A few comments from the…

A few comments from the discussion questions:

Registration and Payment

1. For clients, where I register their waste activities on their behalf, as part of my practice, i have always informed the client on their obligations under the regulations. This information came in the form of an authorization form, which outlined what was being registered and why. I found this provided the generator the information they need, if they were inspected by the MECP. In addition, my contact information was also available to assist as needed.
As a full time worker in the hazardous waste business, it is second nature to properly register a client under HWIN. If the client is allowing a consultant to register the waste, it should be the responsibility of the consultant to ensure that the generator is fully aware of their regulatory obligations.

2a. supporting documentation should be allowed to be stored electronically. As waste disposal sites heavily rely on electronic databases, these databases are now allowing for the storage of a large amount of information, including analysis and waste classification data.
Providing proof of classification by uploading the appropriate documentation will save time and space in the long run.

3. In the event of a spill, getting the spill contained and cleaned up is our first priority. Once any residual waste is ready to move out, we start the process of registration.
Currently, we seek an emergency generator number for spills requiring registration. This route works well, but it is normally the same number for all spills.
An alternative could be using something like the Field Operations Exemption. In a spill, we know who the generator of the spill is. Instead of issuing an EGN, use the generator number for the generator of the spill. If the generator needs to be added, then the generator is added. the new waste reporting system may need to have the capability of having multiple generating sites added to it, but this would also be a benefit for multi-site generators such as schools or large corporations, where there is one main mailing address and multi generator sites.

Tracking and Reporting

1. Personally, I sync my own data on a monthly basis. I find that I generally know what is going on month to month and ensure my database is updated to reflect minor changes every month upon inspections.

2a. On a legal note, two years is what is required to hold onto data. In terms of how long information is usually relevant, maybe within a 6 month window, once invoicing has been complete. If there will be a dispute in invoicing, we usually turn to the shipping documentation as proof of shipment.
2b. The generator should always store their information aside from what is in the new system. This is their proof of shipments and their compliance to Reg. 347. This storage of information can be downloaded and stored electronically from the new reporting system.
2c. no comment

3a. I like an excel option as it can provide better sorting and organization

4a. for emergency situations, could a combination of both off-line and paper availability work? SAC will still be involved in the gathering of information and the primary goal for emergency response is to attend to the emergency and ensure the safety of the public and natural environment. As per above, information can be collected VIA off-line and/or paper, relayed to SAC and moved over to the reporting system, once able to do so. All activities of an emergency response will be part of the supporting documentation.

5. Better enforcement is one of the best ways to fully improve awareness and compliance with waste management requirements. Far too often, I go to generator sites, where waste has appeared to sit for a long time. When trying to explain the regulation and the generator's requirements for storage and disposal, I often hear that there has been no inspection. On the other hand, when a generator does receive a visit from the MECP, they are fully aware of what they need to do.

6. For non-compliance, an anonymous hot-line for people to call or email into for the ministry to take action. For this new reporting system, would it also be possible to flag some actions i.e. where a generator was producing x amount of subject waste and suddenly stops. Or a listed waste is registered and it suddenly stops with no support. Or a profile will not match up. a 148C is profiled once but can represent a wide range of different waste streams.

7. for better accuracy in shipped quantities of subject waste, one idea could be to have the receiving facility list how they are obtaining their measurements. Is it through a scale, dip stick and chart. in addition, make it a requirement to have proof of calibration or accuracy to ensure that what is being received is correct. The estimates are only estimates (hopefully within 10%) but put the responsibility on the receiver to prove what they are receiving is accurate...after-all, they are probably billing on this.

8. the only other feature would be to have a better way to correct the manifest or even reject a load of subject waste on this service.

Transition

1. no comment - ASAP is my preference

2. Just making sure that all companies are on the same page. Have transport companies and receivers go first, to learn the system. Have them work to help the generators of waste.

3. no comment.

4. just how the system will work and some time to work within the system itself.

5. as a subject waste receiver, just showing our current database for our own incoming waste. Everything we do is tracked, where we can see where every drop of waste went. Once a generator sees this detail, they get on board to properly track their own waste...especially generators with zero land-fill requirements.