NGO comments to the Regulation for Hazardous and Special ProductsBlog
HEJSupport joined a group of seven NGOs to prepare comments to the proposed producer responsibility regulation for Hazardous and Special Products (HSP) in Ontario, Canada. Comments provided are guided by NGO primary focus of environment protection and human health.
In the letter to the Ministry of Conservation, Environment, and Parks, NGOs note that due to the hazardous nature of the targeted materials and their potential for harm, ensuring effective HSP Regulation is critical.
As drafted, the proposed regulation is deficient in several areas that could result in substantial regression from Ontario’s current performance and waste reduction objectives. The following initial recommendations are drafted for consideration. All comments are informed by the following principles that Ontario should strive for:
• Reduce and ultimately eliminate the use of toxic substances, and reduce residuals that require management.
• Eliminate risks of harm to the environment and human health through proper collection, management, reporting, and auditing requirements.
• Ensure designated materials include all related hazardous and special products or substances subject to the
regulation regardless of where they are sold in Ontario.
• Fully transfer all associated costs of end of life management from taxpayers and other actors to producers.
• Facilitate innovations at a product or systems level.
• Guarantee consumer protection and foster competition within the marketplace.
• Offer flexibility and allow for innovation for producers to operationalize their obligations.
• Make producers responsible for providing or publishing public information about hazards of improper disposal
and safe collection options.
• Mandate highest and best use of recovered materials resources
Detailed comments can be downloaded here.