Compliance Verification Activity Report: CV2021-218 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2021-218
Start date: 2021-03-16
End date: 2021-03-17

Team:

Regulated company: Trans Mountain Pipeline ULC

Operating company: Trans Mountain Pipeline Expansion Project

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

This inspection focused on Trans Mountain Expansion Project (TMEP) construction activities taking place on spread 3 and 4a near Valemount, BC. Scope included field implementation of construction safety manual and project specific safety plans for ongoing construction activities; worker tasks including identification of potential hazards and appropriate controls relevant to the job tasks via hazard assessments; company implementation COVID-19 safety protocols; and company oversight of contractors. Inspection Officers verified implementation of TMEP project-wide corrective actions following the fatality of a contracted worker in Oct 2020 and a serious injury in Dec 2020.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - IR 1 - Spread 3 Construction schedule (pre-inspection)

Discipline: Safety Management

Categories:

Facility:

Observations:

CER Inspection Officer is requesting from TMEP a schedule of weekly planned, Pipeline Construction Activities for the dates of March 1-30, 2021 - applicable to Spread 3, Valemount area.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Company action required:

Please provide before February 26, 2021, the updated schedule of planned pipeline construction activities, for the dates of March 1-31, 2021, for TMEP Spread 3.

Due date: 2021-02-26

Date closed: 2021-03-02
Note: the date closed is the date that the inspector completed their review of the company corrective actions for adequacy and determined that no further actions are required.

Reason closed: Requirement met

Compliance achieved: Yes

Observation 2 - IR 2 - PSSP and CHRR (pre-inspection)

Discipline: Safety Management

Categories:

Facility:

Observations:

N/A

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

CER Inspection Officer requests a copy of the following applicable to spread 3.

Due date: 2021-03-15

Date closed: 2021-03-15
Note: the date closed is the date that the inspector completed their review of the company corrective actions for adequacy and determined that no further actions are required.

Reason closed: Requirement met

Compliance achieved: Yes

Observation 3 - CNC 1 - Open excavation guarding and fencing

Date & time of visit: 2021-03-16 16:00

Discipline: Safety Management

Categories:

Facility:

Observations:

An open pipeline excavation fencing had sloughed in and was no longer effective, the site was also unattended.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Inspect and repair locations with excavationas, and ensure excavation hazards and mitigations are implemented.

Due date: 2021-03-17

Date closed: 2021-03-18
Note: the date closed is the date that the inspector completed their review of the company corrective actions for adequacy and determined that no further actions are required.

Reason closed: Requirement met

Compliance achieved: Yes

Observation 4 - CNC 2 - pipe handling

Date & time of visit: 2021-03-16 11:00

Discipline: Safety Management

Categories:

Facility:

Observations:

CER Inspection Officer (IO) observed workers guiding pipe by hand during stringing operations contrary to:

IO also learned through document review the contractor job hazard assessment for stringing states "an open hand may be used on the side of the pipe" to guide the pipe while setting pipe on skids. The stringing job hazard assessment being used by workers is inconsistent with the requirements of the TMEP HSMP and PSSP. Additionally, the contractor pipe handling safe work practice is inconsistent with the TMEP HSMP and PSSP regarding the use of tag lines.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Ensure the written instructions used by workers for stringing and pipe handling are consistent with the requirements of the TMEP HSMP and PSSP.

Due date: 2021-03-17

Date closed: 2021-03-17
Note: the date closed is the date that the inspector completed their review of the company corrective actions for adequacy and determined that no further actions are required.

Reason closed: Requirement met

Compliance achieved: Yes

Observation 5 - CNC 3 - Chemical Safety Data Sheets - Pipeline Coating

Date & time of visit: 2021-03-17 12:47

Discipline: Safety Management

Categories:

Facility:

Observations:

Pipeline Coating Crew was not able to produce chemical Safety Data Sheets (SDS) for the base coat and hardner coating products they were observed using. A email to the Inspection Officer later provided material safety data sheets (MSDS) for the coating chemicals, but MSDS sheets are outdated (2009) and not in compliance with WHMIS 2015.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Demonstrate to the Inspection Officer chemical safety data sheets relevant to pipeline coating operations, are in the required WHMIS 2015 format. Safety Data Sheets must be readily produced for workers upon request, digitally, in paper format, or by other means.

Due date: 2021-03-31

Date closed: 2021-03-24
Note: the date closed is the date that the inspector completed their review of the company corrective actions for adequacy and determined that no further actions are required.

Reason closed: Requirement met

Compliance achieved: Yes

Observation 6 - General Observations - March 16, 2021

Date & time of visit: 2021-03-16 06:30

Discipline: Safety Management

Categories:

Facility:

Observations:

General Observations, March 16, 2021

Compliance tool used: No compliance tool used

Observation 7 - General Observations - March 17, 2021

Date & time of visit: 2021-03-17 08:30

Discipline: Safety Management

Categories:

Facility:

Observations:

General Observations, March 17, 2021

Compliance tool used: No compliance tool used

Observation 8 - ATCO Worker Camp - March 17, 2021

Date & time of visit: 2021-03-17 13:00

Discipline: Safety Management

Categories:

Facility:

Observations:

ATCO Worker Camp - March 17, 2021

Compliance tool used: No compliance tool used

Observation 9 - Indigenous Monitor Observations - CV2021-218

Date & time of visit: 2021-03-16 08:30

Discipline: Indigenous Monitoring

Categories:

Facility:

Observations:

Additional observation recorded by IAMC Indigenous Monitors participating in the CER inspection. Any compliance related observations that require regulatory follow-up have been recorded above.

IMAC - SCFN Services – IM
CV2021-218 CER Inspection  - Spread 3/4a March 15-18
 
March 16, 2021 – March 17, 2021
 Inspection in Valemount, BC accompanied with CER IO's and Trans Mountain Rep's
 
Mar 15Mar 16/17, 2021

Compliance tool used: No compliance tool used

Observation 10 - Indigenous Monitor Observations - CV2021-218

Date & time of visit: 2021-03-16 08:30

Discipline: Indigenous Monitoring

Categories:

Facility:

Observations:

Additional observation recorded by IAMC Indigenous Monitors participating in the CER inspection. Any compliance related observations that require regulatory follow-up have been recorded above.

CV2021-218 WPCIB Indigenous Monitor Observations
 
03-16-2021~Reminder to use common space used/clean indicator placards.
~emphasis on heavy equipment etiquette and safety. (Addition of “Thumbs up rule.”, Line of fire, Fatigue.)
~Weather briefing included.
~prescription drugs are considered under the influence.
~Safe Work Agreement (SWA) new form developed for site supervisors to prevent workers from changing tasks with out proper planning and or training.
~ Contractor Hazzard Risk Registry a complex spread sheet to detail all identified risks, assessment of their likelihood and impact to worker health and safety.Road#82 site visit 
03-17-2021~Does the contractor have approval for the use of trench boxes? Trans mountain Corporation (TMC)reply: Logistically prepared worker training in final stages.
~TMC health & safety management plan is not aligned with contractor SWP about hands on handling of pipe while setting.
       Road#12 Site visit~ included SWA, tailgate, Field level hazard assement (FLHA), supervisor also had majority of safe work procedures (SWP).
~ Site supervisor & TMC safety inspector demonstrated in depth understanding of safety program improvements.Forestry Clearing activity Site visit.Valemount camp site visit~ ATCO safety absolutes reminders and checks of high-risk activities.~ Cultural sensitivity training being planned.Closing meeting.

Compliance tool used: No compliance tool used

Observation 11 - IR 3 - steep slope authorization

Discipline: Safety Management

Categories:

Facility:

Observations:

While observing forestry clearing activities, a Contractor supervisor communicated concerns to the IO and IM that TMEP steep slope requirements prevented the use of mechanized falling on slopes greater than 5º. Work was resultantly being performed by hand fallers.
 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Describe how TMEP steep slope requirements inclusive of the related approval processes have been effectively communicated to Contractors.

Due date: 2021-04-09

Date closed: 2021-05-11
Note: the date closed is the date that the inspector completed their review of the company corrective actions for adequacy and determined that no further actions are required.

Reason closed: Requirement met

Compliance achieved: Yes

Observations (company follow-up required)

Identified non-compliances to company plans or procedures are non-compliances either to:

- the condition of an authorization document that requires the implementation of that plan or procedure; or

- the relevant section of the regulations that requires implementation of that plan or procedure including those sections that require implementation of plans or procedures as a part of a Program