Re-classify site: step 6 of federal contaminated sites decision-making framework

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Step 6: re-classify site

At this step, the site is classified for the first time, or reclassified from Step 4 if new information acquired through the Detailed Testing Program (Step 5) must be input into the classification system in order to accurately assess the priority for action of a site. A complete site classification is required in order to receive FCSAP remediation/risk management funding. Custodians should complete the Canadian Council of Ministers of the Environment (CCME) National Classification System for Contaminated Sites spreadsheets (NCSCS) (CCME, 2008) or the Federal Contaminated Sites Action Plan Aquatic Site Classification System (ASCS) worksheets (FCSAP, 2015) based on the results of the initial and detailed testing programs as detailed in the National Classification System for Contaminated Sites Guidance Document (CCME, 2008). Stakeholders can provide key information about the site history and condition, end use of the site, exposure pathways, receptors, contaminants of potential concern, and safe exposure limits.

Site classifications include Class 1, 2, 3, INS (insufficient information) or N (not a priority for action), with Class 1 having the highest priority for action.

At this step, custodians should consider whether there is sufficient information to meet the five mandatory recognition criteria for reporting a liability as defined by the Treasury Board Secretariat of Canada and, if so, report the liability for the site using the FCSI portal. The estimate of a remediation liability includes costs directly attributable to remediation activities required to bring the site up to the current minimum standard for use prior to contamination.

A liability for remediation of contaminated sites should be recognized when, as of the financial reporting date, the following apply:

• an environmental standard exists;
• contamination exceeds the environmental standard;
• the Government of Canada:
  • owns the land; or
  • is directly responsible; or
  • accepts responsibility (e.g., when there is little, if any, discretion to avoid the obligation);
• it is expected that future economic benefits will be given up;
• a reasonable estimate of the amount can be made.

After completion of Step 6, if the custodian wishes to have the site considered for FCSAP remediation/risk management (R/RM) funding, the classification worksheets will be reviewed by expert support departments to determine if the site meets the eligibility requirements for FCSAP R/RM funding. Only Class 1, 2 and 3 sites may eventually proceed to Step 7, although Class 1 and Class 2/3 sites require different follow up actions.

Key decision(s)

• Determine the new/revised site classification and if further action is required
• If further action is required, determine if site is eligible for FCSAP R/RM funding and proceed to Step 7

Treasury Board of Canada (TB) definition

According to the TB definition, a contaminated site is “one at which substances occur at concentrations (1) above background (normally occurring) levels and pose or are likely to pose an immediate or longterm hazard to human health or the environment, or (2) exceeding levels specified in policies and regulations”.

Consider seeking FCSAP R/RM funding

For federal contaminated sites to be eligible for R/RM funding under FCSAP, the following conditions must be met:

• the site must meet the TB definition of a contaminated site
• contamination must have occurred before April 1, 1998. Beginning in FCSAP Phase IV (2020-2024), certain sites contaminated after 1998 will be eligible for FCSAP funding. This will allow remediation on more sites that may impact Indigenous people living on reserves or in Northern communities. Please consult this link for more information about FCSAP funding
• the site must have an associated financial liability reported in the Public Accounts of Canada, in accordance with current TB guidance on recording remediation liabilities for contaminated sites
  • In those circumstances where FCSAP funding is used for remediation expenditures but no liability can be recorded, custodians should provide a justification as part of the FCSAP Secretariat’s review of priority sites
  • An example is when a site with no opening liability for the fiscal year receives assessment and remediation funding in one field season
• a complete and accurate site record, including annual expenditure and liability data, must be recorded in the Treasury Board of Canada Secretariat (TBS) Federal Contaminated Sites Inventory (FCSI), in compliance with Treasury Board’s Policy on Management of Real Property and the Reporting Standard on Real Property

Custodians seeking or having obtained FCSAP funding must use the Interdepartmental Data Exchange Application (IDEA). IDEA was developed under FCSAP to facilitate the exchange of information between the program Secretariat, custodians of federal contaminated sites (departments, agencies, and consolidated Crown corporations), and the Expert Support departments (Health Canada (HC), Environment and Climate Change Canada (ECCC), Fisheries and Oceans Canada (DFO), and Public Services and Procurement Canada (PSPC)). On IDEA, custodians submit new site funding requests and update their previously approved site submissions. Custodians who need to create user accounts should contact the FCSAP Secretariat.

How Fisheries and Oceans Canada (DFO) expert support can assist

• review relevant components (e.g., fish and fish habitat) of the National Contaminated Sites Classification System (NCSCS) Guidance Document (CCME, 2008) or Aquatic Sites Classification System (ASCS) classification scores and associated reports (FCSAP, 2015)
• provide training resources (such as the FCSAP Aquatic Sites Classification System (FCSAP, 2015) Detailed User Guidance Manual) and provide advice on the submission score
• provide assistance in applying the Framework for Addressing and Managing Aquatic Contaminated Sites under the FCSAP (FCSAP, 2011)

How Environment and Climate Change Canada (ECCC) expert support can assist

• review the NCSCS or ASCS score and associated reports to confirm the accuracy of the classification derived by the custodian (mandatory for sites that custodians are requesting be added to the FCSAP Priority List for R/RM funding)
• provide information on training resources

How Health Canada (HC) expert support can assist

• review human health components of the NCSCS and ASCS and associated reports to confirm the accuracy of the classification derived by the custodian
• provide advice on the use and interpretation of NCSCS and ASCS worksheets
• provide advice, guidance, training and/or peer review on conducting and interpreting Human Health Risk Assessment (HHRA) results as they apply to site classification

How Public Services and Procurement Canada (PSPC) expert support can assist

• provide advice on the review and classification, and liaise with other expert support departments

How the FCSAP Secretariat can assist

• provide clarification on the application of the Eligible Cost Guidance, v. 5.0 document (FCSAP, 2016), the NCSCS Guidance Document (CCME, 2008) and Aquatic Sites Classification System (FCSAP, 2015) as required.
• communicate decision to custodians on the eligibility of new sites once reviewed, and add new eligible sites to the FCSAP Priority Site List
• provide information on how to access and use the Interdepartmental Data Exchange Application (IDEA)

Supporting documents and tools specific to Step 6

Please also refer to the list of “Supporting documents and tools useful throughout the 10-step process” at the beginning of the document.

Canadian Council of Ministers of the Environment (CCME) Guidance

• CCME National Classification System for Contaminated Sites (NCSCS) Guidance Document (CCME, 2008)
• National Classification System for Contaminated Sites Spreadsheet (CCME, 2008)

Federal Contaminated Sites Action Plan (FCSAP) Guidance

• Supplemental Guidance for the Scoring of Sites Using the National Classification System for Contaminated Sites (NCSCS) and Aquatic Sites Classification Systems (ASCS) under the Federal Contaminated Sites Action Plan (FCSAP, 2013)
• Aquatic Site Classification System (ASCS) - Version 3.2 Detailed User Guidance Manual (FCSAP, 2015)
• Aquatic Site Classification System (ASCS) worksheets (FCSAP, 2015)

Other guidance and tools

• Checklist for Peer Review of Detailed Human Health Risk Assessment (HHRA) (HC, 2010)
• Remediation Liabilities Related to Contaminated Sites: A Supplement to the Financial Information Strategy (FIS) Manual (TBS, 2010)
• Interdepartmental Data Exchange Application (IDEA)