The County of Dufferin is…

The County of Dufferin is pleased to submit comments on the Ministry’s proposed Hazardous and Special Products (HSP) regulation.

An ERO submission has been made by the joint group of AMO, Toronto, RPWCO and MWA, in which the County of Dufferin is in strong support. The County would like to highlight a few specific areas in our comments.

- Delay implementation – more time is needed to properly draft the final regulation and for all stakeholders to properly plan based on the final regulation. Service contracts need to be amended/extended/completed, and new agreements developed.

- Designating materials – there are various hazardous and special wastes that are in the municipal waste stream, that are dealt with by municipal depots and events. We reiterate that the regulation should designate the materials municipal governments recommended in the July 2020 joint-submission by AMO, Toronto, RPWCO and MWA. Municipal taxpayers are paying for the end of life management of these materials, and by not including them (within Phase 1 and 2 for example), they will continue to pay for them, instead of the producers that should be responsible.

- Refillable propane tanks and fertilizers – these materials should not be excluded from the regulation, and should have management targets. The reality for municipalities is that residents will bring these materials to our depot and events, regardless if they are designated or not.

- Education by producers - we reiterate that producers should be required to provide at least one direct educational piece to every household once per year. Households are inundated with various messages, information etc. every day. Sources include social media, websites, newspapers, etc. With these various channels, the message can be lost sometimes if the household doesn’t use/read/access that channel. A HSP education piece (i.e. through a calendar, flyer etc.) would help to ensure each household receives the message directly.

- Collection and consumer accessibility – within Section 14.3 (HSP collection events) of the draft regulation, it states that “If the HSP collection event is held in respect of a hazardous and special product in a municipality, it must be held at least 30 days after the last day of the previous HSP collection event that was held in that municipality in respect of that hazardous and special product”. From a contract servicing point of view, this becomes difficult when there are limited dates available with a limited number of service providers (i.e. as they are servicing many different locations, and many events are held only seasonally). There is also a concern with recording personal information when a person drops off more than 25 kg (or more) of materials in a day. In the case of the County, we do not have scales at event day locations. Most people would have well over 25 kg of material that is a mixture of designated and non-designated material.

Thank you for the opportunity to comment.