Records of Site Condition are the regulatory documents used in Ontario to confirm whether a potentially or actually contaminated site meets acceptable standards for a particular land-use, under the Environmental Protection Act and O.Reg. 153/04.
The Ministry of Environment and Climate Change has issued a Records of Site Condition-Getting them right, a list of the most common errors that they are finding when consultants and owners attempt to submit Records of Site Condition. Hopefully, regular use of the list as a checklist will help to reduce these errors moving forward, and possibly reduce the frustratingly lengthy delays in having RSCs accepted for filing.
Submitting Records of Site Condition – Getting it Right the First Time
This document deals with some common pitfalls to avoid when making a record of site condition (RSC) submission. The article focuses on issues with RSC submissions themselves, rather than on details of the underlying scientific environmental site assessment (ESA) work. ESA reports are not part of the RSC submission, except for conceptual site models. It is important to note that most of the legislative requirements deal with ESA work. This article assumes familiarity with the relevant part of the Environmental Protection Act (Part XV.1) and with Ontario Regulation 153/04 (Records of Site Condition – Part XV.1 of the Act), (the Regulation). Readers unfamiliar with this legislation may wish to refer to the “Background Information About Records of Site Condition” at the end of the article as well as O.Reg. 153/04 and the Environmental Protection Act via www.ontario.ca/laws.