Clubroot Management: Risk-based Guidance Document
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Clubroot Management: Risk-based Guidance Document 31 MAY 2021 PREPARED BY: PARAGON SOIL AND ENVIRONMENTAL CONSULTING INC.
REVISION HISTORY RECORD Revision Date of Next Responsible Description of Change or Review Approval No. Issue Review Outcome Date 2.0 July 2021 2024 EWG Updated to reflect current industry Approved by EOSC practice and scientific learnings July 2021 Clubroot Management aboutpipelines.com 1 of 49 Risk-based Guidance Document, May 2021
NOTICE OF COPYRIGHT Copyright © 2018 Canadian Energy Pipeline Association (CEPA). All rights reserved. CEPA and the CEPA logo are trademarks and/or registered trademarks of CEPA. The trademarks or service marks of all other products or services mentioned in this document are identified respectively. DISCLAIMER OF LIABILITY The Canadian Energy Pipeline Association (CEPA) is a voluntary, non-profit industry association representing the Canadian energy transmission pipeline industry. The Clubroot Management: Risk-based Guidance Document (hereafter referred to as the “Guidelines”) was prepared to provide common guidelines to enhance industry best practice and performance. Use of the Guidelines described herein is wholly voluntary. The Guidelines described are not to be considered industry standards and no representation as such is made. It is the responsibility of each pipeline company, or other user of these Guidelines, to implement practices to ensure the safe operation of assets. While reasonable efforts have been made by CEPA to assure the accuracy and reliability of the information contained in these Guidelines, CEPA and its member companies make no warranty, representation or guarantee, express or implied, in conjunction with the publication of these Guidelines as to the accuracy or reliability of these Guidelines. CEPA and its member companies expressly disclaim any liability or responsibility, whether in contract, tort or otherwise and whether based on negligence or otherwise, for loss or damage of any kind, whether direct or consequential, resulting from the use of these Guidelines. These Guidelines are set out for informational purposes only. References to trade names or specific commercial products, commodities, services or equipment constitutes neither an endorsement nor censure by CEPA of any specific product, commodity, service or equipment. The guidelines are intended to be considered as a whole, and users are cautioned to avoid the use of individual sections without regard for the entire document. Clubroot Management aboutpipelines.com 2 of 49 Risk-based Guidance Document, May 2021
Contents List of Tables 5 List of Figures 6 Acronym 7 Glossary 8 1. Introduction 9 1.1. Document Use 9 1.2. Clubroot Overview 10 1.2.1. Transmission 13 1.2.2. Distribution 13 1.2.3. Management and Mitigation 15 2. Risk Level Determination for Pipeline Activities 15 2.1. Overall Risk Level Determination Rating 16 2.1.1. Land Use 18 2.1.2. Soil Contact Activity 18 2.1.3. Soil Disturbance Activity 18 2.1.4. Clubroot Presence 18 2.2. Clubroot Sampling Program 19 2.2.1. Clubroot Sample Design 19 2.2.2. Clubroot Sample Protocol 19 2.2.3. Clubroot Laboratory Testing and Sampling Limitations 20 2.2.4. Documentation and Communication of Clubroot Sampling Results 20 3. Managing Clubroot Transmission Risk 23 3.1. Minimizing Vehicle and Equipment Movement 23 3.2. Clubroot Cleaning Protocol 23 3.2.1. Cleaning Stations 27 3.2.2. Documentation for Clubroot Cleaning 27 3.3. Soil Disturbance and Management Practices 29 3.3.1. Wet Weather 29 3.3.2. Erosion and Sediment Control 29 3.3.3. Imported Materials 30 4. Closure 30 Clubroot Management aboutpipelines.com 3 of 49 Risk-based Guidance Document, May 2021
5. References 31 Appendix A. Clubroot Distribution Maps by Province 34 Appendix B. Plans, Directives and Best Management Practices 38 Appendix C. Baseline Clubroot Sampling General Checklist 40 Appendix D. Example Checklist for Baseline Clubroot Sampling Equipment 41 Appendix E. Example Baseline Clubroot Sample Inventory Form 42 Appendix F. Example Cleaning Activities Log 43 Appendix G. How to Obtain 1-2 % Active Ingredient Bleach Solution 46 Appendix H. Example Cleaning Stations 47 Clubroot Management aboutpipelines.com 4 of 49 Risk-based Guidance Document, May 2021
List of Tables Table 1: Risk Level Determination for Pipeline Activities ................................................................. 16 Table 2: Cleaning Tier Descriptions ............................................................................................. 24 Table 3: Important Cruciferous Crop and Weed species in Canada ................................................... 29 Table 4: Water: Initial Bleach Product Mixing Ratios to Obtain 1-2 % Active Ingredient Bleach Solution 46 Clubroot Management aboutpipelines.com 5 of 49 Risk-based Guidance Document, May 2021
List of Figures Figure 1: Process Overview ........................................................................................................ 10 Figure 2: Life Cycle of a Plasmodiophora brassicae, the Pathogen that Causes Clubroot ...................... 11 Figure 3: Visual Identification of Clubroot Disease ......................................................................... 12 Figure 4: Cumulative Clubroot Infestations from 2003-2018 for Alberta, 2008-2019 for Saskatchewan and 2009-2019 for Manitoba ............................................................................................................ 14 Figure 5: Risk Level Determination for Pipeline Activities ................................................................ 17 Figure 6: Sample Design for Baseline Clubroot Sampling (Soil and/or Plant) ...................................... 19 Figure 7: Risk Level Determination following Clubroot Sampling ...................................................... 22 Figure 8: Level of Cleaning Required Before Moving to a New Work Area .......................................... 26 Figure 9: Cleaning Station Recommendations Based on Risk Level Determination .............................. 28 Figure A1: Distribution of Clubroot in Alberta (2005-2020) ............................................................. 34 Figure A2: Distribution of Clubroot in Saskatchewan (2008-2020) ................................................... 35 Figure A3: Distribution of Clubroot in Manitoba (2009-2020)........................................................... 36 Figure A4: Distribution of Clubroot in Ontario (2016) North ............................................................ 37 Figure A5: Distribution of Clubroot in Ontario (2016) South ............................................................ 37 Clubroot Management aboutpipelines.com 6 of 49 Risk-based Guidance Document, May 2021
Acronym C o Degrees Celsius % Percent ATV All-Terrain Vehicle CEPA Canadian Energy Pipeline Association CoC Chain of Custody DNA Deoxyribonucleic Acid GPS Global Positioning System ISO International Standardization Organization L Litres PCR Polymerase Chain Reaction qPCR Quantitative Polymerase Chain Reaction RoW Right-of-Way SDS Safety Data Sheet UTV Utility Task Vehicle Clubroot Management aboutpipelines.com 7 of 49 Risk-based Guidance Document, May 2021
Glossary Cautionary Note Provided on laboratory results for qPCR results below 1,000 spores/gram. Clean Free of soil, vegetation, and other debris. Cruciferous Crops Crops belonging to the Brassicaceae family (e.g. canola, mustard, cabbage, cauliflower, radish, broccoli, turnip). Cruciferous Weeds Undesirable plant species belonging to the Brassicaceae family (e.g. wild mustard, stinkweed, and shepherd’s purse) Equipment Machinery used in construction and reclamation that come in contact with and handles topsoil, includes access mats/rig mats utilized for access development, and rubber-tired equipment (e.g., vehicles, ATVs, UTVs). Gear Boots, hand tools, shovels, safety gear High Risk High risk of clubroot presence at a given location based on available data determined through consultation, project planning and site-specific planning and updated throughout the lifecycle of the project; thus, there is a high risk of transferring clubroot to another location. Level 1 Mechanical Clean Using physical means to achieve a clean condition (i.e., free of soil, vegetation, or other debris). An example of mechanical cleaning would be removing soil from a shovel with a scrapers and wire brushes or using pressurized air. Level 2 Wash Use a pressure washer at 2,000 to 3,000 psi or steam on all areas where soil can accumulate after mechanical cleaning. An industrial detergent can be added to enhance the degree of soil removal. Level 3 Disinfect Applying a 1-2 % active ingredient bleach solution and wait for a minimum of 15 minutes after Level 1 Mechanical Cleaning and Level 2 Wash to kill any remaining clubroot protists or spores. Low Risk Low risk of clubroot presence at a given location based on available data determined through consultation, project planning and site-specific planning and updated throughout the lifecycle of the project; thus, there is a low risk of transferring clubroot to another location. Moderate Risk Moderate risk of clubroot presence at a given location based on available data determined through consultation, project planning and site-specific planning and updated throughout the lifecycle of the project; thus, there is a moderate risk of transferring clubroot to another location. Modified Level 3 Disinfect Use a 1-2 % active ingredient bleach solution and wait for a minimum of 15 minutes after Level 1 Mechanical Cleaning to kill any remaining clubroot protists or spores. This disinfection method must only be used in dry or frozen conditions. Pipeline Activities Pre-construction (e.g., planning), construction (e.g., new build), operations (e.g., brushing, post-construction monitoring), maintenance (e.g., integrity digs, cathodic protection, depth of cover remediation), decommissioning and abandonment activities Topsoil The uppermost layer of soil. It has the highest concentration of organic matter and microorganisms and is where most of the biological soil activity occurs. It is also the zone that typically has the highest concentration of resting spores in clubroot-infected fields. Work Area The geographic location of the project. Clubroot Management aboutpipelines.com 8 of 49 Risk-based Guidance Document, May 2021
1. Introduction Clubroot is a soil-borne disease of canola and other crops in the cabbage and mustard (Brassicaceae) family. This group of plants was previously known as the Cruciferae family. Cruciferous crops display enormous diversity and are used as sources of oil, vegetables, mustard condiments, and fodder. Cruciferous vegetables like broccoli, Brussel sprouts, cabbage, cauliflower, Chinese cabbage, kale, kohlrabi, radish, rutabaga, and turnip, are susceptible to clubroot, as are many cruciferous weeds, for example, wild mustard, stinkweed, and shepherd’s purse (GOA 2021). There are currently no economical control measures that can remove this pathogen from a field once it has become infested, therefore management of clubroot has become a key agricultural issue in recent years, given the risk posed through the inadvertent introduction and spread of the disease. The objectives of this document are to provide guidance around assessing risk for clubroot transmission and a summary of best management practices for mitigation of clubroot risk throughout Pipeline Activities, which include: pre-construction (e.g., planning), construction (e.g., new build), operations (e.g., brushing), maintenance (e.g., integrity digs, cathodic protection, depth of cover remediation), decommissioning and abandonment activities. This document was developed using information provided by Canadian Energy Pipeline Association (CEPA) member companies in 2016, and updated and revised in 2021. Current best management practices used by several CEPA member companies were evaluated. This document is intended to be reviewed and amended as required to update clubroot distribution maps and best management practices according to new research and experience. For specific project procedures for individual CEPA member companies, refer to information available through each operator. 1.1. DOCUMENT USE This document may be used as a general guide and resource to assist with the development of clubroot management plans. The emphasis in this document is placed on risk-based management. Systems and procedures are designed around a three-tiered evaluation outcome (e.g., whether the work area is considered to be high, moderate or low risk for clubroot transmission). The goals are to provide clarity around planning and cleaning scenarios, and overall clubroot management. To use this document, review the overall symptoms and impacts (Section 1.2), transmission variables and vectors of transmission (Section 1.2.1), known distribution (Section 1.2.2), and current management and measures used to mitigate the overall clubroot problem (Section 1.2.3). Then review the general steps to determine and evaluate risk level (Section 2.1), and plan for baseline sampling (Section 2.2), if required. Mitigations for reducing clubroot transmission risk through minimizing vehicle and equipment movement (Section 3.1), clubroot cleaning protocols (Section 3.2), soil disturbance and management practices (Section 3.3) are provided, along with all necessary documentation processes during Pipeline Activities. Additional steps or procedures may also be necessary during the construction phase as the work progresses. A general overview of the process is illustrated in Figure 1. Clubroot Management aboutpipelines.com 9 of 49 Risk-based Guidance Document, May 2021
Figure 1: Process Overview 1.2. CLUBROOT OVERVIEW Clubroot is a soil-borne disease caused by Plasmodiophora brassicae, a microscopic protist that shares characteristics with fungi and amoeba. It is an obligate parasite, meaning it cannot grow and multiply without a living host. The life cycle of P. brassicae is shown in Figure 2. The disease is visibly identified within a host by the swollen, misshapen, galled, or “clubbed” roots along with stunting, yellowing, or wilting of the aboveground growth of plants (Photos 1 through 5, Figure 3). A number of pathogens may cause similar symptoms (including nematodes, fungi, and bacteria). Identification is confirmed by examining the roots and verified through dissection – clusters of enlarged host cells containing plasmodia and amoebae can be observed with proper staining (Grabowski 1999). Once established, deformed plant roots may restrict water and nutrient uptake, resulting in premature ripening or plant death. Symptoms may vary slightly from host to host (Grabowski 1999). The first observable ground symptom is day wilting; otherwise healthy-looking plants appear to wilt on hot, dry days, but then recover once the sun sets or temperatures cool. As the disease progresses, leaves typically yellow and die. Diseased plants are stunted compared to uninfected plants. When exposed, roots exhibit small knot-like galls in new infections, whereas long spindle-shaped clubs on primary and lateral roots are displayed in more developed infections. Clubroot Management aboutpipelines.com 10 of 49 Risk-based Guidance Document, May 2021
Yield loss is dependent on many factors, including infection timing, soil moisture and temperature, spore load, soil pH, soil texture, host genotype, pathogen pathotype, etc. (Canola Council of Canada 2021a). An early infection with favorable conditions and moderate to high spore loads can lead to 100 % loss, while low spore loads in less favorable conditions may result in little to no yield loss (Canola Council of Canada 2021a). Figure 2: Life Cycle of a Plasmodiophora brassicae, the Pathogen that Causes Clubroot Source: Ohio State University via Government of Alberta (2021) Clubroot Management aboutpipelines.com 11 of 49 Risk-based Guidance Document, May 2021
Figure 3: Visual Identification of Clubroot Disease Clubroot Management aboutpipelines.com 12 of 49 Risk-based Guidance Document, May 2021
1.2.1. TRANSMISSION Clubroot reproduces through the production of spores released from galls formed on the roots of infected host plants. The spores germinate in the spring, producing zoospores that can swim short distances in soil water, and infect the root hairs of other plants. While the swimming zoospore phase is relatively short- lived, the mobility of the zoospores allows them to seek and find potential host plants (Canola Council of Canada 2021a). After initial infection through root hairs or wounds on the host plant, the zoospore forms an amoeba-like cell that multiplies and joins with others to form a plasmodium (mass of protoplasm with many nuclei). This mass eventually divides to form many secondary zoospores that are released into the soil after the host roots begin to decompose (Canola Council of Canada 2021a). Warm soil (20 to 24 degrees Celsius [ oC]), high soil moisture content (moderately well to poorly drained soils), and acidic soil (pH less than 6.5) provide conditions favourable to disease development (Canola Council of Canada 2021a). Soils with a pH greater than 7.2 tend to inhibit spore germination and disease development, although the disease can still develop (Canola Council of Canada 2021a). Areas of a field with more soil moisture typically see the most severe infestations, such as areas with higher clay content, depressions or subsoil horizons that cause poor water infiltration (like Luvisolic or Solonetzic soils). Clubroot transmission is of concern in cropped fields during both canola and non-canola cropping years (Canola Council of Canada 2021a). In recent years, attention has been given to potential influx areas from affected adjacent fields (water runs and shared edges of diseased fields). Some studies have started to investigate vertical distribution within the soil profile; however, little is known about resting spore viability at greater depths. Clubroot is spread by the movement of soil containing soil-borne resting spores and soil transport occurs mainly on farm machinery (Canola Council of Canada 2021a). Minimizing the movement of soil into and out of the field is the best way to prevent the transmission of clubroot. Preventing the transmission of clubroot is a challenge during Pipeline Activities, as soil contact and disturbance are regularly required. Soil contact and disturbance can occur with gear (e.g., boots, hand tools shovels, etc.), vehicles and equipment during Pipeline Activities. Additionally, clubroot spore transmission can be amplified during periods of soil disturbance through an elevated risk of wind and/or water erosion due to an increase in exposed soil surface area. Clubroot spores can travel great distances (greater than one kilometer) by wind-mediated soil erosion. Undesirable cruciferous plants or weeds can act as a clubroot host where uncontrolled (Alberta Clubroot Management Committee [ACMC] 2014). Finally, there is potential for clubroot to be introduced through imported reclamation materials (e.g., topsoil or fill, gravel, straw or seed mixes). 1.2.2. DISTRIBUTION Clubroot is present in many of the agricultural regions of the world, including Canada. According to the Canola Council of Canada (2021a), clubroot has infected cruciferous vegetable crops for several years across Ontario, Quebec, British Columbia, and the Atlantic provinces; however, the first case of visible clubroot symptoms in a canola field in Canada was in 2003 near Edmonton, Alberta (Manitoba Agriculture 2021a). Since then, clubroot has continued to spread in canola growing regions in Canada, particularly in central Alberta where there is extensive canola production and the highest incidence of clubroot infection. The Canola Council of Canada (2021a), highlights the following prairie provinces: • As of Fall 2019, clubroot was identified in 296 individual fields in Manitoba through positive soil analysis, with an additional 35 fields confirmed to have visual field symptoms • As of Fall 2020, clubroot has been identified in over 3,000 fields in Alberta • As of Fall 2020, clubroot has been identified in 40 municipalities in Saskatchewan Clubroot Management aboutpipelines.com 13 of 49 Risk-based Guidance Document, May 2021
A cumulative clubroot map shows spread across the prairie provinces: from 2003-2018 for Alberta; from 2008-2019 for Saskatchewan; and, from 2009-2019 for Manitoba (Figure 4). Data is more readily available for clubroot infestations in canola, in the prairie provinces, where research is more concentrated but clubroot continues to be a significant issue for cruciferous vegetable crops in southern British Columbia and in the eastern provinces. Detailed clubroot maps by province are included in Appendix A. For the most current information on field infestations in specific areas, visit the local government website directly or contact the local pest inspector. In the field, clubroot has a patchy or non-uniform distribution, often distinguishable in canola fields through premature ripening (Canola Council of Canada 2021b; Photo 1). Most clubroot is found within 50 metres of the field access. Figure 4: Cumulative Clubroot Infestations from 2003-2018 for Alberta, 2008-2019 for Saskatchewan and 2009-2019 for Manitoba Clubroot Management aboutpipelines.com 14 of 49 Risk-based Guidance Document, May 2021
1.2.3. MANAGEMENT AND MITIGATION According to the Canola Council of Canada (2021a), there are currently no economic measures to remove clubroot from a field once it has been infected. Land management techniques for controlling clubroot once it has been introduced can be costly. Resting spores are very hardy, can overwinter in the soil, and may survive in soil for up to 20 years (Canola Council of Canada 2021a), although many of the resting spores appear to become inactive or non-viable after a two year break from a host crop (Canola Council of Canada 2021a). It is possible to limit the spread of the pathogen and reduce the incidence and severity of the disease, through management and mitigation. For landowners, management of infested fields through the combination of scouting and record keeping, appropriate sanitation practices (of machinery and equipment accessing fields), crop rotation (e.g., a minimum of four years for canola), controlling land access, soil amendments, and the cropping of clubroot-resistant varieties are the most effective methods of controlling this disease (Canola Council of Canada 2021a). During Pipeline Activities, the primary mitigation for clubroot transmission is to avoid the movement of soil between fields. This is largely accomplished through equipment sanitation, and prevention of wind or water erosion. Guidance for determining appropriate cleaning level based on risk factors is included in Section 3. For specific cleaning protocols and measures for erosion control, refer to the operator’s best management practices. Regulatory guidance, including national and provincial plans, directives and best management practices have been provided for reference in Appendix B. County and Municipal District plans are an additional resource for clubroot information and should be consulted during project planning. 2. Risk Level Determination for Pipeline Activities Clubroot transmission risk during Pipeline Activities can be categorized into three risk ratings (low, moderate, and high) by determining the risk level of contributing factors such as land use, the degree of planned soil contact or soil disturbance and the presence of clubroot disease in the work area. All contributing factors for a project may not fall within the same risk level rating, and project specific tasks may overlap multiple risk levels. The final risk level determination is at the discretion of the operator with the best understanding of the project and conditions, and their internal best management practices. An overview of risk level determination for Pipeline Activities is presented in Table 1. Clubroot Management aboutpipelines.com 15 of 49 Risk-based Guidance Document, May 2021
Table 1: Risk Level Determination for Pipeline Activities RISK LAND USE SOIL CONTACT SOIL DISTURBANCE ACTIVITY1 CLUBROOT LEVEL ACTIVITY DISEASE RATING PRESENCE Low • Forested Soil contact is Topsoil is not to be disturbed as part of Pipeline Activities. Clubroot presence minimal. Access to Examples include: has not been • Native work area is via • Instrumentation Checks identified through Range high-grade road or the desktop review • Post-Construction Monitoring • Forested- on foot Pasture Moderate • Cropland Vehicle or Topsoil may be disturbed as part of Pipeline Activities. Clubroot presence equipment access Examples include: has not been • Pasture with soil contact • Vegetation clearing identified through • Hayland the desktop review • Cathodic Protection • Depth of cover assessment High • Cropland Vehicle or Topsoil is to be disturbed or potentially disturbed as part of Clubroot is known equipment access Pipeline Activities. to be present on or • Pasture with soil contact Examples include: in proximity to the • Hayland work area • Topsoil salvage and RoW Preparation • Plough-in construction • RoW Clean Up • Integrity Digs • Decommissioning (e.g., removal of any buried facilities or pipe) Notes: 1 Not an exhaustive list, and Pipeline Activities may vary on degree of soil disturbance based on site specific conditions. Con sult with Operators BMPs for additional information related to mitigation for clubroot transmission. 2.1. OVERALL RISK LEVEL DETERMINATION RATING An overview of the process for risk level determination for Pipeline Activities is provided in Figure 5. Clubroot risk level (low, moderate, or high) should be displayed on planning documents (e.g., maps, figures, and/or Environmental Alignment Sheets) for effective communication of risk level to all involved parties. The determined risk level will form the basis of the best management practices regarding clubroot cleaning protocols on each work site and inform and prepare employees, contractors, and subcontractors. It may also be a source for training (e.g., cleaning crews). For the most conservative approach, the most limiting of individual factors would determine the overall risk rating. Ultimately, the operator must follow the conditions outlined in the license or project approval and will select the level of risk and associated cleaning protocols and mitigation that reflects their best management practices. Where work areas are identified as moderate or high risk for clubroot presence or transmission, a clubroot sampling program may be desired, for details on designing a clubroot sampling program, refer to Section 2.2. The following sections provide guidance and suggested resources to characterize clubroot transmission risk and to guide discussion around project work. Clubroot Management aboutpipelines.com 16 of 49 Risk-based Guidance Document, May 2021
Figure 5: Risk Level Determination for Pipeline Activities Note: All contributing factors for a project may not fall within the same risk level rating, and project specific tasks may overlap multiple risk levels. The final risk level determination is at the discretion of the operator with the best understanding of the project and conditions, and their internal best management practices. Clubroot Management aboutpipelines.com 17 of 49 Risk-based Guidance Document, May 2021
2.1.1. LAND USE Land use mapping is critical in the determination of clubroot transmission risk. Lands that are passively managed (i.e., forested-pasture, undisturbed lands with native vegetation [native range] and forested land) are at a low risk of clubroot disease based on current land management practices (minimal soil contact or soil disturbance). Where these land uses are present, the operator may request that potential clubroot encroachment issues are observed from adjacent fields for consideration during assessment, such as shared boundaries or areas of shared standing water. Lands that are more intensively managed (i.e., cropland, pasture or hayland) are at an increased risk (moderate or high) for clubroot disease based on increased soil contact and disturbance through land management practices. Increased soil contact and soil disturbance can create areas of bare soil which increases the risk of wind and water erosion (an essential requirement or vector of clubroot spore transmission and distribution) and can increase establishment potential for undesirable cruciferous plants and weeds (e.g., wild mustard, stinkweed and shepherd’s purse) that may act as a host plant. In addition, the use of equipment during cultivation increases potential contact with soil and plant material being transported from neighbouring fields (e.g., increased exposure risk). Land use information for work areas may be available through several sources. A review of current aerial imagery or contact with the landowner can provide this information; however, it may be readily available through pre-disturbance assessment survey (where completed). If applicable, refer to the Environmental Alignment Sheets for pipeline projects. This information may also be verified during clubroot sampling programs for Pipeline Activities. 2.1.2. SOIL CONTACT ACTIVITY Soil contact (contact between gear, vehicles or equipment and soil) increases the potential for clubroot transmission through exposure. Soil contact is considered low risk where access to the work area is using a high-grade road (no soil contact) and where work is completed on foot using hand tools (cleaning is more controlled using booties and/or following operators clubroot cleaning protocols for gear). Soil contact is considered moderate risk where an established vegetation layer (e.g., a strong sod layer) exists, and acts as a partial barrier between the work area and the soil surface. Soil contact is considered high risk where vehicles or equipment travel directly on the exposed soil surface. 2.1.3. SOIL DISTURBANCE ACTIVITY Soil disturbance increases the potential for greater soil movement through interaction which increases the risk of clubroot transmission. Where topsoil is not to be disturbed (e.g., instrumentation checks for valve sites, post-construction monitoring without vegetation issues, abandonment activities, etc.), the soil disturbance is not applicable, and the activity is considered low risk. When topsoil may be disturbed through project work, but any disturbance is expected to be minimal (e.g., vegetation clearing, cathodic protection, depth of cover assessment, etc.) the soil disturbance is moderate, and the activity is considered to be of moderate risk. Because project work can be variable in specific task, the risk category for soil disturbance activity is at the discretion of the operator. Where topsoil is planned to be disturbed or potentially disturbed (e.g., topsoil salvage and RoW preparation, plough in construction, RoW clean up, integrity digs, decommissioning [e.g., removal of any buried facilities or pipe], etc.) the soil disturbance level is high, and the activity is considered high risk. 2.1.4. CLUBROOT PRESENCE To prevent the spread of clubroot, it is critical to know where clubroot already exists within or in proximity to the work area. Data regarding clubroot status may be available or requested through the following sources: • County, Municipality or District offices Clubroot Management aboutpipelines.com 18 of 49 Risk-based Guidance Document, May 2021
• Landowners • Industry or government associations (e.g., British Columbia Ministry of Agriculture, Canola Council of Alberta, SaskCanola, Saskatchewan Ministry of Agriculture, Manitoba Canola Growers Association) Landowners may have records of previously completed clubroot survey or sample data, but asking for any land history (e.g., observed clubroot symptoms) is equally important. Additional information collected from landowners may assist operators in further refining clubroot transmission risk, including historic land uses, crop rotations (where applicable), landowner clubroot management and biosecurity protocols (where applicable), and field entrance locations. This information can also be used where a clubroot sampling program is proposed. For information on clubroot sampling, see Section 2.2. 2.2. CLUBROOT SAMPLING PROGRAM Where moderate or high risk is identified through the risk assessment or as per operator requirements, a soil or vegetation sampling program may be completed. The benefits of a sampling program are the ability to develop more targeted clubroot cleaning protocols. Clubroot sampling design generally follows Section 2.2.1, but individual operators requirements may vary. 2.2.1. CLUBROOT SAMPLE DESIGN Sampling intensity and locations are dependent on specific requirements of operators. Some activities may require sampling the full extent of the RoW at regular intervals, while others may focus on moderate or high-risk areas only. Specific targets within at-risk work areas for clubroot presence include: • Field entrances, prominent drainages into the field, and low areas • Areas with clubroot-symptomatic plants • Areas of poor plant performance Samples are typically collected from five discrete subsamples, collected in a “W” pattern that does not cross quarter section boundaries or into new land uses (Figure 6). Sample locations should be identified prior to mobilizing to the field. Circumstances may arise where subsample locations are not able to be collected as planned or as outlined in Figure 6 due to field conditions (e.g., new disturbance, etc.). Field crews should document rationale for modification of the sample locations. Figure 6: Sample Design for Baseline Clubroot Sampling (Soil and/or Plant) 2.2.2. CLUBROOT SAMPLE PROTOCOL Planners and field crews can follow the baseline sampling general protocol checklist outlined in Appendix C. All-terrain vehicles (ATVs) and utility task vehicles (UTVs) are not typically utilized for baseline clubroot sampling. Crews should travel on foot whenever possible to avoid disturbing topsoil, and to reduce the amount of equipment that needs to be cleaned. An example checklist for suggested sampling equipment is provided in Appendix D. Clubroot Management aboutpipelines.com 19 of 49 Risk-based Guidance Document, May 2021
Clubroot samples must be submitted to an International Standardization Organization (ISO) certified laboratory. The selected laboratory should be engaged early in the planning process to ensure that sampling and submission protocols are followed, and that the required volume of topsoil is collected and/or plants sampled are appropriate. Discrete soil samples should be combined for a composite sample and submitted for analysis. During plant sampling, five to 10 plants should be collected at each discrete subsample location. If visible symptoms of clubroot are present (i.e., root galls) all symptomatic plants should be submitted for analysis. If no symptoms of clubroot are visible, one plant from each discrete subsample should be submitted for analysis. A current list of commercial laboratories that provide diagnostic services for clubroot plant and soil sampling can be found on the Canada Canola Council website. Sample handling and chain of custody (CoC) requirements should be confirmed with the laboratory selected for sample analysis. If conditions permit, plant sampling may also be completed in lieu of or in combination with soil sampling. Visual indicators can be very accurate (e.g., galls observed in discoloured patches of canola) and less expensive than soil testing. Plant sampling is generally limited to the growth stage of plant (i.e., late July to August). Soil sampling can be completed at any time of year; however, spore populations are generally highest in the Fall following decay of infected roots and release of resting spores into soil. 2.2.3. CLUBROOT LABORATORY TESTING AND SAMPLING LIMITATIONS Clubroot is not evenly distributed within an infected field; therefore, the objective of any sampling program prior to soil disturbance activities is to sample as much of the work area as is practicable, and the field access points and nearby topographically low areas. Soil samples are typically analyzed using a conventional Polymerase Chain Reaction (PCR)/ Deoxyribonucleic acid (DNA) analysis method to identify the presence or absence of clubroot spores, using the standard minimum detectable limit of 1,000 spores/gram of soil. Knowing the quantity of spores (qPCR) in addition to the simple presence/absence PCR result allows for evaluation of the field distribution of spores and helps to assess the risk of disease manifestation. It is of note that each laboratory may have slightly different processes for how clubroot analysis is completed. It is important to determine if the detection limits that are in place will meet project objectives. If the presence of clubroot DNA is detected by PCR and/or qPCR for soil, or visual analysis in laboratory for plants, it should be assumed that the field is infested, and there is a risk for transfer of clubroot spores during Pipeline Activities. A cautionary note will be provided on soil laboratory results for results below 1,000 spores/gram. As clubroot can take several years to manifest to an infection after it is introduced to an area (Canola Council of Canada 2021a), baseline sampling may not capture soil clubroot presence at all sample locations. It is at the discretion of the operator how to manage a cautionary note. The conservative approach would be to resample the field or treat a cautionary note as clubroot positive. 2.2.4. DOCUMENTATION AND COMMUNICATION OF CLUBROOT SAMPLING RESULTS A tracking system is recommended for use during sample collection and laboratory submission. An example template for a sample inventory form is provided in Appendix E. Other methods include electronic tracking with Global Positioning System (GPS) equipment, and/or use of laboratory CoC form. A summary report should be prepared to provide the results of the clubroot baseline sampling, including the presence of the pathogen in fields crossed by the RoW and/or work area. Data collected, photo records, and summaries of mitigation methods used during sampling should be included. Clubroot detection locations can be added to planning documents (e.g., maps, figures, and/or Environmental Alignment Sheets). As displayed on Figure 7, where negative results have been provided through a clubroot sampling program, a work area identified with moderate or high-risk factors may be treated as low risk, depending on the operator’s best management practices. Clubroot Management aboutpipelines.com 20 of 49 Risk-based Guidance Document, May 2021
Where positive results have been provided through clubroot sampling, a work area should be treated as high risk. Clubroot Management aboutpipelines.com 21 of 49 Risk-based Guidance Document, May 2021
Figure 7: Risk Level Determination following Clubroot Sampling Clubroot Management aboutpipelines.com 22 of 49 Risk-based Guidance Document, May 2021
3. Managing Clubroot Transmission Risk Reducing clubroot transmission risk can be achieved through minimizing vehicle and equipment traffic to and from the work area, cleaning gear, vehicles, and equipment and modifying soil disturbance practices for challenging conditions. The following section outlines best management practices for minimizing soil contact and movement during soil disturbance activities. Mitigation measures for preventing clubroot transmission should be available to all involved parties. Clubroot plans should include access points, soil handling, and identify mitigative measures based on the determined risk and operators’ internal procedures. As clubroot transmission risk is linked to soil disturbance activities and may be influenced by environmental conditions (e.g., wet weather or high wind speeds), it is recommended that the risk level be monitored throughout Pipeline Activities as project tasks and conditions change. Keeping records of the clubroot risk level determination assessment, any modified soil handling and soil conservation measures implemented during soil disturbance and cleaning documentation is recommended to demonstrate operator’s due diligence. 3.1. MINIMIZING VEHICLE AND EQUIPMENT MOVEMENT The best way to limit soil movement from one field to another is to limit equipment movement, particularly from high (clubroot confirmed) to moderate or low-risk areas. Using dedicated topsoil- handling equipment and personnel for high-risk areas is ideal and should be considered when resources allow. If having dedicated crews and equipment is not feasible, direction of travel should be planned from lower risk to higher risk areas to avoid the spread of clubroot-infected soil. All traffic to and from fields should be minimized to the extent possible during project work, and non- essential traffic should be prohibited. Any individuals or companies who may be accessing the work area should be informed of the clubroot risk and of the designated cleaning procedures and cleaning station locations (where applicable). Vehicle (including ATV and UTV) and equipment travel across the work area should be minimized as much as is practicable. Vehicles should be restricted to roads where possible. 3.2. CLUBROOT CLEANING PROTOCOL The clubroot cleaning protocol required in a work area is dependent on the outcome of the risk level determination and operators’ specific requirements. Clubroot cleaning typically falls within the four cleaning tiers identified in Table 2. Clubroot cleaning protocols apply to all gear, vehicles and equipment that come into contact with soil, and cleaning must take place prior to entering a work area. Current operator best management practices focus primarily on topsoil. Examples of a personnel and equipment cleaning checklist and equipment cleaning field entry log are presented in Appendix F. Instructions for mixing a 1-2 % active ingredient bleach solution is presented in Appendix G. For determining the level of cleaning recommended when moving between work areas of both the same and differing risk levels, see Figure 8. Clubroot Management aboutpipelines.com 23 of 49 Risk-based Guidance Document, May 2021
Table 2: Cleaning Tier Descriptions CLEANING TIER DESCRIPTION APPLICATION SCENARIOS Level 1: Mechanical Remove loose and clinging soil and vegetative • Complete Level 1 (Mechanical Clean) when moving Clean debris from gear, vehicles and equipment using between low-risk fields. hand scrapers, wire brushes, and/or compressed air. • Level 1 (Mechanical Clean) must be completed at a minimum before leaving any parcel and, before travelling on public roads. • If Level 1 (Mechanical Clean) does not sufficiently remove mud and debris, complete Level 2 (Mechanical Clean/Wash). Level 2: Mechanical Level 1 Mechanical Clean and: • Complete Level 2 (Mechanical Clean/Wash) when Clean and Wash Use a pressure washer at 2,000 to 3,000 pounds moving between moderate-risk fields or from per square inch (psi) or steam on all areas where soil can accumulate – use a turbo nozzle if moderate to high-risk fields. Modified Level 3 available. Use an industrial detergent to enhance (Mechanical Clean/Disinfect) can be used where the degree of soil removal. conditions are dry/frozen and meet the Modified Level 2 (Wash) should remove any remaining Level 3 requirements. debris from Level 1 (Mechanical Clean). • Typically required after working in muddy areas, weedy areas, or when working in organic/certified seed areas. Level 3: Mechanical Level 2 (Mechanical Clean and Wash) and: • Equipment should arrive to work area having Clean, Wash and Disinfect by misting with a 1-2 % active completed Level 3 (Mechanical Disinfect ingredient bleach solution (or comparable alternative of equivalent efficacy). Keep wet with Clean/Wash/Disinfect). the solution as long as is practical (up to 15 • If a vehicle is temporarily mobilized to another minutes in non-frozen conditions). work area, it should be Level 3 (Mechanical Clean/Wash/Disinfect) cleaned before returning, unless otherwise directed by the operator. • Complete Level 3 (Mechanical Clean/Wash/Disinfect) when moving from a moderate-risk field to a low-risk field or when moving from a high-risk field to a low, moderate or high-risk field. Modified Level 3 (Mechanical Clean/Disinfect) can be used where conditions are dry/frozen. Modified Level 3: Level 1 (Mechanical Clean) in dry or frozen • Typically required when Level 2 (Mechanical Mechanical Clean conditions where physical removal of soil and Clean/Wash) is not required and the gear, vehicles, and Disinfect vegetative debris is achievable and: Disinfect by misting with a 1-2 % active and equipment are clear of debris. ingredient bleach solution (or comparable • Only to be used in dry or frozen conditions alternative of equivalent efficacy). Keep wet with the solution as long as is practical (up to 15 minutes in non-frozen conditions). It is recommended that all gear, vehicles and equipment be cleaned with a Level 3 (Mechanical Clean/Wash/Disinfect) before arriving to the work area and before moving from a high-risk work area to a low, moderate or high-risk work area. This level of cleaning also applies when moving from a moderate- risk to a low-risk work area. Where conditions are dry or frozen, and soil and vegetative debris is removable by mechanical means, a Modified Level 3 (Mechanical Clean/Disinfect) may be considered at the discretion of the operator, based on site conditions. Clubroot Management aboutpipelines.com 24 of 49 Risk-based Guidance Document, May 2021
For moving from a moderate-risk work area to a moderate or high-risk work area, a Level 2 (Mechanical Clean/Wash) or Modified Level 3 (Mechanical Clean/Disinfect) is recommended based on site conditions and operator’s best management practices. For travel from a low-risk work area to a low, moderate or high-risk work area, a Level 1 (Mechanical Clean) is recommended. Clubroot Management aboutpipelines.com 25 of 49 Risk-based Guidance Document, May 2021
Figure 8: Level of Cleaning Required Before Moving to a New Work Area Note: * A Modified Level 3 (Mechanical Clean/Disinfect) may be considered at the discretion of the operator, based on site conditions. Clubroot Management aboutpipelines.com 26 of 49 Risk-based Guidance Document, May 2021
3.2.1. CLEANING STATIONS Where required by the operator, implement cleaning stations to support the removal of soil and plant debris from gear, vehicle and equipment that come into contact with soil. Equipment cleaning stations fall under two main categories: • Mechanical and/or Compressed Air Cleaning Stations – using hand scrapers, shovels, brooms, and wire brushes and/or using portable compressed air equipment • High-pressure Cleaning Stations – using portable pressure washer units with water tanks Location and Design Purposefully designed cleaning stations with high-pressure washers, steam, and/or compressed air should be set up at the exit points of fields, or before entry points (Figure 9). Gravel or grassed sites should be used if possible, where the risk of runoff, erosion, and sedimentation is low. Examples of cleaning station design are provided in Appendix H; however, each operator should provide guidance on cleaning station requirements. Where water is used in washing activities and/or bleaching solution is used during disinfecting activities, cleaning station waste should be contained and must be managed to adhere to provincial and municipal regulations. Cleaning stations should be clearly marked with signs and flagging in both directions of travel, indicating the level of cleaning required at that station. Gear, vehicles and equipment should be inspected and documented prior to leaving cleaning stations. 3.2.2. DOCUMENTATION FOR CLUBROOT CLEANING Documentation of cleaning activities provides a record of mitigation efforts to prevent the spread of clubroot. Records should include equipment inspections, cleaning activities, and cleaning logs for all applicable gear, vehicles and equipment, and training for personnel. Photos are recommended to supplement these records, particularly for cleaning activities. Example documentation forms for cleaning activities, as well as an example equipment cleaning field entry log, is provided in Appendix F. Fields should include: • Date/time/work area • Gear, vehicle and equipment involved • Cleaning process applied (Level 1 Mechanical Clean, Level 2 Mechanical Clean/Wash, Level 3 Mechanical Clean/Wash/Disinfect, Modified Level 3 Mechanical Clean/Disinfect) • Personnel involved and sign off • Photographic record Clubroot Management aboutpipelines.com 27 of 49 Risk-based Guidance Document, May 2021
Figure 9: Cleaning Station Recommendations Based on Risk Level Determination Clubroot Management aboutpipelines.com 28 of 49 Risk-based Guidance Document, May 2021
3.3. SOIL DISTURBANCE AND MANAGEMENT PRACTICES Modifications to existing soil disturbance and management practices reduce clubroot transmission risk during Pipeline Activities. Mitigation measures to implement during wet weather, for erosion and sediment control and assessing importing material for bringing into the work area are outlined below. 3.3.1. WET WEATHER Avoid equipment use and travel across work areas during wet conditions, particularly on moderate and high-risk work areas with bare soil. Wet soil can cling to equipment, and runoff may transport clubroot spores to unaffected areas. Completing soil disturbance activities during winter months when topsoil is frozen may reduce the risk of transporting clubroot spores unless achieving a mechanical clean is not possible and sterilization may be more challenging. Equipment movement, material handling, and cleaning requirements when working under frozen conditions should remain the same as under non- frozen conditions, as dormant clubroot spores can be transported on equipment and remain viable even when frozen. 3.3.2. EROSION AND SEDIMENT CONTROL Any movement of soil from an infested site could spread clubroot spores. Controlling erosion and sediment movement throughout Pipeline Activities, and particularly during soil disturbance activities will help to mitigate clubroot spread. To reduce wind and water erosion, silt/sediment fencing may be required at watercourses, cleaning stations, and anywhere soil erosion might occur. Tackifiers may also be applied, if appropriate, to increase soil adhesion in wind erosion-prone topsoil where the material will be stockpiled for extended periods of time. Limit work under excessively wet (water erosion) or excessively dry (wind erosion) conditions. Cover crops may be used to stabilize soil and reduce sediment transport. When selecting seed mixes for permanent reclamation and revegetation; non-competitive annual seed (e.g., annual ryegrass [Lolium multiflorum], barley [Hordeum vulgare], and oats [Avena sativa]) should be used to stabilize topsoil temporarily at field entrances/exits and in stockpiles. Cruciferous species should not be included in any seed mixes as they can act as hosts for clubroot. Examples of cruciferous crop and weed species are provided for reference in Table 3. Table 3: Important Cruciferous Crop and Weed species in Canada CROP SPECIES WEED SPECIES Canola and industrial oil: Brassica • Garlic mustard (Alliaria petiolata) napus, Brassica rapa, and Brassica • Thale cress (Arabidopsis thaliana) juncea • Bitter cress (Barbarea vulgaris) Vegetable crops: Cruciferous crop • Hoary alyssum (Berteroa incana) cultivars (Brassica oleracea), swede or • Brown mustard (Brassica juncea), black mustard (B. nigari), rutabaga (Brassica napus), turnip • Warty-cabbage (Bunias orientalis) (Brassica rapa) and radish (Raphanus sativus) • Flax gold-of-pasture (Camelina alyssum), lesser gold-of-pasture (C. microcarpa), false flax (C. sativa) Condiments: Indian mustard (Brassica • Shepherd’s purse (Capsella bursa-pastoris) juncea), white mustard (Sinapis alba), • Hoary cress (Cardaria draba), hairy white-top (C. pubescens), and horseradish (Armoracia rusticana) • Hare’s ear mustard (Conringia orientalis) • Mountain tansy mustard (Descurainia incana), western tansy mustard (D. pinnata), tansy mustard (D. sophia) • Annual wall-rocket (Diplotaxis muralis), perennial wall-rocket (D. tenuifolia) • Hairy rocket (Erucastrum gallicum) Clubroot Management aboutpipelines.com 29 of 49 Risk-based Guidance Document, May 2021
CROP SPECIES WEED SPECIES • Western wallflower (Erysimum asperum), wormseed wallflower (E. cheiranthoides), European wallflower (E. hieracifolium), small-flowered wallflower (E. inconspicuum) • Dame’s rocket (Hesperis matronalis) • Field pepperweed (Lepidium campestre), common pepperweed (L. densiflorum), clasping pepperweed (L. perfoliatum), Virginia pepperweed (L. virginicum) • Watercress (Nasturtium officinale) • Ball mustard (Neslia paniculata) • Wild radish (Raphanus raphanistrum) • Australian yellow-cress (Rorippa austriaca), creeping yellow-cress (R. sylvestris) • White mustard (Sinapis alba), field mustard (S. arvensis) • Tall mustard (Sisymbrium altissimum), tall hedge-mustard (S. loeselii), hedge- mustard (S. officinale) • Pennycress (Thlaspi arvense) • Tower-mustard (Turritis glabra) 3.3.3. IMPORTED MATERIALS Where topsoil is to be imported to the work area, it should be assessed for clubroot potential prior to placement. If sampling is required by the operator, the sampling procedure is similar to the steps outlined in Section 2.2 with the following steps: STEP 1: Consult with an ISO-certified laboratory to confirm sampling and sample submission requirements. STEP 2: Take five subsamples from the stockpile or borrow area and combine them to yield one composite sample for analysis – Note: the “W” sample pattern is not required for topsoil from stockpiles; subsamples should be sufficiently spaced to capture a representative sample from the pile. STEP 3: Prepare CoC forms and submit samples, as per instructions from the ISO-certified laboratory. Straw, hay, and seed can also contain resting clubroot spores; avoid the use of straw or other materials from infested fields. Where practicable, use manure, straw and/or hay from the same landowner during application. 4. Closure All operators are encouraged to develop a documentation and communication process that will demonstrate how they are reducing the potential for transmission of clubroot, and how information is shared within the operating company. The type and level of documentation should be determined by individual operators but needs to show compliance with any clubroot prevention conditions listed on the project license or approval. In general, documentation components should include, but are not limited to, the following: • Feedback, results, or information from consultation activities, including landowner contact reports (if created) • Laboratory sample analyses and reports (if applicable) • The process used for equipment cleaning and tracking • Photographs (visual records of cleaning methods) Compliance during soil disturbance activities is facilitated through sharing and communicating results from the risk determination, clubroot baseline sampling (where completed) with all key personnel, Clubroot Management aboutpipelines.com 30 of 49 Risk-based Guidance Document, May 2021
providing orientations/training/task instructions, monitoring clubroot management activities, and adhering to clubroot transmission related mitigations during Pipeline Activities. The purpose of this document is to provide a general guide and resource to assist with the development of clubroot management plans, depending on risk level and site conditions associated with the work to be carried out. The emphasis in this document is placed on risk-based management, where recommendations and best management practices are dependent on the level of risk of clubroot spread. Operators project-based and operational documentation must be consulted in conjunction with this document. 5. References Alberta Clubroot Management Committee (ACMC). 2014. Alberta Clubroot Management Plan. Alberta Agriculture and Forestry. Available at: https://open.alberta.ca/dataset/b7210af8-2660-4055-b171- 4cbd6ffa463e/resource/2883d945-9938-4655-906a-415744cb3314/download/2014-140-638-2-web.pdf. Accessed March 2021. Canadian Association of Petroleum Producers (CAPP). 2008. Best Management Practices: Clubroot Disease Management. Available at: http://www.capp.ca/publications-and-statistics/ publications/139848. Accessed in September 2017. Canola Council of Canada. 2016. Canola Watch. Available at: http://www.canolawatch.org/ 2016/02/03/clubroot-maps-what-do-they-tell-you/. Accessed in March 2021. Canola Council of Canada. 2021a. About Clubroot. Available at: http://www.canolacouncil.org/canola- encyclopedia/diseases/clubroot/about-clubroot/. Accessed in March 2021. Canola Council of Canada. 2021b. Identify Clubroot. Available at: http://www.canolacouncil.org/canola- encyclopedia/diseases/clubroot/about-clubroot/. Accessed in March 2021. Canola Council of Canada. 2021c. Regulation. Available at: http://www.canolacouncil.org/canola- encyclopedia/diseases/clubroot/regulation/. Accessed in March 2021. Canola Council of Canada. 2021d. Control Clubroot. Available at: http://www.canolacouncil.org/canola- encyclopedia/diseases/clubroot/control-clubroot/. Accessed in March 2021. Canola Council of Canada. 2021e. Managing Clubroot: Equipment Sanitation Guide. Available at: http://www.canolacouncil.org/publication-resources/print-resources/crop-production- resources/managing-clubroot-equipment-sanitation-guide/. Accessed in March 2021. Canola Watch. 2011. How to Scout for Clubroot. Available at: http://www.canolawatch.org/ 2011/08/10/how-to-scout-for-clubroot-2/. Accessed in March 2021. Corteva Agriscience. 2021. Cumulative Clubroot Infestations from 2003-2018 Alberta, 2008-2019 for Saskatchewan and 2009-2019 for Manitoba. Available at: https://www.canolacouncil.org/canola- encyclopedia/diseases/clubroot/. Accessed March 2021. Government of Alberta. 2014. Agricultural Pests Act. Revised Statues of Alberta 2000 Chapter A-8. Alberta Queen’s Printer. Available at: http://www.qp.alberta.ca/1266.cfm?page=a08.cfm& leg_type=Acts&isbncln=9780779782642. Accessed March 2021. Government of Alberta. 2019. Preventing Clubroot Agricultural Sanitization: Which disinfectants kill resting spores? Available at: https://open.alberta.ca/dataset/d526b5f4-46e5-420c-a33e- Clubroot Management aboutpipelines.com 31 of 49 Risk-based Guidance Document, May 2021
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