Management Acknowledgement and Response to the DFO Hazardous Occurrence Investigation Report
February 21, 2018
Table of Contents
February 21, 2018 the Investigation Report prepared by the Occupational Health and Safety Unit, a component of the Regional Real Property Safety and Security (RPSS) sector concerning the fatality on board a Conservation and Protection vessel on July 10, 2017, was submitted to the Regional Director General’s Office. The following formally acknowledges receipt of the report and advises of the action plan to address the recommendations presented in the report.
Recommendation #1
It is recommended that a policy Instrument be developed to provide clear guidelines on granting of access to non-DFO personnel on-board DFO operations on water. The guidelines should explain clearly the duties and responsibilities of DFO staff prior to granting access to non-DFO staff in operational zones and during specific events as well as the restrictions.
The Guidelines should include the requirement to confirm if the people granted access have the experience, knowledge and training required to execute tasks at hand and that they have been briefed on any hazards associated with the operations.
These verifications must be conducted before the activities take place to ensure the safety of all staff and non-DFO personnel.
Response to Recommendation #1
DFO committed has committed to develop a Policy on Non-Employee Granted Access to DFO Workplaces. The new Directive will be drafted in consultation with key sectors of the department at the national level and will supplement already existing documents, such as the “Guide on the Safety Responsibilities of DFO in Relation to Contractual Agreements, Partnering and Volunteers“. The directive will cover the requirement to provide and wear personnel protective equipment when appropriate. This policy will be in place for January 1, 2019.
Contracts with external organizations will also require that individuals working or volunteering for these organizations must wear the appropriate personal protective equipment, including helmets, every time they work from a DFO vessel.
Recommendation #2 (Specific hazards related to whale disentanglement operations)
Due to the specific nature of this type of operation and with the unique hazards that personnel may be exposed to, a safe work procedure and a task hazard analysis, specific to whale disentanglement operations should be developed.
Staff must be instructed and trained in those procedures to ensure that they are aware of the safety precautions to be taken and to ensure that control measures are identified and in place.
Response
On October 30, 2017, Conservation and Protection (C&P) published national procedures providing clear instructions to fishery officers on their role during marine animal incidents, including disentanglement operations. These procedures complement the safe work procedures already in place at the time of the incidents. They ensure that fishery officers across the country are approaching disentanglements in a consistent and safe manner, no matter where they are located. Such procedures also stipulate that at no point fishery officers will lead the response during disentanglement.
C&P reviewed all its standard operating procedures related to the involvement of its fishery officers in marine animal incidents. As a result, helmets have been added as mandatory personal protective equipment for fishery officers and all persons granted access to C&P vessels. The updated documents include:
- 038 Task Hazard Analysis: Responding to Marine Mammal Incidents
- 038 Safe Work Practice: Responding to Marine Mammal Incidents
- Marine Mammal Response Standard Operating Procedures
C&P National Executive Committee took the decision on February 8, 2018 to purchase helmets for all fishery officers trained to support disentanglement situations. These helmets will be received by March 31, 2018.
DFO developed safe work procedures and task hazard analysis for the work being conducted by its fishery officers, which is limited to supporting experts during disentanglement operations. At no time are fishery officers cutting any ropes entangling whales. The lead disentanglement activities are done by an internal expert (Pacific) and by external partners (Atlantic).
DFO (Resource Management) has initiated a review of existing whale disentanglement risk assessments created by the International Whaling Commission, the National Oceanic and Atmospheric Administration (NOAA Fisheries and other competent authorities in other countries. Such risk assessments will be adapted for domestic species to suit the Canadian environment, as appropriate. This review will be completed by March 2018.
In addition, by December 31, 2018, DFO will improve the governance structure related to whale entanglement response and enhance staffing levels to complement the management of the Marine Mammal Response Program. The intent of these measures is to ensure a dedicated focus to enhancing the policy suite and management measures available to address whale issues that respond to various risk factors. This will include conducting a risk analysis of the response program components and determining the accepted best practices for disentanglement activities through the engagement of subject matter experts and the analysis of best practices from recognized expert disentanglement practitioners. This in turn will lead to policy and directives tailored to responding safely to entanglement situations involving different types of whales.
Training and supervision of the members in relation to whale disentanglement operations
In regards to responding to similar types of operations, the CLC Part II requires that the employer must provide each employee with the information, instruction, training and supervision necessary to ensure their health and safety at work. This also entails that each employee must be made aware of every known or foreseeable health or safety hazard in the area where the employee works.
Whale disentanglement operations are considered highly hazardous in nature and must be done in a very specific way. The training received by staff consisted of approaching the whale and setting up a location tracking system on the whale and then retreat to a safe zone.
Response
Through the DFO MMPR we will, through a staged approach over the next year, develop, implement and monitor a program that covers all disentanglement activities. This revamped program will be fully in place by March 31, 2019 and will include:
- Developing response protocols based on appropriate risk-based analysis
- Maintaining and developing in-house DFO expertise
- Ensuring that human safety takes top priority and that safety equipment is available
- Providing capacity building to third party responders
- Maximizing international co-operation.
Recommendation #3 (Training and supervision of the members in relation to whale disentanglement operations)
It is recommended that C&P conduct a risk assessment to determine the level of training required by the staff if they are to be involved in similar operations in the future. Due to the nature specific to each species of whale, it is recommended that the training addresses specific types of approach and response for each species.
The training should address the various components of the operations to ensure that all personnel are aware of their duties and responsibilities as well as being aware of the various hazards each task represents.
Response
C&P is implementing an enhanced Marine Mammal Response and Marine Protected Areas Surveillance and Enforcement Program. This initiative has already commenced and will strengthen DFO’s operational capacity to support expert third-party lead responders to marine mammal incidents in a safe and timely manner, including collisions, entanglements and stranding’s. The initiative is national in scope and the enhanced training, equipment and capacities will be in line with international best practices. The initiative will provide dedicated capacity building over the next five years and will continue annually.
C&P is establishing a training standard that will address the risks specific to different types of whales. The safety module of the existing training program will be updated to include a component on maneuvering a vessel around different types of entangled whales.
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