ERO 019-6963 Streamlining…

ERO 019-6963 Streamlining environmental permissions for waste management systems under the Environmental Activity and Sector Registry

Due to the ongoing and current lack of compliance with the requirement to register with the Excess Soil Registry (RPRA), I am opposed to any changes in the Environmental Compliance Approval process for waste management systems. Each of the listed waste types presents serious environmental and human health risks.
• Asbestos
• Biomedical waste
• Treated biomedical
• Hazardous waste
• Liquid industrial waste
• Waste that was characteristic waste

There appears to be serious non-compliance which seems to be well known to the soil movement industry. It has been reported that:
• Ontario’s Excess Soil Registry appears to be highly underused by industry participants notwithstanding their regulatory requirement to do so.
• It is estimated that far fewer than 50 per cent of projects that would require such registration are recorded on the Registry.
• There is a growing frustration among industry stakeholders including project owners and their consultants who are following the dictates of the Regulation with those that have either not paid attention to their responsibility for compliance or those that flaunt the rules.
• There have been countless initiatives to educate industry players and as such there is growing sentiment that some, both in private industry and the municipal sector, have willfully chosen to ignore compliance as there has not been any prospect of being penalized for such behavior.

MECP staff advised that waste is tracked through the RPRA (Registry) and only deposited at approved sites. Staff also advised that the industry was tightly regulated through details in O. Reg. 347. However, when questioned about current compliance and records of non-compliance staff advised that they “are not the requirements division” and that they couldn’t speak to compliance specifically.

I am opposed to any streamlining of environmental permissions for waste management systems. The ministry must not remove oversight for any aspect of the transportation and handling of hazardous materials, and this includes liquid industrial waste from hydrovac operations and tracking from source to waste management/disposal facility.

It appears that while the rules are being broken, “the province has not been effectively enforcing its own regulations.” There is a pressing need for enforcement and prosecutions.