Compliance verification activity type: Field Inspection
Team:
Regulated company: Pembina Energy Services Inc.
Operating company: Pembina Energy Services Inc.
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
Assess compliance with the OPR and CLC and program requirements. Incorporate lock out tag out procedure as a focus area.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - Process Document Review
Date & time of visit: 2017-05-31 08:30
Discipline: Safety Management
Categories:
Facility:
Observations:
Process Document Review Observations
Compliance tool used: No compliance tool used
Observation 2 - Record of Verification of Job Observation Analysis Prior to Safety Critical Task Performance
Discipline: Management System
Company representatives advised inspectors that Job Observation Analysis is included in the process and procedure(s) used by the company for verifying that employees and other persons working with or on behalf of the company are trained and competent prior to their ever performing a safety critical task, including lock-out-tag-out. However, company representatives were not able to provide documentation of this part of the process for verifying competency.
Compliance tool used: Information Request (IR)
Regulatory requirement:
Relevant section(s):
Company action required:
The company is requested to to provide the documented (written) process or procedure that includes the process for verifying competency through Job Observation Analysis of employees and other persons working with or on behalf of the company prior to their ever performing a safety critical task, including lock-out-tag-out.
Due date: 2017-07-04
Date closed: 2017-10-30 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 3 - Legal Requirements References
The Task Hazard Analysis Standard and the Isolation from Energy Sources Standard each included a list of applicable legal requirements and there was agreement that the lists should be reviewed to ensure all appropriate federal references were included . It was explained to the NEB inspection team that the standards are under a review cycle such that they would be updated in November of this present year.
The company is requested to provide an explanation of the steps that will be taken and timeline to update the legal requirements (or "Regulations") listed in the Task Hazard Analysis Standard and Isolation from Energy Sources Standard to include all applicable federal requirements.
Due date: 2017-11-30
Observation 4 - Car Seal Use in Isolation from Energy Sources Standard
The intended use of car seals as referenced in the Isolation from Energy Sources Standard was not clear to the NEB inspection team or to the company representatives. The question was raised as to its appropriateness at all in the standard.
Clarify the intended use of car seals in the Isolation from Energy Sources Standard and inform the NEB inspection team in writing (by email or letter) of this clarification to the use of car seals in the standard or if it is removed from the standard.
Observation 5 - Pump Station
Date & time of visit: 2017-06-01 10:30
LOTO Process Observations
There are no observations with outstanding follow-up
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
Observation 6 - 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