Ian Drew…

Ian Drew
Senior Policy Advisor
Ministry of the Environment and Climate Change
Climate Change and Environmental Policy Division
Resource Recovery and Policy Branch
40 St. Clair Avenue West
Floor 8
Toronto, Ontario
M4V 1M2
Dear Mr. Drew:
Re:Ontario Food Collaborative Response – EBR Number 013-1814 - Proposed Food and Organic Waste Framework
As a member of the Regional Public Works Commissioners of Ontario (RPWCO), the City of Hamilton (City) is supportive of the proposed Food and Organic Waste Framework (Framework) issued by the Ministry of the Environment and Climate Change (Ministry). The following are the City of Hamilton’s comments regarding the Framework:
1. The City’s Solid Waste Management Master Plan (SWMMP), approved by Council in June 2012, supports actions which encourages waste reduction, optimizes the use of waste diversion facilities, and minimizes residual waste. The City’s Food Strategy provides direction to guide decision making about food related issues for the City and community, including actions to deal with food production, food processing and distribution, access to healthy food for all residents, increasing food literacy, promoting healthy eating, and food waste management.
2.The City is supportive of the Ministry’s implementation of the Framework in order to guide all sectors within the Province to reduce food and organic waste generated within Ontario. The strategies that reduce food and organic waste must consider environmental responsibility, economic requirements and social accountability.
Municipalities are a major stakeholder regarding to food management and waste management services in Ontario, therefore it is imperative that municipalities should continue to be involved with discussions, assessments, program design, implementation, and outcomes of the actions related to food and organic waste diversion and supporting resource recovery infrastructure.
It is recommended that the Ontario Government avoid any additional new costs to be paid by municipalities resulting from the Framework.
3.The City supports the Ministry’s proposed actions to work with partners to develop promotion and education tools to support food waste prevention and reduction as proposed in Action 1. To achieve this goal, it’s recommended that the Ministry works with municipalities, public health departments, non-governmental organizations, the food industry, and other stakeholders to develop educational materials to promote healthy eating and food waste reduction. The Ministry should collaborate with public health representatives to ensure that educational materials also include messaging related to healthy eating. Key stakeholders have reported that there is a connection between healthy eating attitudes and post-consumer food waste reduction.
4.Action 2 in the Framework indicates that the Province plans to enhance and incorporate waste reduction and resource recovery activities within schools. In order to implement this action, the Ministry should work closely with school boards and independent/private schools to ensure they have the resources necessary to establish successful resource recovery programs within schools. This may require development of guidance tools, preparing school curriculum materials, and possible amendments to operating contracts for school boards.
5.As part of Action 3 in the Framework, the Ministry’s plan to work with the Government of Canada on preventing food waste is a major step towards achieving the targets outlined in the Framework. In particular, there should be a greater focus on food safety, food packaging, and “best before” date labels on food packaging.
6.Action 6 in the Framework indicates that the Province shall support academic research at reducing and recovering food and organic waste. As part of the action, the Ministry should connect with municipalities and stakeholder organizations involved with food waste activities to identify opportunities to make improvements towards reducing and recovering food and organic waste.
7.The City supports the Ministry’s goal to increase resource recovery of food and organic waste in multi-unit residential buildings as noted in Action 10. Resource recovery in multi-unit residential buildings is very challenging due to several factors including buildings not being designed to encourage waste diversion programs, tenant transiency, and lack of ownership for maintaining the waste diversion programs in these buildings. The Ministry should work closely with municipalities that have direct experience with providing organic waste diversion programs for multi-unit residential buildings to determine best practices that support successful programs.
8.The City supports the Ministry’s plan to develop best management practices for the effective use of public waste receptacles as stated in Action 11. The Ministry should work closely with municipalities that operate public space recycling programs to understand the challenges associated with resource recovery from public spaces. Although the Ministry indicates possible solutions such as labels and receptacle placement as ways to improve the quantity and quality of materials captured, there are other factors which impede the success of public space recycling programs.
9.As part of Action 15 to promote beneficial uses, the Ontario Government should ensure there are sustainable end-markets so that food and organic waste can be recovered and re-integrated into the economy. The Ministry should consider developing policies which allow less stringent standards for organic waste resource recovery facilities that produce products which are being used exclusively on farm lands. Compost products used on farm lands have different quality requirements than compost products used for residential use. The current processing standards for moisture content and duration during curing process do not increase the value of compost to farms, but rather it decreases the facility’s operating capacity. The Province should consider creating a new category of compost from source separated organic waste that is used exclusively for farm lands.
10.Policy #2.1 in “Part B – Proposed Food and Organic Waste Policy Statement” (Part B) includes ambitious waste reduction and resource recovery targets for food and organic waste for various entities including municipalities, multi-unit residential buildings, and industrial, commercial and institutional facilities. In many cases, municipalities are responsible for providing food and organic waste collection programs for a wide range of properties including single-family dwellings, multi-residential buildings, and other public buildings such as long-term care facilities, and convention facilities. The Ministry should clarify how the proposed targets in Policy #2.1 would be applied for municipalities that are responsible for servicing a broad range of properties.
11.Policy #2.3 in Part B may need to be revisited considering that personal hygiene waste, sanitary products, and pet waste pose challenges for resource recovery facilities depending on the type of organics processing system being used.
12.Policy #5 in Part B reflects issues related to compostable products and packaging. The Ministry should consider the impacts of compostable packaging and branding testing standards (ASTM D6400, 6868, BPI) to reflect the operating conditions at composting facilities. Producers of compostable packaging should be required to demonstrate that their product(s) can be successfully composted in current processing technologies and processing timelines.
13.Policy #6 in Part B states that “Ontario will need to support existing resource recovery systems and develop additional capacity to process food and organic waste.” The Ontario Government needs to implement measures to support environmental technologies and facilities which handle food and organic waste as well as minimize regulatory burden on organic waste processing facilities with low environmental risk. Existing composting facilities would like to see greater policy support and additional financial resources from the Province in order to help achieve the Framework’s goals. Financial support can be used to upgrade existing facilities with improved processing technologies which can increase resource recovery. Upgrades will allow the facilities to provide additional processing capacity while reducing potential adverse effects on the environment. Upgrades could include waste screening systems and odour control equipment.

[Original Comment ID: 212008]