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Good Day, With respect to the proposed regulation, is aggregate that is imported to a site (i.e. Granular A for a road base) considered excess soil if it is transported to another site (i.e. during road reconstruction) and used for a similar purpose?

I ask this question because as far as I understand aggregate is not subject to environmental testing prior to shipment from the pit/quarry/recycling facility etc. I know from my experience in environmental consulting that recycled aggregate containing slag, concrete or asphalt will often exceed the MOE's least stringent Standards (Table 3). Our municipality, as does many others, allow for the use of recycled materials in aggregate for civil projects. In fact, the Ontario Provincial Standard for aggregate (OPSS 1050) allows for slag, asphalt and concrete in granular materials, which if tested as soil would likely exceed the MOE Standards. I've found that even some quarries produce natural aggregate that exceeds the MOE Standards for zinc.

If aggregate on a site is considered excess soil once removed, this could have an affect on use of recycled aggregate on construction projects, as it could significantly increase future disposal costs during reconstruction or maintenance.

Could you please provide clarification.

[Original Comment ID: 209619]