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? - email preferred
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? - electronic preferred
3. Currently spills and emergency reporting is managed through the Spills Action Centre. How should we manage registration for emergency situations going forward? - continue to manage through Spills Action Centre

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? - 2 to 3 working days
2. How long do generators need access to their online registration/reporting data? - 1 year
a. When can we archive it from the reporting service? - 1 year
b. Will the reporting service suffice as the record or will the generator also need to store this? - reporting service should suffice as record
c. How long should we maintain records of active manifests in the reporting service? - 1 year
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? - excel
b. downloaded as a flat file (i.e. as a datafile that stores data in a plain text format)? - excel allows for calculations on data
4. How will we handle reporting during emergency situations? if this is a spill emergency, then this question is not applicable to us, - if this means no access to internet then a backup system, such as paper forms would have to be maintained
a. Use offline capability? - no
b. Paper availability? - preferred
5. How can we improve awareness and compliance with short-term storage and onsite waste management requirements? - n/a
6. What is the best way to notify of reporting non-compliance to prevent future non-compliance and ensure timely action is taken? - talk to a representative to be able to get accurate information transferred and get direction for future

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? - yes, allow as many options as possible to make it simple
b. Are there other ways we can improve reporting estimates? - provide conversion tools in the reporting system
8. What other system features would you like to see in the new reporting service? - keep it straightforward and user friendly, include a comment or notes field to describe unique situations

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? - summer 2021 is reasonable, as proposed
2. Are there any transition issues we should be aware of? - no
3. How much will it cost your business (i.e. labour, capital, IT, etc.) to switch reporting to a digital reporting service? - we expect to have our costs impacted by the waste hauling companies as they cover their cost to implement a new system
4. What supports do you need to ensure a seamless transition to a digital reporting service? - we are assuming that we will be inputting information to our carrier's system or RPRA/ministry system, just need training and access
5. What best practices do you have in place that you think would benefit other businesses transitioning to digital reporting services? - create a test system and validate it in parallel with the legacy system

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? - validation tool, if we have not completed submission correctly, then flag warning comes up before submitting to RPRA/ministry
2. What performance measures would you like to see the ministry track? - n/a

Continuous Improvement - Discussion Questions
1. What continuous improvement initiatives do you think should be considered in the next phase of the project in 2022? - tracking use of harmful chemicals
2. In the future, how can we move beyond the safe management of hazardous waste to the reduction of hazardous waste? - recycling, and reducing use of harmful chemicals

General Discussion Questions
1. How will the Hazardous Waste digital reporting service modernization project impact you (or your business)? - takes time to initiate but expect streamlined processes to follow, expect cost will increase
2. How would you like to be consulted on the future regulatory changes? - like this
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? - Current payment format is awkward and restrictive