3. Conclusions
- 3.1 Industry
- 3.2 Non-governmental and Community Organizations
- 3.3 All Stakeholders
- 3.4 Suggestions from the Workshop Groups
As detailed is Section 2 above, a range of issues respecting the proposed PCBWEIR were discussed in the three workshop sessions. Overall there was general support for the proposals, but there were some concerns. To better understand and therefore address the concerns of the participants representing the various points of view, this section summarizes the key issues raised according to stakeholder group.
Proposed changes of greatest concern to industry participants were:
- Consideration of controlling imports and exports of wastes containing PCBs in concentrations between 2 and 50 ppm:
- Industry participants were worried about the "stigma" associated with labelling a waste between 2 and 50 ppm PCBs and the resulting implications that might have for their operations.
- Many viewed this possible regulation as the "thin edge of the wedge" to regulating these wastes as hazardous.
- Some participants were apprehensive that the increased volumes of wastes that would need to be reported could impede recycling, e.g. auto bodies.
- Requirement that the country of export provide written confirmation that it does not have the technical capacity and the necessary facilities, capability or suitable disposal sites in order to dispose of the waste in an environmentally sound and efficient manner:
- Overarching concern about the increased administrative requirements (paper burden and waste analysis) that have the potential to negatively affect company competitiveness.
- Requirement to ensure that the PCB waste and any residue from its production can be treated at an authorized facility:
- This requirement that imports be received only by properly authorized destruction facilities could also be a competitiveness impediment for importers who receive wastes in temporary storage facilities until sufficient volumes justify shipping them to appropriate destruction facilities.
- Obligation to make alternative arrangements should disposal of an imported material not be able to occur as notified:
- Competitiveness concerns arose because of worries that this requirement would complicate commercial transactions, make companies deal with their competitors, impose unnecessary administrative overhead, and cause shipments to go to facilities in provinces with lower standards.
Proposed changes of greatest concern to non-governmental and community participants were:
- Notice
- Many individuals representing environmental, community and First Nations interests were very concerned about the public's right to know and having an effective mechanism with guidelines for consultations respecting hazardous wastes.
- Criteria on the country of export
- Participants were concerned that Canada would become dumping ground for the world's PCB wastes.
Overall, there was a plea for harmonization from many different stakeholders:
- Participants identified a lack of consistency between the proposed threshold of 2 ppm for low-level PCB containing wastes and the current 0.5 ppm criterion for treatment/clean-up of PCB wastes;
- They recognized several different guidelines about acceptable levels of PCBs in wastes; and
- Were concerned that the current processes that harmonize federal - provincial notification requirements for contaminated soils be preserved.
A number of participants thought that low-level PCB containing wastes were not actually wastes as defined in the regulations and therefore consideration should be given to including their control somewhere other than in the PCBWEIR.
The need for information, openness and transparency in the process of developing regulations calls for additional and more effective public consultation. It was suggested that public consultation guidelines be developed and implemented.
Industry representatives suggested that when seeking export authorization, technology or capacity evaluations that it might be more appropriate if this were undertaken as a country-to-country initiative.
It was proposed that Environment Canada consider requesting the source of wastes to address dioxin and furan concerns for wastes containing between 2 and 50 ppm PCB.
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