Compliance Verification Activity Report: CV2223-091 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2648
• Inspector 2773

Regulated company: Trans Mountain Pipeline ULC

Operating company: Trans Mountain Pipeline ULC

Province(s) / Territory(s):

• British Columbia

Discipline(s):

• Safety Management

Rationale and scope:

TMX Spread 7B - 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 &amp; competence, monitoring, supervision and accountability; assess execution of work per applicable procedures and documented work practices.<br /> <span style="font-size:11pt"><span style="font-family:Calibri,sans-serif">Verify/assess implementation of noise and traffic management plans - Conditions 73 &amp;&nbsp;74.</span></span><br /> &nbsp;

Compliance tool(s) used:

• None

Facility details

Facilities:

• TRANS MOUNTAIN EXPANSION PROJECT

Facility Types

• Pipeline
• Pipeline

Life-cycle Phases

• Construction

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canada Labour Code (CLC)
• Workplace Harassment and Violence Prevention Regulations(WPHVPR)
• Canada Labour Code (CLC) 2021-12-29
• Canadian Energy Regulator Act (CERA)
• Canadian Energy Regulator Act (CERA)
• Canadian Energy Regulator Pipeline Damage Prevention Regulations – Obligations of Pipeline Companies
• Onshore Pipeline Regulations (OPR) 2020-03-16
• Plans And Procedures
• Project-specific plan or procedure
• 01-13283-GG-0000-HSHSE-0001 R6, 2022-04-25
• Standards
• CSA Z662-19 - Oil and Gas Pipeline Systems

Observations (no outstanding follow-up required)

Observation 1 - General Observation

Date & time of visit: 2022-10-28 15:00

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Industrial Sanitation and Personnel Facilities
• Occupational Medical Surveillance
• Electrical Safety
• Fire Protection
• Flammable and Combustible Liquids
• Limits of Exposure
• Training and Competency
• Training, Competency and Qualification
• Workplace Practices
• Ground Disturbance Activities
• Safe Work Permits
• House Keeping
• Procedures/Work Instructions
• Scaffolding, temporary stairs, ramps and platforms
• Traffic Control
• Shelving and General Storage
• Workplace Harassment and Violence
• Leadership and Supervision
• Contractor Management & Oversight
• Responsibilities and Accountability
• Supervision, Inspection and Monitoring
• Records & Documentation
• Internal near miss and incident trending, reporting, preventive and corrective actions
• Hazard Management
• Management of Hazardous Materials & Substances
• Equipment, Tools, Machinery
• Safety Critical Equipment Identification, Inspection, Testing and Maintenance
• Use, Operation, Repair and Maintenance of Mechanical & Critical Lifting Equipment
• General
• Signage

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

• CER inspectors observed that perimeter fencing and gates at 88 Golden Drive Office / Project Yard appeared to be maintained in good condition with proper signage and company and emergency contact numbers and warning signs to deter intrusion.
• Parking area for project construction trailer site within perimeter fencing was well graded and aggregate applied.
• Company representatives provided a brief safety orientation at the 88 Golden Drive TMEP office/yard in Coquitlam, B.C. (First Aid, Emergency Response & muster locations, and identified the PPE Free Areas). 
• CER Inspectors were provided a Field Level Risk Assessment (FLRA) prior to accessing each construction work place (CWP), identifying planned activities on the field inspection. This FLRA was delivered by the TransMountain representative.
• CER Inspection Officers verified both Occupational First Level-2 certification record for worker on site & that B.C.- Level 2 first aid kits resided at all Construction Workplaces Inspected. 
• Company representatives delivered a site-specific orientation to CER staff at all CWP sites, which included a description of emergency procedures, alarm types and muster areas. Company representatives provided CER Inspection Officers an escorted tour throughout the Construction Work Places Inspected (CWP: 61, 62, 73, 74, 98, 99, 100, & 101). 
• CER Inspection Officer observed ABC portable fire extinguishers placed on the right of way that had both current monthly inspections and annual inspection tags on cylinders.
• CER inspectors observed vehicles being operated in a safe manner during the right of way inspection.
• CER inspectors observed Mobile Equipment to be in good condition and daily inspection log books to be in order where checked.
• CER Inspection Officers observed several designated smoking areas, each area was roped off, equipped with an “ABC” fire extinguisher, and a cigarette butt dispenser.
• Hazard warning signage (Caution-Yellow or Danger-Red) was affixed to control zones outside the excavated area to identify and mitigate the excavation hazard. Each control zone was identified with either red or yellow ribbon/plastic chain length, to identify the control zone and sandwich board signs displayed the contact information for the person who was the responsible supervisor for controlling that zone.
• Vertical posts and rodding were observed to be capped off with protective plastic mushroom caps to protect workers from being impaled from a fall type hazard.
• Washrooms at Project Construction site were functional and all field portable toilets in Construction Workplaces (CWP’s) inspected were operational, clean, and equipped with sanitary hand disinfectant.
• Overhead power lines at crossings were identified by marker clearance banners at the safe clearance measure below the power lines and had visual red markers (ribbon/rope) placed where the power lines parallel the pipeline right of way, providing a visual indication to workers of a safe distance reference mark to the workers of the power lines. The power line marking flagging was erected by the power line company's contractor.
• Workers were observed wearing CSA Class 2 high visibility clothing, CSA approved side protection hard hats, and CSA approved safety footwear.
• Hearing protection was noted to be used in areas where identified as being required.  Company representatives indicated that they would also be doing additional noise monitoring of equipment to increase general knowledge of noise levels and further reduce potential for over exposures.
• All diesel equipment observed by the Inspection Officers was equipped with positive air shut-offs (PASO's) where checked.
• Inspection Officers observed portable lighting generators, and Herman Nelson heaters with spill kits placed underneath and the wheels chocked.
• Inspection Officers observed that portable power plants and pumps appeared to be bonded to an earth ground.
• CER IOs observed Daily Ground Disturbance report was completed at CWP's that were inspected.
• CER IOs reviewed lift plans, including tandem lifts that had been used for previous lifts at CWP 62.  The HDD set up was observed and no concerns identified.  TMEP oversight representatives were able to describe their role and hazards associated with the work at this location.
• Traffic control measures were observed in place at many project access points. Particularly at CWP 73, CER IOs observed use of the AFADs system for managing traffic at this location.  The TMEP Traffic Control Inspector and contractor on site traffic management representative were able to articulate their roles, site hazards and the traffic control plan that was in place at this location.
• CER IOs observed what they consider to be Best Practice examples exhibited on the Spread 7B project.  An example of this is the degree of coordination and efforts to have the TMEP and contractor safety teams working in close collaboration to identify and manage project hazards.  The project team explained their practice of pairing TMEP safety representatives with their contractor safety representatives on a daily basis to conduct site inspections.  In addition, the TMEP and contractor teams have a weekly joint meeting to review what they are observing and discuss potential areas of focus.  The CER IOs encourage TMEP to identify Best Practices that are occurring on specific spreads and capture these to the extent possible for use across the project and for future work.

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 - Fraser Mills Pipe Yard

Date & time of visit: 2022-10-26 11:00

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Limits of Exposure
• Training and Competency
• Training, Competency and Qualification
• Workplace Practices
• Hot Work
• House Keeping
• Job/Task Safety Analysis
• Procedures/Work Instructions
• Contractor Management & Oversight
• Supervision, Inspection and Monitoring
• Records & Documentation
• Performance Metrics
• Equipment, Tools, Machinery
• Safety Critical Equipment Identification, Inspection, Testing and Maintenance
• Use, Operation, Repair and Maintenance of Mechanical & Critical Lifting Equipment

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

• Although no pipe handling occurred at the time of the site inspection, TMEP oversight representatives were able to articulate their safe handling procedures and piping was observed to be stored and secured in accordance with company commitments.
• Welding was occurring at site and welders were noted to be wearing appropriate PPE and welding tools (e.g. grinders with guards) were observed to be in good working order.
• CER IOs observed the general management of lifting gear as hooks, slings, etc. are stored at the pipe yard and inspected to ensure fit for use.  At the time of inspection, gear was brought to site that was known to be or otherwise thought may be unfit for use.  The gear was being assessed and either disposed of in metal waste bin on-site or set aside for further examination as appropriate.
• CER IOs observed KLTP Hot work checklist and Hazard Hunt weekly document, which is completed on each Wednesday, which appeared to be complete.
• CER IOs observed Foreman's Safety and Quality meeting record & Operations Smart Card for Skid Steer (mobile equipment) documentation appeared to be complete. Foreman (Adam) provided explanation to inspection officers for both documents for procedure on completing.
• CER IO observed (on-line) several worker competency Level 1 & 2 assessment records for "Crosby Rigging" that appeared complete.

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: