Ontario ICI Managers: Compare Waste Audit Routes in Canada

Choose the right waste-audit route

For Ontario industrial, commercial and institutional operations, self-perform when capable staff need an internal baseline, hire an independent professional when objectivity matters, or train staff when recurring audits justify internal capacity.[1][2][5]

BDC-style self-performed audit

• Who performs the work: Company staff equipped to collect, sort and weigh material safely.[1]
• Evidence: A one-week collection of garbage, recycling and compost produces measured internal evidence through sorting, weighing and contamination observations, but not an independent assessment.[1]
• Suited to: Organizations able to conduct periodic audits and implementation reviews with existing personnel.[1]

Independent professional using BOMA Canada guidance

• Who performs the work: A qualified, trained and experienced auditor. BOMA Canada strongly recommends an independent third party.[2]
• Evidence: Third-party involvement supports objectivity and transparency, while representative sampling and annualized analysis can verify service reports or diversion claims.[2]
• Suited to: Sites needing independent evidence, regulation-aligned sampling, annualized analysis or verification of waste-service data.[2]

Circular Innovation Council Waste Auditor Training

• Who performs the work: Internal personnel who complete the training and earn the certificate by passing its in-class and written-exam components with an overall score of at least 70%.[5]
• Evidence: The certificate confirms completion of the training requirements, but audits performed by employees remain internal rather than third-party assessments.[5]
• Suited to: Organizations planning repeat audits, standardizing work across locations or developing internal capacity.[5]

Confirm regulatory applicability before fixing the scope

O. Reg. 102/94 applies to specified activities and premises, not every Ontario business. Its categories include retail premises, office buildings, construction and demolition, restaurants, hotels and motels, hospitals, educational institutions and manufacturing establishments, with category-specific tests and exceptions.[4]

Before commissioning a statutory audit, ask the responsible owner or operator and adviser to document:

• the applicable Part and section of the current regulation;
• the site or project boundary and the person with waste-management responsibility;
• the floor area, accommodation units, enrolment, sales or employment-hour records relevant to the applicable test;
• any exemption, shared-site arrangement or basis for combining locations; and
• the preparation, update, implementation and communication duties that follow.

This is an applicability checklist, not a determination that a particular site is covered. For covered operations, the audit addresses waste quantity, composition, how operational decisions produce it and how it is managed.[4] Agree the scope against the applicable provisions before the supplier starts sampling.

Set a representative audit scope

BOMA Canada describes an audit as collecting, sorting and categorizing waste over representative days, then extrapolating the results over a year.[2] The audit plan should document the site profile, scope, objective, regulatory and acceptance criteria, team, report content, timetable and confidentiality requirements.[2]

Include solid waste from regular site activities and every stream counted in the annual diversion rate. Generally exclude temporary or atypical activities and construction, renovation or demolition waste unless they contribute to that rate; audit atypical waste separately.[2] Avoid July, December, statutory holidays, special events and other periods that do not represent normal operations.[2]

• Track samples: Record the collection date and stream. Recommended bag-level records include collection day, functional location and stream or sub-stream; operational anomalies should also be noted.[2]
• Control collection: Explain instructions to staff and contractors beforehand, and lock or disable outbound containers during sampling.[2]
• Use consistent measurements: BDC’s self-audit method collects one week of garbage, recycling and compost, then sorts and weighs each category and checks recycling contamination.[1]
• Separate hazards: BOMA Canada says hazardous materials require specialized recovery or disposal and should not enter regular disposal receptacles.[2]

Turn measurements into a material baseline

The baseline should document material mass, composition, streams, disposal methods and contamination rather than provide only bag weights and general observations.[2]

Annualize findings from representative sampling days and preserve the assumptions and operational anomalies affecting the calculation.[2] Where more detail is needed, BDC’s method allows results to be segmented by department, operational area or material subcategory.[1] If verification is an audit objective, compare measured findings with annual service reports or diversion claims and explain discrepancies.[2]

The baseline handover should preserve:

• the site profile, collection dates, scope and exclusions;[2]
• sorting categories, streams, measurement units and raw weights;[1][2]
• the annualization method, assumptions, anomalies and limitations;[2]
• contamination findings and disposal methods; and[2]
• sampling records supporting the calculations and conclusions.[2]

Build the waste-reduction work-plan handover

A regulation-aligned work plan follows the order set out in O. Reg. 102/94: reduction first, reuse where reduction is not possible, and recycling where neither reduction nor reuse is possible.[4]

Package the handover as two linked deliverables:

• Material-baseline report: Identify each material or stream, its source area, measured quantity, contamination issue and supporting sampling record.[1][2]
• Implementation register: Record each action, its reduction, reuse or recycling level, the person responsible, implementation timing, expected result and follow-up measure. The regulation calls for the work plan, to the extent reasonable, to identify who will implement each component, when it will happen and the expected results.[4]

Several covered operating categories have annual audit and work-plan updates, implementation and communication provisions.[4] For covered construction and demolition projects, the regulation places preparation of the report and plan before work begins and provides for communication to site workers.[4]

A new owner or operator may update a predecessor’s audit and plan rather than repeat them where the regulatory exception applies. The exception does not extend to builders or demolishers.[4]

Check deliverables before accepting the work

• People: BOMA Canada says the team should understand waste legislation, have appropriate audit training, meet provincial minimum safety requirements and be able to work safely with little or no supervision.[2]
• Evidence: Look for representative sampling dates, defined scope and exclusions, stream and location records, anomalies, raw measurements, annualization assumptions and contamination findings.[1][2]
• Independence: Decide whether internal evidence is sufficient. BOMA Canada strongly recommends an independent third party for objectivity and transparency but does not require one under its guide.[2]
• Actions: Each work-plan component should identify an implementer, timing and expected result and be traceable to the material baseline.[2][4]

What to confirm with each provider

BDC and BOMA Canada provide audit guidance, while Circular Innovation Council provides training; these are different ways to organise the work, not equivalent supplier quotations.[1][2][5] Obtain a current proposal from the actual auditor or training provider for the scope you intend to buy.

• the total quote and what locations, streams, sampling periods and deliverables it covers;
• contract length, cancellation conditions and charges for scope changes;
• auditor qualifications, independence and provider references;
• the format of the baseline, work plan and supporting records;
• support for annual updates, communication and implementation reviews; and
• for corporate training, the price, registration limit, certificate terms and cancellation conditions.

Compare proposals by scope, sampling plan, auditor qualifications and independence, baseline format, work-plan fields, update support and treatment of atypical or hazardous materials.[2][4] Resolve uncertain regulatory coverage before approving the audit brief.

References

1. How to conduct a waste management audit (bdc.ca, 2022)
2. 1 BOMA Canada Waste Auditing Guide Waste Auditing Guiding Principles (bomacanada.ca)
4. Government of Ontario | Gouvernement de l'Ontario (ontario.ca)
5. Waste Auditor Training (circularinnovation.ca)