Operator guidance

Industrial sites listed in the Scottish Pollutant Release Inventory (SPRI) are required to report the total amounts of a substance that they emit to air or water during the period of a year. This amount is known as the 'annual mass emission'.

Who has to report?

Companies or organisations are served a legal notice known as a Regulation 63(2) Notice under the Pollution Prevention and Control (Scotland) (PPC) Regulations during the year that they are required to report.

If you have received such a notice, it is a legal requirement for you to complete a SPRI return. If you were required to report in a previous year, it is likely that you will have to continue reporting annually. Even if you are not operating during the reporting year, if the process meets reporting criteria for the SPRI and you have received a formal PPC Regulation 63(2) notice, you are required to submit a return.

If you have not operated and have no emissions, then you should state this in your return. If your authorisation or permit has been revoked, then please state this within your return and, after checking, your company will be removed from the SPRI.

If your industrial operation has closed down during the reporting year, you are still required to report emissions from the site for the part of the year that the site operated, by 28 February of the following year. Our SPRI general operator guidance provides more help and advice on who has to report. There are also sector guidance notes available to give process specific advice:

The SPRI is constantly developing: in Scotland and across the UK, the reporting criteria is reviewed every three years. In addition, changes effected by the European Union (EU) to the Pollutant Release and Transfer Register (PRTR) may affect UK reporting criteria. See our indicative substance lists for emissions to air and water for more information.

How do I report?

Operators are required to submit their annual mass emission data by 28 February of the following year. So, for the current reporting calendar year, you must report by the deadline of 28 February.

If you miss the reporting deadline, you must contact us as soon as possible for more information on what to do next. We will pursue the missing information in accordance with our enforcement policy.

Operators can complete the SPRI electronic reporting form online by entering a user name and activation code, which operators will be provided with in advance of the start of the reporting period. Electronic reporting is easy to use and you can complete your form in stages before finally submitting it. Our SPRI operator reporting system guidance provides detailed help and advice on how to complete it.

If you don’t receive or have forgotten your user name or password, please contact us to receive a reminder. This can be done very quickly and need not delay you making your return.

(Some operators of RSA sites cannot submit online returns, however we inform operators of such instances in advance).

Alternatively, you can request a paper form from us. After completing the form, please keep a copy for your records and return the original by post to the address on the form.

Please note that it is your responsibility as an operator to provide us with accurate information and, by signing your declaration, you agree to accept this responsibility.

If you are experiencing any problems in completing or submitting your return, please contact us at the earliest point possible in the reporting period. We can then help and support you to successfully submit your return.

What do I have to report?

The SPRI has a threshold value for each pollutant – substances considered to be environmentally significant and of interest to the public.

These thresholds are set at a UK level (reflecting EU levels) and are designed to capture 95% of the UK’s total emitted pollutants for the particular substance.

Annual mass emissions alone are not necessarily directly related to concentrations being emitted at any particular time and cannot be used to directly predict the resulting concentrations in the environment. Thresholds above which mass emissions of each substance must be reported are prescribed using knowledge of the pollutant (its toxicity, transport and persistence in the environment) to indicate what mass emission may give rise to 'significant' environmental concentrations.

Sites reporting to the SPRI all have total annual mass emissions above the reporting threshold for a particular substance, but this does not imply that these sites are in breach of their licenced emission concentration limits at any time during that year. High annual mass emissions are often due to the large size of the industrial process, where relatively low concentrations are released in very large flows of air or water .

When completing your return, you need to identify which of the SPRI pollutants you emit, all emissions sources and then which of these leave the site boundary and report the actual value of all substances identified on the SPRI schedule (a list of substances, thresholds and media receiving the pollutant). Consented substances must be reported – however, substances such as waste (which are not normally consented) may breach the threshold(s) and, as such, must also be reported.

For each pollutant, emissions released should be summed and then reported against the appropriate media that it is released to. If your emissions are above the thresholds defined within the reporting criteria, you need to report the actual value.

It is very important that the emissions for separate receiving media (air, water and waste) are not added together. Thresholds for emissions to air are often different from emissions to water due to the different criteria considered during the determination of the thresholds.

Even if emissions values fall below the reporting threshold, it is important to us to know where the emissions of pollutants occur in Scotland. We also use this sort of information during auditing, so it is important to include this and shows you have considered all potential pollutant sources from your installation. If the value of your emissions is below the threshold as defined in the reporting criteria, you should report Below the Reporting Threshold (BRT) and no value is required. You must, however, still report a method description you used to decide your emission level – our guidance on methods and methodologies has more information on this.

Accidental emissions, such as those caused by unplanned releases, should also be recorded and entered onto your SPRI annual return – there are separate parts to the form which allow you to add these unplanned events. Accidental releases should be added into the total emission figure for that substance before it is compared to the threshold value.

What happens next?

On receiving your return, we check the information for obvious errors and omissions from the data provided.

A return will be refused and returned to the operator if any mandatory information, including address, SIC and PRTR codes, is missing or ambiguous.

Once you have submitted a return, it is locked. If you need to make any changes to your return after you have submitted it to us, please contact us as soon as possible to enable any editing. We are required to record any changes and the reason for the change, so please ensure that you can provide this information. Please note that you may be asked to justify your emission values during any routine site audits, so please keep any paperwork, measurements or calculations for up to five years.

Once collated, the data returned through SPRI is used as a free and easily accessible information source for the public to review the emissions in their local or national area.

It is also used in research and to fulfil European Union reporting requirements, such as the E-PRTR and the Industrial Emissions Directive.