http://envirolaw.com/enhanced-records-site-condition/?utm_source=rss&utm_medium=rss&utm_campaign=enhanced-records-site-condition News and analysis (not advice) by a top Ontario environmental lawyer Fri, 18 May 2012 00:34:33 +0000 hourly 1 http://envirolaw.com/enhanced-records-site-condition/comment-page-1/#comment-687 Dr. George Duncan Wed, 13 Jan 2010 19:48:52 +0000 http://envirolaw.com/?p=2298#comment-687 To me, the root of the problem is a serious lack of understanding of the chemistry of contamination on the part of the QP's performing Phase I/II site assessments. The MOE may be frustrated with the poor quality of some RSC's but this should not be surprising given the absence of any environmental chemistry courses from most civil engineering and geoscience degrees. How can anyone with no chemistry background whatsoever be expected to interpret the environmental condition of a site with little or no concept of concentrations, reactivities, water solubilities, volatilities, toxicities, degradation pathways and sampling pitfalls of the hundreds of chemical contaminants listed in the Reg? No wonder that the APEO has said that Phase I ESA's are not part of engineering practice and are therefore not subject to disciplinary action. To me, the root of the problem is a serious lack of understanding of the chemistry of contamination on the part of the QP's performing Phase I/II site assessments. The MOE may be frustrated with the poor quality of some RSC's but this should not be surprising given the absence of any environmental chemistry courses from most civil engineering and geoscience degrees. How can anyone with no chemistry background whatsoever be expected to interpret the environmental condition of a site with little or no concept of concentrations, reactivities, water solubilities, volatilities, toxicities, degradation pathways and sampling pitfalls of the hundreds of chemical contaminants listed in the Reg? No wonder that the APEO has said that Phase I ESA's are not part of engineering practice and are therefore not subject to disciplinary action.

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