Step 7: Develop remediation/risk management strategy

A remediation/risk management (R/RM) strategy specifies the remedial or management actions that will reduce the levels of, and exposure to, bioavailable and toxic contaminants so that existing or potential risks to humans and the environment are rendered acceptable. FCSAP DFO expert support concerns usually pertain to how the R/RM strategy will impact fish and fish habitat and the sustainability of aquatic ecosystems. Information obtained as part of the site classification process is used to assist in developing a site-specific R/RM strategy. The R/RM strategy is implemented in Step 8.

How to prepare

• review:
  • information from Steps 3 and 5
  • resource management plans
  • relevant fish, fish habitat, and aquatic ecosystem information
  • relevant information about aquatic species listed under the Species at Risk Act (SARA), including recovery strategies, action plans, and management plans
  • the conceptual site model and refine if required
• examine available R/RM options
• conduct a site visit, if needed, to address specific issues

What to do

• follow planning guidance for measures to protect fish and fish habitat and standards and codes of practice
• evaluate applicable R/RM technologies with the goal of reducing impacts to fish and fish habitat
• conduct:
• an analysis of the R/RM options (e.g., technical evaluation of R/RM options to ensure applicability and effectiveness, a cost-benefit analysis, etc.)
• public information sessions
• develop and prepare documentation needed to develop a comprehensive R/RM strategy, for example:
• Phase III environmental site assessment (ESA), if not already completed
• ecological risk assessment (ERA)
• remedial action plan
• confirmatory sampling plan
• site-specific monitoring plans
• environmental management plan
• plans for the construction/installation of any physical works (e.g., design, timing, mitigation measures, associated temporary structures, erosion control, etc.)
• contingency plans for accidental events
• plans for the management of waste materials/products
• identify opportunities for restoration and enhancement of fish and fish habitat
• submit project details and supporting information to Fisheries and Oceans Canada expert support for review
• apply for a Fisheries Act authorization and SARA permit, if necessary

How Fisheries and Oceans Canada Expert Support helps

• provide input and advice on R/RM options (including mitigation measures) that may lead to more effective and/or cost-efficient results
• review and provide advice on the following points to ensure that activities on site are compliant with DFO’s regulatory requirements and mandate to protect fish and fish habitat and aquatic ecosystem sustainability:
• draft a remedial action plan (RAP) or risk management plan (RMP)
• remedial/risk management strategy to ensure coherence with broader DFO initiatives
• SARA recovery strategies, action plans and management plans to ensure compliance with the SARA-listed aquatic species or particular harvested aquatic species
• draft Impact Assessment (IA) and supporting documentation
• draft Ecological Risk Assessment (ERA)
• plans for physical works, undertakings and/or activities
• mitigation, monitoring, and contingency plans
• participate in site visit activities (if specific issues are identified)
• identify appropriate contacts within DFO for further assistance
• provide support to the public engagement process
• provide advice to custodians in the development of terms of reference for contracts to prevent or mitigate potential impacts to fish and fish habitat that would be associated with testing or R/RM programs
• provide access to training and resources for ERAs (e.g., the FCSAP Ecological Risk Assessment Guidance: Module 4 – Causality Assessment)
• provide assistance in applying the Framework for Addressing and Managin Aquatic Contaminated Sites under the FCSAP
• provide advice on compliance requirements under the Fisheries Act, the SARA and other DFO-related legislation

Federal contaminated sites: Online resources