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Recycling Council of Ontario. Establishing an Independent Stewardship Program for End-of-Life Pharmaceuticals and Sharps in Ontario. www.rco.on.ca. Agenda. Introduction About the RCO Experience in Development and Operations of Stewardship Programs
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Recycling Council of Ontario Establishing an Independent Stewardship Program for End-of-Life Pharmaceuticals and Sharps in Ontario www.rco.on.ca
Agenda • Introduction • About the RCO • Experience in Development and Operations of Stewardship Programs • Diversion of pharmaceutical and sharps in Ontario today (designation, definitions and program delivery ) • Requirement for an alternate, standalone industry stewardship plan and program (ISP) • ISP approach overview • ISP approach benefits • ISP process • Next Steps
Introduction The Recycling Council of Ontario • Established in 1978 • Initially created to help pioneering operators market recyclable materials • Instrumental in developing Ontario’s innovative “Blue Box” household recycling initiative, earning a United Nations Environmental Leadership award in 1989 • Current key functions: • Bridge between industry and provincial/municipal governments on issues of solid waste diversion • Credible, trusted source of information, resources and expertise • Recognizing and advocating environmental best practices
Introduction The Recycling Council of Ontario • Solid Waste Mandate • Active role to support and develop stewardship policies/programs in Ontario • Facilitate roles and responsibility process in early 1990s, lead to current WDA • Dedicated seat on current WDO, program oversight • Involved in every stewardship program under the WDA • Lead and developed one of only two ISPs approved under the WDA • Launched innovative, markets-placed program for mercury-containing lamps in 2008, (recognized by MOE in MHSW designation letter)
RCO’s Stewardship Experience • CREDIBILITY • RELEVANT EXPERIENCE • SUBJECT MATTER EXPERTS
Designation, definitions and program delivery • Pharmaceuticals and sharps are designated materials under O. Reg. 542/06 (Municipal Hazardous or Special Waste) under the Waste Diversion Act (WDA) • “Stewards include brand owners and first importers of products designated as MHSM for sale and use in Ontario that result in MHSW”
Designation, definitions and program delivery (con’t) • “Brand Owner or First Importer • A person in Ontario who is the owner or licensee of a trademark under which Municipal Hazardous or Special Materials (MHSM) are sold or otherwise distributed in Ontario, whether registered or not, or • A person who brings into Ontario MHSM for sale or other distribution in Ontario” • Diversion through Phase 2 of the Municipal Hazardous/Special Waste program operated by Stewardship Ontario
Cancellation of Phase 2 and 3 MHSW program • Cancelled October 12, 2010 • Steward fees were not yet assessed to stewards before program was cancelled by Ontario Government • Approval of revised MHSW plan (when approved) will include Phase1 but not Phase 2 and 3 materials • Revised Phase 1 plan has been submitted to WDO • Government guarantee of non-municipal costs will end upon approval of revised Phase 1 plan
Cancellation of Phase 2 and 3 MHSW program • Government launched Selected Household Hazardous Waste Initiative (SHHWI) post cancelation • SHHWI will only cover municipal costs of pharmaceuticals and sharps diversion (in the interim) • Bulk of pharmaceuticals and sharps collected from retail not municipalities • 6X increase in containers (sharps), 7X increase (pharmaceuticals), and 2.5X increase in recovered weight from retail (July 2010 to April 2011)
There is strong interest by ENGO, health advocates and the Ministry for a replacement industry led, retail based diversion program for pharmaceuticals and sharps as materials of special concern The RCO has responded to the Minister’s request by working with industry to develop a turn-key Industry Stewardship Plan (ISP) for pharmaceuticals and sharps
Industry Stewardship Plans (ISP) • Alternate approach offering stewards choosing to undertake obligations outside of IFOs a way to set up diversion programs • Industry stewardship plans 34. (1) On application, Waste Diversion Ontario may approve a written plan for the purposes of this section if, (a) the plan relates to a designated waste for which the Minister has approved a waste diversion program under section 26; and (b) Waste Diversion Ontario is satisfied that the plan will achieve objectives that are similar to or better than the objectives of the waste diversion program approved by the Minister. • WDO “Procedures for ISPs” also apply
Industry Stewardship Plans (ISP) benefits • Rather than being forced into an IFO stewards enter into an ISP on mutually agreeable terms • A simple approval process focused entirely on assessing the plan’s ability to: • Deliver diversion performance (recovery and proper recycling or disposal) in accordance with S 34 • Report on diversion performance accurately • Ensure WDO is able to fulfill its responsibilities under Section 5 of WDA • The “fee setting methodology” developed for MHSW Phase 2 is eliminated • Stewards pay into the ISP based on overall diversion cost of their material category prorated against their share of sales
ISP process at a high level • Stewards enter into a written agreement with RCO to become “party” to the ISP • RCO indicates to Government (and WDO) that an ISP for pharmaceuticals and sharps is forthcoming (intent to submit) • Stakeholder Consultation (as required) • Submission of a draft plan • Submission review – Government and WDO • Resubmission if necessary • Approval • Annual reporting
ISP process- required information • Name of ISP proponent and verification of steward participation • ISP Proof of incorporation in Ontario or Canada • The designated material(s) which the ISP will be designed to manage. • What designated material supplied into the marketplace is the ISP proposing to manage • The quantity of the designated material supplied into the marketplace by the obligated stewards • The quantity of the designated material that will be available for collection • The relationship between the quantity available for collection and the quantity of the designated material supplied into the marketplace
ISP process- required information • A description of the waste diversion program, including collection system, transportation, consolidation and processing system • A list of key program participants • A summary of the ISP proponent’s financial and human resources available to implement the ISP and details of any services to be sub-contracted to third party service providers. • The program targets for the first five years of the ISP implementation period and the methods that will be used to measure whether the targets are met.
Next steps • Establish a list of the obligated brand owners and/or first importers on behalf of whom the ISP is being submitted; • Collate from stewards sign letters of intent to participate in the ISP • Develop a contract to be entered into between the RCO and stewards that meets the requirements of Section 34(6) of the Waste Diversion Act4; • Notify WDO of intention to file ISP
Thank You Jo-Anne St. Godard Executive Director 905 586 5866 416 657 2797 ext. 3 joanne@rco.on.ca