Compliance verification activity type: Field Inspection
Team:
Regulated company: Trans Mountain Pipeline ULC
Operating company: Kinder Morgan Canada Inc
Province(s) / Territory(s):
Discipline(s):
Related events:
Rationale and scope:
[Spread 2 - TMX Project Construction Inspection; Assess implementation of company COVID-19 procedures and practices; Assess compliance to project specific safety plans/construction safety manuals per HDDs; assess company oversight of primary construction contractor and drilling contractor]
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Regulatory instrument number(s):
Additional Project-specific requirements or conditions:
Observation 1 - General Observations
Date & time of visit: 2020-07-08 09:00
Discipline: Safety Management
Categories:
Facility:
Observations:
Edson Construction Yard (offices)
Compliance tool used: No compliance tool used
Observation 2 - General Observations - Covid-19 Response Plan
Date & time of visit: 2020-07-08 14:00
Observation 3 - NNC 1 - Site Access Temperature Screening
As per the Trans Mountain Site Access Temperature Screening Protocol (Screening Protocol), the CER IOs temperatures were measured at least once daily. Several observations were made which indicate ineffective implementation of the Screening Protocol, a lack of adequate training for those tasked with temperature screening, and inadequate oversight of the contractor(s) hired to perform the screening and a general lack of efficacy of the program in general.
Compliance tool used: Notice of Non-compliance (NNC)
Regulatory requirement:
Relevant section(s):
Company action required:
Establish and implement a plan to restore and monitor the effectiveness of the Site Access Temperature Screening Program that includes the following elements:
Due date: 2020-08-28
Date closed: 2020-11-06 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 - NNC 2 - Safeguarding Personal Information
Date & time of visit: 2020-07-09 14:00
Discipline: Management System
The Trans Mountain Site Access Temperature Screening Protocol v.2 states that “No transfer of the form will occur to minimize the spread of infectious disease”, and that the worker shall retain their test results on their person. During the inspection, however, CER IOs observed that Covid-19 Self Declaration Forms were being collected and stored by several individuals. These records were not being safeguarded in a way that protected the confidentiality and privacy of workers and visitors.
Date closed: 2020-09-01 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 - IAMC Observation - Sucker Creek First Nation
Discipline: Indigenous Monitoring
The observation is contained within the attached file.
Compliance tool used: Information Request (IR)
With respect to TLU-25, provide confirmation that the resource specific mitigation was completed. The response should include the date on which the mitigation was complete, as well as the names of the group(s) who were invited to take part in harvesting. Provide three recent examples of inspection and/or daily reports that have been submitted to Trans Mountain by the company Indigenous Monitor(s) for Spread 2. Provide the standard or protocol that guides how Trans Mountain addresses concerns brought forth by company Indigenous Monitors.
Due date: 2020-09-15
Date closed: 2020-09-15 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 6 - IAMC Observation - Alexander First Nation
Date & time of visit: 2020-07-10 12:00
Compliance Verification Activity 2021-217Safety Inspection – Spread 2Indigenous Monitor Observation Report Edson Laydown Yard
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