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Qualified Person for Environmental Assessment
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The Ministry of the Environment (MOE) and the Government of Ontario have decided to proceed with the proposed amendments
to Regulation 153/04 of the EPA, thereby disqualifying Chartered Chemists as Qualified Persons.
The “transition provision” period has been extended from twelve (12) to eighteen (18) months (effective April 1, 2008). It is our understanding, from speaking with the MOE, that one of the main reasons for this decision is as stated in the Description of Regulation (EBR 010-2364): “At the core of the responsibilities of a qualified person is the application of geoscience and engineering principles.” |
Recent History
In January 2008, the ACPO presented its position to the Ministry of the Environment regarding the proposed Brownfields Regulation. In light of the Ministry's negative reception, the ACPO has now issued a Press Release (Feb. 2008) and submitted an official response.The association has also sent the following message to its members and other stakeholders.
The Ministry has met with special interest groups in recent weeks to hear representations to restrict which professionals can perform environmental site assessments to these groups while excluding all other qualified professionals. The Ministry is giving the latter a reprieve of one year to find other gainful employment AND lose forever their current qualifications. Believe it or not!
If someone was given the choice between a professional chemist who has all the specific knowledge on soil contamination with years of experience in the field and somebody who has often been taught by that professional, wouldn't that someone choose the more qualified person? Indeed, that is what logic would suggest.
Unfortunately, logic and politics do not always mix, especially in a non election year with only a few constituents being affected. The topic not being controversial so far, the decision about it need not be courageous. As they used to say in the series "Yes Minister", controversial means "you will loose votes", while courageous means "you will loose the election", so which does apply in the current situation?
For further details on this topic, click on the Environmental Registry site:
Brownfields Regulation – Qualified Persons (EBR 010-2364).
Please note that the comment period ended on February 24th, 2008.
Background Documents
- Brownfields Qualified Person Amendments by MOE (April 1, 2008)
- Review of Contaminated Site QP Programs (Final Report, Dec. 2007, 1.22 MB)
- Alberta chemists, along with 5 other type of professionals, can "sign off" on environmental work! Why not Ontario professional chemists??
- Alberta Joint Practice Standard (Sept. 2007, 540 kB)
- Earliest version of Ont. Regulation 153/04 (Records of Site Condition)
- Guide on Records of Site Condition (prepared by MOE)
- Laboratory Accreditation Requirements under O. Reg. 153/04 (March 2007)
- More background information can be found by clicking on the Brownfield Soil and Ground Water Standards (formulated in March 2007).
- Ontario Institute of Agrologists - University Competencies
- Ontario Institute of Agrologists - Technical Competencies
Responses to the Environmental Bill of Rights (EBR) posting
- Association of the Chemical Profession of Ontario (ACPO)
- Association of the Chemical Profession of Alberta (ACPA)
- Association of the Chemical Profession of British Columbia (ACPBC)
- National Advisory Committee on the Profession of Chemistry in Canada (NACPCC)
- Canadian Society for Chemistry (CSC)
- Bioforj Environmental, Guelph, ON
- Investigative Science Inc., Burlington, ON
- Dr. David Naranjit, C. Chem.
- Dr. Claude Bordeleau, C. Chem.
- Trevor Janzen, Senior Environmental Scientist, C. Chem.
- Ontario Institute of Agrologists (OIA)
- Ontario Environment Industry Association (ONEIA)
Examples of Letters of Support
Contact Information
- Dalton McGuinty, Premier of Ontario
- Ministers
- Ministry Offices
- Cabinet Ministers and Opposition Critics
- MPP’s - Queen’s Park Offices
- Committee Members (Legislative Assembly)