THE BOTTOM LINE ON RISK ASSESSMENTS AS USED AND ABUSED IN ELMIRA, ONTARIO

I've been attending Webinars (on-line seminars) on Risk Assessments being put on by Woolwich Township's TAG (Technical Advisory Committee) committee. To date I've personally "attended" two of the three Webinars and I've received "Slide Decks" i.e. a written paper copy of the slides presented in the Webinars for them. In my opinion the content of the Webinars has been excellent. Yes I would have preferred live seminars or live delegations versus on-line ones but hey we are still in the midst of the Covid-19 pandemic so certain adjustments have become necessary. I may not like it but I am not yet convinced that they are not worthwhile.

What has impressed me is the extent of detail involved in these risk assessments. I am coming to believe that there may well be a place for these efforts in the scheme of environmental cleanups if they produce better cleanups, not the opposite. There are a host of generic criteria for soil, sediment, ground and surface water including chemicals, metals, radiation, and more. These generic criteria are based upon scientific evidence and risk assessments for the purpose of watering down or minimizing these criteria do not make sense to me. On the day of doing a walk around by a biologist looking for evidence certain sensitive species are using the site in question and then not finding that evidence, should not be an excuse/rationale for loosening or elevating the criteria. Just because carp can survive in horribly contaminated surface water and trout can not is not a valid reason to say oh well the generic criteria is too strict. There aren't trout here today so we don't need to clean up the water. Similarly if a certain very sensitive local mammalian species is not present is not a reason/rationale to suggest that strict generic soil criteria for mercury or polyaromatic hydrocarbons etc. should not be enforced. Not only are those sensitive species likely not currently present because of the existing contamination but that does not preclude them in the future from using the site for habitat particularly if the most offensive and obvious pollution has been somewhat diluted. They may still be at risk.

Above and beyond the issue of receptors being present as just discussed is the issue of gross conflict of interest. What would you think about a committee being formed in Parliament to determine whether the governing Liberal party violated ethics in the current alleged WE scandal? How about if membership of this committee was limited to only Liberal backbenchers? Do you have confidence that the investigation would be professional, honest and defensible? I don't.

What if a major supplier to SNC Lavallin was given the duty and responsibility to determine if their customer should be charged with corruption (bribery) in overseas markets? Do you think that this supplier would be prepared to jeopardize their profitable business arrangement with SNC Lavallin by adhering scrupulously to the standards required for an honest determination? Obviously the supplier should never be put into this situation. Only an independent investigation with no conflicts of interest of any kind should even be considered.

Conestoga Rovers & Associates (CRA) literally have had millions of dollars of business from Uniroyal Chemical and their corporate successors (Crompton, Chemtura, Lanxess Canada)over the decades. CRA were purchased by GHD who have continued on in CRA's efforts to minimize remediation costs for their client Lanxess. Indeed I would suggest that that is the primary purpose of most environmental consultants i.e. find creative ways to find cheaper options to allegedly achieve the same result. Personally I believe that you get what you pay for and that creative cleanup is not always good cleanup. But hey that's just me. In a nutshell should GHD be the company to manage a Site Specific Risk Assessment for Lanxess Canada? Of course not. We went through that crap back in about 2004 with CRA doing so for Crompton and it was a crock. Greenwashing at its best. THis is the ongoing nonsense and scam in some Canadian environmental cleanups. You do not get a good result when the fox is in charge of security for the henhouse. Why would any honest person ever think that they would get an honest, scientifically defensible result?