The following is a summary…

The following is a summary of general comments/sentiments pertaining to the Proposed Hazardous and Special Products (HSP) Regulation. More specific and detailed commentary has been attached that addresses key sections within the Regulation.

1) The Regulation should explicitly say "100% of HSP materials collected must be 100% managed by Producers". While this may be the intent of the regulation, it is not clearly stated and the sentiment is lost in the wording and details. A simple statement to this effect would do a great deal to reinforce the spirit and intention of the regulation and avoid disputes regarding funding responsibilities in the future.

2) Many of the obligated HSP materials are "subject wastes", and therefore must be handled in accordance with Reg.347. I would encourage the proposed HSP Regulation to reinforce that Subject Wastes MUST be handled properly and avoid the temptation to deregulate or exempt these materials in an effort to facilitate retail collections.

3) The regulation should consider implementing Minimum Management Targets for all HSP materials, including consumables. There is sufficient historical data to establish realistic minimum management targets for all categories (including consumables), recognizing these are simply minimum thresholds and any materials collected above & beyond the minimum will be managed by Producers as well. These minimum targets offer accountability and motivation for implementing effective collection systems.

4) Non-retail Collections Sites form an integral part of the HSP collections system. These sites include ECA licensed Municipal and Private depots. The 25kg threshold proposed at these sites poses a significant and unnecessary burden on the management of these sites. I would recommend removing or revising the 25 kg threshold for HSP materials brought to non-retails collections sites.

Further commentary on these topics and additional topics is provided in the attached document.