This proposal brings about many improvements that will support businesses in better managing wastes moving forward. I wonder if it has been thought through for situations where, for example, heating and cooling system recharges result in wastes requiring registration are created, but is a one-time, every 3 year activity for the location? Have there been provisions or processes set up for a Generator who requires registration in this calendar year, and then not again until 2023?
As well, for smaller businesses that are changing processes, that do not actually generate any waste for 6 months, and then complete a review of products that become wastes due to their expiration dates and would then require registration for removal. Have these situations been factored into regulatory and usage updates for the new proposed system?
Will this new system be versatile enough that options for inactivity, or site closure, for the next 3 years, can then be removed using the same username and password to reactivate the registration for the new waste movement?
With the update to the regulation, could there be more clarity on when a waste is actually generated, versus the down time between generation of waste - for example, a manufacturing business running a certain line for 3 months each year, but not running it again until the next year. For 3 months they may create and collect waste, in a range (for example) of 600 Litres per month. For the remaining 9 months of the year, they aren't manufacturing, creating, collecting, storing or handling subject waste. How would this situation be managed through the new system and regulation? Current definitions for small quantity generators indicate 100 kg or litres in any one month or otherwise accumulated. This manufacturer would not fall into this exemption from the information above.
Would the system be versatile enough to maneuver updates to reporting requirements for TDG? In that, if the information order is changed again, would it be easier to adjust boxes on an electronic manifest without requiring work-arounds or additional documentation?
Have there been considerations made for small businesses, or homeowners that are saddled with enormous quantities of subject waste for removal, and who do not regularly or repeatedly have these wastes for removal?
Would there be a place to upload data analysis to support the waste classifications from a Generator? Or a information page, proof of classification pages, SDS sheets etc. used in the establishment and determination of a waste stream? If so, are Generators opening themselves up for further scrutiny and liability by supplying this supporting documentation to the Authority? Or, are Generators being reviewed on this material, to support any updated suggestions for waste classification if Ministry officials or Authority officials feel there are mis-classifications?
Having all of this information in the same place, and available for electronic filing and reporting will ease many aspects of this process now.
Will updates to the EPA include any of the new regulation information or proposed amendments to Regulation 347 - especially the definition, rights, responsibilities, liabilities and ownership of the Delegate?
So far this process appears to be moving an antiquated system forward through many needed modernizations. It would be appreciated for the stakeholders to receive further information dialing up the details of the smaller points of the program proposal before transitions begin.
Submitted October 1, 2020 11:39 AM