National Pollutant Release Inventory Submittal Form
- Proposal for a Modification to the NPRI -

Please complete this form to propose a modification to the National Pollutant Release Inventory (NPRI) and forward to :

Attention: Co-ordinator for Proposals for Modifications (NPRI)
Consulatations and Outreach
The National Pollutant Release Inventory
Environment Canada
9th floor, Place Vincent Massey
351 St. Joseph Blvd.
Hull, Quebec,
K1A 0H3
telephone: (819) 953-1656
fax: (819) 994-3266
e-mail: npri@ec.gc.ca

- Section 1 -

Name of contact: Peter Wong

Company Name: Pilot Working Group of Environment Canada and the Ontario Ministry of Environment (MOE) On the Harmonization of the National Pollutant Release Iventory (NPRI) and the Ontario Airborne Contaminants Dsicharge Reporting and Monitoring Regulation (O.Reg. 127/01)

Address: 125 Resources Road, East Wing
City: Etobicoke
Prov/Terr: On
Postal code: M9P 3V6
Telephone: (416)235-6130
Fax:
E-mail: peter.wong@ene.gov.on.ca

Please indicate the details of the proposal:

Proposed timing for the Change (proposed year for implementation): 2006 reporting year

Industry Sectors to be affected by the change:

Estimate on the number of facilities from following industrial sectors in Canada which meet the reporting thresholds and will be affected by the change.

Proposals for specific industry exemptions or targets (ex. In the case of SOPs a reporting requirement may be intended for a specific industry sector):

- Section 2 -

* This section must be completed for proposals for the addition or deletion of NPRI substances.

Decision Factors¹

1. Does the substance meet the NPRI criteria, that is:

1. Is the substance manufactured, processed or otherwise used (M,P,O)² in Canada ?
2. Is the substance of health and/or environmental concern?
3. Is the substance released to the Canadian environment?
4. Is the substance present in the Canadian environment?

Ethyl acetate meets the original NPRI criteria, that is:

1. The substance that is manufactured, processed or otherwise used (MPO) in Canada with 3 tonnes threshold MPO critieria.
2. Ontario Point of Impingement standard is 19,000 μg/m³, and
   Ontario Ambient Air Quality Criteria is 19,000 μg/m³ for 1 hr basis

Ethyl Acetate is of special concern because of its health effects.

Vapour irritates eyes. nose and throat.
Inhalation causes headache, dizziness, nausea, or loss of consciousness.
Liquid is irritating to skin and eyes.
Threshold limit value - 400 ppm.
Short term inhalation limits - 1000 ppm for 15 min.
Toxicity by ingestion - grade 2, LD = 0.5 to 5 g/kg

Inhalation can cause severe irritation of mucous membranes and upper respiratory tract. Symptoms may include burning sensation, coughing, wheezing, laryngitis, shortness of breath, headache, nausea and vomiting. High concentrations may cause lung damage. An irritant to the nose, throat, and upper respiratory tract. Exposure to high concentrations have a narcotic effect and may cause liver and kidney damage. Chronic overexposure may cause anemia with leukocytosis (transient increase in the white blood cell count) and damage to the liver and kidneys. Persons with pre-existing skin disorders or eye problems, or impaired liver, kidney or respiratory function may be more susceptible to the effects of the substance. (source: http://www.jtbaker.com/msds/englishhtml/e2850.htm)

Ethyl acetate is under the following U.S. Federal Regulatory Program Lists:

• Air Contaminants (Occupational and Safety Health Act)
• Hazardous Substances (Superfund)
• Registered Pesticides (Federal Insecticide, Fungicide, and Rodenticide Act) (source: http://www.scorecard.org/chemical-profiles/summary.tcl?edf_substance_id=141%2d78%2d6)

Other lists include:

• IPCS International Chemical Safety Card
• International Toxicity Estimates for Risk (ITER) from Toxicology Excellence for Risk Assessment
• U.S. National Institute for Occupational Safety and Health Pocket Guide to Chemical Hazards
• OSHA (source: http://www.scorecard.org/chemical-profiles/summary.tcl?edf_substance_id=141%2d78%2d6)

The occupatoinal exposure limits are as following:

• TLV: 400 ppm as TWA; (ACGIH 2004).
• MAK: 400 ppm, 1500 mg/m³; Peak limitation category: I(2); Pregnancy risk group: C; (DFG 2004).

The substance can be absorbed into the body by inhalation of its vapour. A harmful contamination of the air can be reached rather quickly on evaporation of this substance at 20°C. Exposure far above the OEL may result in death. (source: http://www.inchem.org/documents/icsc/icsc/eics0367.htm)

More detailed exposure limits can be seen at: http://www.osha.gov/SLTC/healthguidelines/ethylacetate/recognition.html

This substance is not listed as a carcinogen by ACGIH, IARC, or NTP. (http://www.catalogue.fisher.co.uk/scripts/search.dll?ViewMSDS&SheetNumber=08750)

There are not expected to have any environmental concerns. (source: http://www.jtbaker.com/msds/englishhtml/e2850.htm) But Ethyl acetate evaporates to a gas if released as a liquid. Ethyl acetate is a volatile organic chemical (VOC) and will contribute to the formation of smog. (source: http://www.npi.gov.au/database/substance-info/profiles/38.html)

(iii) Ethyl acetate has been release into the Canadian environment as reported in substantial quantities by various facilities and sectors under MOE's O.Reg.127/01 for the reporting year 2001, 2002, and 2003. See below.

2001 EMISSIONS (in tonnes) [1]: 1,901

2002 EMISSIONS (in tonnes): 3,039

2003 EMISSIONS (in tonnes) [2]: 2,927

Source of Data: OnAIR dataset January 7, 2005
[1] 2001 emissions were for the period May 1, 2001 to December 31, 2001.
[2] 2003 emission data are still being subjected to QA/QC.

The industrial sectors that emit ethyl acetate into the atmosphere according to O.Reg.127/01 are listed below:

Many of these industrial sectors can be found in other provinces. As such, Canada-wide reporting of this pollutant will satisfy the NPRI criteria. Further, with the inclusion of this substance in NPRI, facilities will no longer be required to report to MOE separately.

According to Statistics Canada, Business Patterns Database, December 2003:

There is a total of 242 number of Other Converted Paper Product Manufacturing (NAICS 32229) establishments in Canada. Almost half of these establishments are located in Ontario, but there are facilities distributed throughout Canada except for the territories and PEI. The number of these establishment in Canada had a sharp increase in 2000. The number has decreased slightly since. Based on the Annual Survey of Manufactures data there is a growth rate of 1.3% per year for this sector.(source: http://strategis.ic.gc.ca/canadian_industry_statistics/cis.nsf/IDE/cis32229este.html)

There is a total of 9342 number of Printing and Related Support Activities (NAICS 323) establishments in Canada. There are facilities distributed throughout Canada in all provinces and territories. Based on the Annual Survey of Manufactures data, the chart below illustrates that the number of principal establishments changed from 3,317 in 1993 to 4,735 in 2002. This represents a growth rate of 4.0% per year. (source: http://strategis.ic.gc.ca/canadian_industry_statistics/cis.nsf/IDE/cis323este.html)

There is a total of 237 number of Unsupported Plastic Bag Manufacturing (NAICS 326111) establishments in Canada. There are facilities distributed throughout Canada in all provinces (but not territories). Based on the Annual Survey of Manufactures data, the chart below illustrates that the number of principal establishments changed from 112 in 1993 to 183 in 2002. This represents a growth rate of 5.6% per year. Over the most recent year, the number of establishments in the Unsupported Plastic Bag Manufacturing national industry increased by 2.8% (source: http://strategis.ic.gc.ca/canadian_industry_statistics/cis.nsf/IDE/cis326111este.html)

Based on the NAICS of facilities that have reported to O.Reg 127, a data search of NPRI 2003 has revealed the number of facilities reporting with the same NAICS from each province. This information is seen below:

(iv) Ethyl acetate is reasonably expected to be present in the Canadian environment because of its environmental releases.

2.Do facilities contribute significant releases of the substance?

There are various ways in which ‘significant' can be characterised. The concept relates not only to the proportionate quantity of a substance released by NPRI reporting facilities, but also to the potential for health or environmental impacts. In other words, even if facilities do not account for a major proportion of total releases, facility releases may nonetheless be significant depending on such factors as location, timing, concentration, and the hazard associated with the substance.

Yes. Emission of Ethyl Acetate has been reported under MOE regulation O.Reg.127/01 in Ontario in significant quantities from various facilities and sectors for the reporting year 2001, 2002, and 2003.

3. Does inclusion of the substance support one or more of the objectives of NPRI?

Yes. Inclusion of Ethyl Acetate does support some of the objectives of the NPRI. This will encourage voluntary action to reduce releases, allow tracking of progress in reducing releases, and improve public understanding along with other NPRI substances.

4. Is the substance reported elsewhere? Or if it is reported elsewhere, is there nonetheless additional value in reporting to the NPRI?

Emission of Ethyl Acetate has been reported to MOE under O.Reg.127/01 in Ontario for the reporting year 2001, 2002, 2003 by facilities listed in section 1.

Ethyl acetate emissions data are not collected elsewhere in Canada.

Ethyl acetate emissions data is collected in Austrailia. 37 facilities from 8 industry sources reported Ethyl acetate emissions in Austrailia. (source: http://www.npi.gov.au/cgi-bin/npireport.pl?proc=substance;substance=38)

5. Is the substance already on the NPRI in some form? If it is already on the NPRI in some form, is there nonetheless additional value in including it in another form?

When considering adding a substance in another form (e.g., tetraethyl lead as a separate listing from lead and its compounds), the potential for double-counting will be avoided. For example, a compound will not be both listed as an individual substance, and included as part of an aggregate category. To the extent possible, substances will be listed with their Chemical Abstracts Registry (CAS) numbers.

No. Ethyl Acetate is not included in NPRI presently.

Additional Considerations

1. Sources of Releases of Ethyl Acetate:

Ethyl acetate (CAS # 141-78-6) is a colourless, fragrant liquid; soluble in cholroform, alcohol and ether; slightly soluble in water. It is used as a general solvent in coatings and plastics, organic synthesis, smokeless powders, pharmaceuticals, synthetic fruit essences. (source: Hawley's condensed chemical dictionary)

Sources of emissions:

Point sources - The primary sources of ethyl acetate are the industries that manufacture it or use it in production. Some of the industries that manufacture it or use it in production are the chemical industry, pharmaceutical industry, manufacturers of paints, varnishes and lacquers. These emissions mainly are to the air.

Diffuse sources, and point sources included in aggregated emissions data

Other possible emitters of ethyl acetate are vapours and spilling of commercial and household, varnish and lacquer and their removal, preparation of films and film plates, manufacture of artificial leather and silk, and consumer products containing ethyl acetate. These emissions are to the air unless there is a spill.

Natural sources - Natural sources of ethyl acetate are wines and naturally fermented products.(source: http://www.npi.gov.au/database/substance-info/profiles/38.html)

Recommendations:

- Section 3 -

* This section must be completed for proposals for a change to the reporting threshold of a NPRI substance.

- Section 4 -

* This section must be completed for proposals for a change to the reporting condition of a NPRI substance. The following items should be addressed in this section:

• the proposed reporting condition;
• reasons/justifications why the reporting condition should be changed;
• implications on NPRI reporting facilities;
• sectors/industries that would be affected by this change (NPRI facilities and potential NPRI facilities that may be required to report due to the change);
• consideration of the value of making this change versus the costs of carrying it out (efforts will be made to implement reasonable measures to reduce burdens, hence costs, without compromising the NPRI);
• etc.

- Section 5 -

* This section must be completed for proposals for a change to the reporting requirement of a NPRI substance. The following items should be addressed in this section:

• the proposed reporting requirement;
• reasons/justifications why the reporting requirement should be changed;
• implications on NPRI reporting facilities;
• sectors/industries that would be affected by this change (NPRI facilities and potential NPRI facilities that may be required to report due to the change);
• consideration of the value of making this change versus the costs of carrying it out (efforts will be made to implement reasonable measures to reduce burdens, hence costs, without compromising the NPRI);
• etc.

- Section 6 -

* This section must be completed for proposals for other possible modifications.

1 These decision factors are applicable to candidate substances at both 10-tonne and alternate thresholds.

2 For the purposes of the NPRI, the definition of M,P,O includes by-products. A by-product is an NPRI substance that is incidentally manufactured, processed or otherwise used at a facility and is released to the environment and transferred off site for disposal.

3 In sum, the NPRI is recognised as a key national emissions database; and where a substance falls within the NPRI's mandate, efforts will be devoted to ensuring a single window approach through the NPRI.