REGISTRATION & PAYMENT:…

ERO number

019-1760

Comment ID

47477

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

REGISTRATION & PAYMENT: Supporting documentation should be uploaded to the RPRA online system. Paper copies are not needed as I presume all information will be backed up. The Spills Action Centre should have an electronic fillable form to complete and submit as opposed to the current paper form. This should be linked to the RPRA.

TRACKING & REPORTING: Businesses should be allowed 48 hours to work offline before being required to sync their data. The reporting service should suffice as the official record with generators not needing to store this information as well. Businesses should be able to log in and view their records as well as complete any required actions. Active manifests should be maintained in the reporting service for a period of at least 1 year. My preferred method of accessing electronic manifests, if there is no longer a paper copy, would be in a .pdf format. During emergency situations, my preferred reporting method would be to use an offline capability. Awareness of, and compliance with, short term storage and onsite waste management should be connected directly to the online reporting software. Currently it is difficult and time consuming to find this information for businesses. Also, a link to short term storage reports should be available on this new digital reporting software. Once a business has logged in, notification of items such as reporting non-compliance, should be immediately presented, along with the action to be taken and the time frame for completion of the action. One way of improving reporting of estimates and actual shipped quantities of waste material is to standardize acceptable quantity weighing options, eg. Number of 205L drums, actual weight.

TRANSITION PLANNING: A reasonable time period to transition to electronic registration/reporting is 1 year.

CONTINUOUS IMPROVEMENT: One continuous improvement initiative might be a cost-savings in the fees for companies that switch to products that are environmentally friendly and do not generate hazardous waste.

GENERAL DISCUSSION: Any future regulatory changes could be noted on the digital reporting service to ensure all users have been made aware of them. The fewer methods of communication used is better to ensure the correct individual has been notified. This would eliminate issues if email addresses change.