I agree the HWIN program…

I agree the HWIN program needs updating as I currently have a excel spreadsheet to keep track of my over 50 login names to access all U of T registered sites. It is most inconvenient and can take up to 5 hours to login, confirm, pay and logout for all fees associated with our sites. Why the idea of a parent company, which would be able to over see all registered sites under that organization, was never pursued is beyond me.
My concern for this propose mostly stems around the idea of a digital manifest! A digit manifest is great for one company with one waste stream which is shipped only once a month and I know this digital manifest would eliminate the Ministry's need for people to enter the data found on paper manifests but it would cause extra work and possible errors in our type of environment. First of all a digital manifest is fine for the Ministry but we still need a paper document to travel with the transport vehicle to show at inspection stations, in the event of an incident and should we be auditted by Transport Canada! Currently we need two shipping documents for all shipments because the MOECC prescribed waste manifest doesn't meet the requirements for TDGA. We generate, between Biowaste and Chemical waste at our over 50 sites, on average 15 manifest a week and my group, that manages hazardous waste, doesn't have an office at all site to be able to print off the still needed paper copy of the waste manifest. Errors could develop as the two groups required to complete the manifest before shipping, Generators and Carrier, need to coordinate who has access to the digital document. These error would then be carried into the MOECC database, if all possible checks aren't do. Also not all shipments know what they are collecting before the pickup, so the manifest is written after the waste is packaged. Now we need an app or website access at every site to complete the on-line form which again leads to the availability of a printer for the transport vehicle to leave.
Lastly another problem we have is the public access to our generator information which some contractor will provide to a site contact, not trained in Regulation 347, to 'just sign the manifest'! I find these when I am paying fee and see a manifest which doesn't match any of our filed ones. This then involves searching for the copies based on the site it occurred at since no info on who signed the manifest is currently kept on-line by MOECC. Usual once they are found the mailing address is the site address which means in an environment with many buildings unrelated to the group managing hazardous waste and the waste manifest copy 6 is lost in the mail and we have to contact the reciever for a copy of their copy for our records.
Please make sure you consider all type of waste management environments when enforcing this proposal as many will have issues causing more inconvenience and harder to compliance, in order to make things easier for the Ministry.
PS: Maybe companies with have been more interested in using the current digital waste manifest if they weren't still being charge $5 per manifest when using them too.