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Reply to Comments Received in Submissions on the Proposed Export and Import of Hazardous Waste and Hazardous Recyclable Material Regulations
- Introduction
- Parties Providing Submissions
- Comments and Reply
- Comments and Reply: Harmonization
- Comments and Reply: Pre-Approved Facilities and Three-Year Permits
- Comments and Reply: Decoupling the Definition of Waste and Recyclables
- Comments and Reply: Delisting
- Comments and Reply: Definitions
- Comments and Reply: Content of Notice
- Comments and Reply: Conditions of Export and Import
- Comments and Reply: Movement Document
- Comments and Reply: Returns and Reroutements
- Comments and Reply: Confirmation of Disposal or Recycling
- Comments and Reply: Low-Risk Recyclables
- Comments and Reply: Waste-Export Reduction Plans
- Comments and Reply: Environmentally Sound Management
- Comments and Reply: Permits of Equivalent Level of Environmental Safety
- Comments and Reply: Public Access to Information and Decision Making
- Comments and Reply: Schedule 2 - Recycling Operations for Hazardous Recyclable Materials
- Comments and Reply: Schedule 3
- Comments and Reply: Schedule 4
- Comments and Reply: Schedule 5
- Comments and Reply: Schedule 6
- Comments and Reply: Persistent Organic Pollutants
- Comments and Reply: Vanadium Pentoxide
- Comments and Reply: Treated Wood
- Comments and Reply: Other General Comments
- Comments and Reply: Interprovincial Comments
Comments and Reply: Conditions of Export and Import
A number of comments were received from both industry and association stakeholders with respect to the conditions of export and import set out in the proposed Regulations. Industry stakeholders commented that:
An allowance has been made for a 'problem load notification' that is 'imported but not accepted' (Section 12) to occur within five (5) days of arrival. It will be impossible in certain cases to accept the wastes in these 5 days, depending on the type of analysis that is required.
Environment Canada should extend this to 30 days, a more realistic timeline.
Section 8(b) states that if necessary, the exporter will store the hazardous waste/recyclable in a facility authorized to store the waste or material by the authorities of the jurisdiction in which the facility is located. The requirement to locate an available authorized facility in the specific jurisdiction may be difficult. It is also unclear what defines a jurisdiction.
Response: Environment Canada agrees that five days may not be sufficient to undertake the type of analysis required for facilities to accept hazardous wastes or hazardous recyclable materials. As such, this provision has been removed from the proposed Regulations. Typically, the jurisdiction in which the facility is located sets out how long a waste or material may be stored before it must be disposed of or recycled.
Section 16(o)(ii) has been included in the proposed Regulations, since not all facilities are authorized by their jurisdiction to store hazardous wastes or recyclable materials in the event that these materials are not accepted by the receiving site. If the facility is authorized to store the waste or materials, it may do so until an alternate arrangement can be made, as approved by the Minister. The provincial authority authorizes the facility in the case of an import; the competent authority of the country in the case of an export.
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