13.11 Federal laws govern labelling, safety instructions, training, protective devices, emergency response procedures, transportation documents, packaging, releases into the environment, storage, explosives and radioactive materials. Provincial laws parallel many of the federal laws but also govern outdoor air quality, transportation of hazardous materials within a province and disposal of hazardous wastes. Municipal by-laws regulate discharges of liquid effluent to sanitary and storm sewer systems. All of these laws establish a number of mechanisms to ensure the protection of workers and the environment.
13.12 The Workplace Hazardous Materials Information System (WHMIS) is a national information system designed to protect Canadian workers. It is a systematic approach to identifying the hazards of a material, making safety data on the material available in the workplace and ensuring that workers receive appropriate training. The system groups materials into classifications based on their hazardous characteristics, and uses a set of symbols to identify the main classes. WHMIS consists of three components:
13.14 In addition to classification and symbols under WHMIS, the Transportation of Dangerous Goods Act establishes a second system of classification and symbols for transportation and storage. The classifications in the two systems are similar though not identical, and the symbols are entirely different. The symbols of both systems are often used together on a product.
13.15 Proper storage is essential to protect workers and ensure that hazardous materials do not escape into the environment. Ideally, their storage should be apart from other materials, have limited access and meet recognized standards. Depending on the material, storage facilities may be designed to withstand fires or explosions or to contain spilled material. They may be heated and ventilated, and equipped with particular types of emergency systems such as vapour detectors, sprinklers and explosion-proof lighting. Limits on the size and storage capacity of facilities depend on the nature of the material. Because many hazardous materials react when they come into contact with each other and produce an explosion, fire or toxic gas, there are various tables and compatibility charts to guide workers in identifying incompatible products so they can be stored separately.
13.16 Some types of activities and facilities require licences or permits - for example, air emissions, storage of radioactive materials and ammunition, and facilities that generate hazardous waste. A licence or permit may provide standards against which to check quantities and activities, or may require tracking of activity over time.
13.17 For many hazardous materials, there are legal limits on the quantities to which workers can be exposed or that can be released into the environment. A worker's exposure to hazardous materials can be measured by requiring periodic medical checks, conducting air quality or swipe tests of the workplace, or providing radiation workers with dosimeters. (Our audit of the Department's measuring of workers' exposure was limited to observing some respiratory protection practices at bases.)
13.18 Where their exposure levels could exceed allowable limits, and other means to eliminate the hazard are unavailable or ineffective, workers must be provided with personal protective equipment, properly fitted, and be trained in its use. We did not audit the availability or appropriateness of protective equipment at National Defence facilities.
13.19 Releases into the environment through air emissions, sewage or stormwater also can be measured periodically to establish that legal limits on concentrations of hazardous materials are not exceeded.
13.20 Emergency response equipment and trained emergency response personnel are to be available to limit injuries and prevent the further escape of material into the environment. We did not audit the availability of emergency response capabilities at National Defence.
13.22 The Department uses more than 6,000 hazardous products. Exhibit 13.1 illustrates typical activities at a Canadian Forces base, and examples of the types of hazardous materials that are used.
13.23 According to estimates by the Department, at least one quarter of its 80,700 full-time employees come into frequent contact with hazardous chemical products in the workplace. In addition to those are 293 military and civilian ammunition technicians who have frequent contact with ammunition; and 1,132 employees who wear dosimeters because they work with the more radioactive materials in the Department's inventory. Many contractors also come into contact with hazardous materials on departmental property, and so may the 29,400 reservists in the course of their part-time duties.
13.24 The Department estimates that every worker, like many in light industrial facilities and offices, comes into some contact with hazardous materials during the course of the day. Soldiers may work with ammunition or cleaning solvents for weapons. Even office workers may use cleaning supplies or toner for photocopiers and printers. (see photograph)
13.26 It is the Department's policy that its hazardous materials management activities "must meet or exceed the letter and spirit of all applicable federal acts, regulations, policy and guidelines and, where appropriate, be compatible with provincial acts, regulations and guidelines and municipal and international standards." National Defence has not defined what it means by "where appropriate", and as a result it is not clear in what circumstances the Department's actions will be compatible with provincial, municipal or international laws and standards. For example, the Department conforms to provincial regulations on hazardous waste generation, and recently made a commitment to be compatible with the applicable standards in provincial and municipal laws governing sewage treatment plant and stormwater discharges. However, the Department has made no commitments to meet provincial laws governing air quality and permits for potentially contaminated air emissions, nor to meet the mainly municipal laws governing sanitary sewer discharges to municipal systems.
13.31 Information on contamination is more problematic. While the Department requires the reporting of hazardous material spills, until this year (1999) some discretion in reporting was allowed; moreover, the information was entered into databases that are not compatible. Spills considered "significant incidents" were reported to National Defence headquarters; 58 such spills were reported in 1998, ranging from half a litre to 17,500 litres. The Department recently issued a spill reporting directive and developed a spill reporting computer program, which may address the concerns about inconsistent reporting requirements and incompatible databases.
13.32 Environmental baseline studies and subsequent assessments conducted at all Canadian Forces bases since the mid-1980s have identified significant contamination caused by hazardous material use and accidents. National Defence has developed a database to track its contaminated sites, many of which it believes were contaminated by leaking underground storage tanks or by technology and management practices used in the past. Remediation and monitoring costs are borne by National Defence headquarters for sites contaminated before 1993, and by bases for their sites contaminated since then. The contaminated sites database lists 530 sites on the 10 bases we audited, and headquarters expects to spend $17.3 million on them over the next five years. While it is likely that most of the sites were contaminated before 1993, the database does not identify when the contamination occurred. We did not audit the management and remediation of sites where soil and groundwater contamination have been identified.
13.33 As well as clean-up costs, financial liabilities from claims, fines or prosecutions can result from failure to implement legally required protective mechanisms. To date, the Department has pleaded guilty twice for violations of the Fisheries Act, and has been ordered to pay $42,021.
13.35 Given these efforts, we attempted to assemble an overall picture of compliance with hazardous materials laws and policies at the 10 bases we audited. We examined the reports of all external and departmental audits and inspections conducted from 1993 to 1998 in order to identify instances of non-compliance. We also conducted audits of compliance at three bases: Cold Lake, Gagetown and Halifax. Finally, we examined all the reports on Safety Program Development and Evaluation Technique (SPDET) assessments conducted from 1993 to 1998. These are self-evaluations conducted by units and bases; they provide a rating out of 100 points for each of 16 components of an organization's safety program. The technique includes a section specifically on hazardous materials safety, but several other sections also contain relevant elements.
13.36 We found that many different types of departmental inspections have been conducted at the 10 bases, generally reflecting the different responsibility areas of the base safety and environment officers. Inspection frequency has varied widely, though it has generally increased in the last two years. Inspections of National Defence facilities by other federal departments responsible for enforcing hazardous materials laws are also uneven in frequency and coverage. We found that inspection methods were rarely similar across a base, or at the same unit for two or more years.
13.37 Because of the variety of inspection methods and the gaps in coverage, the inspection data cannot be aggregated to provide performance information on trends or the overall state of compliance, at individual bases over time or across bases. The data indicate, however, that from 1993 to 1998 there were more than:
13.39 Complying with legal and policy requirements ensures that the minimum standards or risk levels established by regulatory authorities or the Department are met. The degree to which a failure to comply with legal and policy requirements increases the risk inherent in the use of hazardous materials is very dependent on the circumstances. A relatively minor oversight, especially if combined with others, can lead to a serious accident. Examples can be found in the Department's widely distributed safety publications. While individual instances listed in the Department's audit and inspection reports may have been corrected, we found that certain problems seem to recur over time and across bases (see Exhibit 13.3).
13.40 We observed the common compliance failures listed in Exhibit 13.3, as well as several others, during our audits of Canadian Forces bases at Halifax, Gagetown and Cold Lake. There was a noticeable difference among the three bases in the general levels of management and compliance. We consider Halifax to be in the best state of compliance, with Gagetown next; Cold Lake faces significant compliance and risk issues. A general summary of what we found at the three bases is provided in Exhibit 13.4.
13.41 The frequency of Safety Program Development and Evaluation Technique assessments is also uneven. None had been conducted at two of the bases in our sample, and the number conducted each year at the remaining eight facilities varied widely. There is no obvious trend in the results (see Exhibit 13.5), but the average ratings achieved in the SPDETs appear quite high; the Department considers that any rating of 75 percent or higher is acceptable. We question whether a rating of 75 percent for handling hazardous materials can be considered acceptable: 90 percent of the points in SPDET assessments are for meeting legal requirements designed to protect the health and safety of workers. Moreover, as self-assessments, the SPDETs may contain a bias toward positive results. We note in particular the contrast between the situation we observed at Cold Lake during our audit and the high average rating of 94 percent achieved in SPDETs conducted there in 1998.
13.42 A department-wide internal audit of hazardous materials management was conducted in 1991-93. The audit included site visits at four Canadian Forces Supply Depots and their support bases, two of which were also in our audit sample. The internal audit observations were similar to our own in a number of compliance areas, particularly inventory information and the use of WHMIS. We concluded that in the last six years, compliance in these areas has shown little or no improvement.
13.44 Even weaker is the implementation of the second WHMIS component, the availability of up-to-date material safety data sheets for all hazardous materials used. Departmental inspections that included WHMIS found deficient MSDS at every base in every year for which data were available, except the base at Wainwright in 1998. There were 76 instances of deficient MSDS reported at the nine other bases in 1998. Our three in-depth base audits found hazardous products base-wide whose data sheets were unavailable or out-of-date.
13.45 We distributed a questionnaire to collect data on a sample of hazardous chemical products recorded on inventory lists at the 10 bases in our audit. Sample selection focussed on locally procured items, though some of the responses indicated that the selected item had been obtained through the national system. Further details about the sample selection process and response rates can be found in the section About the Audit. Of the 607 responses in our sample, only 28 percent had an up-to-date MSDS. We noted three types of deficiency:
13.47 The devolution of responsibility for the purchase and management of hazardous materials in the Department has made it a laborious process to keep MSDS up-to-date. This is because different products may be in each of the widely scattered inventories of hazardous materials at departmental facilities, and the age of the MSDS for each product must be tracked and a new one obtained periodically. Information technology increasingly offers a solution to this problem, provided the available information meets Canadian legal requirements. Many MSDS are now available directly on the Internet. More can be found on commercially available CD-ROMs, and making these accessible through internal computer networks can expand their distribution.
13.48 The Department has been developing its own hazardous materials information system to include electronic versions of MSDS. The Hazardous Materials Information Query, or Hi-Q, has been under development since 1996 but responsible authorities at several bases indicated that they have had problems getting the system to work. However, version 3.0 (distributed in early 1999) may address some of these concerns. Initially, it was available only as a stand-alone system on CD-ROM, but Hi-Q has since been integrated with the Materiel Information Management System that is used mainly at base supply sections and headquarters.
13.49 Making Hi-Q more widely accessible will not alone resolve the problem of MSDS availability. When we compared MSDS on the Hi-Q CD-ROM with the 607 questionnaire responses on our product sample, we found up-to-date data sheets for only 41 percent of the responses (although some did not identify the product clearly enough to be sure it was the product on the disk). With Hi-Q in place, more MSDS on our sample items should now be available, but that will depend on access to Hi-Q information at the work site. Responsible authorities in the workplace will have to supplement Hi-Q with other sources of MSDS information, as they do now. We found, for example, that Hi-Q did not include 74 percent of the up-to-date MSDS we obtained on our sample.
13.50 The Department should ensure that responsible authorities at National Defence workplaces meet the requirement to make available hazardous materials safety and environmental information, particularly material safety data sheets.
Department's response: The Department is committed to rectifying situations where it is out of compliance with the requirements of the Workplace Hazardous Materials Information System. Accordingly, the Department will review and revise its standard operating procedures at all levels so that Material Safety Data Sheets (MSDS) accompany new products introduced into the Canadian Forces Supply System and introduced at Bases and Wings. The Department will establish a system to track the effective dates of MSDS and will review and revise its standard operating procedures to ensure that all data sheets are kept current. The revised standard operating procedures will define the responsibilities and the accountability of all personnel involved in these processes and will also address the issue of local procurement.
13.52 The departmental records available indicate that 205 of the employees in our sample, or 45 percent, did not have any WHMIS training. This compares with the 1993 internal audit, which found that 42 percent of a sample of 1,783 personnel had not received training.
13.53 Of the 249 workers in our sample who had received training, 28 had no record of it on their files. We found the information in other sources, such as safety officers' databases.
13.54 We also found poor record keeping on specific training in packaging, storage and handling, and transportation of hazardous materials. These courses are required only for personnel who work extensively with hazardous materials, such as supply technicians. A certificate is issued to each trained worker and it must be renewed every one to three years, depending on the qualification. Expired certificates must be kept on file for at least two years. Of the 32 workers in our sample who required some type of training in the packaging, storage and handling or transportation of dangerous goods, only 21 had a current recertification. Seven had been employed for several years before they received their first training. Few certificates, current or expired, were kept on file.
13.55 Appropriate and up-to-date records of training in hazardous materials are important because, first, they are required by law and by the Department's policy. Second, they also ensure that training can be delivered efficiently: personnel could be overtrained or undertrained if no records exist to show when their training is to be updated. This is particularly important in an organization like National Defence, with a significant proportion of personnel moving frequently from one job to another.
13.57 We requested copies of all inventory lists of hazardous materials at the 10 bases we examined. In spite of the fact that the Department's hazardous materials safety manual provides clear guidance and examples showing how to prepare inventory lists, there was little uniformity in the documents we received. They ranged from handwritten lists of chemical products, with incomplete identification and no indication of quantities, to computerized base-wide inventories with detailed product information, container sizes, quantities and storage limits, locations, points of contact and availability of MSDS. (see insert)
13.58 Again, information systems technology, including commercially available database applications, would seem to offer a solution. This has been recognized at National Defence headquarters and at three of the bases in our sample; however, each has developed its own system. This has resulted in duplication of effort and wide variations in the type of information available.
13.59 The Department should ensure that hazardous materials inventory systems are implemented and that they contain standard information.
Department's response: The Department will define and issue minimum information requirements to be included in Base- and Wing-level hazardous materials inventory systems.
13.60 Responses we obtained on our hazardous products sample also revealed that inventory lists were not up-to-date. A total of 17 percent of items on which we received a response could not be found, had never been used by the unit, or were no longer used. In a number of cases, units reported having disposed of the product once our request had alerted them to the fact that they had it in inventory.
13.61 We noted that many of the locally procured products were purchased more than one year ago. In several cases, we found more of the product in inventory than had been purchased; in other cases, the full amount purchased was still in inventory more than one year later. Both circumstances suggest that material had been purchased unnecessarily or in excessive quantities.
13.66 The provinces set limits on the concentration of pollutants in the air, and provincial laws require that approvals be obtained for all sources likely to affect ambient (surrounding) air quality. The approvals list on a case-by-case basis the monitoring or other action required to ensure that the concentration limits are not exceeded. Because federal facilities are not subject to provincial laws, National Defence does not apply for provincial permits. Nonetheless, Cold Lake, Trenton, Halifax, Bagotville and Montreal monitor for at least one pollutant whose concentration is limited by provincial law. No base indicated that it monitored paint booth emissions, though Borden did indicate that contractors regularly verify the efficiency of its paint booths.
13.69 To meet the target for sewage treatment plants, the Department is committed to completing a Sewage Treatment Plant Optimization Program at its six plants by 2001. Under the program, each plant's physical design and operating procedures are analyzed during an initial comprehensive performance evaluation. Then, with the assistance of sewage treatment experts, the design and operating procedures are changed during a comprehensive technical assistance phase to make the existing plant work at optimum performance.
13.70 The initial evaluation by National Defence of all six departmental sewage treatment plants found that they did not comply with the applicable legislation or departmental policy on effluent quality. Most often the causes of non-compliance were not the design of the facility but its administration and operation. At the time of our audit, changes proposed during the comprehensive technical assistance (CTA) phase were completed at two plants, Borden and Trenton, at a cost of approximately $350,000 each. By the end of the CTA, both met the applicable standards. Earlier studies by outside consultants had suggested that Borden would have to build an entirely new facility at an estimated cost of $7.6 million and Trenton would have to spend an estimated $2.8 million on upgrades to bring the plants into compliance. The optimization program appears to deliver significant savings over these earlier cost estimates.
13.72 Sewage that leaves National Defence facilities for treatment at municipal sewage treatment plants is not subjected to regular testing for all contaminants limited by applicable standards. Of the six bases we examined that discharge sewage to municipal facilities, two (Edmonton and Wainwright) do no testing. Montreal has conducted one-time risk assessment tests, which failed to meet applicable standards in several respects. Esquimalt and Halifax regularly test sewage effluent from areas they consider to be high risks. Only Bagotville regularly tests its sewage effluent, but not for all contaminants on which limits are set (see Exhibit 13.7). Municipal laws, with which the Department does not have to comply, generally set limits on a wider range of contaminants. Of the bases in our sample that do monitor their effluent, all monitor for contaminants beyond those included in the federal guidelines. However, few of them monitor for all contaminants on which limits are set in local laws.
13.73 As is the norm elsewhere, storm sewers at departmental facilities are generally not treated. At the time of our audit, effluent leaving National Defence facilities in storm sewers was subjected to varying degrees of testing (see Exhibit 13.8). In addition to federal and municipal laws and guidelines, the Air force has an effluent monitoring guide that requires its facilities to test their storm sewer effluent. The three Air force facilities we audited monitor storm sewers regularly, though not for all contaminants limited by applicable standards. Bagotville and Cold Lake have found that their effluent regularly fails to meet the standards set out by the Air Command Effluent Monitoring Manual or other applicable laws and guidelines. Of the other commands, Borden, Edmonton and Wainwright do not test storm sewers at all. Montreal and Gagetown each recently conducted a one-time risk assessment study and failed to meet applicable standards for several pollutants. Esquimalt and Halifax test their storm sewer effluent regularly, but Esquimalt does not test for all regulated contaminants.
13.74 Base staff at Wainwright and consultants engaged by Edmonton and Gagetown have recommended that the regular testing of storm or sanitary sewer effluent be increased. This is both to ensure compliance with applicable laws and policies and, where there is a non-compliant emission, to identify the source.
13.75 National Defence should conduct an assessment of all liquid effluent and air emissions at its bases to ensure that the environment is not being contaminated by hazardous materials. The assessment should be repeated periodically, particularly when there are major changes to the base configuration or activities.
Department's response: The Department's Sustainable Development Strategy includes commitments for storm water and sanitary effluents. The actions associated with these commitments will be reviewed and revised as required. Similar action plans will be developed for air emissions. The Department undertakes to review and revise its existing effluent monitoring protocols as required and to develop monitoring protocols for air emissions that conform to current federal regulations and guidelines. The Department will continue to participate in the interdepartmental sub-working group that is addressing effluent discharges from federal facilities. This sub-working group was established under the Federal Committee on Environmental Management Systems (FCEMS), which has a mandate to identify and resolve environmental issues common to all federal departments. The Department will make a formal request to the FCEMS to investigate whether a gap exists with respect to air emissions and whether this gap should be addressed by FCEMS at the national level.
13.77 Accelerated Reduction/Elimination of Toxics is a voluntary program under which emissions of 117 toxic substances are to be reported and reduced. Because the Department's procurement and use of hazardous materials is decentralized, National Defence is not able to report on uses or emissions. Instead, it has reduced the range of products it uses that contain the targeted toxic substances. By October 1998, the Department had eliminated from use more than 70 percent of the nearly 700 NATO stock number items it had identified as containing the substances.
13.78 National Defence has also committed to reducing its emissions of dichloromethane, used in stripping aircraft paint. The commitment is made under the Strategic Options Process that entails developing mechanisms ("options") for reducing or eliminating chemicals declared toxic under the Canadian Environmental Protection Act. Air force wings have been directed to implement the dichloromethane management plan.
13.80 In the environmental field, the International Organization for Standardization's (ISO) 14000 series is emerging as the voluntary standard for management systems. National Defence has made a commitment to implement environmental management systems that are compatible with this standard.
13.81 We used selected elements from the ISO 14004 standards of Environmental Management Systems Principles (see Appendix) to evaluate the systems the Department uses to ensure compliance with the legal and policy requirements governing hazardous materials. We did not audit the entire environmental management system at any level in the Department.
13.83 The DAOD on management of hazardous materials commits the Department to reduce their use, avoid or minimize the creation of pollutants and wastes, and limit storage to the quantities needed for operational requirements. Similarly, the draft DAOD on nuclear safety commits the Department to protect the environment and minimize human exposure to ionizing radiation. More broadly, several statements in the sustainable development strategy, and particularly the targets established for hazardous materials, commit the Department to continually reduce the amounts of material used and their potential for entering the environment. However, as explained in paragraph 13.26, the Department's policy statements on hazardous materials management include a commitment to meet or exceed applicable federal legal and policy requirements, but be compatible with provincial, municipal and international requirements only "where appropriate".
13.84 As well, the DAOD on hazardous materials management does not define the responsibility and accountability of every organization involved. It does define the responsibilities of various line authorities, including users and their supervisors, as well as material technical authorities and hazardous material control authorities. However, unlike the draft DAODs on ammunition and radioactive material, it does not define the responsibilities of functional experts at headquarters, such as the Director Supply or Director General Environment. Lists of responsibilities can be found in some of the hazardous materials manuals, but they are not necessarily authoritative, complete, or up-to-date.
13.85 National Defence should define the circumstances in which it will apply provincial and municipal laws relevant to hazardous materials management, and should specify the standards that it accepts.
Department's response: In accordance with the environmental management system adopted by National Defence, the Department is required to review environmental legislative and regulatory requirements associated with site- and event-specific activities. Based on these assessments, Bases and Wings will update their environmental management systems to reflect the provincial and municipal regulations and policies that are applicable to their location.
13.86 The responsibility and accountability of National Defence headquarters organizations involved in the management of hazardous materials should be defined, documented and kept up-to-date.
Department's response: The Department will review and revise its internal policy on hazardous materials management to include the responsibilities and the accountability of functional experts involved in the management of hazardous materials.
13.88 In his May 1998 Report to the House of Commons, the Commissioner of the Environment and Sustainable Development reviewed the sustainable development strategies tabled on behalf of 28 federal organizations in December 1997. The review essentially asked whether the sustainable development strategies included all the components required by the Auditor General Act and A Guide to Green Government . The Commissioner concluded that in preparing its strategy, National Defence did what it had been asked to do.
13.89 In accordance with the ISO requirement to define, document and update operational processes and procedures, a series of top-level departmental manuals provide general guidance and some additional policy requirements in the following areas:
13.93 Since the Land and the Maritime environmental audit programs were less than three years old at the time of our audit, not all bases had been audited yet. However, their audit cycles were on schedule and all audits planned to date had been carried out. The initial audit plan for the Air force was incomplete since only 7 of the 11 wings would be audited between 1997, when the revised audit protocol was issued, and 1999. The plan has since been revised to visit all wings between 1998 and 2000.
13.94 The inspection program for licensed radioactive material facilities requires biennial inspections by the Director General Nuclear Safety. Inspection programs for ammunition facilities require annual inspections either by the Director Ammunition Program Management or a qualified explosives inspector from the Chiefs of Staff. Checklists are used for these inspections.
13.95 Both the ammunition and the radioactive material inspection programs have experienced problems due to a lack of resources. In 1998, ammunition storage was not inspected at 8 out of 40 facilities. Additional inspectors have since been hired in an effort to close the gap. The radioactive material inspection process faces greater difficulty. In 1997 and 1998, only 65 percent of the 425 licensed units were inspected. Moreover, the 1999-2004 Business Plan for the Infrastructure and Environment group in National Defence headquarters has identified a long-term inability to oversee the radiation safety program and nuclear safety compliance. Additional resources have been requested to close this gap.
13.96 We did not audit the quality of the audit protocols or the audit and inspection reports. However, we did note that the protocols are all different. As a result, it is not possible to consolidate the audit and inspection findings to produce meaningful performance information on the Department as a whole.
13.97 Moreover, there are significant gaps in the audit programs. The headquarters groups responsible for personnel and materiel management command several field units, including Canadian Forces Base Borden, Canadian Forces Supply Depots at Edmonton and Montreal, and 202 Workshop in Montreal. None of these facilities is subjected to regular external environmental audit that would include assessing hazardous materials compliance.
13.99 The strategy's compliance targets cover only fuel storage tanks, sewage treatment plant discharges, and storm sewer effluent. As we have noted, our audit revealed compliance problems covering many more aspects of hazardous materials management at National Defence facilities. As the Commissioner noted in his 1998 Report, "Environmental performance that is measured, managed and rewarded continually improves." We believe that establishing performance measures and targets for a broader range of compliance requirements and reporting on them annually to Parliament would provide an incentive to improve the current state of compliance.
13.100 Since publication of the Department's sustainable development strategy, the interdepartmental Committee on Performance Measurement for Sustainable Government Operations developed draft indicators for government-wide reporting. The Committee, which includes representatives from National Defence, was formed in 1997 to focus on how to build environmental performance reporting systems. Two of the four hazardous materials performance indicators proposed by the Committee focus on compliance (see Exhibit 13.9). Using performance indicators to measure compliance for more aspects of hazardous materials management in the next revision of the Department's sustainable development strategy could therefore contribute to the development of government-wide reporting. As the Commissioner of the Environment has suggested, using consistent measures could allow departments to build on each other's experience and information, and to realize economies of scale in developing information systems.
13.101 Measures of compliance might also be an effective way to incorporate radioactive materials and ammunition into the hazardous materials component of National Defence's sustainable development strategy. The Department currently holds an inventory of ammunition worth more than $3.5 billion, and over 130,000 items of equipment with a total value of more than $200 million that contain controlled amounts of radioactive material. We believe that inventories as large and as hazardous as these cannot be excluded from the sustainable development strategy's performance reporting on hazardous materials. Because ammunition and radioactive materials are operational necessities, environmental performance measures for them need to demonstrate continual improvement in their safe management rather than reductions in their use. Reporting in these areas should be able to make use of the existing facility inspection programs and analyses, as well as existing processes for accident and incident reporting and analysis.
13.102 In the revision of its sustainable development strategy due in 2000, National Defence should provide performance indicators for hazardous materials compliance. The indicators should measure continual improvement toward a target of full compliance, contribute to government-wide reporting, and include ammunition and radioactive material.
Department's response: In the revision of its Sustainable Development Strategy due in 2000, the Department will include appropriate performance indicators for hazardous materials by:
Department's response: The Department will review and revise current audit and inspection programs, as required, so that protocols used at all levels include core requirements that must be examined during audits and inspections. The Department will also establish guidelines for the frequency of these audits and inspections of its facilities and units.
13.105 Given the short period of time between the tabling of the strategy in December 1997 and the March 1998 cut-off date for the first progress reports, we recognize that the Department might not have been able to report on all its targets. In particular, in December 1997 there were no precise definitions and information mechanisms for the targets of reducing the use of high-risk hazardous materials and showing downward trends in reportable spills and hazardous waste sent for disposal. Since then, the Department has defined terms and developed reporting mechanisms. However, because existing data on hazardous waste and reportable spills are not consistent, baselines will not be established until the new system contains data for a full year (March 2000). Information for a second year will be required before the system can provide the first indication of whether the downward trend targets are being met. Therefore, meaningful information on progress toward two of the hazardous materials targets will not be available before the Department's fall 2001 Performance Report.
13.108 Very few of the compliance management components fully met the ISO 14004 criteria. The main exception was the requirement for an initial environmental review, which was met in most cases by the environmental baseline studies conducted at all bases starting in the mid-1980s. Department-wide, some two thirds of the recommendations from those studies were related to hazardous materials.
13.109 The key weakness in compliance management is the failure to regard it as a continual improvement feedback system. While most bases evaluate compliance to some degree, there are no established objectives and targets, and therefore no plan for achieving any.
13.110 Bases have no performance measures for compliance. We have already noted that base-level audit and inspection programs are highly fragmentary. Moreover, the structure for compliance management is not reviewed to determine whether it is effective and to examine the root causes of problems. In these circumstances, it is not surprising that bases repeatedly display the same problems.
13.111 Although difficult to measure, factors contributing to compliance management problems include the many pressures that the Department and its managers have faced in the last five or more years. Budgets have been cut and devolved, requiring managers to learn new skills. Units have moved; bases have been closed and others restructured, requiring that new procedures be established. Personnel levels have fallen, reducing the reservoir of functional expertise. Particularly at the unit level, the jobs of environment officer or hazardous materials co-ordinator are assigned as secondary duties, perhaps added to other secondary duties, while pay has been frozen for years at a stretch. In such an atmosphere, leadership is vitally important in setting goals, providing direction, and following up to ensure that the goals and direction are carried out.
13.112 The potential impact of an effective compliance management system is indicated by the fact that, at the three bases we audited in more detail, we found that the more complete the system, the better the overall state of compliance. Better management systems will protect workers and the environment better.
13.113 National Defence headquarters has begun to provide guidance to bases and units on developing ISO 14000-compatible environmental management systems. If successfully implemented, the systems should begin to address the many weaknesses in compliance management at the base level. However, no deadline has been established for implementing environmental management systems across the Department.
13.114 National Defence should ensure, as part of implementing environmental management systems, that bases and units establish performance measures for hazardous materials compliance that measure continual improvement toward a target of full compliance.
Department's response: Departmental direction with respect to environmental management systems will be expanded to permit the measurement of continual improvement toward the Department's definition of "full compliance".
13.116 Some of the bases we examined have combined the various functional experts responsible for safety and the environment (and therefore also for hazardous materials) into a single office that reports directly to the base commander. In Montreal and Bagotville, this has resulted in the development of a consolidated base-level safety and environmental inspection process. All base functional experts (safety officer, environment officer, hazardous materials officer or co-ordinator, radiation safety officer, explosives safety officer, fire chief and preventative medicine technicians) inspect a unit at the same time, using checklists. All base units are subjected to this "multi-disciplinary" inspection once a year. The result is an annual "snapshot" of each unit's state of compliance. These snapshots are expected to be comparable across units and over time, thereby providing useful performance information.
13.117 The Department should require the use of a consistent methodology for annual environmental audits and inspections at the base level. Implementing the methodology should involve all hazardous materials functional experts.
Department's response: In the response to the recommendation at paragraph 13.103, the Department committed to establishing core requirements with respect to hazardous materials management that must be examined during audits and inspections programs at all levels. The Department will review and revise its methodology for audits and inspections of Bases and Wings as required so that functional experts participate in the audits and inspections. The Department will also provide guidance on the frequency of these audits and inspections at the Base and Wing level.
13.118 We noted another useful initiative at Halifax. Acquisition of hazardous materials has been restricted to Base Supply, except for a list of items considered to be low-risk. The approach at Halifax goes part way toward initiatives introduced in the United States armed forces to centralize hazardous materials management at the unit or base level. The essential features of the American programs are:
13.120 National Defence should conduct a formal assessment or trial of a centralized hazardous materials management system at the base or unit level, aimed at determining:
13.122 The Department is participating in a number of voluntary programs to reduce its use of hazardous materials, including the Accelerated Reduction/Elimination of Toxics program and the Strategic Options Process. Its sustainable development strategy also includes a target of eliminating the use of specified high-risk hazardous materials.
13.123 The Department's approach to these programs is to identify items with NATO stock numbers in the Canadian Forces Supply System that include the targeted chemicals. Headquarters staff then review the products to determine if they are still needed or if there are environmentally friendly substitutes available. Tools such as the Hazardous Material and Preferred Product Selector database have been developed to help base and unit personnel identify the most appropriate substitute for their needs.
13.124 However, because procurement of many hazardous chemical products is decentralized, not all products used have NATO stock numbers. Approximately 10 percent or 400 of the chemical products in the Hi-Q information system, for example, do not have a stock number, a proportion that is likely to increase as more products are procured locally. Moreover, as a result of local procurement, headquarters may be unaware of the products used at the local level. The Department has recognized this problem, and the hazardous materials directive therefore makes it mandatory to use the materiel information management system for life cycle management of hazardous materials. However, it appears that many personnel are unaware of this requirement and rarely comply. Of the 607 items in our hazardous products sample, the personnel responsible for acquiring them confirmed that only 247, or 41 percent, were recorded in the system. Lack of information at headquarters may mean that products are not included in the lists to be assessed and eliminated or replaced.
13.125 The Department should strengthen mechanisms for ensuring that headquarters is aware of hazardous products in use, and that users are aware of less hazardous substitutes that are available.
Department's response: The Department has developed a process to replace products containing substances of concern with more environmentally friendly products, through its voluntary participation in Environment Canada's Accelerated Reduction/Elimination of Toxics program. This process requires that restrictions be placed on those products containing substances of concern where replacements are not possible, are not cost-effective or affect operational readiness. The Department will develop an appropriate communications strategy to inform departmental staff at all levels about the replacement products, including the products that they are replacing. The Department also commits to conducting annual reviews of the screening methodology that it uses to identify products containing substances of concern. The screening methodology will be updated as required so those products posing the highest risk to workers and the environment will be the first priority for replacement.
13.127 A major factor in the lack of compliance is that the existing management systems to ensure compliance do not promote continual improvement. At the base level, objectives are not set and hence plans do not exist to achieve any. At both the national and base levels, audit and inspection programs are not consistent or implemented fully, and their results do not feed into performance measures aimed at continual improvement toward full compliance.
13.128 Performance measures in controlling and reducing emissions are also inconsistent, targeting some sources but not others. In part, this reflects the fact that departmental policy applies standards found in provincial and municipal laws only "where appropriate", without defining what this means. As a result, the Department's standards are compatible with some provincial and municipal laws, but not with others.
13.129 Information and communication are problem areas in several aspects of hazardous material management. National policies do not seem to be communicated effectively, and information on hazardous materials that are used is not readily available and communicated. Improved information systems or approaches used in other countries may offer solutions in some areas.
13.130 National Defence has committed itself to implement environmental management systems at all levels. If it succeeds, the objective to continually improve compliance will be embedded in policy, plans and procedures at all levels. Effective implementation of environmental management systems would also increase the frequency, comprehensiveness and consistency of internal audits at all levels, which should ensure that external inspections find fewer instances of non-compliance. However, no deadline has been set for implementing environmental management systems across the Department.
To assess the state of hazardous materials management at the base level, we selected a sample of 10 Canadian Forces facilities. Our criteria in selecting the bases were representation of all three services and major types of activity, quantities of hazardous material held, number of injuries occurring in recent years, and proximity to populated areas. The bases selected were 3 Wing Bagotville, Canadian Forces Base (CFB) Borden, 4 Wing Cold Lake, CFB Edmonton, CFB Esquimalt, Combat Training Centre (CTC) Gagetown, CFB Halifax, Montreal (Area Support Units Longue Pointe, St-Hubert and St-Jean), 8 Wing Trenton, and Western Area Training Centre Wainwright. Reserve force units and outlying detachments supported by the bases were excluded.
While the bases are not statistically representative, they are significant in their own right. The facilities represent almost one third of Canadian Forces bases, stations and depots. They hold almost 60 percent of the ammunition and radioactive material recorded in the Canadian Forces Supply System, and almost 80 percent of the hazardous chemical products. The bases also employ 35 percent of the Department's regular force military and civilian personnel. The conclusions from this audit should therefore be of interest to departmental officials involved in environmental and materiel management.
At the base level, we met with officials responsible for the environment, hazardous materials, safety, preventative medicine, and fire prevention, and with users of the materials. We obtained and reviewed documentation on management systems, acquisition, training and effluent monitoring.
At three bases, CFB Halifax, CTC Gagetown, and 4 Wing Cold Lake, a team led by certified environmental auditors conducted audits to determine the current state of compliance.
To obtain information on policies and procedures for acquiring hazardous materials and bringing them into inventory, we selected a sample of hazardous products. We chose 10 types of materials that are widely used across the Department, are authorized for local procurement and are among the more hazardous. They included specific types of camouflage paint, paint thinner and remover, anti-seize lubricant, propane and acid. We obtained copies of all 1,760 inventory listings of hazardous chemical products at the 10 bases. We then selected each instance of the materials on the inventory lists and distributed a questionnaire to the person responsible for acquiring it. Because the same person was often responsible for acquiring several products for each inventory, most people who responded filled out more than one questionnaire.
Shaun Bhagrath
Lori Buck
Darryl Burgess
Anne Hardy
Raymond Kunce
Haleem Mughal
Darlene Mulligan
St�phane Rousseau
Mark Skoczylas
Robert Stopford
Kari Swarbrick
For information, please contact Peter Kasurak.