The Ontario Municipal Water…

The Ontario Municipal Water Association (OMWA) submits that regulatory changes that reduce oversight/stringency should only be considered if there are sufficient technical data demonstrating no impact to the environment or to the safety of water supply. OMWA opposes changes not supported by peer reviewed technical data and analysis.
The OMWA has serious concerns with the Ministry of Environment, Conservation and Parks’ proposal to streamline permissions for waste management systems and requests that the province NOT proceed with these proposals.
Generally, the OMWA opposes changes to environmental protection frameworks that are primarily made for reasons of convenience or expedience which are made without a technical foundation. This proposal eliminates requirements for registrants to submit applications to the ministry that requires an upfront technical review for the transport and storage of hazardous wastes that have the potential to seriously harm the natural environment, impair water quality and safety, and harm human health.
Currently, waste management systems in Ontario must obtain an ECA, or self-registration on the EASR depending on the waste type and activity or may meet the criteria for exemptions in regulations.
OMWA sees the expansion of provisions for eligibility to self-register on the EASR is set out in Ontario Regulation 351/12, which came into force in 2012, as inappropriate for the classes and types of wastes listed for inclusion in this proposal. Regulation 351/12 streamlined the permissions process for waste management systems that met the definition of waste transportation systems as defined in Regulation 347 and whose activities were limited to the collection, handling, transportation, and transfer of waste, and that managed non-hazardous waste only.
OMWA opposes any expansion of these provisions for waste-management systems that transport and store hazardous waste, in particular, asbestos waste, hazardous waste and biomedical waste that have the potential to cause serious harm to the natural environment and human health. Exposure to asbestos can cause serious health impacts, such as lung cancer and mesothelioma. Hazardous waste includes substances which are classified as “toxic substances” under the Canadian Environmental Protection Act, and includes metals such as arsenic and chromium that, which are listed as human carcinogens by the International Agency for the Research on Cancer. Biomedical waste can be infectious or biohazardous and can potentially lead to the spread of infectious diseases.
OMWA opposes changes to regulatory oversight provisions that do not include a proactive, upfront assessment by an objective body (such as MECP) with sufficient training and expertise to understand and mitigate potential consequences for the natural environment, communities, and human health.
OMWA wishes to recognize and thank both the Canadian Environmental Law Association and Barbara Robinson of Norton Engineering for their guidance and assistance in the preparation of OMWA’s comments.