Ontario Hazardous Waste Rules When You Close a Facility

If you are closing or clearing a facility in Ontario and leftover paints, solvents, oils, coolants, lab chemicals or similar materials are on site, those materials fall under Regulation 347 (General: Waste Management) under the Environmental Protection Act. In most cases the site has to be registered as a generator in the Hazardous Waste Program Registry run by the Resource Productivity and Recovery Authority (RPRA), each shipment needs an electronic manifest, and the waste can only go out with an approved carrier to an approved receiver. Ordinary furniture, racking, cardboard and clean scrap are a separate, much simpler stream.

This explainer is for operations managers, landlords and tenants who are wrapping up a lease, shutting a production line or emptying a building in Toronto, Hamilton, Ottawa, Kitchener, London or anywhere else in the province. It is general information, not legal advice. The regulation and the registry guidance are the final word, and your environmental consultant or the Ministry of the Environment, Conservation and Parks (MECP) should settle any grey areas.

Which materials trigger the rules

Regulation 347 sorts waste into categories. The ones that usually turn up during a commercial or industrial cleanout are:

• Liquid industrial waste: used oil, coolant, wash water from parts washers, and other liquids from industrial or commercial processes.
• Hazardous waste: materials listed in the regulation's schedules or that meet a hazardous characteristic (ignitable, corrosive, reactive, leachate toxic). Leftover solvents, thinners, acids, caustic cleaners, aerosol stock and many lab reagents land here.
• Subject waste: the regulation's umbrella term for hazardous waste and liquid industrial waste together. When people say "this needs a manifest," they almost always mean subject waste.

Things that do not belong to these categories still need proper handling, but not the registry process: office furniture, steel racking, pallets, drywall, carpet, general debris and most electronics (which have their own recycling channels).

The practical takeaway is to inventory chemicals early. A closure that discovers forty unlabeled drums in the last week before handover is the one that runs late and over budget.

Generator registration in the RPRA registry

Since January 1, 2022, the Hazardous Waste Program Registry (often shortened to HWP Registry) has replaced the old HWIN system. A business that generates subject waste at a site registers that site in the registry, lists the waste streams it produces using the waste class and characteristic codes, and pays the applicable fees.

A few points that matter during a closure:

• Registration is per site. If you run three locations and you are closing one, the closing site needs its own active registration to ship its waste.
• Register before the first shipment. A carrier should not pick up subject waste from an unregistered generator site.
• Keep it current until the last load leaves. Some businesses deactivate registrations too early, then find a final pail of something in a mezzanine. Close the registration only after the final manifest is complete.
• Small quantities may be exempt. The regulation has small-quantity provisions, so a site with only a trivial amount of certain wastes may not need to register. Read the thresholds in the regulation and the RPRA guidance rather than assuming.

Manifests, carriers and receivers

Every shipment of subject waste moves under a manifest created in the registry. The manifest follows the waste from the generator, through the carrier, to the receiving facility, and each party confirms its part.

What you need to line up:

1. A licensed waste carrier. The hauler needs an Environmental Compliance Approval (ECA) or equivalent authorization that covers the waste classes it is collecting. Ask for it in writing.
2. An approved receiver. The destination (a transfer station, treatment plant or recycler) also needs approval for those waste classes.
3. Correct classification on the manifest. The waste class and characteristic must match what is actually in the container. Mislabeled drums are a common reason a receiver refuses a load.
4. Transportation of Dangerous Goods compliance. Separate from Regulation 347, federal TDG rules cover packaging, labels, placards and shipping documents when the material is also a dangerous good in transport.

Keep copies of every manifest and the receiver's confirmations. A landlord, lender or buyer may ask for them at handover, and they are your proof that the materials left legally.

Where WHMIS and the Fire Code fit

Hazardous waste rules govern disposal, but the people doing the work are still covered by workplace rules. Under Ontario's Occupational Health and Safety Act and the WHMIS regulation, containers in the workplace need supplier or workplace labels, and safety data sheets must be available. A cleanout crew should not be opening or consolidating unlabeled containers without a plan. Our WHMIS guide for industrial cleanouts covers that side in more detail.

The Ontario Fire Code also limits how flammable and combustible liquids are stored. During a long closure, chemicals often get pushed into corners or staged near exits while the building empties out. Keep them in approved storage until the carrier arrives.

A practical order of operations

For a typical plant, shop or warehouse closure, the work tends to run in this sequence:

1. Walk the site and inventory. List every chemical container, tank, sump, drum and tote, with approximate volumes and whatever labels exist.
2. Characterize unknowns. Unlabeled or mixed materials may need sampling and lab analysis before anyone can classify them.
3. Confirm or update the registry. Make sure the site registration is active and lists every waste stream you are about to ship.
4. Book the carrier and receiver. Schedule pickups early, since specialty receivers can have lead times.
5. Ship and close manifests. Track each manifest until the receiver confirms.
6. Clear the non-hazardous stream. Once chemicals are gone, racking, equipment, furniture and debris can be removed without contamination risk.
7. Document everything. Hand the landlord or new owner a file with manifests, disposal receipts and photos of cleared areas.

Running the hazardous stream first matters. It keeps general debris from being contaminated, and it stops a hauler from refusing a mixed load halfway through.

Common mistakes that cause delays

• Assuming the general junk hauler can take it. Most commercial junk removal companies are not authorized to carry subject waste. Mixing a few pails of solvent into a roll-off bin can turn the whole bin into a problem.
• Waiting until the last two weeks. Characterizing unknowns and booking a specialty receiver takes time.
• Leaving residue in equipment. Hydraulic presses, compressors, parts washers and tanks often hold oil or coolant. Drain them before the equipment is sold, scrapped or hauled.
• Forgetting the paperwork trail. Without manifests, it is hard to show a landlord or buyer that the materials left legally.

Frequently asked questions

Do I need to register with RPRA if I am only closing one site?

Usually yes, if that site generates subject waste above the small-quantity thresholds. Registration is tied to the generator site, not the company as a whole, so the closing site needs an active registration before its waste can be shipped. Check the current RPRA guidance for the exact thresholds that apply.

Can a regular junk removal company take leftover paint and solvents?

Generally not. Subject waste must travel with a carrier holding an approval for those waste classes, under a manifest, to an approved receiver. A general hauler can still handle furniture, racking and debris once the chemicals have been removed separately.

Who is responsible for the waste, the tenant or the landlord?

Regulation 347 places duties on the generator, which is usually the business whose operations produced the waste. Your lease may also assign cleanup obligations at the end of the term, so read the surrender and restoration clauses with your lawyer. Either way, the manifest identifies the generator site and its operator.

How long does a hazardous waste cleanout take?

It depends on volume and how well the materials are labeled. A shop with a short list of labeled containers can often be cleared in a few days once a carrier is booked, while a plant with tanks, sumps and unknown drums may need several weeks for sampling, classification and scheduling.

Get a scope for your Ontario closure

If you are clearing a facility in Toronto, Hamilton or elsewhere in Ontario, send the details through our quote form. We help plan the cleanout sequence, coordinate the general removal work and line up licensed disposal partners for regulated materials, then confirm everything in a written scope.