ASTTBC Interprovincial Harmonization of Certification and...

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ASTTBC

Interprovincial Harmonization of Certification and Competency Standards

for ROWPs

August 2016

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Table of Contents

Introduction 1

Methodology 1

Recommendations 2

ROWP Training and Certification Process Survey Findings 4

BC and Alberta Alignment on Core Competencies 9

BC and Alberta Practitioner Registrations Process Gap 12

Summary 20

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Introduction

The Applied Science Technologists and Technicians of British Columbia (ASTTBC) commissioned Gycor Dynamics Inc. to conduct a study that would help ensure common qualifications and licensing standards for workers installing onsite wastewater systems in British Columbia. The study is based on challenges arising from federal labour mobility regulations that obligate ASTTBC to certify workers coming from other jurisdictions. The concern is that the qualifications and competencies of these workers may not be the same as those trained and certified in B.C. This study will help determine if a standard set of competencies can be established by working with regulatory authorities in other provinces to create a national standard that would better promote the ideals of public safety and environmental protection.

This study contains recommendations for ASTTBC to pursue toward this objective. Recommendations are based on observations against best available data that has been uncovered during the research phases of this study along with related completed studies. Suggested courses of action are provided for ASTTBC’s consideration only.

Methodology Several data-gathering methods were deployed in the development of this study.

ROWPs were surveyed on their views of Continuing Professional Development (CPD) requirements and courses. This data was compared against potential Registered Onsite Wastewater Practitioner (ROWP) competency gaps that may exist based on ASTTBC normal Practice Assessment Reviews (PAR) and other means.

Several available ASTTBC staff-authored reports and studies were sourced that relate specifically to the objectives of this study. The most notable of these is a 2009 report that contains a detailed comparative analysis between the competency requirements of onsite wastewater workers in Alberta and B.C. This report does not contain such a comparative analysis because most of the jurisdictions’ competencies are still relevant today. This study takes the 2009 work one step further by identifying those competencies that have the best opportunity to be harmonized among the two and perhaps all provinces. The ROWP survey provides industry’s perspective on these select competencies which provides additional assurance to regulators that efforts made toward harmonization will be met with as little resistance as possible. Several interviews with ASTTBC staff were conducted. Their field-observations, historical perspectives and general guidance provided valuable insight in drafting reasonable and measured recommendations that, if implemented, may offer the most likely approach toward meeting this study’s objectives.

! Interprovincial Harmonization of Certification and Competency Standards for ROWPs 1

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Recommendations

1. ASTTBC should expect that achieving harmonization of certification and training processes will be very difficult to accomplish. There are considerable differences in how the onsite wastewater industries are regulated between British Columbia and other jurisdictions, namely Alberta. Changes to either regulatory environment would require interprovincial like-minded political will and significant effort by senior departmental staff.

2. Still, steps should be taken toward fostering an increased spirit of cooperation among BC regulators, onsite wastewater industry practitioners and training providers with those from other jurisdictions in the name of bettering labour mobility processes and harmonizing the most core industry competencies in the pursuit of strengthening public health and environmental protection.

3. Although there are provisions under the federal labour mobility regulation for jurisdictions to work toward harmonizing competencies in the pursuit of legitimate objectives, the impetus for this work should be based on actual ASTTBC’s findings of those competency gaps that have direct negative impact on the protection of human health and the environment.

4. There is an insufficient compilation of PARs on ROWPs who have achieved certification from other jurisdictions. While some information is available now, a better assessment of competency gaps and their root causes can be more accurately made by reviewing the Review six to 12 months from now, after a sufficient number of PARs have been completed.

5. ASTTBC should host a summit featuring regulators from jurisdictions across Canada to foster a national understanding of the regional required competencies that are in place for their respective industry practitioners.

6. Occupational competencies for Alberta industry practitioners were drafted in 2002 and are in need of updating according to that province’s regulator. This is a prime opportunity for ASTTBC to share its competencies (drafted in May 2015) with Alberta to begin working toward a harmonized list of those that are deemed most core to the onsite wastewater industry.

7. All training bodies in British Columbia and Alberta should be made aware of the expected competencies that are in place in the jurisdictions in which they choose to work. Increased focus on training toward these competencies may lead to fewer instances where critical competency gaps occur.

8. Training and CPD courses should be developed and / or enhanced primarily based on needs of ROWPs as illustrated through their input in the 2015 training needs survey. ROWPs express


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therein a strong need for increased CPD training in soil classification and site / soil evaluation. Regulators in BC and Alberta also see these areas as key competency gaps. Movement toward better training harmonization should begin by focusing in these areas.

9. ROWPs report that there are not enough CPD courses to maintain or increase knowledge levels. This presents a prime opportunity to encourage training providers to increase their number of offerings and for ASTTBC to work with them on guiding them on the type of courses that should be strengthened or developed.

10. Training providers and regulators should work together to make core industry training and CPD courses equally available to ROWPs across BC regardless where they reside. Examples include more online offerings and financial incentives for training providers to travel to remote locations.


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ROWP Training and Certification Process Survey Findings

Respondent Demographics Seventy-three ROWPs responded to the survey, of which 71 indicated their prime geographic area of work. The regional breakdown of respondents was the South Island area (18%). This was followed by North Vancouver (17%), Columbia Kootenay (13%), Okanagan Shuswap (11%), Fraser Canyon and Central Island (10%), Bukley Nechako and Sunshine Coast (5%), Peace River (4%), Kitimat (3%) and Cariboo-Chilcotin and Sea to Sky (2%).

All respondents are ROWPs. The vast majority (just over 90%) are registered as installers, planners or both. Approximately 25% registered as maintenance providers while just over 10% registered as private inspectors.

Training Provider Fifty-six respondents provided training provider information. Of these, 30 (54%) received training from BCOSSA (Westcoast Onsite Wastewater Training Centre - WOWTC), 12 (21%) from WCOWMA, 11 (19%) from Royal Roads University, 2 (4%) from Thompson Rivers University and 1 (2%) from the U.S.-based National Association of Wastewater Technicians.


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The respondents' ratings of the programs were generally favourable. Based on the answers from those who chose to comment on the question, no single program was rated significantly higher or lower than any other. Approximately one quarter of the respondents rated the level of instruction as excellent (13 - 23%), 18 or 32% rated the instruction as very good, 12 or 21% as good, an equal number rated it as adequate, and only 2 or 3.5% rated the level of instruction as poor. General respondent comments were middling, but several pointed out the need for more soils and hands-on learning to supplement the classroom content.

By and large, respondents noted that the training program met their needs, with 33 or 58% responding accordingly. However, this group also noted that they could use more training in certain areas. Fourteen or 25% noted that training was sufficient and that no further training would be required to perform their jobs. However, just under 18% indicated that the training fell short of providing the necessary knowledge to perform their jobs consistently well.

Certification Process Fifty-one respondents provided candid comments on this process, but most were void of significant detail. However, the findings are nonetheless interesting. Approximately half of the respondents characterized the process as good to fair. Close to half respondents looked upon the certification process very negatively.


Total ROWP Applications Total Application Approvals

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One respondent noted the process was very easy, providing one took the “Alberta shortcut” route. While no respondents were asked if they were inter-provincial transfers or not, there is clearly a large divide between those who looked upon the process favourably and those who did not.

Interest in Continued Professional Development (CPD) Courses Respondents were asked to rank their preferences for CPD courses. Of these, 62% stated that they would be most interested in a site and soil evaluation course. This is followed by soil classification (identifying soil types - 55%), limited electrical qualifications (49%), hydraulic design and documentation / filings (each with 43%), pressure distribution calculation (39%), calculating linear loading rates / drawing and planning (each with 38%), liability exposure and risk mitigation (28%), code of ethics / professionalism (21%), and best business practices (17%).

Nearly half (48%) would prefer that these courses were offered online. Nearly 30% prefer that they be offered in the classroom and 22% would like the courses offered in the field. Respondent comments reflect that hands-on training is the most beneficial, but this form of training cannot overcome the geographic realities of the industry. Respondents often state that long travel distances to course locations is a significant barrier.

Respondents were asked who would be best to deliver CPD courses. Responses varied in terms of which person / organization would be best to provide the service, but most noted that any training provider who holds industry field experience would be most preferred.


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On approximate average, respondents noted that 23 hours or 3 days of CPD courses would be required to maintain or increase their level of industry knowledge. Nearly all respondents noted that these courses should be offered during the winter months. On average respondents reported that they took 2.4 courses in the last year, 5.8 courses in the last two years and 8 courses in the last three years.

Interestingly, 66% of respondents report that there are not enough available CPD courses to maintain or increase required knowledge levels. Respondent comments are varied and do not solely reflect a lack of available courses. Other extenuating circumstances are at play with the most notable being high cost and inconvenient course locations.

Sixty-eight per cent of the respondents somewhat agree that the CPD courses are very relevant to their needs, but their views toward the convenience and accessibility of CPD courses trend more negatively. While 39% somewhat agree that the courses are conveniently and very accessible, 56% somewhat or strongly disagree.

Respondents’ attitudes toward CPD course costs are extremely varied. Their opinions were separated out into four categories: (1) costs are too high (22% of respondents indicated this sentiment), (2) opportunity costs and travel / time costs are prohibitive (19%), (3) respondents are reluctant to pay but it is the cost of doing business (25%) and (4) costs are fair (34%).

Attitudes Toward Mentors Respondents were asked to state how they feel about the use of a mentor. Forty-five per cent indicated that a mentor would be useful but it would not be a replacement for CPD courses, 34% stated that a mentor would not be useful, 30% stated that they would use a mentor but they cannot or do not know where to look for one in their area and 14% stated that a mentor would be highly beneficial.

General Comments on Training and CPD Courses Respondents were asked to provide their opinions on training and CPD courses. Most respondents did, and the following is a small random collection of unedited comments.

“The training and CPD courses MUST be BC based and reflect SSR and SPM. CPDs must be meaningful and reflect advanced practice. Classroom training is best and field examples are useful for soils.”

“As BCOSSA only runs the courses sporadically due to not enough people signing up and WCOWMA not being long enough or BC orientated, I feel ASTTBC and the Health Authority


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should be working more to organize a comprehensive training program and also arrange dedicated mentors/teachers who are on ASTTBC or government payroll.”

“As for CPD there needs to be more on the science of treatment. Too many ROWPs are still designing disposal systems imo…I heard at least half dozen ROWPs this year say that the systems they put in the ground worked fine in the old days and the systems nowadays are over engineered and in their opinion unnecessary.”

“If a ROWP is going to take a 5-day course and be certified, he/she needs to do much more CPD than a ROWP who takes the certification through the longer route which shows adequate education, training and mentoring.”

“I wish Alberta and BC could join together in the SPM and SOP manuals. Both have good ideas, however confusing if you switch back and forth.”

“The use of online resources is an area that needs to be further developed and utilized.”

“The training is adequate. CPD is always difficult for me. There should just be a 1 day low cost course required each year to keep us up to date on new technology. This course should be standard and offered in each district just like the courses are. Could even be offered online. Anything more than that is a burden (except self directed study because I can do that anytime I have time).”


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British Columbia and Alberta Alignment on Core Competencies

BC and Alberta regulators were asked to review what they view to be core competency requirements and gaps therein based on field observations. Data was compiled through interviews with these groups. There are matches between these findings and those uncovered in the ROWP survey. These are highlighted in green in the chart below. ROWPs did not indicate that the in situ water mounding assessment topic (outlined in yellow) is a CPD interest, but Alberta and BC regulators recognize this as an observed competency gap.

There are areas where core competencies are not aligned between the two provinces. This may be attributed to their respective approaches to training and the audiences they attracted when the courses were first offered. Alberta assumed that some students already possess a degree of experience. BC assumes that students possess very little or no prior experience exists before courses are taken. This has direct impact on course content because the training programs’ foundational assumptions are different.

Competency gaps are primarily determined after PAR findings are analyzed. To date, ASTTBC notes that only a handful of Reviews have been completed which makes for a low baseline against which more complete observations can be made.

Although it is logical for certifying bodies to arrive at core competencies for like-industries, it may not be possible in all cases. Regulatory paradigms can vary widely from province to province, meaning that there will always be some concessions made when seeking competency harmonization.


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Subject Matter ROWP CPD Interest?ASTTBC Recognized Competency Gap? Alberta Alignment?

Site and Soil Evaluation Yes (1) Yes Yes

Soil Classification Yes (2) Yes Yes

Limited Electrical Qualifications

Yes (3) No No

Hydraulic Design Yes (4) Yes Yes

Pressure Distribution Yes (5 - tie) No Yes

Documentation and Filings Yes (5 - tie) No No

LLR Calculations Yes (6 - tie) No Yes

Drawing / Planning / De-sign

Yes (6 - tie) No Yes

Liability and Risk Mitiga-tion

Yes (7) No No

Ethics and Professional-ism

Yes (8) No No

Best Business Practices Yes (9) No No

In-Situ Water Mounding No Yes Yes

Conflict of Interest No Yes No


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Agreement on Internal Trade - Labour Mobility and the Pursuit of Legitimate Objectives 1

Chapter Seven along with Annexes 703.1, 708 and 712.2 of the federal Agreement on Internal Trade, Labour Mobility, collectively offer the appropriate mechanisms to achieve harmonized competencies.

The Chapter defines a legitimate objective as a pursuit that protects such things as human life or health, and the environment. Each jurisdiction may adopt or maintain any occupational standard or occupational requirement to achieve a legitimate objective, and in doing so establish the level of protection it considers to be appropriate. Efforts in this regard must relate principally to competence, or in other words, the efforts must ensure they result in uniform competency levels that are required of certified workers to achieve a legitimate objective.

It may be determined through available information that there are significant differences in the level of commonality between the jurisdictional occupational standards. If this should occur, the jurisdictions will undertake an occupational analysis to determine the extent to which the standards for that occupation differ. This analysis will consider several areas including the scope of practice, generic and specific skills, licensing, certification or registration requirements and other entry requirements and qualifications pertaining to the occupation. However, it must not consider differences in training methods since competencies and abilities can be acquired through different combinations of training and experience.

British Columbia and Alberta have already begun to better understand the core competencies that need to be in place for their respective industries. However, there is no available information that identifies any competency gaps that could undermine a legitimate objective that is determined to be a cornerstone of the onsite wastewater industry. This information could be determined after more Performance Assurance Reviews have been completed and analyzed.

This report’s content relating to federal labour mobility requirements should be received as information only. It must only be 1

considered as impetus to seek formal legal advice if ASTTBC wishes to pursue this area.


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British Columbia and Alberta Practitioner Registration Process Gap

ROWP Registrations and Approvals Between 2013 and 2015, ASTTBC received 111 applications for ROWP status. Of these, 81 were approved. Looked at in isolation, these findings are not peculiar but the number of interprovincial applications and approvals compared to the number of British Columbia direct applications and approvals should generate interest:

78 interprovincial applications

71 interprovincial approvals

91% success rate

33 British Columbia applications

10 British Columbia approvals

30% success rate

In that time, 88% of all approvals were interprovincial transfers, and 91% of these achieved ROWP certification. ASTTBC staff state that in general those that did not achieve ROWP certification decided not to complete the process. No specific reasons for this were provided.


Inter Provincial Transfer Applications Approved Inter Provincial TransferBC Direct Application Approved BC Direct

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Comparatively, just 30% of British Columbia direct applicants received ROWP certification. The unsuccessful applicants were deferred by ASTTBC’s Onsite Wastewater Certification Board (OWCB) based on identified competency gaps.

These figures hide more than they reveal. On the surface, anyone unfamiliar with labour mobility transfer requirements could assume that interprovincial transferees are better trained, experienced or perhaps both. Using the same perspective, those trained in British Columbia could be considered too poorly trained or experienced to meet industry requirements. Of course, making these assumptions would be pure folly once the respective interprovincial (mostly Alberta) and British Columbia independent certification processes are understood.

In Alberta, Certification and Permit Regulation under the Safety Codes Act (2009) Section 3(1) states that the Administrator may issue or renew a private sewage installer certificate of competency to a person who has (a) training in private sewage systems or in water and sewer service piping, satisfactory to the Administrator, and (b) paid the appropriate fee. Oversight of the certified person is performed by a Safety Codes Officer who is charged with the responsibility of ensuring the system is designed and constructed in a manner that is congruent with the private sewage system permit that was submitted and approved before construction.

In 2009, Ron Hein, then ASTTBC’s Onsite Wastewater Registration Program Manager, authored a report that compared the British Columbia and Alberta onsite wastewater certification and registration programs. The report illustrates the ROWP certification process in British Columbia. A registration 2 3

certificate is issued through ASTTBC to a person who is deemed to be competent to plan, construct and maintain a sewerage system that uses a treatment method classified as Type 1 or Type 2. Registration allowing a person to install or maintain Type 3 (non-engineer professional) is also available through ASTTBC. The Sewage System Regulation states that an Authorized Person may have regard to the Standard Practice Manual, however, ASTTBC requires that a Practitioner must ensure their work conforms to standard practice to limit the liability that falls upon them under a professional reliance process.

Applications are submitted to ASTTBC where they are presented to a panel of peers within the OWCB who review the application and assess whether the applicant meets the requirements of education and experience for registration and in which categories the training and experience exists. Registration categories in British Columbia include Planner, Installer, Maintenance Provider and Private Inspectors. Practitioners may hold only one or several of these categories. Those who lack training or experience in certain areas may be registered but with a practice restriction limiting them, while those with no prior

Comparison Between the Alberta and British Columbia Onsite Wastewater Certification / Registration Programs with Regards to 2

the Trade, Investment and Labour Mobility Agreement, Hein, March 5, 2009

Hein, 2009.3


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experience but who have met the educational requirements may be brought in as Onsite Wastewater Trainees.

As we can see, the registration processes between Alberta and British Columbia are vastly different. Much of this could be based on the professional self-reliance model that is in place in British Columbia against the so-called third-party oversight system in Alberta. In Alberta, the Safety Codes Officer is on hand for every system that is constructed to ensure that the system will perform as designed, which essentially confirms that the installer possesses the necessary competencies. British Columbia does not employ this oversight system. Instead it relies on its professional reliance model whereby the Authorized Person provides his or her own assurance that the system will perform as intended. This is why there is considerable attention placed on the assurance of the Authorized Person’s competency prior to the construction of certain systems.

Knowing these differences, we can assume there are two key reasons for these registration and approval gaps: 4

1. The certification process is far more streamlined in Alberta. 2. The labour mobility provisions under the federal Agreement on Internal Trade calls upon

each provincial jurisdiction to recognize certification status of workers from other jurisdictions.

It stands to reason that practitioners would typically choose to adopt the interprovincial transfer route due to the relatively simpler process involved in obtaining ROWP status.

A word of caution must be made against drawing further conclusions. There is no empirical evidence to suggest that those who moved through the interprovincial transfer process are any more or less capable of installing safe and efficient onsite wastewater systems than those who took the British Columbia direct route. While ASTTBC staff have made note of competency gaps in their Practice Assessment Review (PAR) process for all ROWPs, there is not enough empirical data on-hand to definitively state that interprovincial transferees require more training over ROWPs who achieved certification through the British Columbia direct process. Without this data, it may be difficult for ASTTBC and Alberta to support significant efforts to work toward harmonizing certification processes.

The Reasonableness of Harmonization Most interprovincial transferees hail from Alberta, or at the very least, undertake the Alberta training program and undergo its certification process. Since this report in part deals with national harmonization

There are also differentiators among training programs in both provinces, the most notable of which are course length and cost. 4

However, these are variables that are largely controlled by private training providers. Their practices are not part of this report’s scope.


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of qualifications and licensing standards, other Canadian provinces have been asked to provide input on their views toward this topic. Due to the relative high number of interprovincial transferees from Alberta, any efforts British Columbia may take toward harmonization will have the most impacts on Alberta transferees and that province’s training and regulatory regimes. Therefore, harmonization implications are separated between Alberta and the rest of Canada.

Surveys were distributed to onsite wastewater regulatory contacts in all provinces and territories. A summary of their regulatory and training processes are provided here along with specific regional views toward harmonization where they have been gathered.

Harmonization - Canada 5

The following summarizes key industry components that best illustrate the most relevant differences between national regulatory models.

British Columbia

According to the SSR, an authorized person must submit a filing to the local health authority that consists of the location of the system, its type, technical details about soil conditions on site, construction plans and written assurance that the plans conform to standard practice. Once the system is constructed, the authorized person must provide the homeowner with a copy of the system plans and specifications, a maintenance plan and a copy of the signed assurance letter. The authorized person must also file a letter to the health authority that states the system has been constructed in accordance to standard practice and to the plans that had been previously filed. The letter must also state the estimated daily sewage flow, and that the system will not cause a health hazard if operated and maintained as specified. Appended to the letter must be a copy of the maintenance and construction plans.

No final inspection or approvals are needed before the system is commissioned. ASTTBC conducts installation audits to help ensure that the authorized person is in compliance with proper procedures.

Provincial descriptions taken in part from Reforming the Regulation of BC’s Sewerage Systems: An Urgent Need to Protect Public 5

Health, Environmental Law Centre, University of Victoria, March 2009.


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Alberta

Permits for design-approved private sewage systems are issued by municipalities that are accredited to manage the Safety Codes Act or in other cases by the Province. Permits must be in place before construction can begin. Systems are inspected by a Safety Codes Officer and receive final approval before they are commissioned.

Saskatchewan

Environmental Health Officers issue permits, carry out inspections and approve all systems.

Manitoba

Environmental Officers issue permits, conduct inspections and issue final approvals.

Ontario

Enforced by some health units, conservation authorities and local municipal building inspectors for systems with flows less than 10,000 litres per day. If remediation or upgrade of a system is needed, the agency who enforces the Building Code related to the sewage system would get the referral.

Quebec

In municipalities, housing inspectors issue permits and perform inspections. Throughout the rest of Quebec, Environmental Officers perform inspections except in some First Nations lands.

Nova Scotia

Permit applications are processed by Department of Environment staff. Qualified contractors must be used for installations. Final inspections may be done based on the situation. Installation audits occur.

Prince Edward Island

Two options are available. Department of Environment staff issue system permits plus conduct final inspections or conduct audits of systems as they are installed. Certificate of Compliance is issued. The other option allows for Certified Contractors to install the system and notify officials for final inspection. Inspections are not done on systems that are registered by engineers, but random audits are performed on all others. Some systems may be subject to more audits based on environmental risk factors.


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New Brunswick

Public Health Inspectors assess the property and provide written approval to install. A final inspection is carried out prior to cover. Currently all systems are inspected, but with new regulations coming in to force, officials are planning to move to audits/spot checks of installations. Licensed installers do the work but homeowners can do their own installations (a discouraged practice). Applicants submit a 4-page application with technical specifications.

Newfoundland / Labrador

Environmental Health Officers approve system designs, inspect during the installation process, inspect before backfilling and investigate malfunctions.

Nunavit

No private sewage systems are installed. All systems are community collection systems or pump and hall.

Northwest Territories

Virtually no private sewage systems are installed. All systems are community collection systems or pump and hall.

Yukon

Environmental Health Officers conduct inspections, approve sites, issue permits, authorize approval to backfill and issue final authorizations.

BC is the only jurisdiction that utilizes what is often referred to as a professional reliance model. This model is in part characterized by oversight by an authorized design practitioner during the initial planning stages of onsite wastewater system construction. The only other jurisdiction that is similar is Prince Edward Island, but it only considers professional reliance as an option in some cases.

The merits of this process are not up for debate. However, it should serve as a word of caution to BC regulatory authorities in the pursuit of harmonizing regulations, standards or processes. To be successful, ASTTBC would need to lobby each province to move forward with regulatory changes that require the support of provincial government department officials, managers and ministers.

The merits of this undertaking will have to be weighed against the desired outcomes. Will harmonized changes to provincial regulatory regimes across Canada clearly lead to a greater assurance to the health and safety of British Columbians?


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This question could be answered by Morley Foy, the Prince Edward Island’s Department of Environment’s Approvals and Regulatory Compliance Engineer. He states, “It would be good to have harmonization from a design perspective. It is hard to do this from a legislative perspective because all jurisdictions are so different with different soils, densities and political wills. The Canadian Standards Association tried to do this but could not.”

No empirical evidence has been uncovered to suggest that Authorized Persons from other jurisdictions pose an increased threat to the health and safety of British Columbians and their environment. A more practical short term approach may be to consider the pursuit of strengthening and harmonizing the competencies that are most required of Authorized Persons. A focus placed here will better lead to the desired outcomes of public safety and environmental protection. Taken a step further, harmonizing competencies should begin by partnering with the jurisdiction (or the jurisdiction’s training and certification process) where most interprovincial transferees come from - Alberta.

Harmonization - Alberta

In January 2014, ASTTBC’s current Onsite Wastewater Program Manager Jim Andersen authored a discussion paper entitled “Potential Harmonization of Onsite Wastewater Regulatory Framework for Alberta and British Columbia”. In it he identifies a selection of areas where differences in the Alberta Standard of Practice (SOP) and the British Columbia Standard Practice Manual version 2 (SPM) occur. These are, in no particular order:

1. Soils assessment requirements are a prime focus under the BC Standard Practice Manual (SPM) and the Alberta Standard of Practice (SOP) manual, yet regulatory bodies in both jurisdictions recognize this as a competency gap. ROWPs also call for more CPD courses in this area.

2. Site surveying and project reporting requirements are more comprehensive under the SPM.

3. Designations between Designers/Planners, Installers and Maintenance Providers are made in the SPM. There are no such designations in the SOP.

4. The SOP contains provisions for Increased Hydraulic Loading (decrease system size) for certain situations.

5. The SOP allows for surface drainage in certain situations.

6. The SPM allows for more shallow soil depths to vertical separation or soil depth standards.

7. The SPM contains more liberal provisions for gravity dispersal. The SOP does not allow these.


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8. The SOP requires visual monitoring ports to be installed to the point of vertical separation. This idea was debated for inclusion in the SPM but was subsequently dropped from discussion.

9. The SPM places emphasis on the use of professionals in some situations. The SOP does not stipulate the requirement of professionals (engineers) unless system flow volumes exceed certain capacities.

10. The SPM and SOP have system maintenance requirements of the homeowner, but the SPM places more emphasis on maintenance standards and training.

11. The SOP includes specific in situ treatment treatment objectives. The SPM does not, although the concept has been debated since 2005.

12. The SOP is very clear and easy to apply due in part to Alberta’s prescriptive model. The SPM is generally considered to be less prescriptive.

For more detail on the regulatory differences, the Hein report offers a more detailed list, but many of those points can be grouped under the points made above.

In some cases, the differences between the SOP and SPM are significant. Making changes to these toward harmonizing each jurisdiction’s practices would require significant effort and, based on industry’s history in these matters, it may take years to materialize. Changes here would require fundamental shifts in political and administrative mindsets that drive professional reliance or third-party oversight models.

To illustrate this point, consider that the 2009 Hein report contains recommendations toward harmonization, yet seven years later neither jurisdiction has made significant changes to their respective practices. If this is any indication, all parties are advised to establish realistic goals and milestones that can be reached within reasonable timeframes.


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Summary

Can Canadian provinces harmonize their respective onsite wastewater industry certification and competency standards? The answer is a qualified “yes” providing that only those core competencies that have a direct impact on the legitimate objectives of ensuring public health and environmental protection are pursued. However, such pursuits must be based on substantial evidence that draws one to the conclusion that interprovincial regulatory difficulties are compromising the furthering of these legitimate objectives.

Can British Columbia influence the harmonization of industry certification and competency standards? The answer is another qualified “yes” providing that it understands that the regulatory differences that distinguish one jurisdiction from the next are understood and provincial autonomy (or their way of doing things) is respected. The Province can be an agent of change, however. By bringing regulators from across the country together to discuss the pursuit of legitimate objectives, national labour mobility processes will improve and the greater good of protecting all Canadians served by onsite wastewater systems will be well served.


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