Frequently Asked Questions

The amended Regulation 347: General – Waste Management clarifies that generators can delegate a service provider to submit information to the registry on the generator’s behalf. We call this kind of service provider an “authorized generator delegate” or an “AGD”.

If you choose the AGD role in RPRA’s HWP registry, you must have a written delegation agreement with the generator that appointed you their delegate.

Requirements for written authorizations to delegate, are set out in section 7.2 Delegating Registration and Reporting (section 27.2 of Regulation 347) of the ministry’s revised “Registration Guidance Manual for Generators of Liquid Industrial and Hazardous Waste”.

See FAQ: What is the difference between partial and full delegation?

 

 

Full delegation: when generators hire service providers to do all the facility and waste stream management, reporting and fee payment in the registry on their behalf, and they never have to set up accounts or use the registry.  

Partial delegation: when generators want to set up their own account in the registry and pay their own fees, they can still delegate facility and waste stream management and other reporting activities to a service provider.  

Please note delegation is not needed for a service provider to create manifests for your facility. Delegation is needed only for a service provider to help manage a generator’s facility and waste stream information (e.g., register or edit waste streams) or sign off on manifests on the generator’s behalf. 

Comparison of delegation options

If you are interested in learning more about becoming an AGD, please reach out to RPRA at registry@rpra.ca.  

In terms of setting up your registry account, when creating your account in the HWP Registry, on the “Role Selection” page, users will be able to select the role (or roles) that apply to them, including acting as an authorized generator delegate (AGD).  

Prior to creating an account, selecting the AGD role and submitting information to the registry on your clients’ behalf, you will need to have an agreement in place with your client(s). You should communicate with your generator clients about their ability to delegate to a service provider and prepare your staff to answer questions about delegation.  

Requirements for written authorizations to delegate, are set out in the ministry’s revised “Registration Guidance Manual for Generators of Liquid Industrial and Hazardous Waste”  

In the HWP Registry, one company account will be set up to manage all of that company’s facilities.  The company account will have one account administrator and as many additional users as you choose. Each user will have their own username and password.  

Once you create an account for your company, any user associated with the account can setup and manage all facilities under that one account. More information on account types and how to setup an account, will be made available by RPRA closer to November. 

Note: As a generator, if you fully delegate to a service provider (also referred to as an authorized generator delegate or AGD), you will not have to use the HWP Registry. The AGD will set up the facilities that you have fully delegated to them under their AGD account.  

If you partially delegate to a service provider, you will need to set up your registry account yourself, including initial set up of your facilities and associated waste stream information migrated from HWIN. Once you have set up a facility and identified a service provider as a partial AGD through the registry system, the service provider can register and edit your waste stream information on your behalf. 

The mobile app supports offline reporting. The mobile app will be inaccessible if the user has logged out of the mobile app and the user is offline, as you need a network connection to log into the app. However, if the user stays logged into the mobile app, they will be able to use the app offline. It is advised that drivers/users stay logged into the app or log in before going out of an internet zone, to ensure they can always use offline mode. 

Information that is reported through the mobile app while offline will be replicated in the desktop application (once the user has internet connection again) because of the live synchronization between the two platforms. See our demo video that highlights this functionality: https://www.youtube.com/watch?v=0fN2DPzGc9I&t=8s.  

To note: users can stay logged into the mobile app for 72 hours.

In the HWP Registry, users will be able to access, download and print a PDF version of their manifest. RPRA has worked with Transport Canada to ensure the printable PDF complies with the Transportation of Dangerous Goods (TDG) requirements in most cases.   

For more information about your TDG requirements, visit: https://tc.canada.ca/en/dangerous-goods/transportation-dangerous-goods-canada.

Regulation 347: General – Waste Management outlines the requirement for the regulated community to maintain a copy of paper manifests for a period of two years, for manifests that are applicable prior to January 1, 2023. 

No. If a facility is closed and/or will not be generating hazardous or liquid industrial waste in 2023 and beyond, you do not need to register the facilities in the HWP Registry.

Also, data from inactive facilities in HWIN will not be migrated to the HWP Registry.

See FAQ: Will HWIN users’ data be migrated to the HWP Registry?

No. The rules in Regulation 347 related to who is responsible for reporting information about hazardous waste activities are not changing. Although generators can delegate service providers to submit all information on their behalf, the amended regulation makes clear that, “A generator who has entered into an agreement with a delegate through a written authorization remains responsible for meeting their requirements under this Regulation, including requirements to report, update and ensure the accuracy of all information submitted through the Registry.” 

No, RPRA does not have a list of companies. We recommend that generators reach out to their current service providers to ask if they will be providing delegation services.

Fees will be charged to generators only, aligning with the current Hazardous Waste Program fee structure.

If full delegation is selected, the authorized delegate that registers the generator’s facility will pay the fees. 

If a generator has partially delegated to a service provider, the AGD can manage and report activities at the generators’ facilities, but the generator will be responsible for paying the fees. 

See FAQ: Will I pay my fees using a prepaid account like HWIN?  

See FAQ: Is there a fee to set up an account in the HWP Registry? 

No. All secondary users of the account will be able to access all facilities in the account. Once you create an account for your company, any user associated with the account can setup and manage all facilities under that one account. 

The HWP Registry is equipped with a robust search and filter functionality to make it easier for users within the account to locate and manage the facilities they are responsible for

If you are only providing auditing and training services, you are not considered an AGD under the regulation. However, a generator’s account administrator can add you as a user in the HWP Registry where you can access the registrant’s reporting information. This will support your audit, consulting, and training services. You would be an authorized generator delegate if you are doing reporting on the generator’s behalf under the regulation: registering facility or waste stream information or signing manifests as the generator. 

See FAQ: what is delegation?  

Both. You will continue to report your cross-border shipment through CNMTS (Canadian Notification and Movement Tracking System) and will report your Ontario-required information through the HWP Registry. ​ 

Note: you will no longer need to mail copies of your CNMTS manifest to the Ministry of the Environment, Conservation and Parks.  

See sample invoices here. The three examples included in the PDF are:

• Manifest Invoice – Generator Variant (aggregates fees for multiple manifests over a month; includes a facility-level breakdown) 

• Manifest Invoice – AGD Variant (aggregates fees for multiple manifests over a month; includes a company- and facility-level breakdown) 

• On-site Waste Activity Invoice (fees for a single On-site waste activity) 

Manifest invoices will be issued on the first day of each month and will include all manifests completed in the previous month, For example, an invoice issued on February 1 will include completed manifests from January 1 to January 31.  

The primary user of the account will receive an email notification when a manifest invoice is issued. Any primary or secondary user on the account can access and pay an invoice from the Registry homepage.  

While the manifest invoice provides a total fee for each facility, users can see the fee per individual manifest from the Invoices tab in their Registry Account.

The easiest way to find individual manifest fees is directly in the Invoices tab under Manifests with Fees. Users can find individual manifest fees under the Manifests tab, but they’ll have to navigate to the “Closed Manifests” section and then search for and open the manifest itself.

On-site waste activity invoices will be issued when the Registry user completes an on-site waste activity report and submits their payment information.  

See FAQ: What payment methods are available?

The HWP Registry is unable to issue separate invoices for different facilities managed under one account.

Monthly invoices will include the applicable fees for manifests completed during the previous month and will break fees down by facility. If a user is looking for more details about facility-specific activities, they can find that information in the registry.

 

See FAQ: What information is included on an invoice for HWP Registry fees? 
See FAQ: Can I submit a partial payment for only the facilities I manage?

 

The new HWP Registry has been built to allow draft manifests to be easily created in the new system. Facility and waste stream information can be automatically applied to the manifest through easy lookups and tables, using a web browser or the mobile app. Additionally, manifests can be ‘copied’ for reuse when the same or similar shipments happen more than once.

See below materials showing how to initiate manifests.

• Initiating a manifest as an AGD
• Initiating a manifest as a carrier

See here for manifesting a shipment as a receiver

If you deal with a high volume of manifests, you may wish to make use of the Registry’s external API that allows for automatic integration between external systems and the Registry. Contact RPRA_External_API_Support_Team@rpra.ca for more information.

See FAQ: What information is included on an invoice for HWP Registry fees?

See FAQ: Can we set up separate invoices for each facility within one account?
See FAQ: What payment methods are available? 

The HWP Registry is unable to accept partial payments for invoices issued to an account. Monthly invoices will include the applicable fees for all manifests completed during the previous month and will break fees down by facility. Consider an internal business process to bill back each facility as required.

See FAQ: Can we set up separate invoices for each facility within one account? 
See FAQ: What information is included on an invoice for HWP Registry fees?