General Comment While paper…

General Comment
While paper manifests are inefficient and modernization is encouraged, not all frontline workers will feel comfortable using the new digital reporting service unless adequate guidance and training are provided.

Delegating Authority
Some carriers assist generators with the completion of Part A of the paper manifest; how would this work with the new digital reporting service?

Fee Structure
How much will the new digital reporting service cost to develop, implement and maintain? Will there be an increase in costs to generators?

Improving Data Quality
The new digital reporting service should be designed to highlight differences in the quantity shipped by the generator and the quantity received by the receiver. This would help generators reconcile discrepancies for follow-up with the receiver.

Electronic Manifests
If electronic manifests do not need to be printed and travel with the subject waste, will TDG rules be amended to reflect this? Currently there is an expectation that the manifest will accompany the shipment. Will another document be required? Could the new digital reporting service be in place before the government changes the requirements for the manifest to accompany the shipment?

Electronic manifests should be available to generators for a period of at least two years.

Transition Planning
What supports will be put in place to help businesses transition and to assist front-line workers who will have to use the new system? Will computer-based training be provided? Will a customer support helpline be provided?