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Pollutant Release
and Transfer Register
and Civil Society
Pollutant Release and Transfer Register and Civil Society
PREPARED BY: Jindřich Petrlík, Mochamad Adi Septiono, Penchom Saetang, Nikola Jelínek, Valeriya Grechko,
Annisa Maharani, Miroslava Jopková, Barbora Skořepová, Yuyun Ismawati, Dyah Paramita
December 2023
This report was prepared and published as part of the “Transparent Pollution Control In Indonesia” project funded by the European Union (EU) and co-
funded by the Ministry of Foreign Aairs of the Czech Republic within the Transition Promotion Program, the Sigrid Rausing Trust, and Swedish International
Development Agency via IPEN. Its content is the sole responsibility of Arnika and Nexus3 Foundation and does not necessarily reflect the views of the
donors. The project was implemented by Arnika – Toxics and Waste Programme, based in Prague, Czech Republic, and Nexus3 Foundation, based in
Denpasar, Indonesia. Both Arnika and Nexus3 Foundation are participating organizations of the International Pollutants Elimination Network (IPEN), which
supported publishing this report.
The authors prepared this document based on their best knowledge, literature studies, interviews, and field observation. The authors do not make any
warranty or representation, either expressed or implied, with respect to the completeness of the information contained in this presentation, nor does
the author assume any liability of any kind resulting from the use of or reliance upon any information, procedure, conclusion, or opinion contained in this
presentation. The authors assume no responsibility for maintaining the data contained herein on a current basis or for notification of changes, additions, or
terminations aer the report is published. The authors of this document prepared it based on their own best knowledge, literature studies, interviews, and
field observation. The authors do not make any warranty or representation, either expressed or implied, with respect to the completeness of the information
contained in this presentation, nor does the author assume any liability of any kind resulting from the use of or reliance upon any information, procedure,
conclusion, or opinion contained in this presentation. The authors assume no responsibility for maintaining the data contained herein on a current basis or
for notification of changes, additions, or terminations aer the report is published.
Nexus3 Foundation
Mandalawangi No. 5
Jl. Tukad Tegalwangi, Sesetan, Denpasar Bali, Indonesia, 80223
Email: nexus3@nexus3foundation.org
Website: www.nexus3foundation.org
Arnika – Toxics and Waste Programme
Seifertova 327/85
130 00, Prague 3, Czech Republic
Email: arnika@arnika.org
Website: www.arnika.org
DOI:10.13140/RG.2.2.13612.64643/1
ISBN: 978-80-88508-38-0
Pollutant Release
and Transfer Register
and Civil Society
Arnika – Toxics and Waste Programme / Nexus3 Foundation
Jakarta – Prague
Jindřich Petrlík1 – Mochamad Adi Septiono2 – Penchom Saetang3 –
Nikola Jelínek1 – Valeriya Grechko1 – Annisa Maharani2 –
Miroslava Jopková1 – Barbora Skořepová1 – Yuyun Ismawati2 –
Dyah Paramita4
1) Arnika – Toxics and Waste Programme (Czech Republic)
2) Nexus3 Foundation (Indonesia)
3) Ecological Alert and Recovery Thailand (EARTH) (Thailand)
4) Centre for Regulation, Policy, and Governance (CRPG) (Indonesia)
December 2023
Graphic design: Martin Vimr
Cover page photo: Martin Plocek
Contents
List of Abbreviations .............................................................................................................6
1. Introduction...............................................................................................7
2. Pollutant Release and Transfer Registers (PRTRs) ...................................8
2.1 History of PRTR ..................................................................................................10
2.2 European Pollutants Release and Transfer Register (E-PRTR) ................15
2.3 Examples of the National PRTRs in EU Member States ...........................16
2.3.1 Integrated Pollution Register (IRZ) as PRTR
in the Czech Republic: A Brief Overview ............................................................16
2.3.1.1 Brief History of the Creation of the Czech IRZ ......................................................18
2.3.1.2 Enhancing Accessibility in the 21st Century ....................................................... 20
2.3.1.3 About the IRZ in More Detail .....................................................................................21
2.3.1.3.1 Who and how oen reports to the IRZ ................................................................. 21
2.3.1.3.2 How are data reported to the IRZ obtained? ....................................................22
2.3.1.3.3 Measurement ...............................................................................................................22
2.3.1.3.4 Calculation ................................................................................................................... 23
2.3.1.3.5 Estimation .................................................................................................................... 23
2.3.1.3.6 What data are reported to the IRZ? .....................................................................23
2.3.1.4 How is the Quality of Reported Data Ensured? .................................................. 23
2.3.1.4.1 Verification of reported data ....................................................................................24
2.3.1.4.2 Certification of measurement methods .............................................................24
2.3.1.4.3 Certification of authorized persons .....................................................................24
2.3.1.4.4 Penalties for non-compliance.................................................................................24
2.3.1.5 Photogallery of Facilities Reporting into Czech PRTR .......................................24
2.3.2 IREP as PRTR in France .................................................................................. 26
2.3.3 PRTR in The Netherlands ...............................................................................27
2.4 PRTRs in Other Developed Countries ......................................................... 30
2.4.1 Toxics Release Inventory in USA .................................................................30
2.4.2 National Pollutant Release Inventory (NPRI) in Canada ..................... 31
2.4.3 PRTR in Japan ................................................................................................... 32
2.4.4 PRTR in the Republic of Korea ..................................................................... 34
2.5 PRTRs in some Developing and Low-Middle Income Countries ...........35
2.5.1 PRTR in Chile ...................................................................................................... 35
2.5.2 PRTR in Colombia ............................................................................................ 35
2.5.3 PRTR in Bosnia and Herzegovina ............................................................... 36
2.5.4 PRTR in Tajikistan .............................................................................................36
2.5.5 PRTR in Kazakhstan .........................................................................................37
2.5.6 PRTR in Moldova .............................................................................................. 38
2.5.7 PRTR in Thailand .............................................................................................. 39
2.6 List of Existing PRTR Websites ......................................................................41
2.7 Comparison of the Eciency Between Various PRTRs ........................... 42
3. Multilateral Agreements, Inter-governmental Organizations and PRTR ..44
3.1 Principle 10 of the Rio Declaration................................................................44
3.2 OECD .................................................................................................................. 45
3.3 Aarhus Convention.......................................................................................... 45
3.3.1 Kyiv Protocol ...........................................................................................................46
3.4 The Stockholm Convention on POPs ..........................................................46
3.4.1 Main Provisions of the Stockholm Convention ......................................47
3.4.2 PRTRs and the Stockholm Convention .....................................................47
3.5 Minamata Convention on Mercury .............................................................. 47
3.6 United Nations Framework Convention on Climate Change (UNFCCC) ... 51
3.7 2030 Agenda: UN Sustainable Development Goals (SDGs) ....................51
3.8 Regional Agreement on Access to Information, Public Participation
and Justice in Environmental Maers in Latin America and the Caribbean ... 51
4. PRTRs and Civil Society ..........................................................................52
4.1 Case Studies – Civil Society ........................................................................... 52
4.1.1 Use of TRI by Civil Society in USA ................................................................ 52
4.1.2 Factory Watch – Friends of the Earth UK Project in 1990s ................. 54
4.1.3 Polluters Application in the Czech Republic .......................................... 56
4.1.4 Top Tens of Biggest Polluters for Bosnia and Herzegovina
and Kazakhstan .......................................................................................................... 62
4.1.5 Thailand: CSOs as a Driver for PRTR Implementation ......................... 62
4.1.5.1 Campaign for PRTR Act in Thailand ........................................................66
4.1.6 Case Studies on Volatile Organic Compounds (VOCs) ....................... 68
4.1.6.1 Case Study: Trichloroethylene in Czech PRTR (IRZ) .......................................... 68
4.1.6.2 Case Study: Styrene in Czech PRTR (IRZ) .............................................................69
4.1.6.3 Case Study: Naphthalene in an Industrial Facility Adjacent to the River ...72
4.1.7 Case Studies on Toxic Chemicals in Waste Transfers .......................... 76
4.1.7.1 Case Study: Arsenic in Waste Transfers ...................................................................76
4.1.7.2 Case study: Hexachlorobenzene and similar POPs ........................................... 82
4.1.7.3 Estimation of Dioxins in Waste Based on PRTR Data ........................................ 85
4.2 Beyond NGOs: Expanding Horizons of PRTR Data Utilization ............... 89
5. Crucial Elements of Good PRTR ..............................................................92
5.1 OECD Recommendations ............................................................................... 92
5.1.1 Key Points of the Recommendation ........................................................... 92
5.2 Public Access to All Data about Releases
from Individual Industrial and Agricultural Sources ...................................... 93
5.3 PRTR as a New Database:
Complementary Rather Than Competitive or Cancelling Existing Ones ..... 94
5.4 Civil Society Organizations as Stakeholders of PRTR Design Process .....95
5.5 Concerns of Industrial Companies .............................................................. 96
5.5.1 Benefits of PRTR for Industry ........................................................................97
5.6 Chemically Specific Reporting About Waste Transfers .......................... 99
5.7 Estimation of the Releases - Tools ...............................................................101
5.8 Seing the Good Thresholds for Reporting Obligation ..........................102
5.9 Coverage of the Most Important Pollutants
and Modifications of Their List ................................................................................ 102
5.10 Small and Medium-sized Enterprises and Other Recommendations
by the Toxic Watch Network, Japan on PRTRs in Asian Countries ........... 105
5.10.1 Small and Medium-sized Enterprises
and Industrial Productions in Indonesia ......................................................... 106
5.10.1.1 Artisanal and Small-Scale Gold Mining (ASGM) .............................................. 108
5.11 PRTR and Water Pollution .............................................................................. 112
5.11.1 Cyanide Accidents, River Poisoning and PRTR .................................... 113
5.11.1.1 Cyanides .......................................................................................................................... 113
5.11.1.2 Two Cyanide Accidents and PRTR.........................................................................114
5.11.2 PRTRs and Fishermen .................................................................................................. 115
5.11.2.1.1 How Can PRTR Help Fishing Communities? ................................................... 118
5.11.2.1.2 PFASs, Mercury and Other Persistent Pollutants Contaminate Fish .... 118
Annexes........................................................................................................................123
Annex 1: OECD Recommendations .........................................................................123
Annex 2: List of Substances Incorporated in the Monitoring
Programme in the Netherlands in 1997 ................................................................. 126
References ...................................................................................................................128
6 | Pollutant Release and Transfer Register and Civil Society
List of Abbreviations
ASGM - Artisanal and Small-scale Gold Mining
BAT/BEP - Best Available Techniques and Best Environmental Practices
BD – Brčko District (part of the Bosnia and Herzegovina)
CAPE - Canadian Association of Physicians of the Environment
CEHO - Center for Waste Management
CELA - Canadian Environmental Law Association
CLRTAP - Convention on Long-Range Transboundary Air Pollution
CRI - Chemical Release Inventory
CSO - Civil Society Organization
DIW - Depar tment of Industrial Works
EARTH - Ecological Alert And Recovery Thailand
EFSA - European Food Safety Authority
ENINA - Task Force on Energy, Industry and Waste Management
EPCRA - Emergency Planning and Community Right-To-Know Act
EPER - European Pollutant Emission Register
EPOC - Environment Policy Commiee
EPPO - European and Mediterranean Plant Protection Organization
E-PRTR - European Pollutant Release and Transfer Register
EU - European Union
FBiH - Federation of Bosnia and Herzegovina
FOE UK - Friends of the Earth UK
GCM - Global Community Monitor
GIS - Geographic Information System
HazWI - Hazardous Waste Incineration
HEIS - Hydroecological Information System
IARC - International Agency for Research on Cancer
IPPC - Integrated Pollution Prevention and Control
IREP - le Registre des Emissions Polluantes (French PRTR)
IRZ - Integrovaný registr znečišťování (Integrated Pollution Register; Czech PRTR)
JICA - Japan International Cooperation Agency
MedWI - Medical Waste Incineration
MEWAT – Task Force on Water
MOE - Ministry of Environment
MOP3 - Third session of the Meeting of the Parties
MSDS - Material Safety Data Sheets
MSWI - Municipal Solid Waste Incineration
MTPIE - Map Ta Phut Industrial Estate
NAICS - Nor th American Industry Classification System
NBS - Nature-Based Solutions
NECD - National Emission Ceilings Directive
NGO - Non-Governmental Organization
NPRI - National Pollutant Release Inventory
OECD - Organisation for Economic Co-operation and Development
PAHs - Polycyclic Aromatic Hydrocarbons
PBDEs - Polybrominated Diphenyl Ethers
PCDD/Fs - Polychlorinated Dibenzo-p-dioxins and Polychlorinated Dibenzofurans
PFAS - Per- and polyfluoroalk yl substances
PM10 - Particulate Maer 10
PM2.5 - Par ticulate Maer 2.5
POPs - Persistent Organic Pollutants
PRTR - Pollutant Release and Transfer Register
REACH - Registration, Evaluation, Authorization, and Restriction of Chemicals
RETC - Mexican PRTR system
REZZO - Registry of Air Pollution Sources
RS – Republika Srpska (part of the Bosnia and Herzegovina)
SC - Stockholm Convention
SDGs - Sustainable Development Goals
SEI - State Ecological Inspectorate
SEMARNAT - Secretariat of Environment and Natural Resources (Mexico)
SIC: Standard Industrial Classification
TEQ - Toxic Equivalent Quantity
TgL - Task Force on Agriculture and Land Use
TRI - Toxics Release Inventor y
UK - United Kingdom
UN - United Nations
UNCED - United Nations Conference on Environment and Development
UNFCCC - United Nations Framework Convention on Climate Change
UNITAR - United Nations Institute for Training and Research
USA - United States of America
U.S. - United States
V&V - Task Force on Trac and Transportation
VOCs - Volatile Organic Compounds
WB/GEF - World Bank/Global Environment Facility
WESP - Task Force on Service Sector and Product Use
Introduction | 7
1. Introduction
The inception of Pollutant Release and Transfer Registers (PRTRs) traces
back to a collective global acknowledgment of the need for enhanced
transparency in environmental reporting. This study embarks on a com-
prehensive exploration of the evolution of PRTRs, shedding light on their
historical underpinnings and the subsequent global proliferation of these
registers. This report aims to strengthen civil society groups and the public’s
awareness of the need for integrated data and monitoring of toxic pollution,
its sources, and its impacts on human health and the environment.
Within the broader context of PRTRs, the study emphasizes the dier-
ent developed national PRTRs, oering a nuanced examination of their
creation, evolution, and the mechanisms employed for data. By delving
into the intricacies of PRTR, this study seeks to exemplify the practical
implementation of PRTRs at a national level, unraveling the methodolo-
gies employed for data collection, reporting, and quality assurance.
Beyond national boundaries, this study navigates the global landscape
of PRTR implementation. From the European Pollutants Release and
Transfer Register (E-PRTR) to counterparts in developed countries such
as the United States, Canada, Japan, and Korea, to the initiatives in
developing and low-middle-income nations like Chile, Colombia, Bosnia
and Herzegovina, Tajikistan, Kazakhstan, Moldova, and Thailand, an
intricate web of PRTRs unfolds. This study seeks to discern the e-
ciency disparities among various PRTRs through comparative analysis.
This study examines the connections between PRTRs and agreements
such as Principle 10 of the Rio Declaration, the Aarhus Convention,
the Stockholm Convention on POPs, the Minamata Convention on
Mercury, and the United Nations Framework Convention on Climate
Change (UNFCCC). Moreover, it delves into the role of civil society
in utilizing PRTR data for advocacy and awareness, presenting case
studies from around the globe.
This study can serve as a Guidebook for civil society and other
stakeholders in Indonesia for establishing a good and transparent
PRTR system, which is used to serve as a tool for lowering releases of
pollutants into the air, water as waste, and other transfers. Information
gathered in this Guide is partly based on some previous studies (Havel
et al. 2011; Petrlik et al. 2018; Petrlik and Man 2016), including a desk
study within the project “Transparent Pollution Control in Indonesia”
(Septiono et al. 2023). Its preparation was funded by the European
Commission under the budget line EuropeAid/168799/DD/ACT/Multi
and co-funded by the Ministry of Foreign Aairs of the Czech Republic,
Sigrid Rausing Trust, and Swedish International Development Agency
via IPEN. Its content is the sole responsibility of Arnika and Nexus3
Foundation. It does not necessarily reflect the views of the donors,
such as the US Department of State and Terre des Homme Germany,
which partially supported Nexus3’s personnel.
8 | Pollutant Release and Transfer Register and Civil Society
The Organisation for Economic Cooperation and Development (OECD),
which has been dealing with Pollutant Release and Transfer Registers
(PRTRs) since 1993 (OECD 2000), oers a comprehensive definition of
this tool for accessing information about toxic releases into the envi-
ronment (OECD 2023a).
A PRTR is a publicly accessible database or inventory that shares
information on chemicals or pollutants released into the air, water,
and soil and sent o-site for treatment. It compiles details about
what chemicals are released, where, how much, and by whom (OECD
2023a).
In its introduction to Czech legislation, one of the research team
members characterized PRTR as follows: “The obligation to report data
applies to companies defined either by the number of employees (e.g.,
more than ten) or by the quantity of emissions. Companies annually
provide data on emissions of specific substances into water, air, land-
fills, or other handling (sale, purchase) in special forms. Several tens to
hundreds of selected hazardous substances are recorded. The registry
is freely accessible, for example, in libraries and on the internet “(Velek
and Činčera 2008).
PRTRs typically mandate facility owners or operators to quantify and
regularly report their chemical releases to governments, especially
in manufacturing and mining. This reporting covers emissions from
fixed sources (like factory smokestacks) and diffuse sources (like
vehicles – automobiles, trucks, aircraft, and trains). The reporting
threshold set by governments determines the range of facilities
covered, from large industrial sites to small operations like dry
cleaners (OECD 2023a).
PRTRs oer valuable data for various stakeholders:
• Government agencies (national, state, and local) can use PRTR
data to track trends in pollutant releases, guide environmental
policy decisions, assess environmental programs, and identify
potential health and environmental risks when combined with
health data.
• The public can use PRTRs to discover potential chemical
exposures and risks from nearby facilities, make informed
decisions, and monitor facilities’ eorts to reduce their
environmental impact.
2. Pollutant Release and Transfer
Registers (PRTRs)
Pollutant Release and Transfer Registers (PRTRs) | 9
• Companies can utilize PRTR data to find opportunities for
eciency improvements and waste reduction as a metric for
measuring progress toward sustainable development.
• Other stakeholders, like non-governmental organizations, the
media, and researchers, benefit from access to PRTR information,
especially when combined with Geographic Information Systems
(GIS) and toxicity data, to identify potential areas of concern or
correlations between exposure and observed health or environ-
mental eects.
• Financial organizations use PRTR data to support socially respon-
sible investments, identify potential liabilities of firms, and assess
impacts on real estate prices (OECD 2023a).
Figure 2.1 Information flows. (Taylor 2004)
Releases
Recycling Storage
Process on-site
Input
Output
Transfers
Releases
Water
Energy
Resources
Releases
into water
Releases
into soil
Releases
into air
Product
transfers
Transfers of pollutants
in waste
Transfers of pollutants
in water
10 | Pollutant Release and Transfer Register and Civil Society
2.1 History of PRTR
The first PRTR is always considered to have been established in 1978
in the US state of New Jersey, where information on the production
and use of 155 chemical substances (including their flows into waste)
from more than 7,000 industrial facilities was collected in a one-time
eort (Muir et al. 1995). However, a kind of PRTR database existed in the
Netherlands since 1974 (Ruyssenaars et al. 2007).
The New Jersey model then became the basis for proposing a federal
data collection and disclosure system in the form of the Toxics Release
Inventory (TRI) in the United States, which was enacted in 1986 in the
law known as the Emergency Planning and Community Right-To-Know
Act – EPCRA (Jobe 1999). On June 19, 1989, the Toxics Release Inven-
tory became publicly accessible online via TOXNET (Jobe 1999). It was
the world’s first system for informing the public about releases of toxic
substances into the environment (air, water, soil, and injections into
the ground). Policy-makers have judged the TRI a tremendous success,
as national releases declined by 43% between 1988 and 1999 (Bui and
Mayer 2003).
The creation of the Toxics Release Inventory is also described in the
book “The Right to Information on Chemicals,” published in Czech
in 1995 (Muir et al. 1995). This book highlights the important role of
non-governmental organizations in creating the US register: “The
non-governmental environmental organization INFORM Inc. conducted
a three-year study, the results of which were published in 1985 in a book
called Cuing Chemical Wastes. INFORM explored 29 chemical compa-
nies to determine how they reduce waste production and what organi-
zational, economic, or legislative factors stimulate or enforce eorts to
reduce hazardous waste production. During audits, the availability of
information on used chemical substances and their releases into water,
air, and solid waste was examined, among other things. It was found
that information available in the surveyed companies was scaered in
various parts of the companies, sometimes processed systematically,
oen hidden in extensive documents, or stored in incompatible data-
bases. The data were in such a form that even if extraordinary eorts
were made to collect them from various places, the result would be
a pile of documents containing only poor or incomplete information.
Such data could not be used to estimate the quantities of toxic chemi-
cals used, waste production, or environmental releases. It was impossi-
ble to track trends or evaluate the reduction of waste production from
the data at all” (Muir et al. 1995).
It is generally agreed that the proximate cause for mandating some
form of toxics release reporting occurred on December 4, 1984, when
a cloud of extremely toxic methyl isocyanate (MIC) gas seeped from a
Union Carbide plant in Bhopal, India. Death estimates vary from 4,300
to nearly 20,000 (Terry and Yandle 1997).
Among the experiences of states that introduced national pollution
registers, positive ones prevailed, showing that this measure leads
to a reduction in releases and improves the situation without special
costs. Therefore, the US delegation at the UNCED Conference in Rio in
1992 recommended including the PRTR system in the tools of Agenda
21. The Organization for Economic Cooperation and Development
(OECD) developed Recommendations for Governments to Implement
PRTR Systems through several workshops. OECD prepared a Guidance
Manual for governments considering establishing PRTRs, published in
1996; the OECD Council adopted a Recommendation on Implementing
PRTR in the same year (OECD 2001).
PRTRs were gradually being introduced by states all over the world. In
1996, Japan; 1997, Mexico; 1998, Sweden; and others. However, some
Photo 2.1 Union Carbide pesticide factory, Bhopal, India, 1985.
Photo: Bhopal Medical Appeal, Martin Sto via Wikimedia Commons
Photo 2.2: Monument to the 1984 Bhopal disaster.
Photo: Luca Frediani via Wikimedia Commons
Photo 2.3: Victims of Bhopal disaster march in September 2006
demanding the extradition of American Warren Anderson from the
United States. Photo: Obi from Roma, London via Wikimedia Commons
Photo 2.4: OECD started with PRTRs in the 1990s and, in 2021, released
a Global Inventory of Pollutant Releases. Source: (OECD 2021)
Photos 2.5, 2.6, and 2.7: China is among the countries lagging behind,
although its pollution problems are increasing. The growing number
of large municipal waste incinerators significantly contributes to this
issue. Photos 2.5 and 2.6 depict the Wuhan municipal waste incinera-
tor, identified as a serious source of dioxin contamination, including its
fly and boom ash (Katima et al. 2018; Weber et al. 2015).
Sources: Jindrich Petrlik, Arnika, Zhang et al. (2015)
Photo 2.6
Photo 2.7: Cement kilns, oen co-incinerating waste, are another
significant source of pollution in China. An illustrative photo of a
cement plant across the Yalu River in Ji’an, Dongbei, North China.
Image: Caitrianna Nicholson, CC BY-NC-ND 2.0 (hps://www.flickr.com/
photos/caitriana/7730900090/)
Photos 2.8, 2.9 and 2.10: Russia is also lagging in providing open infor-
mation about toxic releases from industrial enterprises. The chlorine
industry*, partly built for military uses during the Cold War, is part of
the problem. A considerable amount of contaminated waste produced
by chemical factories remains dumped, contaminating the environ-
ment. Additionally, current factories are sources of pollution, particu-
larly with mercury and chlor-organic pollutants (Akhmedkhanov et al.
2002; Shelepchikov et al. 2008; Speranskaya et al. 2005). The photos
are from Igumnovo and Gorbatovka in the Dzerzhinsk region, taken
near chlorine industrial sites in 2004, which are identified as sources
of dioxin contamination. Source: (Speranskaya et al. 2005)
*Chlorine was absorbed practically in all industry branches including drinking water
purification, plastics production and even manufacturing of solid-fuel engines for ballistic
rockets manufacturing. Chlorine industry enterprises, as a rule, were combined into
industrial complexes, including factories producing miscellaneous target products of civil
and military purpose as well as auxiliary production of semi-finished products and raw
materials, including molecular chlorine. Basic technology of chlorine manufacturing was
and still is electrolysis using graphite electrodes. A considerable part of industrial waste
was incinerated on the territory of production complexes. Furnaces with alkaline scrubber
were used for burning of organic chlorine waste. Other waste materials were incinerated in
furnaces equipped with low-eective cyclone dust separators. Wastes that are not subject
to incineration were land-buried near the enterprises (Shelepchikov et al. 2008). Photo 2.10
Photo 2.9
14 | Pollutant Release and Transfer Register and Civil Society
large countries where environmental pollution is a significant problem,
such as Russia, China, or India, are still lagging. China has introduced
some reporting systems since 2013. However, its format diers greatly
from other PRTRs, and data are not publicly accessible (Shi 2013)
according to recent research on related pilot projects, the authentic
PRTR system has not been established (Guo et al. 2021).
The international process of preparing a global convention on reg-
isters of releases and transfers of toxic substances culminated in
creating the Protocol on PRTR to the Aarhus Convention. The working
group, which met eight times between February 2001 and January
2003, created the protocol. This protocol (The Protocol on Pollutant
Release and Transfer Registers) was adopted on May 21, 2003, at the
meeting of the parties to the Aarhus Convention in Kyiv, which was
part of the 5th Ministerial Conference “Environment for Europe.” From
January 1, 2004, all states, including those that had not yet ratified
the Aarhus Convention and were not members of the United Nations
Economic Commission for Europe, can accede to this so-called Kyiv
Protocol, which has been signed by 36 countries, including the Czech
Republic. The protocol became a full-fledged part of European law in
2009. The United Nations Economic Commission for Europe (UNECE)
is the guardian of this protocol (UNECE 2011). The Kyiv PRTR Protocol
has 38 parties as of December 2023 (InforMEA 2023). The integrated
PRTR also operates at the European level. The first version, from 2001
to 2004, was called EPER (European Pollutant Emission Register),
serving as a repository for data reported in connection with the
Integrated Pollution Prevention and Control (IPPC). More than 12,000
industrial facilities across the EU were required to report to EPER,
reporting 50 substances in 32 industrial sectors every three years. The
European Commission’s materials set the limit so that up to 90% of
the total industrial emissions in the EU were reported to EPER (Petrlik
and Man 2016; UNECE 2008). The integrated PRTR also operates at
the European level. The first version, from 2001 to 2004, was called
EPER (European Pollutant Emission Register), serving as a repository
for data reported in connection with the Integrated Pollution Preven-
tion and Control (IPPC). More than 12,000 industrial facilities across
the EU were required to report to EPER, reporting 50 substances in
32 industrial sectors every three years. The European Commission’s
materials set the limit so that up to 90% of the total industrial emis-
sions in the EU were reported to EPER (Petrlik and Man 2016; UNECE
2008).
Photo 2.11: The Volga River (in the photo) is close to many industrial
facilities, including the Kaustik factory in Volgograd, identified as a
serious source of mercury contamination, releasing almost 0.7 metric
tons of mercury annually (Speranskaya et al. 2013). Photo from the
EcoAccord archive. (Katima et al. 2018; Shelepchikov et al. 2008;
Speranskaya et al. 2013; Speranskaya et al. 2005; Weber et al. 2015);
Zhang et al. (2015)
Pollutant Release and Transfer Registers (PRTRs) | 15
In 2006, EPER was replaced by the European Pollutant Release and
Transfer Register (E-PRTR), whose legal framework was established
by Regulation 166/2006/EC, requiring member states to harmonize
reported data to be compatible with the pan-European database. The
first reporting year to the new E-PRTR register was 2007. More than
30,000 industrial facilities in the EU exceeded the reporting limits for
E-PRTR (Petrlik and Man 2016; UNECE 2008).
Table 2.1 Dierences between EPER and E-PRTR.
Source: (Petrlik and Man 2016)
EPER E- PRTR
Legal form of the register’s establishment Decision Regulation
Number of substances in the register 50 91
Number of activities monitored 56 65
Releases to soil No Yes
Emergency releases No Yes
Transfers of waste No Yes
Transfers of wastewater Yes Ye s
Dispersed sources No Yes
Only IPPC facilities Yes No
Reporting cycle Triennial Annual
2.2 European Pollutants Release and Transfer
Register (E-PRTR)
European PRTR (E-PRTR) covers environmental release and emission
reporting from 2007 to 2017 by EU Member States, Iceland, Liechten-
stein, Norway, Serbia, and Switzerland. It is implemented under the
mandate of Regulation (EC) No. 166/2006 of The European Parliament
and of the Council of 18 January 2006 concerning the establishment
of a European Pollutants Release and Transfer Register and amending
Council Directives 91/689/EEC and 96/61/EC (European Parliament
and Council 2006), as well as EU Commission Implementing Decision
2019/1741 (European Commission 2019). In Europe, PRTR started with
seven countries reporting in 2007, then progressed to 18 countries in
2017 (EEA 2022).
E-PRTR presents release and transfer data that can be looked over by
multiple identifications, such as facility, activity, o-site transfer, pol-
lutants or waste, facility owners, etc1. The mandatory reported annual
data is based on measurement, calculation, or standardized estimation
1 Article 4 of EC No. 166/2006
Photo 2.12: Accidental (emergency) releases of toxic substances were
not part of the reports into the EPER system. An accident in the haz-
ardous waste incinerator in Vyškov, Czech Republic, is a photo taken by
Fire Brigade in 2005. Source: (Petrlik and Bell 2017)
16 | Pollutant Release and Transfer Register and Civil Society
methods to indicate chemicals/pollutants released to air, water, land,
and o-site transfers2. The data collection is mandated by the EU
Commission Implementing Decision 2018/1135 (European Commission
2018). These data would then be published within 16 months aer the
end of the reporting year3, aer going through assessments and coordi-
nation for quality assurance and assessment processes4. An example of
the public information in E-PRTR is shown in Table 2.3 below.
There are multiple industry sectors covering 65 industry types/
economic activities, included in the mandatory list to report 91 chemi-
cals and pollutants5 with a standardized format6, such as7:
• Energy sector,
• Production and processing of metals,
• Mineral industry,
• Chemical industry,
• Waste and wastewater management,
• Paper and wood production and processing,
• Intensive livestock production and aquaculture,
• Animal and vegetable products from the food
and beverage sector and
• Other activities
The 91 types of reported pollutants in the E-PRTR are classified under
seven groups:
2 Article 5 of EC No. 166/2006
3 Article 7 of EC No. 166/2006
4 Article 9 of EC No. 166/2006
5 Annex 2 of EC No. 166/2006
6 Annex 3 of EC No. 166/2006
7 Annex 1 of EC No. 166/2006
• Greenhouse gases
• Other gases
• Heavy metals
• Pesticides
• Chlorinated organic substances
• Other organic substances
• Inorganic substances
Even though multiple data gaps have yet to be submied or incomplete
reports (EEA 2021; EEA 2022), the implementation and publication of such
information enable the data accessibility, analysis of release and emission
overtime, and triggers for industries to continuously improve their Best
Available Techniques and Best Environmental Practices (BAT/BEP).
This mandatory reporting of various industry types and chemical
pollutants diers from the list in Indonesia’s environmental conserva-
tion and pollution protection regulatory framework. The comparison
analysis was provided in section 4 of the desktop study report on PRTR
by Nexus3 and Arnika (Septiono et al., 2023).
The Industrial Emissions Portal covers over 60,000 industrial sites from
65 European economic activities (EEA 2021).
2.3 Examples of the National PRTRs in EU
Member States
2.3.1 Integrated Pollution Register (IRZ) as PRTR in the
Czech Republic: A Brief Overview
PRTR system in the Czech Republic called Integrated Pollution Register
(Integrovaný registr znečišťování or IRZ) is a publicly accessible online
database (www.irz.cz) that contains information about specific facilities
Pollutant Release and Transfer Registers (PRTRs) | 17
(a) Map-based display of PRTR facility reporting
(b) Regulatory overview of the reporting PRTR facility
(c) Environmental data overview of the PRTR facility in the E-PRTR
18 | Pollutant Release and Transfer Register and Civil Society
contributions to environmental pollution. Managed by the Ministry
of the Environment, IRZ has been operational since 2003, established
by Law 76/2002 Coll. on Integrated Prevention to implement the
European Commission Directive on Integrated Prevention (96/61/EC).
The creation of IRZ fulfilled commitments arising from ratifying the
Aarhus Convention, focusing on providing information to the public.
The register, introduced in the fall of 2005, marked the beginning of the
dataset, covering reported data from 2004. Since 2004, 72 pollutants
have been reported (MŽP 2021c; Petrlik and Man 2016).
2.3.1.1 Brief History of the Creation of the Czech IRZ
Preparations for the IRZ in the Czech Republic began in 1994, respond-
ing to pressure from international institutions and non-governmental
organizations. Several studies were commissioned, but the quality was
insucient. Simultaneously, NGOs developed proposals. The inclusion
of IRZ in the dra law on integrated pollution prevention in 2001 marked
its first appearance, serving as a tool to monitor the fulfillment of goals
set by this new law.
(d) Details on relevant authority for PRTR reporting
(e) Details of inspection results from the relevant authority for PRTR reporting
Pollutant Release and Transfer Registers (PRTRs) | 19
Representatives of the Association of Industry and Transport of the
Czech Republic (Svaz průmyslu a dopravy ČR) aempted to remove or at
least weaken the IRZ from the dra law on integrated prevention. To help
instigate the process, the Czech environmental NGO Arnika worked to
generate more than 10,000 signatures on a petition, “Toxics-Free Future,
“that called for PRTR and included local authorities, scientists, and prom-
inent figures (DiGangi 2011). Law No. 76/2002 Coll., on Integrated Preven-
tion, thus included the promise of creating IRZ, outlining its general frame-
work. In 2003, Government Regulation No. 386/2003 Coll. established the
Photos 2.13 – 2.14: In 2003, Arnika proposed a much longer list of
substances for the Integrated Register of Pollutants (IRZ) to Minister
of the Environment Libor Ambrozek than was ultimately approved.
The Ministry of the Environment suggested 122 substances. Still, other
ministries in the government reduced the list to 72 substances in the
first phase and 88 in the second phase of the IRZ’s validity (Arnika
2003). Photo: Arnika, 2003
20 | Pollutant Release and Transfer Register and Civil Society
final form of the first Czech IRZ. In 2008, IRZ was legally separated from
integrated pollution prevention and control into Law No. 25/2008 Coll.,
aligning data outputs with E-PRTR (MŽP 2021c; Petrlik and Man 2016).
The list of reported substances, originally 72, increased due to European
regulations, reaching the later 93. Reporting to IRZ began in 2004, and as
of 2007, the number of reported substances increased to 93, surpassing
the E-PRTR requirements of 91 substances. Currently, over 1,600 facilities
report releases and transfers to IRZ annually, with data publicly acces-
sible with a nine-month delay. Reporting obligations arise if facilities
exceed pollutant limits set by decree (Petrlik and Man 2016).
In 2016, under industrial associations and the Ministry of Industry and
Trade of the Czech Republic pressure, a new law was issued listing
operations subject to the obligation to monitor reported substances
(MV ČR 2016). A key point of the IRZ law amendment was limiting the
impact of reporting obligations to IRZ only for 232 selected other activ-
ities or activities with lower threshold values for capacity compared
to E-PRTR (MŽP 2021c). This mostly concerns defining selected areas
of industrial or agricultural activities and the operation capacity. Due
to this change, reporting no longer applies, for example, to small haz-
ardous waste incinerators, even though they can be significant local
sources of dioxin emissions and their transfers in ash. Besides this
change, there had been earlier restrictions on reporting certain sub-
stances in waste, including some persistent organic pollutants (POPs),
such as hexachlorobutadiene. For the reporting year 2021, polychlo-
rinated naphthalenes and benzo(a)pyrene were added to the list of
reported substances, and a new group of reported polybrominated
diphenyl ethers (PBDEs) was distinguished (MV ČR 2020).
In 2023, the Government of the Czech Republic supplemented its IRZ
regulation with the obligation to report per- and polyfluoroalkyl sub-
stances (PFAS) in discharged waters. It tightened the reporting thresh-
old for cyanide transfers in waste from 500 to 50 kg/year. This was in
response to an incident in 2020 on the Bečva River, where a cyanide
leak resulted in massive fish mortality over a 40 km stretch of the river
(Čtk 2023). The tightening was prompted by the Arnika Association’s
call “Toxics Free Rivers” (Arnika 2020a), signed by over 7,000 people
(Arnika 2020b). The requirement was also supported by commiees of
the Parliament of the Czech Republic (Čtk 2023).
The IRZ database does not include all facilities polluting the environ-
ment but generally focuses on larger enterprises or those dealing with
larger quantities of chemical substances. Separate lists of substances
with dierent limits are established for each emission pathway:
• Emissions to the air (67 substances)
• Emissions to water (75 substances; expanding to include PFAS
from 2025)
• Emissions to soil (65 substances)
• Transfers of substances in waste (24 substances)
• Transfers of substances in wastewater (71 substances)
The IRZ, or the Czech version of PRTR, contains data on 97 individual
pollutants or groups of substances (MŽP 2021b).
2 3.1.2 Enhancing Accessibility in the 21st Century
Today, people expect easy access to information from various sources
in one place, ideally from the comfort of their smartphones or PCs
online. In this light, the integrated PRTR appears to be a full-fledged tool
of the 21st century. Before 2005, it was not nearly as easy to check what
toxic substances companies in the vicinity were releasing. It’s not that
emied chemicals were not monitored or measured, but there was a
lack of integration of information and data accessibility to the public.
Pollutant Release and Transfer Registers (PRTRs) | 21
The thought of lengthy correspondence with environmental protection
authorities or directly with the management of a particular industrial
operation discouraged many curious individuals. For example, obtain-
ing information about a complete overview of substances released into
the environment by all major companies in a given region was unimag-
inable for a citizen or organization before the introduction of IRZ.
Currently, a few clicks provide an overview of the entire Czech Republic
(www.irz.cz ), and with a basic knowledge of English, a few more clicks
open the door to a vast pollution database across Europe (hps://
industry.eea.europa.eu/#/home).
Table 2.2: Number of reported substances to IRZ according to legal norms
from 2004, 2008, and 2011. Source: (MŽP 2021b; Petrlik and Man 2016)
2004 2008 2011 2021
Air 57 62 62 67
Water 43 71 71 75
Soil 44 61 61 65
Waste Transfers 56 72 26 24
Total 72 93 93 97
2 3.1.3 About the IRZ in More Detail
2 3.1.3.1 Who and how oen reports to the IRZ
The basic industrial unit for reporting and measuring the quantity
of a chemical substance is a specific facility characterized by geo-
graphic location and technology. This is important, especially for large
chemical companies or smelters and similar facilities, where there may
be multiple production lines, melting plants, etc. According to the IRZ
law, a facility is defined more broadly than an operation or production
line. In large production areas of a company (foundries, chemical
plants), you cannot find specific emissions from a specific smelting
column, for example, or identify leaks from each production line or
associated equipment, such as a power plant. Dierent operation or
production lines within one location and one owner report into IRZ as
one facility collectivelly, not as dierent facilities.
Facilities report to the IRZ themselves. Reports are usually prepared by
the company’s environmental specialist or another authorized person.
Companies or facilities, therefore, ensure, at their own expense and
responsibility, the collection and reporting of data to the IRZ.
The period for which the amount of substances emied to the IRZ is
reported is one calendar year. It is reported in total quantities for the
entire year. This is not a report on concentrations in emissions. The
total amount of substances released into the air for the year can be
calculated from these concentrations, but they cannot be used as
data for the IRZ. Facilities must submit data by the end of March of the
following year, and the information is made available to the public by
September 30.
It is also important to mention that reporting to the IRZ is only done
online - electronically. Traditional paper reporting is eliminated, but some
traditional companies initially found this problematic. There is no alter-
native reporting option. The technical change in reporting came in 2008
when Czech IRZ legislation was harmonized with the European E-PRTR
register to make data easily transferable to the pan-European register.
Even with modern online reporting, industrial companies sometimes
submit incorrect data. A common unintentional error is the displace-
ment of the decimal point, which can lead to reporting the production
of a toxic substance from one facility higher than its estimated emis-
sions for the entire European Union.
22 | Pollutant Release and Transfer Register and Civil Society
Companies had to learn how to report to the IRZ in a certain way. Only
in the last few years has the number of facilities reporting to the IRZ
more or less stabilized. Currently, there are more than 5,000 of them.
Still, only 1,674 facilities reported leaks and transfers of substances. In
contrast, the rest reported only the total amount of produced waste,
which does not indicate the extent of facilities’ contribution to environ-
mental pollution. The number of reporters has increased since 2004.
Initially, it was mainly because companies were geing used to the new
obligation. Today, the number of facilities reporting releases and trans-
fers of chemical substances is twice as high as in 2004.
2 3.1.3.2 How are data reported to the IRZ obtained?
Reporting emissions or transfers of pollutants to the IRZ does not
always require measurement or professional laboratory analysis. When
introducing the IRZ or discussing adding or removing a monitored sub-
stance from the legal list, industry representatives oen mislead them-
selves and the public by claiming they will incur expensive and complex
measurements or chemical analyses. However, this is not always true
and depends on the data acquisition method chosen by the company.
There are three ways companies can approach data collection for
reporting:
I. Measurement
II. Calculation
III. Estimation
It is important to note that only methods and technologies certified
under applicable law may be used to determine emissions or transfers
of pollutants. Companies must ensure that the measurement method
is carried out by authorized persons, and these measurements must
be documented and archived for at least three years. The situation is
similar for calculations and estimates.
In special cases, exceptions exist where a non-certified method can be
used. Emissions from a single facility are aggregated. This is important
for complying with the legal limit for reporting to the IRZ. For example,
a facility with two boilers aggregates emissions from both and reports
the resulting sum. Similarly, total emissions or transfers of substances
from dierent technologies within a single facility are aggregated.
Figure 2.2: Graph shows the development of the number of facilities
reporting releases or transfers of substances into the Czech PRTR
during its first ten years. The graph does not show facilities reporting
only waste quantities. Decrease of number between 2015 and 2016
was caused by change in the rules for reporting introduced under the
pressure from industry lobbyist.
total number of facilities
year
1700
1600
1400
1200
1000
800
600
400
200
0
2004 2007 2010 20132005 2008 2011 2014 2015 2016 2017 20192018 20202006 2009 2012
872
1156
1663 1657
981
1175
1621 1694
1770
1300 1332
1373
1332 1257
1102
1509
1623
Pollutant Release and Transfer Registers (PRTRs) | 23
2 3.1.3.3 Measurement
Measurement is a method of directly determining the quantity of a
released substance. Typically, this occurs during short-term emission
monitoring or water, soil, or waste analyses, such as semi-annual mon-
itoring for IPPC requirements. This method is usually supplemented
by additional calculations, where the annual volume of released or
transferred substances is determined from measurements, as measure-
ments are usually taken only a few times a year and not continuously
throughout the year. The IRZ database marks measured data with the
leer “M” (measurement).
2 3.1.3.4 Calculation
Another method is calculation, based, for example, on knowledge of the
quantity of input fuel or other raw material, the performance and eciency
of the technology, or other input and process parameters from which it is
possible to calculate the quantity of produced pollutants professionally.
For example, in power plants, it is usually the knowledge of the quantity of
fossil fuel burned annually, the performance and the emission coecient
of a given boiler and the number of operating hours. In the IRZ database,
calculated data is marked with the leer “C” (calculation).
2 3.1.3.5 Estimation
Estimation is primarily used when measuring or calculating emissions
is impossible or economically unjustifiable. For example, it is impossi-
ble to measure emissions from small boilers or stoves in households,
garden composting, or the disposal of green waste from gardens. In
these cases, emissions are estimated based on statistical data, expert
estimates, and known quantities of processed materials. For example,
the amount of household waste is known, and the composition of
biodegradable waste is statistically known, so the quantity of biode-
gradable waste disposed of in gardens can be estimated. In the IRZ
database, estimated data is marked with the leer “E” (estimation).
2 3.1.3.6 What data are reported to the IRZ?
Data reported to the IRZ includes the total quantity of substances
released into the air, water, and soil or transferred in waste. This is
reported by individual substances and technologies or installations from
which the substances are released. Reports also include data on waste
transfers. The reporting facility also provides information on individual
technologies’ operational status and technological parameters. This
includes data on the number of hours of operation, the quantity of raw
materials consumed, and the performance of technologies. Such data is
important for the subsequent calculation of emissions or transfers.
Data reported to the IRZ also includes information about the facil-
ity’s environmental impact. This includes data on the consumption
of resources, energy, and water, as well as waste generation and its
impact on human health. In addition, the reporting facility must provide
information on the measures taken to reduce emissions or transfers,
the use of the best available technologies, and the implementation of
cleaner production processes.
2.3.1.4 How is the Quality of Reported Data Ensured?
The quality of reported data is crucial for the reliability and credibility
of the IRZ. It is, therefore, essential to ensure that the data reported
by facilities is accurate and meets certain quality standards. Several
mechanisms are in place to ensure data quality:
I. Verification of reported data
II. Certification of measurement methods
III. Certification of authorized persons
IV. Penalties for non-compliance
Overall, the combination of verification processes, certification of
measurement methods, certification of authorized persons, and
24 | Pollutant Release and Transfer Register and Civil Society
penalties for non-compliance helps ensure the accuracy and reliability
of the data reported to the IRZ. This, in turn, contributes to the
eectiveness of the IRZ in monitoring and managing environmental
impacts from industrial activities.
2.3.1.4.1 Verification of reported data
The data reported to the IRZ is subject to verification by the relevant
environmental authorities. This involves a thorough examination of the
data to ensure its accuracy and consistency. If discrepancies or inaccu-
racies are identified, the facility may be required to provide additional
information or correct the reported data.
2.3.1.4.2 Certification of measurement methods
The methods used by facilities to measure emissions or transfers of
pollutants must be certified under applicable law. This certification
ensures that the measurement methods are reliable and accurate.
Facilities must use certified methods to obtain data for reporting to the
IRZ.
2.3.1.4.3 Certification of authorized persons
Individuals responsible for conducting measurements or calculations
for reporting purposes must be authorized and certified. This certifica-
tion ensures that the personnel involved have the expertise and com-
petence to perform accurate measurements or calculations.
2.3.1.4.1 Penalties for non-compliance
Facilities that fail to comply with reporting requirements or provide
inaccurate data may face penalties. These penalties are designed to
incentivize facilities to adhere to reporting obligations and maintain the
quality of the data submied to the IRZ.
2.3.1.5 Photogallery of Facilities Reporting into Czech PRTR
Photo 2.18: Although Triton laundry and clothing cleaning facility in the
town of Rakovník in Central Bohemia faced complaints in 2010 mainly
due to black smoke from its chimney, it ranked among the top polluters
in the Czech Republic from 2004 to 2010 due to emissions of 2.8 to
8.5 tons of tetrachloroethylene (Arnika 2023b). Photo: Jaromír Olič,
authorized chimney sweep by the Ministry of the Environment of the
Czech Republic, 2010
Photo 2.16: The smaller smoking chimney in this photograph belongs to
a waste-to-energy plant (municipal waste incinerator), while the larger
one belongs to the Liberec Heating Plant. We delve into it further in
Subchapter 4.1.7.3. Photo: Marek Jehlička (www.skywalker.cz), 2021
Photo 2.15: A chemical factory producing nitrogen fertilizers, Lovochemie,
located near the largest Czech river, the Elbe, at the foothills of the
Protected Landscape Area of the Czech Central Highlands, is a source
not only of pollutants released into the air (being a significant emier of
the greenhouse gas nitrous oxide) but also of zinc and its compounds in
releases to water (Havel et al. 2011). Photo: Jan Losenický, Arnika, 2017
Photo 2.17 One of the large brown coal thermal power plants in Ledvice,
owned by the energy company ČEZ, is situated in the Podkrušnohorská
Basin, where brown coal is mined. As it is a valley surrounded by
mountains on both sides, frequent inversions occur here from autumn to
spring, trapping pollution closer to the ground. However, the power plant
chimney and cooling towers peek above the inversion cloudiness in this
photograph. Brown coal power plants, besides emiing sulfur dioxide,
carbon dioxide, and dust, are also significant sources of heavy metals,
including arsenic, which then accumulate in the residues from flue gas
cleaning (Petrlík 2010). Photo: Daniela Endrštová
26 | Pollutant Release and Transfer Register and Civil Society
2.3.2 IREP as PRTR in France
The General Directorate for Risk Prevention of the Ministry of Eco-
logical Transition and Territorial Cohesion oversees the compilation
of crucial data on pollutant releases and transfers in France. This
information, sourced from major industrial installations, urban sewage
treatment plants catering to over 100,000 equivalent inhabitants, and
specific livestock operations, is publicly accessible through the French
Register of Pollutant Releases and Transfers (IREP).
Photo 2.20: Wastewater treatment plants in large cities reflect the
toxic substances present in households or used by cra industries in
the city. Not all of these substances can be completely removed from
wastewater. Thus, even the Central Wastewater Treatment Plant in
Prague, pictured here, is among the largest sources of surface water
pollution with heavy metals (Arnika 2023c). Photo: ŠJů (cs:ŠJů) via
Wikimedia Commons
Photo 2.19: The Lukavec wood processing plant is located in a
rural landscape. Nevertheless, it is among the largest polluters of
carcinogenic formaldehyde, similar to another wood processing plant,
Kronospan, in Jihlava (see Photo 4.4). Since 2007, the Lukavec plant has
reported air emissions of formaldehyde ranging from 2.4 to 9 tons to
the Czech PRTR (IRZ) (Arnika 2023a). Photo: Jindřich Petrlík, Arnika, 2011
Pollutant Release and Transfer Registers (PRTRs) | 27
The IREP is a comprehensive national inventory encompassing chemical
substances and potentially hazardous pollutants released into the air,
water, and soil. It also includes data on the production and treatment
of both hazardous and non-hazardous waste. The register plays a vital
role in meeting international obligations, such as the requirements of
the International PRTR Protocol and the European Regulation E-PRTR,
ensuring transparency in pollutant releases and transfers.
The decree of January 31, 2008 (available at hp://www.ineris.fr/aida/
consultation_document/23106) defines the list of establishments
subject to this annual declaration and the list of pollutants concerned
and the thresholds for mandatory reporting. Here’s a breakdown of
the targeted pollutants in dierent environmental mediums:
1. Emissions into Water:
• Targeted Pollutants: 150 pollutants (including global indicators,
substances, or substance families)
2. Emissions into Air:
• Targeted Pollutants: 87 pollutants
3. Emissions into Soil:
• Targeted Pollutants: 70 pollutants
4. Waste Categories:
• Targeted Categories: 400 categories of waste
Additionally, the register includes information on volumes of water
taken and discharged, subject to specific thresholds. Notably, these
pollutants span various types, reflecting the diverse nature of pollut-
ants released into the environment. Small installations, low emiers,
are not required to produce a declaration, as are installations in certain
sectors of activity. Similarly, the Pollutant Emissions Register does not
include estimated releases from diuse sources such as agriculture
and transportation or from individuals.
The IREP provides a detailed and categorized overview of the pollut-
ants, facilitating a comprehensive understanding of the environmental
impact of dierent sources, including major industrial installations,
urban sewage treatment plants, and certain livestock operations. This
information is crucial for regulatory compliance, environmental man-
agement, and public awareness (MTECT 2023).
2.3.3 PRTR in e Netherlands
Emission estimates in the Netherlands are registered in the PRTR,
which is the national database for sectoral monitoring of pollutant and
greenhouse gas emissions to air, water, and soil. The database was set
up to support national environmental policy, as well as to meet the
requirements of the EU National Emission Ceilings Directive (NECD),
Photo 2.21: Sanofi Chimie in Sisteron, France, pharmaceutical
industrial facility reporting into French PRTR. Photo: K800i via
Wikimedia Commons
28 | Pollutant Release and Transfer Register and Civil Society
CLRTAP, the United Nations Framework Convention on Climate Change
(UNFCCC) and the Kyoto Protocol (National System) (Wever et al. 2023).
In 1974, the Netherlands initiated the establishment of PRTR, evolving it
into a robust national database for emissions. (Ruyssenaars et al. 2007;
Wever et al. 2023).
Task forces, including ENINA, MEWAT, TgL, V&V, and WESP, oversee
the meticulous collection, processing, and validation of emission data,
ensuring a unique dataset. Since 2010, point source emissions have
been electronically submied, emphasizing consistency and validation
under the ENINA task force (Wever et al., 2023).
The E-PRTR directive mandates approximately 1,000 Dutch facilities
to report emissions, supplemented by estimates for comprehensive
coverage. Recent enhancements integrate GIS and web-based tools,
enabling online updates and facilitating public access.
The transition from the Pollutant Emission Register (PER) to PRTR
signifies a shi towards increased public engagement and adherence
to international standards. The PER, initiated in 1974, monitors nation-
al-scale emissions, with dedicated task forces collecting data for
diverse sectors (Ruyssenaars et al. 2007; Wever et al. 2023).
Annual updates of emission estimates for 375 compounds use coun-
try-specific methods and have been coordinated by the Emission
Registration team at the National Institute for Public Health and the
Environment (RIVM) since 2010. The PRTR aims to maintain up-to-date,
transparent, and accurate emission data (Wever et al., 2023). In 1997,
PRTR included the emission data for about 170 substances, including
waste, listed in Annex (see Annex 2, subchapter 6.2) (Evers 1997).
Organized by sectors, task forces conduct annual trend analysis for
data collection, processing, and validation. Point source emissions,
monitored since 2010, contribute to the PRTR database. Integrating
GIS and web-based tools, the PRTR facilitates online updates, public
access, policy-making, and international reporting (Wever et al., 2023).
Ongoing developments addressed the increasing demand for detailed
data at various levels. The Netherlands adapts to international require-
ments, emphasizing transparency, consistency, and comparability in
emission inventories. Aention to emission data quality intensifies at
Photo 2.22: The incinerator in Lunel-Viel is likely to cause serious
illnesses. Professor Dominique Belpomme identified the incinerator
as the reason for the increased number of cancer cases in 2015.
Large waste incinerators are among the pollution sources reported
to the PRTR system, even in France. Source: (Goyon 2015)
Figure 2.3 The organizational
structure of the Netherlands
Pollutant Release and Transfer
Register (PRTR).
Source (Wever et al. 2023)
PRTR Strategic Council
• Ministr y of Infrastructure and Water Management (IenW):
- Air
- Water
• Ministr y of Economic Aairs and Climate Policy' (EZK )
• Ministr y of Agriculture, Nature and Food Quality (LNV)
PRTR Tactical Council
• Statistics Netherlands
• Netherlands Environmental Assessment Agency
• Deitares
• National institute for Public Health and the Environment
• Wageningen University Research
• Head PRTR
Personnel (expertise) through general
agreements and contracts with:
• statistics Netherlands (CBS)
• Rijkswaterstaat:
- water, Trac and Environment
- Centre for Water Management
(WD)
- Centre for Transport and
Navigation (DVS) Human
Environment and Transpor t
Inspectorate (I LI)
• PBL
• TNO
• Wageningen
- Economic Research
- Environmental Research
- Plant Research
- Livestock Research
• De'tares
• Fugro
Ministry of Infrastructure and Water
Management
• Dir. Gen. for the Environment
and International Aairs
• Rijkswaterstaat (RWS)
Ministry of EconomicAairs and
Climate Policy:
• Dir. Climate
Ministry of of Agriculture,
Nature and Food Quality:
• Dir. Gen. for Agriculture
& Nature policy
PRTR executive body (WEM)
• Head PRTR
• Representatives of the contributing institutes
• Taskforce chairmen
Task Force on Agriculture and land use (TGL)
Task Force ENINA (Energy, industry and waste)
Task Force on Trac and transport
Task Force WES P (Service sec tor and product use)
Task Force MEWAT (Emissions to water)
Task Force on Spatial allocation
Working group on
Uniformization manure
numbers (WUM)
Working group on Land
Use, Land Use Change and
Forestry (LULUCF)
Head PRTR
Interaction with
Directorates
of the involved
ministries
30 | Pollutant Release and Transfer Register and Civil Society
national and regional levels, underscoring emissions’ role in evaluating
environmental policy. The PRTR database, managed by RIVM, collaborates
with contributing research institutes to store emission data eectively.
Each contributing institute is responsible for data collection, emission
calculations, and quality control. These are laid down in general.8
In comparison to the E-PRTR, the Dutch PRTR encompasses a broader
range of substances, with a notable focus on air emissions. However,
it distinctly lacks information concerning the transfer of chemical
substances in waste. Specifically, details about chemical substances
in waste are absent, as the information about waste types in the Dutch
PRTR cannot substitute for this critical data.
The sophisticated PRTR system in the Netherlands is described in the
diagram in Figure 2.2 and its flow chart in Figure 2.3.
The Dutch authorities have developed a special guide for facility oper-
ators to calculate their emissions for reporting to the PRTR, called the
"Methodology Report on the Calculation of Emissions to Air from the
Sectors of Energy, Industry, and Waste," as used by the Dutch Pollutant
Release and Transfer Register (Honig et al. 2021). This is a very useful
tool for proper reporting into the PRTR system.
8 Emission data is produced in annual (project) cycles. In addition to RIVM, various ex-
ternal agencies/institutes contribute to the PRTR by performing calculations or submit-
ting activity data: 1) Netherlands Environmental Assessment Agency (PBL); 2)Statistics
Netherlands (CBS); 3) Netherlands Organisation for applied scientific research (TNO);
4) Rijkswaterstaat; Water, Trac and Environment (RWS-WVL); 5) Deltares; 6) Wagen-
ingen University & Research (WUR), Statutory research tasks: − Wageningen Environ-
mental Research (WEnR); − Wageningen UR Livestock Research (WLR); − Wageningen
Economic Research (WEcR); − Wageningen Plant Research (WPR).
Each of the contributing institutes has its own responsibility and role in the data collec-
tion, emission calculations and quality control. These are laid down in general agree-
ments with RIVM and in the annual project plan (Wanders, 2021).
2.4 PRTRs in Other Developed Countries
In this section, we will briefly address PRTR systems in other countries
that are not members of the European Union, which is already covered
in the previous section. Several countries that are discussed in this
section are the United States, Canada, Japan, and Korea.
Figure 2.4 The data flow in the Netherlands Pollutant Release
and Transfer Register (PRTR). Source: (Wever et al. 2023)
Activity data
Statistics
Netherlands
etc.
Collective
industrial
sources
(Task Forces
PRTR)
Geographical
distribution
data
Area/diuse
sources
(Task Forces
PRTR)
Emission
factors
(Literature,
measure-
ments)
(Task Forces
PRTR)
(Electronic)
Annual
Environmental
Reports (AER)
(Individual
facilities)
AER
database
PRTR
database
ER-I database
(Task Forces
PRTR)
Pollutant Release and Transfer Registers (PRTRs) | 31
2.4.1 Toxics Release Inventory in USA
PRTR system in the United States is addressed through the Toxics Release
Inventory (TRI) policy (USEPA 2023b), which requires industries that
belong to the 11 major group industry codes in the US Standard Industrial
Classification (SIC) to report their toxic chemical release, where one of
the codes is further described in certain sub-sector codes in the North
American Industry Classification System (NAICS).9 Based on their activity,
these industries must report certain chemicals listed in 200+ required
chemicals. The latest required chemicals addition in 2022 was PFOS, PFBS,
potassium-PFBS, and chemicals with CAS No. 203743-0307 (USEPA 2022a).
The information on the characteristics of these chemical pollutants is
also accessible through their multiple national databases, including the
TRI-CHIP (TRI-Chemical Hazard Information Profiles) among other avail-
able referable databases (USEPA 2022b), (USEPA 2022a). The information
on the characteristics of these chemical pollutants is also accessible
through their multiple national databases, including the TRI-CHIP
(TRI-Chemical Hazard Information Profiles) among other available refer-
able databases (USEPA 2022b), (USEPA 2022a). The information on the
characteristics of these chemical pollutants is also accessible through
their multiple national databases, including the TRI-CHIP (TRI-Chemical
Hazard Information Profiles) among other available referable databases
(USEPA 2022b). The information on the characteristics of these chemical
pollutants is also accessible through their multiple national databases,
including the TRI-CHIP (TRI-Chemical Hazard Information Profiles) among
other available referable databases (USEPA 2022b).
More information about the history of TRI development in the USA was
included in chapter 2.1 History of PRTR of this Guide.
2.4.2 National Pollutant Release Inventory (NPRI) in Canada
The National Pollutant Release Inventory (NPRI), established in 1992
and launched in 1993, is Canada’s national pollutant release and
transfer register (Johnston Edwards and Walker 2019; Taylor et al. 2020).
Facilities that meet reporting requirements must report to the NPRI
under the Canadian Environmental Protection Act, 1999 (Canada 1999).
9 40 CFR Part 372 § 372.22
Photo 2.23: Abel Arkenbout has been monitoring the long-term
operation of the municipal waste incinerator in Harlingen, the
Netherlands. His studies have focused, among other things, on how
dioxin emissions are monitored, showing that, for example, estimates
of dioxin emissions vary significantly between one-time measurements
and semi-continuous measurements using the Ames system. (Arkenbout
et al. 2018; Arkenbout and Petrlik 2019) This, of course, also aects data
reporting to the PRTR. Photo taken during poster presentation at Dioxin
Conference 2018 in Krakow, Poland. Photo: Jindrich Petrlik, Arnika
32 | Pollutant Release and Transfer Register and Civil Society
As of 2021, there were 320 pollutants on the NPRI list, including volatile
organic compounds (VOCs), toxics like mercury, lead, polycyclic aromatic
hydrocarbons (PAHs), dioxins and furans, etc. Over 7,191 facilities nation-
wide reported 4.99 million tonnes of pollutants for 2021. These facilities
include the chemical industry, oil and gas sector, electricity, mining and
quarrying, iron and steel, and government facilities such as incinerators,
landfills, and sewage treatment plants (CELA 2023).
The facilities must report on their:
• release of pollutants to air, surface waters, and on land;
• disposal on-site, such as in landfills, land application, deep well
injection, and mining tailings and waste rock;
• o-site transfer for treatment and disposal and
• o-site transfers for recycling (CELA 2023).
Some of the NPRI’s valuable features are:
• it provides the public with facility-specific data for each pollutant;
• the data is reported by each polluter annually;
• the polluters are required by law to report and can be charged if
they fail to do so, and
• the data is available to the public through the NPRI website.
The NPRI Multi-Stakeholder Working Group has been established. The NGO
representation in that group includes current members from the following
groups: Canadian Association of Physicians of the Environment (CAPE),
Canadian Environmental Law Association (CELA), Citizens’ Network on Waste
Management, Keepers of the Water, Mining Watch Canada, Watershed Senti-
nel Education Society and New Brunswick Lung Association (CELA 2023).
2.4.3 PRTR in Japan
Japan implemented PRTR in 2002, although it was established in its
legislation earlier (MoE-GoJ 2007). The implementation was stimulated
by the OECD’s recommendation in 1996 and went through several
processes, from establishing a technical advisory commiee, bill
submission, nationwide concept introduction, interim evaluation, and
full implementation for six years (MoE-GoJ 2007). Its implementation
began by enacting the Act on Confirmation, etc., of Release Amounts
of Specific Chemical Substances in the Environment and Promotion of
Improvements to the Management Thereof in 1999. The Environment
Agency of Japan (which later became the Ministry of the Environment,
MOE) started a pilot PRTR project in 1998 (Yamaguchi 1999), covering
30 cities and about 2000 facilities. This ran for three years before the
system was implemented nationally (Nakachi 2010).
Japanese government requires 462 chemicals in their Class I and
another 15 substances in their Specified Class I Designated Chemical
Photo 2.24: Kawasaki Industrial Area, 2014.
Photo: Darwin via Wikimedia Commons
Figure 2.5 The Japanese PRTR system. Source: (MoE-GoJ 2007)
34 | Pollutant Release and Transfer Register and Civil Society
Substances to be reported by the relevant 24 types of industry (MoE-GoJ
2007). These data, both the compiled data and the outline of the result,
are available publicly on their PRTR data page (MoE-GoJ 2023).
The significance of the PRTR system, as outlined by the Japanese Ministry
of Environment, encompasses several key aspects (MoE-GoJ 2007):
• Obtainment of Basic Data for Environmental Conservation:
The system provides essential data that forms the foundation for
environmental conservation eorts.
• Determination of Priorities in Administrative Measures: It aids
in determining priorities for administrative measures related to
chemical substances.
• Promotion of Voluntary Improvement: The PRTR system
promotes voluntary improvement in the management of chemical
substances by business operators.
• Provision of Information to the Public: The system provides
information to the public, fostering their understanding of
chemical substances.
• Understanding the Eect of Environmental Conservation
Measures: It facilitates understanding the impact of environmen-
tal conservation measures and the improvements brought about
by them.
In 2010, the non-governmental organization Toxic Watch Network
provided an overview of the system (Nakachi 2010), noting that data
at the individual facility level were available, with over 34,830 reporting
sites in 2001. The sheer volume of data, exceeding 30,000 pages if
printed, prompted considerations for more accessible dissemination.
“However, the data can be recorded on a CD-ROM in a format for
upload into a database or spreadsheet program. The disk costs only
JPY 1,090 (= approximately 10 euros), an aordable amount in Japan.
Nevertheless, it became an issue for review because the national gov-
ernment was supposed to freely disseminate the data to engage with
citizens and empower them.“ (Nakachi 2010)
Mizutani (2013) evaluated the state of the Japanese PRTR as follows:
“This system is expected to aid in reducing the amount of toxic chemi-
cals being released along with the associated environmental risks. For
Japan’s fiscal year 2011, based on the national PRTR system, 36,638
business entities reported chemical substance amounts being released
and transferred. The total amount released was approximately 174
thousand tons, and the total transferred amount was approximately
225 thousand tons, for an amount of 399 thousand tons released and
transferred in total.”
Since the establishment of the PRTR system in Japan, there has been a
tendency for the total amounts of released and transferred substances
to decrease. This suggests that the system has played a role in contrib-
uting to the reduction of environmental risks associated with these
chemical substances. As highlighted, moving forward with PRTR requires
consideration of several key issues: “1) how to develop/revise a method
for estimating the chemical amounts that have not been reported by
certain sectors, such as waste treatment facilities; 2) how to properly
promote alternatives to chemicals that can work as safe substitutes; and
3) how consumers and waste industries can have access to information
on these chemicals using PRTR data.” (Mizutani 2013)
2.4.4 PRTR in the Republic of Korea
The Japanese NGO Toxic Watch Network described Korea’s Toxics
Release Inventory (TRI) system in 2010: “Korea introduced a PRTR system
earlier than Japan, from 1996. The Korean system is called the Toxics
Release Inventory (TRI). At the “Symposium regarding international
trends for chemical substances” held by the Ministry of the Environment
Pollutant Release and Transfer Registers (PRTRs) | 35
of Japan in March 2007, a manager for the Chemical Substance Safety
Department in the Ministry of Environment of the Republic of Korea
described the TRI as a system which imposes duties on corporations to
report quantities of chemical substances released into the environment
during production and use. Corporations shall also report amounts
transferred for recycling and disposal. The Korean TRI covers 388
chemical substances, and sites that deal with or produce more than 100
kg of chemical substances must report the amounts. It was also reported
that while the handling amounts were 372,250 tonnes and the released
amounts were 16,243 tonnes in 2001, in 2005, the handling amounts were
454,910 tonnes, and the released amounts were 7,750 tons. Although the
handling amounts had increased by 22.2%, the released amounts were
drastically reduced by 53.5%.
According to a survey conducted in 2006, the number of sites that
reported data was 2,829.
A unique feature of the Korean TRI system is that the registered data
has not been disclosed since 1996, when the system was introduced.
Meanwhile, European countries, the US, and Japan all publish their
data through various media such as websites, CDCDs, and reports.
The Korean MOE shows only the total handling amounts and release
amounts (aggregated at the national level) on their website. These data
are published (in pdf format) in Korean. Toxic Watch visited Korea in
March 2010 for research and found that even citizen groups working on
environmental issues did not know of the existence of the TRI system
because the Korean government does not make the data public."
(Nakachi 2010)
The ocial Korean PRTR site in English contains aggregated data for 2001
– 2012 only (NICS 2014). More specific data on various industrial sectors
can be downloaded in PDF format from the PRTR website (NICS 2014).
2.5 PRTRs in some Developing and Low-Middle
Income Countries
Apart from the PRTR implementation in developed nations, we will
also address the implementation of PRTR systems in developing and/
or Low-Middle Income Countries (LMIC), which include, for example,
Chile, Colombia, Bosnia and Herzegovina, Tajikistan, Kazakhstan,
Moldova, and Thailand.
2.5.1 PRTR in Chile
In Chile, voluntary reports of emission and waste transfers, including
121 pollutants and nine physical and biological parameters, are submit-
ted to the government. Its implementation was established through the
regulation Administración del Registro de Emisiones y Transferencias
de Contaminantes (The Management of the Registry of Emissions and
Transfers of Pollutants) in 2010. There are two main pieces of informa-
tion in the Chilean PRTR system: those associated with point and non-
point sources. The point sources information collect information on air
emissions, hazardous waste generation, water discharge (surface and
marine waters), and transfers to the sewage system, while the laer
collects emissions from transportation, agriculture burning, forest fire,
urban fire, as well as urban and rural firewood estimation (Ministerio del
Medio Ambiente 2022).
2.5.2 PRTR in Colombia
Over the past 20 years, Canada has assisted Colombia in building the
capacity to develop and implement PRTR (ECCC 2019). The implemen-
tation of the PRTR system itself has been embedded into several policy
documents throughout the years, including Colombia National Action
Plan (2013-2020) and Environmental Performance Review (2014), to
name a few (Alarcón 2020). According to the 8th meeting of the Working
Group of the Parties to the Protocol on PRTRs on 18th December 2020,
36 | Pollutant Release and Transfer Register and Civil Society
Colombia planned to develop a pilot test of the PRTR with productive
sectors and environmental authorities in 2019-2020 and the issuance of
the regulation in 2020-2021. Although the PRTR in Colombia had not yet
been launched in 2020 (Alarcón 2020), in 2022, the OECD assessed the
task of implementing the PRTR as fulfilled (OECD 2022.
2.5.3 PRTR in Bosnia and Herzegovina
However, even though, in 2009, the EU financed a 1,200,000 EUR
project to implement the EU PRTR Directive in BiH (European Com-
mission 2009; Zahumenská et al. 2015), its enforcement was far from
satisfactory. A new server and soware were purchased, but only a
single Federal Ministry of Environment and Tourism employee was
entrusted with the password to access the data (Bjelić et al. 2017).
Instead of publishing the information from the register in a publicly
accessible manner, access to it is limited to individual requests filed
with the Ministry. Requests are usually answered aer long delays, and
applicants oen receive the information too late to be able to use it
in decision-making procedures. Moreover, the system only covers the
Federation of Bosnia and Herzegovina (FBiH while Republika Srpska
(RS) and Brčko District (BD) are developing self-standing schemes. It
is of great concern that no progress has been noted throughout the
reporting period (Bjelić et al. 2017).
More information about PRTR in Bosnia and Herzegovina is in a case
study in subchapter 4.1.4.
2.5.4 PRTR in Tajikistan
Tajikistan is a mountainous landlocked country in Central Asia, where
agricultural pollution has become the main environmental issue. In
May 2006, Tajikistan joined “The Kyiv Protocol on Pollutant Release and
Transfer Registers,” referring to the Aarhus Convention, which then
established its PRTR working group under the State Commiee for
Environmental Protection and the Forestry of the Republic of Tajikistan
(Aarhus Center - Republic of Tajikistan 2008). Despite the signing of
the PRTR and acknowledging the importance of monitoring pollutant
releases to be publicly accessible, the creation of the PRTR itself is a
challenging task for Tajikistan. Eorts have been taken to transform
the initiative into a real paper, for instance, participating in “Enhancing
Capacity Building for the Development of the National Registers of Pol-
lutant Release and Transfer in Two Countries in Transition: the Republic
of Belarus and Republic of Tajikistan under the Aarhus Convention”
project from 2011 to 2013 resulting in several key points to accelerate
Photo 2.25: The metallurgical complex in Zenica (in the photograph
from 2014) is among the largest polluters in Bosnia and Herzegovina.
This was confirmed by the results of analyses of dioxins and other POPs
in free-range chicken eggs conducted by Arnika in 2015 (Petrlik and
Behnisch 2015). Photo: Martin Plocek, Arnika
Pollutant Release and Transfer Registers (PRTRs) | 37
the realization. However, no PRTR has yet been established, with the
absence of funding as the main reason (UNECE 2017).
Civil society is oen not included in the consultations about establish-
ing PRTRs in the countries (Alarcón 2020). This approach excludes a
critical stakeholder of PRTR.
2.5.5 PRTR in Kazakhstan
On January 27, 2020, Kazakhstan joined the UNECE Protocol on PRTRs,
becoming its 37th Party and marking a crucial step for environmental
transparency in Central Asia (UNECE 2020). Before 2020, discussions
focused on creating a working PRTR, involving a decade-long eort with
achievements and challenges (Mogilyuk 2017).
In 2013, voluntary reporting from 134 facilities provided valuable environ-
mental data, but analysis revealed a concerning trend – about 90% of the
data contained errors. Common mistakes included reporting pollutants
below limits and confusing air and water pollutants (Mogilyuk 2017).
Photo 2.27: The Kazakhstani PRTR (Pollutant Release and Transfer
Register) includes only releases, but industrial operations’ waste
contains a significant amount of toxic substances. These substances
can then accumulate in fish or chicken eggs, as demonstrated by
Arnika’s studies (Petrlik et al. 2015a; Petrlik et al. 2016; Petrlik et al.
2015b). The photograph shows the sampling of ash storage in Temirtau
in 2013. Photo: Ondřej Petrlík, Arnika
Photo 2.26: Like Bosnia and Herzegovina, steel mills are among the
largest polluters in Kazakhstan. The photograph shows Mial Steel’s
steelworks and coking plant in Temirtau in 2013. Photo: Ondřej Petrlík,
Arnika
38 | Pollutant Release and Transfer Register and Civil Society
Recommendations by the Eco Forum of NGOs of Kazakhstan aimed to
address these challenges. They included operator consultations, robust
data verification, mandatory reporting, focusing on emissions exceed-
ing limits, an online reporting form, and capacity building for media and
the public (Mogilyuk 2017).
The rules for maintaining the state register of pollutant emissions,
approved by the Ministry of Energy dated 10 June 2016 No. 241, estab-
lish the list of substances reported by the PRTR. It contains information
on the volume of both actual air emissions of pollutants for 60 sub-
stances and water emissions for 62 substances (OECD 2019).
As of 2017, Kazakhstan had not ratified the PRTR Protocol to the Aarhus
Convention and was still in the process of forming a PRTR system. With
778 nature users providing reports, the system lacked real-time emis-
sions ranking, industry-specific information, and comprehensive national
coverage. The PRTR system, operating in a pilot mode, faced challenges
in providing accurate and transparent information about emissions.
Information was presented only by region. And some enterprises in some
regions are not represented in the PRTR system at all. For example, the
system does not issue reports for Pavlodar and Turkestan (OECD 2019).
In conclusion, discussions before 2020 emphasized the need for a func-
tional PRTR in Kazakhstan. Transparency, accuracy, and stakeholder
engagement were recognized as essential elements for the success of
the PRTR in the country.
2.5.6 PRTR in Moldova
The Central Laboratory of the Chisinau Ecological Agency under SEI
monitored air, soil, and water quality, while SEI and ecological inspec-
tions maintained data on economic agents in their Annual Report.
The “Apele Moldovei” Agency managed water-related policies, and
the Sustainable POPs Management Oce under the WB/GEF Project
handled contaminated sites and PCB data. The Environment Pollution
Prevention Oce of the Ministry of Environment was involved in
draing chemicals and waste-related legislation (Isac et al. 2016).
The Climate Change Oce focused on UNFCCC reports, and the Ozone
Oce oversaw the phase-out of Ozone Depleting Substances. The
National Bureau of Statistics (NBS) collected environmental data, but
evaluations indicated issues meeting UNECE requirements (Isac et al.
2016). Moldova aimed to establish a PRTR by 2020, facing challenges
involving economic agents and NGOs. Since 2013, steps have included
project proposals, working group formation, and awareness eorts.
Recommendations stressed creating a legislative framework, promot-
ing the dra Law on Access to Environmental Information, and aligning
laws with the IPPC Directive. Proposals included an integrated report-
ing procedure with a designated competent authority for streamlined
data flow and beer environmental decision-making (Isac et al. 2016).
The 2019 presentation outlined steps toward PRTR establishment, involving
legal frameworks, infrastructure development, capacity building, and inter-
national reporting. However, funding challenges post-2017 impacted the
operational status of the PRTR in Moldova (Republic of Moldova 2018b; Tugui
2019), suggesting a hiatus despite indications of functionality in 2018/2019.
Reports by individual facilities are available on the ocial website.
However, only data for the years 2015 – 2017 is available (Republic of
Moldova 2018b). So, it seems that with the end of funding from multi-
lateral funds, the PRTR stopped its operation in Moldova, although it
seemed to be fully functional and ready to start in 2018/2019.
This situation was confirmed by the EU4Environment Report published
in 2022 (EU4Environment 2022). The electronic PRTR register was
Pollutant Release and Transfer Registers (PRTRs) | 39
developed in 2016, and the number of registered operators increased
significantly in subsequent years. In 2017, 75 operators joined, followed
by 188 in 2018. Moldova also adopted a regulation on the national PRTR
in 2018. However, as of November 2020, the transfer of PRTR manage-
ment from the Oce of Air Pollution to the Environmental Agency
faced operational challenges, rendering the PRTR non-operational
(EU4Environment 2022).
Data contributors to the PRTR include registered operators reporting
emied or transferred pollutants, the Inspectorate for Environmental
Protection (for non-sanitary or illegal landfills), the Apele Moldovei
Agency (concerning aquatic resources), the National Agency for Food
Safety (related to phytosanitary products, fertilizers, livestock farms,
and wastewater disposal), the Public Services Agency (providing data
on registered cars and engine types), and the National Bureau of Statis-
tics (contributing to the energy balance); (EU4Environment 2022).
The Environmental Agency serves as the information register for the
PRTR, handling primary registration, data updates, and removals. The
inspectorate is responsible for diusing pollutants, demonstrating the
complex data management structure of the PRTR system in Moldova
(Republic of Moldova 2018a).
Plans for the solution are as follows: “There are plans to integrate the
PRTR with various other information systems through the interopera-
bility platform MConnect. There are also plans to elaborate a Guide to
Facilitate the Implementation of the National PRTR. This would indicate
the types of activities to be monitored, methodology, indicators, data
recording instructions and deadlines for sending the data.
It will be important to have a mechanism for checking reports to the
PRTR. This could, for example, compare information provided against
records required for permits, inspections, and samples from the Refer-
ence Laboratory. The Inspectorate for Environmental Protection should
be a recipient of the data, which can feed into its risk assessment
process.” (EU4Environment 2022)
The situation in Moldova appears to be similar to that in the Czech
Republic when the introduction and initial years of operation of the IRZ
system faced challenges in coordinating the reporting of environmental
data into various inadequately coordinated databases, such as the air
pollution register, hydrological register HEIS, etc. (see subchapter 5.3).
2.5.7 PRTR in ailand
The Map Ta Phut Industrial Estate (MTPIE) in Thailand is part of the
Eastern Seaboard Development Program, which aims to boost indus-
trial growth. However, this progress has led to environmental and public
health issues due to industrial pollution. Ongoing eorts to regulate
and improve the situation involve both public and private sectors, but
concerns persist in society. In 2011, the Japan International Cooper-
ation Agency (JICA) initiated a PRTR pilot project in Rayong province
in collaboration with Thai environment NGO EARTH (Ecological Alert
and Recovery Thailand), the Pollution Control Department, the Depart-
ment of Industrial Works (DIW), and the Industrial Estate Authority of
Thailand to address these concerns (Enviliance Asia 2022).
The pilot scheme targets 107 substances from 7 categories of point
sources (refinery, chemical/petrochemical, automobile and auto part
industry, fabricated metal, wood/furniture, electrical machinery, plastic,
and rubber) and non-point sources (mobile sources, agriculture, con-
struction/paint, small industry, other industry outside point source, e.g.,
gas station and households); (PCD and JICA 2014). The pilot implemen-
tation was expanded to cover two more provinces, Samutprakarn and
Chonburi, between 2017 and 2019.
40 | Pollutant Release and Transfer Register and Civil Society
A study conducted in Thailand revealed that stakeholders had mis-
understandings about the private sector’s implementation of PRTRs
(Kondo and Limjirakan 2013). Concerns were raised about costs, tech-
nical issues, and data confidentiality. Despite these concerns, most
petrochemical companies expressed willingness to adopt PRTR, while
some were hesitant due to cost, technical barriers, and stakeholder
understanding of the scientific nature of the data. Additionally, the dis-
cussion included the possibility of including non-point sources in the
PRTR. However, some companies expressed willingness to participate
Photo 2.29: Khon Kaen in Thailand hosts, among other things,
a paper mill. Here is the discharge of wastewater from the canal of
this operation. The planned PRTR should also cover emissions of toxic
substances from such discharges (Mach et al. 2017).
Photo: Jindřich Petrlík, Arnika, 2016
Photo 2.28: Industrial operations in Tha Tum, Thailand, undoubtedly
belong among those that should not be missing among those reporting
to the planned PRTR. For instance, high mercury concentrations were
found in fish from the Shalongwaeng Canal near a coal power plant
(Saetang et al., 2013). Photo: Ondřej Petrlík, Arnika, 2016
Pollutant Release and Transfer Registers (PRTRs) | 41
despite this concern, citing other reasons, such as limited scientific
knowledge among stakeholders.
Compared to Japan’s PRTR, the PRTR in this pilot project in Thailand
reported fewer substances and limited the number of point sources
to 7 categories due to the small scale in only two provinces. Despite
being a pilot project, it has received good cooperation from business
operators in both provinces, including voluntary submission to PRTR
reporting. The top pollutants found in Rayong Province were toluene,
N-hexane, xylenes, methanol, and isopropyl alcohol. In Samutpra-
karn Province, the top pollutants were toluene, isopropyl alcohol,
xylenes, ethyl acetate, and zinc. In 2017, the PRTR system extended
to Chonburi Province, identifying toluene, n-pentane, and xylenes as
pollutants. The data collected between 2013 and 2017 indicates that
the industrial sector has significantly improved its understanding and
reporting capabilities. In Rayong Province, the emissions of the top
three pollutants decreased annually from 2015 to 2017. This reduction
may be aributed to the successful implementation of the PRTR
system, which mandates the industrial sector to increase awareness
and voluntarily reduce emissions (Enviliance Asia 2022). However, no
emission reporting and transfer data for point sources and emission
estimation of non-point sources from the pilot scheme have been
released for public access.
The Ministry of Industry aims to limit the future enforcement of PRTR
from national legislation to ministerial notification and to refrain from
public disclosure of individual facilities’ emission data. In September
2022, the Thailand Ministry of Industry opened the latest dra, "Notifi-
cation of Ministry of Industry: Reporting Pollutant Release and Transfer
Register (PRTR), B.E.25XX" for public consultation, which it was planned
to come into enforcement in January 2023 (Umeyama 2022), but yet
being enforced until the end of 2023.
By the way, in March 2022, Greenpeace Thailand, Enlaw, EARTH,
Northern Region Breath Council and Chiang Mai Breath Council filed
a lawsuit in court against the National Environment Board and two
ministries (Natural Resources and Environment and Industry) for
failing to step up action on the PM2.5 crisis. The measures have fallen
behind the implementation outlined in the Driving National Agenda
on "Solving the Problem of Particulate Maer," resulting in the state’s
failure to protect public health. Surachai Trong-ngam, secretary of the
Environmental Law Foundation, stated that the website aims to provide
the public with easy access to information on the amount and type of
pollutants from dierent sources. According to Greenpeace Southeast
Asia (2023), he also mentioned that PRTR could help Thailand deal with
air pollution more eectively.
2.6 List of Existing PRTR Websites
Australia: hp://www.npi.gov.au/(oficial site)
Austria: hps://secure.umweltbundesamt.at/PRTR-web/state.
do?stateId=APP_START (German)
Canada: hps://www.canada.ca/en/services/environment/pollu-
tion-waste-management/national-pollutant-release-inventory.html
(ocial site)
hps://cela.ca/community-right-to-know/ (civil society website by
CELA)
Chile: hps://retc.mma.gob.cl/ (Spanish)
Croatia: hp://roo-preglednik.azo.hr/Default.aspx (Croatian)
Cyprus: hp://www.prtr.dli.mlsi.gov.cy/prtr/iweb.nsf/ContentDocsBy-
Country/Greek (Greek, English)
Czechia: hp://www.irz.cz/ (Czech)
hp://znecistovatele.cz/ (civil society website by Arnika Association,
Czech only)
42 | Pollutant Release and Transfer Register and Civil Society
Denmark: hps://datacvr.virk.dk/data/ (Danish)
Finland: hps://www.ymparisto.fi/en/pollution-and-environmen-
tal-risks/clean-air/air-pollutant-emissions-finland/prtr-non-point-
source-emissions (Finish, English)
France: hps://www.georisques.gouv.fr/risques/registre-des-emis-
sions-polluantes/etablissement/donnees#/ (French)
Germany: hps://thru.de/ (German)
Israel: hps://www.gov.il/en/departments/topics/prtr/govil-land-
ing-page (English and Hebrew)
Japan: hp://www.prtr.nite.go.jp/index-e.html(ocial site)
hp://toxwatch.net/ (civil society organization Toxic Watch Network
site in Japanese, available also in English version but only until 2012)
Korea: hps://icis.me.go.kr/prtr/english.do# (English)
Malta: hps://era.org.mt/topic/prtr/ (English)
Moldova: hps://retp.gov.md/#/ (Romanian)
Netherlands: hp://www.emissieregistratie.nl/(Dutch)
Norway: hps://www.norskeutslipp.no/ (Norwegen)
Romania: hp://prtr.anpm.ro/Main.aspx (Romanian)
Slovakia: hp://nrz.shmu.sk/index.php (Slovakian)
Spain: hp://www.eper-es.es/ (Spanish)
Sweden: hps://utslappisiror.naturvardsverket.se/en/Search/
(English)
Switzerland: hp://www.bafu.admin.ch/chemikalien/prtr/index.htm-
l?lang=en (English, German)
Thailand: hps://thaiprtr.com/ (civil society organizations website to
support PRTR in Thailand, Thai version only)
USA: hp://www.epa.gov/tri(ocial site)
hp://www.rtknet.org/(civil society organizations The Right-to-Know
Network)
UK: hps://www.gov.uk/guidance/uk-pollutant-release-and-trans-
fer-register-prtr-data-sets (English)
2.7 Comparison of the Eciency
Between Various PRTRs
Kerret and Gray (2007) compared PRTRs in the United States, Canada,
England, and Australia. Their analysis came with interesting outcomes:
“The results from the four studied countries suggest that there is no
consistent relationship between various surrogate measures of risk
and mass emissions. In some cases, reductions in mass may never-
theless increase risk. This could happen while reductions are focused
on chemicals with a lower risk coecient while, at the same time, the
amounts of more risky substances are on the rise. These results support
further research to unravel the reasons behind the dierences among
the countries and the relations between risk and mass trends." (Kerret
and Gray 2007). It also supports previous work that implies that risk and
emissions are not necessarily correlated (Gray 1999). Another practical
aspect of these findings is additional support for the suggestion to
include risk categorizations in the PRTRs (Karkkainen 2019).
Reporting emissions according to their potential risk may increase the cor-
relation between risk and reductions. This aspect can be very well demon-
strated by the releases of substances such as dioxins, which are measured
in fractions of grams. While this may not significantly aect the overall
number of reported releases and transfers in PRTR, these are highly hazard-
ous substances from a risk perspective. Saving every gram released into the
environment can impact millions of people’s health (EFSA CONTAM 2018;
Petrlik et al. 2022a; Petrlik et al. 2021). Dierentiating between risk levels
may increase the focus of reporting facilities on reducing the emissions of
higher-risk substances, concluded Kerret and Gray (2007).
The analysis of the four studied countries suggested that there are sig-
nificant variations between the trends in air emissions as represented
by the national PRTRs: “Clearly, the presence of a PRTR does not auto-
Pollutant Release and Transfer Registers (PRTRs) | 43
matically lead to reductions in air emissions of the target chemical. The
United States and England show consistent reductions in emissions on
many dierent measures. At the same time, it seems that the Canadian
NPRI system did not have a similar eect, and air emissions increased
for some measures and decreased in others. Australia saw increased
emissions by most measures. The laer evaluation clearly shows that
further research is required to assess the benefits of the PRTR approach
to environmental management and, if desired, to identify factors that
influence PRTR” (Kerret and Gray 2007).
From the perspective of civil society, in analyzing and comparing the
PRTR systems in those four countries, it is important to note that in
the USA and England, very active NGOs used PRTR to exert pressure
to reduce emissions from industrial operations (Taylor 2004; Working
Group on Community Right-To-Know 1991; Working Group on Com-
munity Right-To-Know 1997). To be objective, we must acknowledge
that in Canada, CSOs also engaged in campaigns related to PRTR
(CELA 2023; Environmental Defence and CELA 2004) data and used a
system similar to Friends of the Earth UK (OECD 2000; UNITAR 2003),
but such a campaign did not take place in Australia. The US EPA
also announced the so-called 33/50 Program in the USA and actively
utilized TRI data (Bi and Khanna 2012; Khanna and Damon 1999;
USEPA 1991).
44 | Pollutant Release and Transfer Register and Civil Society
UNITAR Guidance gives a very good overall picture of the international
framework of multilateral agreements and/or UN global initiatives
related to PRTRs to a certain extent. Some of them build a base for
establishing PRTRs in whole UN regions (UNITAR 2018) and or support
their development globally (OECD 2023b).
3.1 Principle 10 of the Rio Declaration
United Nations Conference on Environment and Development
(UNCED) provided specific references to establishing national
emission inventories and the right of the public to access this
information. Principle 10 of the Rio Declaration aims to safeguard
the right to a healthy and sustainable environment for present and
future generations. This principle also bridged the government’s
accountability with environmental protection. It states that “envi-
ronmental issues are best handled with the participation of all
concerned citizens” and that “each individual shall have appropriate
access to information concerning the environment that is held by
public authorities, including information on hazardous materials and
activities in their communities, and the opportunity to participate in
decision-making processes.” In addition, “states shall facilitate and
encourage public awareness and participation by making informa-
tion widely available.”10 This Principle will lay the ground for PRTRs.
The Agenda 21 was also adopted during the UNCED-2. Through Chapter
19, which addresses the environmentally sound management of toxic
chemicals, Agenda 21 recommends that “governments and relevant
international organizations with the cooperation of industry should
improve databases and information systems on toxic chemicals, such
as emission inventories programs.” Chapter 19 also states that govern-
ments should “consider adopting community-right-to-know or other
public information dissemination programs as possible risk reduction
tools.” Without such requirements, “industry should be encouraged
to adopt, on a voluntary basis, community right to know programs...
including sharing of information on causes of accidental and potential
releases ... and reporting on annual routine emissions of toxic chemi-
cals to the environment.” (UNITAR 2018)
10 hps://leap.unep.org/en/knowledge/glossary/access-information
3. Multilateral Agreements,
Inter-governmental Organizations
and PRTR
Multilateral Agreements, Inter-governmental Organizations and PRTR) | 45
3.2 OECD
US delegation at the UNCED Conference in Rio in 1992 recommended
including the PRTR system in the tools of Agenda 21. The OECD
developed Recommendations for Governments to Implement PRTR
Systems. In 1996, the OECD Council adopted its “Recommendation
of the Council on Implementing Pollutant Release and Transfer
Registers” (OECD 2001), which was revised in 2018 (OECD 2023c).
Through this recommendation, the OECD encourages Adherents (i.e.,
Members and non-members having adhered to the Recommendation)
to design and establish PRTRs through a transparent and objective
process. The Council recommends that Adherents take into account
certain principles in implementing PRTRs, which include fostering
enhanced international comparability of PRTR data by incorporating
core elements such as triggers for reporting based on a harmonized
list of pollutants and sectors, making the data accessible to the public
in a timely and regular basis and in a user-friendly format such as
through an electronic search tool; ensuring the quality and timeliness
of the data; and regularly evaluating the eectiveness of the PRTR
(OECD 2023c; UNITAR 2018).
Since the beginning of its involvement, OECD activities have aimed
at developing practical tools and guidance to help countries install
and implement a PRTR, including providing information and technical
support. Special focus goes on improving PRTR data quality, exploring
PRTR data applications and harmonizing PRTRs across the countries
(OECD 2023b).
OECD work on PRTRs is overseen by the Task Force on PRTRs
(TF PRTRs), composed of experts on PRTR in member countries.
The TF PRTRs activities aim at:
• advise the Joint Meeting of the Chemicals Commiee and the
Working Party on Chemicals, Pesticides and Biotechnology on
specific opportunities and challenges for the implementation
of PRTRs and propose appropriate measures to meet the chal-
lenges, including ways and means for national and international
actions;
• promote communication and a close working relationship be-
tween the Task Force on PRTRs and the Task Force on Exposure
Assessment, as well as relevant organizations on the various
aspects of the PRTR work and
• analyze developments in the field of PRTRs and bring the implica-
tions of such developments to the aention of the member coun-
tries (OECD 2023b).
3.3 Aarhus Convention
The United Nations Economic Commission for Europe (UNECE)
Convention on Access to Information, Public Participation in Deci-
sion-Making, and Access to Justice in Environmental Maers (Aarhus
Convention 2005) was adopted in 1998 in the Danish city of Aarhus
at the Fourth Ministerial Conference as part of the “Environment for
Europe” process.
The Aarhus Convention gives the public certain rights related to the
environment:
• Access to Environmental Information: Everyone has the right
to get environmental information from public authorities. This
includes details about the environment, policies, measures, and
their impact on human health and safety. People can request this
information; authorities must provide it within a month without
asking why.
46 | Pollutant Release and Transfer Register and Civil Society
• Participation in Environmental Decision-Making: Public authori-
ties must let the public and environmental groups give their input
on decisions that aect the environment. This includes projects,
plans, and programs. The authorities must consider these com-
ments and provide information on the final decisions and the
reasons for them.
• Access to Justice: People can challenge public decisions that
ignore the above rights or environmental laws. The Convention
connects environmental rights to human rights, recognizes our
duty to future generations, emphasizes the involvement of all
stakeholders for sustainable development, and links government
accountability with environmental protection. It promotes inter-
actions between the public and authorities in a democratic con-
text (UNITAR 2018).
• The Aarhus Convention is not just about the environment; it’s also
about government accountability, transparency, and responsive-
ness. It grants the public rights and imposes obligations on parties and
authorities for information access, public participation, and justice.
Additionally, it introduces a new process for public involvement in ne-
gotiating and implementing international agreements (UNECE 2019).
3.3.1 Kyiv Protocol
Ensuing from the Aarhus Convention, the Kyiv Protocol on Pollutant
Release and Transfer Registers (adopted in 2003 and entered into force
in 2009) is the first legally binding international agreement on PRTR. It
is the only legally binding international instrument on pollutant release
and transfer registers, meaning that once a country has ratified it, it
must implement a PRTR at a national level. However, the number of
reported chemicals is at the country’s discretion. Its objective is “to
enhance public access to information through the establishment of
coherent, nationwide pollutant release and transfer registers in accor-
dance with the provisions of this Protocol, which could facilitate public
participation in environmental decision-making as well as contribute
to the prevention and reduction of pollution of the environment”
(Article 1). The Protocol covers 64 activities and 86 substances, as well
as categories of substances that must be reported (EUR-Lex 2021).
However, countries can add more chemicals to the list if they want. All
UN Member States can join the Protocol, including those that have not
ratified the Aarhus Convention and those that are not members of the
United Nations Economic Commission for Europe (UNECE). It is, by
design, an ‘open’ global treaty (UNECE 2011; UNITAR 2018).
The protocol requires that a PRTR is based on a reporting scheme that:
• is mandatory;
• is annual;
• covers dierent media, i.e., air, land, water;
• is facility-specific;
• is pollutant-specific for releases;
• Is it pollutant-specific or waste-specific for transfers?
The protocol sets minimum requirements for pollutants and facilities,
and parties can include additional elements (EUR-Lex 2021).
3.4 e Stockholm Convention on POPs
The Stockholm Convention (adopted in 2001 in force since 2004) aims
to safeguard human health and the environment from 32 Persistent
Organic Pollutants (POPs) as of August 2023 (Chasek 2023; Stockholm
Convention 2023).
POPs are long-lasting carbon-based chemicals released into the environ-
ment through human activities. They endure for years, spreading globally
Multilateral Agreements, Inter-governmental Organizations and PRTR) | 47
via air, water, and soil. POPs accumulate in living organisms, especially in
the food chain, posing toxicity to humans and wildlife. This widespread
contamination, spanning generations, leads to chronic health eects.
Bioaccumulation concentrates POPs in higher food chain organisms,
facilitating their travel to distant regions like the Arctic. Exposure to
POPs can result in severe health issues, including cancer, damage to
the nervous and reproductive systems, immune disruption, and endo-
crine disruption, impacting both exposed individuals and their ospring
(Chasek, 2023; Stockholm Convention, 2019).
Given their long-range transport, no single government acting alone
can protect its citizens or its environment from POPs. In response to
this global problem, the Stockholm Convention, adopted in 2001 and
entered into force in 2004, requires its parties to take measures to
eliminate or reduce the release of POPs into the environment (Chasek,
2023; Secretariat of the Stockholm Convention 2008).
3.4.1 Main Provisions of the Stockholm Convention
Key provisions of the Stockholm Convention include:
• Prohibiting/eliminating the production, use, import, and export of
listed POPs (Article 3; Annex A).
• Restricting production and use of listed POPs (Article 3; Annex B).
• Reducing or eliminating releases from unintentionally produced
POPs (Article 5; Annex C).
• Safely managing stockpiles and wastes containing POPs (Article 6).
Other provisions cover implementation plans, new listings, information
exchange, public awareness, research, technical assistance, financial
resources, reporting, eectiveness evaluation, and non-compliance
(Stockholm Convention 2010).
3.4.2 PRTRs and the Stockholm Convention
Pollutant Release and Transfer Registers (PRTRs) are crucial tools for
monitoring and reporting POPs and supporting compliance with con-
vention requirements (Article 10).
Incorporation of the reporting on chemicals listed under the Stock-
holm Convention into the PRTR system can become one of the tasks
established in the National Implementation Plan of the respective
country(-ies) as defined in Article 7 of the Convention. POPs listed
under SC can even become the initial chemicals for the establishment
of PRTR in the country as there are guidance documents for their
inventories available (UNEP and Stockholm Convention 2013; UNEP
2017; UNEP 2017 a; UNEP 2017 b) and may help to calculate their emis-
sions and transfers from certain sources within the country. We tried to
document the use of PRTR for these purposes in some examples using
data from Czech PRTR, particularly in one of the previous reports within
the project in Thailand (Petrlik et al. 2018).
3.5 Minamata Convention on Mercury
The Minamata Convention (adopted in 2003 and enforced in 2017)
targets mercury’s adverse eects. Highlights include banning new
mercury mines, phasing out existing ones, regulating mercury use,
controlling emissions, addressing artisanal and small-scale gold mining
(ASGM), and managing mercury storage and disposal. Parties report
annually, exchange information, and update implementation plans.
Article 18 encourages using PRTRs for collecting and disseminating
mercury data, emphasizing their importance in estimating annual
quantities released, emied, or disposed of through human activities
(UNITAR 2018).
48 | Pollutant Release and Transfer Register and Civil Society
Photos 3.1 and 3.2: Chlor-alkali plant in Pieve Vergonte, Italy was
found to be a large source of mercury (Fantozzi et al. 2021)* PRTR can
clearly demonstrate to public large sources of mercury, and Mercury
Toolkit (UNEP Chemicals 2013) is an important tool developed within
framework of the Minamata Convention to support reporting into
PRTRs about mercury releases and transfers in wastes.
Photo: Legambiente, 2006
Photo 3.1
* High values of gaseous elemental mercury concentrations (1112 ng/m3) up to three
orders of magnitude higher than the typical terrestrial background concentration
in the northern hemisphere were measured in the proximity of the chlor-alkali plant.
Hg concentrations in lichens ranged from 142 ng/g at sampling sites located north of
the chlor-alkali plant to 624 ng/g in lichens collected south of the chlor-alkali plant
(Fantozzi et al. 2021).
Photo 3.3: The largest Czech chlor-alkali plant, Spolana Neratovice,
was flooded in August 2002. It used mercury for chlorine production
until 2017. Many mercury residues were also present in the so-called
old amalgam electrolysis site, which was contaminated with mercury
(Kuncova et al. 2008; Šamánek et al. 2013).*
Photo: Archive of Arnika Association.
Figure 3.1: Determined and interpolated Hg concentrations in oak tree
bark in the investigated area in the surrounding of Spolana Neratovice
chlor-alkali plant. Source: (Suchara and Sucharová 2008)
* During floods, a significant portion of the mercury undoubtedly entered the river.
The reporting to the IRZ (Czech PRTR) helped reveal the extent of the mercury
problem and clearly showed that its flows in waste were many times higher than
those into the air. Fish in the Labe (Elbe) River and the nearby lake in Mlékojedy were
also contaminated with mercury. The lake, formed in a former sand quarry,
is a popular spot for sports fishermen (Šamánek et al. 2013).
50 | Pollutant Release and Transfer Register and Civil Society
Photos 3.4 and 3.5: Mercury is especially ubiquitous in old chlor-alkali
plants (Mach et al. 2016; Mach et al. 2023). In photograph 3.4, mercury
contamination is shown in the bombarded Pancevo plant in Serbia in
1999 (photo 3.5) (Associated Press 2010; UNEP and UNCHS 1999). PRTR
helps to keep records of mercury flows. Photos: UNEP archive
Photo 3.5
Multilateral Agreements, Inter-governmental Organizations and PRTR) | 51
3.6 United Nations Framework Convention
on Climate Change (UNFCCC)
The UNFCCC aims to combat climate change by limiting global temperature
increases and dealing with its impacts. The goal is to stabilize greenhouse
gas concentrations to prevent dangerous interference with the climate
system. Parties report their emissions to monitor progress, aligning with
principles of shared responsibility. This reporting parallels national Pollutant
Release and Transfer Registers (PRTRs). The convention also emphasizes
education, training, and public awareness of climate change (UNITAR 2018).
3.7 2030 Agenda: UN Sustainable Development
Goals (SDGs)
The 2030 Agenda outlines 17 SDGs to promote sustainable development.
Existing reporting mechanisms, including PRTR data, are encouraged
to measure progress. PRTR data aligns with specific SDG targets, such
as reducing deaths from hazardous chemicals, improving water quality,
promoting sustainable industrialization, upgrading infrastructure, achieving
sustainable resource management, managing chemicals and wastes,
reducing waste generation, and ensuring public access to information
(UNITAR 2018).
3.8 Regional Agreement on Access to
Information, Public Participation and Justice
in Environmental Maers in Latin America0
and the Caribbean
In 2018, 24 Latin American and Caribbean countries adopted a binding
regional agreement (Principle 10) to protect access to environmental
information, public participation, and justice. The agreement mandates
the establishment of a pollutant release and transfer register covering
various pollutants in each party’s jurisdiction. Similar to PRTRs, this
register contributes to environmental protection and sustainable devel-
opment. The agreement is open for signature by all 33 regional nations
(UNITAR 2018).
52 | Pollutant Release and Transfer Register and Civil Society
4.1 Case Studies – Civil Society
There is a list of various uses of PRTR data by various stakeholders, but
NGOs gathered by the Environment Directorate of OECD in a report
from 2023 (OECD 2023e) and its overview is also user-friendly on the
OECD website (OECD 2023f). Engagement of the civil society is indi-
rectly listed among basic guiding principles for establishing PRTR: “In
designing or modifying a PRTR system, the government should consult
with aected and interested parties to develop a set of goals and objec-
tives for the system” (OECD 1997). We gathered examples of how civil
society used data from PRTRs. You can find them in the following case
studies. Links to some civil society websites dedicated to PRTRs can be
found in subchapter 2.6, which lists existing PRTR websites.
4.1.1 Use of TRI by Civil Society in USA
Citizens and civic associations hold the longest experience with the
PRTR in the USA. A group of non-governmental organizations focused
on working with the American TRI system emerged, later expanding its
scope to various issues related to releasing toxic substances into the
environment. It was named the “Working Group on Community Right-
To-Know.” This group published the “Working Notes” magazine every
two months, from which the following examples of TRI utilization in the
United States in the 1990s are derived (Working Group on Community
Right-To-Know 1991; Working Group on Community Right-To-Know
1996a; Working Group on Community Right-To-Know 1996b; Working
Group on Community Right-To-Know 1997).
The “Ozone Advocates” and the “Massachuses Public Interest
Research Group” (MassPIRG) used data obtained from TRI to
advocate for the replacement of substances damaging the ozone
layer and carcinogenic chlorinated solvents at Raytheon. Raytheon
reported to TRI that it had released 1.6 million kilograms of CFC-113
and methyl chloroform during the two years (1987-88). Aer a
campaign led by the “Ozone Advocates” and MassPIRG, Raytheon
announced in 1992 that it would transition to ozone-friendly alterna-
tives. This announcement was made in a joint press conference with
MassPIRG (Wolf 1996; Working Group on Community Right-To-Know
1991). In 1991, seven more companies reported, compared to the
previous year, and in 1990, only three substances damaging the ozone
layer were reported to the American TRI.
4. PRTRs and Civil Society
PRTRs and Civil Society | 53
The environmental association “Blue Ridge Environmental Defense
League (BREDL)” from North Carolina, USA, took the opportunity in
1996 to publish summary data on the amount of chemical substances
released by DuPont. Only with the introduction of TRI were they able
to obtain an overview of the total amount of substances damaging the
ozone layer or carcinogenic substances released into the environment
from DuPont facilities in North Carolina. They released this data on the
eve of the annual cycling race called the “Tour DuPont,” organized by
DuPont to improve its image despite being one of the largest polluters
in the country (Orum 1996).
Following the TRI and Community Right-To-Know law, the environmen-
tal movement CCE (“Citizens Campaign for the Environment”) in New
York led a successful campaign for labeling wastewater discharges.
Over 3,000 industrial facilities and wastewater treatment plants had
to label their wastewater discharges visibly since 1997. In combination
with this, they also had to disclose quarterly summaries of hazardous
substances discharged into the water. The environmental movement
gained 5,000 supporting leers and collected a quarter of a million
signatures on a petition demanding these measures (Working Group on
Community Right-To-Know 1997).
The Information Release Zone doesn’t have to be utilized only by
citizens and civic associations. State environmental agencies in
Massachuses and New Jersey used it to reduce pollution eectively.
In early 1997, these two states published reports revealing that major
chemical processors had significantly reduced the content of toxic
substances in waste and so-called non-product outputs from their
operations. In contrast, the trend for these substance flows was the
opposite throughout the USA. The EPA (Environmental Protection
Agency) aributed this to the fact that, unlike other American states,
these states had a beer-developed system of supplementary infor-
mation complementing TRI, which they required from companies.
Chemical companies could, therefore, better calculate how many
raw materials were escaping due to poor material flow management
or by not utilizing chemicals contained in waste. Both states exerted
pressure to reduce the release of toxic substances at the source.
Environmental organizations in Canada and the United Kingdom went
even further than civic associations in the USA. Until 2002, Friends
of the Earth in the UK operated an online guide called the “Chemical
Release Inventory” (CRI). Visitors to their website could easily find infor-
Photo 4.1: The civil society organization Citizens Campaign for
the Environment, which in 1997 achieved the visibility labeling
of wastewater discharges for over 3,000 industrial facilities and
wastewater treatment plants, is still active. In 2023, it advocated for
legislation to protect bees and birds. Photo: Citizens Campaign for
the Environment
54 | Pollutant Release and Transfer Register and Civil Society
mation about substances released from nearby factories or rankings of
the largest polluters of a certain substance. They operated these pages
until the state Environment Agency essentially began operating a
similar guide in 2015 for the Czech Republic, which Arnika also initiated.
4.1.2 Factory Watch – Friends of the Earth UK
Project in 1990s
The Factory Watch project, a pioneering Friends of the Earth UK (FOE
UK) initiative, was crucial in promoting transparency and public aware-
ness regarding industrial pollution (OECD 2000; Taylor 2004; UNITAR
2003). Unfortunately, the project has been ocially closed, ending its
impactful journey (UNITAR 2003).
Factory Watch, an award-winning website that monitored factory pollu-
tion, aimed to make pollution data accessible to the public. It stood out
as a prominent vehicle for disseminating information from the Pollutant
Photo 4.3: Mossville community is a small, predominantly African
American community suering from PVC production in its neighbor-
hood (Harden et al. 2005). Young residents of Mossville, Louisiana, play
near PVC plants. Many families have been forced to relocate due to
contamination and the expansion of industry surrounding Mossville
(Toxic Free Future 2023). Photo: Gary Lile, Greenpeace; Source: (Toxic
Free Future 2023)
Photo 4.2: Exxon Mobil Refinery in Baton Rouge, Louisiana, seen from
the top of the Louisiana State Capitol. The petrochemical complex
near New Orleans in Louisiana belongs to major polluters with various
releases from the chlorine industry, including dioxins (Harden et al.
2005). Photo: W. Clarke via Wikimedia Commons, 5 March 2017
PRTRs and Civil Society | 55
Release and Transfer Register (PRTR) data. As the first website to
provide the UK’s Chemical Release Inventory data to the public, Factory
Watch published detailed tables ranking the top 100 factories based
on various pollutants such as carcinogens, dioxins, toxic waste, and
acid rain gases (OECD 2000; UNITAR 2003). It started following the UK
Environment Agency’s release of the 1998 data (OECD 2000).
The project’s significance was underscored by its commitment to
transparency and accessibility. Factory Watch allowed users to conduct
searches by chemical, health eects, industrial process, and parent
company, providing a comprehensive and user-friendly interface for
accessing critical environmental information (OECD 2000; Taylor 2004).
One of the notable impacts aributed to Factory Watch was its role
in achieving a 40% reduction in releases of cancer-causing chemicals
across England and Wales between 1998 and 2001. This reduction, from
15,100 to 7,800 tonnes, marked a substantial improvement in environ-
mental conditions. Additionally, Factory Watch shed light on the dispro-
portionate impact of pollution on the most deprived communities, with
80% of emissions concentrated in the 20% most deprived areas, see
Figure 4.2(Taylor 2004; UNITAR 2003).
As the project ended, its legacy lives on in the improvements it cata-
lyzed. While Factory Watch’s website is no longer active, much of its
data is now accessible through the Environment Agency’s Pollution
Inventory. The initiative sparked positive changes, prompting ongoing
advocacy for beer environmental practices, including improved
league tables, monitoring of water and energy use, and disclosure of
production volumes (UNITAR 2003).
Despite its closure, Factory Watch’s impact remains evident in the
broader context of increased public awareness, policy changes, and
Figure 4.1 Photocopy of a newspaper article published in The Mirror,
on Monday, February 8, 1999, in response to the top worst polluters
published by FOE UK. Source: (Taylor 2004)
56 | Pollutant Release and Transfer Register and Civil Society
establishing an Advisory Group for the UK’s PRTR. The project catalyzed
positive environmental change and contributed significantly to the
discourse surrounding industrial pollution and accountability (Taylor
2004; UNITAR 2003).
FOE UK also prepared a guide to help active citizens use the data
published in the PRTR. In its introduction, it was written: “Friends
of the Earth intends that this guide will assist people in becoming
“active citizens,” local watchdogs for the environment, empowered
to act. It is not a comprehensive text on pollution - it gives the
basics and refers you to other sources of information if you want
more “(Warhurst 1998).
4.1.3 Polluters Application in the Czech Republic
Even if facilities already have a system for reporting to the PRTR,
and the data is available to the public, it may not be a clear and
easily accessible system. Therefore, for example, Arnika in the Czech
Republic has developed its own web application using a map to
manage publicly available data following examples of similar initia-
tives (projects) by civil society in other countries like for the FOE UK
Factory Watch project and/or similar project Pollution Watch (Envi-
ronmental Defence and CELA 2004) by Environmental Defence and
Canadian Environmental Law Association (CELA). Both these projects
were already closed.
Note: In 2022, the original spreadsheet application managed by the
Ministry of Environment was replaced by an updated application, but it
is still not user-friendly enough. Data from previous years are currently
being added.
The Arnika web application is available at www.znecistovatele.cz
(Figure 4.4) and contains identical data to the government database.
In addition to current data, it provides information on all facilities
that have reported to the system since 2004, along with an overview
of their reporting history. At the annual level, it is possible to see the
rank order of the largest polluters in the Czech Republic for particular
groups of substances or specific substances. The great advantage of
the map application is that it allows citizens to find out whether there
is a polluting facility near their homes.
Arnika compiled rankings of the biggest polluters even before
the znecistovatele.cz as part of its Toxics-Free Future campaign
application was launched, but they were simple non-interactive
tables. For the reporting year 2009, for example, the Kronospan
Figure 4.2 Factory pollution and deprivation. Source: (Taylor 2004)
Kg carcinogen emissions to air, 1999
Carcinogen emissions in local wards
1 = most deprived 10% of wards
8000000
6000000
4000000
2000000
0
1 4 7 102 5 83 6 9
PRTRs and Civil Society | 57
Jihlava wood processing plant (manufacturer of chipboards)
was the largest producer of cancer-causing substances due
to high formaldehyde emissions (Petrlik 2013). Maršák (2008b)
stated, “Pollution rankings are widely utilized by the media.
Industrial enterprises listed in these rankings, in most cases,
respond with minimal publicly declared efforts to reduce
emissions.” (Maršák 2008b)
Similar to FOE UK, Arnika also prepared a guide for active citizens
on the use of data from PRTR (IRZ), called the “Integrated Pollution
Register (IRZ) to help the public” (Petrlik and Man 2016).
A citizen may be interested in which facilities pollute the area around
their point of interest (home, school, coage, etc.) and in which facil-
ities pollute it the most. Simply put, the facilities are ranked within a
certain radius of a given point. Again, the center can be the address or
the center of the map on the screen, and the default is the year with
the most recent data, but historical data can also be viewed to see if
pollution is geing worse or beer. A substance or group of substances
must be selected. The groups of substances that can be viewed in the
web application (Figure 4.5 ) are:
• Carcinogenic, probable, or possible carcinogenic
• Carcinogenic
• Reprotoxic
• Mutagenic
• Endocrine Disruptors
• Greenhouse Gases
• Acid deposition gases
• Greenhouse gases
• Ozone-Depleting Substances
• Substances harmful to aquatic organisms
• Persistent Organic Pollutants (POPs)
• Mercury and its compounds
• Styrene
• Formaldehyde
• Dioxins
• Dust (Particulate Maer, PM10)
• Heavy metals
• Carbon monoxide
Photo 4.4: Kronospan Jihlava, a manufacturer of chipboards,
was the largest polluter with cancer-causing chemicals according
to data published in IRZ (Czech PRTR system) for several years,
e.g., for the reporting year 2009 (Petrlik 2013).
Photo: Jan Losenický, Arnika, 2011
58 | Pollutant Release and Transfer Register and Civil Society
Figure 4.4 Homepage of the website znecistovatele.cz
Arnika processes this data once a year (for the previous year) and
obtains an overview of the largest polluters at the level of the Czech
Republic. Each group has ten facilities (a specific substance or group of
substances), as seen Figure 4.6. If there are fewer, the ranking is shorter.
The ranking shows an arrow pointing up or down or a waveform
showing the annual trend. The up arrow indicates an increase, the
down arrow a decrease, while the waveform shows approximately the
same amount of substances released into the environment.
The displayed facilities list can be exported directly to Excel for further
processing on your computer. Several graphs can be displayed:
• a pie chart of all the facilities contributing to the emissions, where the
first ten are distinguished by color (Figure 4.7)
• the development of total pollution over the years (Figure 4.8)
Figure 4.5 List of groups of substances or individual substances.
Translation of the groups is in the text of subchapter 4.13, just before
reference to this figure.
Figure 4.6 Top ten polluters in particulate maer (PM10) in 2022.
Translation of the items in the figure: Pořadí = ranking, Organizace/
firma = company, Provozovna = facility, Město = city, town,
Kraj = administrative region, Množství látek v kg = amount of released
chemical/compound in kg/year, Trend = trend.
60 | Pollutant Release and Transfer Register and Civil Society
It is also possible to view historical data for individual facilities (Figure
4.9) by clicking on the facility’s name in the previous view (in the top 10)
or finding the facility using the search field.
Znecistovatele.cz is a user-friendly web application for Czech
citizens that provides easy access to information about polluting
facilities in the country. It offers a clear view of the largest polluters,
categorized by pollutant, allowing users to identify nearby sources of
pollution. The application includes historical data showing trends in
pollution levels over time. It also provides visual aids such as charts
and graphs for better understanding and allows users to export data
for analysis.
Figure 4.7 Pie chart of all the facilities contributing to the emissions of carcinogenic, probable, or possibly carcinogenic.
The first ten are distinguished by color. "Ostatní" stands for “others”.
Figure 4.8 Evolution of total particulate maer
(PM10) emissions in the Czech Republic as reported
by industrial sources into the Czech PRTR from 2004
until 2021.
Figure 4.9 Historical data
for an individual facility
for mercury (blue–water
emissions, black–air
emission).
Photo 4.5: Air pollution in Zenica triggered a large demonstration by
local residents in December 2014. Photo: Adnan Dzolic, Eko Forum Zenica
Photo 4.7: In 2014, the Kakanj brown coal power plant was among the
largest sources of pollution in the Zenica area. Photo: Martin Plocek,
Arnika, 2014
Photo 4.6: Concentrations of sulfur dioxide and other substances in
the air exceeded high values. Photo: Eko Forum, Zenica, 2014
PRTRs and Civil Society | 63
4.1.4 Top Tens of Biggest Polluters for
Bosnia and Herzegovina and Kazakhstan
Civil society organizations Eko Forum Zenica and Arnika published
three top ten of the biggest polluters of Bosnia and Herzegovina for
reporting years 2011-2013, 2015 and 2016, based on the published data
of national PRTR (Arnika and Eko Forum Zenica 2019; Arnika et al. 2016).
Values exceeding safe threshold limits for Bosnia and Herzegovina are
related to only 38 and 28 factories in Bosnia and Herzegovina and cover
only 13 and 11 substances (cadmium, lead, benzene, PAH, HCl, HF, SO2
/SOx, NO2 /NOx, CO, methane, CO2, PM10, PCDD/F) for the reporting
years 2015 and 2016 respectively, according the data from PRTR (Arnika
and Eko Forum Zenica 2019).11
A similar approach was taken by CSOs for Kazakhstan, although the
available data allowed for a much more scarce evaluation as it was only
possible to use data for air pollution for any evaluation. The result was
presented at PRTR Protocol MOP3 in Budva in 2017 (Mogilyuk 2017) and
is available in Russian on Arnika’s website.12
4.1.5 ailand: CSOs as a Driver for PRTR
Implementation
Thailand has experienced rapid economic development since the
1980s, but adequate environmental regulation has been lacking and
absent for a long time. As a result, factories have been able to operate
for decades without limits, technology requirements or audits to
reduce pollution. In this situation, factories dump millions of tonnes
of hazardous waste annually and release huge emissions into the air
and water. Consequently, pollution oen remains invisible in the
environment.
Despite adopting the Sustainable Development Goals by the United
Nations, the Thai government favors investors, not the environment.
While the BAT/BEP approach was still not in place, demonstrations and
petitions against pollution grew. The government’s lack of response
gave rise to citizen campaigns to protect community health and the
environment and addressing the issue of citizen rights to know (RTK)
about the pollutant release from industrial sources. In 2001, the Thai
civil organization CAIN (Campaign for Alternative Industry Network,
11 hps://arnika.org/en/events/download/1213_e4025d8bbf633486f5600867a137e2a1
12 hps://arnika.org/en/events/download/1213_e4025d8bbf633486f5600867a137e2a1
Photo 4.8: However, the main source of pollution in Zenica was the Mial
Steel factories (Petrlik and Behnisch 2015; Zahumenská et al. 2015).
Photo: Martin Plocek, Arnika, 2014
64 | Pollutant Release and Transfer Register and Civil Society
the former name of EARTH) called for a need to have the Pollutant
Release and Transfer Register (PRTR) legislation in Thailand to solve
the problem of industrial pollution that was intensifying in many areas.
Besides this, the lawsuit by citizen groups in Rayong province in 2009
aiming to halt the new investment of 76 petrochemical projects in Map
Ta Phut and its vicinity areas had pressured the Thai government to
set up a pilot PRTR system with the technical assistance of the Japan
International Cooperation Agency (JICA); (Saetang 2022).
In 2012, the civil society organization EARTH helped detect chemical
contamination in Loei Province around a gold mine. Samples collected
with the community’s help included soil, water (including drinking water),
sediment, paddy seeds and rice. The results showed that some samples
exceeded the limits for arsenic, and mercury and lead were also found,
but in minimal amounts. Arsenic was also found in drinking water and
rice (Bystriansky et al. 2018; Mach et al. 2018).13 The results led to a public
campaign against the second phase of the mine expansion and also to
the investigation of heavy pollution by the citizens of the aected area
themselves. As of 2022, EARTH has worked with over 40 communities
across Thailand (in 15 provinces). EARTH has developed the knowledge
and technical skills to empower local people to protect the environment
and believes that this will benefit not only the communities in the con-
taminated areas but also civil society in Thailand and neighboring coun-
tries, academics and industry who can benefit from dialogue with the
community. Furthermore, this approach can lead to a sustainable future
for Thailand and other countries facing similar problems (Saetang 2022).
EARTH uses a concept of the work called Citizens’ Science. Citizens’
Science is a specific term used for science-based observations by
13 Arnika also helped with some chemical analyses from Loei in a joint project with
EARTH in 2015-2019 (Mach et al. 2018).
Photo 4.9: Penchom Saetang, Director of EARTH, observes one of
the local sources of pollution, the aluminum plant in Kao Hin Sorn.
Photo: Ondřej Petrlík, Arnika, 2016.
PRTRs and Civil Society | 65
local citizens and/or activists to back their demands on authorities or
industrial companies regarding pollution caused by industrial estates
across Thailand or other countries (Teebthaisong et al., 2022). Citizen
science was used as recently as 2015 by the Thai organization EARTH
(Ecological Alert and Recovery Thailand). They believed that the com-
munity they were training would be able to generate strategic evidence
to combat pollution. However, Saetang gained experience in 2004-2005
when she collaborated with Greenpeace Southeast Asia (GP SEA) to
map air conditions around a petrochemical industrial zone in the Map
Ta Phut area, receiving technical support from Global Community
Monitor (GCM).
The local community collected five samples in which 20 substances
were identified. These results served as evidence of what the local
community breathes daily. Among the substances identified, the
carcinogen benzene was found to exceed US standards by more than
60 times, while other carcinogens were found to exceed standards
by more than 80 times to 3,000 times. Even with this limited set of
results, it was significant in convincing the National Environment
Board to issue an Announcement on the Annual Ambient Air Screen-
ing Level of 9 Volatile Organic Compounds in 2007, and in 2009, the
PCD issued another announcement about VOCs regarding a 24
hour-Ambient Air Screening Level of 19 Volatile Organic Compounds.
Photo 4.10: Sampling in Loei. Photo: Ondřej Petrlík, Arnika, 2016 Photo 4.11: Landscape in Loei area. Photo: Ondřej Petrlík, Arnika, 2016
66 | Pollutant Release and Transfer Register and Civil Society
This was followed by the PCD’s newly established continuous mon-
itoring of VOCs in air and water in Map Ta Phut. One of the sites
included in the PRTR pilot project that EARTH has been working on
since 2011 was Map Ta Phut. Part of that was also the start of the
sampling and analyses for POPs (Petrlik 2011).
Citizens’ science project in Thailand has a real impact on the regulation
of polluters. EARTH delivered a proposal for a new national law on the
Pollutant Release and Transfer Register (PRTR) in 2022, for example
(Teebthaisong et al. 2022).
4.1.5.1 Campaign for PRTR Act in Thailand
In 2014, EARTH and Enlaw Foundation started to formulate a PRTR
dra act aer years of study to the experiences of the United States’s
Toxic Release Inventory (TRI) and PRTR systems implemented in the
European Union and Japan. EARTH’s PRTR dra act was submied
to the parliament by 20 members of the House of Representatives by
Photo 4.13
Photos 4.12 – 4.15: Photos from Map Ta Phut's broader area, taken in
2016. Pollution originating mostly from the petrochemical industry was
described in the reports by EARTH and Arnika (Bystriansky et al. 2018;
Mach et al. 2017; Mach et al. 2018; Teebthaisong et al. 2022; Tremlova
et al. 2017), and by others (Chusai et al. 2012; Pinyochatchinda 2014;
Rangkadilok et al. 2015). Photo: Ondřej Petrlík, Arnika
PRTRs and Civil Society | 67
the Move Forward Party in December 2020. The Parliament brought
the Dra out for public hearing in February 2021, but it failed to be
endorsed by the Prime Minister in June 2021.
In 2022, EARTH, EnLaw and Greenpeace – Thailand launched a joint
PRTR law campaign to engage Thai citizens’ awareness of the impact
of pollution and participation in the introduction process of a bill to
the Parliament of Thailand. The campaign aims to collect up to or
more than 10,000 eligible voters’ names and signatures supporting the
citizen-initiative PRTR bill. In January 2022, EARTH and Enlaw organized
a hearing of the bill with the participation of key stakeholders from the
Ministry of Industries (MOI), Ministry of Natural Resources and Envi-
ronment (MONRE), Federation of Thai Industries (FTI), environmental
lawyers and academics. The overall result of the hearing was a positive
response with no deprecation to the PRTR bill initiated by the NGOs.
The bill was introduced to the Speaker of the Parliament for preliminary
consideration in July 2022. EARTH, Enlaw and Greenpeace Thailand
had a joint press conference to kick o the Thai PRTR website
(www.thaiprtr.com) to start collecting citizen signatures to endorse the
PRTR bill. The campaign achieved 10,000 names of endorsements in the
middle of December 2023, which will be submied to the whole pack of
endorsements to the Parliament in early 2024.
Photo 4.14 Photo 4.15
68 | Pollutant Release and Transfer Register and Civil Society
4.1.6 Case Studies on Volatile Organic Compounds (VOCs)
4.1.6.1 Case Study: Trichloroethylene in Czech PRTR (IRZ)
Trichloroethylene and tetrachloroethylene were commonly used as
solvents in dry cleaning and engineering. Over 80 % of trichloroethylene
is used to degreasing and clean metal parts. It is also present in some
household products, such as correction fluids for typewriters, paint
removers, adhesives, and stain removers. Additionally, it serves as a raw
material in chemical industries and as a substitute for CFCs, HCFCs,
and HFCs. Trichloroethylene has had limited use as an anesthetic
in medicine and dentistry, and in the past, it was used as a fumigant
pesticide for grains (Válek and Petrlík 2010).
Trichloroethylene is classified as a probable human carcinogen
(Group 2A according to IARC assessment) and has mutagenic eects
(IARC Working Group on the Evaluation of Carcinogenic Risk to
Humans 2014). Like tetrachloroethylene, it has been a common cause
of groundwater contamination in the Czech Republic (Broulík 2009;
Tůmová 2007). The trend in reported releases to air is illustrated in
Figure 4.10.
Figure 4.10: Figure shows the
trend of total reported trichlo-
roethylene emissions to the
IRZ into the air for the entire
Czech Republic, compared to
the emissions reported by the
two largest polluters from 2004,
Federal-Mogul Friction Products,
a.s. in Kostelec nad Orlicí, and
Spolana Neratovice, over the
years. Source: (Petrlík 2010;
Petrlik et al. 2018)
120000
10000
80000
60000
40000
20000
0
Federal-Mogul Friction Products
a.s., Kostelec nad Orlicí
Spolana, a.s., Neratovice Czech Republic
2004 - air releases
2005 - air releases
2006 - air releases
2007 - air releases
2008 - air releases
Air releases of trichlorethylene reported to IRZ- 2004 - 2008
PRTRs and Civil Society | 69
Aer being major polluters in 2004, Federal-Mogul Friction Products
a.s. in Kostelec nad Orlicí, Amati-Denak a.s. in Kraslice, and Galvamet
s.r.o. achieved the most significant decrease in trichloroethylene
emissions between 2004 and 2008 (refer to Figure 4.11). The Mayor of
Kraslice responded to a report on the largest polluters of mutagenic
substances, based on data from the IRZ, which resulted in Amati-De-
nak, a musical instrument manufacturer in Kraslice, installing new
technology in response to pressure from the local government. The
company publicly announced the installation of this new technology
in 2007. In 2008, only Amati-Denak in Hradec Králové, besides Spolana,
reported trichloroethylene emissions, which were below the reporting
threshold of 1180 kg (Petrlík 2010; Petrlik et al. 2018).
If the reporting obligations were limited in the Czech IRZ to the
current level of the E-PRTR, only Spolana Neratovice, among
the major air polluters with this substance, would report to the
registry. Limiting the reporting obligations could potentially
reduce the impetus for polluters to take necessary measures, as
the trend in emissions would appear dierent without a signifi-
cant comparison.
4.1.6.2 Case Study: Styrene in Czech PRTR (IRZ)
Styrene is a crucial monomer widely used in chemical manufacturing. It
is featured in various products such as rubber, plastics, insulation, and
automotive components due to its ability to create long chains, which is
Figure 4.11 Figure shows the
trichloroethylene emissions
reported to the IRZ by major air
polluters in the Czech Republic
between 2004 and 2008. All
major polluters except Spolana
Neratovice were already below
the reporting threshold in 2008.
Amati Denak reported 1180 kg
for its Hradec Králové plant in
2008. The reporting threshold
for trichloroethylene emissions
is 2000 kg, set as the baseline
on the graph’s vertical axis.
Source: (Petrlík 2010; Petrlik
et al. 2018)
37000
32000
27000
22000
17000
12000
7000
2000
2004 - air releases
2005 - air releases
2006 - air releases
2007 - air releases
2008 - air releases
Amati Denak s.r.o.,
Závod Kraslice
Amati Denak s.r.o.,
Závod Hradec
Králové
Federal-Mogul
Friction Products a.s.,
Kostelec nad Orlicí
Galvamet s.r.o.,
dílna Jablůnka
Spolana a.s.
Neratovice
Stim Zet a.s.,
Vsetín - Jasenice
Development of trichlorethylene air releases reported to IRZ- 2004 - 2008
Photo 4.16: Even manufacturers of wind instruments can be regarded
as big polluters according to the PRTR report, but Amati Denak
Kraslice reduced its contribution to emissions of toxic trichlorethylene.
Amati-Denak factory in Kraslice is in the photo. Photo: ChickSR via
Wikimedia Commons, 2020
Photo 4.17: Amati-Denak manufactures wind musical instruments.
Trichloroethylene was used as a cleaning substance. The tenor sax-
ophone with mother-of-pearl keys in the photo is a gi from Czech
President Václav Havel to Bill Clinton and was also manufactured at
Amati-Denak in Kraslice. Photo: William J. Clinton Presidential Library
via Wikimedia Commons
PRTRs and Civil Society | 71
vital in making polystyrene (Kleger and Válek 2010). The Czech Republic
has seen an upward trend in styrene consumption. However, workers
exposed to high short-term concentrations of styrene face neurological
risks. Additionally, the International Agency for Research on Cancer
(IARC) has classified it as a probable carcinogen (Group 2. A) (IARC 2023).
Concern about the potential carcinogenicity of styrene stems largely
from the ability of its metabolite, styrene-7,8-oxide (SO), to bind cova-
lently to DNA and its activity in a variety of genotoxicity test systems.
SO has been classified by IARC in group 2A as probably carcinogenic
to humans. Styrene exposure has been reported to cause an increase
in DNA and hemoglobin adducts and the frequency of chromosomal
aberrations (Rue et al., 2009).
Between 2004 and 2008, reported air emissions in the Czech Republic
increased, which correlates with the rise in reporting facilities from 42
in 2004 to 66 in 2008. Total emissions also increased, peaking at 125.5
tons in 2007, up from over 68 tons in 2004 (Petrlík 2010).
Figure 4.12 Overview of the reported trend in styrene emissions by major air polluters to the IRZ throughout its existence.
The graph includes the largest emier of styrene emissions for each monitored year. Source: (Petrlík 2010)
16000
14000
12000
10000
8000
6000
4000
2000
0
Annual styrene emissions (kg)
2004 - air releases
2005 - air releases
2006 - air releases
2007 - air releases
2008 - air releases
ACO Industries
k.s., Přibyslav
Teiko s.r.o.,
Spytihněv
Rotec - Czech
s.r.o., Chrastava
Hobas CZ s.r.o.,
Uherské
Hradiště
Riho CZ a.s.,
laminovna Suchý
Form s.r.o.,
Laminátovna
Střelná
Duno CS s.r.o.,
Moraveč
L.A.S.T. s.r.o., výro-
ba laminátových
dílů Tečovice
Epuz s.r.o.,
Otrokovice
Duno CS s.r.o.,
Dýšina
72 | Pollutant Release and Transfer Register and Civil Society
Emissions from selected facilities, mostly among the major air polluters
with styrene, have shown significant fluctuations over the five years,
with few exceptions. It is impossible to determine whether the dierent
reported values are primarily linked to output or if they stem from
one-time styrene measurements or calculation methods due to the
absence of reported annual performances (production volumes) from
individual facilities to the IRZ. The graph shows that new facilities can
significantly pollute this substance from the start.
The increasing use of styrene in recent years suggests a rise in emis-
sions of this substance into the air. Therefore, the government admin-
istration should pay close aention to this issue, especially given the
negative health impact of styrene, which could make it a significant
local hazard. In this regard, the IRZ serves as an essential source of
information.
If the Czech system were limited to the level of the E-PRTR, only the
holder of an integrated permit, who is one of the top ten polluters in
this case, would have to report emissions of styrene. This would cause
the vast majority of styrene emiers to vanish from the registry, depriv-
ing governmental authorities, local administration, and the public of a
valuable source of information on emissions of this substance.
Although the technology changes are not too complex, there have not
been many cases of styrene emission reductions. Figure 4.12 shows
that the Epuz s.r.o. plant in Otrokovice achieved significant emissions
reduction. A well-documented example of emission reduction is
demonstrated at the Laminates Klimeš facility in Benešov u Semil.
At this plant, installing a catalytic unit for continuous VOC oxidation,
coupled with a high-pressure supply fan, resulted in a substantial
decrease in styrene emissions. The project received support from the
European Union and the State Environmental Fund (SFŽP) and cost a
total of approximately 6.5 million CZK. (SFŽP 2008). Figure 4.13 shows
the reduction achieved. The reduction was not only due to reporting
to the IRZ but also in response to community feedback and the proac-
tive approach of the facility operator. However, the IRZ prompted this
change.
4.1.6.3 Case Study: Naphthalene in an Industrial Facility
Adjacent to the River
The cleanliness of the Jizera River in Central Bohemia (photo 4.22) is
important not only for the wildlife that inhabits it but also for the purity
of drinking water for Prague, the capital of the Czech Republic. The river
flows in the accumulation zone of the drinking water source for Prague.
Figure 4.13 Trend in styrene emissions reported to the IRZ by the
Laminates Klimeš facility in Benešov u Semil. Source: (Petrlík 2010)
year
2500
2000
1500
1000
500
0
2007 2008 2009
Trend in styrene emissions in kg/year
PRTRs and Civil Society | 73
Photo 4.18
Photo 4.20
Photo 4.19
Photos 4.18 – 4.21: From the gallery of styrene polluters in the Czech
Republic (4.18 - L.A.S.T. Tečovice; 4.19 – BV Plast Klášterec nad Ohří;
4.20 – Hobas Uherské Hradiště), only Synthos in Kralupy nad Vltavou
(photo 4.21) appears at first glance to be a significant polluter; the
others have only small ventilation chimneys. Nevertheless, large volumes
of potentially carcinogenic styrene can pass through them in one year,
and some of these operations bother the surroundings with the sweet
smell of styrene. Photos: Jan Losenický, Arnika, 2011 (4.18 – 4.20) and
Skvor, Creative Commons license (4.21)
74 | Pollutant Release and Transfer Register and Civil Society
Photo 4.21
PRTRs and Civil Society | 75
Photo 4.22: The Jizera River near Benátky nad Jizerou in spring. Photo:
Jindřich Petrlík, Arnika, 2020
Photo 4.24: View of the Carborundum Electrite complex across the
Jizera River, clearly showing its proximity to the watercourse. Photo:
Jindřich Petrlík, Arnika, 2013
Photo 4.23: Carborundum Electrite in Benátky nad Jizerou in January
2015. The small vent at the hall’s beginning is the preliminary unit’s
chimney for the discs’ production using naphthalene. It is no longer
there today, just like the planned production with naphthalene. Photo:
Jindřich Petrlík, Arnika, 2015
76 | Pollutant Release and Transfer Register and Civil Society
Between 2012 and 2016, there was a threat that Carborundum Electrite,
a branch of Tyrolit in Benátky nad Jizerou (photo 4.23), would establish
the production of abrasive wheels using naphthalene, which would be
stored in the facility right next to the river (photo 4.24). In the event of
an accident, if naphthalene were to reach the river, it would significantly
jeopardize its cleanliness. Arnika used data from the IRZ to argue during
the environmental impact assessment of the planned operation. The
proposal also faced strong opposition from the citizens of this Central
Bohemian town. In 2012, when the plan came to light, a petition campaign
was launched, supported by approximately a quarter of the town’s resi-
dents. The company abandoned the proposal aer a four-year campaign
by local residents supported by the Arnika association (Arnika 2016).
Naphthalene is possibly carcinogenic to humans (2B) (IARC 2023). It is
toxic to aquatic organisms. The substance may cause long-term eects
in the aquatic environment. Bioaccumulation of this chemical may
occur along the food chain, e.g., in fish (National Center for Biotechnol-
ogy Information 2024). Naphthalene belongs to the group of polycyclic
aromatic hydrocarbons (PAHs) as well as to the VOCs.
4.1.7 Case Studies on Toxic Chemicals in Waste Transfers
The following case studies are based on experiences using data from
the Czech PRTR (IRZ) because, in other European countries, transfers
of chemical substances in waste are not reported. These case studies
have been previously published in Arnika’s studies (Havel et al. 2011;
Petrlik et al. 2018) and have been shortened, modified, or supplemented
with more recent data for the purposes of this Guide.
4.1.7.1 Case Study: Arsenic in Waste Transfers
Arsenic, a well-known poison, is considered a critical substance in
water pollution, particularly aecting drinking water sources. It has a
notable tendency to accumulate in river sediments. In some cases, the
adsorption and release of arsenic from sediments into the liquid phase
can significantly impact its concentrations in the water.
Arsenic is known for its carcinogenic, neurotoxic, and mutagenic
properties, oxidative stressors, endocrine system disruption, and
inflammatory action. The source, species, and concentration of arsenic
aect the toxicity limit (Kaur et al. 2024; Ratnaike 2003). Even low-level
exposure to inorganic arsenic has been associated with an increased
risk of several cancers, including skin, lung, bladder, and kidney
cancers. Emerging research suggests that chronic exposure to low
levels of arsenic may contribute to cardiovascular disease, including
hypertension and atherosclerosis (Drobna et al., 2009; Hughes et al.,
2011; Kaur et al., 2024).
Unlike mercury, arsenic is highly mobile. Fortunately, it doesn’t accumulate
much in fish, reducing the risk of poisoning through fish consumption.
Persistent use of water with low arsenic concentrations can lead to
chronic diseases. Historical instances in the 1930s and 1940s reported
arsenic poisoning from unsuitable drinking water, with arsenic concen-
trations reaching several mg/l. The toxicity of arsenic depends on its
oxidation state, with AsIII compounds being approximately 5 to 20 times
more toxic than AsV compounds (Hughes 2015).
Human activities, such as fossil fuel combustion, metallurgical pro-
cesses, dye manufacturing, and more, contribute to arsenic pollution
(Zevenhoven et al. 2007). Arsenic is also present in leachate from power
plant fly ash, with drainage water from sludge-drying beds containing
arsenic in concentrations up to several mg/l. Research indicates that
lignite combustion can impact soil contamination by arsenic, and in the
Czech Republic, areas around Chomutov and Most show the highest
values (Ustjak 1995).
PRTRs and Civil Society | 77
Major contributors to arsenic transfers in waste, reported in the IRZ
from 2004 to 2008, include the power plant Elektrárna Mělník I (Energo-
trans a.s.), ranking first, and the heating plant Teplárna Otrokovice a.s.,
ranking second over these years. The facility Kovohutě Příbram a.s., is
the third-largest source of arsenic and its compounds in wastes during
this period (Figure 4.15 ).
Figure 4.14 illustrates that arsenic transfers in waste significantly
exceed reported releases into the air and/or water. This discrepancy is
more pronounced than in the case of mercury and cadmium despite
higher reporting thresholds for waste transfers. Canceling the duty to
report chemical substances in wastes would result in the loss of crucial
information about the flow of arsenic and its compounds into the
Czech Republic’s environment (Petrlík 2010). that arsenic transfers in
waste significantly exceed reported releases into the air and/or water.
This discrepancy is more pronounced than in the case of mercury
and cadmium despite higher reporting thresholds for waste transfers.
Canceling the duty to report chemical substances in wastes would
result in the loss of crucial information about the flow of arsenic and its
compounds into the Czech Republic’s environment (Petrlík 2010).
The heating plant Teplárna Otrokovice a.s., emerges as the second-
largest source of arsenic and its compounds in wastes, as seen in
Figure 4.15. This information is crucial for understanding the plant’s
waste management practices. The waste is utilized for landscape
reclamation, including the sludge-drying bed for fly ash in Bělov.
Figure 4.14 Total amounts of
arsenic and its compounds
reported into the IRZ concerning
the individual years, according to
the type of releases and transfers
in 2004 – 2008.
140000
120000
10000
80000
60000
40000
20000
0
Air
Water
Waste
2004 20062005 2007 2008
Photos 4.25 - 4.26: The ash storage facility near Bělov (photos 4.25 and
4.26), where Teplárna Otrokovice a.s. deposited for many years, has
destroyed the water ecosystem (Nejeschlebová 2013), and according
to local residents, it is also a source of dust (Přecechtěl 2022). A similar
fate threatened wetlands and water bodies in Vážany. The use of data
from the PRTR (IRZ) regarding the amount of arsenic in waste (ashes)
helped to halt this project and thus save the habitat of endangered
species (see photos 4.27 – 4.32).
Photo 4.27: European sparhawk (Accipiter nisus L.).
Castelleo Merli via Wikimedia Commons
Photo 4.28: Common rosefinch (Carpodacus erythrinus L.).
Photo: Adam Kumiszcza via Wikimedia Commons
Photo 4.29: Great reed warbler (Acrocephalus arundinaceus L.).
Photo: Dirk-Jan Kraan via Wikimedia Commons
Photo 4.30: Common kingfisher (Alcedo at this L.).
Photo: Andy Morew via Wikimedia Commons
Photos 4.27 – 4.32: Endangered species from wetlands and water ecosystems in Vážany which were endangered by a plan
to back-fill a clay pit in Vážany. (Bílý 2010)
80 | Pollutant Release and Transfer Register and Civil Society
In 2010, plans were made to use residues from lignite combustion
in Otrokovice to back-fill a clay pit near Vážany (Kroměříž). The sur-
rounding areas include pools and wetlands with protected species,
raising concerns about potential contact with subsurface water (Bílý
2010). Without data from the IRZ, vital information about up to 7.5
tons of deposited arsenic compounds per year in the area would be
unavailable, highlighting the importance of such data in environmen-
tal impact assessments (Havel et al. 2011).
Even though arsenic is naturally present in all lignite from the coal field
Podkrušnohorská pánev, certain large combustion sources, such as
Teplárna Otrokovice, report considerably higher amounts of arsenic
and its compounds in wastes compared to others. Teplárna Otrokovice,
in addition to burning lignite, also combusts light heating oil and, since
2006, biofuel, as outlined in Table 4.1.
Table 4.1 Summary of fuel consumption in Teplárna Otrokovice
(in tons/year). Source: Anonymus 2009
Fuel / year 2002 2003 2004 2005 2006 2007 2008
Lignite 291,407 311,700 311,581 306,282 292,974 303,405 220,896
Light heating
oil 146 101 85 167 157 103 123
Biofuel 2,061 4,965 5,741
Photo 4.31: Grass snake (Natrix natrix L.).
Photo: Isiwal via Wikimedia Commons
Photo 4.32: Eurasian marsh frog (Rana esculenta L.).
Photo: Manfred Heyde via Wikimedia Commons.
PRTRs and Civil Society | 81
Figure 4.15 Development of amounts of arsenic and its compounds in waste transfers reported by selected facilities into the IRZ concerning
the period 2004 – 2008 (expressed on a logarithmic scale). The values concerning the two biggest sources of arsenic in wastes, in the individual
years, are given in the graph heading.
Energotrans a.s. -
elektrárna Mělník I
Teplárna Otrokovice
Příbramská
teplárenská a.s. - CZT
Teplárna Olomouc
ECK, s. r.o. -
elektrárna Kladno
Burson Properties, a.s.,
divize Antonínův Důl
Teplárna Malešice
Elektrárna Kolín
a.s. - Z álabí
Elektrárna Třebovice
Teplárna Přerov
Kovohutě Příbram,a.s .
ArcelorMial Ostrava a.s.
Spalovna Praha -
Malešice
Spalovna SAKO Brno
10000
10000
1000
100
0
Values at Mělník I - 2004: 45,300; 2005: 73,500; 2006: 40,600; 2007: 17,600; 2008: 34, 800
Values at Teplárna Otrokovice - 2004: 16,400; 2005: 19,700; 20 06: 13,600; 2007: 17,300; 2008: 17,400
2004 - wastes
2005 - wastes
2006 - wastes
2007 - wastes
2008 - wastes
82 | Pollutant Release and Transfer Register and Civil Society
Graphs in Figure 4.16 and Figure 4.17 illustrate a potential correlation
between the amounts of combusted lignite and light heating oil and
the total reported arsenic in wastes. The graphs suggest that fluctua-
tions in arsenic amounts in wastes are likely linked to variations in the
amounts of combusted fuels. While biofuel amounts were negligible in
2004 and 2005, ruling out a correlation with arsenic in wastes, a correla-
tion with the combusted amounts of lignite and heating oil couldn’t be
conclusively proven. Unfortunately, available sources do not provide
information on fluctuations in arsenic presence in fuels or whether
such monitoring occurred. It is also unclear if the fuel source, such as
dierent lignite mines, changed. Although an interesting correlation,
future analyses may face challenges due to the limited availability of
information on arsenic transfers in wastes.
4.1.7.2 Case study: Hexachlorobenzene and similar POPs
Hexachlorobenzene (HCB), in high doses, is lethal to some animals and,
at lower levels, adversely aects their reproductive success. Researchers
have also found that HCB, like other organochlorinated compounds,
undergoes transplacental transfer (Sala et al. 2001). Pentachlorobenzene
(PeCB) is highly toxic to aquatic organisms and may cause long-term
adverse eects in the aquatic environment (POP RC 2007). Hexachlorobu-
tadiene (HCBD) is also highly toxic to aquatic organisms, causing kidney
damage and cancer in animal studies, as well as chromosomal aberra-
tions in occupationally exposed humans (Balmer et al. 2019; POP RC 2012).
HCB, PeCB, and HCBD fall under Annexes A and C of the Stockholm
Convention on POPs due to their historical use as pesticides, technical
Figure 4.16 Graph showing
a correlation between arsenic
amounts reported in wastes
from Teplárna Otrokovice and
amounts of combusted lignite
concerning 2004 – 2008,
including the trend curves.
Lignite
Arsenic in wastes
Polyg. (Lignite)
Polyg. (Arsenic in wastes)
Combusted lignite in tons
Arsenic in wastes in kg
350000
300000
250000
200000
150000
25000
20000
15000
10000
311581 306282
303405
19700 292974
17300 1740 0
16400
13600
220896
Year
2004 2008200720062005
PRTRs and Civil Society | 83
substances, and unintentional by-product status in various industrial
processes (Stockholm Convention 2017). Currently, in the Czech
Republic, they pose a significant issue as unintentional by-products,
making it crucial to monitor both their air and water releases and the
amounts transferred in wastes.
However, reporting thresholds for HCB releases into the air, as estab-
lished in the European Register (E-PRTR), are either too high, leading to
few facilities exceeding them, or the total emissions are notably under-
estimated in EU states. The E-PRTR reported HCB emissions into the air
by only a few facilities from the entire EU for 2007 and 2008. E-PRTR data
from 2007 indicated only four operations reporting air emissions and
five in 2008 across Europe. For instance, in 2007, one chemical plant in
Finland and three Belgian cement plants co-incinerating waste reported
emissions. In 2008, one Belgian smelter, one cement plant, one Finnish
chemical plant, one German chemical plant, and a Spanish operation for
metal surface treatment reported air emissions. In terms of water dis-
charges, 11 operations reported in 2007 and six in 2008 in Europe, mostly
from municipal wastewater treatment plants (Petrlík 2010).
The USA had a reporting threshold of 10 pounds (4.5 kg), and Scotland
had an even stricter threshold of 1 kg (Petrlík 2010).
Figure 4.17 Graph showing
a correlation between arsenic
amounts reported in wastes
from Teplárna Otrokovice
into the IRZ and amounts of
combusted light heating oil,
concerning the period
2004 – 2008, including
the trend curves. Arsenic in wastes
Lignite heating oil
Polyg. (Arsenic in wastes)
Polyg. (Light heating oil)
Combusted light heating oil in tons
Arsenic in wastes in kg
190
160
130
100
70
25000
20000
15000
10000
2004 2008200720062005
Year
167
157
85
103
123
17400
13600
19700
16400
17300
84 | Pollutant Release and Transfer Register and Civil Society
Due to high reporting thresholds and inconsistent detection of wastes,
the Czech IRZ lacks comprehensive data on HCB. Notably, a few reports
on HCB transfers in wastes from specific facilities, such as Spolek pro
chemickou a hutní výrobu in Ústí nad Labem, are available (Petrlik et al.
2018).
Total HCB emissions in the EU (assessed in 25 states), including trans-
fers in waste, were estimated at 4,000 kg according to data in the Imple-
mentation Plan of the Stockholm Convention of the European Commu-
nity. However, this estimation contradicts reports from the Spolek pro
chemickou a hutní výrobu in Ústí nad Labem, consistently reporting
hundreds of kg to the Czech PRTR from 2005 to 2008, indicating a
potential order of magnitude error in the estimate for the Community
Implementation Plan. Lowering reporting thresholds and introducing a
duty to report HCB in wastes, similar to other POPs, could provide more
accurate and objective data (Petrlík 2010).
In addition to HCB, other POPs, such as hexachlorobutadiene (HCBD)
and pentachlorobenzene (PeCB), are unintentionally produced at Spol-
chemie in Ústí nad Labem. The decreasing trend in reported amounts
for these substances over the IRZ’s existence is depicted in Figure 4.18.
While their total amounts have decreased, the sum reported in 2008
remained a serious concern for POPs in the Czech Republic (Petrlik et
al. 2018). The duty to submit chemically specific reports on transfers
of HCBD and PeCB in wastes was eliminated, resulting in the loss of
valuable information on the amounts of these substances in the wastes
of Spolek pro chemickou a hutní výrobu and/or its accessor. From 1992
until 1999, HCB, PeCB, and HCBD-containing wastes were stored in
plastic containers with sandy material and covered by a layer of mixed
ash and cement at Všebořice hazardous waste landfill (Kuncová et al.
2006).
Figure 4.18 Graph depicting the development of the amounts of
hexachlorobenzene (HCB), hexachlorobutadiene (HCBD), and penta-
chlorobenzene (PeCB) in wastes, according to the reports of Spolek pro
chemickou a hutní výrobu (Spolchemie) in Ústí nad Labem into the IRZ.
Soruce: Petrlik et al. 2018
600,000
500,000
400,000
300,000
200,000
100,000
0
Amounts of substances in kg
Amounts of selected POPs in wastes from Spolchemie
according to the data in the IRZ • 2004 • 2008
Hexachlorobenzene (HCB)
Hexachlorobutadiene (HCBD)
Pentachlorobenzene
Linear (Hexachlorobenzene (HCB)
Linear (Hexachlorobutadiene (HCBD)
2004
wastes
2008
wastes
2007
wastes
2006
wastes
2005
wastes
PRTRs and Civil Society | 85
Table 4.2 POPs in transfers in wastes reported by Spolek pro chemickou
a hutní výrobu (Spolchemie) in Ústí nad Labem into the IRZ concerning
the period 2004 – 2008; in kg/year. Source: (Petrlik et al. 2018)
Substance 2004 -
wastes
2005 -
wastes
2006 -
wastes
2007 -
wastes
2008 -
wastes
Hexachlorobenzene
(HCB) 423,000 497,000 542,000 489,000 391,000
Hexachlorobutadiene
(HCBD) 161,000 178,000 194,000 175,000 140,000
Naphthalene 1130 720 720 <100 <100
Pentachlorobenzene 26,900 19,100 20,800 18,700 15,000
Sum of HCB, HCBD,
and PeCB 610,900 694,100 756,800 682,700 546,000
4.1.7.3 Estimation of Dioxins in Waste Based on PRTR Data
Arnika and IPEN used data about transfers in wastes from national
PRTRs for the estimation of dioxins (PCDD/Fs) in waste incineration
residues for their study focused on waste incineration fly ash global
control (Petrlik et al. 2021). We calculated an average of PCDD/Fs
reported in WI residues by waste incineration companies to the Czech
PRTR system in 2012 – 2019. An average of 15 g TEQ/year and 20.7 g
TEQ/year were reported for WI ashes from Municipal solid waste incin-
eration (MSWI) and Hazardous waste incineration (HazWI) (including
Medical waste incineration - MedWI), respectively. It is more than
estimated previously for HazWI and MedWI from the Czech Republic.
It is obviously more than estimated in a collective inventory from 2004,
which estimated total releases in waste incineration residues from
HazWI and MedWI to be 5 g I-TEQ and 28 g I-TEQ, respectively, per year
for 13 EU candidate countries (Pulles et al. 2005). In 2006, the Hun-
garian hazardous waste incinerators released more than 11.5 g I-TEQ/
annum (Ministry of Environment and Water 2009) PCDD/Fs into waste
residues. Calculation based on PRTR data has shown that only 2 of 13
former EU candidate states count for the total level estimated for all 13
countries.
Also, Japan reported 1,514 g TEQ of PCDD/Fs in wastes transferred or
buried, such as particulates and burnt residues, according to data from
PRTR for 2018 (Government of Japan 2020).
These examples show that more emphasis should be given to chemi-
cally specific reporting about POPs listed under the SC in waste flows
(transfers) in PRTR systems. The obligation to report PCDD/Fs in waste
to the European PRTR could fill the data gap about PCDD/Fs in WI
residues for many EU states (EEC of SC 2016).
Using data from the national PRTR systems of the Czech Republic and
Japan, the worldwide balance of dioxins in waste is calculated in Arnika
and IPEN’s 2021 study. It reaches 14 - 15 kg TEQ of PCDD/Fs. This seems
to be a bigger share of total PCDD/Fs releases into the environment
than estimated from inventories obtained by the SC Secretariat from
individual countries (EEC of SC 2016).
Another opportunity to utilize data reported to IRZ on dioxin transfers
in waste was mentioned in the context of the update to the National
Implementation Plan of the Stockholm Convention in the Czech
Republic in 2023 (Bláha 2023).
Among the largest producers of PCDD/Fs in waste in the Czech
Republic, according to IRZ data, are metallurgy and waste incineration,
as evident from the table below (see Table 4.3), with some transfers
reported as recycling. Two studies by the IPEN network and Arnika
86 | Pollutant Release and Transfer Register and Civil Society
addressed the issue of dioxins in ashes from waste incineration, high-
lighting potential dioxin leaks into the surrounding areas where these
wastes are managed (Katima et al. 2018; Petrlik and Bell 2017). Global
studies monitoring dioxins and similar substances in free-range eggs
from domestic in various locations, including those where ash from
waste incineration or their surroundings is handled, also document this
concern (Jelinek et al. 2023a; Petrlik et al. 2022a; Weber et al. 2015).
According to data reported to IRZ, nearly 120 g TEQ PCDD/Fs were
transferred in waste between 2014 – 2021, several times more than the
emissions into the air. However, not all data on PCDD/Fs transferred in
waste is included in IRZ. For example, data on PCDD/Fs in waste from
the chemical industry is missing (Bell et al. 2021).
The reported data about dioxins reveal an interesting aspect concern-
ing the municipal waste incineration plant in Liberec (Petrlik et al.
2006). Despite its exemption from reporting obligations to the PRTR,
the incinerator became a significant source of dioxins in waste when it
temporarily halted its practice of converting waste into a product for
European REACH regulation compliance in 2011. This revealed that 8.8 g
TEQ of dioxins ended up in the incinerator’s waste (Petrlik 2013).
The European Food Safety Authority (EFSA) established a tolerable
daily intake of 0.25 picograms of TEQ (toxic equivalent) per kilogram of
body weight in 2018 (EFSA CONTAM 2018). Extrapolating this to a yearly
intake for 1.25 billion people, the tolerable amount is determined to be
8 grams of TEQ. In a city with 100,000 inhabitants, like Liberec, it would
be considered harmful if just 0.008% of this specified amount of dioxins
were to enter the food chain. This underscores the significance of
closely monitoring and controlling the presence of dioxins in the food
supply to safeguard the population’s health (Petrlik, 2023).
In 2016, reporting obligations to the IRZ were waived for small medical
waste incinerators (MV ČR 2016). However, data from previous years
indicates that these incinerators were significant sources of dioxins in
waste, a characteristic shared by small medical waste incinerators in
general (Arar et al. 2019; Jelinek et al. 2023b; Khwaja and Petrlik 2006;
Skalsky et al. 2006). For Indonesia, reporting dioxins and heavy metals,
especially mercury, in euents from small medical waste incinerators
to the PRTR system would be beneficial.
Data from the Czech PRTR confirm that metallurgical operations are
significant sources of dioxins in waste and air emissions. This aligns with
findings of high dioxin and dioxin-like PCB concentrations in eggs from
backyard chickens near metallurgical operations (Jelinek et al., 2023a;
Petrlik et al., 2022a). The examples of Alaverdi in Armenia (Grechko et al.
2021) or the Beihai metallurgical complex in China (Petrlik 2016), and the
earlier discovery of high dioxin concentrations in eggs from Helwan, Egypt
(DiGangi et al. 2005), along with the inclusion of metallurgical operations
in the list of significant sources of dioxin and other POPs in Annex C of the
Table 4.3 Summary of information on dioxins transferred in waste
based on IRZ data; in g TEQ/year.. Source: (MŽP 2022)
Yea r 2014 2015 2016 2017 2018 2019 2020 2021 Average
Municipal
Waste
Incineration 14.77 7.4 2 8.39 28.99 13.87 18.08 8.11 8.74 13.63
Hazardous and
Medical Waste
Incineration 10.67 23.7 17.4 18.98 31.89 39.43 45.16 9.13 22.01
Metallurgy 25.8 48.6 37 199.25 171.43 129.78 106 70.7 83.37
Total 51.24 79.72 62.79 247.22 217.19 187.29 159.27 88.57 119.01
Photos 4.33 – 4.35: A small abandoned medical waste incinerator near
a hospital in Accra, Ghana. A pile of ash residues from waste incinera-
tion showed relatively high concentrations of dioxins. Leaving it acces-
sible to chickens resulted in elevated levels of dioxins in their eggs.
Analyses of samples taken by Arnika in 2018 confirmed this hypothesis
(Hogarh et al. 2019; Petrlik et al. 2019a). Photo: Martin Holzknecht,
Arnika
Photo 4.33
Photo 4.34
88 | Pollutant Release and Transfer Register and Civil Society
Photos 4.36 – 4.37: Small medical waste incinerators built in Asia are
not very dierent from those in Africa. In the photos taken in 2005,
there are two such waste incinerators in Pakistan, Peshawar and
Islamabad (Khwaja and Petrlik 2006). Photo: Jindřich Petrlík, Arnika
Photo 4.37
PRTRs and Civil Society | 89
Stockholm Convention (Stockholm Convention 2008; Stockholm Conven-
tion 2010), underscore the relevance of PRTR for tracking dioxin releases
from metallurgical processes (UNEP and Stockholm Convention 2013).
In summary, the previous text discussed various studies and data
related to the estimation of dioxins in waste, emphasizing the impor-
tance of specific reporting within PRTR systems to address data gaps
and provide accurate information about the presence of persistent
organic pollutants in waste.
4.2 Beyond NGOs: Expanding Horizons of PRTR
Data Utilization
Data from Pollutant Release and Transfer Registers (PRTRs) serve not
only governments (or ministries or environmental agencies) or NGOs
but also individuals, communities (Bui and Mayer 2003), local associ-
ations, scientists, and potential investors (Abashidze et al. 2019). They
also serve society as a whole (Skårman and Sjödin 2013), which places
high demands on the usability of the available data. For the companies
themselves, it can serve to evaluate progress in implementing new,
cleaner production technologies (identifying opportunities, creating
a set of input data for design, implementation and monitoring) (Kolo-
minskas and Sullivan 2004).
One of the most visible results of PRTR implementation is the reduction
of toxic emissions. For example, pharmaceutical companies in the U.S.
saw a more than 60% reduction between 2002 and 2011, which can be
aributed to emissions reporting and the implementation of green
chemistry practices. The PRTR is uniquely suited to assess the progress
that dierent industrial sectors, or specific facilities within them, have
made in adopting green chemistry practices and the eectiveness
of these practices in preventing pollution. Furthermore, the results
suggest that other emission and pollutant transfer registries outside
the USA (PRTR) also have potential for similar purposes (DeVito et
al. 2015). In the U.S. (TRI), access to publicly available data not only
significantly reduced overall pollution but also transformed the role of
the Environmental Protection Agency into a facilitator of information
sharing and voluntary pollution reduction (Jobe 1999).
Photo 4.38: An example of a hazardous waste incinerator from the
Czech Republic with a smaller capacity located in Strakonice burns
mostly medical waste. These waste incinerators have been exempted
from reporting to the Czech PRTR (IRZ) since 2016 despite the high
levels of dioxins in their fly ash (Mach 2017). Photo: Jindřich Petrlík,
Arnika
90 | Pollutant Release and Transfer Register and Civil Society
Photos 4.39 – 4.40: Copper smelter in Alaverdi, a source of POPs
pollution and contamination of free-range chicken eggs in the
surrounding (Grechko et al. 2021; Petrlik and Strakova 2018).
Photo: Ondřej Petrlík, Arnika, 2010
Photo 4.40Photo 4.39
PRTRs and Civil Society | 91
Information reported by companies oen appears in academic articles.
The use of what is considered one of the most comprehensive data
sets available through the PRTR has resulted in numerous studies that
(despite the limitations of the PRTR) have examined the relationship
between toxic releases and their impact on human health (Osornio-Var-
gas et al. 2011). Special articles have also examined real estate prices
aected by the disclosure of emission information in PRTRs in specific
locations (von Graevenitz et al. 2016). PRTR data are generally valuable
for research and have significant potential for identifying priority
research needs that can influence policy, management, and, ultimately,
human health. Despite its inherent limitations, the PRTR represents
a perfect and uniquely valuable resource, yet its use in human health
research seems underutilized (Wine et al. 2014).
An article by Berthiaume, A., in 2021, looked at the use of data from
the Canadian PRTR (NPRI) (Berthiaume 2021). It was found that the
use of NPRI in peer-reviewed research has steadily increased since
1997. Information derived from the NPRI appeared in 225 articles in
academic journals from 1994 to 2019. These data were used primarily
by users from the Canadian government and Canadian universities
and users outside these institutions or outside Canada. Studies
focused on socio-economic issues, waste treatment and remedia-
tion, climate change, indigenous groups, or biomonitoring
(Berthiaume 2021).
Ji & Lee (2016) undertook an interesting study in South Korea. In
summary, traditional methods for testing drinking water have limita-
tions, leading to delays in responding to water incidents. To overcome
this, global trends suggest using risk analysis systems. This study used
a data system (PRTR) to assess the potential risk of harmful chemicals
in drinking water facilities. By looking at factors like the total amount
of chemicals, distance to a city, and chemical toxicity, they identified
the riskiest city using a calculated approach and a statistical method.
The study found that PRTR data helps understand and prevent risks
in water supplies. Although the method may not capture all types of
chemical accidents, it provides a useful way to compare risks between
cities, helping prioritize eorts to reduce potential risks for drinking
water facilities (Ji and Lee 2016).
92 | Pollutant Release and Transfer Register and Civil Society
5.1 OECD Recommendations
The OECD played a pivotal role by developing recommendations
for governments to implement PRTR systems. In 1996, the OECD
Council ocially adopted the “Recommendation of the Council on
Implementing Pollutant Release and Transfer Registers,” which was
revised in 2018 (OECD 2023c). Its full version is in Annex 1 of this
Guide (subchapter 6.1). This recommendation urges OECD Adherents
to transparently establish PRTRs, incorporating principles such as
international comparability, public accessibility, data quality assur-
ance, and continuous evaluation. OECD’s ongoing eorts focus on
providing practical tools, guidance, and support to countries for PRTR
installation, emphasizing data quality improvement, exploring appli-
cations, and harmonizing PRTRs globally (OECD 2023b; OECD 2023c;
UNITAR 2018).
5.1.1 Key Points of the Recommendation
1. Establishment of PRTR Systems: Member countries are encour-
aged to take steps to establish, implement, and make publicly
available PRTR systems. The guiding document for this endeavor is
the OECD Guidance to Governments Manual for PRTRs.
2. Principles for PRTR Systems: In seing up PRTR systems, member
countries are advised to consider a set of principles outlined in the
Annex to the recommendation.
3. Data Sharing: Member countries should consider periodic sharing
of the results of PRTR system implementations among themselves
and, notably, with non-member countries, with a particular focus
on sharing data from border areas.
4. Core Elements of PRTR Systems: When establishing a PRTR,
Member countries should incorporate essential elements into
the system. These include listing pollutants, integrated multi-me-
dia reporting, reporting by source, periodic reporting (preferably
annually), and the imperative to make data available to the
public.
The Annex of the Recommendation enumerates specific principles
that should guide the establishment of PRTR systems. Some of these
include:
5. Crucial Elements of Good PRTR
Crucial Elements of Good PRTR | 93
• Identification and Assessment of Risks: PRTR systems should
furnish data supporting the identification and assessment of
potential risks to humans and the environment.
• Prevention of Pollution: Utilize PRTR data to promote pollution
prevention at the source, such as by encouraging the implementa-
tion of cleaner technologies.
• Cooperation with Stakeholders: Governments should collaborate
with aected and interested parties to establish goals and objec-
tives for the system.
• Involvement of Public and Private Sectors: PRTR systems should
encompass both public and private sectors, including facilities
that may release or transfer substances of interest and, if relevant,
diuse sources.
• Integration with Existing Sources: PRTR systems should be inte-
grated to the extent possible with existing information sources
such as licenses or operating permits to minimize duplicative
reporting.
• Data Accessibility: Results of PRTRs should be promptly and
regularly accessible to all aected and interested parties.
• Mid-Course Evaluation and Flexibility: PRTR systems should
allow for mid-course evaluation and be flexible to adapt to
changing needs.
• Transparency: The entire process of establishing the PRTR system
and its implementation and operation should be transparent and
objective.
These principles underscore the importance of transparency, cooper-
ation, and the use of PRTR data for informed decision-making in the
realm of environmental policy and sustainable development (OECD
2023c).
5.2 Public Access to All Data about Releases from
Individual Industrial and Agricultural Sources
In its recommendations, the OECD emphasizes making PRTR data
accessible to the public (OECD 2023c). Numerous examples demon-
strate that civil society organizations have played a crucial role in
presenting PRTR data to the public in an understandable format. Their
activities are instrumental in exerting pressure on industrial opera-
tions to reduce the release of toxic substances into the environment
(DiGangi 2011; Jobe 1999; Maršák 2008b; Petrlik et al. 2018; Taylor 2004).
In the implementation of PRTR in Thailand, we encountered a recom-
mendation from Japanese experts suggesting that the government
only disclose aggregated data for specific territorial units rather than
information on the quantities of substances released or transferred by
specific industrial facilities. Such a form of disclosure eectively shields
industrial enterprises from natural pressure to reduce emissions of
toxic substances, which is a significant unintended consequence of
introducing PRTR. Consequently, these industrial entities lack a basis
for comparing their environmental performance relative to “compet-
itors” and the eectiveness of their technologies in environmental
protection.
The first PRTR system, namely the Toxics Release Inventory (TRI) in the
USA, was legislated hand in hand with the rule that data must be made
accessible to the public. The law was named the “Emergency Planning
and Community Right-To-Know Act” (Jobe 1999). The U.S. Environmen-
tal Protection Agency (USEPA) stated, “Information also can serve as
a way to reduce risk without using command-and-control regulations.
For example, the information requirements of the Emergency Planning
and Community Right-to-Know Act of 1986 have encouraged compa-
nies to take voluntary actions to reduce their inventories and emissions
of toxic substances” (USEPA 1990).
94 | Pollutant Release and Transfer Register and Civil Society
5.3 PRTR as a New Database: Complementary
Rather an Competitive or Cancelling Existing
Ones
In most countries where reporting to the PRTR is newly established,
other databases where polluters report information about pollutants
already exist or have existed. In the Czech Republic, for example, these
included the Registry of Air Pollution Sources (REZZO) (CHMI 2023) and
the Hydroecological Information System (HEIS) (TGM WRI 2023), among
others. A similar situation is documented in the development of the
PRTR in Moldova (see subchapter 2.5.6). Managers of industrial facil-
ities oen have to repeatedly report similar or identical data to these
databases, leading to resistance against the introduction of another
system like PRTR. Based on our experience at Arnika, it was challenging
to explain to databases like REZZO or HEIS operators that PRTR would
neither eliminate nor jeopardize their databases.
REZZO and HEIS in the Czech Republic continue to operate even aer
almost twenty years of the Integrated Register of Pollutant Releases
(IRZ), the Czech PRTR. They still contain data that cannot be found in
the IRZ. On the other hand, even if we were to combine REZZO and
HEIS under one header (entry page), we would not obtain an equiva-
lent replacement for the IRZ. No other system, except PRTR, gathers
information in one place on the annual total emissions (releases) of a
certain set of substances hazardous to human health and the environ-
ment, both into the air and into water and soil, and additionally trans-
ferred as waste outside of operations.
The situation in Moldova appears to be similar to that in the Czech
Republic when the introduction and initial years of operation of the IRZ
system faced challenges in coordinating the reporting of environmen-
tal data into various inadequately coordinated databases (such as the
air pollution register REZZO, hydrological register HEIS, etc.). The issue
was only resolved by a separate law on integrated reporting system on
the environment (ISPOP), which interconnected the databases and
eliminated the potential for double reporting of data into state-estab-
lished registries focused on environmental data (Maršák 2008a; MV ČR
2008). The solution wouldn’t be some inconsistent mixture of existing
databases, as it would not be navigable nor comply with the require-
ments of the PRTR Protocol. Creating a unified reporting system at the
national level is therefore crucial for a user-friendly PRTR system for
reporters and users. Using Moldova as an example, it can be seen that
the failure to address this issue may hinder the further functioning of
PRTR itself.
Coordination with reporting obligations within international con-
ventions is also important, as demonstrated by a study from Sweden
(Skårman et al. 2014). “The study shows that there are synergies regard-
ing operations, substances, receiving medium, public participation
and capacity building between the PRTR and those regulations that
are included in the project. At the same time, the study also shows
that although common traits can be identified, the same information
is not required by any two regulations, but each regulation is unique”
(Skårman et al. 2014).
As evident from the UNITAR handbook from 1998 (UNITAR 1998), the
duplicity of reporting to various databases has been a problem since
the inception of PRTRs: “Much of the information which will be used
to generate the PRTR reports are data that are collected by various
departments and for reasons other than PRTR reporting. Thus, these
departments/personnel may need to provide a duplicate data set to be
stored with the PRTR coordinator. In some cases, the data collection
forms used by various departments may have to be redesigned to
include new data elements needed for PRTR reporting “(UNITAR 1998).
Crucial Elements of Good PRTR | 95
5.4 Civil Society Organizations as Stakeholders
of PRTR Design Process
Pollutant Release and Transfer Registers (PRTR) have become an
essential information tool for driving toxics use reduction by making
emissions information from industrial facilities public (DiGangi 2011).
Policy-makers stand to gain valuable insights from an in-depth analysis
of aggregate PRTR data, enabling them to discern trends in specific
substances and substance groups, such as carcinogens, persistent
bio-accumulative toxins, VOCs, contributors to smog formation, ozone
depleters, and more. Additionally, the analysis can shed light on the
performance of various industrial sectors, geographical distribution,
including ecosystem analysis, and the eectiveness of specific envi-
ronmental policies. This comprehensive approach facilitates informed
decision-making and the development of strategies that address the
multifaceted aspects of environmental concerns (OECD 2000).
The Kyiv PRTR protocol of the Aarhus Convention explicitly mentions
that each Party shall design the PRTR in a way that “Allows for public
participation in its development and modification “(UNECE 2003).
Engaging in consultations with potential audiences or users of PRTR
data, including the public, industry, and NGOs, is crucial in identifying
the information needs a PRTR could eectively address. This process
aids in directing resources and eorts toward approaches that best
align with the public’s requirements. A meticulous examination of goals,
target audiences, and specific information needs may suggest tailored
delivery mechanisms, ensuring data availability in diverse formats to
cater to various objectives (OECD 2000).
Engagement of the civil society is indirectly listed among basic guiding
principles for the establishment of PRTR as mentioned already earlier in
this Guide: “In designing or modifying a PRTR system, the government
should consult with aected and interested parties to develop a set of
goals and objectives for the system” (OECD 1997).
Through strategic coalitions, Mexican environmental NGOs success-
fully influenced the government to switch from voluntary to mandatory
reporting for RETC (Mexican PRTR system). These groups employed
eective pressure methods, making a lasting impact on RETC’s design
and implementation. Many NGO representatives who advocated for
mandatory reporting are now part of the Mexican consultative group
Photo 5.1: Arnika actively participated in several Aarhus Convention
and PRTR Protocol meetings. This photo comes from the meeting in
Maastricht in 2014. Photo: Arnika
96 | Pollutant Release and Transfer Register and Civil Society
for RETC. They regularly meet with the RETC team at SEMARNAT,
showcasing a successful collaboration between environmental NGOs
and the government. Many see this as a notable success story in
environmental advocacy (Pacheco-Vega 2015).
Czech NGOs Children of the Earth (Děti Země), and since 2001 also
Arnika participated extensively in the design and implementation of
PRTR in the country beginning in the 1990s, long before the country
became an EU Member State. To help instigate the process, Arnika
worked to generate more than 10,000 signatures on a petition that
called for PRTR and included local authorities and scientists as signato-
ries (DiGangi 2011). The chemical industry initially opposed the process
but eventually conceded that the PRTR could cover more substances
than the European Pollutant Emission Register (EPER), which was the
predecessor of the E-PRTR.
Civil society organizations have become advocates for presenting
PRTR data to the public in an easily understandable format, eliminating
the need for extensive navigation between pages. Examples of such
systems include FactoryWatch (Taylor 2004) and PollutionWatch
(Environmental Defence and CELA 2004), with the Czech organization
Arnika’s website, Znecisovatele.cz (Polluters), being one of them. Their
examples have influenced the ocial presentation of data, including
the new design of the E-PRTR.
5.5 Concerns of Industrial Companies
Industrial enterprises and their associations generally do not welcome
the implementation of the PRTR. Their concerns were well summarized
by a case study of a petrochemical complex in the Map Ta Phut Indus-
trial Estate, Rayong, Thailand: “The petrochemical industry expressed
their concerns on the PRTR such as cost increases, overlaps in report-
ing systems, manpower needs, the lack of governmental feedback, and
the lack of knowledge on chemical substances among stakeholders”
(Kondo and Limjirakan 2013).
A common worry of industrial firms is that disclosing the quantities of
consumed and emied substances through such specific reporting will
reveal their trade secrets. However, this is an unfounded concern. A
robust PRTR system allows them to keep sensitive data confidential for
trade secret reasons. However, they usually must demonstrate to the
state administration authorities collecting data for the PRTR that the
request for confidentiality is genuinely due to trade secrets and not for
other reasons, such as concerns about public reactions.
Regarding the possibilities of keeping certain data confidential, the
publication “PRTR System in Questions and Answers” (Nadace Partner-
ství - Právo vědět, 1997) states: "The reporter has the right to request
the confidentiality of identifying a specific substance if they prove
that the information is sensitive in terms of protecting the production
process. However, they cannot request an exemption from the reporting
obligation. Confidentiality cannot relate to data on the release of the
substance into the environment but only to other data, such as the pro-
cessed quantity or retention of the substance in the production facility.
Experiences from other countries prove that manufacturers rarely
request data confidentiality. An alternative name for the substance is
provided in the public PRTR register outputs."
Before the launch of PRTR, there are usually significant concerns
among reporters, leading to exaggerated demands for data confidenti-
ality options. Foreign experiences show that the proportion of requests
for confidentiality in various systems ranges from a few percent to a
few thousandths of reports submied.
Crucial Elements of Good PRTR | 97
5.5.1 Benefits of PRTR for Industry
The systematic data collection required for PRTR reporting serves reg-
ulatory purposes and oers various advantages to industrial facilities
(UNITAR 2018). These benefits encompass:
1. Identifying Opportunities for Release Reduction: PRTR data
enables industrial facilities to pinpoint opportunities for reducing
releases.
2. Enhancing Safety and Eciency: Utilizing PRTR data helps
maintain the safety of workers, industrial facilities, and produc-
tion units, leading to improved processes, reduced costs, and
increased overall eciency. Pollution prevention initiatives,
such as employing alternative chemicals, implementing beer
chemical use controls, enhancing equipment eciency, refining
manufacturing processes, and reducing point source and fugitive
emissions, contribute to this improvement.
3. Incentivizing Innovation: Implementing PRTR encourages indus-
tries to find innovative solutions and adopt cleaner technologies
to enhance their environmental performance.
4. Monitoring Progress Towards Sustainable Development: PRTR
data serves as a metric to evaluate an industry’s progress towards
sustainable development, recording trends over time.
5. Accessing Markets with Higher Environmental Standards:
Industries with robust PRTR practices gain access to markets with
higher environmental requirements, demonstrating their commit-
ment to environmental responsibility.
6. Community Engagement for Environmental Protection: Col-
laborating with communities based on PRTR data fosters partner-
ships to improve environmental protection.
7. Mitigating Public and Government Concerns: PRTR implemen-
tation allows industries to identify mitigation actions that are
more likely to gain public and government acceptance.
8. Building Corporate Image and Trust: Dissemination of PRTR
data strengthens the corporate image and enhances relations
with society and communities, fostering trust and confidence
among community members.
9. Benchmarking Industry Performance: Comparing industry
performance against peers facilitates benchmarking, potentially
leading to the transfer of technology and knowledge within and
among companies.
A U.S. Environmental Protection Agency study utilized data on
370,000 source reduction activities reported to the U.S. Toxics
Release Inventory over 25 years. The study found that these projects
prevented the release of between 5 and 15 billion pounds of chem-
icals, showcasing the tangible impact of such initiatives (UNITAR
2018).
Literature on the implementation of PRTRs provides numerous
examples highlighting the benefits of such systems for companies,
further emphasizing the positive outcomes of PRTR adoption.
Richard Royall, a representative of Xerox, emphasized the transfor-
mative impact of publicly accessible integrated pollution registries,
particularly citing the American TRI. He asserted that since 1988, these
registries contributed to a notable 50% reduction in harmful substance
emissions in the USA. According to Royall, the TRI exposed unforeseen
emission sources across various facilities, resulting in substantial
savings for these enterprises. Specifically, between 1998 and 1999,
Xerox achieved a commendable 27% reduction in total reported emis-
sions to the TRI (Royall 2000).
During a lecture in the Czech Republic, Royall (2000) highlighted
several benefits of implementing the PRTR for industrial enterprises
98 | Pollutant Release and Transfer Register and Civil Society
beyond economic savings. These advantages included improve-
ments in reputation, elimination of communication barriers with
the surrounding community, demonstration of a commitment to
environmental protection, engagement of local residents, a basis for
technological improvements, scaling of production eciency and
emission reduction, beer resource management, and inspiration for
technological innovation.
The magazine “Chemical and Engineering News” reported that
introducing the TRI system in the USA in 1987 initially shocked many
managers. The transparency brought by the TRI revealed significant
chemical emissions, prompting awareness and action within indus-
tries.
Another case illustrating the positive impact of integrated registries
on industry savings is exemplified by 3M, an American company.
Implementing the “Pollution Prevention Pays” (3P) employee program
across its facilities, 3M achieved a remarkable 50% reduction in
waste production, resulting in total savings of nearly $600 million.
The company initiated 2,500 projects globally, leading to substantial
achievements, such as a 92% reduction in solvent use in the Neth-
erlands, a 95% decrease in air emissions in Ribas, Spain, and a 75%
reduction in solid waste production in Geroinon, Wales (Muir et
al. 1995).
Inspired by the introduction of the integrated pollution registry system
and free access to information through the Toxics Release Inventory,
3M went further by adopting an ambitious program, 3P Plus. This
program aimed to reduce releases into water, air, and solid waste by
90% (compared to 1987), aiming to achieve the lowest technically
achievable levels (Muir et al. 1995).
In 1988, the US EPA announced the so-called 33/50 Program, which is
further explained in an excerpt from the publication by W. R. Muir et al.
(1995).
In the “33/50 Program,” the EPA selected 17 priority toxic chemicals and
requested the industry to voluntarily join the program and meet its goals
– a 33% reduction in targeted chemical emissions by the end of 1992 and
a 50% reduction by the end of 1995. The baseline values were determined
in 1988. The program intended to achieve even greater reductions beyond
Table 5.1 Examples of the highest reduction in releases of toxic sub-
stances in the USA between 1988 and 1993 as a result of the implemen-
tation of the TRI system and the subsequent activities, particularly the
“33/50 Program” by the US EPA. Source: (Muir et al. 1995)
REDUCTION IN RELEASES OF TOXIC SUBSTANCES 1988 - 1993
10 substances with highest reduction in releases Percentage
Ammonium sulphate -98.0
Hydrochloric acid -53.1
Toluene -40.4
1,1,1- Trichloroethane -64.3
Acetone -39.4
Methanol -26.9
Dichloromethane -50.0
Chlorine -46.0
Freon 113 -86.1
Methyl ethyl ketone -39.2
Overall reduction (-677 001 tun) -58.0%
Crucial Elements of Good PRTR | 99
the obligations required by legal regulations and to do so more rapidly and
operationally than is possible through regulatory mechanisms.
Aer the program was announced, more than 1,200 industrial companies
commied to voluntarily reducing emissions of priority chemicals. Many
businesses pledged more substantial reductions, oen reaching 90% or
more. Overall releases and transfers of priority chemicals significantly
decreased from the initial 1.47 billion pounds (665 million kg) in 1988 to
973 million pounds (441 million kg) in 1991, representing a total reduction
of 34% compared to the baseline. The first goal of the program, a 33%
reduction, was achieved one year earlier than expected. (Muir et al. 1995)
The examples of savings or emission reductions provided here come
from the industrial sector. I have not mentioned any from the agri-
cultural sector, even though agricultural enterprises will also have to
report emissions of toxic substances from their operations to the PRTR.
In the USA, the TRI system initially applied only to selected industrial
sectors. Therefore, examples of savings and emission reductions come
from the industrial sector. If TRI were not limited to certain industrial
sectors, there would undoubtedly be examples of savings in resources
and finances from large agricultural enterprises. Royall (2000) warned
against limiting the obligation to report to the PRTR only for certain
economic activities precisely because this system helps uncover
unforeseen sources of emissions of toxic substances.
5.6 Chemically Specific Reporting
About Waste Transfers
In the Czech Republic, data on amounts of chemical substances in
wastes are not centrally summarised in any other database than in the
IRZ. Information on the chemical composition of wastes is present in
Figure 5.1 Ten industrial sectors in the USA with the greatest emissions
reduction for 1988-93. Data are in millions of kilograms.
Source: (Muir et al., 1995)
- 15
- 17
- 23
- 23
- 30
- 41
- 43
- 119
- 172
- 510
- 600 - 400 - 200 0
Photography
Engineering
Plastics
Textile
Paper
Transport
Eectronics
Heavy ind.
Mixed ind
Chemical
100 | Pollutant Release and Transfer Register and Civil Society
documents for waste transport and/or may be stated in records doc-
umenting the operation of facilities for waste management. However,
this information is neither recorded nor processed centrally, and its
processing would not result in such a comprehensive system as the
IRZ. It is a pity that the duty to report the presence of chemical sub-
stances in waste was not introduced generally in the EU.
Usually, reporting of transfers of chemical substances does not give
rise to the duty of new measurements. From the very nature of the
problem, the chemical composition of wastes leaving the premises
of industrial facilities has to be found, given limitations valid for the
individual facilities for waste disposal or utilization. The IRZ required
that substances in wastes are to be reported in 72 cases of the total list,
which had 93 items in 2008 (Petrlik et al. 2018). However, the number
of the reported substances is even much lower, a bit more than half, as
shown in Table 5.2.
Table 5.2 Numbers of substances really reported according to the
release/transfer type. Source: (MŽP 2022)
Release/transfer type 2004 2005 2006 2007 2008
Releases into the air 36 36 39 36 36
Releases into water 24 24 25 31 30
Releases into soil 10 10 0 0 0
Transfers in wastewater 32 22 25 28 30
Transfers in waste 34 38 40 39 41
The main argument against the publication of data on chemical sub-
stances in waste is the statement that it is a duplication. However,
proponents of this opinion have not yet proved that similar data could
be found in any other central database. In the CEHO (Center for Waste
Management) system, which they mention when arguing by duplica-
tion, it may be found what amounts of waste a facility produces in the
individual waste categories. However, the system does not contain any
data on the contents of specific substances.
The state administration has no other available database where infor-
mation on, for example, mercury or hexachlorobenzene amounts in
wastes may be found easily. In fact, both these substances belong to
priority ones from the point of view of international conventions and
European strategies. Because of that, it is a pity that the duty to report
the presence of these substances in waste has not been set at the EU
level. From the point of view of the usability of such data, it is a pity that
the reporting threshold has been set at the level of 5 kg in the Czech
Register, which is a relatively high mercury amount.
The importance of waste monitoring in the IRZ may be well doc-
umented by the case of mercury and other heavy metals and/or
persistent organic pollutants, as is obvious from the corresponding
chapters of this study. Both cases will illustrate the importance of
reporting chemical substances in waste from the standpoint of moni-
toring compliance with international conventions and strategies at the
EU level (Petrlik et al., 2018). From this point of view, the IRZ data are an
underestimated information source.
Ji & Lee (2016) used a data system (PRTR) including data about chemi-
cals in waste transfers to assess the potential risk of harmful chemicals
in drinking water facilities in Korea. Also, the Japanese PRTR finds
specific reporting about chemicals in waste transfers valuable: “The
volume of targeted chemicals contained in the wastes was one of the
most important types of data, yet was not always available” (Yamagu-
chi 1999).
Crucial Elements of Good PRTR | 101
Some systems, like the European PRTR, need companies to report what
chemicals they send to public sewerage facilities. But when it comes
to other scenarios like recycling, the focus is on whether the transfer is
hazardous or not. It was concluded one very recent study focused on
PRTR data (Hernandez-Betancur et al. 2023). The problem is, if we only
collect data on chemicals going to sewerage systems and not all End-
of-Life scenarios, it could create a skewed picture (imbalanced data)
for future models. This can make it tough to build accurate models,
potentially causing mistakes when categorizing End-of-Life activities
(Hernandez-Betancur et al. 2023).
This problem aligns with a broader concern highlighted in a recent
European Court of Auditors review addressing hazardous waste (ECA
2023). The review notes that, despite decontamination eorts, recycled
materials, including paper, plastics, rubber, and textiles, still contain
a range of hazardous substances (Behnisch et al. 2023; DiGangi et al.
2011; ChemSec 2021; Strakova et al. 2023a; Straková et al. 2018; Strakova
et al. 2022). The lack of information on the chemical composition of
the waste treated by recyclers is a key factor contributing to this issue
(BiPRO 2017).
We propose that addressing this knowledge gap could be achieved by
enhancing reporting on the flows of toxic chemicals, as outlined in the
PRTR reporting scheme. Specifically, focusing on POPs in chemically
specific reporting for waste transfers, both in the E-PRTR and the Kyiv
PRTR Protocol, could significantly contribute to bridging the gap in
information on the chemical composition of waste treated by recyclers.
It agrees with a suggestion by Article 10 of the Stockholm Convention,
which declares that PRTRs serve as crucial tools for monitoring and
reporting POPs, supporting compliance with convention requirements
(Stockholm Convention 2010).
This problem is closely related to another one stated in a recent EU
Action plan addressing hazardous waste: “Recent studies have shown
that, despite decontamination, a wide range of hazardous substances
(including some phased-out by EU legislation) have been found in
recycled materials, including paper, plastics, rubber, and textiles. This
is mainly because recyclers lack information on the chemical compo-
sition of the waste they treat and can therefore not carry out proper
decontamination.” We believe that increased knowledge about the
flows of toxic chemicals (listed in the PRTR reporting scheme) in waste
transfers could significantly fill the gap in “lack of information on the
chemical composition of the waste” treated by recyclers. Especially
POPs should be covered in chemically specific reporting on waste
transfers in E-PRTR and the Kyiv PRTR Protocol.
5.7 Estimation of the Releases - Tools
For the determination of annual releases and transfers of substances
for reporting to the PRTR, there are essentially three basic options:
1) direct measurement and calculation based on it; 2) estimation using
emission factors determined (calculated and published) for a specific
type of industrial activity and level of technology; and 3) expert estima-
tion (OECD 2005). Most laws implementing the PRTR allow for all three
options. It is not always possible to measure the relevant substances
and calculate the annual volume of the release/transfer based on the
measurements. This system of three methods for estimating the annual
quantity of released/transferred substances is described for the Czech
PRTR in subchapter 2.3.1.3 in this guide.
Handbooks have been created to assist in the calculation of national
inventories of emissions and transfers of certain substances for the
purposes of international conventions. These handbooks establish
102 | Pollutant Release and Transfer Register and Civil Society
emission factors for relevant substances (such as mercury or dioxins)
based on scientific literature specific to a type of activity and the level
of technology used. These emission factors serve as a substitute for
direct emissions measurement or transfers from individual sources. For
reporters, finding their technology in these handbooks and entering
the annual production volume or utilized capacity, such as the quantity
of waste burned in the respective year is sucient. Examples of such
handbooks include international ones for dioxins (UNEP and Stock-
holm Convention 2013) or mercury (UNEP Chemicals 2013), as well as
national ones, for example, from the Netherlands (Honig et al. 2021).
Clearinghouse on estimation techniques is also very broadly presented
on the OECD website (OECD 2023d) and includes links to various
national guides and/or handbooks, e.g., from Australia, Canada, Chile,
EU, or USA.
In 2005, the OECD released a guide on the selection of estimation
techniques. It provides a procedure for deciding which estimation tech-
nique to choose and describes details about their usage. The guide also
discusses the uncertainty that cannot be avoided in determining and
estimating annual releases/transfers. This document is certainly rec-
ommended for everyone starting with PRTR, whether they are involved
in creating the register or are reporters (OECD 2005).
5.8 Seing the Good resholds for Reporting
Obligation
In Germany, in 2021, a detailed analysis of their PRTR, essentially a
replica of the E-PRTR, was conducted. Among other findings, it was
concluded that the set reporting thresholds fail to capture a sucient
amount of major sources of toxic substance emissions in the country.
The necessity to lower the reporting thresholds or adjust them to
reflect approximately 90% of the total industrial emissions of the
respective pollutant emerged from a questionnaire campaign and
interviews as the most pressing need for adjustment in terms of the
meaningfulness of PRTR data. The need for adjustments in this regard
also arose from an analysis of the coverage of PRTR emission data,
comparing air and water data for specific pollutants with emissions
reports according to the 11th BImSchV and eKomm data. For only 19%
of the tested pollutants, it was possible to determine a coverage level of
80 - 100% of the total emissions of the respective pollutant into the air.
For the remaining 36 tested pollutants, the detection level was either
higher than 100% or significantly lower (Zel et al. 2021).
The inadequacy of reporting thresholds, essentially determined by
political decisions during the negotiation of the Kyiv PRTR Protocol,
was also highlighted in earlier studies by Arnika analyzing data from
the Czech PRTR. A case study in subchapter 4.1.6.2 of this guide
examined the issue of reporting thresholds using hexachlorobenzene
as an example. Lowering reporting thresholds and introducing a duty
to report HCB in wastes, similar to other POPs, could provide more
accurate and objective data (Petrlík 2010).
5.9 Coverage of the Most Important Pollutants
and Modifications of eir List
The PRTR should not be a static system because the use of chemical
substances in industry is rapidly evolving, and some already prohib-
ited substances are slowly disappearing. From this perspective, for
example, the list of substances in the Kyiv PRTR Protocol of the Aarhus
Convention is very conservative, reflecting the situation in the 1990s
when it was created. Since then, however, several new pollutants have
Crucial Elements of Good PRTR | 103
emerged, and the problem of substances released during the produc-
tion, use, and disposal of plastic waste has grown. The current state
of knowledge is not reflected in the reporting thresholds for releasing
(emission) chemical substances into the air or water in the Kyiv PRTR
Protocol.
This recommendation reflects the need to revise the list of substances
in PRTR systems at the international and national levels (Zel et al.
2021). Ideally, such revisions should be conducted by a commission
established by the Ministry of Environment and/or government at
the national level with representation from all stakeholders, includ-
ing industry and civil society organizations. The involvement of the
academic community is crucial for assessing the risks associated with
individual substances.
One study evaluating the functionality of the Canadian NPRI con-
cluded: “While relative pollutant release levels have decreased, overall
toxicity has increased. Coupled with the omission of toxicity factors
and pollutant thresholds from the NPRI, this creates a false sense of
progress for stakeholders” (Johnston Edwards and Walker 2019). Its
analysis shows that early PRTR systems focused on substances emied
in large volumes but omied substances released into the environment
in small volumes, yet more toxic.
Most PRTR systems but U.S. TRI and Czech IRZ14 lack substances like
PFAS (Audrlická Vavrušová et al. 2022; MŽP 2021b; USEPA 2022a),
whose flows would be important to monitor due to their toxicity even
at low concentrations (Chang et al. 2016; Strakova et al. 2023b; Szilagyi
et al. 2020). Although PRTR systems track chlorinated dioxins (PCDD/
Fs) (Petrlik et al. 2018), they have omied similar brominated dioxins
14 PFASs will be reported into the Czech PRTR from 2025 (MŽP 2021b).
(PBDD/Fs), which are equally toxic substances (Behnisch et al. 2023;
Birnbaum et al. 2003). PRTR systems appear inflexible in reflecting
the most toxic substances released into the environment (Johnston
Edwards and Walker 2019).
The global list of substances monitored in PRTR systems compiled by
the OECD contains 1,274 items (OECD 2021). OECD describes the list
as follows: “The OECD examined the pollutants and reporting sectors
Table 5.3 Numbers of substances in various PRTRs – overview based
on previous subchapters. Sources: (Australian Government 2022; CELA
2023; European Parliament and Council 2006; French Republic 2012;
Ministerio del Medio Ambiente 2022; MoE-GoJ 2007; Mogilyuk 2017;
MŽP 2021b; Nakachi 2010; USEPA 2023c; Wever et al. 2023)
Country Number of substances in PRTR
Europe (E-PRTR) 91
Czech Republic (IRZ) 97
France (IREP) 191
Netherlands 375
USA 794
Canada 320
Australia 93
Japan 477
Korea 388
Chile 121
Kazakhstan 86
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Photo 5.3: Pastor R. L. Gundy of Mount Sinai Missionary Baptist
Church, who has been diagnosed with prostate cancer, lived in 2009
in Jacksonville, USA, in the vicinity of a waste incineration ash dumps.
According to the 1990 U.S. census, more than 30 thousand inhabitants
lived in four sites contaminated with ash. Sources: (Morrison 2009;
Petrlik and Bell 2017; USEPA ROD 2006)
Photo 5.2: The man in the photo lived when it was taken in 2016 in the
vicinity of the petrochemical complex in Map Ta Phut, Thailand. Map
Ta Phut was found to be contaminated with POPs, heavy metals, and
VOCs (Bystriansky et al. 2018). The incidence rates of all types of cancer
and leukemia in Rayong’s Muang district, where Map Ta Phut is located,
were higher than those of other districts of the province (Hassarungsee
and Kiatiprajuk 2010). Photo: Ondřej Petrlík, Arnika
Photos 5.2 and 5.3: Various pollutants released or deposited by industry into the environment can induce or contribute to cancer development
(being potential or proven carcinogens). Therefore, the most hazardous substances need to be listed in the PRTR. On the photographs are two men
from dierent corners of the world, both suered from cancer at the time the photos were taken. Of course, we do not know to what extent indus-
trial activities in their vicinity contributed to this, but in the vicinity of steelworks, chemical plants and waste incinerators, cases of cancer may be
more frequent (Domingo et al. 2020; Garcia-Perez et al. 2013; García-Pérez et al. 2010; Garcia-Perez et al. 2016; Jirik et al. 2021; Li et al. 2011; López-
Abente et al. 2012). TRI in the USA was used as an important source of information in a study focused on the association between six environmental
chemicals and lung cancer incidence in the United States. (Luo et al. 2011)
Crucial Elements of Good PRTR | 105
covered by PRTRs around the world to develop a harmonized list of
pollutants/reporting sectors common to most PRTRs. The findings are
presented in the Harmonised List of Pollutants/Sectors. It describes the
methods used and the resulting lists. It provides the harmonized lists in
a format that others can use to develop their own pollutant/sector lists
or conduct multi-country analyses “(OECD 2021). The Global PRTR also
presents statistics for certain pollutants collected from various PRTRs
from 2008 to 2017.
The new study aempted to evaluate the toxicity of emissions based
on the E-PRTR and identified a limited number of substances, number-
ing less than a hundred, as a limiting factor (Erhart and Erhart 2023):
“The obstacles to the toxicity impact potentials analysis based on the
E-PRTR are numerous. One obstacle to our approach is that the number
of substances in the E-PRTR is limited, as less than 100 pollutants are
on the E-PRTR reporting list, which is well below the 100,000 chemical
products listed in the Swedish System of Environmental and Economic
Accounting (Persson et al. 2019). The E-PRTR list itself is also being
revised currently (Erhart and Erhart 2022).“
5.10 Small and Medium-sized Enterprises and
Other Recommendations by the Toxic Watch
Network, Japan on PRTRs in Asian Countries
When introducing PRTR systems to countries where there are oen
many small and medium-sized enterprises, governments should adopt
a system for estimating releases from such smaller sites, similar to
the approach taken by the Japanese government. Governments may
need on-site inspections to calculate the quantities in use and releases
from those sites. The results can then serve as a basis for estimating
releases from small and medium-sized enterprises nationwide.
Additionally, independent research conducted by the Toxic Watch
Network has armed the necessity of including small-scale business
operators employing fewer than 21 individuals, who are currently
not obligated to report the quantity of any chemicals they release.
(Mizutani et al. 2021). That study also “estimated the distribution of
emissions from small-scale businesses. Depending on the chemical
substance and industry, the estimated distribution of the released
chemicals diered from that in the PRTR. This finding suggested that
the reported release in PRTR was insucient in assessing the risk of
chemical leakage during a natural disaster.” (Mizutani et al. 2021)
Before implementing a PRTR system, governments should conduct
pilot programs for approximately three years. The Japanese govern-
ment initiated a three-year PRTR pilot program in 1998, before the
system’s ocial launch in 2001. In the last year of the pilot program,
the Japanese government asked approximately 2,000 sites in 30 pre-
fectures to report their releases voluntarily. This amounted to 5% of all
sites with reporting requirements, and the number of persons in charge
and involved in the program was rather limited. Nevertheless, it is
considered that the pilot program greatly facilitated the full implemen-
tation of the PRTR system (Nakachi 2010).
There are many subsidiary companies of European or Japanese group
companies in Asian countries. When introducing PRTR systems in
Asian countries, they should be designed to require corporations to
satisfy the same standards as their parent corporations in Europe or
Japan to avoid double standards. Such standards should be applied not
only to reported releases of chemical substances but also to environ-
mental reports and MSDS (Nakachi 2010).
In Japan, quantities being handled at a site are not disclosed due to
strong opposition by industry. However, handling amounts is crucial to
106 | Pollutant Release and Transfer Register and Civil Society
assess appropriately per unit whether the reported data are accurate
and whether a reduction of releases has been promoted. These han-
dling amounts should be reported in addition to the released amounts
(Nakachi 2010).
The ocial Korean PRTR site in English contains aggregated data for
2001 – 2012 only (NICS 2014). More specific data on various industrial
sectors can be downloaded in PDF format from that website.
5.10.1 Small and Medium-sized Enterprises and Indus-
trial Productions in Indonesia
The discussed small and medium-scale industrial productions are
abundant in Indonesia.
Those mentioned above small and medium-scale industrial pro-
ductions are numerous in Indonesia, as we confirmed during joint
projects with Nexus3 and Arnika. These operations can be significant
sources of pollution with toxic substances such as dioxins, bromi-
nated flame retardants, and mercury. For instance, several dozen
small aluminum smelters in Kendalsari are significant sources of
dioxin emissions, as are several dozen tofu factories in Tropodo or
Photo 5.5Photos 5.4 - 5.5: Tofu factories in Tropodo replaced wood with plastic
waste as fuel and became a serious threat to public health. High
levels of POPs, including dioxins and/or BFRs, were measured in local
food sources (Ismawati et al. 2021; Petrlik et al. 2019b). Such pollution
sources should be somehow included in future PRTR in Indonesia.
Photo: Jindřich Petrlík, Arnika, 2019
Crucial Elements of Good PRTR | 107
Photo 5.7
Photo 5.6
Photos 5.6 – 5.9: Similar to the tofu factories in Tropodo, a series of
small aluminum foundries in Kendalsari is a somewhat analogous
source of pollution. They also emit dioxins while simultaneously
producing waste residues containing relatively high concentrations
of dioxins. Moreover, these residues are provided to the villagers for
constructing road reinforcements and river embankments (photo 5.9)
(Petrlik et al. 2020). Photo: 5.6 – 5.8 Jindřich Petrlík, Arnika; 5.9 Ecoton
108 | Pollutant Release and Transfer Register and Civil Society
lime kilns in Karawang that burn plastics instead of traditional wood
as fuel (Ismawati et al. 2021; Ismawati et al. 2022; Petrlik et al. 2022b).
It’s airborne emissions and the transfer of dioxins in waste in the form
of ash used in villages for road and river embankment stabilization
(Petrlik et al. 2020).
5.10.1.1 Artisanal and Small-Scale Gold Mining (ASGM)
The extraction of gold in ASGM is carried out with mercury, leading to
significant environmental pollution in both water and air. In areas where
ASGM is practiced in developing countries, high concentrations of
mercury have been detected in both fish and the hair of people working
and living there (Evers et al. 2013; Fernandez 2013;
Gerson et al. 2018; Gonzalez et al. 2013; Ismawati et al. 2013; Mng’anya
et al. 2013; Sherman et al. 2015; Trasande et al. 2016). At some Indone-
sian ASGM sites, people experience a disease very similar to one called
Minamata disease, caused by mercury poisoning (Price and Price 2015).
More than two thousand gold mining locations exist in present-day
Indonesia. Artisanal and small-scale gold mining (ASGM) sites are
spread out across thirty provinces in Indonesia (Meutia et al. 2022).
At gold processing sites where mercury is burned, BaliFokus found
ambient air mercury concentrations greater than 51,000 nanograms per
cubic meter, the highest level their meters could measure, or more than
50 times the safe level established by the World Health Organization.
Photo 5.9Photo 5.8
Crucial Elements of Good PRTR | 109
Photo 5.11
Photo 5.12
Photo 5.10
Photos 5.10 – 5.13: In Karawang, where a series of lime kilns are
located, experts from Nexus3 and Arniky collected samples of ash
from kilns, soil, and free-range chicken eggs from local poultry farms:
“Very serious contamination of the environment and food chain with
POPs as a result of using plastic and rubber waste as fuel in lime kilns
in Karawang Regency was confirmed by measurements of samples of
ash, soil, and free-range chicken eggs” (Petrlik et al. 2022b). The con-
tamination of eggs with dioxins was among the highest ever measured
levels in Asia and globally. (Petrlik et al. 2022a). Photo: 5.10 - 5.12 Ondřej
Petrlík, Arnika, 2022 and 5.13 Nexus3, 2022
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Photo 5.13
Photo 5.14: Poboya, Central Sulawesi. Block A mining site. The photo
was taken in June 2011. Over 20,000 miners from dierent areas of
Indonesia work under the 40 - 100-meter-deep shas. Photo: Yuyun
Ismawati, Nexus3
Crucial Elements of Good PRTR | 111
Photo 5.16
Photo 5.17
Photo 5.15: The pond’s surface in Kasepuhan Adat Cisitu, Lebak Regency.
The ASGM site is so contaminated with mercury that mercury bubbles
have formed on the local pond’s surface. Photo: Yuyun Ismawati, Nexus3
Photos 5.16 and 5.17: ASGM is not only a problem in Indonesia. ASGM
sites in Tanzania and Nigeria.
Photos: Agenda, Tanzania and Dame Yinka via Wikimedia Commons.
112 | Pollutant Release and Transfer Register and Civil Society
Soil and water samples also had high mercury concentrations, ranging
from 600 to 3,000 times the acceptable limits established by the WHO.
Rice tested on Cisitu had mercury contamination that ranged from 0.81
ppb to 241.90 ppb (Price and Price 2015).
In 2008, ASGM was identified as the second-largest source of global
atmospheric mercury pollution (UNEP Chemicals Branch 2008). The
estimated mercury releases from ASGM should also appear in the PRTR
as estimates from small and medium-sized enterprises in Indonesia.
However, it cannot be expected that operators of these small artisanal
operations will estimate and report their toxic substance releases to
the PRTR on their own. Therefore, it is necessary to introduce a tool to
assist PRTR-managing institutions or regional administrative author-
ities in calculating and entering the data into the reporting system.
For example, the Mercury Toolkit includes the calculation of mercury
releases from ASGM (UNEP Chemicals 2013).
5.11 PRTR and Water Pollution
PRTR is oen the sole accessible and comprehensive source of
information on substances released into water. Consequently, various
institutions and researchers utilize it for water protection purposes.
Similarly to other cases, the crucial factor here is how sensitively the
reporting thresholds are set, both for reporting substances in water
discharges and their transfers in wastewater and waste.
In a study conducted by Yamagata et al. (2006), the focus centered
on selecting 30 chemical substances, specifically those identified or
nominated within environmental criteria and recognized as endocrine
disrupters. The researchers meticulously gathered data on the volume
of discharged chemical substances from public and industrial wastewa-
ter treatment plants, relying on information from the Pollution Release
and Transfer Register (PRTR). The investigation extended to observing
the behavior of these substances within the river located in the desig-
nated model area.
The outcomes revealed that while the PRTR reported the discharge
of 12 chemical substances, the river actually manifested the presence
of 17 substances. Notably, certain inorganic compounds exhibited
intensive detection near the discharge sites documented in the PRTR.
Intriguingly, some organic compounds and endocrine disrupters, such
as oestrone, were detected even though their discharge had not been
reported in the PRTR for the model area (Yamagata et al. 2006).
The study’s conclusion by Yamagata et al. (2006) emphasized the
utility of PRTR information in identifying hot spots. However, it also
highlighted the imperative for further investigation to comprehensively
understand the discharge paerns of chemical substances, particularly
from smaller entities such as businesses, farmland, and houses.
In a related study by Miho et al. (2015), a comprehensive monitor-
ing initiative was undertaken involving 359 PRTR chemicals (388
including isomers) over three years. This represented the first
large-scale monitoring eort of PRTR chemicals in Japan. Of the
monitored chemicals, 232 were detected, with most exhibiting very
low concentrations and low detection ratios. Interestingly, only ten
industrial chemicals were found to have high detection ratios and
concentrations. Some chemicals were discerned solely at specific
sites or during specific seasons. The study conclusively confirmed
the usefulness and necessity of environmental monitoring for PRTR
chemicals. It suggested that multiple monitoring points would likely
be necessary to thoroughly evaluate the presence of PRTR
chemicals in a given river (Miho et al. 2015).
Crucial Elements of Good PRTR | 113
Ji & Lee (2016) undertook an interesting study in South Korea. In
summary, traditional methods for testing drinking water have limita-
tions, which can lead to delays in responding to water incidents. To
overcome this, global trends suggest using risk analysis systems. This
study used a data system (PRTR) to assess the potential risk of harmful
chemicals in drinking water facilities. By looking at factors like the total
amount of chemicals, distance to a city, and chemical toxicity, they
identified the riskiest city using both a calculated approach and a sta-
tistical method. The study found that PRTR data helps understand and
prevent risks in water supplies. Although the method may not capture
all types of chemical accidents, it provides a useful way to compare
risks between cities, helping prioritize eorts to reduce potential risks
for drinking water facilities (Ji and Lee 2016).
5.11.1 Cyanide Accidents, River Poisoning and PRTR
5.11.1.1 Cyanides
Cyanides are white crystalline substances containing carbon and
nitrogen in the molecule. Various elements, such as sodium, potassium,
and others, may be present as cations. Cyanides may also contain
toxic metals as cations. These can include cadmium, lead, and many
other metals. Sodium cyanide and potassium cyanide are the most
common compounds in this group. Cyanides are soluble in both water
and alcohol. Cyanides are used in metallurgy, the chemical and photo-
graphic industries, and in plastics (nylon) production. They can also be
found in manufacturing rubber, explosives and fuel. Sodium and potas-
sium cyanide are important agents in the electrochemical plating and
hardening of steel. Cyanides can also be used in the mining industry
to extract gold and silver from minerals. Cyanides are produced in
combustion processes and used in several industries (Botz 2001; MŽP
2021a). Cyanides are unstable when they enter water or soil, so bioac-
cumulation in aquatic organisms is unlikely. They can evaporate rapidly
Figure 5.2: Whole river Tisza and part of the Danube were poisoned by
cyanide spill from gold mine in Baia Mare, Romania in January 2000
(Cunningham 2005). Source: (EEA 2009)
114 | Pollutant Release and Transfer Register and Civil Society
from water and soil into the air as hydrogen cyanide, especially at low
pH. They are subject to microbial degradation. Cyanides do not bind to
soil particles and may leach into groundwater.
Cyanides are highly toxic to fish and other aquatic life. All cyanides
are toxic to aerobic organisms, including humans, by interfering with
oxygen fixation by respiratory enzymes (MŽP 2021a). The presence
of cyanide ions in food and their use in the industry are dangerous to
people’s health and safety. Compounds containing cyanide ions are
rapidly acting poison that mainly interferes with the process of cellular
respiration, which results in several ailments and illnesses and even
death (Jaszczak et al. 2017). Cyanides are a frequent source of fish
poisoning in surface waters of long reaches of rivers (Arnika 2020a;
Cunningham 2005; Svobodová and Sehonová 2021).
In January 2000, a retaining wall failed at the Aurul gold processing
plant in Romania, releasing a wave of cyanide and heavy metals that
moved quickly from one river to the next through Romania, Hungary,
the Federal Republic of Yugoslavia and Bulgaria, killing tens of thou-
sands of fish and other forms of wildlife and poisoning drinking-water
supplies (Cunningham 2005).
5.11.1.2 Two Cyanide Accidents and PRTR
The information from the Czech PRTR proved crucial in connection
with two river accidents. In 2006, there was a cyanide leak from the
chemical plant LZ Draslovka Kolín into the largest Czech river, the
Elbe (see map in Figure 5.4). An eighty-kilometer stretch of the river
was contaminated (Svobodová and Sehonová 2021), and despite the
responsible party not admiing fault for several days, the IRZ data
clearly indicated the likely culprit. Similarly, in the basic navigation of
those who could be responsible for the cyanide poisoning on the Bečva
River in September 2020 (Svobodová and Sehonová 2021), the registry
Figure 5.3: Cover page of newspapers showing Baia Mare mine.
Photo 5.18: Tisza cyanide spill from Baia Mare gold mine in Romania
killed fish Photo: hps://www.delmagyar.hu/szeged_hirek/azonnal_
olt_a_cian_a_tiszaban/2415983/ via Wikimedia Commons
Crucial Elements of Good PRTR | 115
could have been useful. However, it did not display all entities handling
cyanides due to the high reporting threshold for cyanide transfers in
waste. In response, Arnika issued a call for “Rivers without Poisons,”
demanding tightening the reporting threshold for cyanide transfers in
waste from 500 to 50 kg/year. This was prompted by an incident on the
Bečva River, where a cyanide leak resulted in massive fish mortality
over a 40 km stretch of the river (Čtk 2023). The call garnered support
from more than 7,000 people (Arnika 2020b). The requirement was also
endorsed by commiees of the Parliament of the Czech Republic
(Čtk 2023).
5.11.2 PRTRs and Fishermen
Fishing communities, recreational anglers, and their families belong
to parts of the human population that are highly vulnerable to water
pollution and aquatic ecosystem degradation. Pollution of rivers
and waters affects them in several ways: 1) leaks of substances
toxic to fish destroy their food source or the object of their interest;
2) accumulation of toxic substances, which do not kill the fish but
accumulate in them, can also accumulate in the bodies of anglers or
people consuming the fish, and 3) accidental spills can be a disaster
for entire communities. Despite this, the use of data in relation to
Figure 5.4: Part of the
Labe (Elbe) River was
aected by a cyanide leak
from LZ Draslovka in Kolin
2006.
CYANIDE IN ELBE
Most aected area
AFFECTED AREA .............LENGTH IN KM
Kolín ................................................................................... 5
Nová Ves .......................................................................... 5
Poděbrady ..................................................................... 13
Nymburk .........................................................................11
Čelákovice ...................................................................... 6
Brandýs nad Labem ............................................... 11.5
Kostelec nad Labem................................................... 6
Neratovice ...................................................................... 6
Obřistvi ............................................................................ 7
Mělnik ............................................................................... 4
Lysá nad Labem ............................................................9
116 | Pollutant Release and Transfer Register and Civil Society
fishing has not been the focus of many scientific studies, except for
exceptions that studied, for example, certain substances in PRTR
systems in connection with the development of ecotoxicity releases
(Erhart and Erhart 2022).15
15 Recent Swedish study observed "The downward trend of human toxicity is more ob-
vious for zinc and arsenic than for mercury or lead. Ecotoxicity impacts have been also
decreasing in total, in particular in early 2000s and less dynamically recently“ (Erhart
and Erhart 2022). This covers also toxicity through the releases to water to certain ex-
tend, and applies to Sweden.
However, fish are evidently the first victims of the leakage of certain
substances into water, as we have shown in subsection 5.11.1.2, which
focuses on river poisoning by cyanides. Their poisoning, however, is
caused by various other substances, and not all of them are monitored,
for example, in the E-PRTR. In the case study from the Czech Republic
(see subsection 4.1.7.1), it is evident that fish poisoning is not only a
result of the direct discharge of toxic substances into the water but
also improper handling of waste containing toxic arsenic or other
metals and their compounds.
Endangered fishing communities also include those in Map Ta Phut or
Douala, where industry takes precedence (Fonge 2011; Hassarungsee
and Kiatiprajuk 2010; Kuepouo and Petrlik 2013; Saetang 2022). These
two places are just examples of many spread globally.
Photos 5.19 – 5.20: The chemical plant LZ Draslovka Kolín (photo
5.18), which produces hydrogen cyanide and related products such as
sodium cyanide, potassium cyanide, diphenylguanidine, and others,
became the source of one of the largest cyanide accidents in the Czech
Republic in January 2006 (photo 5.19). Photos: 5.18 – Michal Gregor via
Wikimedia Commons; 5.19 – Arnika’s archive.
Photo 5.20
Photos 5.21 – 5.22: Cyanide poisoning on the Bečva River in September
2020. Photos: 5.20 – Michal Berg, Green Party Czech Republic; 5.21 -
Stanislav Pernický, Czech Fishermen Association
Photo 5.22
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5.11.2.1 How Can PRTR Help Fishing Communities?
PRTR does not regulate industrial activities but collects valuable
information from them for fishermen. At the same time, PRTR, in combi-
nation with public data accessibility, puts pressure on industrial opera-
tions to beer monitor and reduce their releases of toxic substances. In
the case of accidents, PRTR helps to quickly identify the polluters (see
Chapter 5.11.1).
5.11.2.2 PFASs, Mercury and Other Persistent Pollutants
Contaminate Fish
Research in the USA found that: ‘an individual’s consumption of
freshwater fish is potentially a significant source of exposure to perflu-
orinated compounds. The median level of total targeted PFAS in fish
fillets from rivers and streams across the United States was 9,500 ng/
kg, with a median level of 11,800 ng/kg in the Great Lakes’ (Barbo et al.
2023). However, when we look at PRTR systems, we find that only two
require reporting of some substances from the large group of PFASs.
Photo 5.23: Industrial plants in the bay with mangrove swamps near
Gladstone, Queensland, Australia. Toxic substances aect fishermen
fishing in rivers and those along the coast near industrial facilities.
High concentrations of PFASs were found in the port of Gladstone (GPC
2020). Photo: Jindřich Petrlík, Arnika, 2022
Photo 5.24: Discharge of wastewater from a canal of paper mills in
Khon Kaen, Thailand. Photo: Jindřich Petrlík, Arnika, 2016
Crucial Elements of Good PRTR | 119
Photo 5.25
Photo 5.27 Photo 5.26
Photos 5.25 – 5.27: Sampling in Tha Tum, Thailand in 2012 and 2016.
Sediment sampling in 2016 (photo 5.25), analysis of fish caught in 2012
(photo 5.26) for mercury, as well as hair analysis of the local commu-
nity (photo 5.27) that frequently consumes fish. Photos: 5.25 – Ondřej
Petrlík, Arnika, 2016; 5.26 – 5.27 EARTH, 2012 (Saetang et al. 2013)
120 | Pollutant Release and Transfer Register and Civil Society
Photos 5.28 – 5.30: The chemicals released into the waters oen aect
Thai fishermen. Photos: Ondřej Petrlík, Arnika, 2016
Photo 5.28
Photo 5.30
Photo 5.29
Crucial Elements of Good PRTR | 121
Photos 5.31 – 5.33: Fishing communities near the large city of Douala in
Cameroon are also aected by mercury, as found in a study by CREPD,
IPEN, and Arnika in 2013 (Kuepouo and Petrlik 2013). Photos: CREPD, 2012
Photo 5.31
Photo 5.32
Photo 5.33
122 | Pollutant Release and Transfer Register and Civil Society
For example, E-PRTR does not include this group (OECD 2021). In the
case of BFRs, on the other hand, there is not much reporting in E-PRTR
(EEA 2022), even though these substances are widely present in the
environment and in fish.
Mercury is also among the significant pollutants accumulating in fish.
Monitoring not only emissions into the air and direct discharge into
the water but also the handling of waste containing mercury and soil
contamination is important, as documented by examples of chlorine
chemicals, smelters, or coal-fired power plants and contamination of
fish in their vicinity (Mach et al. 2016).
As the USEPA states: “Nearly all fish and shellfish contain traces
of mercury, no maer what body of water they come from” (USEPA
2023a). However, fish advisories do not only track mercury: “Most
advisories are based on contamination from five toxins that persist
for long periods in sediments at the boom of certain water bodies: 1)
Mercury; 2) Polychlorinated Biphenyls (PCBs); 3) Chlordane; 4) Dioxins;
5) Dichloro-Diphenyl-Trichloroethane (DDT)” (USEPA 2023a). PFASs have
recently been added to this list (Pickard et al. 2022). However, there is
a problem with this group, as there are thousands of substances to
monitor: “Fish consumption advisories are primarily being developed
for perfluorooctane sulfonate (PFOS), but this work reinforces the
need for risk evaluations to consider additional bioaccumulative PFAS,
including perfluoroalkyl sulphonamide precursors” (Pickard et al. 2022).
How PRTR systems will deal with them will hopefully be seen soon.
Chemical analyses of PFASs are a rapidly developing field of analytical
chemistry (Al Amin et al. 2020; Weiss et al. 2015), including bioassay
methods that are usually more cost-ecient and help indicate prob-
lematic locations (Behnisch et al. 2021; de Schepper et al. 2023).
Annexes | 123
ANNEX 1: OECD RECOMMENDATIONS
Background Information
The Recommendation on Implementing Pollutant Release and Transfer
Registers as adopted by the OECD Council on 20 February 1996 on the
joint proposal of the Environment Policy Commiee (EPOC) and the
Joint Meeting of the Chemicals Commiee and the Working Party on
Chemicals, Pesticides and Biotechnology (today under the responsibil-
ity of the Chemicals Commiee). The Recommendation is an important
initiative that helped promote (both within and outside OECD) the
establishment of PRTRs and provide general principles to guide the
design of such systems. Only four PRTR programs were in operation
when the Council Recommendation was adopted. The Recommenda-
tion was abrogated on 10 April 2018. (OECD 2023c)
THE COUNCIL,
HAVING REGARD to Article 5 b) of the Convention on the Organisation
for Economic Co-operation and Development of 14 December 1960;
HAVING REGARD to Principle 10 of the Report of the United Nations
Conference on Environment and Development of 3-14 June 1992
(Agenda 21) to which all OECD Member countries have subscribed, and
which states that “each individual shall have appropriate access to
information concerning the environment that is held by public author-
ities, and the opportunity to participate in decision-making processes
and that countries shall encourage public awareness and participation
by making information widely available”;
HAVING REGARD to Chapter 19 of Agenda 21, which states, among
other things, that governments, with the cooperation of industry,
should improve databases and information systems on toxic chem-
icals, such as emission inventory programs and that the broadest
possible awareness of chemical risks, is a prerequisite for chemical
safety;
NOTING that several Member countries and the European Community
are acting to collect data concerning pollutant releases and transfers
from various sources and to make these data publicly accessible;
NOTING that many individual enterprises and industrial sectors within
the OECD area are voluntarily providing information about pollutant
releases and transfers;
Annexes
124 | Pollutant Release and Transfer Register and Civil Society
NOTING that a number of non-member countries are also exploring
ways to obtain and make available national data about pollutant
releases and transfers;
NOTING that the OECD Secretariat, with the aid of Member gov-
ernments and other aected and interested parties, has prepared a
Guidance for Governments Manual specifically to assist governments
wishing to institute a Pollutant Release and Transfer Register;
RECOGNISING that reducing potentially harmful releases and transfers
of pollutants while promoting economic progress is a foundation for
achieving sustainable development;
On the joint proposal of the Environment Policy Commiee (EPOC) and
the Joint Meeting of the Chemicals Commiee and the Working Party
on Chemicals, Pesticides and Biotechnology;
I. RECOMMENDS:
1. That Member countries take steps to establish, as appropriate,
implement and make publicly available a pollutant release and transfer
register (PRTR) system using as a basis the principles and information
set forth in the OECD Guidance to Governments Manual for PRTRs.
2. Member countries, in establishing PRTR systems, should take into
account the set of principles contained in the Annex to this Recom-
mendation, of which it forms an integral part.
3. Member countries should consider periodically sharing the results
of the implementation of such systems among themselves and with
non-member countries, with particular emphasis on sharing of data
from border areas among relevant neighbouring countries.
II. FURTHER RECOMMENDS:
That member countries in establishing a Pollutant Release and Transfer
Register should take into account the following core elements of a system:
1. A listing of chemicals, groups of chemicals, and, if appropriate, other
relevant categories, all of which are pollutants when released or trans-
ferred;
2. Integrated multi-media reporting of releases and transfers (air, water
and land);
3. Reporting of data by source where the reporting sources are defined;
4. Reporting periodically, preferably annually; and 5. Making data avail-
able to the public.
III. INSTRUCTS:
1. The Environment Policy Commiee is to review actions undertaken
by Member countries and to report to the Council three years from the
date of this Recommendation and periodically aer that concerning
progress.
2. The Environment Policy Commiee to consider how OECD can aid
other international organizations and bodies, upon their request, in
helping non-member countries that may be contemplating the estab-
lishment of PRTR systems.
Annexes | 125
ANNEX
PRINCIPLES CONCERNING ESTABLISHMENT
OF PRTR SYSTEMS
1. PRTR systems should provide data to support the identification and
assessment of possible risks to humans and the environment by identi-
fying sources and amounts of potentially harmful releases and transfers
to all environmental media.
2. The PRTR data should be used to promote the prevention of pol-
lution at source, e.g., by encouraging the implementation of cleaner
technologies. National governments might use PRTR data to evaluate
the progress of environmental policies and to assess to what extent
national environmental goals are or can be achieved.
3. In devising PRTR systems, governments should cooperate with
aected and interested parties to develop a set of goals and objectives
for the system and estimate potential benefits and costs to reporters,
the government, and society as a whole.
4. PRTR systems should include coverage of an appropriate number
of substances that may be potentially harmful to humans and/or the
environment which are released and or transferred.
5. PRTR systems should involve both the public and private sectors
as appropriate and include those facilities that might release and/or
transfer substances of interest, as well as diuse sources, if appropriate.
6. To reduce duplicative reporting, PRTR systems should be integrated
to the degree practicable with existing information sources such as
licenses or operating permits.
7. Both voluntary and mandatory reporting mechanisms for providing
PRTR inputs should be considered with a view as to how best to meet
the goals and objectives of the system.
8. The comprehensiveness of any PRTR in helping to meet environmen-
tal policy goals should be considered, e.g., whether to include releases
from diuse sources should be determined by national conditions and
the need for such data.
9. The results of a PRTR should be made accessible to all aected and
interested parties on a timely and regular basis.
10. Any PRTR system should allow for mid-course evaluation and
have the flexibility to be altered by aected and interested parties in
response to changing needs.
11. The data handling and management capabilities of the system
should allow for the verification of inputs and outputs and be capable
of identifying the geographical distribution of releases and transfers.
12. PRTR systems should allow comparison and cooperation with other
national PRTR systems as far as possible and possible harmonization
with similar international databases.
13. A compliance mechanism to best meet the needs of the goals and
objectives should be agreed upon by aected and interested parties.
14. The entire process of establishing the PRTR system and its imple-
mentation and operation should be transparent and objective. (OECD
2023c)
126 | Pollutant Release and Transfer Register and Civil Society
ANNEX 2: LIST OF SUBSTANCES
INCORPORATED IN THE MONITORING
PROGRAMME IN THE NETHERLANDS
IN 1997
Following list of sbustances/wastes was part of the reporting in the
Netherlands for 1997 (Evers 1997).
1. ANORGANIC COMPOUNDS
1.1. Metals and metalloids (10)
Antimony, Arsenic, Cadmium, Chromium, Copper, Mercury, Lead,
Nickel, Selenium, Zinc.
1.2. Anorganic compounds (13)
Ammonia, Nitrogen oxides, Dinitrogen oxide, Asbestos, Chlorides,
Fluorides, Hydrogen sulfide, Sulphur dioxide, Carbon dioxide, Carbon
monoxide, Cyanides, Fine dust, Coarse dust.
2. ORGANIC COMPOUNDS
2.1. Specified non-halogenated organic compounds (17)
Acrolein, Styrene, Acrylonitrile, Ethene, Ethylbenzene, Formaldehyde,
Benzene, Phenols-total, Toluene, Methane, Methyloxirane, Oxirane,
Xylene, Isopropylbenzene, Dibutylphthalate, Dioctylphthalate,
Phthalates total, Phenols total.
2.2. Specified halogenated organic compounds (24)
1,2-Dichloroethene, 1,2-Dichloroethane, Dichloromethane,
Epichlorohydrin, Hexachlorocyclohexane, Tetrachloroethene,
Tetrachloromethane, 1,1,1-Trichloroethane, Trichloroethene,
Trichloromethane, Vinylchloride, Methylbromide, Hexachlorobutadiene,
Chloroanilines, chlorobenzenes non-specified, Chloronitrobenzenes,
Hexachlorobenzene, Trichlorobenzenes, 2-Chlorotoluene,
4-Chiorotoluene, 1,4-Dichlorobenzene, Dioxines, Pentachlorophenol,
Chlorophenols nonspecified.
2.3. PAH, CFC, HCFC, HFC, and halones (31)
Polycyclic aromatic hydrocarbons (Ministry of VROM selection),
Polycyclic aromatic hydrocarbons (Borne selection), Naphthalene,
Phenanthrene, Anthracene, Fluoranthene, Chrysene, Benzo(a)
anthracene, Benzo(a)pyrene, Benzo(k)fluoranthene, Benzo(g,h,i)
perylene, Chlorofluorocarbons non-specified, CFC 11, CFC 12, CFC 13,
CFC 113, CFC 114, CFC 115, Halones
non-specified, Halon 1211, Halon 1301, Halon 2402, HCFC non-specified,
HCFC 22, HCFC 123, HCFC 124, HCFC 141b, HFC non-specified, HFC 125,
HFC 134a, HFC 143a.
2.4. General mixtures (7)
Volatile organic compounds, Non-methane volatile organic
compounds, Halogenated organic compounds, Non-halogenated
aliphatics, Non-halogenated aromatics, Halogenated aliphatics,
Halogenated aromatics.
3. PESTICIDES, HERBICIDES AND FUNGICIDES (26)
DDT, Drins non-specified, PCB’s~ non-specified, Azinphos-ethyI,
Azinphos-methyl, Dichlorovos, Endosulfan, Fenitrothion, Fenthion,
Malathion, Parathion-ethyl, Parathion-methyl, Atrazine, Bentazon,
Simazine, Trifluralin, Organic tin compounds, DNOC, 2,4-D, Diuron,
Chloridazon, Dimethoate, Mevinphos, Aldicarb, Dithiocarbamates,
Pesticides non-specified.
Annexes | 127
4. OTHER SUBSTANCES (3)
Phosphorus-total. Nitrogen-total, Mineral oil non-specified.
5. Miscellaneous (6)
Radiating substances non-specified, Radon, Smell, Noise, Black smoke,
Water consumption
6. SOLID WASTE (30)
Waste oil, Car tires, End of life vehicles, Dredging sludge, Baeries,
Construction and demolition waste, Animal manure, Ferro domestic
waste, Phosphoric acid gypsum, Glass, Bulky household waste, Waste
containing halogenated substances, Household waste non-specified,
Waste from cables, Jarosite, Oce, shop, and service waste, Plastic
waste, Waste paper and cardboard, Oxy-lime sludge, Shipping waste,
Shredder waste, Slag and fly ash from incinerating household and
communal waste, Waste from painting activities, Blasting grit, Street
waste/ market waste/ waste from parks and waterways, Polluted soil,
Packaging waste, Fly ash from coal fired power plants, Hospital waste,
Sewage sludge.
128 | Pollutant Release and Transfer Register and Civil Society
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is report was prepared and published as part of the
“Transparent Pollution Control In Indonesia” project
funded by the European Union (EU) and co-funded by the
Ministry of Foreign Aairs of the Czech Republic within
the Transition Promotion Program and the Sigrid Rausing
Trust, and Swedish International Development Agency
via IPEN. Its content is the sole responsibility of Arnika
and Nexus3 Foundation and does not necessarily reflect
the views of the donors.
