Manage Your Site's Unique Challenges, Protect Human Health and the Environment, and Reduce Cost
In some instances, completing a remediation to Ministry of the Environment and Climate Change (MOECC) generic standards becomes practically impossible, either due to prohibitive costs or practical challenges that cannot be overcome. When this becomes apparent on a project, risk assessment is another option to allow site goals to be met.
By following the approach used in the MOECC generic criteria, an owner can develop site-specific criteria that is accepted by the MOECC for use at the site. These criteria are equally protective of human health and the environment and also allows the owner to be protected by meeting the appropriate standard of care, and indemnification from the MOECC upon acknowledgement of a risk-based Record of Site Condition (RSC).
About Environmental, Groundwater, and Soil Risk Assessments
Risk assessment calculates the probability that a hazard (like environmental contamination in the soil or groundwater) will cause harm to humans, plants, wildlife and the natural environment under specific conditions of exposure to a contaminant. The purpose of a risk assessment is to develop property-specific standards that will protect the uses that are being proposed for the property, so it is important to consider the client’s end use goals when choosing risk assessment options.
The Groundwater & Soil Risk Assessment Process
The QP initially prepares information on the property and how people would be exposed to contaminants. Human health risk assessment (HHRA) is the evaluation of the risk of adverse health effects to humans caused by exposure to a contaminant at a given property. Ecological risk assessment (ERA) evaluates the risk that adverse ecological effects may occur as a result of exposure to contaminant(s). Many contaminants may be present together in different media such as food, air, water, soil and dust. These contaminants reach receptors through multiple exposure pathways such as ingestion, dermal contact in inhalation.
This information is submitted and reviewed by the Ministry of Environment and Climate Change (MOECC) using a Pre-Submission Form (PSF). This review allows the Ministry to comment on the scope and approach of the RA. This helps the property owner to decide the best way to proceed with completing the RA and if any additional investigations are required prior to undertaking the RA. A PSF can save the owner time and money!
An owner can submit a Modified Generic Risk Assessment (MGRA) or Tier 2 Risk Assessment (RA). The MOECC has developed an “Approved Model” which allows users to modify some of the generic assumptions used in creating the standards. The MOECC’s review time for a MGRA is approximately eight weeks. This approach is intended to be timelier and more cost effective. The “Approved Model” can result in less stringent standards while maintaining the same target level of protection as a generic standard.
The Approved Model can be used in either a MGRA (Tier 2 RA) or a full (Tier 3) RA. For an RA to be considered an MGRA, the RA must have used only the Approved Model and used only RM measures as stipulated in the model. For a full Tier 3 RA, the approval times range from 4 months to 18 months (excluding external delays). There is also a Streamlined Tier 3 RA. This is a hybrid approach which incorporates many aspects of the Modified Generic RA but deviates from the MGRA in areas such as exposure limits and the derivation of property-specific standards other than those produced by the Approved Model. The use of this approach is acceptable by the MOECC but its application should be reviewed with the MOECC’s Streamlined Risk Assessment Coordinator prior to submission. This approach has a timeline typically longer than a MGRA but much shorter than a full Tier 3 RA.
The MOECC will review the completed RA and will decide to accept or reject the risk assessment. If the risk assessment is not accepted, the property owner can revise the risk assessment and resubmit it or choose to remediate the site to generic standards.
RA Risk Management Measures
Risk assessment can often lead to recommendations to manage risks in order to provide protection to human health and the environment. Risk management is a process to control or reduce the level of risk estimated by the risk assessment. Risk management integrates the results from the other components of risk assessment with information about technical resources, socio-economic factors and control options in order to reach decisions about the best way to manage a property.
The MOECC may issue a certificate of property use (CPU) to ensure that over time the property owner maintains the risk management measures and may even ensure the CPU is registered on the title to the property. Local stakeholders may be consulted when considering risk management measures.
In summary, the risk assessment process can be complex, but is also very worthwhile when used appropriately. If you have questions about whether an RA is right for your property, contact us.