Compliance Verification Activity Report: CV1920-083 - Genesis Pipeline Canada Ltd.

Overview

Compliance verification activity type: Field Inspection

Activity #: CV1920-083
Start date: 2019-06-05
End date: 2019-06-05

Team:

Regulated company: Genesis Pipeline Canada Ltd.

Operating company: Nova Chemicals Corporation

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

Safety oversight of operation activities - Assess compliance with the OPR (Safety Management Program)

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

Date & time of visit: 2019-06-05 09:00

Discipline: Safety Management

Categories:

Facility:

Observations:

The NEB received a presentation on the NOVA Chemical Safety Management System and Safe Work Permitting. The NEB were informed that all new employees receive an 8 hour Safety Management System (SMS) Training session that goes over hazard assessment and risk mitigation. It covers the 4 main elements of NOVA's SMS in the form of:

  1. Toolbox Talk (pre and post shift)
    • All persons about to complete a job must participate in and sign off on the daily toolbox talk at the beginning of the shift and they must also sign off on it at the end of their shift
  2. WHAT-IF
    • completed in the field prior to starting work and addresses the specific task to be performed.
  3. Safety Interaction
    • conversation between two or more people at any time during the work shift, designed to recognize and reinforce safe work practices; to stop unsafe activities, and; talk about safety concerns.
  4. Am I Ready?
    • safe-start principles - have a conversation with self prior to conducting any task
The NEB were informed that the average shift does not extend beyond 13 hours and that the facility has recovery rooms where staff is able to take a rest break.

With respect to Safe Work Permits (SWP) the NEB were informed:The NEB were informed that NOVA Chemicals were conducting ground disturbance activities in the prescribed area of Genesis pipeline 39. The NEB reviewed the following for this activity:The NEB were informed that all process units have naturally occurring radioactive materials (NORMs) and that all staff working in these areas have NORM training

The NEB examined information with respect to the contractor hiring process and the Contractor Responsible Care Management Program. The NEB were informed that:The NEB were informed that NOVA Chemicals uses a data system called 3E for their online safety data sheets (SDS). The NEB were informed that no product is allowed to be onsite unless it has gone through the process for registering the products, this includes personal items brought in by employees, and general housecleaning products. The NEB were informed that the only printed copies of the SDS are in the emergency response plans (ERP) that are provided annually to the area first responders; these are numbered and controlled documents which are collected annually and a new one is issued annually.

Incidents, the NEB were informed and examined:Training, the NEB were informed:The NEB was informed that the right of way is patrolled by air on a weekly basis and ground on a bi-weekly basis.

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