Topic: Generator

Will the electronic manifest satisfy the TDG requirements for the transport of dangerous goods? 

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.

Will I be able to access the HWP Registry or mobile app in remote areas ( i.e without internet)?

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.

Can you access/use the mobile app without internet?  

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. 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.

What does a receiver do if they receive a shipment in 2023 that has a paper manifest? 

If a receiver receives a shipment with a shipment date in the 2023 calendar year that has an accompanying paper manifest and they have not been notified by the generator or carrier that there is permission to submit paper for that particular shipment, they should contact the generator and/or carrier to explain that the shipment needs to be completed through RPRA’s new Hazardous Waste Program Registry. The paper manifest would not be accepted by the ministry and does not meet the regulatory requirements under the amended Regulation 347: General – Waste Management. Starting January 1, 2023, reporting on waste management activities, including manifesting, is to be completed through RPRA’s new digital registry. 

Note that there may be an exceptional and rare circumstance where a generator has received approval from the ministry to submit paper manifests to the ministry for a time-limited period. The generator or carrier should make the receiver aware of this undue hardship approval. This undue hardship provision is outlined in section 27.1 (1) of Regulation 347 that will take effect January 1, 2023. In this exceptional circumstance, the 2023 shipment can proceed through a paper manifest. 

How do I manage multiple generator facilities in the HWP Registry? 

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. 

What is delegation?

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?

 

 

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

FunctionFull delegationPartial delegation No delegation
Create my own generator registry account and register my own facilities
Register my own wastes
Create my own manifests
Sign my own manifests (including corrections)
Have an AGD register my facilities
Have an AGD register my wastes 
Have 2 or more AGDs register and manage waste at the same facility
Have an AGD or other service provider create my manifests
Have an AGD sign manifests on my behalf (including corrections)
Note: If you fully delegate to a service provider, you will not have to use the HWP Registry

Will all generators be required to use the new Registry?

All information required to be reported under the Hazardous Waste Program and Regulation 347: General – Waste Management will need to be submitted through the new Hazardous Waste Program Registry starting January 1, 2023.

However, the amended Regulation 347: General – Waste Management makes clear that a generator can delegate reporting activities to a service provider, so service providers can submit the required information to the Registry and pay fees on behalf of the generator.

See FAQ: Where can I find information about the Hazardous Waste Program and associated regulations

See FAQ: what is delegation?