May, 1999
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Attention
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A subcommittee of APEGGA’s Practice Standards Committee (PSC) recently undertook a study to determine what aspects of environmental site assessment might be considered to be the practice of engineering, geology, or geophysics. APEGGA’s Enforcement Review Committee (ERC) occasionally deals with concerns that unqualified parties are conducting site assessment work, and that this work might involve the practice of engineering or geoscience. Clarification would assist the ERC in determining whether enforcement action should be pursued against non-registered individuals or firms that may be practicing engineering or geoscience when conducting site assessments.
The Canadian Standards Association (CSA) defines environment site assessment as follows:
Phase I Environmental Site Assessment (ESA)—the systematic process by which an Assessor seeks to determine whether a particular property is or may be subject to contamination.
Phase II Environmental Site Assessment (ESA)–the systematic process by which an Assessor seeks to characterize or delineate the levels of contaminants of concern related to a site. Phase II ESAs may be used to confirm or refute the findings of a Phase I ESA, gather information in support of remedial measures or site redevelopment, make informed decisions about property transactions, or to establish a baseline of environmental conditions.
The ESA process may be arbitrarily divided into five broad classes of activities as used by the PSC subcommittee:
- Phase I ESA (non-intrusive investigation)
- Phase II ESA (site assessment and
characterization)
- Remediation Planning
- Remediation Implementation
- Post Remediation Monitoring
The subcommittee spent considerable effort identifying the range of activities that may be involved in environmental site assessment and discussing whether those activities might be the exclusive area of practice of APEGGA members. The subcommittee concluded that, without becoming excessively narrowly focused, it was not possible to generally identify any site assessment tasks that could not, in some situations, be conducted by non-APEGGA professionals. As a result, potential enforcement issues would need to be dealt with case by case with input from professionals experienced in site assessment.
Many of the general activities involved in site assessment could, in some circumstances, involve the practice of engineering or geoscience. In other situations, many of those same activities might more (or equally) appropriately be conducted by members of other professions. One of the prime examples was soil sampling conducted for the purpose of oil and gas lease site reclamation.
The subcommittee also weighed the benefits of developing a guideline for APEGGA members conducting environmental site assessments and developing a definition of the practice of environmental site assessment. The general consensus was that definitions and guidelines already exist, and there would be little benefit to duplicating previous efforts. The Canadian Standards Association has a guideline for Phase I Environmental Site Assessment and was developing a guideline for Phase II Environmental Site Assessment. Professional Engineers of Ontario has also published a guideline for Environmental Site Assessment, Remediation and Management.
While there were no environmental site assessment tasks that were considered to be, in all instances, the exclusive domain of the practice of APEGGA professionals it was none the less recognized that engineering and geoscience firms play an important role in promoting professionalism and ensuring quality control in this area of practice. Most engineering or geoscience firms engaged in environmental site assessment employ other professionals such as agrologists, hydrogeologists, biologists or chemists to provide special expertise.
APEGGA professionals have a duty to have proper regard for the safety and welfare of the public and the physical environment affected by their work. The advantage to the client who retains a registered professional or firm is that this duty and the Association’s power of enforcement and discipline help to ensure that the client can rely on competent and skilled service.