BC Hydro. Interviews Completed VP Manager Supervisor Worker KSR Total

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1 Contact Information Name Grant Baxter Title Manager, Vegetation Maintenance Phone Fax Location Lower Mainland Transmission Auditee Information Name Grant Baxter Title Manager, Vegetation Maintenance Phone Fax Location Lower Mainland Transmission Scope of Audit Start Date 2003/11/24 Audit Profile Field Services - Transmission and Vegetation Headquarters Lower Mainland (HPN, LMT LMS), Kamloops, Prince George, Nanaimo, Vernon, Victoria. Audit Team Members Greg Quan/Todd Rapin - Lead Auditors; Peter Ficzycz (Corporate Safety); Wayne McLeod (Corporate Safety); Andy Merrill (Corporate Safety). Facilities Audited Notes Field Services Transmission Vegetation - Headquarters selected to participate in this Safety Management System Audit included: Prince George, Victoria, Nanaimo, Lower Mainland (Edmonds Operation Center, Lower Mainland Transmission, Lower Mainland South), Kamloops and Vernon. A total of 19 individuals were interviewed during this audit which comprised of representation from Managers, Work Leaders and Workers. Vegetation Maintenance provides professional vegetation management services that contribute to safe and reliable system, respect the environment, and optimize program values. Lead Auditor Information Name Greg Quan / Todd Rapin Phone or Fax (604) Location Edmonds - 12 Interview Information Total Number of Employees in Business Unit 50 Number of Employees in Audit Scope 19 Minimum Number of Interviewees Required 17 Employees in Business Unit Employees in Audit Scope Min Interviews Required Interviews Completed VP Manager Supervisor Worker KSR Total #2496 Field Services Page 1 of 46

2 Element 1 - Safety Leadership Element 1-1: Are safety leadership responsibilities for conducting operations in a manner that minimizes the risk of injury or disease to workers, contractors and the public understood by all personnel? 1.01.V1. Interview to verify Manager s understanding of their safety leadership responsibilities. Int : 6 / 6 Key Strength All interviews revealed that management demonstrate strong safety leadership and are committed to safety! 1.01.V2. Interview to verify Manager s understanding of their legal accountabilities related Int : 6 / 6 to providing a safe workplace V3. Interview to verify Supervisor s understanding of their safety leadership responsibilities V4. Interview to verify Workers understanding of their safety leadership responsibilities. Int : 6 / Element 1-2: Is Safety Leadership demonstrated? 1.02.V1. Interview a cross section of Managers, supervisors and workers to ask whether the management team (managers and supervisors) consistently follow all safety rules? Int : 6 / V2. Are members of the management team and specifically including the manager, involved in safety activities? Doc : 3 / 3 Int : 3 / 3 Total : 6 / V3. Are members of the management team and specifically including the manager, visible in the workplace discussing safety? Int : 6 / V4. Do members of the management team regularly intervene and address any unsafe act or condition they may observe? Int : 3 / 3 Doc : 3 / 3 Total : 6 / V5. Do members of the management team positively reinforce safe work behaviors on a regular basis? Int : 6 / 6 Element 1-3: Is the Safety Policy and related safety principles communicated to all employees? 1.03.V1. Ensure the Auditee Manager is aware of and can locate a copy of either the BC Doc : 3 / 3 Hydro Safety Policy or the BCH Safety Leadership Statement of Strategic Intent. Ensure that it is the most current version V2. Ensure the Auditee Manager has personally endorsed and supported the Safety Policy or BCH Safety Leadership Statement of Strategic Intent. Doc : 0 / 3 Not all managers provided endorsement that they supported the Safety Policy/Statement of Strategic Intent. #2496 Field Services Page 2 of 46

3 Consideration should be given to communicate safety policy and related safety principles to all employees as required by SMS 1 'Safety Leadership' section 3.3. For example; documenting actions such as addressing the safety policy/principles in meetings or posting their own version of safety concepts based on the policy statement V3. Interview to verify that either the Safety Policy or the BCH Safety Leadership Statement of Strategic Intent was communicated. Int : 6 / V4. Observe the workplace to verify that the current version of the Safety Obs : 3 / 3 Policy is communicated to all employees (for example posting on the wall or easy access to electronic version, etc.). Element 1-4: Are appropriate resources provided to meet the objectives and complete the activities outlined in the annual safety plan? 1.04.V1. Interview to determine how appropriate resources are provided to meet the objectives and complete the activities outlined in the annual safety plan. Int : 3 / V2. Interview to verify that adequate resources are provided to meet regulatory health and safety regulations, and other planned safety activities. Int : 6 / V3. Using the information provided in V1 and V2 (above), also select at least four of the activities outlined in the annual safety plan, obtain documented evidence of resources provided (for example, time and labor records, training records, capital expenditure, etc.). Doc : 6 / 6 Section Total Total Possible 84 Total 6 Total Applicable 78 Total Score 75 Percent 96% #2496 Field Services Page 3 of 46

4 Element 2 - Hazard Identification and Risk Assessment Element 2-1: Are safety and health hazards in the workplace identified annually? 2.01.V1. Obtain documentation of the identification of the safety and health hazards. Verify that this identification includes: Doc : 3 / 3 - safety and health hazards identified through interview - safety and health hazards identified through observation 2.01.V2. Obtain documentation of the identification of the safety and health hazards. Verify that this identification includes: Doc : 0 / 1 - safety and health hazards at all customer sites or other third party premises where BC Hydro employees perform work for (if applicable). Some locations did not provide an annual documented hazard identification and risk assessment for input into the workplace safety plan. Consideration should be given to ensure all areas identify safety and health hazards in the workplace and assess the risks as required in SMS 2 'Hazard Identification and Risk Assessment' section V3. Interview a cross section of workers to confirm their acceptance that the identified hazards cover the hazards faced in their job function. Int : 5 / 5 Nineteen (19) percent of the individuals interviewed did not confirm that identified hazards covered the hazards faced in their job function. (e.g. Anticipate hazards when working in the field during winter season) V4. Tour the operation to observe safety and health hazards in the workplace to confirm that the identified hazards adequately reflect the conditions of the workplace. Obs : 5 / 5 Element 2-2: Have the identified hazards been assessed for health and safety risk? 2.02.V1. Verify through Interview and through document review that a risk assessment on identified hazards has been completed. Doc : 3 / 3 Int : 2 / 2 Total : 5 / 5 Key Strength Field Services Vegetation Maintenance has completed their own hazard identification and risk assessment document ('Vegetation Management Risk Assessment - June 2003') following the Spring Field Services March 2003 Risk Assessment document V2. Confirm through documentation that the risk assessment has been completed in the last year, or that a previous risk assessment has been reviewed and updated as necessary within the last year. Doc : 3 / V3. Review the documented risk assessment and verify that relevant WCB Occupational Health & Safety Regulations with specific requirements for hazard identification and risk assessments are referenced. Doc : 5 / 5 #2496 Field Services Page 4 of 46

5 Element 2-3: Are the hazards identified reviewed to consider the adequacy and maintenance of existing preventive measures? 2.03.V1. Interview to determine that the identified hazards are reviewed to determine the adequacy of existing preventive measures and to identify the need for new or modified preventive measures. Int : 3 / V2. Obtain a copy of the results of the review that determined the adequacy of preventive measures and identified the need for additional or modified preventive measures. Doc : 5 / 5 Element 2-4: Are maintenance and monitoring of existing measures, and the development of new or additional measures, reflected in the annual safety plan? 2.04.V1. Obtain a copy of the annual safety plan. Verify, using the sample (at least three) selected (above), that the mitigation plans form part of the annual safety plan. Doc : 3 / 3 Consider inclusion of helicopter safety training (e.g. Lower Mainland Distribution, Vancouver Island Vegetation Mangement already include this in their safety plans) V2. Interview to determine that maintenance and monitoring of existing measures is conducted. Int : 2 / V3. Verify that the annual safety plan includes the maintenance and monitoring of existing measures. Doc : 1 / 1 Element 2-5: Have hazard and risk assessments been completed for significant changes in the workplace? 2.05.V1. Interview to determine that significant changes in the workplace are identified. Int : 1 / V2. Obtain documentation to verify that any hazards and risks related to the changes have been evaluated and managed through training, procedures, engineering methods, etc. Doc : 0 / 1 Key The auditors acknowledge that hazard identification and risk assessments have just been implemented. The SMS 2 'Hazard Identification & Risk Assessment requires that hazards and risks related to changes be evaluated and managed. (ie. Helicopter "Low and Slow" procedures used in some areas of Vegetation Maintenance for purposes of hazard tree assessment). Consideration should be given to ensure a documented hazard identification and risk assessment has been completed where significant changes in the workplace have occurred as required by SMS 2 'Hazard Identification and Risk Assessment' section and V3. Interview to determine if significant changes they have faced in the workplace have been identified and evaluated as per V1 and V2 of this Question. Int : 2 / 2 #2496 Field Services Page 5 of 46

6 2.05.V4. Observe the workplace and identify changes to the workplace have been made, or are planned, and identify any changes that are significant. Element 2-6: Are more detailed task analysis completed for job categories or specific tasks that are known to cause high rates or high severity of injury? 2.06.V1. Interview to determine that job categories or specific tasks that are known to cause high rates or high severity of injury have been identified. Int : 2 / V2. Obtain documentation that jobs identified as causing high rates or high severity of injury have had job specific hazard and risk reviews. Doc : 3 / 3 Section Total Total Possible 51 Total 1 Total Applicable 50 Total Score 48 Percent 96% #2496 Field Services Page 6 of 46

7 Element 3 - Monitoring Regulatory Compliance Element 3-1: Do Business Units review safety, legal and regulatory requirements? 3.01.V1. Obtain a record of the regulatory review and verify that the review determined which requirements apply to the Business Unit s operations. Field Services Safety Services has a process to communicate regulatory change via s or direct changes to safety standards that affect the field. exists for Field Services Safety Services to formalize tracking of regulatory changes. NOTE - This will be captured in the LoB safety Audit V2. Obtain a copy of the annual safety plan and related activities, to verify incorporation of the applicable regulatory and legal requirements. This type of review is outside the scope of this audit. This should be completed at the LOB level V3. Obtain training records to verify that workers have been trained to ensure they are aware of their legal and regulatory requirements and responsibilities, and how to apply them in their work. Doc : 2 / V4. Interview workers to verify that they are aware of their legal and regulatory requirements and responsibilities, and how to apply them in their work. Int : 2 / 2 Element 3-2: Do Business Units monitor changes to legal and regulatory requirements and make the necessary amendments to standards and supplementary instructions? 3.02.V1. Interview to verify that they have determined which changes to legal and regulatory requirements are applicable. Int : 5 / V2. Interview to verify that they have determined which changes standards and supplementary instructions are applicable. Int : 2 / V3. Interview to determine that applicable regulatory changes are communicated to workers. Int : 1 / V4. Interview to verify that applicable regulatory changes were communicated. Int : 2 / V5. Observe, and/or obtain documentation, to verify that changes are implemented. Doc OR Obs : 0 / 2 No records were provided to indicate that regulatory changes have been reviewed and implemented. For example, implementation could be noted in safety meeting minutes. Consideration should be given to ensure regulatory changes monitored by Field Services Safety are implemented in conformance with SMS 3 'Monitoring Regulatory Compliance', sub-section #2496 Field Services Page 7 of 46

8 Element 3-3: Are personnel performing tasks requiring specific licensing or certification (by legislation or regulation) in possession of current appropriate licenses or certificates? 3.03.V1. Observe the work environment, review job descriptions and emergency plans, and interview to determine if personnel are expected to perform tasks requiring specific licensing or certification. Obs : 2 / V2. Verify that the identified personnel (sample at least three) are in possession of current appropriate licenses or certificates (i.e. first aid, drivers licence with endorsement 15 for air). Doc : 5 / V3. Verify that the appropriate licenses or certificates are current. Doc : 0 / 3 Documents provided indicated that there is no formal system for recording/tracking expiry dates of licenses and certificates in place (e.g. Class 3 drivers license). Note - This could be accomplished at the LOB level using the Field Services TQTs program. Element 3-4: Are there requirements for interacting with and reporting to the Worker s Compensation Board, and other safety-related regulators, established? 3.04.V1. Interview to determine how requirements and processes for interacting with WCB, and other regulators, were established. Int : 2 / V2. Interview to determine if reports of inspections from WCB and other agencies have been received. Int : 2 / V3. Verify ( , interview, observation, record) that all reports of inspections from WCB have been forwarded to the Line of Business Safety Department. Doc : 3 / V4. Verify ( , interview, observation, record) that all reports of inspections from other safety-related regulators have been forwarded to the Line of Business Safety Department V5. Verify ( , interview, observation, record) that all reports of inspections from WCB and other agencies have been forwarded to Corporate Safety V6. Verify ( , interview, record) that all reports from other safety related regulators are forwarded to the Business Unit safety office and Corporate Safety (e.g. TDG Inspections, Fire Department Inspections). #2496 Field Services Page 8 of 46

9 Section Total Total Possible 45 Total 12 Total Applicable 33 Total Score 28 Percent 85% #2496 Field Services Page 9 of 46

10 Element 4 - Planning Element 4-1: Has an annual Safety Plan been prepared? 4.01.V1. Obtain the documented annual Safety Plan. Verify that it was prepared annually. Doc : 2 / V2. Interview to determine that the annual Safety Plan was established and documented. Int : 2 / V3. Review the annual Safety Plan and verify that it identifies and documents specific safety performance improvement objectives. Doc : 2 / V4. Review the annual Safety Plan and verify that it identifies and documents activities to achieve the objectives. Doc : 2 / V5. Interview to determine that the annual Safety Plan was reviewed and is scheduled for the next review. Doc : 2 / 2 Element 4-2: Are objectives, documented, and consistent with the commitments of BC Hydro Safety Policy? 4.02.V1. Interview to determine that objectives were established. Review the documented objectives and/or supporting documentation to verify that regulatory compliance requirements, identified hazards and assessed risks, technological options, financial, operational and business requirements were considered. Doc : 2 / 2 Int : 3 / 3 Total : 5 / V2. Review the documented objectives. Verify that they are consistent with the commitments of the Safety Policy, and align with corporate and business unit objectives and performance expectations. Doc : 5 / 5 Element 4-3: Are targets (performance criterion) developed to help assess progress in achieving objectives? 4.03.V1. Interview to determine that performance measures (targets) were developed. Int : 2 / V2. Obtain the documented targets. Select two objectives from the Safety Plan and verify that each objective has at least one target. Doc : 0 / 4 Not all areas provided documentation on safety targets/metrics to track objectives in the year's safety program as indicated in the Field Services Vegetation Maintenance Safety program. Consideration should be given to ensure that all safety plans include documentation of safety targets to verify objectives are being met V3. Review the documented targets (selected above) and verify that they include performance measures that help assess progress in achieving objectives. Doc : 0 / 4 Not all area annual safety plans (Schedules activities) included safety targets/metrics to meet objectives in the year's safety program as indicated in the Field Services Vegetation Maintenance Safety Program. Consideration should be given to ensure that all safety plans include documentation of #2496 Field Services Page 10 of 46

11 safety targets to verify objectives are being met. Element 4-4: Is the annual Safety Plan prepared and administered? 4.04.V1. Review the annual Safety Plan and verify that it includes a schedule of required safety program activities, including: Doc : 8 / 8 1) meetings 2) inspections 3) maintenance of safety equipment 4) the education and training of workers Element 4-5: Is the annual Safety Plan monitored to ensure that scheduled activities are completed? 4.05.V1. Obtain the annual Safety Plan and determine the monitoring schedule (ie: Quarterly). Doc : 10 / 10 Section Total Total Possible 48 Total 0 Total Applicable 48 Total Score 40 Percent 83% #2496 Field Services Page 11 of 46

12 Element 5 - Training, Awareness and Competence Element 5-1: Is the required safety training defined and updated annually through a training needs analysis? 5.01.V1. Interview to determine that training needs analysis has been conducted for safety related training. Obtain a documented training needs analysis to verify that the safety training is defined. Doc : 1 / 1 Int : 1 / 1 Total : 2 / V2. Confirm through documentation that the training needs analysis has been done Doc : 2 / 2 within the last year, or that a previous needs analysis has been reviewed and updated as necessary within the last year V3. Interview a cross section of workers to confirm their acceptance tha the identified training covers the hazards and needs of their job functions. Int : 4 / V4. Tour the operation to observe safety and health hazards in the workplace to confirm that identified training will adequately address these hazards. Obs : 4 / 4 Element 5-2: Is the required training entered into the Safety Plan and is being performed for appropriate personnel? 5.02.V1. Sample three different types of training identified in the training needs analysis. Review the Safety Plan and verify that these training needs are outlined in the annual Safety Plan for all relevant employees. Doc : 1 / V2. Confirm that training is being completed as outlined through the training needs analysis and as documented in the Safety Plan. Doc : 4 / V3. Interview Workers to determine whether training they receive is appropriate and sufficient in order for them to work safely. Int : 3 / 3 Element 5-3: Are training records maintained for employees? 5.03.V1. Using the sample, obtain and review records of training to verify that training records are maintained. Doc : 2 / V2. Verify through Interview that workers are aware of their documented training record, and their ability to access their training record. Int : 2 / 2 Element 5-4: Has the effectiveness of the training been assessed? 5.04.V1. Interview to determine that the effectiveness of the training has been assessed and documented and that as required by this assessment, subsequent training will be revised. Doc : 4 / V2. Interview Managers and Supervisors to ensure that subsequent to worker training, they review and observe the work practices and behaviors of workers under their direction match expectations defined in the training. Confirm review has been documented. Doc : 0 / 2 Int : 4 / 4 Total : 4 / 6 Key Not all areas audited provided the necessary documentation. Consideration should be given to document workplace inspections to ensure worker #2496 Field Services Page 12 of 46

13 training has been effective. Reference SMS 5 'Training, Awareness, Competence', subsection Element 5-5: Are new or transferred workers provided with safety related instructions / training? 5.05.V1. Interview to determine that new or transferred workers are provided with appropriate safety related instructions / training. Int : 3 / V2. Interview a sample of new or transferred workers and verify that they were provided with appropriate safety related instructions / training. Int : 0 / 3 Thirty one (31) percent of individuals interviewed felt that new or transferred workers were not provided with appropriate safety related instruction and training. Consideration should be given to ensure that new or transferred workers are provided with appropriate safety related instruction/training. Reference: SMS 5 'Training, Awareness, Competence', section V3. Obtain training records to verify that safety related instructions / training were provided. Doc : 2 / 2 Element 5-6: Has training covered tailboards and related risk assessment, plus an overview of roles and responsibilities? 5.06.V1. Obtain documentation to confirm that appropriate personnel have received training regarding the need for, and methods to perform tailboards. Doc : 0 / 4 Key Consideration should be given to provide tailboard training to those individuals who are new or recently transferred. Refresher training needs to be provided to workers where necessary V2. Obtain documentation to confirm that all personnel have received instruction outlining their roles and responsibilities related to safety (legal responsibilities as well as responsibilities outlined in the BCH Safety Management System). Doc : 0 / 4 Documentation provided does not indicate that instruction on roles and responsibilities was presented to workers. Consideration should be given to ensure personnel receive instruction outlining their roles and responsibilities related to safety. Reference: SMS 5 'Training, Awareness, Competence', section 3.6. Section Total Total Possible 50 Total 0 Total Applicable 50 Total Score 37 Percent 74% #2496 Field Services Page 13 of 46

14 Element 6 - Employee Involvement Element 6-1: Are safety committees established and maintained? 6.01.V1. Interview to determine that safety committees are established to represent all workers regarding safety and health issues. Int : 5 / V2. Obtain information on the safety committee (such as terms of reference or meeting minutes) and verify that the committee has been established in accordance with applicable regulatory and/or collective bargaining agreement requirements. Doc : 1 / V3. Use a cross-functional sample, obtain and review training records to verify that members of the joint safety committee has received instruction on its purpose and operation. Doc : 1 / 1 Safety Committee of record is the Field Services Joint Health and Safety Committee V4. Use a cross-functional sample, obtain and review training records to verify that members of the joint safety committee has received instruction on their responsibilities. Doc : 1 / V5. Use a cross-functional sample, obtain and review training records to verify that members of the joint safety committee has received familiarization with safety programs. Doc : 1 / 1 Element 6-2: Are all workers represented by Joint Safety Committees? 6.02.V1. Interview a cross functional sample of workers to determine that workers are represented in joint safety committees, as one channel for obtaining input and participation in the annual safety planning process. Int : 0 / 15 Key Thirty nine (39) percent of the individuals interviewed could not describe how they are represented by the FS Joint Health and Safety Committee. It is critical that workers understand the relationship with the "Committee of Record" that is their official (which is legally required) safety resource for safety related input. Consideration should be given to review Field Services Joint Health and Safety Committee structure and process with workers. Reference: SMS 6 'Employee Involvement', sub-section Element 6-3: Do workers know who are their Joint Safety representatives, and other safety resources? 6.03.V1. Interview to determine that workers have been informed as to who their joint safety committee representative(s) and their other safety resources are. Int : 5 / 5 Note - This is a different Question than 6.02.V1. Workers understand who their key safety representative is despite not understanding how they are being represented by the Field Services Joint Health and Safety Committee. #2496 Field Services Page 14 of 46

15 Element 6-4: Are workers informed of the ongoing Joint Safety Committee activities? 6.04.V1. Interview a cross functional sample of workers to determine that workers have been informed of the ongoing joint safety committee activities, both through posted safety committee meeting minutes and/or effective safety representative/worker communications (e.g. , general safety meetings, informal discussions, one-on-one conversations). Int : 0 / 10 Key Thirty three (33) percent of individuals interviewed were not familiar with the process. It is critical that all workers understand how the Safety Committee of record represents them. It is also critical that workers understand the relationship with the "Committee of Record" that is their official (which is legally required) safety resource for safety related input. Consideration should be given to ensure workers receive affective communication regarding the activities of the safety committee of record (Field Services Joint Health Safety Committee) in conformance to SMS 6 'Employee Involvement', section Element 6-5: Are workers encouraged to be involved in the safety program? 6.05.V1. Interview a cross-functional sample of workers to determine if, and how, workers are involved in the safety program. Int : 15 / 15 Element 6-6: Is safety recognition provided? Total : 0 / V1. Interview to determine that processes have been established and maintained to ensure that meaningful safety recognition is provided to workers. Int : 2 / V2. Obtain documents of processes and/or records of recognition and verify that the process includes meaningful recognition provided to workers for (two points per bullet): Doc : 0 / 6 - Participation in the safety program and safety planning process; - Achievement of safety performance; - Demonstration of good safe work practices. Not all managers provided documentation. Consideration should be given to ensure meaningful recognition is provided to workers for: 1. participation in safety program and planning process 2. achievement is safety performance 3. demonstration of good safe work practices. For example: document recognition in team meeting minutes. Reference: SMS 6 'Employee Involvement', section V3. Interview to verify that Business unit recognition processes incorporates the corporate-level Don McEwan Award that recognizes special achievements in safety, by workers or working groups, within the organization. Int : 2 / 2 #2496 Field Services Page 15 of 46

16 Element 6-7: Is there a process in place for getting safety improvement suggestions from the workforce? 6.07.V1. Interview to determine that the Business Unit has identified and implemented process by which to routinely acquire safety improvement suggestions from the workforce. Int : 2 / V2. Interview personnel in the workforce and determine examples of their safety improvement suggestions. Int : 2 / V3. Obtain documents/records of safety improvement suggestions from the workforce. Doc : 0 / 2 Key Not all areas provided information on getting safety improvement suggestions from workers. Consideration should be given to the implemention of a process to routinely receive safety improvement suggestions from the workforce. Reference: SMS 6 'Employee Involvement', section V4. Verify that these suggestions (in V3) are consistent with the worker suggestions obtained through interviews (from V2) with workers. Doc : 0 / V5. Obtain documents/records of the feedback on the suggestions from management. Doc : 0 / V6. Verify that the feedback (in V5) is given in a timely manner with the objective of dealing with safety issues more rapidly than waiting for periodic safety meetings. Doc : 0 / 2 Element 6-8: Does the recognition process encourage workers to intervene to correct unsafe acts or conditions? 6.08.V1. Interview a cross functional sample of workers and verify that meaningful safety Int : 5 / 5 recognition has been provided and incorporates the objectives of encouraging workers to intervene to correct unsafe acts or conditions. Element 6-9: Does the recognition process provide positive support and reaction to the reporting of unsafe conditions and near misses? 6.09.V1. Interview a cross functional sample of workers and verify that meaningful safety recognition has been provided and incorporated the objectives of providing positive support and reaction to the reporting of unsafe conditions and near misses. Int : 5 / 5 Section Total Total Possible 86 Total 0 Total Applicable 86 Total Score 47 Percent 55% #2496 Field Services Page 16 of 46

17 Element 7 - Documentation Element 7-1: Are pertinent documents related to the Business Unit Safety Program maintained? 7.01.V1. Verify that the Safety Plan is available, accessible to management, safety representatives and workers. Obs : 4 / 4 Element 7-2: Are activities undertaken within the annual safety plan recorded? 7.02.V1. Select a sample of activities (at least 5) undertaken within the annual safety plan. Obtain documentation / records to verify that the activities have been recorded and tracked. Doc : 5 / 5 Element 7-3: Are safety related documents managed in accordance with the requirements of the Safety Management System? 7.03.V1. Obtain a sample of these ten documents (from Appendix A), and verify that they exist (one point per bullet to a maximum of 10): Doc : 10 / 10 - Hazard ID Risk Assessment Records - Violence in the Workplace Assessment - Joint Health and Safety Meeting Minutes (12 months) - Annual OSH Plan - New employee orientation records - Pre job conferences and tailboards - Local inventory of Hazardous Materials - Working Alone Procedure - Site Fire and Emergency Plan - Inspection Reports (these could be departmental, WCB, or other regulatory reports) 7.03.V2. Using the sample documents above, verify that these documents can be located and are accessible (all ten must be correct for points). Obs : 2 / V3. Using the sample documents above, verify that these are legible (all ten must be correct for points). Doc : 2 / V4. Using the sample documents above, verify that these are signed or have personnel assigned responsibility for their maintenance (whichever is most practicable), and that access to master copies is restricted to those who have authority to make revisions (all ten must be correct for points). Doc : 0 / 2 Not all documents provided were signed and/or identifed a key contact person. Consideration should be given to ensure documents are signed or have personnel assigned who are responsible for maintenance. Reference: SMS 7 'Document Control', section 3.2. #2496 Field Services Page 17 of 46

18 7.03.V5. Using the sample documents above, verify that these are dated (with the date of revision). (All ten must be correct for points). Doc : 0 / 2 Not all sample documents provided were dated. Consideration should be given to ensure documents are signed or have personnel assigned who are responsible for maintenance in conformance with SMS 7 'Document Control', section V6. Using the sample documents above, verify that these are current and the current versions are available at all locations where activities essential to effective functioning of the safety program are performed (all ten must be correct for points). Doc : 2 / V7. Using the sample documents above, verify that these which are obsolete or contain out-of-date information and are promptly removed from all points of issue, to prevent unintended use and confusion (all ten must be correct for points). Doc : 2 / 2 Element 7-4: Are documents retained as required by? 7.04.V1. Using the sample documents identified in Question 7-2 (above), verify that the documents are retained in accordance with requirements. (All ten must be correct for points). Obs : 2 / 2 Section Total Total Possible 33 Total 0 Total Applicable 33 Total Score 29 Percent 88% #2496 Field Services Page 18 of 46

19 Element 8 - Operational Controls Element 8-1: Do adequate safe work procedures exist and meet requirements? 8.01.V1. Interview to determine that the Business Unit has identified where safe work procedures are needed, and that they have been established. Obtain documentation. Doc : 0 / 3 Int : 2 / 2 Total : 2 / 5 Key Minimal documentation provided by all managers. Consideration should be given to topics identified by the audit team following interviews with workers that are not covered by documented safe work procedures (e.g., Helicopter "Low & Slow", rock cliff/scaling, avalanche safety & chain saw safety). Reference: SMS 8 'Operational Controls', section V2. Verify that the safe work procedures: - Are written - Identify the work to be performed - Effectively identify and control the hazards - Identify any special protection or tools required by the worker - Identify the part of the company that it applies to (i.e. the local area, or the Line of Business/Service Organization, or all of ) This question was not scored as no documentation was provided at the time of the audit. See comment in Question 8.01.V V3. Interview a cross section of Workers to confirm their acceptance that the identified safe work procedures adequately cover the hazards and needs of their job functions. Int : 5 / 5 Nineteen (19) percent of individuals interviewed did not support the statement that adequate safe work procedures were provided. See comments in 'Key ' in Question 8.01.V V4. Tour the operation to observe hazards in the workplace to confirm that identified safe work procedures adequately address these hazards. Obs : 5 / 5 Element 8-2: Do workers conduct tailboard meetings prior to conducting work? 8.02.V1. Verify that Tailboards are performed before starting a job, that they give proper understandable safe work instructions to all workers involved in the job and that they are documented. Confirm through documentation and through Interviews. Doc : 4 / 4 Int : 5 / 5 Total : 9 / V2. Select a Tailboard Meeting that occurred in the last 6 months. Obtain documentation / records to verify that: - It included a review of job hazards and related work procedures - Was held before work commences for all work that is deemed as hazardous and #2496 Field Services Page 19 of 46

20 involves two or more workers - Cover the required inspection of specialized personal protective equipment to be used on the job, e.g. condition of live line tools, fall protection equipment, etc. - It was held before work begins, and at other times during the job when there are changes of plan, or when any interruption has involved significant time durations (e.g. long breaks) - The following concepts were communicated: Does the worker have all the necessary risk controls (e.g., appropriate training, personal protective equipment, back-up resources in case something goes wrong) in place? Is there anything the worker needs to do anything more or differently to improve the safety of the job? This question was not scored as Vegetation Maintenance assess contractor tailboards and rarely conduct their own as part of their work activities. Element 8-3: Have there been pre-job conferences to ensure sufficient resources are provided for the tasks at hand? 8.03.V1. Select a pre-job conference (for larger jobs that involve more than one line of business, service organization or contractor) that has occurred in the last six months. Obtain documentation to verify that: - It was set up in advance - All work crews are represented by at least one supervisor. - It ensured all workers know what to expect as the job progresses, communicate any known hazards related to the job and how they can deal with the hazards. - The following concepts were communicated: Does the worker have all the necessary risk controls (e.g., appropriate training, personal protective equipment, back-up resources in case something goes wrong) in place? Is there anything the worker needs to do anything more or differently to improve the safety of the job? This question was not scored as Vegetation Maintenance workers do not regularly conduct pre-job conferences. Element 8-4: Do supervisors ensure that work being performed under their authority is carried out in a safe manner? 8.04.V1. Interview to confirm that Supervisors are knowledgeable of the potential safety and health hazards associated with the work they are supervising, and the safe work practices and procedures that need to be followed in performing that work. Int : 3 / V2. Interview to confirm that Supervisors actively participate in safety instruction and training provided to Workers. Confirm attendance through documentation. Doc : 1 / 1 Int : 1 / 1 Total : 2 / V3. Interview to confirm that Supervisors attend or review the minutes of Joint OSH Committee meetings with their crew. Int : 0 / 1 Consideration should be given to ensure Managers review the minutes of the Field Services Joint Health and Safety Committee with their workers. #2496 Field Services Page 20 of 46

21 8.04.V4. Interview to confirm Supervisors give direction to their crew in how to perform work safely. This would be an ongoing activity (daily discussions, Tailboards, discussions through the course of a job). Int : 3 / V5. Interview to confirm that Supervisors perform field reviews of work being Doc : 3 / 3 performed under their authority. Review needs to include observation of work activity, Int : 3 / 3 assessment of workers behaviors, and confirmation of workers correct use of safe work Total : 6 / 6 practices and procedures. Review needs to include feedback between Supervisor and crew (this can be a correction of work practice, a discussion of issues, or a brief well done, depending upon circumstances). Confirm Supervisor documents field reviews (can be a canned form, or it can be a brief notation in a personal diary) V6. Interview Workers to verify that safe work practices and procedures are understood by them and are being applied. Int : 5 / 5 Element 8-5: Are workplaces inspected as per the requirements? 8.05.V1. Obtain a sample of requirements for inspections and verify that the inspection process defines: Doc : 0 / 2 - Where and how often the inspections are to be performed. - What is to be inspected and what is considered an acceptable or hazardous condition. - How to record and report the inspection results. Not all areas provided documention. Consideration should be given to ensure all managers maintain records of workplace inspections V2. Obtain a sample of records of inspections and verify that the inspections confirmed: Doc : 0 / 1 - That safe working conditions (housekeeping and other physical conditions) are maintained, and - That tools and equipment (including owned or leased vehicles) are kept in safe working order and in accordance with manufacturer s instructions. Not all areas provided documentation. Consideration should be given to ensure all managers document workplace inspections V3. Using the sample of records of inspections, verify through observation that the potential hazards observed during inspections were addressed, and any hazards with a high risk to cause serious injury or illness were addressed immediately. Obs : 2 / V4. Observe the work area to verify that workplace inspection reports are posted in a conspicuous location until hazards are corrected. Obs : 1 / 1 #2496 Field Services Page 21 of 46

22 8.05.V5. Obtain a copy of the annual safety plan. And verify that it includes documentation of the inspection process. Doc : 0 / 1 Not all areas provided documentation. Consideration should be given to ensure all managers include workplace inspections in their annual safety plan V6. Auditor to perform a general Observation of the work area to assess current physical conditions. Issues to assess include: Obs : 10 / 10 - general housekeeping - condition of tools and equipment - storage of hazardous materials Element 8-6: Is all personal protective equipment identified, provided and used? 8.06.V1. Interview to determine that personal protective equipment requirements have been identified. Confirm that PPE requirements have been documented. Doc : 0 / 2 Int : 1 / 1 Total : 1 / 3 Not all managers had the necessary documentation identifying the requirement for PPE. Consideration should be given to ensure that personal protective equipment requirements are documented. Reference: SMS 8 'Operational Controls', section V2. Interview and obtain documentation to verify that a PPE program is in place. Doc : 0 / 1 Int : 1 / 1 Total : 1 / 2 Consideration should be given to ensure a personal protective equipment (PPE) program is instituted. Reference: SMS 8 'Operational Controls', section V3. Interview to ensure that the identified and approved personal protective equipment is utilized. Int : 3 / V4. If PPE is required only in specific zones within the workplace, confirm that these zones are communicated. Obs : 2 / V5. Observe and verify (through inspection records where necessary) that personal protective equipment is used, is maintained in proper working order, and is inspected as required. Obs : 10 / 10 #2496 Field Services Page 22 of 46

23 Section Total Total Possible 92 Total 11 Total Applicable 81 Total Score 70 Percent 86% #2496 Field Services Page 23 of 46

24 OC Electrical Safety Operational Control 801-1: Has a qualified person performed an electrical safety evaluation at this site? V1. Interview to determine the evaluation process to review the Business Units operational performance with respect to this sub-element. Int : 3 / V2. Obtain records and verify that this evaluation covered training and the application of safe work procedures, and quality control of testing and maintenance of tools and equipment. Doc : 0 / 2 There is currently no electrical safety evaluation process that covers; training, application of safety work procedures, the quality control of testing and maintenance for tools and equipment. Vegetation workers are not the people that perform all of the above, however because they have the responsibility of managing contracts, their understanding of all of the above is crucial. Consideration should be given to ensure a documented evaluation process is in place that ensures a safe workplace when work is done in proximity to distribution and transmission systems. Reference: OC 801 'Electrical Safety', section 3.1 & 3.6. Operational Control 801-2: For energized electrical work are safe work procedures provided and workers trained and competent in their use? V1. Obtain training records to verify that these workers have been trained in the required safe work procedures. Doc : 2 / V2. Verify that Managers and Supervisors inspect to ensure workers are competent in the application of safe work procedures. Doc : 0 / 4 Consideration should be given to ensure all managers document their inspection process to include their workers' knowledge of the application of safe work procedures (e.g. Limits of Approach etc.) V3. Interview to determine that Workers know and understand Limits of Approach. Int : 2 / V4. Interview to determine if there is adequate provision for visual indicators (e.g. flags, rope. Tape, etc.) to identify designated work zones that will assist any worker to recognize the boundaries of a designated work zone. This question was not scored as Vegetation Maintenance workers do not use tools associated with electrical safety. Operational Control 801-3: Are tools and equipment tested, kept clean and in good working order? V1. Interview to verify if any tools or equipment, that are to be used to work on or in proximity to energized equipment, have been identified. #2496 Field Services Page 24 of 46

25 V2. Using a sample of electrical protective equipment, obtain records, or view labels, to verify that they have been tested in qualified testing shops to ensure they retain the required protective features V3. Using the sample of electrical protective equipment, obtain records, or view labels, to verify that they have been tested (including field testing) at the frequency stated in Table V4. Observe live line tools and equipment and verify that this equipment is not used without a valid TEST DUE decal or stamp V5. Observe tools and equipment (applicable to this Operations Control element) in operation and out of operation and verify that live line tools and equipment, which are damaged, have be withdrawn from service. Section Total Total Possible 25 Total 12 Total Applicable 13 Total Score 7 Percent 54% #2496 Field Services Page 25 of 46

26 OC Isolation Lockout and Tagout Operational Control 802-1: Has an isolation, lockout, tag out evaluation been performed at this site by a qualified person? V1. Verify tht the site has reviewed and followed up on the latest LoB Audit report recommendations (whatever deficiencies have been identified in a LoB Audit will have been reviewed and addressed for the Area by some knowledgeable person). Doc : 5 / 5 Operational Control 802-2: Have isolation procedures been defined for all equipment that has the potential for injury to workers? V1. Interview to determine whether any new or recently installed equipment (which due to unexpected start-up, operation or energization, could cause injury to workers) has isolation procedures defined V2. Interview to determine if all potential hazards have been considered due to energized equipment, to ensure existing safe work procedures will protect workers V3. Observe the work areas and verify that all boundaries between the areas that utilize differing procedures (e.g. PSSP vs. WPP vs. Personal Lockout) are clearly defined, visibly marked, and communicated to all workers working on or near them. Operational Control 802-3: Are all workers who apply isolation procedures trained and competent in their use? V1. Verify the training authorization of workers who apply isolation procedures or work on equipment that is isolated. Doc : 2 / V2. Verify that workers use a test step prior to initiating work (to verify that the equipment or machinery is de-energized) V3. Verify that Managers and Supervisors inspect to ensure workers are competent in the application of isolation procedures. Doc : 0 / 4 Key Consideration should be given to ensure all managers include this issue in their inspection documentation. Documentation shows a focus more on vegetation contractors and lacking in documentation of inspection of coordinators for their knowledge of the application of isolation procedures. Operational Control 802-4: Have the tools used for isolation and de-energization been inspected and tested? #2496 Field Services Page 26 of 46

27 V1. Verify that the site has a process to inspect tools used for isolation and deenergization and to test them to ensure they retain the required protective features. See documents that show inspection and testing records V2. Observe a sample of personal protective grounding devices and verify that they are not used without a valid TEST DUE decal or stamp. Section Total Total Possible 25 Total 14 Total Applicable 11 Total Score 7 Percent 64% #2496 Field Services Page 27 of 46

28 OC Workplace Environment Operational Control 803-1: Are chemical, physical, ergonomic and biological hazards identified and controlled? V1. Obtain the results of the hazard identification and risk assessments (per SMS Element 2 Hazard Identification and Risk Assessment, sub-section 3.1) and verify that the workplace assessment considered common work workplace environment hazards (see Operational Control sub-element 803 for details) including physical, ergonomics, chemical and biological hazards and risks. Doc : 9 / 9 Not all areas provided the necessary documentation. Points were awarded with the understanding that there was a recent addition to the Vegetation Maintenance management team V2. Sample at least three of the potentially harmful work environments that have been identified. Obtain documentation to verify that the hazards were evaluated to determine the level of severity of exposure. Doc : 3 / 3 Not all areas provided the necessary documentation. Points were awarded with the understanding that there was a recent addition to the Vegetation Maintenance management team V3. Where the severity of the hazard has been confirmed to create an unacceptable level of exposure to workers, obtain documentation to verify (for the sample) that a control measure has been developed, implemented, communicated, and maintained. Doc : 3 / 3 Not all areas provided the necessary documentation. Points were awarded with the understanding that there was a recent addition to the Vegetation Maintenance management team. Operational Control 803-2: Are chemical, physical, ergonomic and biological hazards communicated? V1. Obtain documentation to verify that all evaluations and assessments (especially those conducted outside of the worksite) are documented, and that these have been communicated to the manager responsible for the worksite. Doc : 2 / 2 Not all areas provided the necessary documentation. Points were awarded with the understanding that there was a recent addition to the Vegetation Maintenance management team V2. Sample at least one identified workplace hazard. Interview and obtain documentation to verify that significance of the hazard and control measure was explained to the worker(s) in the affected workplace (interview at least three relevant workers). Doc : 0 / 1 Int : 1 / 1 Total : 1 / 2 Consideration should be given to ensure all areas document significant hazards and control measures. Interviews revealed numerous examples that were not documented (i.e. Wildlife, drinking water & winter survival). #2496 Field Services Page 28 of 46