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Ontario · O. Reg. 153/04

Record of Site Condition (RSC)

Filed in the Environmental Site Registry when a property's use is changing to something more sensitive than what came before — confirming the site meets the standards the new use requires.

Regulation
O. Reg. 153/04as amended
Filed in
Environmental Site Registryrequired before the new use proceeds
Common trigger
Change of useto a more sensitive use, e.g. residential
Benefit
Reduced liabilityfor pre-existing contamination

What a Record of Site Condition is

The condition of the site must meet the applicable standards for its new use, or the standards set out in an approved Risk Assessment.

A Record of Site Condition is typically required if the use of a property is being changed to a new use that is more sensitive than the previous one — for example, converting an auto repair garage, a gasoline service station or a dry cleaner into residential use. These properties often include vacant or abandoned sites previously used for commercial or industrial activity, known as brownfield properties.

In these cases, filing the Record of Site Condition in the Environmental Site Registry is required before the new use of the property is legally permitted to proceed. Filing may also reduce the property owner's liability for contamination that existed before their ownership.

We prepare the supporting Phase 1 and Phase 2 assessments, then the RSC filing itself, under O. Reg. 153/04.

Common triggers for an RSC

A change from a less sensitive to a more sensitive use is the pattern behind most filings.

Auto repair garage → residential
Gasoline service station → residential
Dry cleaner → residential
Vacant or abandoned industrial → sensitive use
Factories & scrapyards → redevelopment
Waterfront brownfield → redevelopment

Common questions

Record of Site Condition Questions

When is a Record of Site Condition required?

Typically when a property's use is changing to a new use that is more sensitive than the previous one — for example, converting an auto repair garage, gasoline service station or dry cleaner into a residential use. Vacant or abandoned properties formerly used for industrial or commercial activity, including brownfield sites, are also commonly involved.

What does the RSC confirm?

That the condition of the site meets the applicable standards for the new, more sensitive use — or the standards set out in an approved Risk Assessment, where one has been used instead of meeting the generic standards.

Where is it filed?

In the Environmental Site Registry. Filing is required before the new use of the property is legally permitted to proceed.

Does filing reduce liability?

Yes, filing an RSC can reduce the property owner's liability for pre-existing contamination, which is one of the reasons it matters even where it is not strictly required by a municipal approval.

Have the RSC rules changed recently?

Yes. Amendments in October 2025 eased requirements for certain low-risk projects, following earlier streamlining in 2019. See our Insights coverage of both changes for the current detail.

Changing the Use of a Property?

Send us the property address and the intended new use — we'll confirm what filing is required and reply with a fixed quote, usually within one business day.