VERTEX, 3Rs Waste Audits – Is your Ontario Corporation in Compliance?Ontario’s 3Rs Regulations (Ontario Regulation 102/94 [O.Reg. 102/94]) govern non-hazardous solid waste generated from, Industrial, Commercial and Institutional (IC&I) sources.

3Rs (Reduce, Reuse, Recycle) Waste Audits

Since 1994, designated IC&I organizations in Ontario have been required to implement Waste Audits, Waste Reduction Work Plans and Source Separation Programs. Pursuant to O.Reg. 102/94, regulated organizations are required to conduct these audits on an annual basis and report the results to the Ontario Ministry of the Environment and Climate Change (MOECC), and to occupants/staff or the organizations.

Results of the 3Rs waste audits are required to address the following components:

  • Amount, nature and composition of the waste produced in all departments
  • How the wastes are produced including relevant management policies and practices
  • How wastes are currently managed

Waste Reduction Work Plans

After determining what wastes are produced and from which processes, a waste reduction work plan is prepared to provide recommendations for reducing the wastes.

Waste reduction work plans must include the following:

  • A plan for reducing, reusing and recycling waste
  • Identification of who is responsible for the implementation of the plan
  • A schedule for implementation
  • Anticipated results from the waste reduction projects

As part of the implementation, the work plan must be communicated to all staff and a summary of the plan must be posted so that it is clearly visible. The waste reduction work plan must be updated annually.

Waste Reduction Work Plans: Who Must Comply?

  • Retail shopping complexes with floor areas of >10,000m2
  • Class A,B or F hospitals under Ontario Reg 964
  • Schools with >350 students at a location or campus
  • Restaurants with gross annual sales of >$3,000,000
  • Office buildings with floor areas of >10,000m2
  • Hotels and motels with >75 units
  • Building construction projects with floor areas of >2,000m2
  • Building demolition projects with floor areas of >2,000m2
  • Manufacturing sites with 16,000 employee hours/month

Source Separation Programs

An integral part of the source separation program requires that collection, handling and storage facilities must be provided for all recyclable materials.

Site management must make reasonable efforts to ensure that the system is used and that source separated materials are reused or recycled.

Source separation programs must provide the following components:

  • A communications component to promote the program
  • Instructions to staff regarding how to use the program
  • Feedback on how many materials are diverted

Source Separation Programs: Who Must Comply?

  • IC&I establishments in municipalities with populations >5,000
  • Retail shopping complexes with floor areas of >10,000m2
  • Class A, B or F hospitals under Ontario Reg. 964
  • Schools with >350 students at a location or campus
  • Restaurants with annual gross sales of >$3,000,000
  • Office buildings with floor areas >10,000m2
  • Hotels and motels with >75 units
  • Multi-unit residential buildings with 6 or more units

The following IC&I sectors must comply regardless of location:

  • Building construction projects with floor areas of >2,000m2
  • Building demolition projects with floor areas >2,000m2
  • Manufacturing sites with >16,000 employee hours per month

Over the last twelve (12) years, VERTEX Canada (VTX Consulting Services Inc. [VTX]) has noted that several IC&I organizations have adopted corporate strategies to improve sustainability. As part of their internal corporate mandates, these organizations have implemented Ontario’s 3Rs Audit programs on a national level. Although not regulatorily mandated in jurisdictions outside of Ontario, these programs are facilitating improvements in sustainability across Canada.

VTX has provided 3Rs services across Canada.


For more information, please contact Michael Cugino at

VTX Consulting Services Inc. (VTX), a wholly owned subsidiary of The Vertex Companies, Inc., offers first-class Environmental and Waste Reduction solutions, Construction/Surety and Design Engineering services across Canada. Our client base spans commercial, industrial, financial, land development corporations, property management companies, automotive, food industry, and petroleum and petrochemical companies.

VTX is headquartered within the Greater Toronto Area (GTA). We provide unparalleled service within the Province of Ontario and across Canada with technical staff located from coast to coast. Since 2013, VTX has continued to grow its operations, expanding our expertise in all service areas, as we remain committed to achieving the highest levels of service for our clients. 


Michael J. Cugino, P.Geo., QPESA, P.Geol.

Principal Geoscientist, Vice President