Comments and Reply: Environmentally Sound Management

• Content of the ESM Criteria
• Application of the ESM Criteria
• Cost

A number of comments were received by environmental groups, provincial, industry and association stakeholders with respect to the environmentally sound management (ESM) criteria set out in the proposed Regulations.

Environmental groups commented that:

Industry and association stakeholders commented that:

Response: The criteria in the proposed Regulations are meant to build on the progress that has been made at the international level and to reflect the criteria used by the OECD. The OECD Council adopted the Recommendation on the Environmentally Sound Management of Waste on June 9, 2004.

Environment Canada will consider further clarification through compliance-promotion material.

Industry and association stakeholders commented that:

A provincial government stakeholder commented that:

An industry stakeholder commented that:

Response: In accordance with Part 7, Division 8, of CEPA 1999, the Minister may refuse to issue a permit to import, export, or transit hazardous waste or hazardous recyclable material if the Minister is of the opinion that the waste or material will not be managed in a manner that protects the environment and human health. These proposed Regulations set out the criteria under which the Minister will make this determination.

In order for the export and import of low-risk recyclable materials, now listed in Schedule 8 not to be subject to the proposed Regulations, the material must be destined for recycling at an authorized facility within the OECD, and must exhibit only leachability.

An industry stakeholder commented that:

Response: The RIAS estimates the costs to industry of complying with the proposed Regulations. Exporters and importers may require an initial investment to verify that they meet the criteria set out in the proposed Regulations and to take corrective measures, where necessary.