Additional requirements,…

Additional requirements, largely aimed at document control requirements for various management systems, are so basic that Operating Authorities need not establish additional controls within the DWQMS program.

Additional feedback, on subjects other than one addressed here, is very critical in many ways, including "getting value for resources expended by the Operating Authorities under the regulations established by the Ministry.

1. Surveillance audits conducted are limited to documentation audit between an site re-assessment audit is conducted every three years. Document audits are not of much value. For a marginally higher cost (transportation) there is huge value to OA in receiving an on-site audit. This feedback is being provided by someone who is a Management System auditor with thirty (3) years of global experience and 15 years of DWQMS audits.

2. Future changes, specific requirements as an outcome, or process, should be flowed through DWQMS. A robust Management system can encompass future changes quite easily and effectively.

3. We in Ontario should work toward the empowerment of all stakeholders such that new requirements, programs, and processes are embraced rather than forced upon.

If further dialogue is useful to Ministry personnel reviewing this feedback, I will be thrilled to spend my personal time as a proud Ontarian and Canadian. please send e email message to kd_assoc@hotmail.com