On March 15, 2002 Marks S. Winfield, Director of the Pembina Institutes Environmental Governance program submitted a letter to Mr. Frank Coschi of the Waste Water Management Policy Branch. This letter comments on the Ministry of the Environment's proposals posted on the EBR Registry on December 18, 2001, and the announcement of decisions regarding the implementation of hazardous charges and annual generator registration on the same day (EBR Registry No.RA01E0003)
The Pembina Institute supports the Ministry's overall direction towards the strengthening of Ontario's hazardous waste management framework. Gaps in the existing framework have been identified as a major factor in the growth of hazardous waste imports into Ontario since the mid-1990's, when the United States adopted new standards regarding the handling and disposal of hazardous wastes. The current situation with respect to hazardous waste standards in Ontario places the health, safety and environment of the province's residents at risk, and needs to be addressed on an urgent basis.
However, the Institute is seriously concerned by several aspects of the Ministry's December 2001 proposals, particularly with respect to the mandating of the destruction of PCB's currently in storage within three years, and certain aspects of the Ministry's proposals regarding biomedical wastes. The letter outlines the Pembina Institutes specific comments.