Compliance verification activity type: Field Inspection
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:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
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)
N/A
Relevant section(s):
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.
Observation 3 - CNC 1 - Open excavation guarding and fencing
Date & time of visit: 2021-03-16 16:00
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)
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.
Observation 4 - CNC 2 - pipe handling
Date & time of visit: 2021-03-16 11:00
CER Inspection Officer (IO) observed workers guiding pipe by hand during stringing operations contrary to:
Ensure the written instructions used by workers for stringing and pipe handling are consistent with the requirements of the TMEP HSMP and PSSP.
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.
Observation 5 - CNC 3 - Chemical Safety Data Sheets - Pipeline Coating
Date & time of visit: 2021-03-17 12:47
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.
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.
Observation 6 - General Observations - March 16, 2021
Date & time of visit: 2021-03-16 06:30
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
General Observations, March 17, 2021
Observation 8 - ATCO Worker Camp - March 17, 2021
Date & time of visit: 2021-03-17 13:00
ATCO Worker Camp - March 17, 2021
Observation 9 - Indigenous Monitor Observations - CV2021-218
Date & time of visit: 2021-03-16 08:30
Discipline: Indigenous Monitoring
Observation 10 - Indigenous Monitor Observations - CV2021-218
Observation 11 - IR 3 - steep slope authorization
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.
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.
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
