Tracking Excavated Contaminated Soils: Traces Québec

According to Quebec’s Ministère de l’Environnement, de la Lutte contre les changements climatiques, de la Faune et des Parcs (MELCCFP), more than 3 million metric tonnes of excavated contaminated soils are transported to treatment, reuse and landfill sites. That is equivalent to more than 115,000 dump truck trips. Ensuring that every load from all these trips actually reaches its final destination is quite a challenge.

Traces Québec ensures the traceability of contaminated soils during transport

The Government of Quebec introduced Traces Québec, a traceability system for excavated contaminated soils. Using Traces Québec is mandatory for owners of contaminated land and their representatives, since it is set out in the Regulation respecting the traceability of excavated contaminated soils (RTSCE). The regulation does not apply to in-situ decontamination or rehabilitation of contaminated land.

With this government tracking system for excavated contaminated soils, the goal is to prevent illegal dumping and improve the monitoring of contaminated soils.

In this article, we discuss the RTSCE and its implementation. We then take a closer look at Traces Québec, how it works and the fees for using this government platform for tracking excavated contaminated soils.

The Regulation respecting the traceability of excavated contaminated soils

The Government of Quebec adopted the RTSCE to ensure the rehabilitation of land with contaminated soils while limiting the contamination of other soils and of groundwater and surface water.

The regulation applies to contaminated soils excavated in Quebec, from their origin to their final destination.

Electronic manifests are used to track the soils at every stage of transport. Satellite geolocation is used to track movements between the site of origin and the final receiving site.

The regulation provides for monetary administrative penalties ranging from $2,500 to $10,000 and penal sanctions ranging from $7,500 to $6 million.

Phased implementation of the regulation on tracking excavated contaminated soils

Starting in late summer 2021, owners of contaminated land could voluntarily choose to use the government traceability system, Traces Québec, to ensure that excavated soils were properly managed.

As of November 1, 2021, using Traces Québec became mandatory for projects exceeding 5,000 tonnes.

As of January 1, 2022, all projects exceeding 1,000 tonnes had to use the Traces Québec platform, as did any project started earlier with more than 1,000 tonnes remaining, except for contracts signed and calls for tenders issued before the RTSCE came into force.

What is Traces Québec?

Developed by the non-profit organization Attestra, Traces Québec is an integrated IT platform for the traceability of excavated contaminated soils in Quebec. It complies with the best practices for the traceability of excavated contaminated soils published by the Ministère in 2018.

Using electronic manifests and GPS tracking through a smartphone app, Traces Québec ensures the traceability of excavated contaminated soils from the excavation site to an accredited landfill or treatment site located in Quebec or elsewhere.

The soils are weighed when they leave the site of origin and when they arrive at their final destination, a site able to treat, reuse or landfill them.

Using Traces Québec, the government platform for tracking excavated contaminated soils, is a requirement under the RTSCE.

How much does Traces Québec cost?

The fee for using Traces Québec, payable by the owner of the site of origin, is $2 per tonne of contaminated soil transported. This amount is indexed annually to Canada’s Consumer Price Index.

How to use Traces Québec

Here are the steps for using Traces Québec:

1. The owner of the contaminated land or their representative registers with Traces Québec
2. The owner or their representative creates a project on the Traces Québec platform
3. The owner or their representative enters the following in the project:
   • The nature of the contaminated soils to be transported
   • The tonnage of the contaminated soils to be transported
   • The carrier
   • The receiving site
4. Before leaving the excavation site, the carrier confirms the soil load in Traces Québec
5. The smartphone app tracks the load by GPS
6. On arrival at the receiving site, a manifest is completed with the following information:
   • The weight of the load received
   • The time of arrival
7. The manifest is closed by an authorized person
8. A traceability report is generated

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