Historical review: step 2 of federal contaminated sites decision-making framework

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Step 2: Historical review

In Step 2, a suspected site identified in Step 1 undergoes a Historical Review of information, also known as a Phase I Environmental Site Assessment (ESA) and the custodial department accountable will consult with stakeholders. The four principal components of a Phase I ESA are 1) a records review; 2) a site visit; 3) interviews; and 4) an evaluation of information and reporting.

This information will provide insight into the types and locations of potential contaminants and the suspected pathways and receptors. Custodians must prioritise the sites that are being assessed (for financial capacity or prioritization of activity reasons). For FCSAP-funded site assessments, a priority assessment must be submitted to the Secretariat at some point during Step 1 to 6. Sites that are not identified as a priority for assessment should be re-evaluated periodically according to a custodian’s portfolio characteristics.

If there is evidence or reason to suspect environmental or human health issues of concern, then the custodian could develop a Preliminary Sustainability Plan (see Appendix A) for the site as described in the Sustainability Strategy and Implementation guidance (Appendix A). The plan should also require any consultants and contractors working on the site to consider implementing, where feasible, elements of the Preliminary Sustainability Plan.

Key decision(s):

• validate Step 1 conclusions that there is reason to suspect that the site is contaminated and that assessment should continue to Step 3 (Initial Testing program)
• determine whether the site can be closed because no further action is required
• determine whether a preliminary Sustainability Plan should be developed and, if applicable, at which steps sustainability should be integrated

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

• provide fish, fish habitat and fisheries background information at or near the site, if available
• provide information on regulatory frameworks applicable to aquatic sites
• review the Phase I ESA(CSA, 2001) and provide advice
• participate in site visit activities
• provide assistance in applying the Framework for Addressing and Managing Aquatic Contaminated Sites under the Federal Contaminated Sites Action Plan (FCSAP, 2011)

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

• provide regulatory advice concerning past operations conducted at the site
• provide advice on site assessment standards and best practices
• review the Phase I ESA, identify information gaps and provide advice on information gathering
• participate in site visit activities.

How Health Canada (HC) expert support can assist:

• provide advice on developing a site assessment that can be used for adequately characterizing chemicals of potential concern in site media based on historical land use, which is important for assessing risks to human health and future decision making
• review the Phase I ESA report and provide anticipatory technical comments related to requirements for the Step 3 Phase II ESA (CSA, 2001) to identify potential human health exposure and information gaps that may require additional assessment in order to identify whether there are human health risks
• participate in site visit activities

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

• provide advice on the Phase I ESA, including the historical review/assessment, and determine if further work is required or no further action needs to be taken

How the FCSAP Secretariat can assist

• provide general FCSAP program information and support
• provide assistance in using the Eligible Cost Guidance, v. 5.0 document (FCSAP, update in progress), as required

Supporting documents and tools specific to Step 2

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

General Guidance

• Canadian Standards Association (CSA) Standards for Phase I Environmental Site Assessments (CSA, 2001)
• Framework for Addressing and Managing Aquatic Contaminated Sites under the Federal Contaminated Sites Action Plan (FCSAP, 2011)

Federal Contaminated Sites Action Plan (FCSAP) Guidance

• Eligible Costs Guidance, 5.0 (FCSAP, update in progress)
• Framework for Addressing and Managing Aquatic Contaminated Sites under the Federal Contaminated Sites Action Plan (FCSAP, 2011)