Waste Management Systems –…

Waste Management Systems – EASR Proposal
Comments from United Soils Management

United Soils Management is a beneficial reuse site that accepts clean fill under a municipal instrument granted in 2016. We are not a waste management company, but our work is part of the construction and trucking industries.
We have reviewed the proposal to ease Environmental Compliance Approval (ECA) requirements and allow Environmental Activity and Sector Registry (EASR) registration for some aspects of waste management systems. The changes are for the parts of waste management systems associated with collection, handling, transportation, and transfer and does not include the storage, treatment, processing, and disposal of waste.
It is good that the change will allow technical reviewers to focus on the more complex waste management operations. It is important that any reduction in Ministry review time be accompanied by a strong education and enforcement effort. It is critical that waste management operators be fully aware of the need for environmental protection and safety in the operation of waste management systems.
It is also critical that companies managing hazardous waste and naturally occurring radioactive materials incorporate the highest performance standards to ensure environmental and employee protection. It is important that any change to this regulation instill fairness in the industry while still assigning responsibilities commensurate with the risks associated with the materials being handled. Fairness may not mean the same restrictions across the board for all waste management systems. Changes to the permitting process cannot water down the protections that Ontario residents expect.
Strong enforcement is needed, not only “periodic auditing”, particularly in the early days of the change. Penalties for non-compliance needs to be significant, to ensure that the self-registration option provided by the EASR process is not used to avoid requirements that would be imposed if a full technical review was completed.
Finally, the suggested limits for insurance of $2,000,000 is not high enough for systems managing hazardous or NORM waste. Limits of $5,000,000 to as much as $10,000,000 might be more appropriate for these higher risk operations.