As a member of the Regional…

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Commenting on behalf of

City of Hamilton - Environmental Services Division

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As a member of the Regional Public Works Commissioners of Ontario (RPWCO), the City of Hamilton is providing comments on the proposed Regulation concerning the Hazardous Waste Digital Reporting Service Modernization (ERO 019-2332).

The following comments represent information in the proposed Regulation that the City of Hamilton would like the MECP to consider as part of the development of the final Regulation:

1. The digital hazardous waste reporting service should be designed to be user-friendly and include greater capability to search and use the data compared to the existing Hazardous Waste Information Network (HWIN) system, i.e. completed electronic manifests can be easily extracted from the system and repurposed for other reporting requirements such as MECP reporting.

2. The digital reporting system could place pressure on Hazardous Waste service operators to revise their operating systems to access the new system, i.e. requiring field staff to carry tablet computers to access and input data into the new system.

3. The transition to the proposed digital hazardous waste reporting service should include sufficient time to allow individuals to be trained and become accustomed to the new system.

The following comments are in support of the proposed Regulation:

1. The proposed change to the Resource Productivity and Recovery Authority (RPRA)’s mandate to provide the digital reporting services through its registry will benefit the regulated community and create a more efficient and effective framework for digital reporting, fee setting and cost recovery for the Hazardous Waste program.

2. The transition from paper manifests to a new digital reporting service is a beneficial change which should improve efficiency and increase the accuracy of transmitted information.