Choosing the Right Environmental Consultant: Essential Questions to Ask

The standard for environmental care in Ontario is found in Ontario Regulation 153/04. This extensive regulation defines what property owners are required to do for their site to ensure that they are protecting the environment.

  1. Reg. 153/04 essentially defines the process that leads to obtaining a Record of Site Condition (RSC) for a property. This generally involves a Phase 1 Environmental Site Assessment (ESA), which looks at the history and possible areas of concern on a site. Next, it may require a Phase 2 ESA, which involves testing the soil and groundwater on the site to determine if any impacts exist. If contamination is found, a clean-up may be carried out -this could take many forms, from simply disposing of some soil, to performing a large scale bioremediation or other operation. Finally, an RSC may be issued when the site meets certain criteria.

If you require an RSC, you will likely be looking for an environmental consultant to work with you in the process. An environmental consultant knows the regulation and what will be requited for your site.

Here are some helpful questions to ask when selecting an environmental consultant who will help you to bring your site into compliance. By asking these nine questions, you can be confident that your consultant understands your project goals. You can quickly determine whether they are a good fit for what you need.


Are you a Qualified Person (QP) as defined by O.Reg. 153/04?

Only a QP can file an RSC, complete a Phase 1 site walkover, and other key tasks under Ontario’s environmental regulations. If your RSC is signed by someone other than a QP, it won’t be valid. A QP is a Professional Engineer or Professional Geologist who has received QP status from the Ministry of the Environment, Parks and Conservation (MECP). They have a proven background in interpreting and applying environmental regulations. They understand what issues may be found on complex environmental sites. Working with a QP right from the beginning will save you time and keep the project moving in the right direction.


What regulatory standard will the RSC be filed under?

In Ontario, the most common environmental regulatory standard for properties is Ontario

Regulation 153/04. Ensure that the consultant is able to complete any investigations in accordance with applicable regulations and standards. Request that they provide proof of this. If the consultant is providing a Phase 1 or 2 ESA only (not filing an RSC for the property), confirm

that the Phase 1 and 2 will be valid if you choose to file an RSC in the future.


If my property requires a Risk Assessment, are you able to complete that?

Be certain your consultant has the ability to undertake a full complement of risk assessment (RA) under the regulation including Modified Generic Risk Assessments (MGRA) Tier 2 and 3.

While not always required, RAs greatly expand the flexibility of site approaches allowed under the regulation. Therefore, it is in your best interest to keep this option open at the start of the project in case it is required during a later stage. Consultants must hold the designation of a QPRA in order to do this.


What is the upper cost limit for this project?

It is very helpful to get your consultant’s quotation for a project in writing, with an upper limit. Site work costs can be unpredictable. Make sure that your consultant has a plan for preventing overruns and advising you of any budget changes. Clear communication is key here and can prevent costly surprises. You can also ask how they track their expenses and how frequently you will get updates on the budget. One way to do this is to use web based programs that allow real-time account reconciliation and project management. This helps the project manager to keep a close eye on the cost of a project, and can provide clients with up-to-date information on the work that their consultant is doing.


What do you think the end goal for the project is?

See if the consultant is interested in what your priorities for the property are, and is willing to modify project plans in order to try to meet these priorities. A good consultant will work within your goals for a property. From a consultant’s perspective, it is helpful to hear the client’s plans for the site and their perceived timeline. This can provide insight into their expectations and make an achievable action plan and timeline.


On the complex sites, what are some approaches you have taken to meet the requirements for an RSC?

A good consultant will consider and be able to discuss multiple solutions to your problem while still satisfying the regulatory requirements. They are also happy to keep you involved and informed about the process. The solutions they use may include various methods of testing, different approaches to remediation, and risk assessment. In Ontario, there are many options within the RSC process. Ontario Regulation 153 is very prescriptive, but also provides options for different approaches as long as the result satisfies the regulation. For instance, your QP may suggest classifying the site for non-portable water use because the standards are less stringent. This is one approach to meeting the requirements of the site, and may or may not give the results you need. It is important to know how your consultant will work within the regulations.


How will I be kept informed of project progress?

Does the consultant communicate well? Make sure that he or she has assigned you a project manager who you can easily contact with concerns and who will stay with the project until completion. Your consultant should give you frequent updates. This prevents misunderstanding, unnecessary delays, and costly overruns. This can be done successfully using project management software that identifies upcoming tasks and allows the project manager to provide real-time updates to the client. A consultant can also provide written monthly updates as record of project progress.


What technology do you use in site Assessment? Do you use on-site testing?

Access to innovative technologies can decrease time on-site and lower the cost of your site assessments or remedial activities. One example of this is on-site x-ray fluorescence testing which can detect metals contamination in soil in a matter of minutes, while significantly lowering laboratory costs for the client and expediting field work. For consultants that use it effectively, on-site testing has sped up remediations by finding the boundaries of contamination within minutes. If a soil sample tests positive for an impact, the excavation is expanded slightly and tested again, until the limit of the impact is found. This keeps the remediation moving quickly, prevents the excavation and disposal of clean soil, and ensures that all the contamination is removed in one try. Results are confirmed with lab testing (including all necessary duplicates and blanks). By using appropriate and advanced technology, your consultant will be able to

direct the investigation and remediation confidently.


How many RSCs have you successfully had acknowledged since July 2011?

Be sure that the consultant has adequate experience. A consultant who has been in the industry for a long period of time will know how to navigate the amended regulations better than somebody new to the field. In addition, an experienced consultant understands the challenges and options within the regulation and can give you a realistic picture of the time, sampling, and cost that will be require. Since O. Reg. 153/04 became more stringent in 2011, filing an RSC has been more challenging. Ensure that your consultant has enough experience to bring your

property into compliance.

Have More Questions?

By asking these questions, site owners can gain a clear sense of their consultant’s approach to filing an RSC and can ensure that there is a high level of mutual understanding. On any project, this can mean the difference between a rough, stressful project and a straightforward one. If you want to learn more about the Record of Site Condition process or speak with AEL’s senior engineers, call 416-657-2367. AEL is committed to providing innovative land restoration solutions through site assessment and remediation and offers high-quality environmental consulting all over Ontario and beyond.

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