Step 7: Develop Risk Management Strategy

Navigate between each steps Step 1: Site Identification Step 2: Historical Review Step 3: Initial Testing Program Step 4: Initial Site Classification Step 5: Detailed Testing Program Step 6: Site Reclassification Step 7: Develop Risk Management Strategy Step 8: Implement Remediation/Risk Management Strategy Step 9: Confirmatory Sampling Step 10: Long-Term Monitoring

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. FCSAP DFO expert support concerns usually pertain to how the risk management strategy will impact fish and fish habitat and the sustainability of aquatic ecosystems. 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 fish, fish habitat, and aquatic ecosystem information;
    • 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 risk management options.
  • Conduct a site visit, if needed, to address specific issues.

What to Do

  • Follow planning guidance in the Measures to Avoid Causing Harm to Fish and Fish Habitat
  • Evaluate applicable remediation technologies with the goal of reducing impacts to fish and fish habitat.
  • Conduct:
    • an analysis of the risk management options (e.g., technical evaluation of remedial options to ensure applicability and effectiveness, a cost-benefit analysis, etc.);
    • public information sessions.
  • Develop and prepare documentation needed to develop a comprehensive RMS, for example:
    • Phase III Environmental Site Assessment (ESA), if not already completed;
    • Ecological Risk Assessment (ERA);
    • Remedial Action Plan (RAP);
    • confirmatory sampling plan;
    • site-specific monitoring plans;
    • Environmental Management Plan (EMP);
    • plans for the construction/installation of any physical works (e.g., design, timing, mitigation measures, associated temporary structures, erosion control, 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 and supporting information 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) that may lead to more effective and/or cost-efficient results.
  • With the goal of protecting fish and fish habitat and aquatic ecosystem sustainability, review and provide advice on:
    • draft Remedial Action Plan (RAP) or Risk Management Plan (RMP);
    • remedial strategy to ensure coherence with broader DFO initiatives;
    • draft Environmental Assessment (EA) and supporting documentation;
    • draft Ecological Risk Assessment (ERA);
    • plans for physical works, undertakings or activities;
    • mitigation, monitoring, and contingency plans.
  • DFO expert support will provide advice to facilitate coherence/compliance with:
    • broader DFO initiatives; and
    • relevant regulatory requirements.
  • Participate in site visit(s) (if specific issues are identified).
  • Identify appropriate contacts within DFO for further assistance.
  • 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.
  • Provide access to training and resources for ERAs (e.g., the FCSAP Ecological Risk Assessment Guidance: Module 4 – Causality Assessment)

Supporting Documents

Next Step: Implement Remediation/Risk Management Strategy