Compliance Verification Activity Report: CV2122-096 - Trans Mountain Pipeline ULC


Compliance verification activity type: Field Inspection

Activity #: CV2122-096
Start date: 2022-03-22
End date: 2022-03-23


Regulated company: Trans Mountain Pipeline ULC

Operating company: Trans Mountain Pipeline ULC

Province(s) / Territory(s):


Rationale and scope:

TMX Spread 6/7a - 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 oversight of contractors - training & competence, monitoring, supervision and accountability; assess execution of work per applicable procedures and documented work practices.

Compliance tool(s) used:

Facility details


Regulatory requirements

Regulatory requirements that apply to this activity:

Regulatory instrument number(s):

Observations (no outstanding follow-up required)

Observation 1 - IR 1 - pre-inspection document review

Discipline: Safety Management





Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Provide a copy of the following to the Inspection Officers:

  1. The latest revision of the project specific safety plan (condition 64b), if not already filed with the CER.
  2. Spread 6 contractor hazard risk registry.

Due date: 2022-03-16

Date closed: 2022-03-11
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

Observation 2 - General observations spread 6 and 7a

Date & time of visit: 2022-03-23 14:00

Discipline: Safety Management




CER Inspection Officers (IO) and TMX-IAMC Indigenous Monitor performed a field safety inspection of Trans Mountain Expansion Project (TMEP) spread 6 and 7a. IOs verified compliance with TMEP contractor oversight obligations and condition 64 requirements.

  1. TMEP appears to be making reasonable efforts to ensure work performed by their contractors is carried out in accordance with the TMEP Health and Safety Management Plan (HSMP) and Project Specific Safety Plan (PSSP). These findings are supported by the following observations:
    1. IOs observed several interactions between TMEP Field Safety Inspector (FSI) and contracted workers. Upon observing a hazard or unsafe behavior, the TMEP FSI immediately intervened and engaged the contractor to ensure resolution.
    2. IOs observed several interactions between TMEP Field Safety Inspector (FSI) and TMEP General Inspectors.  The rapport between the FSI and General Inspectors was noted to be open and professional with the FSI in a position to provide safety related guidance as appropriate.
    3. Document review supports the IOs observations that TMEP FSI’s perform and document focus safety inspections in accordance with the HSMP. TMEP FSIs document any deviations from the PSSP or regulatory requirements and works with the contractor to ensure resolution.
    4. IOs observed work performed by the contractor at seven construction work areas over 2 days. Field observations included excavation, shoring, confined space entry, working from heights, working around mobile equipment, working near overhead power lines, pipe storage, and hauling. Work appeared to be executed in accordance with the HSMP and PSSP.
    5. Scheduled daily meetings involving TMEP and contractor representatives provide opportunity to review and identify any issues related to the effective implementation of the HSMP, PSSP, and safety program requirements.
  2. TMEP is providing consistent and frequent safety oversight in accordance with the HSMP (condition 64a).
    1. Document review show FSIs observe work performed by the contractor daily. When asked by IOs, contracted workers verified that TMEP FSI’s are routinely present to oversee their work and readily engage workers to ensure work is being carried out in accordance with the PSSP.
    2. IOs observed a TMEP General Inspector present at each construction work area; upon inquiry from IOs contracted workers verified at least one TMEP Inspector was present any time field activities were taking place.
    3. IOs observed that TMEP General Inspectors typically include safety related observations in their daily inspection reports as exception only.  The IOs suggested that it would be a good practice and assist in verifying TMEP oversight obligations are being achieved to include positive safety interactions/observations in the daily reports.
  3. TMEP Inspectors appeared to be trained and have had their competency verified in accordance with the HSMP.
    1. IOs interviewed four (4) TMEP Inspectors, all of which verified they had their competency assessed by TMEP at regular intervals; later confirmed by document review.
    2. The TMEP FSI who accompanied the inspection over 2 days demonstrated thorough knowledge of the HSMP, PSSP, and TMEP lifesaving rules.

Compliance tool used: No compliance tool used

Observation 3 - Indigenous Monitor Observations – (Seabird Island Band)

Date & time of visit: 2022-04-21 13:36

Discipline: Indigenous Monitoring




Additional observations recorded by independent Indigenous Monitors participating in the CER inspection. Any compliance-related observations which require specific regulatory follow-up have been recorded above.

I had participated as indigenous monitor along with C.E.R. safety inspectors.

With my in person inspections on numerous worksites.

I have seen in person that all operations were fully written out on flha's as well on ground disturbance permits, confined space plans e.g. safe work procedures, pre entry procedures, atmospheric testing before entries, and during work tasks, most of all emergency response plans in place, safe work authorization permits filled out to precise work tasks to be completed when permitted, I m very pleased that I have plenty of safety signage for all worksites stating hazards, contact information at all levels of clients, prime contractors, sub contractors.

I m very pleased to see the work of stantec taken care of the traditional land use sites, archeological sites, as well for cmt's. There was plenty of information at all levels of working crews knowing of each of these sensitive areas listed above in this paragraph. The signage in place, locations, buffer zones marked out with ribboned rope as well construction fencing.

To see that all workers were fully competent in there work tasks, machine operations, environmental measures while while working in sensitive areas of water courses etc.

Trans mtn was very aware of work activities happening in capacities in through prime contractors, sub contractors, truck deliveries of machinery, materials, fuel trucks, gravel trucks, etc.

At all levels the trans mtn, prime contractor, sub contractors vendors are very well informed, trained to carry out the daily tasks permitted on these TMEP spread 6 & 7A.

With this I thank you for this opportunity for participating on this safety inspection.

I look forward to participating in future C.E.R. / I.A.M.C. inspections  whether environmental or safety.

Indigenous monitor

Compliance tool used: No compliance tool used

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