Appendix D: Comments Received after the Workshops

I enjoyed the workshop in Toronto on February 11/12. While you are writing your summary notes on this workshop, I just wanted to remind you that a few of us believe that these regulations should mention the importance of "onsite treatment" as a preferred alternative to final disposal of hazardous waste.

The printed material provided by Environment Canada during the workshop often encouraged reuse and recycling before final disposal, but I think they should actually include the word "treatment" as a preferred option to final disposal. Unless the words "treatment" are written, many waste generators may not consider "onsite treatment" as a viable option and chose hazardous disposal as their preferred waste management option if reuse or recycling is not available.

Consider the list in the second paragraph of Section 10.4 in the January 18th Discussion Paper. You could add the descriptor "onsite treatment" after "eliminate" in the first bullet so that it would read:

• reduce and eliminate (ex. using onsite treatment) the generation of hazardous waste

I also think "onsite treatment" should be used in the discussion of the "conditional exclusion process". Failing to mention "treatment" in this section, created a great deal of confusion in the Calgary "Interprovincial" Workshop Oct 2/3 1999, especially when Joe Wittwer mentioned that, "you can not test out for listed waste". I think it would be much clearer if Environment Canada said something like this:

• Cannot test out for listed waste (Schedule 4, List 2) [Unless generator applies for and is granted a conditional exclusion]. Then in the definition of "conditional exclusion" include, " a waste that does not exhibit any characteristic or has been treated to remove the hazardous characteristic (Note: dilution is not treatment)."

Encouraging treatment over disposal also promotes "innovation". No one will make these investments in new treatment technologies if waste generators have no incentive to choose treatment over disposal. Industry Canada has made some efforts to promote Canadian industry to be more innovative, however, there needs to be either a financial or regulatory "driver" to entice waste generators to consider treatment ahead of disposal.

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