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Toronto Water Comments for ERO 019-2332 – Hazardous Waste Digital Reporting Service Modernization

ERO Number: 019-2332
Title: Hazardous Waste Digital Reporting Service Modernization

Toronto Water has reviewed the proposed regulatory changes that would modernize and transition the delivery of hazardous waste digital reporting services to the Resource Productivity & Recovery Authority. We agree that these changes would make reporting simpler, faster and more cost-effective.

In response to the proposed regulatory changes listed in the Proposal, Toronto Water has the following comments in italics:

1. Amend Regulation 347 under the EPA to transition the delivery of hazardous waste digital reporting services to the Authority

A. Transition delivery and operation of the hazardous waste digital reporting service
o Agree.

B. Change registration and reporting requirements to support electronic service delivery

a) Annual registration

• MECP is proposing to remove the annual registration renewal requirement (currently between January 1st to February 15th) and to ensure ongoing accuracy with facility, contact and payment information, the Authority would require that businesses review and update their initially reported information when they are ready to report their first waste management activity after 365 days from the last time they reviewed and confirmed this information.
o We support this change as it reduces administration work.
o If you can provide a demonstration of the new reporting service, it would be useful to understand how this requirement will be fulfilled.

b) Reporting requirements
• Businesses that generate subject waste would be required to report their activities on, or prior to, the date that the activity takes place or within 90 days of generating or temporarily storing the subject waste if no other waste management activity has taken place. No generator of subject waste would be permitted to store subject waste for a period of greater than 90 days without reporting an activity to the Authority. No generator would be permitted to manage such waste without reporting the activity to the Authority.
o We understand that the reporting requirements remain the same after Regulation 347 amendment and would like to request a demonstration on digital reporting service which includes all reporting requirements.

• In the near term, the ministry’s approach is to ensure that the proposed amendments would support the continued use of paper manifesting as an alternative to electronic reporting through the Authority’s Registry, in a manner similar to that currently provided for under Regulation 347. Such reporting would continue to be provided directly to the ministry (director).
o We agree as it provides flexibilities during transition period.

c) Report Completion
We are proposing to amend Regulation 347 to clarify that reporting information would not be accepted in the new hazardous waste digital reporting service unless:
• The entire waste management activity report is completed in a manner consistent with the requirements of the Regulation.
• Any applicable fee payable by the generator is paid by or on behalf of the business.
o We support this amendment which ensure generators provide accurate information on a timely basis to comply with the reporting completion requirement.

d) Delegating Authority
MECP is proposing that the new hazardous waste digital reporting service would allow delegates to register, report, and pay fees on behalf of generators. The generator would remain responsible for the subject waste that they generate and the information that is reported on their behalf. The Authority would be responsible for ensuring confidential business information remains protected. We are proposing to amend Regulation 347 to include a definition for ‘Delegate’ that would clarify this role.
o We support this amendment which provides flexibilities to the generators to register, report, and pay fees.
o We would like to request guidance on qualifications of delegates.
e) Paper-based reporting
The rules for paper-based reporting would remain the same in Regulation 347 because there is still a possibility that paper documents could be used in certain circumstances.
o We support this amendment which provides flexibilities to the generators under certain circumstances that paper documents could be used.
o We would like MECP to provide clarification on certain circumstances where paper documents could be used. For example, is it to be approved on case by case basis even after transition period?

C. General housekeeping amendments to provide more clarity
Aligning with Federal regulatory phrases under the Transportation of Dangerous Goods Act (TDGA) would make it easier for businesses to learn and comply with both federal and provincial rules.
• Align with the Federal phrasing in the TDGA by replacing “packaged” to “means of containment”.
• The word “issued” should be removed when referencing TDGA manifests – because TDGA no longer “issues” manifests.

o We support the alignment with Federal regulatory phrases.
o In some situations when hazardous waste is dangerous goods, the paper manifest of the hazardous waste is used as the TDG shipping document and we would like to see this practice be continued in digital reporting service.

2. Create a new regulation under the RRCEA to carry over fee exemptions for certain activities related to hazardous waste - the Authority would be required to consider the exemptions when setting program cost recovery fees.

o No comments.