Appendix A: Pre-Identified Issues for Discussion

  1. Are the definitions of the terms "waste" and "recyclable material" sufficient to avoid ambiguity? Overall, are all of the proposed definitions clear?
  2. Are there any terms or definitions that you believe should be included in order to make the Regulations clearer?
  3. The proposed amendments have included separate control regimes for waste and recyclables. Will this assist in removing some of the perceived "stigma" associated with hazardous waste from being placed on hazardous recyclable material?
  4. Scope of Coverage - conditional exclusion - Will this mechanism be useful?
  5. The exemption limits are 5 kg/5L for wastes and recyclables, or 25 kg/25L for recyclables that are samples. Are these quantities adequate?
  6. Prohibitions - Do you have any concerns with these, or related issues?
  1. Will the proposed renewal mechanism be helpful in reducing the amount of repetitive work that must be done for your notices?
  2. Would e-filing (notices/manifests/certificates of completion) make submission of the required documents easier?
  3. PELES - Do you have any concerns with the use of PELES and/or the types of information that must be provided? Will they be a useful tool for your industry?
  4. Do you believe that the existing levels of insurance required for shipments of hazardous waste and hazardous recyclable materials are adequate? Should they be reduced/increased?
  5. CEPA, 1999 provides a mechanism to require exporters to provide waste reduction plans to reduce or phase out the export of hazardous waste. Under these powers, the definition of "exporter" may include the generator. What potential problems do you forsee for your industry? How would this impact the waste management industry in Canada?
  6. In your opinion, are the proposed regulatory elements and guiding criteria for waste reduction plans reasonable? Are there any elements that are missing? Do you believe these plans will succeed in reducing exports for final disposal?
  1. In the application of ESM in Canada, what is your view of the use of regulatory versus voluntary tools as presented in the overheads? Do you want a strictly regulatory ESM system or a mix of regulatory and voluntary measures?
  2. The Europeans favor the use of ISO 14,001 with third party auditing as a means of implementing an Environmental Management System (EMS). How do you think Canada should meet the goal of an EMS as part of an ESM system?
  3. Do you believe that an EMS would be beneficial, and serve the purpose as described above? Are there any barriers (practical or financial) unique to your sector that would make it difficult to obtain certification in an EMS such as ISO 14,001, etc.?
  4. The core performance standards were proposed by the OECD as part of an ESM system. Are there additional performance standards that need to be considered, in order to achieve the overall effect of protecting human health and the environment against adverse effects?
  5. What are the pros and cons of the proposed models (short term versus long term) for implementing the framework? Which do you believe would work best for your sector?
  6. Would linking ESM criteria and review to provincial processes for C of A's ensure safe transport and management of hazardous wastes across Canada, an lead to an acceptable degree of uniformity among provinces/territories, without creating inter-jurisdictional interference or duplication of effort?
  7. What do you think about housing the ESM performance criteria in a National standard and using that as an evaluation protocol?
  8. Do you believe that 'recycling' and 'treatment/disposal' should be treated equally under ESM? Are there better ways to ensure that recycling operations meet ESM criteria without linking them to waste disposal?
  9. How should Canadian ESM criteria be applied to exports? The proposed criteria require the existence of effective legislative and enforcement program in the country of import, and adherence with its emissions standards. Is this sufficient?
  10. One of the proposed criteria is that disposal take place as close as possible to its point of generation to minimize transboundary waste shipments, while recognizing that economically and environmentally sound management of some wastes requires facilities located at a greater distance or across an international boundary. Is this position too lenient or too restrictive?
  11. Under the new regulations, waste exporters or generators will have to have an effective program for minimizing the generation/export or wastes destined for disposal. In your opinion how important, and how reasonable, is this requirement?
  12. What do you think of the proposed means of putting the ESM framework into place?

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