The Saskatchewan Onsite Wastewater Management Association provided feedback to the Ministry of Health on the Private Sewage Works Regulation and the Shoreland Pollution Control Regulation during a recent survey.  The Ministry is collecting preliminary information in anticipation of reviewing these regulations.  The feedback SOWMA provided is below:

While the overarching requirements outlined in the above-listed regulations are well-defined, the document that supports them, the Saskatchewan Onsite Wastewater Disposal Guide should be reviewed and updated.  Suggestions for changes to the guide are listed below along with reasoning for those changes.

Under the definitions and further under section 5(1) Eligibility for a Permit, it states that a ‘qualified’ person may obtain a permit and the definitions outline what constitutes a qualified person.  This definition puts significant responsibility on the health inspector to determine who is or isn’t qualified.  The definition should be expanded to state that only trained and certified contractors who have been determined to have the equipment, knowledge and experience deemed necessary to design and install private sewage works are able to obtain permits.  The province has a significant number of contractors available to perform this work. Requiring only those trained and certified under a recognized training program would protect the homeowner, and reduce the number of failed or inadequately designed and installed systems in the province.

1. Those designing and installing of onsite wastewater systems should be limited to those trained and certified.  There are a significant number of contractors in the province who have been certified.  They have done this on their own recognizance.  This could be accomplished simply by better defining the use of the term “qualified person” in the SOWDG.  Saskatchewan is the only province in Western Canada and one of only a couple of provinces and territories in the entire country that doesn’t require those working in the private sewage industry to be trained and certified or licensed.  Requiring contractors working in this industry to be trained and certified would help to professionalize the industry.  It would support the pro-active contractors who want to do good work to have a more level playing field.  It would improve the quality of the systems being installed and provide for more responsible and sustainable onsite wastewater systems overall.
2. The option for Basic soils evaluation and/or the ability to assess soils by texture only should be removed from the Saskatchewan Onsite Wastewater Disposal Guideline.  Most jurisdictions have now removed the option of a basic site and soils evaluation and prescribed soils sampling depths in favour of detailed site and soils evaluations that require sampling at the limiting (design) layer and restrictive (non-permeable layer).  There is significant research and data demonstrating that soils structure is a critical component in the soils ability to renovate and disperse effluent.  Structure goes hand-in-hand with soils texture in determining system size, effectiveness of the treatment and dispersal of effluent, etc.  The detailed site evaluation should be utilized on every site. This ensures that systems are built on soils that can manage and treat the wastewater being applied.
3. There should be no prescription as to where to take the soils samples from.  Soils samples should be taken at the restricting and limiting layers.  There is no scientific basis for taking samples at three, six and eight feet.  By prescribing where the samples are taken from, there is the risk of missing a significant issue in the soils interface at a depth that wasn’t targeted.
4. Monitoring ports at each end of the onsite system allow system maintenance providers to look inside the laterals and check for ponding and other issues that may occur.
5. Requiring a high level alarm on the septic tank protects the homeowner by ensuring that if their tank is full and requires pumping, they are warned before sewer backs up into the home.
6. GPS locations for both the test pits and system should be listed on the permit application.
7. Subdivision developments must go through Community Planning so:

There should be consistency in the subdivision process
Community Planning should not be able to supersede the regulation and the guideline

1. Under the Shoreline Pollution Control Regulation – Must maintain the requirement for 25 foot vertical separation and 1500 foot horizontal separation from the high water mark
2. Setbacks for septic tanks, privy vaults or other storage units should be increased from 50 feet horizontal and 10 feet vertical to 150 feet horizontal and 25 feet vertical
3. Fines and penalties for non-compliance should be significant enough to be a deterent
4. Effluent filters should be required on all systems
5. Onsite Wastewater Systems should be part of any New Home Warranty Program required in the Province.
6. Contractors see a lot of contaminated groundwater due to failed jet systems.  Jets should be restricted and limited to only certain sites by:

Increasing horizontal setbacks
Requiring proper site evaluation for areas of discharge
Allowing jets only on certain soils.

1. Tank sizing should be revisited to ensure minimum tank sizes are adequate for modern homes.
2. Criteria should be set for appropriate ground cover as follows:

Remove straw from the requirements of coverage
Disallow use of rubber tire chips
Allow the use of geogrid in place of washed rock
Provide the use of chamber credits
Specify material quality to remove the option for unwashed rock, poor quality sand and poor quality piping

1. Reduce the number of homeowner permits by increasing the cost for a permit if a homeowner pulls the permit and by requiring a letter of certification of the system by the contractor.
2. A best practices process should be developed for system inspection
3. Septic tank depth and burial depth should be part of the inspection
4. Manways should be a minimum of 30” wide.  This is a safety issue.
5. Photos of the soils evaluation and the system install should be part of the final permit package upon inspection
6. Higher permit fee for uncertified installers or homeowners
7. Permit costs should be representative of the cost of two inspections and paper work.
8. A permit should be required for system repairs or enhancements.
9. Need to identify what constitutes a repair
10. There should be an enforceable fine for unpermitted systems.  Real Estate inspections are finding that no permit was ever pulled on many systems.
11. Health Officers need to be trained in Onsite Wastewater
12. A central database of all permits pulled and all systems installed should be developed and maintained.  This would help with land use planning in more populated areas.

This survey provided a rare opportunity for onsite wastewater stakeholders to provide input on regulatory change that impacts the industry.  If you have suggestions for improvement or change that you would like to be brought forward for consideration, contact the SOWMA office and we will bring those ideas forward.  Comments and suggestions should not be limited to the regulations, but should include suggested improvements for the Saskatchewan Onsite Wastewater Disposal Guideline, as that document supports the regulations.