Deng: The Association of Municipalities of Ontario (“AMO”), the City of Toronto, the Regional Public Works Commissioners of Ontario (“RPWCO”) and the Municipal Waste Association (“MWA”) collectively submit these comments on behalf of municipal governments regarding the Proposed producer responsibility regulation for Hazardous and Special Products (HSP). [...] This will mean the need to extend the current program timelines but believe it to be prudent given the potential for issues with this regulation and the lack of time to plan. [...] Housekeeping Recommendation 14: There appear to be a number of drafting errors in the draft regulation that include, but are not limited to the following: • Section 10(2)1i appears to be missing the word ‘producer’; • Section 13 and 14 do not clearly delineate the difference between collection sites and collection events; • Appears that section 26 might be missing the need to report supplied data. [...] The basis for proper management begins with an educated consumer relative to the human health and safety and environmental risks associated with MHSW products, and clear direction on how to dispose of the material into a collection system that is convenient to use and widely available for designated products and containers. [...] For the rest of the materials, which are largely captured by municipal depots and special events, it would be reasonable to follow similar accessibility rates to the draft electronic and electrical equipment regulation.3 Fundamental to the new regulation is the requirement that accessibility and collection not be curtailed or impeded when producers are approaching or have met any management target.
- Pages
- 24
- Published in
- Canada
