metal found in the environment, especially as an impurity in metal ores. Arsenic compounds are commonly used to preserve wood; as metal alloys; 

and in pesticides. Humans may be exposed to this substance 

by ingesting small amounts in food and water, or breathing 

sawdust or smoke from wood treated with arsenic. Exposure 

may also result from work involving arsenic (e.g., copper or 

lead smelting, wood treating, pesticide application). Breathing high levels of arsenic can irritate the throat and lungs, 

while exposure to lower levels may cause nausea and damage 

to blood vessels. Arsenic in drinking water can cause bladder, 

lung, skin, kidney and liver cancer, and ingesting very high 

levels can result in death. There is evidence that long-term 

exposure to arsenic in children may result in lower IQ scores, 

and that exposure to arsenic in the womb and early childhood 

may increase mortality in young adults. 

Cadmium is a natural element found in the earth’s crust, 

usually in combination with other elements such as oxygen, 

chlorine, or sulfur. Most cadmium is extracted during the 

production of other metals such as zinc, lead, and copper. 

Cadmium does not corrode easily and has many uses, in 

batteries, pigments, metal coatings, and plastics. Cadmium 

enters the environment from mining, certain industrial processes, fuel combustion, and disposal of household wastes. 

It does not break down in the environment, but can change 

forms, and cadmium particles in air can travel long distances 

before being deposited. Some forms of cadmium dissolve 

in water, and cadmium binds to soil particles. Fish, plants, 

and animals take up cadmium from the environment and 

thus, people can be exposed to this pollutant by eating foods 

containing cadmium. Exposure can occur through breathing contaminated workplace air, or drinking contaminated 

water. Exposure to cadmium in air, food, or water can lead 

to damage of the lungs, digestive system, and kidneys. 

Lead is a naturally occurring metal which does not break 

down, but can be transformed by sunlight, air and water. 

Activities such as mining and manufacturing, burning fossil 

fuels, and disposal of lead-containing material can release 

lead into the environment. Lead is found in vehicle batteries, pigments, plastics, glass, electronics, and jewelry and 

pottery. It is also used to shield X-rays, and in insecticides, 

rodenticides and ointments. Human exposure can occur 

through eating food or drinking water that contains lead, 

or from inhaling lead released from leaded paint in older 

homes. Water pipes in older homes may contain lead solder 

that leach lead into the water. Inorganic lead is considered 

a probable carcinogen and developmental or reproductive 

toxicant, and exposure to even small amounts can affect 

almost every organ in the body, especially the nervous 

system. High levels of exposure to lead during pregnancy 

may cause miscarriage, growth defects and mental impairment in offspring. Low levels of exposure can affect a child’s 

development and because it is a PBT, lead is stored in the 

bones and accumulates over time. 

Mercury is a naturally occurring metal that takes several 

forms. Metallic mercury is a shiny liquid that becomes a 

gas when heated. Mercury combines with other elements 

to form inorganic mercury compounds, and with carbon to 

make organic mercury compounds, including methylmercury. Mercury is used in thermometers, dental fillings and 

batteries. Anthropogenic sources of exposure are emissions 

from coal-fired power plants, mining, smelters, cement 

plants and the disposal of products containing mercury. 

The nervous system is very sensitive to all forms of mercury. 

Methylmercury and metallic mercury vapors are the most 

harmful, because more mercury in these forms reaches 

the brain. Exposure to high levels of mercury can permanently damage the brain, kidneys and the developing fetus, 

and very young children are especially sensitive. Mercury 

transported over long distances through the atmosphere 

is deposited in soils and in water. Because it is a PBT and 

bioaccumulates in fish, humans can be exposed when they 

consume fish, shellfish and marine mammals. 

Hexachlorobenzene is a fungicide whose production and 

use are now prohibited internationally under the Stockholm Convention and the Protocol on Persistent Organic 

Appendix 5

Selected Pollutants: Industrial Sources, Uses and Chemical Properties
112 Commission for Environmental Cooperation

Pollutants, under the United Nations’ Convention on 

Long-Range Transboundary Air Pollution (LRTAP). However, small amounts are emitted as a result of its formation as a waste product during the manufacture of other 

chemicals, and through its release during combustion. 

This pollutant is very slow to break down in air and is subject to long-range transport in the atmosphere. It does not 

dissolve easily in water, but binds to sediments and settles 

to the bottom. It has a strong tendency to bioaccumulate 

in animals that live in hexachlorobenzene-contaminated 

water. Brief exposure to very high levels of hexachlorobenzene may cause effects on the nervous system such as 

weakness and convulsions; skin sores; and liver and thyroid effects. Long-term exposure can cause damage to the 

liver and reproductive system and can cause developmental effects. Hexachlorobenzene is also considered to be a 

human carcinogen.

Chromium is a naturally occurring element found in liquid, 

solid and gas forms. It can change form easily in water and 

soil. The most common forms are chromium(0), the metal, 

as well as chromium(III) and chromium(VI). The metal is 

used in making steel. Chromium(VI), also known as hexavalent chromium, and chromium(III) are used in chrome plating, dyes, leather tanning and wood preserving. Exposure to 

chromium can occur through eating food containing chromium(III), breathing contaminated air (e.g., during the manufacture of chrome-based products), skin contact, drinking 

contaminated well water, or living near uncontrolled waste 

sites containing chromium or near industries that use chromium. The hazards associated with chromium depend on its 

form. Breathing high levels of chromium(VI) can cause problems such as asthma and damage to the male reproductive 

system. Chromium(VI) compounds are also known carcinogens and inhalation has been linked with lung cancer. 
Taking Stock North American Pollutant Releases and Transfers Vol. 14 113

Volatile Organic Compounds (VOCs) are a category of 

organic compounds that exist as gases at room temperature (e.g., solvent vapors). VOCs react with nitrogen oxides 

(NOx

) to form ground-level ozone, the major component 

of smog and a severe lung irritant. Methanol is one of the 

VOCs emitted in largest proportions during pulp and paper 

manufacturing (as an inadvertent by-product of wood pulping, chemical recovery, and pulp bleaching). It is a suspected 

developmental toxicant, neurotoxin, and a gastrointestinal 

or liver toxicant. Other VOCs resulting from pulp and paper 

manufacturing include acetaldehyde, propionaldehyde, 

methyl ethyl ketone, phenols, and terpenes.

Reduced Sulfur Compounds (e.g., hydrogen sulfide, carbonyl sulfide) are associated with the distinct rotten egg 

odor associated with some kraft pulp mills. Exposure to 

reduced sulfur emissions has been linked to symptoms that 

include headaches, watery eyes, nasal problems and breathing difficulties. 

Chlorinated Compounds include chlorine dioxide and 

sodium hypochlorite, which are chlorine-based chemicals 

commonly used for bleaching pulp. Chlorine dioxide has 

the potential to be a severe acute and long-term respiratory 

irritant, and can lead to death at high-level exposures. 

Dioxins and Furans are incidentally produced during the 

chlorination stage of bleaching pulp, especially when this 

involves elemental chlorine (Cl2

), and this discovery led to 

the phase-out of the use of elemental chlorine for bleaching in North American chemical pulp mills. Dioxins and 

furans are a group of PBTs. They are known human carcinogens and can cause immune system suppression and 

reproductive failure. In areas where pulp mills use wood 

from logs transported in salt water, combustion of wood 

residuals (called “salty hog fuel”) can lead to low levels of 

dioxins released to the air.

Chloroform may be formed by the use of chlorine-based 

compounds for bleaching in pulp and paper manufacturing. 

It is a human carcinogen and suspected respiratory, cardiovascular, liver and kidney toxicant, and endocrine disruptor. 

Total Suspended Solids (TSS) is a measure of solid material suspended in mill effluent, which material, if present in 

high amounts, can adversely affect bottom-living organisms 

upon settling in receiving waters.

Nitrogen Compounds (e.g., nitrates, nitrites, ammonia) 

and Phosphorus are added during the wastewater treatment 

process to help remove dissolved organic material from 

the effluent. In excess amounts, nitrogen and phosphorus 

can have adverse effects on the quality of receiving waters, 

by causing increases in aquatic plant growth and areas of 

depleted oxygen (called “dead zones”). Ammonia is also a 

precursor to fine particulate formation, and a lung irritant. 

Biochemical Oxygen Demand (BOD) is the amount of 

dissolved oxygen that is needed by the organisms living in 

water to break down organic material. It is affected by discharges of waste matter and is often used as an indicator of 

water quality. 

Criteria Air Contaminants (CACs) are typically released 

from the combustion of fuel (often fossil-based, such as coal, 

oil and natural gas) for generation of energy used during 

pulp and paper manufacturing. Due to differences among 

the three countries in PRTR reporting requirements, data 

on releases of CAC are not included in this report. Common 

CACs include the following:

•	 Carbon monoxide is produced by incomplete combustion of fossil fuels. Acute exposure to this air 

pollutant can lead to death, and high levels in the 

atmosphere can harm vegetation. 

•	 Nitrogen oxides (NOx

) are products of the combustion of fuels. They combine with volatile organic 

compounds and sunlight in the lower atmosphere to 

form ozone, a key component of smog. In moist air, 

nitrogen oxides can also form nitric acid, which is 

precipitated as a component of acid rain. NO2

 is also 

an acute respiratory irritant. 

•	 Particulates are small particles that are dispersed 

into the atmosphere from combustion. They can be 

fine or coarse, and be composed of wood ash or of 

chemical compounds created from carbon, metallic 

oxides and salts, acids, oils, lime, etc. The greatest 

health impact is felt from the particulate matter 

(PM) in the smallest size category—PM 2.5—which 

penetrates the lungs. Fine particulates are linked to 

serious health impacts, including chronic bronchitis, 

asthma, and premature deaths.

•	 Sulfur dioxide (SO2

) is a chemical compound produced 

from the combustion of fuel containing sulfur (e.g., oil, 

coal). Sulfur dioxide can cause haze and acid rain, which 

contributes to the acidification of lakes and streams, 

damage to forests, corrosion of buildings and machinery, 

and poor air quality, which in turn causes respiratory 

problems such as asthma and bronchitis.

Greenhouse Gases (GHGs), such as carbon dioxide (CO2

), 

contribute to climate change and are typically released by 

this pulp and paper mill sector, mainly from the boilers that 

generate energy. GHG emissions data are excluded from this 

report, due to differences in national PRTR reporting requirements for these pollutants. 
114 Commission for Environmental Cooperation
Taking Stock North American Pollutant Releases and Transfers Vol. 14 115

A. Environmental Management

The questions in this section focus on facilities’ environmental management activities from 2005 through 2010. 

1. Does your company have a stated environmental policy?

Yes If yes, is this information available to the public? Yes No 

No 

Do not know 

2. Does your facility have an environmental management system (EMS)?

Yes (e.g., ISO 14001, other) If yes, please specify: 

No 

Do not know 

3. From 2005–2010, did your facility implement changes with the objective of preventing or reducing pollution? 

Yes No Do not know (If you answered “no” or “do not know”, please go to question #6).

If yes, please check any of the following actions taken and indicate the year (or period) in which they were implemented:

Installation of pollution control equipment Year(s): ____

Implementation of new processing technology Year(s): ____

Renovation of existing technology Year(s): ____

Substitution or reformulation of raw materials Year(s): ____

Fuel substitution Year(s): ____

Recycling Year(s): ____

Improvement in energy efficiency Year(s): ____

Replacement of electricity generation or steam with external source Year(s): ____

Other (please specify): Year(s): ____

Appendix 6

Questionnaire Survey for Pulp, Paper and Paperboard Mills
116 Commission for Environmental Cooperation

4. If you answered yes to question #3, were these actions taken to address one or more of the following environmental 

issues? Please check all that apply and if possible, describe briefly:

Emissions to air of criteria air contaminants

Emissions to air of other hazardous or toxic substances

Emissions of greenhouse gases 

Discharges to water of toxic substances 

Discharges to water of other substances

Management of solid waste

Management of hazardous waste

Other

5. If you answered yes to question #3, what was(were) the main driver(s) in the decision to make this(these) 

change(s) at the facility? 

Community relations 

Compliance with local, federal or international regulations. If possible, please provide name(s):

Corporate commitment to the environment

Environmental management system 

Price of raw materials 

Access to international markets

Client demand

Modernization of the facility

Other economic benefit (e.g., waste minimization) Please specify:

Specific incentive programs (e.g., energy efficiency program). If possible, please provide name(s):

Other (please describe briefly) 

Do not know 

6. To your knowledge, did your facility’s reported pollutant releases to air decrease from 2005–2010?

Yes No Do not know

If yes, was this decrease due to any of the following factors that are not part of a pollution prevention strategy? (please check 

all that apply):

Changes in emission factors used, sampling or calculation methodology, or correction of past estimation errors

Changes in PRTR guidance or regulations 

A decrease in production at the facility 

Other reason NOT related to a specific pollution prevention strategy (please specify):

Do not know
Taking Stock North American Pollutant Releases and Transfers Vol. 14 117

7. To your knowledge, did your facility’s reported pollutant releases to water decrease from 2005–2010?

Yes No Do not know

If yes, was this decrease due to any of the following factors that are not part of a pollution prevention strategy? (please check 

all that apply):

Changes in emission factors used, sampling or calculation methodology, or correction of past estimation errors

Changes in PRTR guidance or regulations 

A decrease in production at the facility 

Other reason NOT related to a specific pollution prevention strategy (please specify):

Do not know

8. To your knowledge, how are your facility’s reported PRTR data used? (Check all that apply):

To inform or measure progress in your facility’s (or company’s) environmental objectives? (e.g., performance indicators) 

To comply with facility permitting requirements? 

To communicate with stakeholders and/or the public? 

Other (please describe briefly): 

Do not know

9. When reporting your facility’s PRTR data, how are your facility’s releases and transfers quantified? (Check all that apply):

Direct measurement (e.g., monitoring)

Engineering calculation or estimation

Mass balance calculation

Emission Factors 

Other (please describe)

Do not know

10. To your knowledge, how does your facility verify the accuracy of the PRTR data reported?

Do not know
118 Commission for Environmental Cooperation

A. Company, Facility, and Job Position Characteristics Please help us to validate and complete the following information:

1. Please provide the full name and address of your facility (i.e., buildings that are on a contiguous site and under 

common control by a company): 

Name of facility

Street name/number 

City 

State/province/territory 

Postal code 

Facility PRTR (NPRI, TRI or RETC) ID:

2. If you have a parent company, please provide its full name and location below:

Name of parent company

City 

State 

Country 

3. Description of your facility’s activities:

Industry sector name:

North American Industry Classification Sector (NAICS) code(s):

Year in which your facility started operations: 

4. Please provide the following information:

Raw materials used (e.g., solid wood, wood chips, recycled fiber) – please specify:

Process (e.g., Kraft, mechanical pulping, de-inking, other) – please specify:

Fuel used (boiler) – please specify:

Air pollution control technologies (e.g., scrubbers, cyclones, bag houses) – please describe briefly: 

Raw water treatment – please describe briefly: 

Waste treatment (e.g., incinerators, sewage treatment, on- or off-site landfills, recycling) – please describe briefly:

Other (please describe briefly):
Taking Stock North American Pollutant Releases and Transfers Vol. 14 119

5. Which of the following most closely reflects your job title? (Check only one):

Environmental/EHS manager or specialist

Regulatory compliance specialist

Plant manager

Human resources manager or specialist

Consultant

Other (please specify):

6. How many years have you held this job within the facility? 

7. To what extent is your work related to PRTR reporting?

A great deal (50% or more) 

Some (20 % - 49%) 

A little (0% - 19%)

8. Including yourself, about how many full-time equivalent employees work at your facility? 

9. Please provide any additional comments about PRTR reporting, or environmental management challenges at 

your facility that you would like us to know. 

10. In the next Taking Stock report, the CEC will make general reference to information about facilities’ processes 

or environmental management practices obtained via this survey. In the event that your facility’s environmental sustainability efforts could be used as an example of best practices, do you give the CEC permission to 

name your facility in the report? YES NO 

We greatly appreciate your taking the time to respond to this questionnaire. Your participation in this survey will help to 

make our effort a success.
120 Commission for Environmental Cooperation

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Commission for Environmental Cooperation

393, rue St-Jacques Ouest, bureau 200

Montreal (Quebec) 

H2Y 1N9 Canada 

t 514.350.4300 f 514.350.4314

info@cec.org / www.cec.org