Authorization & Oversight Activities

The legislation sets minimum requirements for offshore health and safety and is written to promote proactive practices, and to empower workplaces where everyone has responsibilities to keep the workplaces safe and healthy. Operators have the ultimate responsibility of implementing and maintaining an occupational health and safety management system. The occupational health and safety management system should foster a culture of workplace safety and specifically address the operations or activities in the Canada-Nova Scotia offshore area.

Safety culture was first referenced in an offshore oil and gas context in the inquiry into the Piper Alpha disaster, which occurred in July 1988. Today safety culture continues to be recognized as a determining factor in health and safety outcomes. We have developed a safety culture framework with the Canada Energy Regulator and the Canada-Newfoundland and Labrador Offshore Petroleum Board to promote a shared understanding of safety culture. It is our expectation that the operators we regulate build and sustain a positive organizational safety culture, while continually examining their organization for potential threats.

More information on safety culture and our collaborative efforts with other government departments and   agencies can be found here:

• Safety Culture Indicators Research Project: A Regulatory Perspective (2016)
• Advancing Safety in the Oil and Gas Industry: Statement on Safety Culture (2021)
• North American Regulators Working Group on Safety Culture: Safety Culture Indicators Research Project Continued Learning (2018)
   

Operator’s Occupational Health and Safety Management System

Operators must submit supporting documents for our review that demonstrates they have a health and safety management system in place that meets our regulatory requirements. This includes having a safety plan which highlights all the necessary steps that are taken to ensure the health, safety and security of offshore workers on a marine installation or structure, vessel, aircraft, or support craft associated with the specific offshore activity or project. This assessment is completed before an authorization can be granted and helps us to determine the readiness of an operator to conduct activities in a safe, responsible and compliant manner.

For petroleum-related activities, our experts have developed a joint Safety Plan Guideline with the Canada-Newfoundland and Labrador Offshore Petroleum Board to assist operators in meeting legislative requirements and associated regulations. The Safety Plan Guidelines provide our expectations for industry in meeting the statutory requirements.

When reviewing an Operator Safety Plan, we ensure an operator’s written policies, programs and procedures focus on:

• Authorities/command structure
• Risk assessment
• Operations and maintenance
• Training and qualifications
• Contingency planning
• Physical environment monitoring

If an operator is not able to provide the required health and safety documents and demonstrate to us that they are able to conduct the work safely, they will not be granted an authorization to work in the Canada-Nova Scotia offshore area. If an authorization is accepted, the operator must continue to demonstrate to us that the accepted safety management system effectively identifies, assesses and controls health and safety hazards throughout the lifecycle of a project.

Although prevention is the primary focus, operators must, just as importantly, prove that they are prepared and able to respond quickly and effectively to an incident of any size, should one occur.
 

We require operators to conduct risk assessments and submit contingency plans to address emergency situations. Operators must identify and manage hazards, potential situations and events that may occur in order to be prepared for an emergency. We must accept these plans before we can issue an activity authorization.

Contingency plans include measures to prevent, mitigate and respond to emergencies. We review the plans submitted by operators to ensure that they include items such as the duties and responsibilities of personnel, medical support, communications equipment/facilities, reporting and notification procedures, and the appropriate contact information for responders and identified stakeholders. In addition, operators must test their contingency plans regularly to ensure effectiveness. As part of our oversight, we observe or participate in some of these simulations, to evaluate an operator’s emergency procedures, preparedness and response.