Compliance Verification Activity Report: CV2223-221 - Foothills Pipe Lines (South B.C.) Ltd.

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2223-221
Start date: 2022-07-18
End date: 2022-07-22

Team:

Regulated company: Foothills Pipe Lines (South B.C.) Ltd.

Operating company: Foothills Pipe Lines (South B.C.) Ltd.

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

Foothills Pipe lines (South BC) Ltd. - Zone 8 West Path Delivery 2022 Project: 32 km of NPS 48 steel pipe, ILL launcher and receiver facilities: 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 of infection prevention 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:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - General Observation

Date & time of visit: 2022-07-19 16:15

Discipline: Safety Management

Categories:

Facility:

Observations:

  1. CER Inspectors met with TC Energy (TCE) and Surerus Murphy (SMJV) prime contractor for BC Mainline Loop No. 2, Elko Section, and reviewed the Site Specific Safety Plan (SSSP) for the project. 
     
  2. CER Inspectors observed workers wearing required PPE for work being performed, such as safety glasses, hard hats with side protection, CSA safety footwear, and protective gloves.
     
  3. CER Inspectors completed company’s site orientation. During discussion after the orientation, company informed CER that most heavy equipment is equipped with back up alarms; although some equipment may not have such feature.
     
  4. At the time of inspection, SMJV had completed one JHSC and was in process of scheduling regular JHSC meetings for remainder of the project.
     
  5. Training mandated by TCE to its contractors is audited by TCE. SMJV provided training is audited by the contractor and is reported to TCE. However, no auditing or approvals of SMJV mandated training is performed by TCE.
     
  6. Informal quality checks are performed by TCE on the FLHA completed by SMJV and its contractors.
     
  7. TCE employs craft or trade specific inspectors who are also responsible for general health and safety of the work sites they oversee. TCE employs two Field Safety Inspectors who visit different work locations based on daily work plan. A daily inspection report is submitted by these inspectors.
     
  8. SMJV employs additional health and safety inspectors to provide oversight for their employees and subcontractors.
     
  9. CER Inspectors inspected contents of six Flammable Liquid Storage cabinets containing controlled products where the products in each cabinet appeared to be stored correctly. Also, the cabinets appeared to be grounded and equipped with the manufacture bungs in place.
     
  10. CER Inspectors reviewed competency assessment of a supervisor and verified competency assessment of the supervisor’s crew.
     
  11. Attended Foreman/Supervisor 0600 hours meeting where TCE and SMJV supervisors and foremen were present. CER reviewed findings from an informal FLHA documentation review and reiterated the importance of signing and completing FLHAs.
     
  12. CER IOs observed grounding at the fuelling station (three fuelling stations at SMJV yard) that appeared to be grounded correctly.
     
  13. CER IOs observed a locked sea-can at the SMJV yard containing rigging gear that had been received in the SMJV yard, the TCE/SMJV representatives advised that contents in the sea-can will be inventoried, and condition checked prior to releasing for use in the field. All gear found to be worn or defective will be tagged as defective, not for use and will be destroyed.
     
  14. CER IOs signed onto two FLHAs of traffic control personnel. It was observed that the worker who had completed the FLHA had not signed on. This observation was communicated to workers directly and addressed promptly.
     
  15. IOs engaged an excavator operator building the right of way at Flathead ridge location. Worker shared the pre-use daily inspection checklist and explained maintenance commentary. Worker had been an equipment operator for 17 years and confirmed that competency is verified by the site assessor, the area supervisor in this case.
     
  16. A rock drill operator was engaged and reviewed their daily tail gate topic. Operator was able to explain dust collector operation attached to the rock drill. Water suppression system for dust control was observed installed on the equipment.
     
  17. Equipment walk around was performed and fire extinguisher and spill kit were found to be in good condition.
     
  18. Equipment operator was asked about equipment seat and related settings to improve ergonomics. Operator stated that he was aware of the seat settings and had made the necessary adjustments. Training specific to equipment ergonomics had not been provided.
     
  19. Brigade cameras observed to be on excavators that I.O. inspected, mandatory to have 2 cameras, one excavator (Model 336-EX371) observed had 360 degree visibility for the operators position (4 cameras).
     
  20. A medic was present at this location and was able to produce their certification. Medic was able to demonstrate that the required equipment (AED, ABC type fire extinguisher, Fire Jump Bag, Basket and Clam shell stretchers, etc.) was available and up to date.
     
  21. At the E20 lay down, another OFA3 medic was also able to demonstrate equipment adequacy.
     
  22. SMJV informed CER inspectors that positive air shut off (PASO) was not a requirement for this project. As a result, not all equipment is installed with this feature. Equipment with the PASO feature is tested in the construction yard before being deployed to the field.
     
  23. CER Inspectors reviewed hazards and controls encountered by the clearing crew at KP 0+400. All documentation was found to be in good order.
     
  24. Danger Tree assessor at KP 0+200 reviewed the assessment for July 21, 2022 including key items of focus for their assessment.
     
  25. Tree Faller lead at KP0 0+200 communicated all FLHA steps (hazards and controls) taken for July 21st, 2022 FLHA, prior to having workers that may be exposed to the hazards sign off, to CER IOs, IOs then signed this FLHA.
     
  26. Document review during field visits included:

Compliance tool used: No compliance tool used

Observation 2 - Information caviardée conformément au paragraphe 144(5) du Code canadien du travail

This information has been redacted pursuant to Section 144(5) of the Canada Labour Code

Observation 3 - CNC 1 Fire Extinguisher

Date & time of visit: 2022-07-19 14:00

Discipline: Safety Management

Categories:

Facility:

Observations:

CER Inspectors observed 20 lb, Type ABC Fire Extinguisher mounted on light generator trailer unit LT1007, that had a defective nozzle hose.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Company shall replace damaged nozzle hose on ABC type fire extinguisher mounted on light generator. Company shall replace nozzle hose on 20 lb ABC Fire Extinguisher that is attached to light generator trailer or replace with new Fire Extinguisher of the same size/type, that has valid inspection tags attached.

Due date: 2022-07-19

Date closed: 2022-07-20
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 - CNC 2 Antennae Grounding

Date & time of visit: 2022-07-19 13:30

Discipline: Safety Management

Categories:

Facility:

Observations:

CER Inspectors observed a portable steel trailer with antennae and ladder vertically attached that was not bonded or grounded to an earth ground.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Company shall bond portable steel trailer with antennae and ladder vertically attached to an earth ground.

Due date: 2022-07-19

Date closed: 2022-07-20
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 - CNC 3 Grounding of Switchgear

Date & time of visit: 2022-07-19 13:40

Discipline: Safety Management

Categories:

Facility:

Observations:

CER Inspectors observed portable electrical generator running that was connected to switching breaker panels that was not earth grounded or bonded to the portable electrical generator that was bonded to an earth grounded.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Company shall bond each 120/208 volt switch gear cabinets to an earth ground or bond the two swich gear cabinets to the portable generators earth ground.

Due date: 2022-07-19

Date closed: 2022-07-20
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 - CNC 4 Control Zone

Date & time of visit: 2022-07-19 15:00

Discipline: Safety Management

Categories:

Facility:

Observations:

CER Inspectors observed a steep slope (leading edge) directly southeast of Warehouse which did not have a control zone to prevent workers from accessing the lower SMJV parking area.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Company is to place a caution control zone that identifies the hazard and prevents workers from accessing the slopped terrain.

Due date: 2022-07-19

Date closed: 2022-07-20
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 - CNC 5 Loading Warehouse Dock

Date & time of visit: 2022-07-19 15:20

Discipline: Safety Management

Categories:

Facility:

Observations:

CER Inspectors observed Construction Yard warehouse dock without barrier protection chain fence secured to end posts while dock was not in use.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Company shall attach chain barrier  at each control barrier post at loading dock entry/exit points when dock is not in use.

Due date: 2022-07-19

Date closed: 2022-07-19
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