We are operating as a dental…

We are operating as a dental clinic generating a small amount of X-ray fixer solution which needs to be removed periodically by a certified carrier. The volume involved is less than 30 litres every 3 years.

We used to be exempted from HWIN registration before, but somehow the regulation was amended to include dental practice with more than one dentist (we have 2).

Our comment: If the purpose of the proposed change is the save money and time, we suggest that consideration be given to exempt small offices like us from being required to register/ do periodic electronic reporting, if any, under the program.

We also suggest that consideration be given for any requirement to register/report to go by the actual volume of waste generated rather than by the number of dentists in the office.