Clarification should be made…

Clarification should be made regarding the requirements of one large source site (excess fill exceeding 1000 m3) shipping to multiple small receiving sites (receiving less than 350m3). There appears to be a disconnect regarding the applicable standards to use for characterization as well as the required record keeping activities if the size of the generating and receiving sites are of very different sizes. There could be implications to property owner of the small fill sites if documentation does not exist and issues or concerns are raised at a later date. As small fill sites likely will not require MOECC approval (i.e. no Record of Site Condition required) there would be no further testing of the soil material if it not tested and documented on import. If soil is used as backfill that is questionable or does not have documentation and a concern arises in future the property owner would not have any recourse and would not be able to prove the source or quality of material imported.

[Original Comment ID: 209782]