Regulatory Update: Stage 10 (Omnibus) and Stage 11 Amendments to the BC CSR

Dec. 4 2017

After a one year transition period, the Stage 10 (Omnibus) Amendments followed by the Stage 11 (Housekeeping) Amendments to the British Columbia Contaminated Sites Regulation (BC CSR) came into force on November 1, 2017. The amended regulation provides updated soil, water, sediment and vapour standards that reflect current science.

In addition, the amended regulation:

  • Identifies new triggers for soil relocation from sites undergoing remediation
  • Aligns the Contaminated Site Regulation with BC’s Hazardous Waste Regulation and Organic Matter Recycling Regulation
  • Introduces a five (5) year review cycle

These amendments make the BC CSR unique in the Canadian regulatory framework in that the regulation contains soil, water, sediment and air standards for upwards of 600 compounds. Over half of these compounds are not regulated elsewhere in Canada or the US. Prior to the amended regulation, there were specific lists of soil and water standards for a relatively short list of compounds (Schedules 4 and 7) which were the standard monitoring lists provided by BC laboratories. In addition there was a more comprehensive list (Schedule 10) of hazardous chemicals, which were rarely requested. Under Stage 10, there has been no such differentiation and to this point, laboratory analyses to support remedial activities in BC are based on the discretion of the Contaminated Site Approved Professionals (CSAPs).

Throughout the development of the regulation as well as its implementation, Bureau Veritas has been very active in its advocacy on behalf of the environmental industry in BC. In particular, Bureau Veritas’ participation in the British Columbia Environmental Laboratory Advisory Committee (BCELTAC), helped establish laboratory best practices to measure the contaminants of concern.

Dr. Barry Loescher, Bureau Veritas’ Quality Systems Specialist, and long-standing member of the BCELTAC, headed Bureau Veritas' efforts in the writing of seven new methods including the new leach procedure, demonstrating our ongoing commitment to good science and scientific advancement.

An important change associated with these amendments is the addition of specific “emerging contaminants” of environmental concern to the schedules of soil, water and air standards. BC becomes the first jurisdiction to regulate these compounds rather than simply providing provisional guidelines in environmental matrices.

Analytical Capabilities

Bureau Veritas’ network of analytical laboratories currently offers all of the new and amended BCELTAC methods. Specific new compounds identified as emerging contaminants are highlighted in Table 1.

Particularly significant for the BC environmental marketplace, is the development of new methods for liquid-solid partitioning (leachability) as a function of pH for metals, inorganics, and semi-volatile organic compounds (SVOCs), as well as liquid-solid partitioning (leachability) of volatile organic compounds (VOCs).

Table 1

17α-Ethinylestradiol (EE2) Water Liquid Chromatography/Tandem Mass Spectrometry (LC/MS/MS) Performance-based
Asbestos Soil Polarized Light Microscopy (PLM) Performance-based
Asbestos Water Transmission Electron Microscopy (TEM) Prescriptive
Diisopropanolamine (DIPA) Soil and Water Liquid Chromatography (HPLC) Performance-based
Nonylphenols and Ethoxylates Soil and Water Liquid Chromatography/Tandem Mass Spectrometry (LC/MS/MS) Performance-based
Perfluoroalkyl Substances (PFAS) Soil and Water Liquid Chromatography/Tandem Mass Spectrometry (LC/MS/MS) Performance-based
Sulfolane Soil and Water Gas Chromatography/Flame Ionzation Detection (GC/FID) Gas Chromatography/Mass Spectrometry (GC/MS) Performance-based