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Reply to Comments Received in Submissions on the Proposed Export and Import of Hazardous Waste and Hazardous Recyclable Material Regulations

Comments and Reply: Schedule 6

Provincial and industry stakeholders provided comments with respect to Schedule 6 of the proposed Regulations.

Schedule 6 would appear to apply to any land disposal of a long list of chemicals. No Concentration Limits Are Included. If these lists are meant for pure chemical streams (like the EPA P&U lists or Alberta Discarded Commercial Chemical lists), then their application in this context should be made clear.

Environment Canada's stated objectives (Senes Report) were to introduce P and U for possible regulation creation with the intended purpose of managing landfill practice in Canada. Waste lists for this purpose should harmonize with those in Ontario's Regulation 347.

There is no justification for singling out energy recovery (R1) as a reason for classifying recyclable materials under Schedule 6. This is a valid form of recycling in controlled situations, as permitted by provincial jurisdictions.

Response: Environment Canada agrees that the application of Schedule 6 should be harmonized. Schedule 6 applies to chemicals that are unused and that are either pure or the only active ingredient. In addition, the applicability of the disposal and recycling codes has been clarified to improve harmonization with the provinces and territories and the U.S EPA.

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