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):
Rationale and scope:
TMX Reactivation - Assess field implementation of construction safety manual and project specific safety plans for ongoing construction activities; worker tasks including identification of hazards and appropriate controls relevant to the job tasks via hazard assessments; company implementation COVID-19 safety protocols; company oversight of contractors - training & competence, monitoring, supervision and accountability; assess execution of work per applicable procedures and documented work practices.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - General Observations - COVID-19 Screening
Date & time of visit: 2021-08-17 08:05
Discipline: Safety Management
Categories:
Facility:
Observations:
Covid 19 Screening - Jasper Yard
Compliance tool used: No compliance tool used
Observation 2 - General Observations - Ghita Creek
Date & time of visit: 2021-08-17 11:00
Observation 3 - General Observations - Dig 59
Date & time of visit: 2021-08-17 14:00
August 17th
Observation 4 - General Observations - Tunnel West
Date & time of visit: 2021-08-18 10:16
Observation 5 - General Observations - Dig 38
Date & time of visit: 2021-08-19 13:00
Observation 6 - IR 1 - Sling Management
Sling use was observed at Ghita Creek location and subsequently at Dig 59. Roung slings were observed to have labeling in line with ASME B30.9 standard. Workers on location confirmed that daily pre-use inspection were performed and provided the CER an overview of how to perform such inspections. Workers were aware of the working load limits of various slings.Further discussion on detailed or periodic inspection on roundslings did not clarify periodic inspection frequency.
Compliance tool used: Information Request (IR)
Regulatory requirement:
Relevant section(s):
Company action required:
(1) Provide documentation (standards, safe work practices, or procedures) which demonstrate how TMEP's existing sling management program ensures compliance with detailed/periodic inspections of round slings as indicated in WorkSafe BC regulation 15.30 (standard reference ASME B30.9-2006) or other applicable regulations.
Due date: 2021-09-15
Date closed: 2021-10-27 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 - NNC 1 - Ineffective hazard identification and controls around asbestos containing coating
Date & time of visit: 2021-08-19 14:15
On August 17, 2021, IO observed a crew of workers at Dig 59 entering an excavation with the re-activation line. This line appeared to have a coal tar coating which was shown to contain asbestos on other Spreads. Interview with the workers on site involved in slope work and trench box assembly showed that none of the workers were aware of possible presence of asbestos on the line inside the trench box. Furthermore, a review of FLHA and daily safety toolbox documentation made no mention of the presence of ACM coating at the dig site. Slings were wrapped around the pipe; materials such as tape, water bottles, and slings were placed on the pipe as well. The coating on the pipe was visibly damaged in some sections.TMEP provided a bulk sampling report from 2014 performed by an Occupational Hygiene consultant which showed 4 out of 5 bulk samples were found to be positive for varying amount of asbestos content.On August 18, coating supervisor at Tunnel West location indicated that abatement had been performed on Tunnel west section of the pipe as the coating was asbestos containing. The supervisor was also aware that the coating in the current project scope is presumed to be asbestos containing.On August 18, workers at Dig 59 were still unaware of the presence of asbestos on the coating as they were observed to continue placing light material on the pipe inside the trench box.
Compliance tool used: Notice of Non-compliance (NNC)
1. Ensure workers are aware of presence of asbestos on portions of the reactivation line. 2. Ensure that areas where interaction with damaged or deteriorating ACM coating is likely to occur, coating is wrapped or enclosed or other means of control employed to reduce potential worker exposure across the reactivation segments. 3. Ensure that workers in the vicinity of such pipe adequately assess and document potential hazard posed by ACM coating. 4. Specific to Dig 59, submit evidence of effective control that mitigates potential exposure to ACM.
Date closed: 2021-10-25 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 8 - NNC 2 - Musculoskeletal Injury Prevention
Date & time of visit: 2021-08-18 12:30
A worker was observed entering a tunnel/confined space carrying a card board box of materials. The following conditions were observed:
1. Tunnel West - Verify to CER IO's that the ergonomic hazard related to transferring material into the tunnel has been addressed. Describe how the hazard was assessed including consideration of weight of load, ground surface, lighting and body posture during transfer.2. On 19 July 2021 TM issued a memo to all of its GCCs regarding the WorkSafe BC Orders and Inspection Report issued on Spread 5A (CV2122-094). TM issued each GCC a PAR with instructions to conduct a gap assessment related to musculoskeletal injury prevention among others. Please provide the PAR completed for reactivation as a result of their gap analysis with respect to musculoskeletal injury prevention.3. Please describe how the TMEP Senior Project Management Team is actively engaged and meeting its roles and responsibilities with respect to:
Date closed: 2021-10-14 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 9 - Indigenous Monitor Observation Report
Date & time of visit: 2021-08-20 12:00
Discipline: Indigenous Monitoring
Additional Observation recorded by an Indigenous Monitor participating in the CER Inspection. Any compliance related observations that require specific regulatory follow-up have been recorded in stand alone observations.Indigenous Monitor Report Joint CER - IAMC Safety Inspection CVA2122-098 – TMX Reactivation - Jasper Spread: Jasper - Reactivation Start Date: Aug 17, 2021End Date: Aug 19, 2021
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
