As the conversations about the importance of environmental protection become more popular, regulators are often making changes and updating the policies and regulations surrounding environmental laws in Ontario.  For instance, the Registration Guidance Manuel for Generators of Liquid Industrial and Hazardous Waste has been recently updated in conjunction with regulatory changes.  As of January 1, 2023, hazardous waste generators, carriers, and receivers must now register any liquid industrial or hazardous wastes through the Resource Productivity & Recovery Authority’s (RPRA) online Hazardous Waste Program (HWP) Registry as opposed to registering through the Ministry of the Environment, Conservation and Parks (MECP) Hazardous Waste Information Network (HWIN) [1].  The RPRA online Hazardous Waste Program Registry is replacing the MECPs HWIN system.  The new online registry allows the MECP to shift from paper-based reporting to online tracking for the storage, transportation, recycling, recovery, and disposal of liquid industrial and hazardous wastes in Ontario [2].

 

Previously, HWIN was used by the MECP to allow businesses to register their hazardous waste activities online.  Although HWIN is currently still available to businesses for paying fees or completing reporting associated with 2022 waste activities, all hazardous waste generated, stored, transported, recycled, recovered, or disposed of in 2023 must be registered with the new HWP Registry.  The HWP Registry includes an online reporting portal and electronic manifesting solution, including a mobile app [3].  The HWP Registry allows for an updated filing system and new interface that ensures the MECP can accurately and effectively track hazardous waste generation and businesses can easily ensure they remain compliant with the MECP.
 

Any business that produces hazardous wastes must register with the HWP Registry.  Registerable wastes include waste chemicals, oils, pesticides, solvents, and fuels.  All wastes registerable with HWIN have remained the same under the new registry [3].  Additionally, the MECP remains responsible for ensuring compliance and any enforcement actions [1]. 

 

All generators must create an account with the new HWP Registry to complete activities associated with hazardous waste generation.  These activities include completing a Generator Registration Report, being listed on a manifest, creating, editing, or signing manifests, and reporting on-site waste activities [4]. 

 

We understand that the primary focus for your business is your business and that sometimes it is challenging to find the time to completely understand the continuous changes being made to laws and regulations.  Understanding how to register hazardous wastes with the new platform may be confusing to businesses, so we have identified any important information below to help you better understand and use the new system.

 

Are you a generator of hazardous waste?

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According to the RPRA, a generator is the operator of a waste generation facility, including the initial generator of the waste and all the subsequent generators involved in the waste’s chain of custody [4].  If your facility produces any hazardous wastes, including the registerable wastes identified above and any registerable wastes identified by the MECP, you are a generator.  Furthermore, this includes transfer stations, as transfer stations generate waste being shipped from their facility.  Many businesses generate some type of registerable waste through their operations, and waste classes can sometimes be difficult to identify.  Click this link to see a full list of Ontario waste classes to see if your business falls under any of these categories.

 

Are you a carrier or receiver of hazardous waste?

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According to the RPRA, a carrier of hazardous waste is the operator of a waste transportation system [4].  This involves any party who is involved in the off-site transportation of waste [4].  According to the RPRA, a receiver of hazardous waste is the operator of any facility where waste is collected via a carrier [4].  Receivers of hazardous wastes include transfer stations, processing facilities, and final disposal sites [4].

 

What does this mean for generators?

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As a generator, this update means that you will need to register with the new HWP Registry to generate and dispose of hazardous wastes in 2023.  However, if you use a service provider to report your hazardous waste on your behalf, you will not need to register yourself as your service provider would have registered you under their Authorized Generator Delegate (AGD) account [4].  Any invoices will be sent to your service provider.  Additionally, you can partially delegate to a service provider.  This works such that you will have to create your own account with the new HWP Registry, and all invoices will directly be sent to you; however, your AGD can manage and report any of your hazardous waste activities [4].

 

To register for an account with the new HWP Registry, visit RPRA’s website.  Once you have created your account, you will be able to transfer any account data from HWIN to the HWP Registry [4].

 

How does this change impact S2S?

 

Based on the MECP’s move from HWIN to the HWP Registry, S2S will need to ensure that any data collected within the new registry is reviewed appropriately to identify current hazardous waste generators for Phase I Environmental Site Assessments.  S2S’s plan is to review the HWP Registry in the same manner that the MECP’s HWIN was reviewed. 

 

S2S staff are always adjusting to the changing landscape of the environmental sector, and for large changes such as the new HWS Registry, S2S diligently trains staff to ensure that we continue to provide the highest quality reports for our clients.

 

Updating the method in which the MECP tracks hazardous waste from a paper system to an electronic system will be beneficial in helping the MECP keep more accurate and accessible records for the generation, transportation, and disposal of liquid industrial and hazardous wastes in Ontario.  To learn more about this update and what steps your company needs to take to register the generation of hazardous waste, you can visit RPRA’s website.