‘Traces’ contaminated soil tracking takes effect in Quebec

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The on-site manager can use a tracking slip to enter the soil information into the Traces online system. The soil can then be weighed and transported to an authorized receiving location, treatment centre, burial or reclamation site, which will also file into the Traces system to accept the load. Photo credit: Artinun, stock.adobe.com

Keeping tabs on project-site contaminated soil in Quebec is now mandatory under the Traces Quebec system.

To comply with regulations and track all movements of the some 3 million metric tons of contaminated soil excavated in the province each year, businesses or project managers must create an account with Attestra to report through its web portal.

As of 2023, registration with Traces Québec is mandatory for all stakeholders covered by the Regulation respecting the traceability of excavated contaminated soil.

Fees per metric ton for the custody of the soil are applicable under the regulation’s fee structure. Fees of $2 per ton now apply to any quantity of contaminated soil.

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The program has been phased in since 2021 and gradually lowered the thresholds to trigger fees. Initially, Traces only charged projects that transported 5,000 metric tons from its land of origin, and a year later lowered that to 1,000 metric tons. The intent initially was to only target large-scale construction sites where “the risk of illegal management was high,” stated Quebec Environment officials.

The program is designed to discourage illegal dumping and counteract potential spills of contaminated soil.

The on-site manager can use a tracking slip to enter soil information into the Traces online system. The soil can then be weighed and transported to an authorized receiving location, treatment centre, burial or reclamation site, which will also file into the Traces system to accept the load. The soil’s location is tracked through GPS monitoring to ensure proper transport. A final traceability report is then generated by the system.

“The method of management and the place of destination of excavated contaminated soil are mainly determined by its level of contamination,” states the province’s good practices guide, translated from French. “As soon as soil is identified as contaminated and the contamination is quantified, its management must be prepared by choosing service providers for excavation, transport and reception.”

Carriers of contaminated soil must be members of the Quebec Trucking Association or the National Association of Artisan Truckers Inc. Upon arrival, the potential contaminants and minimum and maximum concentrations of the load must also be recorded.

Article 16 of the Quebec regulation aims to create some separation between the party which owns the soil and the process of reporting and transporting the soil. Essentially, the regulation is creating accountability beyond a single party to avoid any fraudulent management or practice around the soil.

The new Quebec process is similar to the soil registry system developed in Ontario, spearheaded by the Resource Productivity and Recovery Authority.

Related Professional Development Course

Attend “Excess Soils and Contaminated Sites: The new rules” on May 10th at the 2023 CANECT Environmental Compliance and Due Diligence Training Event to learn more about contaminated sites and Ontario’s new excess soils regulation. event takes place May 9-11, 2023 in Vaughan, Ontario. Visit www.canect.net for more information.

This article appears in ES&E Magazine’s April 2023 issue:

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