Study of Approaches to Define Hazardous Waste and Hazardous Recyclable Material

Hazardous waste (HW) and hazardous recyclable material (HRM) are defined, for the purpose of export or import, under the Export and Import of Hazardous Waste and Hazardous Recyclable Material Regulations (EIHWHRMR). Since the development of these definitions in 1990’s, the types of hazardous wastes and hazardous recyclables exported and imported have changed. The reduced life-span and increase rate of product upgrades means more types of hazardous waste and hazardous recyclable materials are being generated than before. The current definitions under the EIHWHWHR rely on the waste or recyclable material to undertake a disposal or recycling operation(s) and meet of one or more of the following:

a. Listed in Schedule 3 – Hazardous Wastes and Hazardous Recyclable Materials;

b. Included in Transportation of Dangerous Goods Regulations – Classes 2 to 6, 8 or 9;

c. Listed in Schedule 4 – F and K Lists and exhibits a Class 2 to 6, 8 or 9 characteristic;

d. Contains substance listed in Schedule 5 – Environmentally Hazardous Substances at or above specified concentrations;

e. Contains substance listed in Schedule 6 – Leachate Test and Regulated Limits at or above specified concentrations determined in accordance with Method 1311;

f. Listed Schedule 7 – P and U Lists where the substance is pure or is the only active ingredient and is unused; or

g. Defined as hazardous under the legislation of the country receiving it and is prohibited by that country from being imported or conveyed in transit.

The hazard characteristic used to define HW or HRM under the EIHWHRMR mainly rely on criteria defined by the Transportation of Dangerous Goods Regulations which captures immediate dangers during transport. Chronic long-term effects posed by HW and HRM are not necessarily taken into consideration under the current definitions. This review is required to help Canada adapt to evolving domestic and international classification systems for HW and HRM to ensure our definitions are up-to-date with representative hazard characteristics.