The sentence right above the CI 2009 MRc2 chart clearly says: 'Documentation is required for commingled waste only' but this requirement also seems to apply to 'diverted' waste (by further defining 'diverted' as 'comingled'). We did not submit the docs for 'diverted' waste, just for 'comingled' per that sentence. The reviewer took issue with not reporting comingled consiistently. The form seems to auto-define 'diverted' as 'comingled', therefore docs need to be requirred for both diverted and comingled. Has anyone else found this to be the case?
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623 thumbs up
August 20, 2012 - 2:11 pm
John - I interpret the form such that “diverted” is for site separated single stream waste - like metal or cardboard. Whereas I use “commingled” only if the waste was collected commingled on the site and ultimately diverted. You have to provide commingled backup with the completed form to show how the information was reported to you (project specific or annual diversion rate of the facility).
Was you “diverted” waste commingled? If it was, you should have selected “commingled” in the drop down menu instead of “diverted.” The v4.0 version of the MRc2 does not even let you check the Doc Provided checkbox for diverted.
Regardless of the classification, you should always have backup for everything you submit because the reviewers can request verification of your data - even if it does not say so on the form. However, sometimes you have to gently clarify your approach to reviewers.