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National Office of Pollution Prevention
Table of Contents
Abstract
Summary
1. Introduction
2. Monitoring/Direct Measurement of Releases
3. Analytical Methods
4. Quality Assurance/Quality Control
5. Estimation of Releases
6. Reporting
7. Validation / Verification
Glossary of Terms and Acronyms
References
Bibliography
Appendix A: Standardized Release Reporting Template
Appendix B: Error Estimation
Appendix C: US EPA AP-42 Emission Factors
GUIDANCE DOCUMENT FOR REPORTING OF RELEASES FROM THE BASE METALS SMELTING SECTOR

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7. Validation/Verification

This section provides guidance on external validation and verification of the data reported to various environmental agencies. It provides some background information on third party verification and some existing practices in the Canadian Base Metals Smelting Sector.

7.1 Third Party Verification

Third party verification of release data is often obtained to validate self-reported data and confirm the accuracy of the values.

The Ontario Ministry of the Environment requires both Falconbridge Sudbury and Inco Copper Cliff to have third party verification of their reported annual SO2 releases. For example, Paragraph 19 of the Verification Control Order calls for Falconbridge to retain an independent consultant to design an audit protocol, and perform and report on procedural audits of the SO2 emissions from the complex.

Noranda Brunswick's Approval requires a yearly audit of the sulphur dioxide continuous emission monitors to verify the accuracy of the concentrations and mass discharges of the sulphur dioxide.

The European Eco-Management and Audit Scheme (EMAS)53 is a voluntary initiative to encourage business to improve their environmental performance. There is a requirement in Article 5 of the EMAS Regulation (EEC No. 1836/93) to prepare an Environmental Statement. To ensure that third parties can have confidence in the information supplied, EMAS requires that the statement be validated by an accredited, independent third party verifier.

Australian Minerals Industry Code for Environmental Management Interim Guidance Note on Environmental Reporting, August 199854 indicates that while third party verification is not expected by the Code for Environmental Management, "independent reporting or verification of internally produced reports increases the credibility of report and has been strongly suggested by environmental non-government organisations." The Guidance Note also indicates that "If this is completed, it would be beneficial to include full statement from the third party describing the parameters used and their recommendations."

7.1.1 Recommendations for Validation Verification

It is recommended that facilities identify data that has been validated by an external third party in their reporting documents.

Third party verification should be conducted as frequently as required by regulations. Since a key consideration in obtaining third party verification is cost, it is therefore, recommended that the release data be subject to an external audit at least every three years, where more frequent verification is not a regulatory requirement. However, when significant changes to process inputs, processes or calculation methodology have occurred, the subsequent calculations should be subject to external verification.

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53 Eco-Management and Audit Scheme EMAS www.emas.org.uk.

54 Australian Minerals Industry Code for Environmental Management Interim Guidance Note on Environmental Reporting, August 1998 www.minerals.org.au.

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