Registration & Payment -…

Registration & Payment - Discussion Questions In addition to comments or recommendations on the sections outlined above:
1. How can we ensure generators are aware of their regulatory obligations (i.e. registration and reporting on storage, processing and movement of subject waste) even when they have chosen to delegate registration and reporting requirements to another individual or organization?
Have generators who decide to have their registration and reporting processes handled by their waste contractor or consultant obtain an annual summary of shipments, registrations and changes from their delegate. This annual summary would be required to be kept on file for same length of time as the waste manifests (two years) or for supporting documents (3 years).

2. Generators must maintain records of all data, analysis, and other information used to register subject waste.
a) Now that businesses are moving digital, should we allow supporting records (e.g. data, analysis and other supporting information used in the preparation of the Generator Registration Report) to be kept electronically? Are paper copies needed?
Paper copies of waste manifest have always been held in the event of a site audit but the safety of those copies have always been a concern. We looked for direction from the MOECC and receive none so for due diligence we have scanned copies of all manifests. We go through approximately 900 manifests a year so it is a lot to safe guard. If waste manifests move to electronic form they are not necessary for audit since the MOECC would have access to them similar to generators. However the waste manifest as a shipping document needs to accompany the shipment to the Receiver for weight station inspections, confirmation of load (TDGA requirement) and /or spill incident identification. As long as the waste manifest is a shipping document it will need to be printed for the Carrier to take with the load. Hopefully with these changes the form of the Waste manifest will again meet the requirements of TDGA.

3. Currently spills and emergency reporting is managed through the Spills Action Centre. How should we manage registration for emergency situations going forward?
If waste registration is made simple and straight forward why wouldn’t the Spills Action Line provide the file number to the reporter who can enter it in the registration process to identify it as an Emergency Registration and exempt from normal charges.

Tracking & Reporting - Discussion Questions In addition to comments or recommendations on the sections outlined above:
1. What is an appropriate amount of time to allow businesses to work offline before being required to sync their data, eliminating gaps in time between shipment and time reported?
Currently Regulation 347 allows 3 days before the generator needs to submit waste manifest copies, why not a similar length of time to work offline?!
2. How long do generators need access to their online registration/reporting data?
a. When can we archive it from the reporting service?
I would assume after the generator marks the site as being closed; they may still need access to the site history.
b. Will the reporting service suffice as the record or will the generator also need to store this?
Why is the MOECC looking to cut down ‘unnecessary manual data entry’ but expect the generator to take on more?
c. How long should we maintain records of active manifests in the reporting service?
Unless you are going to make changes in Reg 347 and with Transport Canada currently they need access to those shipping documents for a least 2 years.
3. How would you like to access electronic manifests in the reporting service if there is no longer a paper copy to file?
a. pdf or excel option?
b. downloaded as a flat file (i.e. as a datafile that stores data in a plain text format)?
Pdf and excel would be the most universal method but given they are looking at being able to correct manifesting error online they would need to be stored in way that corrections can be done until all parties included (Generator, Carrier & Receiver) have added their parts and agree the manifest is correct and complete. One of our big issues with the current electronic manifest is it has to be initiated by the Carrier (similar to the paper waste manifest process) which is fine if the shipment is a known regular waste stream. In our situation we sometimes need extra waste manifests or additions to the expected items being shipped while the contractor is on-site; not to mention having the abilities to print off the manifest for the Carrier to take with them while working in a remote area. Lastly regarding updating the waste manifest reporting can you look at increasing the number of lines available for waste streams on the manifest? Currently it is only four and we have many occurrences when the shipment requires more than four.

4. How will we handle reporting during emergency situations?
a. Use offline capability?
b. Paper availability?
Emergency should still go through Spills Action Line but your new registration/ waste manifest need to be 100% smart phone capable online or off!
5. How can we improve awareness and compliance with short-term storage and onsite waste management requirements?
It will be a lot better if the 90 days storage notice was available to be completed on-line with the waste code information (a check box to confirm whether or not the waste stream will be kept on site longer than 90 days).
6. What is the best way to notify of reporting non-compliance to prevent future non-compliance and ensure timely action is taken?
The question is how many non-compliance do you expect to find if the generator is filling in the NECESSARY data (instead of the MOECC) and can only enter information (ie waste code, generator numbers, addresses etc) associated with the waste generator site they are logged into to. On that note PLEASE make it easier for someone managing several waste generation sites for the same organization/ company to log into ONE account (a parent site) and have management and control over all sites associated with the that company. I have an excel spread sheet only to manage my login username for approximately 45 sites, when I should have one login to manage them all.
7. How can we improve reporting of estimates and actual shipped quantities of subject waste?
a. Should the ministry allow different forms of shipped quantity to be reported? For example, allow reporting of:
• number of 205L drums?
• number of Liters extracted by a vacuum truck?
• number of boxes with dimensions included?
We have two hazardous waste contractors and both estimate volumes at time of pickup; only one has the volumes different in Part C of the current waste manifest as they weigh the material upon receiving. I am unsure if this weight is just waste and doesn’t include the shipping container. Given most waste (90%) is billed to the customer by the container the actual volumes are not as important to the customer. We can’t carry around a scale for every pickup so the only way to improve this reporting is regulate Receivers to enter actuals upon receiving shipments which is entered in part C of the waste manifest and those numbers are carried through the system as actuals.
b. Are there other ways we can improve reporting estimates?
No, estimates are just that an estimate based on the professional opinion of the individuals involved or on the direction they receive in their training. Even renovation work is an estimate and they are expected to vary plus or minus by 20%.
8. What other system features would you like to see in the new reporting service?
One of the biggest issues we have now is the waste generator information is publicly available which means a contractor can get the info, generate a waste manifest and ask the contact on site to sign it off EVEN if that person isn’t listed as the responsible individual for the generator! There have been lots of instances where I have had to search for waste manifest copies for this type of situation and it is hard to let everyone in a large organization know what a waste manifest is and that they need to call us to check, sign and collect the copies. Electronic waste manifest will help with it IF they are easy to access and setup while at a remote site; but it could have been solved for paper waste manifest by requiring the Carrier to have a generator site listed person sign off the manifest for it to be correct and accurate.

Transition Planning - Discussion Questions In addition to comments or recommendations on the sections outlined above:
1. What is a reasonable amount of time to transition to electronic registration/reporting?
Registration can be over night with instructional training video given all information is transitioned completely, but waste manifests are a different story.
2. Are there any transition issues we should be aware of?
Waste manifest are used everyday and several times a day. On a day the contractor is onsite (at least 3 times a week per contractor) we can generate 3 to 5 waste manifests. This switch to electronic will take training, practice and coordination since three different parties are involved (generator, Carrier and Receiver). Given current waste manifest cost $5 each (electronic or paper) an incentive to help the transition would be that electronic waste manifests are exempt from the cost to help company cope with the other issues that arise from trying to implement the new electronic waste manifest.

3. How much will it cost your business (i.e. labour, capital, IT, etc.) to switch reporting to a digital reporting service?
Of the things that will be affected by this change will be updated cellular phones for all staff involved (possible tablets), increased data usage, additional printers either in office or remote and additional IT expenses for increased memory storage.
4. What supports do you need to ensure a seamless transition to a digital reporting service?
Webinars, MOECC staff that is approachable and fluent in the new software and most of all accessible immediately; not replies within 48 hours.
5. What best practices do you have in place that you think would benefit other businesses transitioning to digital reporting services?
No idea, we only use paper waste manifests.

Performance Measures - Discussion Questions In addition to comments or recommendations on the sections outlined above:
1. What performance measures should be in place to ensure the digital reporting service is working for you?
My performance indicator will be based on serviced vs scheduled hazardous waste pickups. We cannot miss pickups because a waste manifest is not ready or available. Cannot have to reschedule because a waste code isn’t set up in the system yet or the info needed to fill in the electronic waste manifest is unavailable or missing.

2. What performance measures would you like to see the ministry track?
It would be very helpful for planning and budget (especially with the current surcharge on all our waste) if MOECC could track in the new system, for each waste generator site, the actual waste volumes per waste code over user defined periods of time.

Continuous Improvement - Discussion Questions
1. What continuous improvement initiatives do you think should be considered in the next phase of the project in 2022?
More checks and balances should be looked at, like making sure the waste class being used by the generator is an approved waste class on both the Carriers and Receivers Environmental Compliance Approval.
Access to review or edit Emergency Spill notification files would be helpful and save staff at the Action Centre time.
2. In the future, how can we move beyond the safe management of hazardous waste to the reduction of hazardous waste?
Reduce the cost and hurdles for new pilot projects to start up.

General Discussion Questions
1. How will the Hazardous Waste digital reporting service modernization project impact you (or your business)?
It will either help reduce some of the issues over missing manifests and error on manifest, or create service issues and delay for our hazardous waste pickups.

2. How would you like to be consulted on the future regulatory changes?
Either through email or notifications in HWIN or replacement system is fine. You can’t complain about something you choose to ignore or not provide feedback.

3. What additional steps can we take to improve digital tracking of hazardous waste by generators from the point at which it is generated to the point at which it is disposed/treated?
In this day and age of instant communication, providing notification options for things like shipment received/ shipped and manifest generated/ completed/ final approval for the generator, carrier and receiver involved with be proactive.