Classify site: step 4 of federal contaminated sites decision-making framework

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Step 4: classify site (optional)

Step 4 is an optional step that can be used at the discretion of the custodians who wish to complete a preliminary assessment of a site’s classification or if they wish to determine if enough information on the site has already been gathered to complete a robust site classification. Equally, custodians can choose to proceed directly from Step 3 to Step 5 if they need to collect more data to complete a meaningful classification (at Step 6).

In Step 4, custodians complete the Canadian Council of Ministers of the Environment’s (CCME) National Classification System for Contaminated Sites Guidance Document (NCSCS) (CCME, 2008) or the Federal Contaminated Sites Action Plan (FCSAP) Aquatic Site Classification System (ASCS) worksheets (FCSAP, 2015). Custodians should refer to the 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). This exercise can further help the custodians identify the priority of sites for subsequent action (assessment or remediation).

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.

When further testing is not required and sufficient site information is available, and if the custodian wishes to have the site considered for FCSAP remediation/risk management (R/RM) funding, the site classification worksheet can be reviewed by the expert support departments and the FCSAP Secretariat to determine if the site meets the eligibility requirements for FCSAP remediation/risk management funding. However, it should be noted that classification of sites conducted at Step 4 are generally too preliminary to be reviewed for FCSAP funding eligibility. Very often it is necessary to complete Steps 5 and 6 to obtain a site eligibility review. Step 4 remains more of an internal exercise for custodians.

Key decision(s)

• Determine if the completion of a preliminary assessment of a site’s classification is needed in this step
• Determine if it is preferable to collect more information before assessing a site’s classification - do not complete Step 4 and go right to Step 5 (Detailed Testing Program)
• Alternatively, determine the classification of the site at this step
• Based on the level of priority for action and on the completeness of the classification assessment, determine if the site is eligible to request FCSAP R/RM funding and proceed to Step 7 (Develop Remediation/ Risk Management Strategy)

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

• review and provide advice on relevant (i.e., fish and fish habitat) components of the National Classification System for Contaminated Sites (NCSCS) (CCME, 2008) or Federal Contaminated Sites Action Plan (FCSAP) Aquatic Site Classification System (ASCS) worksheets (FCSAP, 2014)
• provide access to training and resources for the ASCS [such as the FCSAP Aquatic Sites Classification System Detailed User Guidance Manual (FCSAP, 2015)]
• 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

• provide advice on the use and interpretation of NCSCS spreadsheet (CCME, 2008) and ASCS worksheets (FCSAP, 2014)
• review and provide advice on ecological concerns described by the NCSCS or the ASCS
• provide training and guidance on the use of NCSCS or ASCS worksheets

How Health Canada (HC) expert support can assist

• review and provide advice on relevant (i.e., human health) components of NCSCS and ASCS classification scores and associated background information, including interpretation of NCSCS and ASCS worksheets
• provide advice, guidance, training and/or peer review on conducting Human Health Risk Assessments (HHRA) and interpreting their results with respect to site classification
• provide advice and support in ranking and prioritizing sites from a human health risk perspective

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

• provide advice throughout Step 4, including on determining whether R/RM is required at a site
• assist in determining whether further work is required or whether no further action is necessary

How the FCSAP Secretariat can assist

• provide assistance in using the Eligible Cost Guidance, v. 5.0 document (FCASP, 2016), as required
• provide support to custodians on the process for submitting a site to the FCSAP Priority List for remediation/risk management (R/RM) funding (navigating through the Interdepartmental Data Exchange Application [IDEA], mandatory documents, reports and other eligibility concerns) if sufficient information about the condition of the site is available at this step

Supporting documents and tools specific to Step 4

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

• 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

• Eligible Costs Guidance, 5.0 (FCSAP, update in progress)
• Supplemental Guidance for the Scoring of Sites Using the National Classification System for Contaminated Sites (NCSCS) and Aquatic Sites Classification System (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)