Comments and Reply: Confirmation of Disposal or Recycling

• Confirmation
• Prescribed Timing for Disposal or Recycling

A number of industry, association and provincial stakeholders provided comments with respect to the confirmation of disposal or recycling for wastes and recyclable materials.

A provincial stakeholder provided the following comment:

Response: A completed copy of the movement document indicating that the hazardous waste or hazardous recyclable material has been delivered or received by the authorized facility is not sufficient. Rather, the exporter or importer must provide the Minister with written confirmation that the waste has been disposed of or the material recycled. The proposed Regulations do not prescribe the form of the confirmation of disposal or recycling, which may be submitted to the Minister by the exporter or importer in accordance with Section 36.

Both industry and association stakeholders commented that:

Response: The requirement that the final disposal of waste or recycling of material must take place within one year is a new element of the proposed Regulations, and is consistent with the time limit specified under the OECD Decision. An allowance has been made that interim disposal and recycling operations, including storage, must be completed within 180 days prior to final disposal or recycling. If the disposal or recycling cannot be undertaken in the time-frame prescribed by the proposed Regulations, the exporter or importer may apply to Environment Canada for a permit of equivalent level of environmental safety (PELES) outlining the variance.