Written by Bill Leedham, P. Geo., CESA
With AESAC’s 2024 training course schedule underway, it’s good time to talk about one of the key components for achieving AESAC’s Certified Environmental Site Assessor (CESA) designation – submission of a Phase I ESA report for Certification review. In addition to meeting various certification requirements for CESA such as education, training, professional designations and related ESA work experience; applicants are also required to submit a CSA-compliant Phase I ESA report for review (and a Phase II ESA report for the enhanced CESA-II designation). The AESAC review is checking to see that the applicant has conducted the work in compliance with the CSA Standard, and not conducting a detailed and technical peer review.
Over the years, I have seen several main report components that have been deficient and resulted in the report not being accepted for CESA certification, as summarized below.
The CESA designation and report review are based on the CSA Standards, and submission of a different format is not acceptable. While the AESAC courses discuss ASTM, Alberta Oil and Gas and Ontario’s Record of Site Condition formats, the certification is based on CSA Standards, and the submitted report must meet the applicable CSA Standard.
Scope of Work
Both the ESA and the report must follow the CSA format in their scope of work. Whenever the Standard says the Assessor ‘must’ or ‘shall’ complete a specified task, those activities are considered mandatory. In some cases certain information or data may be unavailable within a reasonable time frame or cost. In these situations the Assessor should attempt to utilize other information sources to fill in data gaps; and to state the limitations in their report, as well as the impact the missing data may have on the report’s findings and conclusions. Deviations from the specified scope may be acceptable provided sufficient rationale is provided to satisfy the stakeholders and reviewer(s). Throughout the report, the level of detail and site description should be sufficient to provide a clear presentation of the subject property, site conditions, site development history and the actual and potential environmental concerns that may be present, both currently and historically.
Mandatory and Optional Research Items
CSA provides a list of Mandatory and Optional ESA research tasks. To be thorough and reduce potential data gaps, I recommend competing both of these, provided sufficient data is available. Too often in reviews, I see missing Mandatory items, and very few of the Optional tasks. Mandatory means just that – you have to complete these tasks to meet the CSA Standard. In some cases, such data may not be readily available, and you will have to consider a work-around, or determine if the data gaps will impact your findings (see above).
Special Attention Items (ALUPO – Asbestos, Lead, UFFI, PCB, ODS)
CSA provides a list of Special Attention Items that must be addressed as they are deemed to create potential environmental, health or financial liabilities. It’s also important to note that these items are not covered under either ASTM or the Ontario RSC formats. The most common omission I see is for properties without any current or historical buildings or structures; where such materials are unlikely to be present. For these sites, the potential presence (or likely absence) of Special Attention Items should still be discussed in the report.
Other Miscellaneous Deficiencies
While the CESA review is more generalized and less detailed than a technical peer review, there are still some basic considerations and specific that should be included in the CSA report, and that are sometimes deficient. The report should be complete, well written and professional. The report conclusions should logically follow from the findings, which should be derived from the observations and research. Appropriate Figures, References and Assessor Qualifications should also be included.
Bill Leedham, P. Geo., CESA
Bill is the Head Instructor and Course Developer for the Associated Environmental Site Assessors of Canada (www.aesac.ca); and the founder and President of Down 2 Earth Environmental Services Inc. You can contact Bill at email@example.com.