Summary of the ERTF Second Quarterly Report

The full ERTF Second Quarterly Report.

This is a summary of the Second Quarterly Report from the Emergency Response Task Force since its creation following the Ministerial Announcement on April 23, 2014.  The purpose of the quarterly report is to provide a progress report to the Director General of Transport of Dangerous Goods Directorate (TDG Directorate), to submit recommendations and explain the next steps.

Building on Protective Direction 33:

Subgroup 1 focused their attention on Building on the Protective Direction 33 (PD 33)^{Footnote 1}.  Their conclusions and recommendations were submitted to the Task Force for decision on February 19, 2015.  The recommendations were accepted and included in this report as recommendations 17, 18 and 19.

The subgroup has corroborated and validated the TDG Emergency Response Assistance Plan (ERAP) review process for spill-only flammable liquids rail incident scenarios.  For fire flammable liquids rail incident scenarios, the subgroup identified areas for further examination including:

• Unknown response service levels and timelines once an ERAP is activated;
• Capability and competency requirements description for a Technical Advisor resource  for flammable liquids ERAPs; and
• First Responders knowledge on the availability and competency requirements for an ERAP-holder’s Technical Advisors.

Results of this examination allowed the members to suggest the following to Transport Canada:

• Clarify service level and timeline expectations on activation of an ERAP, a three Tiered Response Timeline was developed to serve as a best practices baseline standard;
• Consider further developing a Flammable Liquids Technical Advisor (FLTA) Competency Profile (including expected credentials and equivalencies), and to suggest competency assessment criteria to be used by Transport Canada during its ERAP review process;
• Increase awareness in communities of the availability and competency of the FLTA.  Transport Canada should include the FLTA profile as part of its Awareness and Communication Strategy for emergency planners.

Incident Management/Structure:

Subgroup 2 on Incident Management/Structure provided their findings and submitted their proposed recommendations to Task Force members for decision on January 15, 2015.  The recommendations were accepted and included in this report as recommendations 5 to 16.

Subgroup 2 discussions led the Task Force in identifying key issues including:

• Incident Command System (ICS) coordination challenges regarding rail incidents involving flammable liquids; and
• Need for a comprehensive training standard for First Responders regarding specialized firefighting techniques involving flammable liquids incidents.

To ensure the successful coordination and management of emergency response to flammable liquids rail incidents, Subgroup 2 members agreed on the following key components of an Incident Management Structure and Command:

1. All those involved in the response must have a clear understanding of the roles and responsibilities of the primary government agencies and the private sector organizations during a rail incident;
2. The local “Authority Having Jurisdiction” must be recognized as the authority that designates the Incident Commander, providing clarity on “Who’s In Charge”;
3. The Incident Management Structure needs to use a Unified Command Structure where representatives with appropriate agency authority are “All in the Same Tent” (Command Post), recognizing that there is a single Incident Commander who bears ultimate responsibility for decision making;
4. For situations where the local community is not capable of managing the incident, the railways may be the only organization to initiate and organize a response. In these instances, a Federal/Provincial/Territorial government body needs to be recognized as the Authority Having Jurisdiction to ensure compliance with health, safety and environment regulations to maintain public confidence in government oversight;
5. The priority and focus of the Transport Canada TDG inspectors/Remedial Measures Specialist should be public safety and not enforcement activities, until the incident is stabilized and public safety is assured;
6. Building trust before an incident occurs is important and can be accomplished by training and participating in exercises across the greater emergency response community.

Recognizing that the safety of First Responders and the public is a critical element in establishing an effective ICS structure and developing an Incident Action Plan that is understood and followed by all on-scene agencies and personnel, the Task Force suggested 11 recommendations for Transport Canada’s consideration.

Recommendations by the Task Force

Recommendation 5: Support the concept of a standardized ICS, based on the ICS Canada program and that the Incident Commander in charge of a railway or other dangerous goods incident will be a representative of the local authority having jurisdiction working within a unified command structure.

Recommendation 6: Require ERAP documents to include identification of ICS and a Unified Command structure as part of the planning requirements for response to incidents.

Recommendation 7: Require ERAP Technical Advisors to complete, at a minimum, the following ICS Canada incident command courses, appropriate to their roles in an incident:

• I-100 Introduction to ICS
• I-200 Basic ICS for Single Resources and Initial Action Incidents
• I-300 Intermediate ICS for Expanding Incidents

Recommendation 8: Require railway companies to provide copies of their Emergency Response Plans to the TDG Directorate, with details on how the ICS System is incorporated within those plans for dangerous goods incidents and, that the information in the railway Emergency Response Plans is immediately available to CANUTEC during an emergency incident.

Recommendation 9: Require railway companies to have company managers, supervisory staff and contractor supervisors, who attend dangerous goods incidents, complete at a minimum, the following ICS Canada incident command courses, appropriate to their roles in an incident:

• I-100 Introduction to ICS
• I-200 Basic ICS for Single Resources and Initial Action Incidents
• I-300 Intermediate ICS for Expanding Incidents

Recommendation 10: Include in the Transport Canada Training Program for TDG Inspectors and Remedial Measures Specialists the following ICS Canada courses, appropriate to their role in an incident:

• I-100 Introduction to ICS
• I-200 Basic ICS for Single Resources and Initial Action Incidents
• I-300 Intermediate ICS for Expanding Incidents

The CANUTEC representative indicated that this training should also be included in their plan so CANUTEC Advisors could get training on ICS.

Recommendation 11: Review and define the roles and responsibilities of TDG Inspectors and RMS to include consultation and advice with the Incident Commander to help in developing an Incident Action Plan.  Transport Canada should make those roles and responsibilities well known to both the public sector and private sector as part of their Awareness and Outreach Program.

Recommendation 12: Facilitate the development of a template for a Community Dangerous Goods Emergency Response Plan that can be incorporated in Community Emergency Plans.

Recommendation 13: Work in collaboration with Public Safety Canada, Senior Officials Responsible for Emergency Management (SOREM), Railway Association of Canada (RAC), Canadian Association of Petroleum Producers (CAPP), Canadian Fuels Association (CFA), Aboriginal Firefighters Association of Canada (AFAC) and the Canadian Association of Fire Chiefs (CAFC) as well as other stakeholders in a comprehensive outreach and education program that provides information and training/reference materials for dangerous goods ICS “best practices”, as well as recommending the use of ICS Canada training courses for First Responders.

To increase awareness and as part of the Communication and Outreach Strategy, it is further recommended that these documents be developed and completed by Transport Canada to be distributed in conjunction with the 2016 Emergency Response Guidebook to all first response agencies and community/First Nations emergency planners in Canada.

Recommendation 14: Complete the development of and production of the following concept documents:

• Community Emergency Planning Guide for Dangerous Goods
• The Emergency Planning and Response Cycle Chart
• ICS Structure Using Unified Command for Railway Dangerous Goods Incidents Chart
• Railway Dangerous Goods Incidents – Roles and Responsibilities Table and Chart
• Flammable Liquid (TDG) Emergency Response Chart - A Disciplined Approach
• The Disciplined Approach work sheets for developing an Incident Action Plan (IAP) with ICS
• Provide a dangerous goods lexicon with standard names and terminology

Recommendation 15: Work with the Centre for Security and Science (CSS), First Responders, emergency planners, RAC member companies, ERAP holders, CANUTEC and Transport Canada RMS representatives to develop response exercises to test and evaluate the effectiveness of the ERAP program and identify opportunities for improvement.

Recommendation 16: Encourage and support training, exercises, networking and interaction between railway personnel, First Responders, emergency planners and Transport Canada to build experience, trust and communications in application of the ICS and unified command at dangerous goods incidents.

Recommendation no. 17: Further develop a Flammable Liquids Technical Advisor (FLTA) Competency Profile that can be used as a tool during the review and approval process of an ERAP for Class 3 Flammable Liquids.

Recommendation no 18: Include the Response Tier and Timelines Best Practices as a standard addition for outreach activities.

Recommendation no. 19: Include the Flammable Liquids Technical Advisor (FLTA) Competency Profile in the TDG Directorate planning for outreach activities.

Training for First Responders:

Subgroup 2 identified that the National Fire Protection Association (NFPA) Standards are currently being used to train firefighters across Canada. To provide a single comprehensive standard addressing flammable liquids incidents being transported by rail, a submission to the NFPA Standards Council was filed on January 27, 2015, proposing a new Standard on Competencies for Responders to Incidents of Flammable Liquids in Transport – High-Hazard Flammable Trains (HHFT).

In addition, a NFPA sponsored Training Workshop is scheduled for March 18, 2015, for the purpose of developing specialized training guidelines to help support First Responders when dealing with flammable liquids incidents by rail.

Data Collection and Analysis:

Following a request made by the Task Force to Transport Canada for assistance in the collection and analysis of data that is required to pursue its work, the TDG Directorate has several initiatives underway to provide the requested information to the Task Force.  Work is now underway to provide the following:

• Mapping of Fire Stations, equipment and resources located along rail corridors;
• List of flammable liquids (UN numbers), volumes and rail corridors;
• Mapping of rail corridors transporting flammable liquids; and
• Inventory and categorization of flammable liquids (a team of subject matter experts are currently working on this initiative).