Numerous incidents involving the release of contaminated soil into the environment have made headlines in recent years, highlighting significant gaps in the management of excavated soil during construction work in Quebec.
Numerous incidents involving the release of contaminated soil into the environment have made headlines in recent years, highlighting significant gaps in the management of excavated soil during construction work in Quebec.
Indeed, the common factor in most of the non-compliant projects sanctioned by the Ministère de l’Environnement et de la Lutte contre les Changements Climatiques (Ministry of the Environment and the Fight Against Climate Change, MELCC) involved a lack of traceability of excavated soils. The findings revealed that, without increased monitoring, determining the final destination of these soils once excavated proved difficult.
Through its regulation on the traceability of excavated contaminated soils, effective as of November 1, 2021, the MELCC will require the tracking of soil movement from the excavation site to its final destination to regulate the management of contaminated soils and prevent their illegal disposal.
The Traces Québec software will serve as the platform through which soil traceability will be conducted.
Relevant parties will have, among others, the following roles and responsibilities in the traceability process of excavated soils:
Property owner
- Provide soil characterization data for the soils to be excavated (chemical analyses and concentrations according to the MELCC Guide – criteria “A, B, C”);
- Pay the platform usage fees (invoiced directly to the owner by the MELCC).
Contractor/Transporter
- Ensure that truck drivers/transporters possess cellphones capable of using the mobile application and allowing real-time GPS tracking for traceability;
- Collaborate in the environmental monitoring of excavated soil layers and the sorting of different soil types and contamination levels.
Soil disposal site
- Register in the system and confirm authorization to receive soils in accordance with MELCC requirements;
- Confirm receipt of the transported soils;
- Document the quantities of disposed soils by weight.
External certifier
An authorized external representative oversees and certifies that all contaminated soils excavated as part of the project have been documented with a tracking form registered in Traces Québec.
The contractor responsible for the work must not underestimate the planning required for such traceability prior to beginning soil loading operations.
Clear communication and strong preliminary coordination among the parties listed above pave the way for success by helping prevent work stoppages, penalties, and other project-related setbacks. Despite the efforts involved in implementing the regulation, keeping the primary objective in mind remains essential: protecting against unauthorized disposal and other environmental disasters as part of a sustainable and responsible approach to resource development.
The MELCC has provided the following explanatory overview outlining the traceability process:
