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Site risk classification

Last updated on February 15, 2023

Part 4 of the Environmental Management Act (EMA) enables the ministry to classify contaminated sites based on an evaluation of risk to human health and the environment.

The ministry has developed a site risk classification procedure which is detailed in Protocol 12: Site Risk Classification, Reclassification and Reporting (Revised) (PDF, 737KB).

The site risk classification is based on fact-based criteria and data easily obtainable and routinely collected in contaminated site investigations.

How sites are classified

Sites can be classified as:

  • High risk (HR)
  • Non-high risk (non-HR)

High risk (HR) sites may become eligible to be reclassified to Risk Managed High Risk.

A site is considered HR if either of the 2 HR conditions is present.

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Condition 1: Mobile nonaqueous phase liquids (NAPLs) are present 

The presence of mobile NAPLs on the site leads to contaminant spreading and has a potential for increased exposure to contaminants.

It's generally associated with increased complexity, cost and effort in remediating sites.

The procedure to determine the presence of mobile NAPLs is outlined in Protocol 16: Determining the Presence and Mobility of Nonaqueous Phase Liquids and Odorous Substances (PDF, 259KB).

 

Condition 2: High-risk exposure potentially exists

For a site to qualify as HR under Condition 2:

  • Upper cap concentrations must be exceeded
  • One or more complete exposure pathways must be present

Upper cap concentrations are concentrations established by the ministry for substances with numerical standards in the Contaminated Sites Regulation (CSR) and are listed in Protocol 11: Upper Cap Concentrations for Substances Listed in the Contaminated Sites Regulation (PDF, 2.8MB).

If upper cap concentrations are exceeded, exposure pathways must be evaluated for completeness with the use of an Exposure Pathway Questionnaire (EPQ), which is a step-by-step assessment tool.

For soil vapour contamination, you need to assess the exposure pathway for vapours on the basis of attenuation factors outlined in Table 1 in Protocol 22: Application of Vapour Attenuation Factors to Characterize Vapour Contamination (PDF, 421KB).

High risk (HR) sites pose serious risks to human health and the environment. As they require high standards of care, under the current legislation, the ministry must be involved in HR site investigation and remediation to ensure that appropriate and timely action takes place.

A site can be classified as a RMHR site if risks associated with the site can be managed by application of risk management measures, including access restrictions and engineering controls to mitigate the risks.

All other sites are currently classified as non-HR sites.

 

When a site needs to be classified

A Site Risk Classification Report (SRCR) (PDF, 159KB) needs to be submitted to the ministry in the following instances:

  • When submitting a Notification of Initiation of Independent Remediation (NIR)
  • When submitting a site investigation report ordered by a director of waste management or required by section 6.2(2)(b) of the CSR
  • When submitting a site investigation report after decommissioning of a site or ceasing operations at a site (section 6.3 of the CSR)
  • When submitting a Notification of Likely or Actual Migration (NOM)
  • When applying to the ministry for a contaminated sites service
  • When required by a director of waste management
  • In case of contaminant migration to a neighbouring parcel, when there's a potential for HR conditions at such parcel and this is indicated in the SRCR for the parcel that's likely to be the source of contaminant migration

The timing for submitting site risk classification information is outlined in Table 1 of Protocol 12: Site Risk Classification, Reclassification and Reporting (Revised) (PDF, 737KB). You may be exempt from submitting an SRCR for certain scenarios. Refer to Section 5.3 of Protocol 12 for details.

The site risk classification process does not apply to:

  • Certain sites used for oil and gas activities
  • Sites under Federal jurisdiction
  • Independent remediation arising from an emergency response to a spill

According to Section 4.2 of Protocol 12, current and proposed or planned future uses of the site must be taken into consideration to properly classify a site.

How to prepare an SRCR

Based on Protocol 12, an SRCR and additional information must be prepared by a Qualified Professional (QP).

Additional documentation could be provided to the ministry depending on:

  • Notification trigger
  • Risk classification
  • Type and duration of remediation (as indicated in Tables 2 and 3 of Protocol 12)

Persons signing the SRCR (with or without an EPQ attached) must confirm that they have demonstrable experience in conducting the types of site investigations that are to be reviewed as part of the preparation of the SRCR.

HR sites have specific submission requirements, which are described further in Protocol 12. Documents related to the remediation of HR conditions within 90 days of initiating independent remediation and site risk reclassification must be signed off by an Approved Professional (AP) who is a member of the Society of Contaminated Sites Approved Professionals of British Columbia.

If you do not have sufficient information to complete an SRCR and EPQ, you need to provide an estimated date for obtaining the necessary site information in Section V of the SRCR form.

How to make a submission to the ministry

You may find the current SRCR form on the Forms page. 

Additional information on how to submit an application to the ministry is available on the Apply for services page.

The required SRCR and supporting documents should be submitted to the ministry inboxes as described below, along with a Contaminated Sites Services Application (CSSA) (Online) where needed:

How to reclassify a site

If your site has been classified as an HR site, you may apply for a site risk reclassification to a non-HR site once all HR conditions have been remediated at the site. If HR conditions at a site were addressed by risk management measures, the site can be reclassified as a RMHR site.

When applying for site risk reclassification, you need to submit a contaminated site service application form and all relevant documentation as required by section 6 of Protocol 12.

Compliance verification

To ensure the quality and accuracy of the submissions under Protocol 12, the ministry is performing a targeted review for sites classified as non-HR sites to verify that site risk classification requirements have been met.

If your site is selected for the targeted review, the ministry will request all relevant information used to classify the risk at the site, including analytical results and supporting data.

The ministry will follow up on potential and identified incidents of non-compliance. Penalties for non-compliance with the contaminated sites requirements of EMA and CSR are provided in Section 120(17) of the EMA.

The information on this web page does not replace the legislative requirements in the EMA or its regulations and it does not list all provisions for contaminated site services.

If there are differences between this information and the Act, Regulation, or Protocols, the Act, Regulation, and Protocols apply.