O. Reg. 406/19 imposes…

O. Reg. 406/19 imposes unnecessary, additional regulatory burden for industrial sites.

Project areas which include processes identified as “potentially contaminating activities” are classified as “areas of potential concern”. In the event that soil from these “areas of potential concern” is not appropriate for reuse and must be relegated to landfill based on the recommendations of a Qualified Person, the requirement for registry and load tracking under the Excess Soil Regulations should be removed to reduce unnecessary administrative requirements.

All excess soil sent to landfill is accompanied by documentation and the landfill’s permit will require that records of material received be maintained. There is no benefit to accounting for waste sent to landfill via multiple means.