Discussion paper on modernizing hazardous waste reporting in Ontario

We reviewed and considered the comments received on the "Modernizing Hazardous Waste Reporting in Ontario" discussion paper. We received a total of 76 comments from the following stakeholder groups:

• individuals: 29 comments
• industry: 23 comments
• industry associations: 10 comments (2 of these comments were exact duplicates, resulting in 9 unique comments for this group)
• municipalities: 9 comments
• stewardship organizations: 3 comments
• government agencies: 1 comment
• academic institutions: 1 comment

We received many helpful recommendations to improve the new digital reporting service and make the transition process easier for businesses that we will consider as we move forward. Most of the comments we received fell into three key themes that we will discuss below.

Supportive of a new digital service and going paperless

We put forward a number of questions in the discussion paper around moving to a modern, digital reporting service and how to manage the transition. The majority of comments received have been supportive of the move to a new digital service and moving to a paperless system. Commenters asked us for a user-friendly design for the service, and to make training available to users to ensure they are educated and ready to use the new system.

Commenters expressed that they are looking forward to transitioning to a modern, digital reporting service as this would likely reduce errors typically associated with completing a paper document, would reduce storage space required for paper filing, and would improve efficiency in their business processes. We received recommendations on how to reduce errors and improve data quality, such as designing the new service to highlight differences in the quantity shipped by the generator and the quantity received by the receiver.

Managing manifests in the new system

We received many recommendations and questions on how electronic and paper manifests would be managed going forward. In terms of paper manifests, we received recommendations to continue the use of paper manifests for certain reasons, primarily in areas where there may be poor internet connectivity.

We also received comments about allowing delegates to report certain information, such as allowing the waste carrier to complete a portion of the manifest on behalf of the waste generator. Some commenters alternatively recommended that delegates should only complete specific fields and that the waste site owner should be responsible for the majority of information.

We also received recommendations on ensuring that active digital manifests remained available in the reporting service. Most commenters suggested between 2-5 years.

We also received recommendations to align with the federal Transportation of Dangerous Goods Act to reduce current differences in the manifesting process.

Registration and record management

We put forward a number of questions in the discussion paper around how registration and payment should operate in the new system. One question included “now that businesses are moving digital, should we allow supporting records (e.g. data, analysis and other supporting information used in the preparation of the Generator Registration Report) to be kept electronically or are paper copies needed” – we received consistent feedback that no paper copies of this type should be required going forward.