1. CSAP ORIENTATION FOR NEW MEMBERS
2017

2. 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

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

4. 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

5. 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.

6. 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)

7. “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
“Who does what” in a detailed risk submission

8. 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.

9. 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 guidelines/

10. 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

11. 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
What happens at CSAP when a submission is received?

12. 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?

13. 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?

14. 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:
What happens at CSAP when a submission is received?

15. 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:

16. Performance Assessment
How a Performance Assessment Works
Performance Assessment

17. 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

18. 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)

19. 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

20. 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

21. 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

22. 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. ?

23. 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

24. 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

25. 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!

26. Steps following deficient finding

27. 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

28. 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.

29. 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:
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