Environmental Guide for Federal Real Property Managers

The Canadian Environmental Assessment Act (CEAA) states that a construction project must be assessed for its effects on the natural environment at the earliest possible stage in the delivery process, and before any irrevocable implementation decisions are made. This requirement applies to all new buildings and, in some cases, to an alteration to an existing building.

Regardless of any legal requirements, public concern for the natural environment may be such that a public information session related the proposed construction is advisable in this case. An environmental assessment with reports - such as a financial analysis, space requirement studies, changed use demands or building condition reports - will be useful.

For new buildings, if the required environmental assessment can be completed before the programming and design of the project is finalized, the design must allow for measures to mitigate identified conditions that may threaten the natural environment.

The programming and design of the project should allow for a monitoring program. The CEAA requires a monitoring program to respond to the anticipated impact of the project's construction or operation on the natural environment and to determine the effectiveness of mitigation measures.

If the monitoring process shows that the mitigation measures are not as successful as expected, then the organization must devise more effective mitigation measures. This program is to be implemented early in the construction phase of the project and will sometimes proceed into the operation phase of the project.

With continuing government reorganization and review, property renovation, restoration, alteration, extension and reconstruction are becoming increasingly more important aspects of property management. The issues for renovation and reconstruction projects are similar to those for new construction.

For renovation or reconstruction projects, the CEAA requirements for an environmental assessment are limited by the scope of the project and its impact on the existing structure. A building or facility 'footprint' is the area occupied at ground level by that building and its ancillary structures, such as loading docks, covered access ways and connecting passageways. If the renovations or reconstructions do not increase the building footprint or height by more than 10 per cent, are not carried out within 30 metres of a body of water and do not involve the release of polluting substances into a water body, then no assessment is required under the CEAA. This is not to say that some form of environmental assessment will not be useful. It is always good environmental management practice to undertake an assessment to identify the likely effects of the project.

If the renovation or reconstruction project will result in an increase of greater than 10 per cent in the footprint or height of a building, will be carried out within 30 metres of a body of water or will involve the likely release of polluting substances into a water body, the CEAA will apply. Any mitigation measures identified in the assessment should be incorporated in the programming and design of the project and the management of its delivery. A more comprehensive description of the CEAA and its associated regulations is presented in the 'Planning' chapter.

To meet the commitment of the federal government to the philosophy of sustainable development, the project should be energy efficient and should use materials and methods effectively in order to preserve nature, including protected and endangered species and their habitat.

2. Guidance

The programming and design of a construction project can be an intricate and demanding task, proportional to the size and complexity of the project. It may involve a team of many professional designers and managers of various disciplines and backgrounds.

However, no matter what the size and complexity of the project, there will be opportunities to make choices between various alternatives with significant environmental implications.

When considering implementing any project, organizations should consult experienced design professionals, such as architects, engineers and other specialists, early in the delivery process, and invoke the principles of responsible environmental design. Environmental assessment specialists should be working co-operatively with the design team right from the start of the design process.

If the environmental assessment has recommended mitigation measures, the organization must implement these measures to avoid any significant adverse environmental effects. These measures may relate to the actual facility design, such as measures to modify the design to reduce the unwanted effects of wind deflection. Or they may relate to the construction process, such as measures to protect a specific habitat during construction activities.

An organization should also include a monitoring program in the design and management process, to measure the effectiveness of the mitigation measures. This program will continue through the commissioning, occupation and facility operation phases of the project. The measures implemented for effective mitigation must be sufficiently flexible to permit the organization to incorporate alternative mitigation measures into the process if the monitoring program demonstrates that the original measures are not totally effective.

Organizations must address many subjects before and during the programming, design and construction process, including the following:

the feasibility of, and the need to implement, the project;
the facility location and siting options available;
the predictable effects of their activities on land, water, air, and protected or endangered species of animals or vegetation;
buffer zones, sensitive areas and noise abatement;
the required integration with local services, such as power, communication, fuel, water supply, drainage and sewage systems;
erosion prevention and dust control;
any alternative design possibilities;
the design's energy efficiency;
mechanical systems, including heating, ventilation, cooling, plumbing and fire suppression systems;
the design of lighting, power distribution, emergency power supply and communication systems;
interior design, including finishes, furnishing and equipment;
construction schedules, which should take into account periods when the environment is particularly sensitive;
access to and from the site of the facility, and the effect on local traffic;
equipment movement on land and over water;
the effects of vegetation clearing, grubbing, stripping and disposal;
methods of excavation, trenching, formation of embankments and grading;
dredging and disposal of dredged material;
the effects of site drainage, de-watering and water in-fill operations;
drilling on land and over water;
the management of solid waste disposal;
the use, handling, storage and disposal of petroleum, oils, lubricant and hazardous materials;
the use of quarrying and burrow pits;
aggregate handling and storage; and
measures and a monitoring program for mitigation.

For buildings that are to be altered, organizations should determine whether the planned renovation or reconstruction will

If none of the conditions mentioned above occur, the project is excluded from assessment under the CEAA. If one or more of these conditions are met, the organization must assess the project for its impact on the natural environment.

In making environmentally sensitive design and specification decisions, and in an effort to achieve sustainable development, organizations should consider

using products that minimize the use of original resources and energy, generate as little waste as possible and maximize the recovery of useful surplus reusable materials;
using products that require less energy to extract, manufacture, ship, assemble and install than others;
eliminating products that use tropical hardwoods or other rare or endangered tree species;
using products or construction methods that minimize the use of sealants, adhesives and finishes that produce high levels of volatile organic compounds (VOCs);
using products or types of equipment that do not contain or use chlorofluorocarbons (CFCs) or polychlorinated biphenols (PCBs); and
using space dividers and other components that can be disassembled and reassembled for reuse when accommodation needs change.

This list is not exhaustive, but it does illustrate the general character and range of the issues an organization should address when undertaking a design to ensure that the design permits enhanced environmental performance.

Under environmental legislation, the property owner is usually responsible for compliance with regulations. The property owner may not be directly involved in an activity that results in an infraction, such as an infraction caused by a contractor working under the direction of a project manager. However, the owner may be held responsible if it cannot show that it exercised due diligence in maintaining its mandate, and that it ensured that proper procedures to protect the natural environment were defined and followed.

Requiring suppliers to reduce packaging when shipping, to ship in bulk or in reusable containers where possible, or to take back packaging material also reduces the environmental impact of the construction process.

3. References

Regulations
Law List
Inclusion List
Exclusion List
Comprehensive Study List
Regulations Respecting the Coordination by Federal Authorities of Environmental Assessment Procedures and Requirements
Federal Authorities Regulations

This Act, with its first four regulations, was proclaimed into law on January 19, 1995, and replaces the Environmental Assessment and Review Process Guidelines Order of 1984.

Since the CEAA is law, the process outlined by the Act must be followed. The purpose of an environmental assessment under the CEAA (in most cases, an environmental screening) is to evaluate the negative and positive environmental implications of a proposed project before irrevocable decisions to implement the project are made.

While there are no penalties incorporated into the CEAA legislation, failure to conduct the required assessment could lead to a court order forcing the proponent to stop the execution of the project until a CEAA assessment is completed.

The CEPA was proclaimed into law in 1988 and is designed to protect Canadians from pollution caused by toxic substances. It provides the power to regulate the entire life cycle of toxic substances.

A person whose property is affected by the release of a toxic substance in contravention of the CEPA regulations has to report the matter to an inspector.

Costs related to measures to stop further release may be recovered against the landowner to the extent of the owner's negligence in contributing to the release.

Also, if contamination is occurring on a property, there is the potential for liability, even if that property has just been acquired and the contamination occurred before the acquisition. Penalties for an infraction under the CEPA can be as severe as fines of $1,000,000 per day and/or imprisonment for five years. When a person in contravention of the Act "shows wanton or reckless disregard for the lives or safety of other persons and, thereby, causes bodily harm or death,"that person may be prosecuted under the Criminal Code.

There is no general requirement for an environmental emergency plan under the CEPA. However, the Storage of PCB Material Regulations does require organizations to put fire protection and emergency procedures in place for PCB storage facilities.

The Fisheries Act is concerned with the protection of fish and fish habitat, and people's use of fish. Any activity or physical work that may or does negatively affect any of these can result in charges being laid under the Fisheries Act.

The Fisheries Act has penalties for violations of the Act, including requirements to repair damage to habitat, substantial fines and/or prison terms with a criminal record. Convictions for multiple offences involving introducing deleterious substances into fish habitat can be as severe as fines of $1,000,000 per day and/or three years in jail.

The Migratory Birds Convention Act commits Canada to protecting the special habitats and spaces used by migratory bird species in North America. The Act prohibits the deposit of "oil or oil wastes or any other substance harmful to migratory birds, in any waters or any areas frequented by migratory birds." Mitigation measures must be incorporated into any project that may cause this result.

The Navigable Waters Protection Act requires approval for any work that may affect navigable waters, which are defined as "a canal and any other body of water, created or altered as a result of the construction of any work."This general definition means that any water body is covered by the Act if it can be navigated by any type of watercraft, from a canoe to an ocean liner.

Fisheries and Oceans (FO) will grant approval only if the project has been assessed environmentally and has obtained a satisfactory screening decision from FO. Without a permit, the project cannot proceed. Failure to comply with the Act may result in a court injunction against continuing with the project, granted either to FO or to an interested third party.

Transportation of Dangerous Goods Act (TDGA) and Transportation of Dangerous Goods Regulations

To control the transportation of dangerous goods by air, sea, rail and road in order to promote public safety and protect the environment during transport, the TDGA was proclaimed in 1980. The Act and regulations require clear identification of dangerous goods under one of nine categories; proper containers and packaging; and training for employees shipping, receiving and transporting dangerous goods. The Act does not cover waste products, which are covered by separate legislation.

This list is not exhaustive. However, it indicates the variety and extent of federal legislation and policy positions that may affect the design and construction of a facility.

To ensure a comprehensive review of the legislative and regulatory requirements affecting a project, organizations should consult an environmental assessment specialist early in the planning process.

It is government policy to acquire, use and dispose of real property in a manner consistent with the principle of sustainable development. The Government of Canada has also made a commitment to implement a code of environmental stewardship, which affects some aspects of real property management.

Model National Energy Code for Buildings, Natural Resources Canada, Office of Energy Efficiency

Public Works and Government Services Canada, March 1996
To order: e-mail : doc.centre@pwgsc.gc.ca, fax (613) 736-2029

This text base, devised as a master construction specification, will be used as a basis for contract documents for federal construction projects. It contains references to environmentally friendly methods and materials for construction and disposal

Construction

1. Environmental Considerations

1.(a) New Construction

New construction undertaken by a federal organization that is listed in Schedule I or II of the Financial Administration Act will be governed by the Canadian Environmental Assessment Act (CEAA). Consequently, construction works and methods are subject to CEAA requirements.

If the final design of the facility has met the requirements of the CEAA as outlined in the 'Design' chapter, the management of the construction phase of the project should also meet these requirements.

In most cases, the proposed facility will be constructed in accordance with the approved bid documentation for the final project design. However, in some cases, an organization may issue addenda during the bidding process or modify the scope of the construction contract using approved change orders during construction.

For construction projects, organizations should address issues related to the federal government's commitment to sustainable development. These include matters such as reducing resource use, reducing waste generated by the federal government and its activities, creating efficient and effective design, using energy efficiently, and preserving special natural spaces, as well as any protected or endangered species. Refer to the 'Guidance' section of this chapter for details.

When a government organization owns a property, many pieces of environmental legislation hold this owner ultimately responsible for ensuring that the requirements of that legislation are met. Organizations should recognize these requirements and integrate them into the bid documents and construction contracts for the project.

Consult legal services staff to ensure that the clauses covering these matters, in addition to causing the implementation of the necessary protective practices, adequately protect the organization from environmental liabilities and possible prosecution.

1.(b) Renovation and Alteration

Any federal government department or agency that undertakes a renovation, restoration, alteration, addition, extension or reconstruction project that directly affects and alters an existing structure or building related to a facility must meet the requirements of the Canadian Environmental Assessment Act (CEAA). For additional information, refer to the Design section.

Renovation or alteration activities, as with any construction operation, may also be subject to the requirements of other federal legislation, such as the Migratory Birds Convention Act or the Fisheries Act. These pieces of legislation are put in place to preserve and maintain a clean and healthy natural environment. Sound project management will ensure that the activities undertaken in delivering the proposed project will not contravene the provisions of these Acts by introducing pollutants, including hazardous or toxic substances, into the environment.

The federal government aims to reduce its overall waste by 50 per cent of 1988 levels by the end of this century. To contribute to this goal, organizations should identify and examine their construction waste from an environmental management perspective.

Construction waste constitutes close to a third of all solid waste in Canada, and efforts to divert it from landfill sites will have a significant positive impact on the environment. It is important to select and separate types of solid waste at source, and to prevent contamination on site. To manage solid wastes effectively, an organization will provide separate waste bins for separate waste streams, and will educate construction crews in the benefits of participation. The other important task is to find receivers, recyclers and reusers for the waste at realistic costs.

The paragraphs under 'Construction of New Projects' in this chapter also apply to renovation and alteration work. However, when a building is altered, the main difference in the construction process is that dismantling and removals are carried out. Refer to the 'Demolition and Dismantling' chapter to find out more about the environmental concerns related to these activities.

2. Guidance

Constructing new buildings for facilities, or renovating or altering existing facilities, can be intricate and demanding undertakings, proportional to the size or complexity of the project. They may involve many skilled and experienced managers, expeditors, co-ordinators, tradespeople and professional consultants from a wide range of disciplines.

However, even relatively simple projects will present opportunities to make choices between various alternatives with significant environmental implications.

When undertaking a construction project, organizations should consult competent professionals - such as project managers, architects, engineers, technologists, specification writers, quantity surveyors, cost engineers and inspectors - early in the process, and invoke the principles of environmentally responsible project management and construction practices.

Environmental assessment specialists should be working with the entire project management team from the beginning of the process.

An organization must integrate measures to mitigate environmental hazards into the construction process and related practices. It must also monitor the effectiveness of these measures throughout the construction period and during the commissioning, occupation and operation phases of the project.

The mitigation measures must be sufficiently flexible to permit alternative measures to be incorporated into the process if the monitoring program shows that the original measures are not totally effective.

Among the subjects related to the construction process that organizations must consider for their environmental impact are the following:

the location, on site, of construction management facilities and services;
the predicted effects of their activities on land, water and air;
the protection of special, protected or endangered species;
buffer zones, protection of sensitive areas and noise abatement;
construction schedules, which should take into account periods when the environment is particularly sensitive;
access and the effect on local traffic;
the movement of equipment on land and over water;
the clearing of vegetation, including grubbing, stripping and disposal;
excavation, trenching, the formation of embankments and grading;
drainage, de-watering and water in-fill operations;
drilling, on land and over water;
dredging and disposal of dredged material ;
erosion prevention and dust control;
specifications for structural elements, envelope and exterior finishes;
mechanical systems, including steam/hot water, heating, ventilation, exhaust, cooling, plumbing, fire suppression, conveying and industrial processing systems;
power generation, transformer, distribution, lighting and emergency power supply systems;
connection and integration with local services, such as communication, power, fuel, water supply, drainage and sewage systems;
solid waste disposal;
the use, handling, storage and disposal of petroleum, oils and lubricants;
the use, handling, storage and disposal of hazardous materials;
the use of quarrying and borrow pits, as well as aggregate handling and storage;
the continued safe, effective operation of existing facilities closely affected by construction operations; and
required mitigation measures and a monitoring program.

To be environmentally responsible in the construction process, organizations should consider taking the following actions, if they have not already done so during the design and specification phase:

using products that minimize the use of original resources and maximize the recovery of useful surplus reusable materials;
scheduling construction activities and using procedures to minimize energy use as much as possible;
using construction methods that minimize the use of sealants, adhesives and finishes that produce high levels of volatile organic compounds (VOCs);
using products or types of equipment that do not contain or use chlorofluorocarbons (CFCs) or polychlorinated biphenols (PCBs);
eliminating products that use tropical hardwoods or other rare or endangered tree species; and
using mechanical fasteners that allow building elements to be disassembled and reassembled when accommodation needs change.

These matters should be discussed with the entire project team to maximize the efficiency and effectiveness of the construction program.

3. References

This Act, with its first four regulations, was proclaimed into law January 19, 1995, and replaces the Environmental Assessment and Review Process Guidelines Order of 1984.

The CEPA was proclaimed into law in 1988 and is designed to protect Canadians from pollution caused by toxic substances. It provides the power to regulate the entire life cycle of toxic substances.

A person whose property is affected by the release of a toxic substance in contravention of the CEPA regulations has to report the matter to an inspector.

Costs related to measures to stop further release may be recovered against the landowner to the extent of the owner's negligence in contributing to the release.

There is no general requirement for an environmental emergency plan under the CEPA. However, the Storage of PCB Material Regulations SOR/92-507 does require organizations to put fire protection and emergency procedures in place for PCB storage facilities.

The Navigable Waters Protection Act requires approval for any work that may affect navigable waters, which are defined as "a canal and any other body of water created or altered as a result of the construction of any work." This general definition means that any water body is covered by the Act if it can be navigated by any type of watercraft, from a canoe to an ocean liner.

Transportation of Dangerous Goods Act (TDGA) and Transportation of Dangerous Goods Regulations

To ensure a comprehensive review of the legislative and regulatory requirements affecting a project, organizations should consult an environmental assessment specialist early in the planning process.

Public Works and Government Services Canada, March 1996
To order: e-mail : doc.centre@pwgsc.gc.ca, fax (613) 736-2029

British Research Environmental Evaluation Method (BREEM), The Building Research Establishment

This text base, devised as a master construction specification, will be used as a basis for construction documents for federal construction projects. It contains references to environmentally friendly methods and materials for construction and disposal.

Commissioning

1. Environmental Considerations

Commissioning is the comprehensive process of verifying that a facility, and its systems, are designed and constructed in accordance with the construction contract documents and that it will function as the client, usually the owner, requires.

The process begins when the bid documents are virtually complete. It includes a systems risk assessment and a review of the approved, 90-per-cent completed technological design and specifications, along with related documents, such as the project manual. This process ensures that the documents, designs and specifications reflect the client's requirements, and that they effectively communicate these requirements to contractors and inspectors.

Once the construction contract is entered into, this process continues through the construction phase to ensure that the requirements described by the working drawings, schedules and specifications are properly executed, and that the resulting facility reflects the client's intentions.

Throughout the construction phase, commissioning is carried out using a systematic process of monitoring, testing, balancing, observing and recording observations. All of these activities are designed to transform the building systems from a static to a dynamic state of operation.

This testing applies first to individual components, and then to the integrated systems of the building or facility, such as the heating, ventilation and air conditioning systems; the plumbing and fire suppression systems; the electrical services; the communications systems; systems to detect fire or other hazards; the security and emergency response systems; the conveying systems, such as elevators, lifts and escalators; and the environmental impact monitoring system. Commissioning will continue after occupancy to ensure that all systems operate effectively under all anticipated conditions for at least a year and, in certain specified circumstances, beyond that.

The operation and maintenance conditions for the various individual and combined systems will be specific to the particular facility. The commissioning process must ensure that the property management staff is thoroughly familiar with these unique conditions.

To train staff effectively, the facility's chief of operations should work closely with the commissioning team from the day the first piece of equipment arrives at the construction site right through the construction process to occupancy.

This approach to training should extend to the entire operations and maintenance staff, with members brought into the commissioning process as the construction proceeds, until the entire staff has been included and the facility is ready for occupation.

In any complex facility, the primary integrated systems may be made up of many secondary and tertiary systems. To ensure that all the systems and subsystems operate as intended at their designed level of efficiency, a comprehensive program to monitor their performance is essential.

Before the design and construction team can turn over responsibility for running the building to the property and facility management team, it must compile complete documentation for the property managers. These documents include:

contract design documents, including drawings and specifications, and related inspection reports, including the environmental screening, environmental assessment and other specialized reports;
'as built' drawings, schedules and specifications of the facility and of its various systems and subsystems;
descriptive lists of materials, products and components used to construct the project;
energy efficiency reports;
response procedures for environmental and other emergencies;
performance reports from the commissioning process itself; and
operation and maintenance manuals, developed for the facility's systems and subsystems.

The environmental concerns at issue in the commissioning process are generally those that apply to the operation and maintenance phases of a facility. For more information, refer to the 'Operation and Maintenance' chapter. As well, the monitoring and mitigation measures described under 'Program Planning' and 'Project Planning and Site Selection' in the 'Planning' chapter may be relevant to the commissioning process.

2. Guidance

Activities that organizations should consider early in the design and commissioning stages include:

conserving energy by using more efficient mechanical and electrical systems;
improving indoor air quality for a healthier, more comfortable working environment;
selecting more durable systems for better performance on a life cycle basis; and
ensuring that systems are designed and constructed properly the first time so that the organization doesn't need to replace components or systems prematurely.

At the operational testing stage, the subsystems will be tested for the first time or, at least, for the first time as part of an integrated system. In that situation, the system as a whole may be more susceptible to failure. Care must be exercised to ensure that there are adequate procedures in place to deal with any toxic spills or excessive emissions that might occur.

Such procedures must be discussed with the property and facility managers, the project manager, and design consultants, inspectors, construction contractors, major installation trades and service suppliers, as well as the occupant representatives. This will ensure maximum awareness and co-operation during the commissioning process, and provide a sound basis for a continuing effective relationship throughout the extended post-construction and occupancy phase of the commissioning.

Interim commissioning reports should be made available at significant points of the project. These points include when the technological design is complete; when the bid documents are 90-per-cent complete; when construction is substantially finished; after the integrated systems have been tested; and the end of the commissioning process.

The property and operations management and their support staff must review these interim reports and the final report, as well as the operation and maintenance manuals developed during the commissioning process. Such reviews will familiarize them with the characteristics and performance standards of the facility, and help them focus on potential concerns and any future enhancements that may be developed.

3. References

Demolition and Dismantling

1. Environmental Considerations

It is sometimes necessary to demolish all or part of a structure or building that has served its purpose, and to remove that which is demolished. An organization can considerably mitigate the environmental impact of such work by carefully using dismantling and disassembly processes.

As part of its effort to reduce the amount of solid waste it generates, the Government of Canada is investigating opportunities to conserve and recycle building materials by dismantling or disassembling existing structures and buildings, rather than demolishing them. The solid waste generated during the demolition phase of these kinds of projects is a significant environmental issue.

Growing experience in North America indicates that dismantling can be more cost effective than the usual demolition approach, partly because it reduces the quantities of waste sent to landfills. Documented case studies in British Columbia, Ontario, New Brunswick (by CMHC) and Nova Scotia have demonstrated that organizations can divert a significant amount of waste, reducing landfill tipping fees and some costs for heavy equipment.

Considerable amounts of reusable and recyclable material can usually be recovered from buildings intended for demolition or major renovation.

Construction waste contributes almost one third of the solid waste being sent to landfill sites, with the products of demolition making up a significant proportion of this amount.

The careful dismantling or disassembly process, designed to yield reusable or recyclable materials, will often be more time consuming and labour intensive than current demolition methods. However, the labour is generally unskilled, and organizations can usually avoid charges for expensive equipment and the use of sophisticated explosive systems. Modest revenues may be realized.

In time, as the practice of dismantling becomes more common, costs may actually decrease as more efficient techniques are developed. Savings may increase because tipping fees are likely to continue to rise, and revenue may increase if the construction industry's demand for reusable and recycled material rises.

2. Guidance

Determine whether the building to be demolished has a floor area of 1,000 square metres or more, and whether the demolition will have one or more of the following characteristics:

If mitigation measures can stop significant adverse environmental effects from occurring, an organization must plan, implement and monitor these measures as part of the project management process. Such measures may include specific procedures required to deal with hazardous substances, such as asbestos. As well, during demolition activities to renovate or alter a facility, an organization may need to take measures to protect the health and safety of the facility's users, as well as any environmentally sensitive areas.

The organization should review any renovation or alteration project with the design and management team to determine whether it can use the dismantling approach rather than conventional selective demolition. Discuss not only which materials can be directed away from the usual waste stream, but also which materials could be reused in the reconstruction of the project itself.

When submitting bids for a demolition or dismantling project, contractors should survey the structure in question and submit the survey as part of their bid. This survey will include an inventory of the type and quantity of material that can be reused, refurbished, recycled or discarded.

Business directories, such as the Yellow Pages, list companies that specialize in collecting and distributing reusable construction materials or reselling hardware supplies. The Canadian Waste Exchange, a local or provincial waste exchange, and local construction associations may be able to provide a list of their members, some of which may be interested in purchasing materials from dismantling projects.

To protect workers and occupants, especially those in a facility being renovated or altered, a hazardous substances survey of the facility should also be done before work commences. This will generally include a list of toxic or hazardous materials recognized in federal or provincial regulations or guidelines. At a minimum, it should include common hazards such as asbestos, lead paint and PCBs. The staff of the local Environment Canada office (refer to Appendix A for a list of offices) or the provincial ministry of the environment may be able to help.

Currently, most companies specializing in dismantling are small, with limited assets and capital resources. Their labour force usually has lower levels of skill and training. The owner's project manager for a dismantling project should, therefore, make sure that all the required protection, liability insurance and worker's compensation coverage is in place. It will also be prudent to supervise the project closely, especially at particularly critical or risky stages.

Large demolition projects can benefit from a dismantling approach as well. Empire Stadium in Vancouver, a 30,000-seat outdoor track and field stadium, was successfully dismantled recently, and approximately 65 per cent of the materials removed were diverted from landfill. Other large-scale examples exist. Scale, therefore, is not necessarily the determining factor in making a decision to dismantle.

3. References

This Act, along with the first four listed regulations, was proclaimed into law on January 19, 1995, and replaces the Environmental Assessment and Review Process Guidelines Order of 1984.

Since the CEAA is law, the process outlined by the Act must be followed. The purpose of an environmental assessment under the CEAA (in most cases, an environmental screening) is to evaluate both the positive and negative environmental implications of a proposed project, before irrevocable decisions are made.

While there are no penalties incorporated into the CEAA legislation, failure to conduct the required environmental assessment could allow an interested third party to obtain a court injunction against proceeding with the project.

Ontario may extend its waste audit and waste planning legislation to apply to renovation and reconstruction projects. Such an extension would mean that these projects would have to be redesigned to incorporate reuse, recovery and recycling possibilities in the demolition or dismantling phase of the work. The results of this revised plan would have to be kept on file and made available to the provincial government for review. Similar legislative approaches in other jurisdictions can be anticipated as well.

"The purpose of this Part is to prevent accidents and injury to health arising out of, linked with or occurring during employment to which this Part applies." (s122.1)

"Every employer shall ensure that the safety and health at work of every person employed by the employer is protected". (s124).

Conviction for an offence under the Canada Labour Code can result in substantial personal fines, up to $1,000,000 per day, and/or a prison term with a criminal record.

It is government policy to acquire, use and dispose of real property in a manner consistent with the principle of sustainable development. The Government of Canada has also made a commitment to implement a code of environmental stewardship, affecting some aspects of real property management.

Public Works and Government Services Canada, March 1996
To order: e-mail : doc.centre@pwgsc.gc.ca, fax (613) 736-2029


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