See detailed comments in…

ERO number

019-2332

Comment ID

49348

Commenting on behalf of

ArcelorMittal Dofasco

Comment status

Comment approved More about comment statuses

Comment

See detailed comments in attached document. Key points include:

In the new system, there should be an Administrator login (with full rights) for each generator site account to do things such as:
• Adding new subjects wastes for off-site disposal
• Updating facility, contact and payment information as required
• Adding new on-site management reports.

There should also be User logins (with rights to generate manifests only) for those who generate and/or sign manifests. Waste information would already have to be in the system by the Administrator in order to generate a manifest for that waste.
• The system needs to allow the Carrier (as a delegate, with a User login) to generate a manifest on behalf of the Generator and pre-fill / complete the generator section.
• An employee can then log in as a User to complete / sign the manifest.

Administrative issues with the electronic document should not hold up on-site work to manage waste (i.e. transportation off-site for disposal). If the system is set up properly, the Generator, Carrier and Receiver information should populate automatically. The system should be flexible enough to accept a manifest with differences between the amount generated and the amount received (if one is estimated and one is measured).

Fees should not have to be paid in real time (e.g. as the waste leaves the Generator site for disposal). The regulated community needs to see clear calculation of fees (including tonnage fee exemptions for recycling). The system should issue detailed invoices after the fact (e.g. monthly) so the Generator pays based on the service provided which should be detailed in the invoice. The system also needs the ability pay fees with electronic transfer (in addition to Interac and credit card).