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Reply to Comments Received in Submissions on the Proposed Export and Import of Hazardous Waste and Hazardous Recyclable Material Regulations
- 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: Delisting
The proposed Regulations should permit the straight de-listing or exemption of specified hazardous recyclable material where a possible hazardous waste is being removed from the environment through recycling, its non-toxic, and where the recycling of materials is being in a manner that will protect the environment and human health. Straight delisting is much simpler rather than PELES which will require additional requirements, time and expenses imposed on the recycler.
A mechanism for generators to delist a listed hazardous waste if it does not exhibit a hazardous characteristic should be included in the proposed Regulation. The characteristics of the material should be the prime mechanism to govern the degree of hazard. The lists can then be used by those companies, primarily small and medium sized, that choose not to test their material, but rely on the lists for classification. This would allow for testing to show that the material is non- hazardous, otherwise, the "lists" would become paramount without analysis, as the generator or receiver would be accepting the hazardous classification of the material in the absence of any other data.
Response: Environment Canada agrees with the recommendation to allow testing of a waste or material to demonstrate that it is no longer hazardous. The proposed Regulations maintain controls for hazardous waste and hazardous recyclable materials that meet the hazardous criteria set out in the proposed definitions.
As indicated above, the proposed regulations exempt specific low-risk recyclable material destined for an authorized recycling facility within the OECD.
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