The Corporation of the City…

The Corporation of the City of Barrie's Environmental Compliance Unit (City) has reviewed the ERO proposal and has the following discussion comments to be taken into consideration when modernizing the Hazardous Waste Reporting in Ontario:

Registration and Payment

1. To ensure generators are aware of their regulatory obligations public outreach and education is recommended. This can be achieved through the Ministry’s website, email to hazardous and industrial waste facilities, and to the HWIN administrators.
2. All information provided by the Ministry should clearly outline in the legislation the records retention responsibilities for each regulated group.
The requirement for paper copies is unclear. If the Inspection Officer has access to the digital records at the time of the inspection, this would eliminate the purpose of the requirement for paper copies.
3. Typically, when spills or emergency situations occur the Owner may not be registered in the digital system, as an address may not be applicable. The new digital system will need to be web based and smart phone friendly. The legislation needs to make clear; the roles and responsibilities of each regulated group (Generator, Carrier, and Receiver), how each section of the manifest is to be completed by each group, and how the chain of custody moves through the process digitally. The new system should provide the Generator with notification that the manifest has been completed.

While in the beginning stages/phases of implementation, Spills and emergency situations should be handled per the current processes, until the digital system is operating with minimal errors.

If Generators are required to both implementing digital information and maintain the current paper manifests for the same Hazardous waste disposal event, this will result in duplicated work. We strongly recommend that one system be utilized.

Tracking and Reporting

1. Generators should provide offline information forthwith, (within 24 hours) of any shipment/movement of hazardous waste. This will ensure that the information is accurate and up to date and minimize gaps. The legislation should include enforcement actions for not reporting information within the specific timeframe if offline. Streamlining the information for the Generator and Carrier requirements will allow for faster response times when offline. Legislation will need to clearly outline manifest completion when offline and ensure gaps between groups is minimized.
2. Maintaining current record management practices will ensure proper records are maintained and archived accordingly. Record management responsibilities for each party (MECP, RPRA, Generator, Carrier, Receiver) must be clearly outlined in the legislation (digital and/or paper). It must be made clear if the records found on the new system will suffice as record management/retention or if a backup method is required.
3. The format will depend on what businesses are required to do with the information. Excel format is recommended to track and document waste movements. Whichever format the documents are to be provided, consideration must be taken to ensure that the documents can not be changed or tampered with.
4. Legislation should also outline the responsibilities for the Generators, Carriers, and Receivers.
The legislation needs to make clear the roles and responsibilities of each group (Generator, Carrier, and Receiver) for completing each section of the manifest to ensure that the chain of custody moves through the process.
In emergency situations, paper may be the easiest way to track waste until the new digital system is fully functional, and all users are online. Not all Generators will be mobile ready. Contingency measures should be developed if a group does not have the digital capacity to complete the manifest or there is an error in the system. 24hour support should be available for emergency disposals.
While implementing the digital system and if maintaining the paper manifests, this will result in duplicated work for each group. We recommend that one system be used. Document maintenance will become cumbersome if two systems are used.
5. Improving awareness and compliance with short-term storage and onsite waste management requirements can be achieved through the Ministry website, generators/receivers of subject waste are sent notification emails, use of the ERO.
6. The best way to notify of reporting non-compliance to prevent future non-compliance is to be notified immediately of the non-compliance by email/text. Non-compliance in the new reporting system should be flagged. If improper information is submitted an error is triggered.
7. Having different forms for the standard types of shipped quantities (i.e. number of 205L drums, volume extracted by a vacuum truck, etc.) would make it easier for businesses to complete the digital manifests. If standard forms are developed, auto populated sections should also be developed to allow businesses easier access for completing the form (i.e. Once an address is provided, the business must provide contact information, etc.)
8. The City does not have any comments for other system features in the new reporting service at this time.

Transition Planning

1. Depending on the platform that is developed (i.e. web, app, etc.) and once training has been provided and manuals have been created for all users’ groups, further comments can be provided for the reasonable timeframe for the transition to electronic registration and reporting.
2. Transition issues would include software or electronic devises that are required to utilize the new reporting system. The new digital system should be developed for mobile devise use. Businesses may require longer timelines to implement mobile devises for their use.
3. The costs to the City could be significant if the digital system is not compatible with mobile devises currently in use.
4. To ensure a seamless transition, manual development for all user groups, training and 24/7 IT support services should be developed. Contingency measures will need to be developed and clearly understood if IT support is unavailable during waste movement.
5. IT support services, manuals, Standard Operating Procedures, and FAQ section on the digital system for how to use the new digital reporting system would benefit all groups involved.

Performance Measures

1. The City does not have any additional performance measures to add to the list provided in the discussion paper.
2. The City does not have any additional performance measures to add to the list provided in the discussion paper.

Continuous Improvement

1. The City recommends that comments be requested for the digital system once it has been developed.
2. The City does not have any comments with regards to moving beyond the safe management of hazardous waste to the reduction of hazardous waste.

General Discussion

1. The Hazardous Waste digital reporting service modernization project may impact the City of Barrie response to hazardous waste spills, acceptance, and movement of hazardous waste, but until the digital system has been developed it is unclear of the impacts.
2. Consultation on the future regulatory changes should be through the ERO.
3. The City has no comments with regards to any improvement for the digital tracking of hazardous waste until the new reporting system has been developed and is operational.