CSAP ORIENTATION FOR NEW MEMBERS

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Presentation transcript:

CSAP ORIENTATION FOR NEW MEMBERS 2017

Important document to review in detail located on the CSAP Website Make a Submission CSAP Practice Guidelines Performance Assessment Guidelines Submission screening Annotated SoSC Getting Started

Making Your First Submission Is the submission eligible for P6 ? Understand the AP’s role Understanding “arm’s length”

Is the submission eligible for P6? P6 is intended for low to moderate risk sites. P6 submissions for High Risk sites (classified under P12) require approval from the MoE A Director’s approval is required before the submission of a legal instrument application which would use any of the approaches listed in Table 2. Entire extent of the area of contamination would not be delineated and/or remediated. AG 15 provides guidance on the process and supporting documentation for applications to the Director for approval

Is the submission eligible for P6? Background substance concentrations. Approvals are required under P4 (background substances in soil) or P9 (background substances in water) Orders (eg., Remediation Orders, Pollution Prevention Orders) Risk assessments which include: de novo derivation of toxicity reference values. derivation or use of a site-specific risk-based concentration.

Understanding the AP’s role Acting as a surrogate for MOE Responsible for the instrument recommendation Responsible for confirming P6 Eligibility Responsible for assessing the adequacy of underlying investigations Best if not directing investigation (required for arms length submission)

“Who does what” in a detailed risk submission Numerical Standards Approved Professional Check the role of a submitting numerical standards and risk APs in the CSAP Practice Guidelines Numerical standards AP relies on the risk AP’s review of the risk assessment Evaluate conclusions where professional judgement is used in site investigation Confirms submission is complete Confirms that the site investigations meet the requirements under the CSR Risk-based Standards Approved Professional Check the role of a submitting risk AP and numerical standards AP in the CSAP Practice Guidelines Risk AP relies on the standard AP’s review of DSI Evaluate conclusions where professional judgement is used in risk assessment Confirms submission is complete Confirms that risk assessment meets requirements under CSR http://csapsociety.bc.ca/members/practice-guidelines/ “Who does what” in a detailed risk submission

Understanding Arm’s length MoE Procedure 8 defines Arm’s Length Review (a) the Approved Professional performing the review and any person involved in the preparation of the reviewable document did not directly supervise or report to the other either at the time the reviewable document was prepared or at the time of the review, and (b) the Approved Professional performing the review did not participate in the preparation of the reviewable document nor give any instructions as to its preparation except through the issuance of general guidance regarding the approach and methodology to be used in relation to the preparation of that document.

Understanding Arm’s length MoE Procedure 3 (Table 1) outlines the type of applications requiring arm’s length review by AP’s CSAP has developed a letter template for arm’s length review http://csapsociety.bc.ca/members/practice- guidelines/

Organizing the Submission Use the spreadsheets in the practice guidelines  Use the annotated version of the SoSC Submission transmittal letter Getting the stand alone document right A well-organized submission will decrease the amount of time and effort required for CSAP to conduct administrative screening, detailed screening or a Performance Assessment. Organizing the Submission

What happens at CSAP when a submission is received? All submissions are subject to administrative and detailed screening. Become familiar with the screening sheets posted to the CSAP website http://csapsociety.bc.ca/members/guidelines/submission-screening/ What happens at CSAP when a submission is received?

What happens at CSAP when a submission is received? Administrative Screening Reviews simple administrative detail Is the Schedule A map correct? Is the site description correct and consistent? Are all the necessary documents included? Does it meet MoE requirements? If your submission is randomly selected (ratio: 1:8) for a performance assessment you will be notified within 3 working days. What happens at CSAP when a submission is received?

What happens at CSAP when a submission is received? Detailed Screening Reviews submission to determine compliance with Procedure 12: Procedures for preparing and issuing contaminated sites legal instruments Review of instrument, Summary of Site Conditions and supporting documents, but not technical documents Detailed Screener communicates directly with submitting AP to resolve questions What happens at CSAP when a submission is received?

What happens at CSAP when a submission is received? Detailed Screening Note: if the detailed screening process results in unresolved issues, the submission will be forwarded to the PAC. The PAC appoints a Delegated Member (DM) to review the submission documents including the technical reports, if required If the DM’s review cannot resolve the issues, a non-random Performance Assessment may be initiated. Detailed Screening Lessons Learned webinar available at: http://csapsociety.bc.ca/members/pd-webinars/ What happens at CSAP when a submission is received?

Detailed Screening Common Issues: Instrument template not properly formatted Review Procedure 12 and MoE released instruments available inside the CSAP submission manager for acceptable Schedule A Site Plan and location map format, Schedule B conditions and Schedule C format AG 11 not complete Review CSAP AG 11 template DW doesn’t apply Insufficient scientific rationale provided to support exemption from DW – use annotated SoSC Detailed Screening Common Issues:

Performance Assessment How a Performance Assessment Works Performance Assessment

Two types of Performance Assessments Random PA’s are conducted on 1:8 submissions Non-random PA’s Resubmission of deficient submission Unresolved issues from detailed screening Requested by the Ministry or CSAP Board Two types of Performance Assessments

The PA is completed by a Panel and Delegated Member(s) Numerical Standards-based PAs consist of a DM and 2 panel members Detailed Risk-based PAs consist of 2 DMs (1 risk and 1 numerical standards DM) and 4 panel members (2 risk and 2 numerical standards) The PA is completed by a Panel and Delegated Member(s)

Steps in the PA process Getting Started AP notification – does your disc contain all the submission files? large maps or other items difficult to read electronically should be provided in hard copy Administrative issues, if any – need to be resolved PA under way Submission files are added to the PA drop box for easy access by the PA DM(s) and panel members The DM conducts the detailed screening and provides findings to the panel members Steps in the PA process

PA selected - submission randomly selected for a PA Steps in the PA process Re-submission Possible Outcomes STAGE 1 Reports FINAL FINDINGS Meeting with DM & panel Deficient Sufficient Finalized additional information Additional information required Sufficient Appeal MoE MoE Draft additional information

Steps in the PA process – Stage 1 Reports PA Timelines for Stage 1 Findings: 10 days for a Numerical Standards PA 15 days for a Risk based PA Possible outcome - sufficient finding or requires additional information If additional information is required the submitting AP has 2 months to submit an addendum The PAC strongly recommends that the submitting AP meet with the DM(s) and panel to review a draft addendum before finalizing. Meeting to be requested within 1 month of Stage 1 Findings Steps in the PA process – Stage 1 Reports

Why? Interpretation, is a big factor in AP work and it is important to make sure that everyone is on the same page. Meeting with the DM and panel members provides an opportunity to explain rationale and seek clarification APs can revise their addendum before finalizing to ensure that the appropriate information is brought forward. ?

Steps in the PA process – Final Findings Final Addendum is reviewed according to PA Guidelines Table 1: Process Clarification Chart. PA Timelines for Final Findings: 10 days for a Numerical Standards PA 15 days for a Risk based PA Main Considerations – Does the addendum information support the original conclusions Is the scope of additional work limited compared to the original scope Steps in the PA process – Final Findings

Steps in the PA process – Final Findings Possible outcomes - Sufficient or Deficient findings Sufficient submissions - are sent on to the Ministry for final review and release of the instrument. - Submitting APs may be sent a “yellow letter” if their work is inconsistent with current standards of care. Deficient submissions – in order to obtain a certificate(s) the submission will require a re-submission that addresses the issues that triggered a deficient finding Note: A site that has received a PA deficient finding will be subject to a non random PA regardless of who makes the re-submission If a submission found deficient is re-submitted with in 6 months of the deficient finding the CSAP fees are reduced to 50% Steps in the PA process – Final Findings

Next steps when a PA is found deficient PAC informs the Discipline Committee when a submission under PA has been found deficient Discipline Committee reviews the DM letter outlining reason for deficient finding, PA Stage 1 and Final Findings reports, Addendum prepared by submitting AP(s), and APs submission history. The Discipline Committee Guidelines outline the process and list possible remedial measures, including an option to determine that remedial measures are not warranted. Next steps when a PA is found deficient Before we get started on the discipline process please keep in mind that since 2008, the number of deficient findings for PA’s has generally been one a year and never more than 3 per year!

Steps following deficient finding

Describe the remedial measures Remedial Measures may require the AP to undertake training and may include any of the following depending on the issues identified in the submission. No measures One or more submissions to be co-signed by another AP Mandatory PA Next submission 1 of the 2 next submissions Of the next 2 submissions Require the AP to rewrite the regulatory, numerical standards and/or risk assessment exams Suspension from CSAP 6 months or longer, as appropriate Other measures or a combination of the above measures Describe the remedial measures Remedial measures may require the AP to undertake training and may include any of the following depending on the issues identified in the submission

APs can appeal the PA findings The submitting AP will have a 7 day window to launch an appeal after receiving the PA Final Findings and a letter from the Discipline committee stating what measures will apply, if any.

Now that you’re a member Your membership will be up for renewal in 3 years (December 31st, 2019). You will need a min. of 30 PDHs per year totaling 150 PHDs within the 3 years. Please use the Submission Manager to submit your PDHs: http://csapsubmissions.com/ You will need a min. of 1 submission before your next renewal. Alternatively, members without a submission can write the Regulatory Exam to retain their membership. Now that you’re a member