Ontario’s Ministry of Environment, Conservation and Parks (MECP) is proposing to exempt certain waste management systems that involve asbestos waste, biomedical waste, hazardous waste, liquid industrial waste, and treated waste that can not be disposed of by land. It would also exempt certain stormwater management activities, water-taking for construction sites dewatering activities, and foundation drains. Streamlining would involve updating existing operational requirements, and by moving additional waste types and activities to the existing Environmental Activity and Sector Registry (EASR).


The proposed changes will streamline the approval process for waste management systems by expanding the existing eligibility criteria under Ontario Regulation 351/12 to include waste management systems that manage the following wastes:

  • Asbestos waste as defined in Regulation 347.
  • Biomedical waste as defined in the ministry publication “Guideline C-4: The Management of Biomedical Waste in Ontario.”
  • Treated biomedical as defined in the ministry publication Guideline C-4: The Management of Biomedical Waste in Ontario.
  • Hazardous waste as defined in Regulation 347.
  • Liquid industrial waste as defined in Regulation 347.
  • Waste that was characteristic waste but that has been treated so that it is no longer characteristic waste. if the waste may not be disposed of by land disposal pursuant to subsection 79 (1) of Regulation 347.

The proposal would also expand the list of waste activities to include:

  • in-transit storage of waste based on waste types and operations.

Information Sessions

The MECP is holding a number of information sessions that include a presentation on the entire proposal. Waste/stakeholder specific sessions will also include a more focused discussion on the operational needs unique to that waste type or stakeholder group.

The event is free but tickets must be obtained through eventbrite. The MECP suggests you select your ticket based on the session you wish to attend:

Session 1: October 12, 10:00 am – 12:00 pm

  • General stakeholder consultation session

Session 2: October 18, 10:00 am – 12:00 pm

  • Existing EASR Registrants, Hauled Sewage & Non-Hazardous waste

Session 3: October 19, 10:00 am – 12:00 pm

  • Liquid industrial, Hazardous (including NORM, PCB) waste (manifesting)

Session 4: October 26, 10:00 am – 12:00 pm

  • Biomedical waste

The proposal is open on the EBR ER until October 30 for a 60-day public review and comment period.

Comments can be formally submitted by visiting the ERO posting above, or by email to permissions.modernization@ontario.ca. Your feedback will be considered to inform how the ministry will move forward on this proposal.

Opposition to the Proposal

The Canadian Environmental Law Association is against the proposed exemptions for the following reasons:

  • There would no longer be an upfront review by Ministry staff to assess the potential environmental impacts of the specified operations
  • Public participation and appeal rights under the Environmental Bill of Rights would no longer apply.
  • The proposed activities would no longer be subject to either government or public scrutiny prior to commencing operation in Ontario.

CELA is hosting a free webinar on Tuesday, October 17th at 1:00 pm ET. CELA encourages concerned citizens to register and learn more about these alarming proposals, and the implications they could have for our communities.