Where are electronic documents for hazardous waste? Under Ontario’s Regulation 347, waste generators must keep some documents at the waste generation facility, in either physical or electronic form. Physical storage at each waste generation facility may be challenging. Will cloud (or other remote) storage do?Under section 18 of Regulation 347, under the Environmental Protection Act, generators of hazardous waste must retain their generator registration documents, for at least three years at the head office plus retain an electronic copy of the GR at the waste generation facility. Under section 23, waste generators must also retain Copy 2 (Green) of each waste manifest for at least two years at the head office and retain an electronic copy of the manifest at the waste generation facility.
Some Ministry of the Environment inspectors have expressed concern that cloud or remote storage of electronic documents isn’t good enough, because the Internet is sometimes unavailable or servers can be down. The easiest workaround is probably to install a “mirror drive” at the waste generation site, which will automatically download the electronic copies on a regular basis, (perhaps every day?). Has anyone had any problems with that?
with thanks to Meredith James