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Risk Assessments in Support of filing a Record of Site Condition under O.Reg.153/04

The MGRA approach uses the same model used by the MECP to generate the generic standards in order to generate site-specific Property Specific Standards (PSS). The PSS generated are protective of both human and ecological health, unlike the DDRA/SLRA, which only examines human health. The site-specific PSS are generated by the modification of MECP defined parameters such as soil type and distance to the nearest surface water. With the modification of some site-specific standards it is
possible to generate highly (or less conservative) PSS for the site than the generic MECP standards. In addition to being able to modify some site-specific parameters, the MGRA model has incorporated some risk management measures, which when included in the model, can further modify the generated PSS to less conservative values thereby decreasing the remediation required at the site. A MGRA assessment is much easier to accept by a potential purchaser, given that it employs the MECP’s model to generate the PSS and as such requires much less technical review to ensure its results. The time to receive MECP approval for a MGRA is typically 6-12 months as the review times by the MECP are only 8 weeks. The MGRA is a much quicker option than the Tier III below, however, each RA site must undergo a pre-consultation with the MECP to allow them to accept the MGRA approach for the RA site.


In the case of a Tier III Risk Assessment, unlike the MGRA, all site-specific parameters are open for modification, with proper modification. While the MECP prefers the use of MECP standard values, it is possible to modify any site-specific parameter involved in the risk assessment, as long as valid justification is provided for deviating from the MECP value. The use of the Tier III RA approach provides the opportunity to further refine the PSS generated, by using even more site-specific values, than would be permitted under a MGRA approach. Ultimately, the purpose of a Tier III RA is to provide the most realistic representation of the site conditions in order to generate the PSS. Generally, the PSS generated using a Tier III approach are less conservative (e.g. higher) than the MECP generic standards or those generated using a MGRA approach, thereby further reducing the remedial costs at the site. One drawback of the Tier III RA approach is the length of time to received MECP approval as reviews of submitted reports takes on average 16 weeks, resulting in a typical timeline for acceptance of 18-24 months.
 

HS Group has successfully completed hundreds of risk assessment approved by the MECP under the regulation leading to Record of Site Conditions since the regulation came into place back in 2004.

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Due Diligence Risk Assessments

The Due Diligence (DDRA) or Screening Level Risk Assessment (SLRA) is typically conducted as part of due diligence and while the format generally follows that of a risk assessment conducted under Ontario Regulation 153/04 (O. Reg. 153/04) (as amended) that would be used to support a RSC, the DDRA/SLRA is not submitted to the MECP, nor be used to support the filing of a RSC. The key difference in a DDRA/SLRA from the other risk assessment approaches is that it only considers risks to human health at the Site, as typically the purpose of the DDRA/SLRA is to facilitate the sale of the property and to support future financing of the property. The DDRA/SLRA format follows the general approach, analysis and protocol utilized in conducting a risk assessment under O.Reg. 153/04 (as amended), however a formal risk assessment document will not be submitted to the MECP for review, nor will it be used to support the filing of a RSC. HS Group has successfully completed hundreds of DDRAs for clients allowing for financing or sale of properties throughout Ontario.

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Federal Contaminates Sites

HS Group is routinely called upon to complete either Preliminary Quantitative Risk Assessments (PQRAs) or Detailed Quantitative Risk Assessments (DQRAs) for federally-owned properties across Canada. HS Group has played a major role in conducting numerous risk assessment projects of various complexity (qualitative, screening-level, preliminary, and detailed-quantitative). HS Group has experience with a number of federal department with the company’s years of experience, such as DFO,
Parks Canada, DCC and PWGSC. HS Group is here to help with any federal risk assessments wherever the sites are located in Canada.

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