Notice

On June 29, 2012, the Fisheries Act was amended. Policy and regulations are now being developed to support the new fisheries protection provisions of the Act (which are not yet in force). The existing guidance and policies continue to apply. For more information, see Changes to the Fisheries Act.

Step 7: Develop Risk Management Strategy

A Risk Management Strategy (RMS) specifies the remedial or management actions that will reduce the levels of, and exposure to, bioavailable and toxic contaminants so that existing or potential risks to humans and the environment are rendered acceptable. DFO concerns usually pertain to the impacts of the risk management strategy to fish and fish habitat that support fisheries. Information obtained as part of the site classification process is used to assist in developing a site-specific RMS, which typically, but not always, includes remediation. The RMS is then implemented in Step 8.

How to Prepare

• Review:
  • information from Steps 3 and 5;
  • resource management plans;
  • relevant information about aquatic species listed under the Species at Risk Act (SARA), including recovery strategies, action plans, and management plans;
  • the Conceptual Site Model (CSM) and refine if required.
• Examine available remedial options.
• Complete site visit to address specific issues.

What to Do

• Follow planning guidance in the Working Near Water Operational Statements
• Evaluate applicable remediation technologies with the goal of reducing impacts to fish and fish habitat.
• Conduct:
  • an analysis of the remedial options (e.g., technical evaluation to ensure applicability and effectiveness, a cost-benefit analysis);
  • public information sessions.
• Develop and prepare:
  • Phase III Environmental Site Assessment (ESA);
  • Ecological Risk Assessment (ERA);
  • Remedial Action Plan (RAP);
  • confirmatory sampling plan;
  • site-specific monitoring plans;
  • Environmental Management Plan (EMP);
  • plans for any physical works (e.g., mitigation measures, construction or installation of structures in or near water, etc.);
  • contingency plans for accidental events;
  • plans for the management of waste materials/products.
• Identify opportunities for restoration and enhancement of fish and fish habitat.
• Submit project details to Fisheries and Oceans Canada (DFO) expert support for review.
• Apply for a Fisheries Act authorization and SARA permit, if necessary.

How Fisheries and Oceans Canada (DFO) Expert Support Helps

• Provide input and advice on risk management options (including remediation and mitigation measures).
• To ensure activities on-site are compliant with DFO's regulatory requirements and mandate to protect fish and fish habitat that support fisheries, review and provide advice on:
  • draft Remedial Action Plan (RAP) or Risk Management Plan (RMP);
  • remedial strategy to ensure coherence with broader DFO initiatives;
  • SARA recovery strategies, action plans, and management plans to ensure compliance with the SARA-listed aquatic species or particular harvested aquatic species;
  • draft Environmental Assessment (EA) and supporting documentation;
  • draft Ecological Risk Assessment (ERA);
  • plans for physical works and undertakings;
  • mitigation, monitoring, and contingency plans.
• Participate in site visit(s) (if specific issues raised).
• Identify appropriate contacts within DFO.
• Provide support to the public engagement process.
• Provide advice to custodians in the development of terms of reference for contracts to prevent or mitigate potential impacts to fish and fish habitat that would be associated with testing or risk management/remediation programs.

Supporting Documents

• Canadian Environmental Assessment Act
• Canadian Environmental Assessment Agency
• Contaminated Site Remediation Projects Roadmap
• FCSAP Ecological Risk Assessment Guidance
• FCSAP Guidance Document on Statements of Work for Ecological Risk Assessments at Federal Sites
• FCSAP Site Closure Tool & Guidance
• Fisheries Act
• Guidance and Orientation for the Selection of Technologies (GOST)
• Interdepartmental Recovery Fund
• Pathways of Effects (PoE)
• Proponent's Guide to Information Requirements for Review Under the Fish Habitat Protection Provisions of the Fisheries Act
• Species at Risk Act (SARA)
• Terms and Concepts Used in the Species at Risk Program
• Working Near Water: Operational Statements
• Working Near Water: What You Need To Do