Not Just “Dirt”: Why Does Clean Fill Matter?

The Ontario Ministry of the Environment and Climate Change (MOECC) has identified improperly managed Soil Fill as an important potential contributor to contaminated sites. Soil to be moved from one property (Source Site) to a different property (Receiving Site) must be managed in order to prevent the discharge of a contaminant to the environment that may cause an adverse effect, as defined under the Ontario Environmental Protection Act.

Soil Management involves the consideration of different soil standards that the MOECC has created, and which are determined by property use.  Higher impact property uses, such as commercial/industrial uses, are subject to less stringent standards than residential or agricultural property uses.  For example, soil from an industrial/commercial property cannot be imported to a residential property without vigorous testing to ensure it meets a residential property’s stricter standards.  Soil sampling and analysis should always consider the existing conditions at the Receiving Site, and the anticipated future use of the Site.

Property owners who are seeking to import soil to their sites should consider the following:

  • Read and follow the Ontario Ministry of the Environment’s document titled “Management of Excess Soil – A Guide for Best Management Practices”, which provides guidance for environmental decision making.
  • Property owners should strongly consider retaining a Qualified Person (as described in O. Reg 153/04) to develop a soil management plan, and guide them through the process of importing soil to their site.
  • Consult with the local municipality or Conservation Authority, where applicable
  • Develop a Fill Management Plan, which will, amongst other things, identify ways to control dust and noise, reduce the potential for contamination or introduction of invasive species, site security measures, and identifying appropriate soil quality to be imported to the site.
  • Soils should be sampled and analyzed prior to receipt at the new site to ensure that they will not introduce new contaminants to the Site that will require a potentially costly clean-up/remediation effort. A Qualified Person can provide aid in not only the review of soil results, but can develop a soil sampling and analysis program, if necessary.
  • All soil sampling and analysis, whether performed by the Source Site or by the Importing Site should follow the soil sampling requirements as set out in O. Reg 153/04, and be performed by a Qualified Person.
  • Maintain all records of the Source Sites of imported fill, the volumes, times and dates of shipments, analytical results from those soils, and any rejections of soil fill loads.
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