2. Generator registration process
2.1 How to determine if registration is required
Waste generators need to determine if the wastes they produce or accumulate are subject to Ontario’s registration and reporting requirements. This section of the manual provides a systematic approach to reaching this determination. It also explains how to determine the hazardous waste numbers (if applicable), waste characterizations and corresponding waste class that must be entered on the GRR for each waste stream.
2.1.1 Who is a generator
Regulation 347 defines a generator as the operator of a waste generation facility. A waste generation facility is defined to mean facilities, equipment and operations that are involved in the production, collection, handling and storage of waste at a site. The definition of generator would include operators of commercial and manufacturing facilities that produce wastes, as well as operators of waste disposal, transfer, bulking or processing facilities that forward materials off-site for subsequent waste management.
Certain receivers of subject waste who are not the final destination for the waste (such as a transfer station or processing facility) become waste generators by managing the waste, and therefore, subject to the generator registration and reporting requirements that are outlined in this section. Receivers of non-subject waste may also become waste generators by managing the waste that they receive. For example, municipal hazardous or special waste (MHSW) depots receive waste that is not subject waste from domestic sources, and later ship the collected waste for disposal. As a result, MHSW depots are subject to the province’s generator registration and reporting requirements. These facilities must therefore characterize the waste they collect and ensure that any waste that is either hazardous waste or LIW is appropriately managed.
2.1.2 What is a waste
Wastes are defined in the EPA, and Regulation 347 also designates specific wastes. Waste includes all materials that are normally considered waste — such as ashes, garbage, domestic waste, industrial waste, commercial waste, construction debris and residues from industrial and commercial activities. Economic value is not a reliable indicator of whether or not a material is a waste. For example, while some waste materials are sold for their heating value, or otherwise reused, recycled, recovered or reclaimed — they are still wastes under Ontario law, and must be managed appropriately.
All outputs from waste transfer, bulking, or processing facilities are considered to be wastes. Such outputs include oil that is recovered from oily water treatment facilities, and blended or bulked waste solvents that are destined either for disposal or recycling. Commercial waste chemicals that either are or contain a commercial chemical product or by-product, including those that are off-specification or that have exceeded their expiry date, are also considered to be wastes.
By contrast, by-products or intermediates from a series of traditional metal refining operations, such as mineral or metal recovery, are not considered to be wastes. For example, sludges from an electrolytic recovery process for metals, such as nickel, which are later processed to remove precious metals such as silver, are not considered to be wastes.
Section 2 of Regulation 347 designates a number of materials as waste. Section 3 of Regulation 347 sets out a number of requirements that, when met, exempt certain wastes from the requirements of Part V of the EPA and Regulation 347. However, these materials are still wastes, and must be managed with care.
To ensure that your hazardous waste and LIW are being managed appropriately, you should familiarize yourself with the EPA and Regulation 347 including the Land Disposal Restriction requirements.
2.1.3 Determining when waste is generated
To determine when a waste has been generated, generators need to consider the point at which their process ends. In the case of listed wastes, determining when a waste has been generated can usually be accomplished by following the descriptions of wastes provided in the detailed schedules of Regulation 347. All wastes that meet the descriptions in these schedules are considered to have been generated and must therefore be handled as hazardous wastes. In the case of wastes that are not listed in the schedules, the waste is considered to have been generated after the process is completed — for example, at the end of a manufacturing process, or at the last stage of any process that generates the waste. Once the process has been completed and the wastes have been collected, the generator must classify them properly according to the regulation.
When a material may be a subject waste, but is still in use or in equipment that, by its nature, is designed to capture and hold material until the equipment is serviced, the material is not yet considered to be a subject waste. The material is only a subject waste when the generator removes it from the equipment — for example, when waste oil is collected during the servicing of equipment, or when dust is removed from vacuum equipment or a baghouse.
Regulation 347 requires generators to keep each waste stream separate and to characterize it individually before determining whether or not the wastes can be mixed. For example, if a manufacturing process has three waste streams that exit the system from three different pipes, each of the three waste streams must be characterized to identify whether it is hazardous, and to determine if Ontario’s land disposal restriction (LDR) requirements apply. This must be done before the generator can determine if any of the three waste streams may be mixed or combined into a single collection vessel. Determining whether the LDR requirements apply must occur at the point of generation, to prevent the waste from being diluted and thus avoiding proper treatment.
A generated waste may be characterized as either a hazardous waste or LIW. The characterization depends on the various definitions for hazardous waste and LIW in Regulation 347, and the small quantity exemptions provided for each type of waste. Most wastes become either hazardous waste or LIW when the generator accumulates them in an amount that is equal to or greater than the small quantity exemption (SQE) amount for the waste. The Determining the characterization of your waste stream section provides detailed information about SQE for each type of hazardous waste and LIW.
Depending on the types of wastes generated at a facility, Regulation 347 may restrict generators from mixing and processing them. This is particularly important with wastes that are required to meet the province’s land disposal treatment requirements. Restrictions on mixing of waste with other wastes or materials are discussed in the Managing your waste section.
2.1.4 What is a hazardous waste
Hazardous wastes are wastes that, when present in quantities and concentrations that are high enough, pose a threat to human health or the environment if they are improperly stored, transported, treated or disposed. Accordingly, hazardous wastes require special handling and management. To manage hazardous wastes appropriately, there must be systematic control of how they are collected, stored, transported, treated, recovered and disposed.
Improper management or disposal of hazardous wastes can have a direct or indirect impact on many aspects of the environment, human health and the economy. For example, improper waste disposal practices or leachate from landfills that are not designed to accept these wastes may contaminate ground water and surface water.
While Ontario’s industrial and manufacturing sectors generate most hazardous wastes, the commercial and institutional sectors, as well as individual households, also generate significant quantities of hazardous waste. Most of the hazardous wastes covered by Regulation 347 are identified through a listing and testing approach.
Hazardous wastes include:
- Listed wastes:
- Listed wastes include specific waste streams and wastes from industrial processes, waste chemicals and severely toxic wastes. A listed waste is defined in Regulation 347 as a hazardous waste that is: an acute hazardous waste chemical (Part A of Schedule 2); a hazardous industrial waste (Schedule 1); a hazardous waste chemical (Part B of Schedule 2); or, severely toxic waste (Schedule 3). These schedules of Regulation 347 identify the listed wastes and their associated treatment requirements.
- Characteristic wastes:
- Characteristic wastes are identified through testing. Characteristic waste is defined in Regulation 347 as hazardous waste that is: corrosive waste; ignitable waste; leachate toxic waste; or, reactive waste. Schedule 5 of Regulation 347 identifies the characteristic wastes and their associated treatment requirements.
- Pathological wastes:
- Pathological wastes include human and animal remains and other non-anatomical waste that is infected with a communicable disease. Pathological wastes are included in the biomedical waste definition in Guideline C-4, Management of Biomedical Waste, which provides best management practices to generators, carriers and receivers of biomedical waste.
- PCB wastes:
- PCB waste has the same meaning as in Regulation 362 and includes PCB equipment, PCB liquid or PCB material.
- Radioactive wastes:
- Radioactive waste — except radioisotope wastes that are produced as part of the nuclear fuel cycle and are disposed of in a landfill site in accordance with the written instructions of the Canadian Nuclear Safety Commission, formerly the Atomic Energy Control Board — is considered to be hazardous waste. The Ministry regulates radioactive waste that contains naturally occurring radioactive material on a case-by-case basis. Generators of radioactive waste should contact the Ministry for further information on the appropriate management of waste that contains naturally occurring radioactive material (NORM).
2.1.4.1 The mixture and derived-from rules for hazardous waste
The mixture and derived-from rules apply to listed wastes, pathological wastes and radioactive wastes.
The Mixture Rule — The mixture rule states that a listed waste, pathological waste or radioactive waste that is mixed with any other waste or material retains its waste characterization, even if it is processed at an approved facility, unless the waste ECA for the facility specifically states otherwise. For example, if a hazardous industrial waste listed in Schedule 1 of Regulation 347 (i.e., a listed waste) is mixed with a non-hazardous waste, the mixture is considered to be a listed waste, and must be managed accordingly. The mixture rule is designed to provide an incentive for generators to segregate different waste types, while helping to prevent the dilution of a specified hazardous waste to alter its primary characterization.
The Derived-from Rule — Under the derived-from rule, a waste is considered to be derived from a listed waste, pathological waste or radioactive waste if the waste is blended, stabilized, processed or disposed. A waste that is subject to the derived-from rule therefore retains its hazardous waste characterization even if it is processed at an approved facility, unless the waste ECA for the facility specifically states that the resulting waste no longer retains the original hazardous waste characterization. For example, a listed waste (for example, a Schedule 1 hazardous industrial waste) that has been processed to reduce its toxicity and any residual from the processing are both considered to be listed wastes after they have been treated, and must be disposed of at an approved hazardous waste facility.
The intent of the mixture and derived-from rules is to prevent the mixing or processing of a waste so that it no longer meets the original definition of hazardous waste, without addressing its hazardous constituents. Any waste that is mixed with one of these hazardous wastes retains its waste classification and must continue to be managed appropriately as a hazardous waste. Please note, however, that the mixture and derived-from rules do not apply to PCB waste or characteristic waste.
Regulation 347 also contains provisions for waste generators, carriers and receivers that specifically prevent the mixing blending, bulking or intermingling of hazardous wastes with any other wastes or materials. These activities are permitted only under certain conditions, or if they are authorized by the conditions of a waste ECA. In general, hazardous wastes that are not similar in nature (for example, solids and liquids) and that do not have the same waste number (i.e., the same waste class and waste characterization) cannot be mixed. The Managing your waste section discusses the limitations on mixing that apply to all hazardous wastes in more detail.
The details of these provisions, as they relate to activities that take place at the waste generation site, are presented in Mixing, blending and bulking of hazardous wastes. The provisions identify the conditions under which mixing, blending, bulking or intermingling of hazardous wastes is permitted at the waste generator’s facility. The restrictions are most stringent for wastes that are subject to the LDR requirements. There are also specific provisions for carriers and receivers. Please note that these restrictions apply only to hazardous wastes, and that Regulation 347 does not prevent the mixing, blending, bulking or intermingling of LIW with similar wastes.
Generators should also note that Regulation 347 contains provisions that exclude some wastes from the derived-from rule. These provisions include exemptions specified in the regulation (in Schedules 1.1, 2.1, and 2.2 of Regulation 347), through the formal de-listing process, or through a waste ECA.
2.1.4.2 How to de-list a hazardous listed waste
A generator or receiver can submit an application to the Ministry to de-list or review the status of a listed waste. Most wastes from specific sources are listed because of the toxicity of the waste’s constituents. However, a listed waste may no longer exhibit hazardous characteristics if a facility uses or processes raw materials differently from the industrial processes that were considered when the listing was developed. These exclusions may be approved if the waste does not have characteristics that are similar to the characteristics of the waste from which it was derived.
An application to de-list a hazardous waste that is a listed waste must include the results of comprehensive testing and analysis to demonstrate that the waste does not meet any of the criteria for which it was originally listed, or exhibit other hazardous properties or hazardous constituents at significant levels. De-listing applications are subject to a technical evaluation by the Ministry as well as public consultation. It should be emphasized here that this type of review pertains only to a specific waste from a specific facility. Further details on de-listing can be found in Guideline C-16-1 "Guidance Manual for Hazardous Waste Categorization and Review, Volume B, Guidance Manual for the Review of Wastes Listed in Regulation 347". This guideline also covers the listing process for hazardous wastes.
In certain cases, listed wastes that have been treated may be disposed of in a non-hazardous waste facility, provided that a waste ECA has been issued stating that in the opinion of the issuing Director, the waste that is produced in accordance with the waste ECA does not have characteristics similar to the characteristics of the hazardous waste from which it was derived and provided that the treated waste is also not a characteristic waste. In such cases, the treated listed waste is no longer considered to be a listed waste, since the Director has determined that the derived-from rule does not apply. The determination that a waste is no longer a listed waste is based on the same principles used to de-list a hazardous waste through the regulatory de-listing process.
Listed wastes and characteristic wastes may be subject to the land disposal restrictions. Further information on the LDR program is provided in the Land disposal restrictions of this manual.
2.1.5 Liquid industrial waste (LIW)
LIW are wastes from industrial or commercial sources that are liquid waste, but not hazardous waste. For registration purposes, the criterion for determining whether a waste is liquid is the slump test, which is set out in Schedule 9 of Regulation 347.
While LIW must be registered and reported through the Registry, they are not subject to the same level of regulation as hazardous wastes. For example, the mixture and derived-from rules do not apply to LIW. Moreover, while LIW must be managed at an approved facility, they are not subject to land disposal restrictions. Please see the section on Exemptions for information about exemptions from the definition of LIW.
2.1.6 Special cases
2.1.6.1 Remediation waste
Industrial sites may become contaminated through spills of hazardous waste or product chemicals, or through historical management practices. Wastes that are generated when such sites are being de-contaminated are called remediation wastes.
In general, the strict application of the mixture and derived-from rules is not appropriate for remediation wastes. Typically, the remediation waste generated at contaminated sites is in the form of large quantities of soil or a soil mixture that contain relatively low concentrations of chemicals. Moreover, it is often difficult to determine if a listed waste has contaminated a soil or a soil mixture, because remediation waste is often the product of the historical activities carried out at a facility. Strictly applying the mixture and derived-from rules to a soil or a soil mixture at contaminated sites could result in many tonnes of a soil or a soil mixture being classified as hazardous waste, despite the fact that these wastes generally have low concentrations of chemicals and pose little real threat to health or the environment. In addition, managing a soil or a soil mixture as a listed waste would also act as a significant disincentive to site remediation. For these reasons, a soil or a soil mixture or a debris or a debris mixture generated during remediation activities is normally identified as hazardous waste only if it exhibits a hazardous waste characterization other than the listed waste characterizations.
This approach does not apply, however, to a soil or a soil mixture that is known to have been contaminated by a listed waste due to an immediate spill or other activity. In such cases, the resulting waste must always be managed at a hazardous waste facility, since the derived-from rule applies.
Contaminated soils can present health or environmental risks if they are not properly handled and disposed of, and remediation wastes must be characterized to determine if they exhibit any characteristics of hazardous waste. If a remediation waste is determined to be hazardous, it is subject to the requirements of Regulation 347, including the requirements of the LDR program.
The LDR provisions in Regulation 347 do not apply to contaminated soils during the course of on-site remediation activities. However, the LDR requirements do apply to a soil or a soil mixture when it is managed as a waste, including on-site or off-site land disposal of the waste. See the Land Disposal Treatment Requirements section on soils for more information.
2.1.6.2 Waste that is debris
Debris or a debris mixture can include glass, metal, plastic, brick, concrete, wood and other, similar materials that are produced during site remediation or building demolition. Debris or a debris mixture that is considered to be hazardous waste may be contaminated with either a listed waste or a characteristic waste. As with remediation waste, if debris or a debris mixture is known to have been contaminated by a listed waste, it must be managed in accordance with the rules for the listed waste with which it is contaminated. However, where the source of contamination is due to historical practices at a site, and debris or a debris mixture is not known to have been contaminated by a listed waste, the debris or debris mixture is only considered to be hazardous if it exhibits a hazardous waste characterization other than the listed waste characterizations.
If debris or a debris mixture is a listed waste or a characteristic waste and is being land disposed, it is subject to LDR requirements and must be treated to meet the treatment standards. See the Land Disposal Treatment Requirements section on debris for more information.
2.1.7 Subject waste
Subject waste is a term used to identify the types of wastes that must be registered and reported through the Registry. The movement of these wastes must be tracked through the Registry. Carriers and receivers of subject wastes must meet the requirements of Part V of the EPA, as well as Regulation 347.
Subject waste means hazardous waste, LIW and waste that was characteristic but that has been treated so that it is no longer characteristic waste, if the waste may not be disposed of by land disposal under subsection 79 (1).
Wastes that may be subject wastes include wastes that have been de-characterized so that they no longer exhibit the characteristics of a corrosive waste, ignitable waste, leachate toxic waste, or reactive waste. But these wastes cannot be land disposed because they need further treatment to meet the land disposal treatment requirements for additional regulated constituents that are listed in Schedule 6 of Regulation 347.
As a result, de-characterized wastes that have other regulated constituents at concentrations that are at or above the treatment requirements in Schedule 6 and cannot be land disposed, remain a subject waste, and the generator is required to register it. De-characterized wastes that do not have other regulated constituents, or that have regulated constituents at concentrations that meet the treatment requirements and can therefore be land disposed, are not considered to be subject wastes. As a result, the generator is not required to register these wastes.
Some specific wastes are exempted from the definition of subject waste and are therefore exempt from the registration and reporting requirements that apply to other hazardous wastes and LIWs. The exemptions from the definition of subject waste are discussed in the next section of the manual.
2.2 Exemptions
2.2.1 Exemptions available through definitions, Section 1 of Regulation 347
Regulation 347 contains a number of provisions that exempt certain waste streams from the definitions of hazardous waste, LIW, or subject waste (see Section 1 of Regulation 347 for definitions), or from the sections of the regulation that apply to generator registration and manifesting. Exempted wastes do not have to be registered or manifested. However, while these exempted wastes are not subject to registration and manifesting, they must be managed appropriately, and transported and disposed of by approved carriers and receivers (i.e., companies and facilities that are approved for the type of waste being carried or received). Please note that for hazardous waste and LIW exclusions, the wastes must generally be characterized before it can be determined whether or not they are exempt from registration.
2.2.1.1 Hazardous waste and liquid industrial waste definitions
The definitions of hazardous waste and LIW in Section 1 of Regulation 347 specify that certain wastes are excluded from these definitions. While such materials are still considered to be wastes, the requirements for registration and manifesting do not apply. In some cases, other regulatory requirements must be met in order for a waste to be excluded from a definition.
2.2.1.1.1 Hauled sewage
Hauled sewage, generically referred to as septage, is exempt from the definitions of LIW and hazardous waste. Hauled sewage (also known as septage) refers to waste from portable toilets, holding tanks, septic and aerobic systems that are regulated under Part 8 of the Ontario Building Code (OBC). This exemption applies to waste suitable for storage, treatment or disposal in a sewage system regulated under Part 8 that is not disposed of at the site where it is produced. However, the exemption does not include waste from an OWRA facility where the waste is transferred by a sewer, or waste from a vehicle’s holding tank. Septage haulers are exempt from generator registration. However, they must obtain the appropriate approval for the purposes of transporting the waste. The land application of septage requires a waste disposal site ECA. However, treated septage may also be land-applied under a Non-Agricultural Source Materials (NASM) Plan approved by the Ministry of Agriculture, Food and Rural Affairs and issued under Ontario Regulation 267/03 (General) made under the Nutrient Management Act, 2002.
2.2.1.1.2 Sewage sludge
Wastes from municipally owned sewage works, Crown-owned sewage works or sewage works owned by the Ontario Clean Water Agency (OCWA) under an agreement with a municipality and approved under the OWRA, are also exempt from the definitions of LIW and hazardous waste. Wastes from privately owned sewage works that only receive wastes that are similar in character to domestic sewage, not including industrial sewage, are also exempt. Sewage sludge refers to raw, untreated municipal wastewater solids. Treated sewage sludge is referred to as sewage biosolids, which are nutrient-rich organic materials. Haulers of sewage biosolids are exempt from generator registration.
2.2.1.1.3 Domestic wastes
Household wastes are exempt from the definitions of LIW and hazardous waste. Once a household waste is collected at a MHSW depot, however, the exemption no longer applies if it is characterized as a hazardous waste or LIW, and the waste becomes subject to generator registration and reporting requirements. This exemption applies only to domestic waste from households, and does not include waste from institutions, hotels, motels, etc.
2.2.1.1.4 Incinerator ash
Incinerator ash (bottom ash) resulting from the incineration of waste that is neither hazardous waste nor LIW is exempt from the definition of hazardous waste. Incinerator ash does not include fly ash. Incinerator ash is defined as ash residue that contains less than 10% combustible material by weight.
2.2.1.1.5 Small quantities exemption (SQE)
The regulation provides exemptions for some types of SQE waste under the definitions of LIW and hazardous waste. The exempted quantities vary, depending on the characterization of the specific waste. As a result, the exemption cannot be confirmed until the waste has been evaluated and the primary waste characterization established. Although small quantities of a waste may be considered non-hazardous, and thus exempt from generator registration and reporting requirements, the small quantity is still considered to be waste, and must be transported by an appropriately approved waste carrier and disposed of at an approved facility.
2.2.1.1.6 Empty containers or liners
Depending on the characterization of the material they once contained, empty containers or inner liners may or may not be exempt from registration and manifesting under the definition of hazardous waste. As with SQE waste, the exemption for empty containers or liners cannot be determined until the waste has been evaluated, and the primary waste characterization has been established.
Regulation 347 defines an "empty container" as a container from which wastes and other materials have been removed, using common removal practices such as pumping or pouring, and which contains less than 2.5 centimetres of material on the bottom of the container.
2.2.1.1.7 Exemptions that are specific to LIW
The following wastes are only exempt from the definition of LIW; they do not apply to hazardous wastes.
- Discharges to sanitary sewers
- Wastes or wastewater discharged directly by a generator to a sanitary sewer (either municipally owned or privately owned) that is located at the waste generation site. Please note: The discharge to sanitary sewer exemption does not apply to hazardous wastes
- Wastes that result directly from food processing and preparation operations (Food processing and preparation operations include food packing, food preserving, wine making, cheese making and restaurants)
- Waste from the operation of a water works subject to the OWRA
- Drilling fluids and produced waters associated with the exploration, development or production of crude oil or natural gas
- Processed organic waste (Processed organic waste includes waste that is predominantly organic in composition and has been treated by aerobic or anaerobic digestion, or another means of stabilization, and includes residue from sewage works that are subject to the provisions of OWRA)
- Asbestos waste
2.2.1.2 Subject waste definition
The definition of subject waste in Section 1 of Regulation 347 specifies wastes that are excluded from the definition, which can be found in subsection 1 (3). Wastes that are excluded from the definition of subject waste do not require registration or reporting through the Registry but are still wastes that:
- may still meet the definitions of hazardous waste or LIW
- must be managed or disposed of at an appropriately approved facility
- when transported, must be shipped with an appropriately approved carrier
Please note that some of the exclusions have specific requirements that must be met in order for the waste to be excluded from the definition.
2.2.1.3 Retail motor vehicle service station or service facility wastes
(Please note: This exemption is limited to retail motor vehicle service stations or service facilities that have a valid written agreement for the collection and management of their wastes from the servicing of motor vehicles with a waste management system that has a waste ECA to haul the hazardous waste or LIW off-site.)
Wastes resulting from the servicing of motor vehicles at retail motor vehicle service stations or service facilities are excluded from the definition of subject waste.
A retail motor vehicle service station or servicing facility provides services to the public for any type of motor vehicle (for example, public vehicle). Facilities that meet these requirements may include gasoline service stations, automotive repair garages, car washes and service centres at automobile dealerships, auto body shops that are open to the public, marinas that service boats for the public, and farm equipment dealers that perform retail servicing. Facilities used by organizations to service their own fleet vehicles — such as government, utilities, bus, transport, rent-a-car or heavy equipment companies — do not qualify for the exemption unless they provide retail services as the primary function of their business.
This exemption only applies to subject waste from the servicing of motor vehicles. Such wastes can include used lubricating oil, service station interceptor waste, water pump-out from underground storage tanks, waste batteries, waste antifreeze, liquid waste paints and waste solvents. However, please note that the exemption does not apply to wastes generated by activities that are not associated with the servicing of motor vehicles (for example, site remediation waste).
A Ministry document entitled, "Best Management Practices — Procedures for the Handling and Disposal of Selected Wastes from Retail Motor Vehicle Servicing Facilities (Formerly Guideline C-11-1)," has been developed to address the appropriate management of these wastes. This document provides further information about managing the wastes that are typically generated at these facilities and the details that must be included in the written agreement referred to above.
2.2.1.4 Specifically exempted facilities
Waste from:
- a nursing home as defined under the Nursing Homes Act
- a home as defined under the Homes for the Aged and Rest Homes Act
- a home for special care as defined under the Homes for Special Care Act
- the professional office of a member of the Royal College of Dental Surgeons of Ontario
- the professional office of a member of the College of Physicians and Surgeons of Ontario
The wastes that are excluded from the subject waste definition for the professional office of a member of the Royal College of Dental Surgeons of Ontario and the professional office of a member of the College of Physicians and Surgeons of Ontario are wastes that are solely from a single doctor’s office or single dentist’s office. Wastes that are consolidated from multiple doctors’ or dentists’ offices (for example, professional offices in a medical or dental building) are not excluded from the subject waste definition.
Wastes from the facilities described above that are not subject waste, but are hazardous waste or LIW, must be handled at approved facilities.
2.2.1.5 Intact waste batteries
Damaged, spent, worn out or discarded intact electric batteries that are destined for waste battery recovery facilities are excluded from the definition of subject waste. A "waste battery recovery facility" is a site at which intact waste batteries are received for recovery of battery components and there is no disposal of intact waste batteries or of recovered battery components.
2.2.1.6 Common mercury waste
Common mercury waste that is destined for a common mercury waste recovery facility is excluded from the definition of subject waste.
"Common mercury waste" means:
- electrical switches, thermostats or fluorescent lamps that contain mercury and that are damaged, worn out or discarded
- thermometers, barometers or other measuring devices that contain mercury and that are damaged, worn out or discarded
- discarded material that contains mercury from dental procedures carried out by a member of the Royal College of Dental Surgeons of Ontario
A "common mercury waste recovery facility" is a site at which common mercury waste is received for recovery of mercury and, where there is no disposal of common mercury waste or mercury.
2.2.1.7 Waste electrical and electronic equipment (WEEE)
Intact WEEE that is destined for a site for the recovery of materials is excluded from the definition of subject waste. WEEE has the same meaning as in Ontario Regulation 389/16 (Waste Electrical and Electronic Equipment) made under the Waste Diversion Transition Act, 2016, and includes common items such as televisions, computers, printers and fax machines.
2.2.1.8 Printed circuit boards
Intact waste printed circuit boards that are destined for a site, where they will be processed for the recovery of materials, are excluded from the definition of subject waste.
2.2.1.9 Excess soil that is liquid soil
Excess soil that is liquid soil, unless the liquid soil is hazardous waste, is excluded from the definition of subject waste.
2.2.2 Exemptions from Part V of the EPA and Regulation 347, section 3 of Regulation 347
Section 3 of Regulation 347 identifies wastes that are exempt from Part V of the EPA and Regulation 347. Although these materials are considered to be wastes, they are not subject to generator registration and reporting requirements, as long as they meet the Section 3 requirements. Please note that there are sites that receive these wastes but do not meet the Section 3 requirements. These sites are waste management operations that require a waste ECA, even though some or all of the waste is processed for recovery or reclamation.
The wastes in Section 3 that are exempted from the requirements of both Part V of the EPA and Regulation 347 are listed below. Please note that the full text of Section 3 is not included here, and that this section also addresses wastes that are neither hazardous waste nor LIW. The Section 3 exemptions include:
- agricultural wastes
- inedible material within the meaning of Ontario Regulation 31/05 (Meat) made under the Food Safety and Quality Act, 2001
- any material that is condemned or derived from a carcass at a registered establishment within the meaning of the Meat Inspection Act (Canada)
- dead farm animals within the meaning of Ontario Regulation 106/09 (Disposal of Dead Farm Animals) made under the Nutrient Management Act, 2002 or regulated dead animals within the meaning of Ontario Regulation 105/09 (Disposal of Deadstock) made under the Food Safety and Quality Act, 2001
- inert fill
- rock fill or mill tailings from a mine
With respect to hazardous waste and LIW, the following may be exempt from the requirements of both Part V of the EPA and Regulation 347.
Please note that for certain exemptions to apply, there are documentation requirements that need to be met. These are described under Documentation requirements for specific section 3 exemptions. If you have a waste stream and are unsure if it meets any of the Section 3 recyclable material exemptions, please contact the Ministry for assistance.
2.2.2.1 Generic recyclable material exemption — (covered in paragraph 1 of subsection 3 (2) of Regulation 347)
Municipal waste, hazardous waste or LIW, other than used, shredded or chipped tires, that is transferred by a generator for direct transportation to a site, and that is:
- to be wholly used at a site in an ongoing agricultural, commercial, manufacturing or industrial process or operation that is used principally for functions other than waste management and does not involve combustion or land application of the waste
- neither excess soil, other than excess soil described in subsection 3 (8) of Ontario Regulation 406/19 (On-Site and Excess Soil Management) made under the Act, nor processed organic waste from a composting facility, and the waste is transferred by a generator for direct transportation to a site,
- to be promptly packaged for retail sale, to meet a realistic market demand
- to be offered for retail sale to meet a realistic market demand
In every sense, the waste described above can be used as raw material, and as such is exempt from registration and reporting requirements and all other provisions of Regulation 347 and Part V of the EPA. To qualify for this exemption, the waste must be used completely, either in a process or operation whose function is not waste management or be taken directly for retail sale or prompt packaging before retail sale.
While "wholly" has not been defined, it means that all of the wastes must enter the process or operation. If the waste is used as a substitute for virgin material and is processed in the same unit as virgin material, it is exempt. For example, if lead dross is fed with lead concentrate into a sintering plant before smelting, the waste meets the requirement for this exemption. Minor modifications to the wastes, such as incidental sedimentation in storage tanks where treatment is not intended, may be acceptable. However, major pre-processing (for example, calcining, roasting, sintering) of the waste on its own before it is used is not permissible in this exemption. For example, the breaking of lead acid batteries before the battery lead is fed into a smelter is not exempt.
In most cases, it is possible to determine whether or not the function of a process is for waste management by reviewing the viability of the process if the waste were not available. Processes or operations that are not viable without the incoming wastes are considered to be in the business of waste management. If only waste is being used in the process, and no virgin materials are used, the facility is considered a waste management operation, and therefore requires the appropriate waste ECA. For example, an oily water treatment facility is not viable without oily water. The facility is thus considered to be a waste management facility, and the oily water does not meet the requirements of the exemption described in subsection 3 (2).
By contrast, a metal degreasing operation can continue to operate without waste solvents. The supply of waste solvents is simply an alternative that is substituted for virgin solvents to obtain an economic benefit. Facility operators should be aware that the use of a waste as a substitute reagent (for example, a re-hydrating agent) in a process that is recognized as waste management does not make the waste exempt in accordance with subsection 3 (2).
The difference between ongoing manufacturing operations and waste management activities can also be illustrated through the example of recycling metal-bearing wastes. In the primary metal industry, where ores or concentrates are processed, metal-bearing wastes may be fed into the smelter operation in the same process as the ores or concentrates for metal recovery. In this case, the metal-bearing wastes are considered to meet the requirements of the subsection 3 (2) exemption. However, in the secondary metal industry, where wastes are the only feedstock for the recovery of metal at the facility, the operation is considered to be engaging in waste management. In this case, the metal-bearing wastes do not meet the requirements of the general recyclable material exemption in subsection 3 (2).
Processes that combust waste or apply waste to land are not included in the exemptions described in Section 3, and thus would not meet the recyclable material requirements described above.
Waste that is packaged "as is" without any processing before packaging is considered to be "promptly packaged." If a waste is broadly available for purchase by interested consumers, it is considered to be offered for retail sale. However, this does not mean that the waste is available for purchase by a manufacturer as a raw material.
2.2.2.2 Specific recyclable material exemptions (covered in paragraphs 6 to 13 of subsection 3 (2) of Regulation 347)
- Pickle liquor transferred by a generator for direct transportation to a site at which it is to be wholly utilized as a treatment chemical in:
- a sewage works that is subject to the OWRA
- a sewage works outside Ontario, if the utilization of pickle liquor for this purpose is acceptable to the environmental regulatory authority in the jurisdiction where the sewage works is located, or
- a wastewater treatment facility that discharges into a sanitary sewer
- Solid photographic waste that contains silver, including spent chemical recovery cartridges that contain silver, when the waste is transferred by a generator and destined for a site at which it is to be processed for the recovery of silver.
- Waste paint or waste coatings transferred by a generator and destined for a site at which the waste is to be used in an ongoing manufacturing process for the production of paint or coatings, if the process does not involve combustion of the waste and the paint or coatings that are produced are not used as fuel.
- Emission control dust from the primary production of steel in electric furnaces, if the dust is transferred by a generator for direct transportation to a site at which it is to be used as a feedstock in an ongoing high-temperature metal recovery process in a rotary kiln, flame reactor, electric furnace, plasma arc furnace, slag reactor, industrial furnace or combination of a rotary hearth furnace and electric furnace.
- Spent activated carbon transferred by a generator for direct transportation to a site at which it is to be used in a process to reactivate activated carbon.
- Metal-bearing waste, other than lead acid batteries or aqueous waste, that is transferred by a generator for direct transportation to a smelter at which the waste is to be used as a feedstock in an ongoing operation for the recovery of metal-including waste that, for the purpose of being used as a feedstock, is processed through size reduction, blending, calcining, roasting, sintering, drying, pelletizing, cleaning, leaching or separation of solids from liquids, but not including waste that, for the purpose of being used as a feedstock, is processed in any other manner.
- Printed circuit boards that are waste and that are transferred by a generator and destined for a smelter at which they are to be used as a feedstock in an ongoing operation for the recovery of metal.
- Waste that is to be processed and used at the same site at which it is generated, if:
- neither the processing nor the use of the waste involves combustion or land application of the waste, and
- the waste is not PCB waste, PCB soil or a PCB soil mixture
The specific Section 3 exemptions that are listed above are waste management processes that do not fit the generic recyclable material exemption. However, the Ministry wishes to promote these recycling activities, and when these wastes are managed as described, they are exempt from Part V of the EPA and Regulation 347, including generator registration and reporting requirements.
"Direct" transportation for generic and specific recyclable material exemptions means that the waste must go directly from the generator to the end user. In such cases, no intermediate transfers may take place while the waste is on the way to the recycling site.
By contrast, waste that is "destined" to go to a recycling site for generic and specific recyclable material exemptions means that the waste can go indirectly from the generator to the end user. Intermediate transfers can take place while the waste is en route to the recycling site. However, no processing, except bulking for transporting purposes, may take place at the intermediate sites.
2.2.2.3 Documentation requirements for specific section 3 exemptions
In order to maintain the validity of the exemptions that require direct transportation, the carrier must also comply with Section 3 (3) of Regulation 347. The carrier must have in his or her possession a document from the owner or operator of the site to which the material is being transported, and this document must:
- indicate that the owner or operator of the site agrees to accept the material
- specify the use that will be made of the material, and
- stipulate that the transported material is being shipped to an ongoing process or operation that is currently in operation, if the exemption refers to an ongoing process or operation
For the exemptions that stipulate "destined" to be valid, the above requirements are also required for the carrier and any owner or operator of any transfer station at which the material is collected, handled, stored or transferred before reaching the site to which the material is destined. No processing is permitted at any intermediate site.
2.2.3 Exemption for selected waste depots
Sections 43 through 60 of Regulation 347 provide the regulatory requirements for selected waste depots. If a facility meets the regulatory requirements, it is exempt from generator registration and manifesting, and does not need an ECA for a waste disposal site.
The purpose of a selected waste depot is to provide a location for consumers to return selected wastes to a retail facility for proper management (for example, when "do-it-yourself" oil change waste is returned to a facility that sells oil). Only businesses that sell goods or service motor vehicles as one of their primary functions can set up a selected waste depot to take back wastes generated from selected products that are regularly sold at the business. The depot must be located at the business site and managed by the person who owns or has the charge, management or control of the business. Selected wastes that can be accepted at a depot include waste anti-freeze, waste oil filters, and waste lubricants (crankcase oil, gear oil, transmission fluid and hydraulic fluid).
A business that sets up a selected waste depot in accordance with the regulation must also follow the operating standards set out in the regulation. Meeting the standards allows the selected wastes from the "Do-It-Yourself" consumer and small quantity-exempt generator to be returned to retailers and service stations without waste management system (carrier) requirements for the generator, waste disposal site (receiver) requirements for the depot, and generator registration and manifesting requirements for the depot when the selected wastes are being shipped off-site.
Since these wastes are hazardous waste or LIW, the depot must therefore ensure that these wastes are managed by approved facilities.
Selected Waste Depots must have one or more valid written agreements with a waste management system that has a waste ECA to accept the selected wastes and have them hauled off-site.
An example of a selected waste depot could include a retail business that sells goods to the public, in which anti-freeze and oil products are among those goods. This facility has the option of setting up a selected waste depot on-site that accepts waste anti-freeze and waste oil from consumers. The wastes may be collected on-site, and then sent for appropriate management at an approved facility, using an approved waste hauler.
2.2.4 Exemption for field operations
Sections 29.1 to 29.5 of Regulation 347 provide the regulatory requirements for field operations. Field operations are activities or services that are performed by companies (or a public sector agency) and are part of their regular duties. Wastes that are generated from carrying out these activities or services require proper management. If the activity or service is not performed, the waste would not be generated.
A field operation activity or service must take place away from the company’s normal place of business (i.e., at a "remote site"), either on property owned by the company or on the property of another company that authorizes the activity or service to take place. If a company (or public sector agency) goes to a "remote site" and wishes to manage a waste that has already been generated (i.e., not from the activity or service that is to be performed) then it is not considered a field operation.
The field operations provisions eliminate the need for carrier and transfer station ECA’s in certain special situations. Generator registration and manifest requirements are also removed. In general, wastes generated from a field operation can be transported to a facility referred to as a local waste transfer facility without the need for generator registration at the field site or a manifest to transport the waste from the field site. Neither the carrier nor local waste transfer facility needs to obtain an ECA.
These exemptions are intended for operations that generate waste but are located in places that make it difficult to comply with the waste management requirements previously mentioned. Examples include: locations that are very remote or difficult to access and where, for example, mining and exploratory work takes place; operations that take place away from a permanent site, such as servicing manholes or pole-top transformers; or operations such as carpet cleaning or elevator repair that are performed on behalf of another company but away from the operator’s base of operation.
Field operations are not intended for companies that provide waste management services or for operations that generate waste on-site as part of their normal business. It includes conditions and restrictions that allow companies to consolidate wastes at a specific location, at which the registration, manifesting and waste ECA requirements apply.
In 2022, the Ministry expanded the Regulation 347 definition of “mobile health care” — an activity referenced within the definition of field operations. The amendment allows a variety of health care related activities such as: blood collection, collection of specimens, and administration of vaccines to fall under the field operations exemption. Examples include: blood donation events at libraries or shopping malls or vaccine events held at temporary locations.
2.2.5 Exemption for waste from COVID‑19 antigen point-of-care testing
Section 29.6 of Regulation 347 provides the regulatory requirements for waste generated from undertaking COVID‑19 Antigen Point-of-Care Testing (POCT). Persons who generate waste from administering antigen POCT are exempt from certain regulatory requirements such as registration, manifesting and specific management requirements that apply to the hazardous waste. This applies to all subsequent persons who handle this POCT waste, including those who collect, transport, and store the waste on a temporary basis in Ontario. In addition, facilities that collect, handle, temporarily store, transfer, and transport COVID‑19 testing waste are exempt from the requirement in the EPA to have an environmental compliance approval. (Note: The exemptions only apply to waste generated from antigen POCT kits. They do not apply to other hazardous waste that a facility might generate.)
In addition, these exemptions do not apply to the rules governing the treatment, processing, deposit or disposal of POCT kits. Waste from POCT kits must still be finally disposed of at an authorized hazardous waste disposal site.
Those who are handling COVID‑19 testing waste would be expected to follow ministry guidance on handling, storage, and transportation.
The exemptions found in section 29.6 of the regulation only apply if the COVID‑19 testing waste is destined for final disposal in Ontario at a waste facility that is approved for the treatment and final disposal of hazardous waste. If a person decides to export COVID‑19 testing waste to another jurisdiction, they cannot rely on the section 29.6 exemptions in Regulation 347. They must comply with the normal requirements related to the registration, reporting, manifesting and management of hazardous waste.
2.3 Overview of waste streams requiring generator registration
Generators are required to register subject wastes that are generated at a facility, even if the wastes are not being shipped off-site. Figure 1: Overview of waste streams requiring generator registration identifies the most common waste streams and situations that require registration with the Ministry. The figure is included in the manual to provide an overview of waste management activities that affect generator registration. To determine if your specific waste stream must be registered, you will need to follow the process outlined in Figure 2: Do any exemptions apply to your waste including characterizing the waste and determining whether Ontario’s land disposal restrictions apply.
The final determination of whether you need to register your waste stream is based on the waste characterization, whether the LDR requirements apply and how the waste will ultimately be managed.
A detailed explanation for each of the situations shown in Figure 1: Overview of waste streams requiring generator registration is provided below.
2.3.1 Waste shipped off-site
Any subject waste that is transported off-site must be registered. This requirement includes any subject waste hauled to an off-site waste management facility, wastes that are sent to a facility on the Tonnage Fee Exempt Recycling Facilities Directory, and liquids that are transported to an off-site OWRA-approved facility.
2.3.2 Off-site waste management facilities
A characteristic waste that is subject to the LDR requirements and treated on-site so that it has been de-characterized after treatment but remains a subject waste (i.e., the waste cannot be land disposed because the regulated constituents in Schedule 6 of Regulation 347 do not meet the treatment requirements), must be registered before it is hauled to an off-site waste management facility. A characteristic waste that is subject to the LDR requirements and fully treated on-site (i.e., de-characterized and the regulated constituents in Schedule 6 meet the treatment requirements) is no longer a subject waste and registration is not required when it is hauled off-site for disposal.
2.3.3 On-site processing of listed wastes or characteristic wastes that are subject to LDR
When subject wastes are processed on-site and the processed waste or residual from the waste processing remains a subject waste, the province’s registration requirements apply, and the generator must prepare a waste analysis plan as outlined in Section 85 of Regulation 347.
If the on-site processed waste or residual from the waste processing is not a subject waste, registration is not required, but a waste analysis plan as outlined in Section 85 of Regulation 347 is required, and records must be maintained for LDR purposes. Generators must also provide notification to the receiver to meet the LDR requirements for treated characteristic wastes (i.e., wastes that can be land disposed under Section 79 of Regulation 347) when they are disposed off-site. Please see Section 84 of Regulation 347 and the Notification, Record-Keeping and Waste Analysis Plan Requirements section for further details.
2.3.4 On-site processing of wastes that are not subject to LDR
Wastes that are managed by other on-site processes, such as bulking or blending operations, do not need to be registered prior to processing, if the waste is not subject to land disposal restrictions. However, subject wastes (including any residues) that are subsequently hauled off-site must be registered. Wastes that are bulked or blended and returned to an on-site process operation do not require registration.
2.3.5 On-site waste disposal
All subject wastes that are disposed of at an on-site waste management facility must be registered. Examples of on-site disposal include thermal treatment such as incineration, on-site combustion such as boilers or space heaters, landfilling, landfarming and use of a waste-derived fuel. Any residues that are subject waste must also be registered. Please note that thermal treatment is not considered processing.
2.3.6 OWRA facility (wastewater treatment) — hazardous waste discharges to final stage only
For OWRA facilities (wastewater treatment processes), registration is only required for all of the independent hazardous waste discharges to the final stage of the OWRA facility (wastewater treatment). Wastes discharged to intermediate stages in the overall process do not require registration. Discharges from the final stage of the OWRA facility to a watercourse do not need to be registered. If the waste is subject waste, sludges and skimmed waste from the OWRA facility must be registered.
2.3.7 Discharge to municipal sanitary sewers
Hazardous wastes discharged to a municipal sanitary sewer must be registered. A generator that discharges hazardous wastes into a drain that leads to a municipal sewer must register each hazardous waste being discharged. Laboratory facilities, such as educational, research and quality control laboratories, are required to estimate the types and quantities of hazardous wastes that are disposed of in this manner, and to ensure that they are registered appropriately.
Generators should also note that discharges of hazardous waste to sanitary sewers are permitted only in accordance with municipal by-laws governing sewer use.
2.3.8 Off-site water pollution control plants
All hazardous wastes and LIW hauled off-site to an OWRA-approved Water Pollution Control Plant (WPCP)/ Wastewater Treatment Plant (WWTP) must be registered. By contrast, wastewater discharges from an OWRA-approved WPCP/WWTP to a watercourse do not need to be registered. Similarly, residues that are produced through the treatment process do not need to be registered, provided that a municipality, the Crown or the Ontario Clean Water Agency under an agreement with a municipality, owns the WPCP/WWTP.
2.3.9 On-site storage
All subject wastes must be registered at the point of generation. Therefore, all subject wastes stored more than 90 days at a waste generation facility must be registered.
When a generator registers a waste that is being stored on-site for more than 24 months, an ECA number or the PCB storage site approval number must be provided, as applicable.
Final disposal sites can also be waste generating facilities, if the residues or discharges from the facilities are subject wastes. Any facilities engaging in on-site waste management activities producing wastes (for example, sludges, skimmings, etc.) become generating facilities and the resulting wastes may be subject to registration. Small quantity exemptions may apply to these situations.
2.3.10 Figure 1: Overview of waste streams requiring generator registration
Figure 1 is a graphical representation of the information in the Overview of waste streams requiring generator registration section. To determine if generator registration is required for a specific waste stream, generators should review the How to determine if registration is required section.
Figure notes
- N – No registration required
- Y – Subject waste registration required
- Y+ – Registration is only required if the processed waste or the residual from the processed waste is still subject waste
- Y* – Only hazardous waste registration required
Any of the above on-site waste management activities producing wastes (sludge, skimmings, etc.) become generating facilities and the resulting wastes may be subject to registration based on destination. Small quantity exemptions apply to all of the above situations.
The waste characterization process is outlined in the Determining the characterization of your waste stream section of this manual. After completing this process, you need to determine whether the LDR requirements apply for the purposes of registration (see LDR and other regulatory requirements).
Once you have confirmed that your waste requires registration, you will need to identify the appropriate waste class. Guidance on this process is provided in the Determining the appropriate waste class for the generator’s waste stream section of the manual.
2.4 Determining registration and other regulatory requirements
The Ministry has developed a number of flowcharts to guide generators through the process of determining whether they need to register their waste, and to help them identify other regulatory requirements related to registration. Generators also need to know if the LDR requirements apply to their wastes, since this will have a bearing on the generator registration process. The flowchart below identifies the steps that generators should follow to determine if they need to register their waste, and whether there are other regulatory provisions that require them to provide additional information.
The first step in determining whether registration is required is to determine whether you generate waste, and if so, whether your waste is subject to any registration exemptions or exclusions.
The generation of waste and the legislative and regulatory provisions that may exempt specific wastes from some regulatory requirements (for example, registration) are discussed earlier in this section of the manual. The Exemptions from waste generator registration table below summarizes the exemptions discussed in the section entitled Exemptions along with exemptions from the generator registration requirement through exemptions in the definitions of subject waste, hazardous waste, and LIW.
If you are a generator and your waste qualifies for any of these exemptions, including any associated regulatory requirements that make your waste eligible for the exemption, generator registration is not required. By contrast, if your waste does not meet the exemption requirements, you need to characterize your waste (please see Determining the characterization of your waste stream and Figure 3: Waste characterization flowchart). In the case of both hazardous waste and LIW, you cannot determine whether your waste is exempt from registration under the definitions outlined above until you have characterized the waste.
2.4.1 Figure 2: Do any exemptions apply to your waste
2.4.2 Table 1: Do any exemptions apply to your waste
| Question | Section of Regulation 347 | Requirements |
|---|---|---|
| Do you generate waste? |
|
|
| Is your waste exempt from Part V of the EPA and Regulation 347? |
|
|
| Is your waste excluded from the definition of subject waste? |
|
|
| Is your waste excluded from generator registration by other specific legislative or regulatory provisions? |
Exemptions through the EPA, other Acts, or Regulation 347
|
|
| Is your waste excluded from the definition of hazardous waste? |
|
|
| Is your waste excluded from the definition of liquid industrial waste? |
|
|
2.5 Determining the characterization of your waste stream
This section of the manual is designed to help generators determine if their waste meets the criteria for hazardous waste or LIW. The first step in determining the characterization of your waste is to identify any constituents in the waste that could make it hazardous. This can be done through a combination of testing and applying the generator’s own knowledge of the waste stream, and is discussed in more detail in the Waste analysis requirements section below.
The second step in the process of waste characterization is to determine whether registration is required, as outlined in Figure 3: Waste characterization flowchart. This figure will help you identify those waste characterizations that are primary and those that are secondary.
You should also ensure that you follow the waste characterization flowchart and associated explanations through to completion, to ensure that you have identified all of your subject wastes. At the same time, you will need to identify the appropriate waste class for each of your waste streams. The Determining the appropriate waste class for the generator’s waste stream section provides guidance on choosing the most appropriate waste class for your waste.
Please note that determining the characterization of your waste stream must be done at the point of generation (please see the Determining when waste is generated section for more information). Wastes should not be bulked, blended or mixed in any way until the characterization process has been completed.
2.5.1 Waste analysis requirements
Generators need to have enough knowledge about their waste streams to be able to characterize them accurately, in order to determine whether or not each waste Figure 3: Waste characterization flowchart stream needs to be registered. In some cases, the waste may need to undergo laboratory testing, while in others the generator’s knowledge of the waste may be all that is needed to characterize the waste appropriately. In many cases, a combination of the generator’s knowledge and laboratory testing will be the best approach to characterization.
As a generator, you are responsible for accurately characterizing and registering the waste. Your records are subject to Ministry inspection, and they must demonstrate that the waste analysis you carried out resulted in the waste being characterized appropriately. Generators must maintain at least three (3) years’ worth of records at the waste generation facility showing all data, analysis and other information used to prepare the GRR. Waste analysis does not have to be repeated to characterize the waste unless there is a change to the process or materials used in the process that produces it. As a result, generators should retain their waste analysis and other relevant records for as long as they continue to generate the waste, and for the required period after they cease generating it.
2.5.1.1 Waste characterization using generator knowledge
There are a number of cases where the generator’s knowledge of the waste may be sufficient to characterize the waste stream appropriately. For example, if you know that your waste is a hazardous waste chemical, you do not have to perform an analysis to confirm this.
Similarly, it may not be necessary to test listed wastes in a laboratory. For example, if an industrial process that is identical to the process described in the listing generates a listed waste, analysis may not be necessary to identify the waste stream’s hazardous characteristics. If the waste stream is not a listed waste, information from the Safety Data Sheets (SDS) or laboratory analysis can be used to determine if the waste exhibits any of the characteristics of hazardous waste.
By contrast, in the case of wastes that are subject to LDR requirements, the generator’s knowledge may not be sufficient for characterization. In such cases, additional analysis and assessment may be needed to identify the regulated constituents in the waste that have to be treated.
2.5.1.2 Waste characterization using laboratory analysis
If laboratory testing is needed to characterize your waste stream, you should use your knowledge of the waste to help determine the specific analyses that are needed, since it is only necessary to analyze the waste for constituents that are reasonably expected to be present.
For hazardous industrial wastes, if the production process differs from the process described in the listing in Regulation 347, generators may need to test their waste for additional constituents that may be present. Again, however, the specific analysis carried out should be based on the generator’s knowledge of the process used and the waste being produced. For example, if all of the chemicals used in the industrial process are inorganic, it is not necessary to test the waste for organic compounds.
A similar approach is recommended for characteristic wastes. Depending on the origin of the waste, lab testing may be needed to identify whether the waste is corrosive, ignitable, and/or leachate toxic. The analyses conducted should be based on the generator’s knowledge of the waste stream. For example, when you are analysing for leachate toxicity you should test for contaminants that can reasonably be expected to be present in the waste. With this approach, a complete analysis to identify all the possible contaminants that can cause a waste to be leachate toxic would only be necessary if there was no information on the history or origin of the waste.
2.5.2 Using the waste characterization flowchart
Figure 3: Waste characterization flowchart is designed to help you bring a systematic approach to determining whether or not you need to register your facility and the wastes it produces. This section of the manual contains the explanations that appear throughout the flowchart.
Please note that you need to follow the flowchart in Figure 3: Waste characterization flowchart through to completion for each waste stream, to ensure that you have identified and prioritized all characterizations for a particular waste. If more than one waste characterization applies, the first characterization identified using the flowchart is defined as the primary characterization that you should report for all subject wastes. Any additional characterizations that you identify using the flowchart are defined as secondary characterizations. For wastes that are subject to LDR notification requirements, you must identify all additional secondary characterizations for each waste stream and report them in the LDR notification form of the GRR.
All subject waste generated on-site must be registered, even if it is not shipped off-site. Please note that after a characteristic waste is fully treated to meet the land disposal treatment requirements, it is no longer a subject waste.
Please do not attempt to complete your GRR until you have followed the flowchart through to completion for each waste stream and have read all the relevant explanations.
2.5.3 Figure 3: Waste characterization flowchart
This flowchart is a graphical representation of the information contained in the Determining the characterization of your waste stream section.
2.5.4 Flowchart explanations
2.5.4.1 Explanation 1 — Severely toxic waste
Severely toxic wastes are characterized as wastes that contain one or more of the contaminants listed in Schedule 3 of Regulation 347 at a concentration greater than one part per million. Severely toxic wastes could include pesticides such as 2,4,5-T and pentachlorophenol, but are unlikely to include industrial waste streams. Please note that a mixture of severely toxic waste and any other waste or material remains severely toxic waste.
Similarly, waste that is derived from severely toxic waste remains severely toxic waste unless it is produced in accordance with an ECA that states that, in the opinion of the Director, the waste that is produced in accordance with the ECA does not have characteristics similar to the characteristics of the severely toxic waste from which it was derived.
Please note that there is no SQE for severely toxic wastes, and that empty containers and liners are also considered to be hazardous waste.
If you generate a waste that is severely toxic, you will need to specify the following information on the GRR:
- Waste characterization — Severely toxic (S)
- Waste Class — Select the three-digit waste class number from Appendix A: Ontario waste classes next to the listing that best describes your waste
- Waste Number — Add the letter "S" to the waste class number to specify the above waste characterization, for example, 242S
- Hazardous Waste Number — select the four-character code (a letter followed by three numbers) found in Column 1 of Schedule 3, used to identify individual Severely Toxic wastes (for example, S001)
Please note that severely toxic wastes are subject to LDR treatment requirements before land disposal.
2.5.4.2 Explanation 2 — Pathological waste
Regulation 347 defines pathological waste, in part as follows:
- any part of the human body, including tissues and bodily fluids, but excluding fluids, extracted teeth, hair, nail clippings and the like, that are not infectious
- any part of the carcass of an animal infected with a communicable disease or suspected by a licensed veterinary practitioner to be infected with a communicable disease, or
- non-anatomical waste infected with a communicable disease
If you are in doubt as to whether or not your waste is pathological, you should consult with, for example, a licensed medical practitioner, a veterinary doctor or a bio-safety officer. Please also note that a mixture of a pathological waste and any other waste or material remains pathological waste. Waste that is derived from pathological waste also remains pathological waste, unless it is produced in accordance with an ECA that states that, in the opinion of the Director, the waste that is produced in accordance with the ECA does not have characteristics similar to the characteristics of pathological waste.
Please note that there is no SQE for pathological wastes, and that empty containers and liners are also pathological waste unless they have been incinerated, autoclaved or otherwise sterilized to make them non-infectious.
If you generate a pathological waste, you will need to specify the following information on the GRR:
- Waste characterization — Pathological waste (P)
- Waste Class — Select the three-digit waste class number 312 from Appendix A: Ontario waste classes
- Waste Number — Add the letter "P" to the waste class number to specify the above waste characterization, 312P. Please note that no other combination of waste class and characterization can be used to identify pathological waste
- Hazardous Waste Number — Not Applicable
Pathological wastes are not subject to Ontario’s LDR treatment requirements.
2.5.4.3 Explanation 3 — PCB waste
PCB waste in Regulation 347 has the same meaning as in Regulation 362. In general, PCB wastes are wastes that contain PCBs at concentrations greater than 50 parts per million (ppm) by weight. Please refer to Regulation 362 for further details.
Electrical or other equipment that contains PCBs that is still in service is not considered to be waste, and thus does not require registration. However, if the equipment comes out of service or the PCB liquid is drained from the equipment, registration is required. PCB wastes that are stored on a site, whether or not this is authorized by any other regulation, must be registered.
If you generate PCB wastes or have PCB wastes stored, you will need to specify the following information on the GRR:
- Waste characterization — PCB waste (D)
- Waste Class — Select the three-digit waste class number 243 from Appendix A: Ontario waste classes of this manual
- Waste Number — Add the letter "D" to the waste class number to specify the above waste characterization, 243D. Please note that no other combination of waste class and characterization can be used to identify PCB waste
- Hazardous Waste Number — Not Applicable
Regulation 347 prohibits the land disposal of PCB wastes. Generators should note, however, that wastes containing PCBs that do not meet the definition of PCB waste may exhibit a characteristic of hazardous waste (see leachate toxic wastes).
Generators of PCB wastes must also meet federal reporting requirements for PCBs. Visit Environment and Climate Change Canada’s website for more information on the Canadian Environmental Protection Act Registry.
2.5.4.4 Explanation 4 — Acute hazardous waste chemical and hazardous waste chemical
For wastes that are commercial chemical products or combinations of commercial chemical products, generators must consider Part A of Schedule 2 (acute hazardous waste chemical) and Part B of Schedule 2 (hazardous waste chemical) of Regulation 347.
It is important to note that Part A and Part B of Schedule 2 are lists of products or by-products that are seldom disposed of, but, for whatever reason, become wastes. These are not lists of contaminants that, if present in a waste stream, make the waste stream hazardous.
Acute hazardous waste chemicals or hazardous waste chemicals are commercial chemical products or manufacturing intermediates that are off-specification or otherwise unacceptable for use from time to time. Commercial waste chemicals include materials such as pharmaceutical or pesticide waste products that contain active ingredients in Part A or Part B of Schedule 2. Active ingredients are chemical constituents that have been included in a formulated product for an intended effect. For example, a waste pesticide formulation that includes dieldrin (which is listed in Part A of Schedule 2) as an active ingredient would be classified as an acute hazardous waste chemical.
A mixture of an acute hazardous waste chemical and any other waste or material remains an acute hazardous waste chemical. In the same way, a mixture of a hazardous waste chemical and any other waste or material remains a hazardous waste chemical.
Waste derived from an acute hazardous waste chemical remains an acute hazardous waste chemical — unless it is produced in accordance with an ECA that states that, in the opinion of the Director, the waste that is produced in accordance with the ECA does not have characteristics similar to the characteristics of the acute hazardous waste chemical from which it was derived. Similarly, waste derived from a hazardous waste chemical remains a hazardous waste chemical — unless it is produced in accordance with an ECA that states that, in the opinion of the Director, the waste that is produced in accordance with the ECA does not have characteristics similar to the characteristics of the hazardous waste chemical from which it was derived.
For the wastes listed in Part A of Schedule 2, or wastes that contain active ingredients in Part A of Schedule 2, the small quantity exemption (SQE) is one kg of waste per month. If you generate one kg or more of this type of waste in a one-month period, or accumulate one kg or more at your site over any period, the small quantity exemption does not apply, and you must register the hazardous waste. For example, if your facility generates 0.5 kg per month but accumulates waste for six months before shipping it off-site for disposal, the waste is not eligible for a small quantity exemption, since the total quantity accumulated is greater than the small quantity exemption.
Containers with 20 litres or more of capacity that previously contained products in Part A of Schedule 2 are considered hazardous waste unless they have been triple-rinsed with an appropriate solvent. Inner liners that weigh 10 kg or more and that previously contained products in Part A of Schedule 2 are also considered hazardous waste, unless they have been triple-rinsed with an effective solvent.
Generators should carefully review Part A and Part B of Schedule 2. While there are a number of ways of naming any chemical, the chemical abstracts service registry number (CAS # number) is a unique number assigned to each chemical.
To determine whether a waste chemical is in these schedules, generators should search for the CAS # number, if available. Otherwise, the synonyms for each chemical must be identified and each synonym compared to the schedules, which are arranged alphabetically. For commercial chemical products that are known only by the trade name, generators should contact the supplier to identify the generic name or CAS # number of the active ingredients, so they can be compared with the schedules.
If you generate a waste that is found in Part A of Schedule 2, or that contains active ingredients in Part A of Schedule 2, you will need to specify the following information on the GRR:
- Waste characterization — Acute Hazardous Waste Chemical (A)
- Waste Class — Select the three-digit waste class number from Appendix A: Ontario waste classes next to the listing that best describes your waste. For example, the number could be 148 if the chemical is inorganic, 263 if the chemical is organic, or 261 if the waste is pharmaceutical
- Waste Number — Add the letter "A" to the waste class number to specify the above waste characterization, for example, 148A, 263A or 261A
- Hazardous Waste Number — select the four-character code (a letter followed by three numbers) found in Column 1 of Part A of Schedule 2, which is used to identify individual Acute Hazardous Waste Chemicals (for example, P026)
Acute hazardous waste chemicals are subject to LDR treatment requirements before land disposal.
For wastes listed in Part B of Schedule 2 or wastes containing active ingredients in Part B of Schedule 2, the SQE is five kg of waste per month. If you generate five or more kg of this type of waste in a one-month period, or accumulate five or more kg at your site over any period, the SQE does not apply, and you are required to register the hazardous waste. Empty containers and inner liners that contained products in Part B of Schedule 2 are not considered to be hazardous waste.
If you generate a waste that is found in Part B of Schedule 2 or that contains active ingredients in Part B of Schedule 2, you will need to specify the following information on the GRR:
- Waste characterization — Hazardous waste chemical (B)
- Waste Class — Select the three-digit waste class number from Appendix A: Ontario waste classes, next to the listing that best describes your waste. For example, the number could be 148 if the chemical is inorganic, 263 if the chemical is organic or 261 if the waste is pharmaceutical
- Waste Number — Add the letter "B" to the waste class number to specify the above waste characterization (for example, 148B, 263B or 261B)
- Hazardous Waste Number — select the four-character code (a letter followed by three numbers) found in Column 1 of Part B of Schedule 2, which is used to identify individual Hazardous Waste Chemicals (for example, U021)
Hazardous waste chemicals are subject to LDR treatment requirements before land disposal.
2.5.4.5 Explanation 5 — Hazardous industrial waste
Industrial waste streams that are considered to be hazardous are listed in Schedule 1 of Regulation 347.
A mixture of a hazardous industrial waste and any other waste or material remains a hazardous industrial waste. Waste that is derived from hazardous industrial waste remains hazardous industrial waste — unless it is produced in accordance with an ECA that states that, in the opinion of the Director, the waste that is produced in accordance with the ECA does not have characteristics similar to the characteristics of the hazardous industrial waste from which it was derived.
For hazardous industrial waste, the SQE is five kg per month. If you generate five or more kg in a one-month period, or accumulate five or more kg at your site over any period, the SQE does not apply, and you are required to register the hazardous waste. Empty containers and inner liners that contained wastes listed in Schedule 1 are not considered hazardous wastes.
If you generate a waste that is listed in Schedule 1, you will need to specify the following information on the GRR:
- Waste characterization — Hazardous industrial waste (H)
- Waste Class — Select the three-digit waste class number from Appendix A: Ontario waste classes, next to the listing that best describes your waste
- Waste Number — Add the letter "H" to the waste class number to specify the above waste characterization (for example, 211H)
- Hazardous Waste Number — select the four-character code (a letter followed by three numbers) found in Column 1 of Schedule 1, which is used to identify individual Hazardous Industrial Wastes (for example, F001 or K001)
Hazardous industrial wastes are subject to LDR treatment requirements before land disposal.
2.5.4.6 Explanation 6 — Ignitable waste
Wastes that are ignitable are defined in Regulation 347 by any of four criteria listed below.
- It is a liquid, other than an aqueous solution containing less than 24% alcohol by volume, and has a flash point less than 61° C, as determined by any of the following test methods:
- ASTM D-56-79
- ASTM D-3243-77
- ASTM D-3278-78
- ASTM D-93-79
- as determined by an equivalent test method approved by the Director
- It is a solid and is capable, under standard temperature and pressure, of causing fire due to friction, absorption of moisture, or spontaneous chemical changes, and when ignited burns so vigorously and persistently that it creates a danger.
An example of an ignitable solid waste is sodium metal.
- It is a Class 2.1 Flammable Gas within the meaning of paragraph 2.14(a) of the Transportation of Dangerous Goods Regulations (TDGR) made under the Transportation of Dangerous Goods Act (Canada).
Class 2, Division 1 gases in the TDGR are identified as:
- Class 2.1, Flammable Gases, which consists of gases that, at 20° C and an absolute pressure of 101.3 kPa:
- are ignitable when in a mixture of 13% or less by volume with air, or
- have a flammability range with air of at least 12 percentage points determined in accordance with tests or calculations in ISO 10156
- Class 2.1, Flammable Gases, which consists of gases that, at 20° C and an absolute pressure of 101.3 kPa:
- It is a Class 5.1 Oxidizing Substance within the meaning of paragraphs 2.24(a) of the Transportation of Dangerous Goods Regulations made under the Transportation of Dangerous Goods Act (Canada), or it is a Class 5.2 Organic Peroxide within the meaning of paragraphs 2.24(b) of the Transportation of Dangerous Goods Regulations made under the Transportation of Dangerous Goods Act (Canada). This includes substances such as chlorates, permanganates, and nitrates that readily yield oxygen to stimulate, or contribute to, the combustion of other materials. Substances that contain the bivalent -O-O- structure are also considered to be oxidizers.
To assist in your evaluation, Schedule 1 of TDGR lists a number of oxidizing substances and organic peroxides as Class 5 dangerous goods. These are substances that have a 5.1 or 5.2 designation in column 3 of this list. In the same manner, Schedule 1 of the TDGR lists a number of ignitable and flammable gases as Class 2 dangerous goods. These are substances that have a 2.1 designation in column 3 of this list.
For ignitable wastes the SQE is five kg per month. If you generate five or more kg in a one-month period, or accumulate five or more kg at your site over any period, the SQE does not apply, and you must register the hazardous waste. Empty containers and liners that contained ignitable wastes are not considered to be hazardous waste.
If you generate a waste that is an ignitable waste, you will need to specify the following information on the GRR:
- Waste characterization — Ignitable waste (I)
- Waste Class — Select the three-digit waste class number from Appendix A: Ontario waste classes, next to the listing that best describes your waste
- Waste Number — Add the letter "I" to the waste class number to specify the above waste characterization (for example, 213I)
- Hazardous Waste Number — select the four-character code D001 found in Column 1 of Schedule 5 of Regulation 347, used to identify Ignitable Characteristic wastes
You may also be required to specify the following information on the GRR:
- Underlying Hazardous Constituent (UHC) — select the regulated constituents found in Column 1 of Schedule 6 of Regulation 347 that are present in the waste at the point of generation, if its concentration is at or above the treatment requirement described in the schedule.
Ignitable wastes are subject to land disposal treatment requirements before land disposal. If you process ignitable wastes on-site that will be land disposed, please also see Explanation 10 on de-characterized waste with untreated UHCs.
2.5.4.7 Explanation 7 — Corrosive waste
Wastes that are corrosive are defined in Regulation 347 by any of the three criteria listed below.
- It is aqueous and has a pH less than or equal to 2.0, or greater than or equal to 12.5, as determined by a pH meter.
- It is a liquid and corrodes steel (SAE 1020) at a rate greater than 6.35 millimetres per year at a test temperature of 55° C, using the National Association of Corrosion Engineers (NACE) test method TM-01-69 or an equivalent test approved by the Director.
- It is a solid and, when prepared in a mixture or solution with distilled water that is 50% waste by weight, has a pH less than or equal to 2.0 or greater than or equal to 12.5, as determined by a pH meter — other than:
- solid incinerator ash or fly-ash from a woodwaste combustor site, or
- solid wastes generated by a manufacturer of pulp, paper, recycled paper, corrugated cardboard or other paper products
For corrosive wastes the SQE is five kg per month. If you generate five or more kg in a one-month period, or accumulate five or more kg at your site over any period, the SQE does not apply, and you are required to register the hazardous waste. Empty containers and inner liners that contained corrosive wastes are not considered to be hazardous waste.
If you generate a waste that is a corrosive waste, you will need to specify the following information on the GRR:
- Waste characterization — Corrosive waste (C)
- Waste Class — Select the three-digit waste class number from Appendix A: Ontario waste classes, beside the listing that best describes your waste
- Waste Number — Add the letter "C" to the waste class number to specify the above waste characterization (for example, 111C)
- Hazardous Waste Number — select the four-character code D002 found in Column 1 of Schedule 5 of Regulation 347, which is used to identify Corrosive Characteristic wastes
You may also be required to specify the following information on the GRR:
- Underlying Hazardous Constituent (UHC) — select the regulated constituents found in Column 1 of Schedule 6 of Regulation 347 that are present in the waste at the point of generation, if its concentration is at or above the treatment requirement described in the schedule.
Corrosive wastes are subject to land disposal treatment requirements before land disposal. If you process corrosive wastes on-site that will be land disposed, see also Explanation 10 on de-characterized waste with untreated UHCs.
2.5.4.8 Explanation 8 — Reactive waste
Regulation 347 defines reactive waste as a waste that can exhibit a range of diverse properties. Generally, the intent is to include wastes that are susceptible to violent/vigorous reactions or are likely to generate toxic fumes. A reactive waste is one that meets any of the criteria listed below, which are used to define reactive wastes in Regulation 347:
- it is normally unstable and readily undergoes violent change without detonating
- it reacts violently with water
- it forms potentially explosive mixtures with water
- when mixed with water it generates toxic gases, vapours or fumes in a quantity great enough to present danger to human health or the environment
- it is a cyanide- or sulphide-bearing waste which, when exposed to pH conditions between 2.0 and 12.5, can generate toxic gases, vapours or fumes in a quantity great enough to present danger to human health or the environment
- it is capable of detonation or explosive reaction if it subjected to a strong initiating source or if it is heated under confinement
- it is readily capable of detonation or explosive decomposition or reaction at standard temperature and pressure
- it is a Class 1 Explosive within the meaning of section 2.9 of the Transportation of Dangerous Goods Regulations made under the Transportation of Dangerous Goods Act (Canada)
For reactive wastes the SQE is five kg per month. If you generate five or more kg in a one-month period, or accumulate five or more kg at your site over any period, the SQE does not apply, and you must register the hazardous waste. Empty containers or inner liners that contained reactive wastes are not considered to be hazardous waste.
If you generate a waste that is reactive, you will need to specify the following information on the GRR:
- Waste characterization — Reactive waste (R)
- Waste Class — Select the three-digit waste class number from Appendix A: Ontario waste classes, next to the listing that best describes your waste
- Waste Number — Add the letter "R" to the waste class number to specify the above waste characterization (for example, 263R)
- Hazardous Waste Number — select the four-character code D003 found in Column 1 of Schedule 5 of Regulation 347, which is used to identify Reactive Characteristic wastes
You may also be required to specify the following information on the GRR:
- Underlying Hazardous Constituent (UHC) — select the regulated constituents found in Column 1 of Schedule 6 of Regulation 347 that are present in the waste at the point of generation, if its concentration is at or above the treatment requirement outlined in the schedule.
Reactive wastes are subject to land disposal treatment requirements before land disposal. If you process reactive wastes on-site that will be land disposed, please also see Explanation 10 on de-characterized waste with untreated UHCs.
2.5.4.9 Explanation 9 — Leachate toxic waste
Leachate toxic waste means a waste that produces leachate that contains any of the contaminants listed in Schedule 4 of Regulation 347 — if these contaminants are at a concentration that is equal to or in excess of the concentration specified for that contaminant in Schedule 4, using the Toxicity Characteristic Leaching Procedure (TCLP). This characterization, as described by the TCLP, applies to both liquid and solid wastes, and includes multi-phase wastes. This test identifies the leachability of hazardous constituents, and is used to determine if a waste is hazardous.
The determination of leachate toxicity is not limited to wastes that will be land disposed. Leachate toxicity describes a characterization of hazardous waste, and may apply to any kind of waste, regardless of how it will be disposed. The term "leachate toxic" should not be confused with leachate that is produced at a landfill site.
For leachate toxic wastes the SQE is five kg of waste per month. If you generate five or more kg in a one-month period, or accumulate five or more kg at your site over any period, the SQE does not apply, and you are required to register the hazardous waste. Empty containers and inner liners that contained leachate toxic wastes are not considered to be hazardous waste.
If you generate a waste that is leachate toxic waste, you will need to specify the following information on the GRR:
- Waste characterization — Leachate toxic waste (T)
- Waste Class — Select the three-digit waste class number from Appendix A: Ontario waste classes, beside the listing that best describes your waste
- Waste Number — Add the letter "T" to the waste class number to specify the above waste characterization (for example, 131T)
- Hazardous Waste Number — select the four-character code (a letter followed by three numbers) found in Column 1 of Schedule 5 of Regulation 347, which is used to identify individual Leachate Toxic wastes (for example, D004)
You may also be required to specify the following information on the GRR:
- Underlying Hazardous Constituent (UHC) — select the regulated constituents found in Column 1 of Schedule 6 of Regulation 347 that are present in the waste at the point of generation, if its concentration is at or above the treatment requirement outlined in the schedule.
Leachate toxic wastes are subject to land disposal treatment requirements before land disposal. If you process leachate toxic wastes on-site that will be land disposed, please also see Explanation 10 on de-characterized waste with untreated UHCs.
2.5.4.10 Explanation 10 — De-characterized waste with untreated UHCs
On or after December 31, 2009, subject waste includes waste that was characteristic waste but that has been treated so that it is no longer characteristic waste, but does not meet the LDR treatment requirements in subsection 79 (1) of Regulation 347. Typically, this is waste that has been treated to remove the hazardous characteristic but that still requires further treatment of regulated constituents to meet the land disposal treatment requirements in Schedule 6 of Regulation 347. De-characterized wastes that will be land disposed and have UHCs that do not meet the Schedule 6 standards must be registered and manifested when they are shipped off-site. See the LDR and Other Regulatory Requirements section for more information.
If a characteristic waste has been treated so that it is no longer hazardous but does not meet the land disposal treatment requirements in subsection 79 (1) (i.e., additional regulated constituents from Schedule 6 still require treatment), the waste must be registered if it is shipped off-site. The waste characterization that has been created for these de-characterized wastes is U. This waste characterization applies once the Schedule 6 treatment standards take effect, on December 31, 2009.
If you generate a waste that is de-characterized, you will need to specify the following information on the GRR:
- Waste characterization — De-characterized Waste with Untreated UHCs (U)
- Waste Class — Select the three-digit waste class number from Appendix A: Ontario waste classes, beside the listing that best describes your waste
- Waste Number — Add the letter "U" to the waste class number to specify the above waste characterization (for example, 113U)
- Hazardous Waste Number — select the four-character code (a letter followed by three numbers) found in Column 1 of Schedule 5 of Regulation 347, which is used to identify individual Characteristic wastes (for example, D001 or E001). The original hazardous waste number for the untreated characteristic waste should be used
- Underlying Hazardous Constituent (UHC) — select the regulated constituents found in Column 1 of Schedule 6 that are present in the waste at the point of generation, if its concentration is at or above the treatment requirement
Fully treated characteristic wastes that are not subject to LDR requirements do not need to be registered.
2.5.4.11 Explanation 11 — Hazardous waste
If a waste exhibits any of the waste characterizations discussed in explanations 1 through 9, it is considered to be a hazardous waste and is therefore subject to generator registration and manifesting provisions. Listed and characteristic wastes (explanations 1 and 4 through 9) are also subject to LDR requirements if they are to be land disposed. See the LDR and Other Regulatory Requirements section for more information.
The first characterization identified in the flow chart is defined as the primary waste characterization for the waste, and this is used to identify the appropriate waste class for the purposes of registration. However, all additional secondary characterizations must also be identified. For wastes that are subject to LDR notification requirements, all characterizations must be identified for each waste stream, and reported in the LDR notification form of the GRR .
If you generate a characteristic waste (explanations 6 through 9) that is being processed on-site, the waste may remain a subject waste after processing if the waste will be land disposed. Please see Explanation 10 for further information.
Where it is desirable to manage a number of wastes with different primary characterizations as a single load, the combined load is referred to as a "lab pack." Further information about lab packs can be found in Lab Packs section of this manual.
A number of explanations refer to waste that is derived from waste with a specified characterization. A waste subject to the derived-from rule retains its waste characterization, even if it is processed at an approved facility — unless the ECA for the facility specifically states that the resulting waste no longer retains the original hazardous characterization. A number of explanations also indicate that waste that is mixed with any other waste or material retains its original hazardous characterization. The mixture and derived-from rules are discussed in the mixture and derived-from rules for hazardous waste section.
There are additional limitations on the mixing of hazardous wastes with other wastes or materials, particularly for wastes that are subject to LDR. The conditions under which mixing of hazardous wastes can occur at a waste generation facility without an ECA are outlined in the Regulatory Requirements section. Hazardous waste exemptions are discussed in the Exemptions section.
2.5.4.12 Explanation 12 — Liquid industrial waste
LIW are also subject to generator registration and manifesting provisions. These wastes include any liquid waste from industrial, commercial, manufacturing, research or experimental activities. Liquid wastes include wastes that are obvious liquids, such as spent acid solutions, as well as those sludges that fail the slump test included in Schedule 9 of Regulation 347.
The slump test involves placing the waste in question in a 30&bsp;cm open inverted cone. The cone is removed and the immediate decrease (slump) in the height of the waste material is measured. If the material slumps so that the original height is reduced by 15 cm or more, the waste is a liquid. Please refer to Regulation 347 for further details.
For LIW, the SQE is 25 litres per month. If you generate 25 or more litres in a one-month period, or accumulate 25 or more litres at your site over any period, the SQE does not apply, and you are required to register the LIW.
If you generate a LIW, you are required to specify the following information on the GRR:
- Waste characterization — Liquid industrial waste (L)
- Waste Class — Select the three-digit waste class number from Appendix A: Ontario waste classes, beside the listing that best describes your waste
- Waste Number — Add the letter "L" to the waste class number to specify the above waste characterization (for example, 121L)
- Hazardous Waste Number — Not Applicable
LIW is not subject to LDR requirements. LIW exemptions are discussed in the Hazardous Waste and Liquid Industrial Waste Definitions section. These exemptions are listed in the definition of LIW in Section 1 of Regulation 347. If your waste is not any of the hazardous waste characterizations and is also not a LIW waste, then it is not a subject waste.
2.6 LDR and other regulatory requirements
Once you have characterized your waste and determined that it must be registered, you also need to determine if Ontario’s land disposal restrictions apply. How you register your subject wastes (for example, characteristic waste) depends on whether the land disposal treatment requirements apply, and whether you must provide additional information during the registration process.
Appendix F: Declaration of wastes subject to land disposal restrictions provides a series of questions that when answered, will help you determine if you are required to provide additional information by filling out the LDR Notification portion of the GRR. Note: If you register a waste with a characterization of L, P or D you are not required to answer any of these questions. These questions will help you determine whether your waste is subject to LDR.
If your facility is a MHSW depot, you should refer to section 9.5.2 Wastes from municipal hazardous or special waste (MHSW) depots for more information. Figure 7: Declaration of waste streams subject to land disposal restrictions is included in the manual, and this flowchart includes the special situation of MHSW depots.
Appendix F: Declaration of wastes subject to land disposal restrictions will help you determine whether the LDR requirements apply. Once the determination is made, proceed to either Figure 4: Registration and other regulatory requirements: Wastes mot subject to the LDR program or Figure 5: Registration and other regulatory requirements: Wastes subject to the LDR program. These flowcharts are provided to help you identify the registration and other regulatory requirements for your waste. In some cases, you may determine that your waste does not need to be registered (for example, for characteristic wastes processed on-site, registration is not required if both the processed waste and residual are not subject wastes). Please note that processing does not include disposal (for example, OWRA treatment, incineration, waste-derived fuel), nor does it include mixing, blending or bulking that does not result in any treatment of the waste.
Once you have identified which waste streams need to be registered, the Determining the appropriate waste class for the generator’s waste stream section provides information to help you determine the appropriate waste class, which is needed when you are registering your waste. Please see section 10.1 Managing your waste for further information on managing your hazardous wastes and the regulatory requirements associated with different waste management methods.
2.6.1 Figure 4: Registration and other regulatory requirements: Wastes not subject to the LDR program
This flowchart is a graphical representation of the information immediately below.
You must have completed the Determining the characterization of your waste stream section for each waste generated at the facility and identified whether the LDR program requirements apply to your waste before completing the Figure 4 flowchart. If the waste is subject to LDR program requirements, go to Figure 5: Registration and other regulatory requirements: wastes subject to the LDR program.
2.6.2 Registration and other regulatory requirements: Wastes not subject to the LDR program (text version)
You must have completed the Determining the Characterization of Your Waste Stream section for each waste generated at the facility and identified whether the LDR program requirements apply to your waste before completing the steps described below. If the waste is subject to LDR program requirements, go to Figure 5: Registration and other regulatory requirements: Wastes subject to the LDR program.
Step 1. Is your waste processed on-site? This does not include mixing, blending or bulking where no treatment is involved or disposal through OWRA facilities, thermal treatment or waste-derived fuel sites. If yes, go to Step 2. If no, skip to Step 3.
Step 2. Is the processed waste or residual a subject waste? Note that if you process a listed waste, the processed waste and residuals must be registered as listed wastes. If no, registration is not required. If yes, go to Step 3.
Step 3. Register the subject waste. (See Figure 6a and Figure 6b: How to complete the intended waste management portion of the waste generator registration process on how to register.) Go to Step 4.
Step 4. Will your waste be disposed off-site? If no, there are no manifest requirements. Where applicable, must meet other requirements (for example, ECA, municipal by-laws etc). If yes, manifesting of off-site waste shipments is required. (See Sections. 19 and 23 through 26 of Regulation 347 and section 6 Manifesting.)
2.6.3 Figure 5: Registration and other regulatory requirements: Wastes subject to the LDR program
This flowchart is a graphical representation of the information immediately below.
You must have completed the waste characterization flowchart (Figure 3) for each waste generated at the facility and identified whether the LDR program requirements may apply to your waste before completing the Figure 5 flowchart.
2.6.4 Registration and other regulatory requirements: Wastes subject to the LDR program (text version)
You must have completed the waste characterization flowchart (Figure 3) for each waste generated at the facility and identified whether the LDR program requirements may apply to your waste.
Step 1. Does your site meet the requirements as a small quantity generator? (See section 80 of Regulation 347 and section 9.5.1 Wastes from a small quantity generator (SQG) . Note that a small quantity generator is a facility that generates a total of less than 100 kg/month of hazardous wastes and the wastes do not have the characterization of A or S. If yes, generator registration is required but the information contained in the LDR Notification Form is not required. LDR treatment is not required but LDR container and certification requirements must be met. If no, go to Step 2.
Step 2. All hazardous characterizations and associated hazardous waste numbers must be identified at this point. Regulated constituents must also be identified at this point. (See section 9.4 Land disposal treatment requirements for the land disposal treatment requirements.) Go to Step 3.
Step 3. Will the waste be processed on-site? Note that this does not include mixing, blending or bulking where no treatment is involved or disposal through OWRA facilities, thermal treatment or waste-derived fuel sites. If no, register the subject waste. Note that waste cannot be land disposed until land disposal treatment requirements have been met. If yes, proceed to Step 4.
- Manifesting of off-site waste shipments required. (See sections 19 & 23 through 26 of Regulation 347 and section 6 Manifesting.
- LDR Notification required for off-site waste shipments. Maintain records for LDR purposes. (See section 84 of Regulation 347 and section 9.8 Notification, Record-Keeping and Waste Analysis Plan Requirements.
Step 4. Waste analysis plan (WAP) is required. (See section 85 of Regulation 347 and section 9.8.2 Waste analysis plan requirements . Proceed to Step 5.
Step 5. Is the processed waste or residual from the processing a subject waste? If yes, register the waste that entered the process and the processed and residual wastes that are subject waste. If no, registration is not required. LDR Notification is required for treated characteristic wastes disposed off-site. Maintain records for LDR purposes. (See section 84 of Regulation 347 and section 9.8 Notification, record-keeping and waste analysis plan requirements.
2.7 Determining the appropriate waste class for the generator’s waste stream
In Ontario, the waste class is a three-digit number. Each number is assigned to a generic waste description that is used to classify the type of waste being managed. Ontario waste classes are a vital component of registration and manifesting. The waste classes are included in an ECA for waste carriers or receivers, to identify the waste streams they are permitted to handle or manage. The various waste classes can be found in Appendix A: Ontario waste classes.
A very large number of different waste streams are generated in Ontario each year. The Ministry has consolidated these streams into a total of 53 waste classes. These waste classes are divided into three major categories: inorganic wastes, organic wastes and other wastes. In turn, these three major categories are further subdivided into minor groups that describe the waste types or similar waste groupings. Finally, there are three-digit waste classes within each minor group — classes that describe wastes that are similar in composition, physical properties and generation source.
Please note that the waste class is not used to indicate the hazard associated with the waste. However, the hazard associated with the waste may help you to determine the appropriate waste class of the waste(s) in your waste stream.
This section of the manual provides a description of each waste class, along with examples of appropriate waste streams. The examples are intended to guide you in deciding on identifying an appropriate waste class for your waste, but they are not intended to be exhaustive lists of all the potential waste streams included for each waste class. In cases where the examples provided do not clearly represent a given waste stream, you should use the waste description to choose the appropriate waste class.
As a waste generator, you are responsible for assessing the waste(s) you produce and for complying with Ontario’s registration and related waste management requirements.
2.7.1 Choosing a waste class by major or minor category
When selecting an appropriate waste class, it is often easiest to begin by determining the major category that represents the waste stream, followed by the appropriate minor category, before you select the most reasonable waste class. In some cases, however, this approach may not always result in the selection of the most appropriate waste class. To determine the most appropriate waste description, you can use the minor or major category that best describes the waste. If you have any doubt about the appropriate waste class, you should base your waste class selection on the description that best fits your waste. The following example illustrates how this approach works.
Example: A spent alkaline battery may be classified as either 122 (alkaline solutions, sludges and residues containing other metals and non-metals, not containing cyanides) or as 146 (other specified inorganic sludges, slurries and solids). If the spent battery is being registered due to the corrosivity that results from high alkalinity, then the appropriate waste class is 122, since this falls under the minor category of alkaline solutions. If the spent battery is not being registered due to its alkaline nature, then the appropriate waste class may be 146.
2.7.2 Choosing a waste class by using the description of the waste stream
In some instances, a specific waste class accurately describes a waste stream, but the waste stream does not appear to belong under the major or minor category. In such cases, you should still choose the waste class that best describes the waste stream, even though the major or minor category may not seem appropriate. The waste class that best describes the waste stream should always be chosen.
Example: Waste oil-based paint is an organic waste stream. However, it is most accurately described by the inorganic waste class 145 (wastes from the use of paints, pigments and coatings).
2.7.3 Choosing a waste class by using the "main component" rule
Where two or more waste classes could reasonably be used to describe the waste stream, the waste class that appears to be the most relevant should be chosen. You may encounter this situation where your waste stream contains components that, if they were separate, would have resulted in you choosing a different waste class for each component.
Similarly, a situation could arise where a waste stream could be described differently according to its individual components, rather than to how it was generated. The applicable waste class is usually selected based on the largest component or group of components that are present in the waste stream that share the same waste class, rather than on the most hazardous contaminant present. If you have any doubt about the appropriate waste class, you should base your waste class selection on the description that best fits your waste.
Example: A waste stream contains 75% crankcase oil, 15% water, 5% dirt and solids, and 5% gasoline. The appropriate waste class for this mixture is 252 (waste crankcase oils and lubricants) because the greatest proportion of the waste (75%) falls under this class. Although gasoline likely has the most hazardous waste characterization, waste class 221 (light fuels — gasoline, kerosene, diesel) would not be chosen because it does not reflect the main component of this waste stream.
Notable exceptions to this "main component" rule are the waste classes 241, 242, 243, 312 and 321, which are special cases and are addressed separately below. Aqueous wastes and contaminated solid wastes can also pose problems when applying the "main component" rule. For example, most acid, alkaline and aqueous salt solutions are composed largely of water. This aqueous composition is an important consideration and should not be disregarded when choosing the appropriate waste class for these types of wastes. Normally, water and non-hazardous solids are disregarded when considering components of a waste, unless these are an integral part of the waste description. These special cases are discussed in the following sections.
2.7.3.1 Special waste classes
There are several waste classes that are unique, in that relatively small amounts of a particular contaminant in the waste stream dictate the appropriate waste class. These special waste classes are:
- 241 — halogenated solvents and residues
- 242 — halogenated pesticides and herbicides
- 243 — polychlorinated biphenyls (PCBs)
- 312 — pathological wastes
- 321 — wastes from the manufacture of explosives and detonation products
Waste class 241 (halogenated solvents and residues) should be selected whenever a waste stream contains a minimum of 2% of halogenated organic materials by weight.
Waste class 242 (halogenated pesticides and herbicides) should be used whenever a waste stream is contaminated with halogenated pesticides and herbicides at a level great enough that its hazardous primary characterization results from the presence of these contaminants.
Waste classes 243 and 312 are similar, in that they must both be selected based on the primary characterization of the waste. Any waste that has a primary hazardous characterization identified as PCB waste (D) must also have the associated waste class of 243. The same applies for a primary hazardous characterization of pathological waste (P) and the waste class of 312. The waste numbers 243D and 312P are fixed, and no other waste class may be used with the waste characterizations D and P for PCB and pathological wastes.
A similar situation occurs with waste class 321. Any wastes that are not federally regulated under the Explosives Act (Canada), and that result from the manufacture of explosives and detonation products characterized as reactive (this is the Ontario waste characterization for explosive wastes) are automatically classified as 321R. Unlike the situation for 243D and 312P, however, the characterization of reactive can be used in conjunction with other waste streams.
2.7.3.2 Contaminated solids
Although the "main component" rule can generally be used to determine waste class numbers, one significant area where the rule cannot be easily applied involves solids that are normally non-hazardous, but that have become contaminated, for example, from a spill, leak, deliberate mixing or accident.
Wastes that do not need to be registered, such as non-hazardous solids including soils, sand, rubble, rock, glass and wood do not normally require a waste class number. However, when these non-hazardous solid wastes become contaminated with a subject waste, they may require a waste class number. In such cases, the primary waste characterization of the contaminant that made the material hazardous is used to determine the appropriate waste class.
To determine the waste class for contaminated solids, the degree of contamination is also important. If there is sufficient contamination, the entire waste may have the same primary waste characterization as the contaminant and may therefore have the same waste class as the contaminant.
Example: Soil becomes contaminated with diesel fuel. The diesel fuel is an ignitable waste (I) identified as waste class 221. If the waste soil is tested and found to be ignitable, it would be classified as an ignitable waste (I). In this case, its waste class should also be 221, like the diesel fuel.
If the primary waste characterization of the solid waste differs from that of its contaminant, waste class 146 (other specified inorganic sludges, slurries and solids) or 270 (other specified organic sludges, slurries and solids should be used to classify the solid waste. There are several reasons for a difference in primary waste characterization, including situations where a solid that was initially non-hazardous becomes contaminated through some previous exposure to an unknown contaminant.
Example: Soil becomes contaminated with diesel fuel. The diesel fuel is ignitable waste (I) having the waste class 221. If the soil is found to be leachate toxic waste (T) due to the presence of inorganic contaminants in the diesel fuel ignitable waste (I), then it should be identified as waste class 146, which is the general waste class for inorganic solids, because the soil does not share the same characterization as the fuel that contaminated it.
2.7.3.3 Aqueous wastes
The "main component" rule is also relevant where waste streams contain mostly water. Many of these wastes are appropriately classified using one of the "aqueous waste" classes. These include acid solutions (111-114), alkaline solutions (121-123), aqueous salts (131-135), landfill leachate (149) and inert inorganic wastes (150).
For other wastes that are not specifically included in one of these "aqueous waste" classes, you can apply the "main component" rule to help determine the waste class. However, in these cases, the aqueous portion of the waste should be ignored, and the waste should be classified based on the remaining composition of the waste. Thus an aqueous waste could have the waste class of an organic waste.
Example: An underground gasoline storage tank is contaminated with water. While most of the waste is made up of water, this constituent can be ignored, since it is not a hazardous component. The waste is therefore considered to be waste gasoline and identified as waste class 221.
2.7.4 Combining wastes into a single waste stream
To classify your waste stream appropriately, it is important to determine if the various wastes in the stream need to be registered individually as separate waste streams, or if they can be combined and registered as a single waste stream. This is not always an easy task. Any mixture of wastes, even if they form a multi-phase mixture, must be considered as a single waste stream for registration purposes. At the same time, however, wastes should only be mixed, blended or bulked under certain conditions.
To determine if a waste can be mixed, blended or bulked with other wastes, you must first identify the type of wastes that are being generated. Each waste must be characterized at the point of generation to identify whether it is hazardous, what type of hazardous waste it is, and whether it is subject to the LDR requirements. At this point you can determine whether each of the wastes can be mixed, blended or bulked with any other waste.
When the wastes are physically separate, each waste generated can be considered and managed as an individual waste stream. However, the Ministry recognizes that generators need some flexibility when registering their waste streams, especially when the wastes are generated from the same or similar operations, such as waste lubricants from various machinery and wastewaters from various cleaning/rinsing operations. Such wastes may contain similar (though chemically different) components, and can reasonably be considered as one waste stream and mixed together. However, mixing similar wastes for the purpose of classification should not be confused with mixing them for the purposes of treatment or dilution.
Here are some considerations that can help you determine when wastes may be mixed, blended or bulked or may be separately managed:
- Do the wastes have the same waste class?
- Are the waste characterizations the same for each waste?
- Are the composition and physical state of the wastes similar?
- Can the wastes be managed using the same processing or disposal method?
- Have the wastes been generated from similar operations?
If the answer to any of the first four considerations above was "NO," it probably means that the waste streams should not be mixed. Please see the Managing Your Waste section for more information about on-site processing of waste and mixing restrictions. A review of the mixing restrictions is particularly important for generators that have waste that will be land disposed.
2.7.5 Lab packs
"Lab packs" represent something of a special situation that does not follow any of the "standard" waste classification rules. The term "lab pack" was originally applied to small quantities of miscellaneous chemicals that were generated in a laboratory. Today, lab packs involve registering multiple wastes that are packaged together — using only two waste classes — 148 and 263. These waste classes are used for all lab-packed wastes, even though individual wastes in the lab pack may be more appropriately registered with other waste classes.
To use the lab pack designation, each of the wastes must be kept segregated in its own separate container inside the lab pack. These individual wastes are then "over-packed" and shipped for disposal. Individual wastes should not be bulked before disposal, both for safety reasons and because mixing may not be permitted, due to restrictions on mixing of hazardous wastes with other wastes or materials (Please see the Managing Your Waste section for more information).
The original intent of lab packs was to reduce the administrative effort and time required to register and manifest a multitude of wastes whose total quantity was relatively small. The use of lab packs has since been expanded to include larger quantities of each waste stream, and to accommodate situations other than those found in laboratories — such as plant closings, inventory clean-ups, research and development areas, and municipal hazardous or special waste collections. Any situation where many chemicals need to be registered but are only present in relatively small quantities may warrant the use of the "lab pack" registration.
When registering and shipping lab packs, the waste characterization used should represent the "worst" waste that is included in the lab pack (i.e., the first waste characterization identified when following Figure 3: Waste characterization flowchart). For example, a lab pack may contain individual containers of hazardous wastes with waste characterizations such as I, B, C, T, and A. In this case, the lab packed waste would be registered with a waste characterization of "A" since this is the first waste characterization identified in the flowchart.
Generators must be aware of restrictions that apply to larger quantities of specific waste streams or larger total lab packs shipped for disposal. In particular, quantity and waste type restrictions apply to small quantity generators whose waste is subject to land disposal restrictions.
2.7.5.1 Lab packs and generators with small quantity exempt (SQE) waste
In general, small quantity exempt (SQE) generators are not required to register or manifest their waste. However, if a generator uses a lab pack for SQE waste, the Ministry recommends that the generator register and classify the lab packs using waste classes 148 or 263. The registration should include the worst waste characterization for the wastes that are included in the lab pack, and the waste should be manifested on shipment to a certified carrier and receiver. The generator should identify the hazardous waste number that is appropriate for the most hazardous waste in the lab pack when registering.
2.7.5.2 Lab packs and small quantity generators (SQGs)
Lab packs that come from a small quantity generator (SQG) and also meet the requirements of Section 80 of Regulation 347 (a properly labelled, sealed container) are not subject to LDR treatment requirements. In such cases, the Ministry recommends that generators register and classify the lab pack as 148 or 263, identifying the worst waste characterization for the wastes in the lab pack and manifesting when shipping off site. Since the SQG exemption from meeting the LDR treatment standards does not apply to acute hazardous waste chemicals or severely toxic wastes, these wastes cannot be added to the lab pack, and must be dealt with separately. Generators should enter the hazardous waste number that is appropriate for the most hazardous waste in the lab pack in their registration.
2.7.5.3 Lab packs and large quantity generators
Generators that have wastes that are subject to LDR, but do not meet the quantity requirements for Section 80 SQG provisions, or that have acute hazardous waste chemicals or severely toxic wastes, may still use lab packs to package their wastes. These lab-packed wastes are subject to all LDR requirements. Those requirements include reporting the hazardous waste number and applicable regulated constituent for each hazardous waste in the lab pack in the LDR notification form as primary and additional characterizations. Lab packs may be registered and classified as 148A, 263A or 242S, and manifested on shipment.
Please note that providing the information requested in the LDR Notification Form is a one-time notification requirement. Updates will be required if additional waste with different hazardous waste numbers are placed in the lab pack. For generators, the advantage of using lab packs is that one waste stream can be registered for all the different wastes, rather than registering each separate waste stream.
2.7.5.4 Lab packs that are not land disposed
For lab packs that will not be land disposed, the lab packs may be registered and classified as 148A or 263A and manifested on shipment. Generators should use the hazardous waste number appropriate for the most hazardous waste in the pack.
2.8 Determining waste streams at waste receiving sites
Determining and registering waste classes for waste streams is handled somewhat differently at waste receiving facilities such as waste transfer stations, waste processing sites and MHSW depots than at the facility where the wastes were originally generated. Since the receiving facilities can handle such a wide variety of wastes, and since their list of registered waste streams can become somewhat lengthy, a broader definition of "waste stream" may be used in accordance with the facility’s ECA. While the receiving site still needs to register for each waste stream it accepts, the description of each waste stream can be more generic, allowing several different incoming waste streams with the same waste class to be included under the same outgoing waste stream registration.
For example, a facility may receive a number of different wastes, all identified by the waste class 113. Although these wastes may be from different processes at different facilities, the wastes may be bulked together and processed, or shipped off-site as a single waste stream, provided that they all fit within the 113 waste class and have similar characterizations, composition and treatment or disposal requirements.
For receiving facilities, an important consideration when registering waste streams is to determine if the wastes are compatible, both chemically and in terms of the required treatment method. Where wastes are chemically compatible, share treatment requirements, and have the same waste class, they may be registered as a single waste stream. If the wastes have different waste classes, they can only be mixed and registered as a single waste stream if this is specifically allowed for those waste streams through the facility’s ECA.
Restrictions on the mixing, blending, bulking and intermingling of hazardous wastes with other wastes or materials became effective in March 2006. As a result, the ECA for waste disposal sites and waste transportation systems must specifically authorize these operations to mix hazardous wastes with any other waste or material.
Another consideration for receiving facilities is the ability to use special consolidated waste stream classifications. The use of these special waste classes by waste receiving sites recognizes that certain waste streams may be routinely bulked or blended together, either for processing or to improve handling efficiencies, before the waste is shipped off-site for common treatment or disposal. The following four waste classes have been created to allow for such waste bulking: 254, 270, 281 and 282. Please note that the ability to bulk different waste streams must be recognized in the site’s ECA.