Who should the public trust to do environmental site assessments? The Ministry of the Environment (MOE) proposes to sharply cut down the list of “Qualified Persons”, on the assumption that only Professional Engineers and Geoscientists have both qualifications and professional regulatory bodies to ensure their competence.
This argument seems to be falling apart. We don’t know of any case where Professional Engineers Ontario (PEO) has disciplined one of its members for a negligent environmental site assessment. But perhaps PEO don’t even have the right to regulate ESAs. According to an apparently reliable source,
“PEO has taken the position that the preparation of Phase I ESA’s does not constitute the practice of professional engineering. The work associated with or arising from the [ESA] therefore, cannot be considered to comprise professional engineering practice and thus should not be subject to investigation as a potential matter of Professional Misconduct by PEO.”
If so, how can the MOE insist that engineers are the most suitable to be Qualified Persons for Environmental Site Assessments?