• Avoiding Common Phase 2 ESA Errors – Part 3

  • Last month I discussed various mistakes I have encountered in the field work portion of Phase Two Environmental Site Assessments. This month’s blog will focus on some common errors in data interpretation and reporting.

    Sometimes consultants will go above and beyond their contracted scope of work in an attempt to satisfy their clients. Consultants should always follow their work plan and provide nothing more and nothing less than what is in the agreed scope of work. Doing more than proposed can lead to problems, especially if one is providing advice or recommendations beyond one’s expertise. Similarly, failure to follow your agreed scope of work can lead to deficient reports, invalid conclusions and dissatisfied clients, as well as possible legal liabilities.

    When budgets are inadequate, or when important investigation items are missed; the consultant can end up with insufficient data to support their conclusions. The assessor must consider and investigate all relevant contaminants of concern and all potentially impacted media. If contamination is identified, the investigation must collect sufficient data to defensibly and accurately estimate the extent of impact. Too few sampling points can lead to an excessive estimate of a contaminant plume, when the interpretation is properly extrapolated to the next ‘clean’ sample location. In such a case, the inclusion of additional sampling locations can help to better define the extent of impacts and provide more accurate estimates of the scope, effectiveness and costs of remedial actions.

    Failure to identify and discuss relevant items of environmental concern can also lead to adverse consequences. Too often, I see Phase One reports that identify possible contaminant sources, as well as the potential presence of hazardous building materials such as asbestos and lead paint, yet the Phase Two investigates only soil and groundwater concerns, and the potential for dangerous and costly asbestos-containing materials is never considered until the client purchases the property and wants to renovate and demolish. It is vital that the consultant investigate and report all potential environmental concerns affecting the site and stakeholders.

    Lastly, one of my pet peeves in peer reviewing reports involves the presentation of data and conclusions. The observations of the investigation should rationally lead to the report findings, and should defensibly support the conclusions and recommendations. It’s a bonus if the report author makes it easy for the audience to follow along. This is more difficult when the reviewer has to go back and forth between overly wordy report text, lengthy appendices and detailed lab data, and then has to review and compare regulatory criteria separately. My preference is to provide the relevant information in easy to digest tables or bullet points that briefly summarize the sample description, sample location, analytical results and also provide comparison to applicable regulatory criteria. This provides clearer interpretation of actual impacts, helps avoid confusion and reduces the possibility of data transposition errors; and more easily allows any reviewer to track the evidence and come to the same conclusions as the original consultant.

    Bill Leedham, P. Geo., CESA, QPESA
    Bill is the Head Instructor and Course Developer for the Associated Environmental Site Assessors of Canada (
    www.aesac.ca); and the founder and President of Down 2 Earth Environmental Services Inc. You can contact Bill at info@down2earthenvironmental.ca