The OWMA has responded to the Environment and Climate Change Canada (ECCC) consultation opportunity relative to the Discussion Document on Proposed Regulatory Changes and Administrative and Compliance Costs for Business (find here). The association is supportive of consolidating the three regulations into one. While the document and proposed regulatory approaches (find here) are largely conceptual in nature a cursory review also has identified specific concerns with the proposed five year data retention period, Expansion of captured materials, costs and coordination of electronic document requirements between the regulation and provincial regulations.