Compliance Verification Activity Report: CV2021-120 - Many Islands Pipe Lines (Canada) Limited

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2021-120
Start date: 2021-01-26
End date: 2021-01-27

Team:

Regulated company: Many Islands Pipe Lines (Canada) Limited

Operating company: Many Islands Pipe Lines (Canada) Limited

Province(s) / Territory(s):

Discipline(s):

Related events:

Rationale and scope:

Project Construction Inspection; Assess field implementation of construction safety manual and project specific safety plans for ongoing construction activities and worker tasks including identification of potential hazards and appropriate controls relevant to the job tasks via hazard assessments; company implementation COVID-19 safety protocols; company oversight of contractors - monitoring, supervision and accountability; assess execution of work per applicable procedures and documented work practices.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - General Observation 1 - Side Boom Inspection and Welding

Date & time of visit: 2021-01-26 08:45

Discipline: Safety Management

Categories:

Facility:

Observations:

Compliance tool used: No compliance tool used

Observation 2 - General Observation 2 - Documentation

Date & time of visit: 2021-01-26 12:00

Discipline: Safety Management

Categories:

Facility:

Observations:

Compliance tool used: No compliance tool used

Observation 3 - General Observation 3 - HDD

Date & time of visit: 2021-01-26 13:15

Discipline: Safety Management

Categories:

Facility:

Observations:

Compliance tool used: No compliance tool used

Observation 4 - CNC 1 - Side Boom without Log Book

Date & time of visit: 2021-01-26 08:45

Discipline: Safety Management

Categories:

Facility:

Observations:

Inspection Officer approached side boom operator and requested a walk through of a typical pre-use inspection. The operator appeared to be competant and knowledgable about the puropse of the inspection. The operator was able to produce documentation of the days inspection but could not produce a log book. The importance of a log book to detail the history of inspections and possible issues was discussed.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

1. Communicate the requirement to all contractors and operators to maintain a log book on all side booms.
2. Ensure current side booms operating on the project are equiped with the appropriate records.

Due date: 2021-01-27

Date closed: 2021-02-01
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.

Reason closed: Requirement met

Compliance achieved: Yes

Observation 5 - IR 1 - Managing Change to Wetland Crossing Plan

Discipline: Safety Management

Categories:

Facility:

Observations:

Referring to incident INC2021-005, company representatives described a change in the plan from a trenchless crossing to an open cut trench.
 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Describe how MIPL implemented its process for identifying and managing this change including plans for the identification, evaluation and control of any new hazard or risk.

Due date: 2021-02-26

Date closed: 2021-03-04
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 - IR 2 - Welding FLHA and Exposure Assessment

Discipline: Safety Management

Categories:

Facility:

Observations:

Inspection officers observed welding observation and requested safety data sheets for materials used. The safety data sheets were not available on site. Discussion about chemical exposure assessments and exposure control occured. Upon review of the SDS sheets it is noted that for the use of each product the following reccomendation is made: "an approved respirator should be used unless exposure assessments are below applicable exposure limits."

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

1. Provide the FLHA and/or HIAC for the welding operations that were observed on the morning of January 26th
2. Provide a record or other proof of an exposure assessment that informed the work plan as per the SDS sheets provided to CER inspectors.

Due date: 2021-02-26

Date closed: 2021-03-08
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 7 - IOO-DM-001-2021_Observation 1, Worker breathing air supply system

Date & time of visit: 2021-01-26 15:30

Discipline: Safety Management

Categories:

Facility:

Observations:

CER Inspection Officer observed a mobile compressed air system, capable of supplying worker breathing air, without adequate certifications guaranteeing the supplied air quality

Compliance tool used: Inspection Officer Order (IOO)

Regulatory requirement:

Relevant section(s):

Company action required:

  1. Cease the use of air compressors supplying breathing air to workers until air quality certifications, and evidence of equipment inspection, in alignment with CSA Z180.1:19, or a more stringent standard, can be demonstrated to the Inspection Officer
  2. Demonstrate an air quality certification for breathing air and supply systems, at the MIPL(C)L Pierceland Supply Expansion Project.

Due date: 2021-02-05

Date closed: 2021-02-02
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 8 - IOO-DM-001-2021_Observation 2, Workers respiratory protective equipment

Date & time of visit: 2021-01-26 15:30

Discipline: Safety Management

Categories:

Facility:

Observations:

CER Inspection Officer observed workers using respiratory protective equipment incorrectly.

A Coating Crew worker was observed using a half-mask filter cartridge respirator that was heavily soiled with coating chemical product. In addition, no expiration dates or date of issue for the filter cartridges could be identified. Additionally, another coating crew worker could be seen performing similar and same tasks and was not wearing respiratory protective equipment.
 

Compliance tool used: Inspection Officer Order (IOO)

Regulatory requirement:

Relevant section(s):

Company action required:

Specific to Coating Crew(s), provide the Inspection Officer assurance that coating crew workers have received training in the proper selection, use and care of respiratory protective equipment applicable to Coating Crew tasks (e.g.: blasting and coating).
 

Due date: 2021-01-29

Date closed: 2021-02-02
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 9 - IOO-DM-001-2021_Observation 3, Worker fit testing program

Date & time of visit: 2021-01-26 15:30

Discipline: Safety Management

Categories:

Facility:

Observations:

CER Inspections Officer observed workers subject to a respiratory fit test program not meeting the requirements of a fit testing program.
 

Compliance tool used: Inspection Officer Order (IOO)

Regulatory requirement:

Relevant section(s):

Company action required:

Specific to Coating Crew(s), provide the Inspection Officer assurance that coating crew workers who are required to wear and use Respiratory Protective Equipment(RPE) have certification of a valid Respiratory Fit Test.
 

Due date: 2021-01-29

Date closed: 2021-02-02
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 10 - IOO-DM-001-2021_Observation 4, Applicability of WHMIS 2015 and workplace Safety Data Sheets

Date & time of visit: 2021-01-26 13:50

Discipline: Safety Management

Categories:

Facility:

Observations:

Worksite available chemical safety data sheets did not meet requirements of WHIMS 2015

Compliance tool used: Inspection Officer Order (IOO)

Regulatory requirement:

Relevant section(s):

Company action required:

Specific to the abrasive blasting medium and coating products in use, demonstrate to the Inspection Officer valid Safety Data Sheets for blasting and coating products

Due date: 2021-01-27

Date closed: 2021-02-02
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 11 - NNC 1 - Globally Harmonized System of Classification and Labelling of Chemicals

Date & time of visit: 2021-01-26 11:00

Discipline: Safety Management

Categories:

Facility:

Observations:

Compliance tool used: Notice of Non-compliance (NNC)

Regulatory requirement:

Relevant section(s):

Company action required:

1. Create, and provide a copy to the CER, an awareness bulletin and communication plan to inform company personnel and contractors of requirements under the Globally Harmonized System (GHS) including:

2. Identify all trades to which the GHS pertains and provide assurance to the CER that the bulletin developed will be shared in future construction and operations and maintenance activities where applicable.

3. Update manuals and procedures to include references to the GHS where applicable. Provide a list of documents that have been/or will be revised.
 
4. Provide an explanation of how MIPL is ensuring its inspectors are providing adequate oversight on the company’s behalf, considering no HIAC’s provided included the identification, assessment or control of the welding fume hazard.

Due date: 2021-03-31

Date closed: 2021-04-07
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