4. Letter and Reply from PACP - April 2022

Via email

04-04-2022

Michael Keenan,

Deputy Minister

Transport Canada

Dear Mr. Keenan:

As the 44th Parliament begins, the House of Commons Standing Committee on Public Accounts (the Committee) is reviewing the responses it received stemming from reports adopted in the 42nd and 43rd Parliaments. The following Committee report included recommendations to Transport Canada:

Report 3 (43rd Parliament, 2nd Session), Follow-up Audit on the Transportation of Dangerous Goods

Regarding Recommendation 2, the Committee received a government response in April 2021, which stated that regional directors had been made aware that the compliance status of dangerous goods sites must be documented in all cases following a dangerous goods violation. However, the report did not explain how the department verifies that the actions taken are actually documented and that the information is accurate.

The Committee would like to know how the department intends to verify that compliance status is documented in all cases following a violation and that the data is accurate.

The Committee requires that Transport Canada submit a response to this letter by 30 April 2022. The Committee may also request Transport Canada to appear before it should the answer provided be deemed unsatisfactory.

Should you have any questions regarding this request, please contact Angela Crandall, Clerk of the Committee.

 Best regards,

 John Williamson, M.P. Chair, Standing Committee on Public Accounts

Letter from John Williamson (PDF, 118 KB)

April 29, 2022

Mr. John Williamson, M.P.

Chair

Standing Committee on Public Accounts

House of Commons

Ottawa ON  K1A 0A6

Dear Mr. Williamson:

I would like to thank you for your correspondence regarding the responses stemming from reports adopted in the 43^rd Parliament on Follow-Up Audit on the Transportation of Dangerous Goods. I appreciate the Committee’s ongoing interest in the transportation of dangerous goods. I would also like to reiterate Transport Canada’s commitment to pursuing a safe, secure, efficient, and environmentally responsible transportation system.

The Committee received a government response in April 2021, which stated that regional directors had been made aware that the compliance status of dangerous goods sites must be documented in all cases following a dangerous goods violation. However, it was noted that the report did not explain how the department verifies the actions taken are actually documented and that the information is accurate.

The Transportation of Dangerous Goods Program’s new Regulatory Oversight Management application, which provides a fully online and accessible platform to record inspection and enforcement data in real-time, has fully addressed Recommendation 2 by providing a means to verify and document the compliance status of dangerous goods sites.

My department has produced the attached document in response, which provides additional details on how the department is taking steps to verify the compliance of sites that handle, offer for transport, transport, or import dangerous goods. I trust that the attached document addresses the Committee’s question.

Yours sincerely,

Michael Keenan

Enclosure

The Transportation of Dangerous Goods Program’s new Regulatory Oversight Management (ROM) application, which provides a fully online and accessible platform to record inspection and enforcement data in real-time, has fully addressed Recommendation 2 by providing a means to verify and document the compliance status of dangerous goods sites.  

Transport Canada confirms that after an inspector has logged all observed violations following an inspection and generates an inspection report, the Regulatory Oversight Management application will create a record for each violation, which we call a “confirmation of compliance record”. The inspector is not able to delete these records in the application and must close them individually by recording how the violation was resolved. There are various statuses that the inspector can select (e.g., resolved on time, resolved late, escalated, etc.) which allows the inspector to provide a description of how the company has returned to compliance. In addition, the Regulatory Oversight Management application allows inspectors to attach documentation (e.g., photos, documents, etc.) in relation to the violation to document exactly what the violation was and how it was resolved.

The guidance for inspectors is found in the Regulatory Oversight Management User Guide.

15.2    Manage Confirmation of Compliance Records

(1)           When the inspection report is generated, the system automatically creates a confirmation of compliance record for each of the violations.

(2)           When an inspector receives the confirmation of compliance for a cited violation, they can close the record on the Confirmation of Compliance tab.

In addition to the mechanisms in the Regulatory Oversight Management application mentioned above which ensure that follow-ups to non-compliances are conducted, managers supervising inspectors are also responsible for ensuring all targets and follow-up activities are being met as part of program quality assurance measures.