Operator Preparedness & Response

Operator activities must be conducted in a manner that ensures safe and environmentally responsible operations. Learn more about key processes below.

Identification of Hazards, Potential Situations and Events

Before we issue an Activity Authorization, an operator must identify all potential hazards, abnormal situations, emergencies, incidents and other events that could negatively impact the health, safety and security of people, or compromise the workplace or the environment. Operators must consider hazards, potential situations and events, eliminate them where possible and properly manage those hazards that remain. Examples of some of these potential emergencies include: fire, explosion, hazardous gas releases, severe weather, helicopter crash, sea ice, medical emergencies, damage to the workplace or support craft and spills of hazardous substances. Operators are also required to identify and demonstrate that they understand the potential consequences of each hazard and develop appropriate recovery strategies to our satisfaction. For example, this approach is displayed in Figure 1 - Managing Hazards for a potential petroleum-related spill event:

In this example, a threat could be a loss of well control event, which could result in a blowout (the release of water, brine, natural gas or oil during the drilling of a well). There are a number of controls and safeguards that must be in place to prevent a spill incident from occurring, some of the key ones are listed under the left side of Figure 1. Some of the key recovery strategies that could be implemented should a spill incident actually occur are detailed on the right side. Since 2010, there has been a significant increase in regulatory expectations that have been introduced to further reduce the probability of a well control event and to reduce the consequences of a blowout should it occur.

Risk Assessments

Risks related to the hazards, potential situations and events that may lead to emergencies are required to be reduced to as low as reasonably practicable. Operators must complete risk assessments identifying how they will manage and control risks and develop the appropriate emergency plans and evacuation procedures. This is to identify safety and environmentally critical systems, devices and equipment and to establish other practices, resources and monitoring programs that are reflected within their management system. This prepares operators and mitigates the effects of potential emergencies. This includes emergency planning for marine installations, drilling vessels, offshore wind farms, workboats, seismic surveying, diving programs and passenger crafts used to transit employees.

The primary focus of our efforts is to ensure that operators take all reasonable precautions to prevent the occurrence of incidents that may pose a threat to the safety of personnel or to the environment.

Trained Offshore Workers

Operators must ensure offshore workers have received the necessary training to respond to and react in the event of an emergency.

Operators are required by legislation to ensure all offshore workers are provided with information, instruction and training in a wide variety of workplace specific hazards and emergency response measures. Anyone travelling offshore must have the necessary ability, skills, and qualifications and competencies to respond and react appropriately, at a level reasonably required of them to perform their duties in the event of an emergency. This involves a routine of medical exams, high-fidelity simulation training and workplace drills and exercises.

According to the legislation and established standard practices, operators must ensure each worker has appropriate training specific to their position.

To learn more about training requirements, check out the following Code of Practice: Atlantic Canada Offshore Petroleum Standard Practice for the Training and Qualifications of Offshore Personnel.

Tests and Maintenance: Critical Safety and Environmental Machinery, Equipment and Control Systems

Machinery, equipment and control systems used by operators must be tested and maintained throughout the lifecycle of the activity and be fit for purpose in case of an emergency.

Operators must carry out tests and scheduled maintenance to demonstrate and ensure that machinery, equipment and control systems are in serviceable condition. They must also make sure that machines, equipment and control systems are operating to their performance standards and are ready in case of an emergency. Operators must demonstrate that these systems are fit for purpose and that they have access to available offshore facilities, support vessels and aircraft in an emergency situation. To demonstrate this, operators provide us with a Certificate of Fitness. A Certificate of Fitness is a required document for our Activity Authorization process and is issued by a recognized classification society. The Certificate of Fitness verifies offshore installations and vessels associated with an activity authorization are in compliance with regulations, fit for use and can be operated safely without polluting the environment.

If an emergency occurs, an operator must be prepared to respond quickly and effectively to protect the health and safety of offshore workers and minimize effects to the environment. 

Emergency Plans

Operators must submit emergency plans for us to review and accept prior to authorizing an activity. Plans to respond to potential health and safety and environmental emergencies are required by legislation for all offshore energy activities conducted in the Canada-Nova Scotia offshore area.

Contingency Plans

A contingency plan addresses a specific emergency outcome from hazards, potential situations and events.

Operators are required to submit contingency plans before an authorization can be granted. Contingency plans should include measures to prevent, mitigate and respond to emergencies. We review the plans 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 stakeholders. In addition, operators must test their contingency plans regularly to ensure effectiveness. In some cases, our team observes or participates in such simulations, to evaluate an operator's emergency procedures, preparedness and response.

Spill Response Plans

Operators must submit a spill response plan as part of our Activity Authorization process. This plan includes a risk assessment and outlines how an operator would respond to a variety of spill scenarios. Operators must also demonstrate that they have the necessary equipment in place and trained personnel prepared to respond to a spill. We verify that appropriate spill response plans are in place before issuing an authorization.

Net Environmental Benefit Analysis

Net Environmental Benefit Analysis, also known as a spill impact mitigation assessment, is an approach used by the oil and gas response community and stakeholders during oil spill planning and preparedness. It is used to compare the environmental benefits of potential response tools and develop a response strategy that will reduce the impact of a spill on the environment. A Net Environmental Benefit Analysis, or spill impact mitigation assessment, is one of the considerations used to select spill response tools that will effectively remove oil and will minimize the impact of the spill on the environment.

Operators are required to prepare a Net Environmental Benefit Analysis to assist in the development of their spill response plan. The Net Environmental Benefit Analysis is reviewed by us, in collaboration with Environment and Climate Change Canada’s National Environmental Emergencies Centre’s Science Table which includes Canada’s top experts in environmental protection and oil spill response from all levels of government, as well as other stakeholders from the oil spill response industry.

Approval of Dispersants

If a major emergency occurs and an operator was to consider the use of a dispersant, they would need to make the request to our Chief Conservation Officer for approval. Our Chief Conversation Officer would request that Environment and Climate Change Canada urgently convene the National Environmental Emergencies Centre’s Science Table. Once convened, these experts would evaluate the environmental pros and cons of using a dispersant based on the spill-specific scenario and the best available science to determine if using a dispersant would provide an overall net benefit to the environment. What this means is that the assessment would need to demonstrate that dispersant use for the specific instance will assist in minimizing the overall impacts to the environment and marine environment.

If it is determined that dispersants would be beneficial to mitigate the impact of the spill on the environment and marine life, dispersants would be approved for use. It should be noted that the Chief Conservation Officer can only authorize the use of dispersants that are legally approved for use in Canada by Environment and Climate Change Canada.

As part of the compliance oversight, we would closely monitor the operator’s actions to ensure the dispersant is being used appropriately, continues to be effective and has a net environmental benefit and that environmental protection remains paramount.

Emergency Response Team Drills and Exercises

Operators are required to complete emergency response drills and exercises. As part of our monitoring and compliance verification activities, we verify that exercises and drills are conducted as expected and in accordance with the operator’s management system commitments including measures for assessing and continually improving the emergency response plan.

Exercises and drills are conducted by operators, their personnel and contractors on the offshore installations or vessels and at their onshore office locations. The exercises and drills are conducted to test their response and readiness of internal and external resources during an emergency. An emergency response exercise typically involves the operator’s offshore workers located on the installation or vessel and staff that may be located at their onshore office. An emergency response exercise may also include mutual aid from external resources such as the Joint Rescue Coordination Centre, Canadian Coast Guard, other governmental departments/agencies and privately funded specialized emergency response service providers.

Our Role in an Operator's Emergency Response Exercise

As the regulator, we prepare for potential emergencies by participating and observing offshore emergency drills and exercises completed by operators. Our participation in an emergency response exercise allows us to observe and evaluate the operator on their response during the exercise. Some of our main objectives are evaluating an operator’s ability to implement a response command structure, exercise project specific response plans and execute response components such as plans, logistics and communications. We also simulate any decision making processes (e.g. use of dispersants) we are required to be a part of, and to act in our monitoring role as necessary to support the exercise.