In the context of environmental obligations applicable to companies that generate wastewater discharges, it is important to highlight the relevance of complying with Mexican Official Standard NOM-002-SEMARNAT-1996 (the “Standard”), which regulates the maximum permissible limits of pollutants in discharges to urban or municipal sewer systems.
This Standard is mandatory for all parties responsible for wastewater discharges, including industrial, commercial, and service activities, and aims to prevent and control water pollution, as well as to protect sewer system infrastructure.
As part of this regulatory framework, companies are required to prepare and, where applicable, submit periodic reports reflecting the quality of their discharges, which must be supported by technical analyses carried out in accordance with the parameters and methodologies established in the Standard. In particular, discharges must comply with maximum permissible limits for various pollutants, including fats and oils, settleable solids, and heavy metals such as arsenic, cadmium, lead, and mercury, among others. Additionally, specific physicochemical conditions must be met, among other requirements.
Compliance with these parameters must be determined through laboratory analyses based on composite samples representative of the discharge-generating process, considering daily and monthly averages in accordance with the methodology set forth in the Standard. Furthermore, the Standard requires responsible parties to conduct periodic technical analyses, retain the corresponding records for a minimum period of three years, and notify the competent authority of any modifications to their processes that may affect the quality or volume of the discharges.
In this regard, the proper preparation of wastewater discharge reports not only constitutes a formal obligation but also serves as a key element to demonstrate regulatory compliance before environmental authorities and to avoid the imposition of more restrictive discharge conditions or administrative sanctions. Accordingly, we recommend that companies periodically review their sampling processes, verify that all applicable parameters under NOM-002-SEMARNAT-1996 are included in their analyses, and ensure that the information contained in their reports is consistent, complete, and duly supported by laboratory results.
Should you require advisory support in connection with regulatory compliance, or if you have any questions or require additional information, please contact the professionals at Cuesta Campos.
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Berenice Soto
Héctor Ceballos
Sofía Cano
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