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:

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)

Step 6: Re-Classify Site
Long description

Review the findings from previous steps and consult stakeholders. Classify or reclassify the site using NCSCS or ASCS and record it in the FCSI. Develop remediation liabilities estimates and record them in the FCSI. Determine if the site is eligible for FCSAP remediation/risk management funding by applicable class.

If class INS, return to Step 5.

If Class N, no further is action needed. Record the decision and rationale in the FCSI.

If Class 1, 2, or 3 and the custodian wishes to use FCSAP funding to remediate the site, submit the project documentation to the Interdepartmental Data Exchange Application (IDEA) for project eligibility review. Expert Support and the FCSAP Secretariat will review the documentation. If Expert Support agrees, the site will be added to the FCSAP priority list and you should proceed to Step 7. If Expert Support does not agree, record the decision in IDEA and initiate a discussion with the custodian and Expert Support to address issues. Make classification revisions as appropriate. If issues cannot be resolved, inform the FCSAP Secretariat to initiate the resolution process.

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:

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

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

How Health Canada (HC) expert support can assist

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

How the FCSAP Secretariat can assist

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

Federal Contaminated Sites Action Plan (FCSAP) Guidance

Other guidance and tools

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