The NEB requires companies to have a management system that identifies and controls hazards and risks. We require that they continually evaluate and improve effectiveness of their management systems and implement corrective actions to prevent incidents. We do this so that performance of the regulated industry as a whole results in energy infrastructure that is systematically reliable and safe for people, the environment and property.
The NEB investigates and enforces regulatory requirements to prevent harm and acts to compel learnings for further system improvements. Companies must promote a positive safety culture to effectively manage threats to worker health and safety, and process safety. Information acquired from this work is used by the NEB to continually improve its regulations and practices.
Expected Management Systems and Industry Performance Program Outcomes…
- NEB-regulated companies comply with regulatory requirements to have a management system that identifies and controls hazards and risks.
- NEB regulatory actions are management system focused and are informed by results of incident root cause, trending and analysis of pipeline performance information, and leading indicators, research, technology and industry best practices.
- NEB–regulated companies demonstrate an improved commitment to mitigating human and organizational threats, including those related to safety culture.
… to support the prevention of harm to people or the environment throughout the lifecycle of energy-related activities.
Percentage of management system audit findings where the company implemented corrective actions within timelines, to track whether corrective actions are taken in a timely manner.
- Target 100%
Percentage of management system non-compliances determined to be repeat for all NEB-regulated companies. By identifying and communicating common areas of management system non-compliance across all companies back to industry, both the NEB and the regulated companies can take proactive actions to promote compliance.
- Target 10% decrease over previous year’s findings
2016-17 88% increase
2017-18 16% decrease
Common Repeat Management System Non-Compliances – 2017
Common Repeat Management System Non-Compliances – 2018
Figure 12 shows a visual breakdown of where the most common repeat management system non-compliances are found. This data is used to help scope the following year’s audits. Some caution must be used in interpreting this data as the scope of the audit can heavily influence the categories of findings. For example, in 2016-17, there were several audits specifically focused on incident reporting and, not surprisingly, the highest number of repeat findings is in the Investigating and Reporting Incidents area.
Percentage of incidents where the company reported implementing management system preventative actions, to demonstrate where companies are addressing incidents causes through management system actions – company or system-wide changes to management systems to address and prevent a specific incident cause at the management system level.
- Target 50%
2016-17 No Results
Trend of incidents or incident types linked to NEB regulatory actions, to show patterns in incident data and to identify whether the regulatory actions we are taking as a result are having an impact. This indicator allows the NEB to provide greater insight into how its regulatory actions are driven towards incident prevention.
- Target Downward trend
2016-17 Upward trend
2017-18 Upward trend
Understanding Key Incident Trends: Taking a Problem-centric Approach
The conditions in which incidents occur can be multi-faceted and not all incidents can be traced back to root cause in a straight line of cause-and-effect. In some circumstances, the data collected by the NEB points clearly to patterns in incident occurrence without demonstrating an obvious pattern in the cause of those occurrences. Where our data is not sufficient to explain why patterns might exist or what we could focus on in order to make an impact on the problem, the NEB actively develops problem-specific indicators and explores the data and related information. Currently, we are employing this problem-centric approach to the two key incidents trends identified in 2017-18.
In both cases our data demonstrates a clear trend, but not enough to isolate root causes for that trend. The NEB is defining these problems, and collecting data to answer problem-specific questions such as whether there is a relationship between the distance constructed and the number of serious injuries/fatalities, or the correlation of OBDLs with particular locations along a pipeline or in a facility. Identifying key incident trends and systematically defining what we know and what we don’t know enables us to target our resources toward finding solutions with accuracy and efficiency.
External data revealed that 58% of fatalities in the oil and gas industry worldwide relate to breaking of Life Saving Rules (LSR). We looked at those 18 Rules, identified which ones are common in pipeline construction, and updated our inspections procedures to include closer scrutiny of LSRs.
40% of oil and gas fatalities in the U.S. between 1991 and 2010
were linked to 8 high-risk activities at construction sites.
Incident data tells us that incidents increase with construction activity. The NEB believes that significant incidents can be avoided by ensuring that companies have proper systems and processes in place before they begin construction. Pre-construction audits are a new tool that helps the NEB proactively ensure those systems are in place.
In 2017, the NEB evaluated Trans Mountain’s readiness to manage the construction of the Trans Mountain Expansion Project (TMEP) with a focus on worker safety and incident prevention. The pre-construction audit involved two months of document review and on-site activities, including extensive interviews with company employees and review of company procedures, training materials, and staff responsibilities. The NEB concluded that Trans Mountain had not yet established, at the time of the audit, all of the necessary oversight measures to manage construction-related safety and environmental protection for the construction of the project.
TransMountain has since filed its corrective action plan (CAP), which was approved by the NEB. The NEB will monitor Trans Mountain’s implementation of the CAP as a part of ongoing regulatory oversight of the project.
30 repeat violators were
reported in 2017
Every unauthorized activity caused by a repeat violator is treated as high-risk, and given an elevated response by NEB Damage Prevention staff.
Percentage of the number of unauthorized activities that involve repeat violators, to determine the effectiveness of NEB and company follow-up actions to reduce repeat violations.
- Target 15%
Percentage of NEB-regulated companies that have allocated resources to promote safety culture advancement, to track whether companies demonstrate an improved commitment to mitigating human and organizational threats, including those related to safety culture.
- Target 100%
2016-17 No Results
Percentage of compliance verification activities (CVAs) where safety culture data is collected, to track whether companies demonstrate an improved commitment to mitigating human and organizational threats, including those related to safety culture.
- Target Establishing Baseline
2016-17 No Results
Safety culture refers to “the attitudes, values, norms and beliefs, which a particular group of people shares with respect to risk and safety”.
The Board has been developing and promoting safety culture since 2012. An increased focus on safety culture is a significant shift in our approach to proactively regulating safety at the system level. In 2017-18, the NEB initiated a project to explore the potential collection of safety culture data points, or “signals”, through NEB CVAs. The goal is to use this information to have meaningful conversations with regulated companies about cultural trends or issues, and to inform the NEB’s risk-based Compliance Verification Activity planning. In addition, the NEB plans to share notable trends and themes with industry members to support learning and continued improvement. The safety culture signal pilot project will continue in 2018-19 and will focus on building inspection officer competency in identifying and recording safety culture signals.