Phosphorus Guidance


The purpose of this paper is to provide guidance for reporting of phosphorus
(total) for manufacturing.

Background Information:

Phosphorus is essential to life and only very high concentrations can cause direct toxic effects. The main environmental concern with phosphorus is its role as a nutrient (fertilizer) in the aquatic environment where phosphorus can lead to changes in natural flora and fauna and in eutrophication in lakes, rivers and costal waters (eutrophication increased aquatic plant growth which, in turn, leads to undesirable changes in fish diversity, loss of recreational potential, and degraded source water for drinking and industrial uses). Because phosphorus can be transported from one medium to another (releases to air can deposit on land or water, releases to land can leach into water) and phosphorus can transform from one form to another, there is a need for reporting of all forms of phosphorus to all environmental media even though the effects of concern are caused by biologically available phosphorus in water.

The listing for phosphoric acid was removed from the National Pollutant Release Inventory (NPRI) in 2001, because this listing was not capturing relevant releases of phosphorus. One problem with the listing of phosphoric acid is that acids that are neutralised prior to their release are reported as a zero release even though the phosphorus was still being released. The other is that there are other forms of phosphorus that could become biologically available as a nutrient. As a result, in 2003 phosphorus (total) was added to the NPRI.

Phosphorus is contained in many industrial chemicals and products, and tracking and reporting of a large number of phosphorus-containing substances for the NPRI can require significant resources. To minimize the unnecessary reporting burden for industry and yet to allow for the collection of uniform, systematic and valuable data reporting, the following guidance is provided.


The following is a list of items that contain phosphorus where reporting to the NPRI is not required.

  • Phosphorus in metal such as sheets, structural steel rod and bar products is exempt. This is also the case when metal products welded or undergo mechanical transformation. This exemption does not include metal production, recycling or casting where metal are melted and recast;
  • Phosphorus in sealants and adhesives;
  • Phosphorus in greases, oils and lubricants;
  • Phosphorus in plastics, and
  • Phosphorus in paints.
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