Opening Statement to the Standing Committee on Environment and Sustainable Development

Follow-up of Recommendations in Previous Reports
National Defence—Hazardous Materials: Managing Risks to Employees and the Environment – 1999, Chapter 13
(Chapter 12 - December 2001 Report of the Auditor General)

Mr. Chairman, thank you for inviting us to discuss the follow-up of our 1999 audit of the way National Defence managed risks to employees and the environment caused by hazardous materials. This follow-up appeared in Chapter 12 of our Report tabled last December. I am here today with Peter Kasurak, the Principal responsible for the audit, and Ray Kunce, the environmental audit specialist who did much of the work.

Background

In 1999 we examined how National Defence managed hazardous materials such as flammable substances, corrosive products, and ammunition. The Department used over 6,000 hazardous products and estimated that at least a quarter of its 80,700 full-time employees came into frequent contact with hazardous chemicals.

Although departmental policies, plans, and procedures at the national level indicated an awareness of the legal framework and best practices for hazardous materials management, implementation at the base and unit levels was inconsistent. We found shortcomings in compliance with laws and regulations, in application of audit protocols and methodologies, and in application of compliance management systems aimed at promoting continual improvement.

When our audit was tabled in 1999, the Department responded positively to our recommendations and indicated that it would take action to address the concerns raised in our audit. We have distributed to committee members a copy of the recommendations contained in the December 1999 Report.

Follow-up findings

We conducted a follow-up of this audit last year. We found that the Department had developed action plans to address our recommendations and had made some progress. However, it had carried out few recommendations fully and had revised and extended many of the completion dates for its action plans.

Since that time there has been additional slippage. Also, we have several concerns about the Department's response to our follow-up.

I would like to draw the Committee's attention to the Department's actions on three main issues in our audit:

• improving safety for employees who handle hazardous material,
• preventing damage to the environment from the use of hazardous materials and
• putting in place a management system that supports continuous improvement in employee and environmental protection.

Improving safety for employees

The 1999 audit found that the Workplace Hazardous Materials Information System (WHMIS) was not fully in place in the 10 bases and wings that we audited. This national system identifies hazardous materials through labels and signs, makes safety data available in the workplace, and ensures that workers receive appropriate training. We found continuing problems with labelling, materiel safety data sheets were missing, and 45 percent of staff handling hazardous materials lacked appropriate training.

The 2001 follow-up found that the Department had developed a Web-based system that contains current material safety data sheets and also provides reference information. However, the Department is determining requirements and continuing to develop the system.

The Department will offer better training by this July. The Committee may wish to ask the Department about progress in training staff who need it and any change in the proportion of trained staff from the 42 percent we found in our 1999 audit.

Preventing damage to the environment

The 10 bases that we audited did not periodically monitor their air or liquid effluent emissions for all hazardous material contaminants on which limits were set by federal laws or guidelines. While the federal government is not bound by provincial or municipal laws, the Department's policy was that it would follow these standards "where applicable." What this meant, however, had never been defined.

In 2001 we reported that the Department had committed itself to issuing national guidance on liquid effluent monitoring, developing and carrying out an effluent monitoring plan for storm sewers, and periodically testing discharges to municipal sewers. Monitoring at some locations was funded through a corporate account that was due to run out this year. This situation could put this program at risk.

The Department does not expect to have a national air emissions strategy until March 2003. It has received a legal opinion on defining when it should apply provincial and municipal regulations and standards. However, the Department does not expect to issue its own policy until sometime this year.

Continuous improvement

The audit found many gaps in compliance with existing regulations for the management of hazardous materials. We believe that compliance monitoring is an essential part of a continuous feedback and improvement system. Bases should have objectives for compliance and should know how well they are doing. They should monitor shortfalls and try to improve.

The Department has taken some steps in this regard, but progress is slow:

• Goals and objectives against which to monitor at all bases and wings are not expected to be in place and reviewed before 31 March 2004.
• The Department's audit and inspection plan is not fully in place.
• The Department intends to rely on reviewing capacity to meet commitments. It is unclear how this will show the level of actual compliance.

In short, it will have taken at least five years after the audit to run a system supporting continuous improvement.

Conclusion

Our follow-up and tracking shows that environmental specialists in the Department have been steadily—if not quickly—building the necessary tools to better manage hazardous materials. It would be very useful to have better information on the achieved results in complying with workplace standards.

The Committee may wish to ask the Department these questions:

• what is its rate of progress?
• how will the armed services replace central funding?
• how will the Department complete a management system to support continuous improvement?

Thank you, Mr. Chairman. We would be pleased to respond to any questions.