Comments on ERO Registry…

Comments on ERO Registry Number: 019-0671

Changing the Mandate of the Resource Productivity and Recovery Authority

November 27, 2019

Jamie Haldenby
Program Management Branch - Program Oversight
40 St Clair Avenue West, 4th Floor
Toronto, ON M4V 1M2

The Ontario Automotive Recyclers Association (OARA) is a voluntary industry association representing 110 professional automotive recyclers across the province. Formed in 1992, OARA Members have been at the forefront of the industry, working with governments, manufacturers, repairers, vendors and allied industries to bring responsible progress to the industry. Our Members are all audited to the Canadian Auto Recyclers Environmental Code (CAREC), developed for Environment Canada for the National Vehicle Scrappage Program. They are also all registered as End-of-Life Vehicle Waste Disposal Sites on the Ministry’s Environmental Activity and Sector Registry (EASR).

OARA Members process end-of-life vehicles (ELVs) for parts reuse and materials recycling, managing the waste byproducts from the collection of these resources in an environmentally responsible manner. Items from ELVs that are managed and included in current stewardship programs are tires, oil, washer fluid, and antifreeze.

Our interaction with of the Resource Productivity and Recovery Authority (RPRA) has been limited to a few consultations regarding the transition of the scrap tire program. Since that program is less than a year old, we have not been through a full cycle of targets, compliance, education and enforcement with RPRA to gauge whether they are ready to expand their responsibilities. As of yet, RPRA has not demonstrated that it is capable of adding further enforcement activities to its portfolio of responsibilities.

Conceptually it makes sense for a non-government entity to have a role in ensuring compliance and enforcement activities. They can often times be more flexible and nimble in seeking compliance. But the full authority of the government needs to be behind that non-government entity. Without the tools and resources to force compliance with full enforcement, the regulations are toothless, and something business opposes.

Near-government entities like RPRA, especially those without direct industry expertise or overseeing multiple, disparate industries, need to have formal mechanisms to interact with the very industry they are overseeing. Formal, responsible industry advisory committees are required in order for RPRA to be effective – whether their mandate expands or not.

Specific to the issue of reworking the Hazardous Waste Information Network (HWIN), the program is due for modernization but not with the seemingly singular goal of getting more stakeholders to pay more in order for the system to be modernized. Our Members interact with HWIN on an annual basis, so there is very limited opportunity for process improvements that will be beneficial for our sector. We would oppose the concept of the same level of service/benefit at a higher cost simply to look modern.

Whether a business is registered with HWIN is a compliance tool we use to evaluate whether a business is in overall compliance with their regulatory requirements and we would need to have simple, free access to the HWIN registration data. How much a business is manifesting would be very important information for us to review as it is an indicator or whether they are properly depolluting vehicles. Having access to this information would be useful to ensure businesses are in compliance – useful for industry and useful for government.

On balance, I would say that we have insufficient data to determine whether RPRA, at least in their current state, has the expertise and resources to take on more responsibilities. The scrap tire transition has been lackluster and they have an enormous list of future items to transition to IPR. Providing more responsibility before they have demonstrated expertise has crushed more than one business or institution that has grown too big too fast.

Should you have any questions on this submission or desire any further industry information, including site visits to continue your understanding of the impact of the proposed regulations on industry, please do not hesitate to call.

Regards,
Steve Fletcher, BSc, MBA
Executive Director
Ontario Automotive Recyclers Association (OARA)
steve@oara.com
519-858-8761