Summary of the ERTF Third Quaterly Report

The full ERTF Third Quarterly Report.

This is a summary of the Third 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.

ERAP Requirement for Additional Flammable Liquids

The Task Force was mandated to use a risk-based approach to review the possible expansion of the ERAP program to other Class 3 Flammable Liquids that were not included in those identified in PD 33.  To assist the Task Force, two Subject Matter Experts (SMEs) were tasked with the examination of the Flammable Liquids.  Based on the SME findings, the Task Force is proposing the following recommendations for Transport Canada’s consideration:

Recommendation no. 20

When conducting the risk assessment to determine products that require an ERAP, consider:

• The Subject Matter Experts findings regarding the physical-chemical behaviors of Class 3 PG I and II Flammable Liquids as documented in the SME’s Report dated April 12, 2015 (presented in April 2015 to the ERTF Subgroup 3), and
• Volume of product in transport by rail.

Recommendation no. 21

Subject Matter Experts are to continue the work on the technical categorizing of Class 3 Flammable Liquids based on physical-chemical behaviors, in the following priority order:

• Class 3 PG III
• Class 3 (6.1)(8); Class 3(8)
• Class 4.3(3); Class 4.3(3)(8)
• Class 6.1(3); Class 6.1(3)(8); Class 6.1(4.3)(3)
• Class 8(3); Class 8(3)(6.1)

Recommendation no. 22

To continue the mapping work undertaken by TDG on transportation routes and volumes of Class 3 Flammable Liquids and include additional products that may be transported in large volumes by rail in tank cars.

Recommendation no. 23

Establish a performance evaluation program to periodically assess the effectiveness of the ERAP program for Flammable Liquids, taking into consideration changes such as transportation trends, and consider amending the requirements to the products covered by ERAPs to ensure policy objectives are met.

Training for First Responders

A critical issue identified by the Task Force early on was the need to focus on first responders’ capacity to handle flammable liquids spills or fires, given the responder community’s limited knowledge and training opportunities in this area.  An additional challenge is the limited capacity for small or remote communities to fund adequate resources and training to respond in case of an incident involving flammable liquids.  Since available data shows an increase in the volume of Class 3 flammable liquids moving on rail over recent years, the issue of emergency response capacity is a serious concern.

Members discussed how best to address potential gaps in the current training program for first responders in Canada.  Part of the discussion was the identification of existing and potential training resources and facilities in Canada.  A focus group was established to identify key components of an educational program that would reflect Canadian context.

Consequently, the following recommendations are provided to Transport Canada for consideration in helping to develop and deliver appropriate flammable liquids training courses to Canadian fire services:

Recommendation no. 24

Support the concept of a Canadian “Flammable Liquids in Transport Training Program” that addresses the following:

• A training program modeled on the precedent established with the CFI and the Canadian Association of Fire Chiefs (CAFC) program - “Anhydrous Ammonia Awareness for First Responders”.
• A program designed with Canadian content and references in both official languages.
• A multi-level program design consisting of:
  1. Basic (introductory) level - designed as a self-directed, web based program with modular content and an examination component; and
  2. Operations (Hands-on) level – designed for delivery at provincial fire colleges or fire department training facilities.
• A program acceptable to the CAFC and the Council of Canadian Fire Marshals and Fire Commissioners.
• Basic introductory awareness course content development and implementation supported by Canadian Association of Petroleum Producers (CAPP) and Canadian Fuels Association (CFA) through ENFORM in consultation with Emergency Response Task Force stakeholders.  Funding for more advanced training programs needs to be further discussed with input from Transport Canada, CAPP, CFA, CAFC, Railway Association of Canada and other the Class 1 Carriers.‎
• A program maintained and updated as new standards or information becomes available to reflect “Best Practices”.

Recommendation no. 25

Make staff available to assist in developing the training programs to ensure complete and correct information on TDG programs (CANUTEC, ERAP, RMS services, etc.) are included.

Recommendation no. 26

Include these training courses for Remedial Measures Specialists, CANUTEC advisors and other appropriate employees that could be involved in flammable liquids incidents.

Recommendation no. 27

Make available staff to assist in the delivery of Operations level of flammable liquids training programs as a part of the TDG Outreach and Awareness program.

Recommendation no. 28

Establish a forum for members of the ERTF to continue to hold technical discussions once the ERTF has completed its mandate.  This could be in the form of a technical committee or standing working group under the General Policy Advisory Council (GPAC).

ERAP Program Improvement and Effectiveness

Strengthened communication of the ERAP program and regulations is recommended.  During their discussion, members identified four areas of the ERAP program as presenting improvement opportunities:

1. Clarifying ERAP Activation (process, authority, services levels and expectations);
2. Addressing the challenge of coordinating multiple plans implemented for the same incident;
3. Identifying ERAP Program data needs for continued improvement and effective monitoring; and
4. Improving communication and information sharing.

The following recommendations are made to Transport Canada for consideration.

Recommendation no. 29

To include the “Response Tier and Timelines” presented as industry’s best practices, in all ERAPs.  The Response Tier and Timelines is a suggested minimum of three tiers as follows:

1. Tier One response time for a Technical Advisor to provide technical or emergency response advice by telephone would be within 10 minutes of the initial request; 
2. Tier Two response time for a Technical Advisor to attend the incident scene would be within six hours of the initial request; and 
3. Tier Three response time for a response team and equipment to attend the scene would be within 12 hours of the initial request. 

Best efforts are expected, however, consideration must be given to natural disasters, weather conditions, site accessibility, or other circumstances such as acts of terrorism which may interfere with the above timelines.

To further increase confidence in Class 3 ERAP response resources and technical advice, members recommend developing a competency profile for “Flammable Liquid Technical Advisors” designated in ERAPs that would include training and accreditation standard requirements.  This will offer better guidance to ERAP-holders and regulators assessing the plans.

Recommendation no. 30

Transport Canada require rail carriers to share emergency response and preparedness information pertaining to potential dangerous goods incidents with emergency planners, first responders, CANUTEC and other agencies, to increase cooperation and coordination at dangerous goods incidents.

Recommendation no. 31

Recognizing that expected outcomes of an ERAP is to provide response support that is Timely, Appropriate, Safe and Coordinated (TASC), it is recommended that Transport Canada monitor the ERAP program and foster its continuous improvement by establishing criteria to assess if the four identified expected outcomes are being met, collect and assess the necessary data and consider opportunities for improvements.

Recommendation no. 32

Transport Canada provide first responders and emergency planners with information on the contents and resources available to them in the event of a dangerous goods incident and that these documents be made available on line and as part of the Outreach and Awareness program.

Recommendation no. 33

Transport Canada require railways to provide to CANUTEC train consist information, in an electronic format, immediately upon becoming aware of a rail incident involving the release or potential release of dangerous goods.

Next Steps

The Task Force had its last scheduled monthly meeting on June 11, 2015.  As the one year mandate concludes, several items remain outstanding.

One of the three items is the assessment of additional Class 3 Flammable Liquids products for potential inclusion in the ERAP Program.  The SMEs have since concluded their analysis of Class 3 PG III products, and their findings and conclusions were documented in a report presented to the Task Force on June 11, 2015.  The technical categorization of the remaining Class 3 substances as per Recommendation 21 is ongoing and expected to be completed by end of July 2015.

Over the course of the summer of 2015, Transport Canada will study the SMEs finding on the Class 3 products analysis and categorization and will conduct an evaluation for a potential inclusion in ERAP program.  Findings will be shared with the members in early fall 2015.

The second item is to resolve remaining questions pertaining to the activation of ERAPs.  Further consultation is necessary to achieve consensus and draw clear conclusions.

The third item is the development of a Canadian firefighter curriculum for flammable liquids.  Several initiatives undertaken by the Task Force were still ongoing at the time this report was being drafted.  Some initiatives will take some time, such as the development of a specialized tactical hands-on training curriculum for Canadian firefighters.  The curriculum will rely on the development of a new NFPA training standard, and the process can take up to two years.  In addition, the project requires lots of resources.