Is CSA Z768 still relevant in Ontario?

Recently I have had discussions with several colleagues and AESAC members about the use of CSA Standard Z-768 for conducting Phase I Environmental Site Assessments in Ontario. I know of a few Ontario consultants (as well as some environmental educators) that don’t utilize, or teach, the CSA Standard, instead preferring to exclusively concentrate on the Ontario-specific ESA standard specified by the Ministry of Environment, Conservation and Parks (MECP) for supporting the submission of a Record of Site Condition (RSC); that is, Ontario Regulation 153/04, as amended.   Some have even questioned the current relevancy of the CSA Standard, and whether it is still worth learning or utilizing CSA for conducting Phase I ESA. Let me tell you, in my opinion, that’s the wrong approach, and learning and following the CSA format is still very relevant.

• In Ontario, when you intend to change the land use to a more sensitive one (e.g. Industrial or Commercial to Residential), the property owner will legally require a MECP-acknowledged RSC, and that means, at a minimum conducting a Phase One ESA, in accordance with O.R. 153, as amended. But, not all ESAs are completed for the purpose of getting an RSC, and many, many ESAs are conducted for transactional due diligence and/or financing – in which case a CSA-compliant ESA is just fine. In some cases CSA can be better than the RSC format, or at least more cost effective since a lot of the extra (often unnecessary) detail and red tape needed to support the RSC is not needed or in some cases not even relevant to determining potential environmental liabilities. The cynical part of me suspects some consultants default to RSC format because of the higher fees usually charged for RSC compliant reports. Regardless, if you want to be an environmental consultant in Ontario, having good knowledge of both formats is important.
• Ontario is the only Canadian jurisdiction that employs a completely different ESA standard and report format, and only for the purposes of obtaining an RSC. All other provinces and territories follow the CSA Standard, or have provincial-specific ESA requirements that are based on the CSA Standard. If you plan to work solely in Ontario, and only on RSC projects that may be fine, but absence of knowledge of the CSA standard could be limiting if you want to practice outside Ontario.
• The RSC format is focussed primarily on the potential for contamination of soil, groundwater and sediment; and does not consider the concerns or potential liabilities associated with potentially hazardous building materials such as asbestos, lead, or PCBs, all of which are covered as Special Attention Items under CSA. Most of my clients who purchase properties, especially those with older buildings, are very concerned about the health and safety implications and financial liabilities associated with the presence of asbestos, PCBs and lead containing materials.
• Lastly, regardless of the ESA standard required by law, or preferred by the consultant; a competent assessor really needs to know and understand the entire process of conducting ESAs diligently and defensibly. The skills and knowledge obtained through AESAC training courses, which are based on the CSA Standard, are still extremely relevant, and easily transferable to conducting ESA to the RSC format for Ontario projects. I encourage all ESA practitioners (not just in Ontario) to consider in-depth ESA education, such as that offered by ASEAC across Canada 

Bill Leedham, P. Geo., CESA
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