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Ontario Bill 91 Waste Reduction Act and the role of recyclers – some additional thoughts


Since I posted up my blog “Ontario Bill 91 Waste Reduction Act and the role of recyclers” some good questions have come up:

Q) What about out-of-province recyclers? Neither the Ontario Government nor the Waste Reduction Authority will have jurisdiction to enforce Ontario standards on out-of-province recyclers. How can Ontario standards be applied to out-of-provice recyclers?

A) What I’ve proposed works not by imposing Ontario standards on out-of-province recyclers but having them register with the Waste Reduction Authority voluntarily. Why would any out-of-province recycler register and agree to meet an Ontario recycling standard voluntarily? Why, because it is profitable to do so. In order for a producer to use an out-of-province recycler to meet its regulatory obligations, that recycler would have to meet the WRS and accept audits from the Waste Reduction Authority. The recycler would do so voluntarily so it can receive designated waste on behalf of the producer and profit – that is, make money – by recycling it. It’s simply a matter of harnessing the profit motive to align private interests with the public interest. This is the approach that many existing stewardship programs use to approve and administer out-of-province recyclers that choose to participate in their programs.

Q) Are there any examples of jurisdictions regulating recyclers/waste management service providers for the purposes of providing services to producers under producer responsibility regulations?

A) One does not need to look far. In October 2012 the Ontario Government promulgated Ontario Regulation 298/12 “Collection of Pharmaceuticals and Sharps – Responsibilities of Producers” under the Environmental Protection Act. The regulation assigns end-of-life responsibility for waste pharmaceuticals and sharps to individual producers of those products. Under that regulation producers are required to utilize, “operator(s) of a waste management system who holds an environmental compliance approval in respect of the collection, handling and transportation of the pharmaceuticals, sharps and containers to be collected, handled and transported”. The operators of such approved waste management systems are required to adhere to a specific guideline for the management biomedical waste (Guideline C-4 The Management of Biomedical Waste in Ontario).

Many other jurisdictions require recyclers that service producers to be registered and to adhere to minimum recycling standards and report on their recycling activities. A perfect example is Minnesota that requires registration, minimum operating requirements, insurance and annual reporting of collections, recycling and disposition of recycled materials.

My next blog post is going to explore the nature of Industry Funding Organizations under Ontario’s Waste Diversion Act, Stewardship Agencies under the BC Recycling Regulation and “Intermediaries” as proposed under Ontario’s BIll 91 Waste Reduction Act.


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