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Implementation Guidelines for the Environmental Emergency Regulations 2011

Appendix 8

Checklist to Prepare an E2 Plan

Subsections 4(2), 4(3) and 5(1)

Checklist to Prepare an E2 Plan

Subsection or paragraph of the E2 Regulations
Ask Yourself

Which substances at the facility are regulated?

  • Does this facility have any regulated substances that are not included in the facility's E2 plan?
  • Are by-products from a fire or a chemical reaction that are substances on the E2 list identified in the E2 plan?
4(3)(a)

Consideration of the following factors covered under subsection 4(2) in the facility's E2 plan

4(2)(a)

Properties and characteristics of the substance and the maximum expected quantity of the substance:

  • Is the information on the properties and the characteristics of the substances complete (e.g. pH, vapour pressure, solubility, explosiblity, flammability, toxicity, corrosivity…)?
  • Are there material safety data sheets (MSDSs) for the substances?
  • Are all MSDS sections completed?
  • Are they up to date? (max. 3 years old)
4(2)(b)

Activities for which the plan was prepared (commercial, manufacturing, processing or other):

  • Is the reason this particular substance is used on the site well described?
4(2)(c)

Possiblity that characteristics of the place where the substance is located and characteristics of the surrounding areas could increase risks to the environment or human life or health:

  • Is there a map of the property (facility) and surroundings or a complete description?
  • Is there a detailed plan of the installation or a complete description?
  • Are they up to date?
  • Are the following elements clearly indicated on the plan?
  • Emergency exits
  • Fire extinguishers
  • Location of personal protective equipment
  • Location of the dangerous substances
  • Is there a plan or procedure to segregate incompatible substances?
  • Are outside hazards and possible domino effects identified on the map?
  • Are the sensitive areas (hospitals, schools, specific flora…) identified clearly on the map?
  • Are the maps up to date?
4(2)(d)

Potential consequences of an environmental emergency and possible scenarios:

  • Has a history of internal accidents been compiled and kept up to date?
  • Has a history of external accidents in similar facilities been compiled and kept up to date?
  • Which analytical method was used to identify plausible scenarios (What if, HAZOP, fault-tree, etc.)?
  • Who did the analysis?
  • Did a multidisciplinary team participate in identifying and evaluating risks? If so, who participated (operators, chemists, engineers, etc.)?
  • Is there a process for management of change (as recommanded in PSM or in the MIARC guide)?
  • Are the employees aware of the process?
  • Is there a procedure for the investigation of accidents?
  • Is there a procedure for investigation of near-misses?
  • Who participates in these investigations?

Your worst-case scenario:

  • Is a worst-case scenario presented for each toxic substance?
  • Is a scenario presented for flammable materials?
  • Is the worst-case scenario well described?
  • Is it really the worst-case scenario? Does it respond to the definintion from the MIARC guide?
  • Which software was used to calculate impact distances (RMP*.Comp, ALOHA, PHAST, other…)?
  • Who did the modelling? Does the person have sufficient knowledge to perform it?
  • Are the results consistent with our calculations and experience?
  • Do the modelling criteria used correspond with those of the MIARC guide (worst-case conditions)?
  • Penalizing weather conditions?
  • Duration of leak? (see Table 2.4, p. 36-37 of the MIARC guide 2007)
  • Have passive and active mitigation measures been determined? If yes, which ones?
  • Is a cartographic representation of the impact areas presented?
  • Is there a legend and a scale?
  • Are the locations of sensitive human elements (schools, hospitals, seniors' residences, etc.) and environmental elements (lakes, forests, wells, etc...) that may be affected clearly shown on the map?
  • Surroundings? (urban/rural)

Alternative scenarios for toxic substances:

  • Is an alternative scenario presented for each toxic substance?
  • Is the chosen scenario truly representative for each of these substances (site visit, verification of all scenarios to determine whether the chosen one is the best)?
  • Is the justification of choices of alternative scenarios (risk evaluation: consequences × probabilities) presented?
  • Who did the analysis?
  • Was there participation of a multidisciplinary team in identifying the scenarios and risk evaluation?
  • Which software was used (RMP.Comp, ALOHA, PHAST, etc.)? Is this the best software?
  • Who did the modelling? Does the person have sufficient knowledge to perform modelling?
  • Are the results consistent with our calculations and experience?
  • Do the modelling criteria used correspond with those of MIARC? (worst-case conditions)?
  • Have passive and active mitigation measures been determined? If so, which ones? Did they were taken into account?
  • Is the predicted duration of the leak realistic?
  • Surroundings? (urban/rural)
  • Is a cartographic representation of the impact areas presented? Is there a legend and a scale?
  • Are the locations of sensitive human elements (schools, hospitals, seniors' residences, etc.) and environmental elements (lakes, forests, wells, etc...) that may be affected clearly shown on the map?

Alternative scenarios for flammable substances:

  • Are the locations of sensitive human elements (schools, hospitals, seniors' residences, etc.) and environmental elements (lakes, forests, wells, etc...) that may be affected clearly shown on the map?
  • Is a cartographic representation of the impact areas presented?
  • Is there a legend and a scale?
4(3)(b)

Identification of any environmental emergency and identification of the harm and danger

  • Have you identified all environmental emergencies that can reasonably be expected to occur at the place and that would likely cause harm to the environment or constitute a danger to human life or health?
  • Have you identified all the harm and danger?
4(3)(c)

Measures described for every environmental emergency mentioned in 4(3)(b)

Prevention:

Mitigation measures

  • Is there a fire protection system?
  • Is it verified regularly?

Safety Preventive Barriers (examples)

  • Is there a regular maintenance program in place?
  • Is there a preventive maintenance program?
  • Do the maintenance programs reflect the manufacturers' recommendations?
  • Are the employees trained?
  • Detectors with alarms? (i.e. high-level alarms)
  • Are there automatic valves and interlock systems?
  • Are equipment and lines clearly identified (color code / ID tags)?
  • Others?

Safety Protective Barriers (examples)

  • Safety wall
  • Retention basin (good size, watertight, capacity, etc.)
  • Sprinklers, deluge system
  • Drills (testing of E2 plan)
  • Evacuation procedure
  • Others?
  • Redundancy, quality
  • Are barriers verified?
  • How often?
  • Have they been used when incidents have occurred?
  • Were they effective?

Preparation (EEP, training, exercises):

Preparation and notification measures

  • How are employees notified of a leak or other incident?
  • Do they know what the procedure is?
  • Do they understand the procedure?
  • Are there written procedures for
    • the use of the various barriers?
    • the hazards of the material and substances on the site?
    • the processes?
  • Is there a mutual aid agreement?

Response (internal procedure):

  • Is there a telephone list with government agencies that must be notified of an emergency? Is Environment Canada's number listed?
  • Is there an internal emergency response team?
  • Is the team adequately trained?
  • If there is no internal team, is there an agreement with a third party to respond in hazmat situations?
  • Have the third party's capabilities been evaluated? How?
  • Is the response path clearly explained?
  • Is there a response diagram?
  • Is there someone responsible for managing security and site access during an emergency?
  • Is there an investigation following an incident?
  • Are there recommendations?
  • Are they implemented?

Restoration or recovery:

  • Is there a procedure?
  • Does the company have the necessary resources?
  • If not, has it made provisions with a partner?
  • Have the partner's qualifications and abilities been assessed? How?
  • Are the planned measures suited to the location?
  • Are they appropriate with regard to the consequences?
4(3)(d)

List of the individuals who are to implement the plan in the event of an EE and description of their roles and responsibilities

  • Is there a list of the individuals who are to implement the plan in the event of an EE?
  • Is there a description of their roles and responsibilities?
  • Are the people listed aware that they are on the list?
  • Do these people know what their roles and responsibilities are?
  • Are the descriptions of the roles and responsibilities clear and complete?
  • Is there a chart or a table?
4(3)(e)

Identification of the training required for each of the individuals listed under paragraph 4(2)(d)

  • Is there the identification of the training required for each of the individuals listed under paragraph 4(2)(d)?
  • Is the training given appropriate and in relation to the roles and responsibilities?
  • Have the instructors' qualifications and abilities been verified? How?
  • Are the employees satisfied?
  • Has training on personal protective equipment been given?
  • Does it cover the following:
    • use?
    • maintenance?
  • Has training on the detection equipment been given?
  • Does it cover the following:
    • use, interpretation of the results?
    • maintenance / calibration?
  • Has training on hazardous materials been given? (WHMIS)
  • Have the employees understood and absorbed it? (test/exam)
4(3)(f)

Emergency response equipment and location of the equipment

  • Is a list of the emergency response equipment included?
  • Is the location of the equipment indicated?
  • Are the locations of the response equipment shown on the plan of the plant?
  • Does this equipment seem to be in good condition?
  • Is it sufficient and appropriate?
  • Does the regular and preventive maintenance program respect the manufacturers' recommendations?
  • Are the personnel qualified to maintain this equipment?
  • Are the personnel qualified to do the calibration?
4(3)(g)

Measures to be taken to notify members of the public

  • What are the measures? (see the MIARC guide 2007, Chapter 8)
  • Before? (e.g. participation in a joint coordinating committee, information session, posters, information bulletin….)
  • During? (e.g. siren, phone etc. )
  • After? (e.g. press review, public meeting…)
  • How effective are they?
  • Have they been tested on a regular basis? If so,
    • when?
    • by whom?
  • Is the public aware of this?
  • Is there a risk communication program for the public?
  • Does the company participate in a local emergency preparedness committee (LEPC) that includes municipality, industry and government representatives, and citizens?
5(1)

Implementation and testing the plan

  • Exercises
  • Is there a program of exercises, as stipulated in the guidelines or the MIARC guide?
  • The exercise program is over a period of how many years?
  • Does the level of difficulty increase as the program progresses?
  • What kinds of exercises are carried out?
  • Do the exercises reflect the facility's reality?
  • Are the partners involved?
    • If yes, who are they?
  • Is an analysis report written?
  • Does it include recommendations?
  • Are the recommendations implemented?
  • How is the logic of the emergency plan presented? Is it easy to follow and find information?
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