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4.5 Environmental Protection Plans

4.5.1 Purpose

In the last ten years, several developments in Atlantic Canada have used EPPs to facilitate the mitigation of predicted environmental effects (e.g., Hibernia Development Project Platform Construction Site). The use of EPPs has been an effective tool for the management or avoidance of potential environmental effects.

Environmental Protection Plans (EPPs) are an important component of the VBNC EH&S Management System. EPPs are practical documents which set out detailed site-specific protection measures or procedures to be implemented during specific phases of the Project. EPPs are the principal guiding documents that enable mitigation to be properly implemented as prescribed by permits and authorizations, as well as by VBNC policy, guidelines, and standards. A list of potentially relevant legislation, permits, approvals, and authorizations is shown in Appendix 4B. Many environmental requirements and commitments are/will be consolidated into EPPs representing key environmental implementation tools for Project activities. EPPs will be developed for all major phases of the Project:

  • exploration;

  • construction;

  • operation;

  • decommissioning; and

  • post-decommissioning.

  • EPPs are the cornerstone for implementing environmental protection measures. EPPs provide a consolidated documentation of environmental protection procedures, against which performance can be readily assessed.

    EPPs will be used for the following purposes:

  • identify EH&S concerns and develop appropriate protection measures for these concerns;

  • list all required permits and approvals and their associated terms and conditions;

  • provide concise and clear written instructions for procedures that protect the environment;

  • provide a reference document for personnel when planning and/or conducting specific activities;

  • communicate changes in the program through the revision process; and

  • provide a reference to applicable legislative requirements.

  • EPPs are field-useable documents that outline procedures for environmental protection.

    An EPP is a "working document" for use in the field by Project personnel. VBNC off-site personnel can also use the EPP to implement and monitor commitments. EPPs provide a quick reference for Project personnel and regulatory authorities to assess performance and make suggestions for improvements.

    4.5.2 Content

    VBNC has already developed and implemented an Environmental Protection Plan (EPP) for exploration. Many of the procedures will be applicable for future EPPs for construction and later Project phases.

    VBNC has developed and implemented an exploration EPP (VBNC 1997a), which includes specific procedures for activities such as clearing of vegetation, handling of fuel and hazardous materials, solid waste disposal, erosion prevention, and dust control.

    Many of these activities will apply to other Project phases (construction, operation, decommissioning, post-decommissioning), with changes necessary to reflect specific aspects of the activity at each phase, and any changes in regulatory requirements. The exploration EPP has been structured to allow for such updates and revisions. A description of the exploration EPP is included in Appendix 4C.

    Standard environmental protection measures will be applied and modified as necessary for the Project stages. Standard environmental protection procedures have already been developed for:

  • clearing of vegetation;

  • grubbing and disposal of related organic debris;

  • storage, handling and transfer of fuel and other petroleum hydrocarbon products;

  • storage, handling and transfer of chemicals and other hazardous materials;

  • sewage disposal;

  • solid waste disposal;

  • quarrying and aggregate removal;

  • surveying;

  • buffer zones;

  • erosion prevention;

  • drilling - exploration;

  • drilling - geotechnical/water well;

  • dust control;

  • trenching;

  • dewatering - new work areas;

  • marine vessel traffic;

  • pumps and generators;

  • noise control;

  • blasting on land;

  • blasting in the marine environment;

  • permafrost;

  • marshalling, laydown and development areas;

  • marine construction;

  • mineralized rock and acid mine drainage;

  • equipment movement;

  • stream crossings; and

  • dredging and disposal of dredge spoil.

  • The EPPs for exploration will be updated to reflect future goals such as placing a high priority on pollution prevention and waste reduction throughout the operation of the Project, especially with respect to tailings, mine rock, domestic and industrial solid waste, liquid effluent, and hazardous waste. For example, VBNC's acid rock drainage strategy during the operation phase includes segregating non-mineralized mine rock from mineralized rock and placing potentially acid-generating material under water. The EPP, Emergency Response and Contingency Plan, and the Education and Orientation Plan all contribute measures for management of acid rock drainage. The Monitoring and Follow-up Plan and the Audit and Continual Improvement Plan will provide important feedback on the effectiveness of the acid rock drainage strategy, with a view to identifying opportunities for continual improvement.

    4.5.3 Implementation

    At this point, VBNC is in the early stages of Project design. Similarly, construction methodology has not been fully defined. Project design will focus on those elements that are critical to meeting schedules for Project construction. Other design details will be undertaken progressively as construction and later phases proceed.

    VBNC will involve appropriate regulatory authorities, LIA, the Innu Nation and interested parties in the development and review of EPPs.

    The content of the EPPs is dictated to a great extent by the Project phase. To accommodate the evolving details of the Project, VBNC has adopted a staged approach for the development of the EPPs. Stage-specific EPPs will be prepared for each phase. These will be prepared in consultation with the appropriate government officials and other interested parties. Stage-specific EPPs will be completed prior to the commencement of each activity and as detailed information becomes available.

    4.6 Emergency Response and Contingency Plans

    4.6.1 Purpose

    Emergency Response and Contingency Plans (ERCPs) will be prepared for all Project phases to mitigate environmental effects of accidents and malfunctions. ERCPs do not prevent accidents, but rather mitigate the potential magnitude of accidents and malfunctions. ERCPs contain specific procedures for these events when they occur. ERCPs will be developed for:

  • hazardous material spills;

  • wildlife encounters;

  • fires;

  • medical emergencies;

  • mine rescue; and

  • the discovery of historic resources.

  • 4.6.2 Content

    Emergency preparedness and response are critical functions during all Project phases. Given the remoteness of the Project site, many emergency services will be provided by VBNC. Key components of the EH&S Management System will focus on prevention and implementation of emergency procedures. Training and drills will occur routinely.

    Systems for emergency preparedness will be incorporated in ERCPs. An ERCP has been prepared for exploration activities at the site (VBNC 1997b). It includes first aid, fire-fighting, notification procedures, emergency response crews, and contingency planning.

    Although ERCPs will be drafted to address site-specific conditions, they will conform to the outline provided in the Canadian Standards Association (CSA) - Emergency Planning for Industry CAN/CSA-Z731-M91 (CSA 1991) and INCO's Guidelines. Emergency response documentation prepared for exploration activities, and currently in use at site, is described in Appendix 4C.

    Medical Response Team

    VBNC currently has a medical clinic on-site with registered nurses trained in advanced cardiac life support and having experience in critical care and emergency responses. This clinic will be expanded during Project construction as activity increases. The medical staff will participate in training exercises for the establishment of a Medical First Aid Team whose role will be to assist in emergency response by providing logistical and minor medical support. Training will include spinal immobilization, primary assessment, and basic life support techniques.

    Emergency response/mine rescue teams and nursing personnel will be trained to respond to potential injuries. An ambulance/rescue truck will be based at the Project site for emergency transport. First aid requirements will be established as per the Newfoundland and Labrador Occupational Health and Safety Act. First aid training is required for all supervisors and mine rescue personnel. Emergency first aid facilities and supplies will be located at appropriate areas throughout the Project site. Additional training specific to responding to fires, spills and other emergencies will also be provided.

    A site spill response team is in place. A training program and audit were conducted most recently in August, 1997.

    VBNC developed an Oil Pollution Emergency Plan (OPEP) (VBNC 1997c) for exploration which describes procedures to address spills which occur either on land or in water. A brief description of this OPEP is included in Appendix 4C. The safety of all personnel is of overriding importance under all conditions. This is particularly so when working in boats, operating equipment, or conducting containment and cleanup operations in unfamiliar waters or territory. Therefore, all safety precautions detailed in this OPEP must be observed by all personnel at all times. The OPEP provides guidance and direction during those times deemed to be most critical to responding personnel. Integral to the initial and continued response will be the requirement for the response to be safe and controlled.

    Emergency Response Fire-Fighting Team

    A trained volunteer fire-fighting team is in place and drills and exercises are held regularly.

    The Emergency Response Fire-Fighting Team is fully trained to fight fires and respond to hazardous materials spills. Training will include the use of equipment and materials to contain and clean up spills and fire prevention/control techniques. Fire-fighting equipment requirements will be reviewed regularly. The Emergency Response Fire-Fighting Team also has the capability to respond to missing persons reports and assist medical response where requested.

    All fire-fighting systems will comply with the National Fire Protection Association Codes. A designated fire truck capable of meeting all fixed and mobile fire-fighting requirements, particularly fuel fires, will be located at the site. Other emergency response equipment will be stored in emergency response vehicles. Project personnel will comprise all fire-fighting or emergency response units.

    A dedicated system of radio communications will be in place to alert personnel to an emergency. Sufficient numbers of fire-fighting personnel will be maintained on-site, regardless of shift rotation.

    Mine Rescue Team

    A Mine Rescue Team will be established to respond to all mine related emergencies. This team will be in place during both open pit and underground operations. INCO has extensive experience in mine rescue strategies and will work with VBNC and appropriate regulatory authorities in the development of mine rescue procedures.

    4.6.3 Implementation

    ERCPs will follow a similar approach as that described for stage-specific EPPs (Section 4.5.3).

    4.7 Occupational Health and Safety Plans

    4.7.1 Purpose

    VBNC will implement an Occupational Health and Safety Plan/or Program (OHSP) to ensure all workers on the Project have a healthy and safe workplace.

    4.7.2 Content

    VBNC is committed to providing an injury-free and safe working environment. The following principles reflect the company's safety commitment:
  • all injuries can be prevented;
  • employee involvement, participation and training in safety is essential;
  • management is responsible for providing a safe working environment and preventing injuries;
  • VBNC must strive to continuously improve the safety of all people connected with the company;
  • all operating exposure can be safe-guarded;
  • working safely is a condition of employment; and
  • prevention of personal injury and incidents, on and off the job, is good business.

  • Safety is the top priority of VBNC. Employee involvement, good safety practices, compliance with regulatory requirements, continuous safety awareness, and risk management are integral components of VBNC's OHSP.

    VBNC currently has safety procedures and practices in place for exploration activities. These include safety orientation and training, health and safety committees, and emergency response and contingency plans. Employees, contractors, and visitors are required to comply with this OHSP.

    VBNC accepts its responsibility to all employees, contractors, and visitors to provide safe operations, conditions, premises, equipment, and systems. In return, VBNC expects all employees, contractors, and visitors to conduct their work in a skillful, safe, and competent manner and exercise reasonable care with respect to themselves, fellow workers, and the environment. Before arrival on site, VBNC employees are given a pre-placement medical examination to ensure they will be able to perform all aspects of their work without undue stress on their mental or physical health.

    The following sections describe the OHSP, including both its current status (in support of site exploration and Project planning) and plans for implementation through the Project phases. VBNC Safety Program

    The VBNC Safety Program is designed to protect employees from injury. The program focuses on good safety practices, safety awareness, risk management, employee involvement, and management commitment by:

  • identifying possible causes of accidents;

  • setting standards of practice and procedures;

  • setting standards of accountability;

  • measuring performance against standards;

  • evaluating compliance with standards; and

  • correcting deficiencies and non-conformance.

  • The program involves all employees, from the CEO/President to the newest employee. All employees must participate in extensive training in order to protect their personal safety and the safety of fellow employees. For construction, SNC-Lavalin is responsible for development and implementation of occupational health and safety procedures for its workers and subcontractors. A Health and Safety manual has been written for this purpose.

    Safety Reporting

    Each month VBNC prepares a Safety Statistic Report. VBNC has not had a lost-time incident in 1997.

    Employers and employees are responsible for the prompt and accurate reporting of accidents, fatalities, illnesses, exposures, injuries or incidents, in compliance with the Occupational Health and Safety Act (Newfoundland), the Workers Compensation Act (Newfoundland), and VBNC policies and standards. It is the responsibility of each supervisor to ensure this is carried out promptly and in compliance with the regulations and according to VBNC policy.

    Lost-time accidents must be reported to the EH&S Department immediately. Supervisors also prepare a detailed accident/incident investigation report. The Workers' Compensation Board and the insurance carrier are to be notified within the required time frame for reporting any accident. Follow-up reports will be provided upon request. VBNC management is to be notified directly in the event of a serious accident or fatality.
    A monthly safety report is prepared which contains information on the number of employees, total hours worked, number of lost-time injuries, number of total injuries, number of near accidents, and property damage accidents for employees and contractors.

    Occupational Health And Safety Communication

    Effective communication channels between employees is essential for individual commitment to safety and responsible attitudes, behaviour, and practices in the workplace. Workers receive a thorough orientation in the rules and procedures when they arrive for the first time at the site or when there is a major modification to work activity. These include individual responsibility and accountability, emergency procedures, environmental awareness, company policies and procedures, job specific procedures and health and safety requirements.

    Beginning with orientation, relevant occupational health and safety training is provided as an integral part of developing each employee's job competency. At every level, employees are encouraged to maintain a strong interest in health and safety improvement through involvement in activities such as weekly toolbox meetings, occupational health and safety committees, training, health promotion, and workplace design and improvements.

    Contractors, Suppliers, and Visitors

    The selection and retention of contractors and suppliers will be based in part on their demonstrated commitment to occupational health and safety excellence. Past EH&S performance of contractors will be reviewed and assessed.

    Before starting any job, contractors will be required to provide documentation of their health and safety programs, develop and submit plans necessary for the safe completion of the scope of work, and demonstrate a company commitment to safety. Should unsafe or unhealthy contractor work practices or conditions arise, the contractor will be obliged to correct the situation in a timely manner to the satisfaction of Project management personnel and occupational health and safety staff. VBNC policies and standards will serve as the criteria for performance.

    Purchasers and suppliers will be responsible for goods and services conforming to legal requirements, accepted standards, and Project specifications. Any hazard associated with goods and services will be identified, documented, and communicated to Project management prior to delivery and in conformance with VBNC and Workplace Hazardous Materials Information System (WHMIS) requirements.

    Safety Orientation

    VBNC has established an on-site Safety Orientation Program which is delivered to each employee and visitor arriving on-site. The orientation addresses the OHSP and broader EH&S issues including the following:

  • VBNC's commitment to OH&S;

  • safety regulations and rules;

  • hazards identification;

  • control measures;

  • Project facilities layout;

  • helicopter orientation;

  • wildlife encounters;

  • the discovery of historic resources;

  • accident reporting;

  • emergency procedures;

  • EPP and procedures;

  • employee's right to refuse work;

  • work duties and safe work practices;

  • WHMIS training; and

  • disciplinary action after non-compliance with the Safety Orientation Program.

  • Occupational Health and Safety Committee

    OH&S Committee meetings are held monthly at the site and quarterly at the St. John's office.

    OH&S Committee meetings are currently held on a monthly basis. Minutes of safety meetings are posted in prominent locations on site for review. The OH&S Committee provides input into emergency preparedness and response plans as well as training to achieve the appropriate level of competency. This committee also serves as a forum for discussion of health and safety issues with the objective of continually improving work practices.

    Hazard Analysis

    VBNC has implemented hazard analyses on a routine basis to identify and analyze hazardous situations. Hazard analysis is a documented process used to:

  • identify hazards and operability issues which could prevent a project from reaching optimum and safe production;

  • identify and analyze hazards that can lead to undesirable incidents associated with existing processes and/or activities; and

  • investigate the causes of failures and incidents.

  • This same hazard analysis process will be used by VBNC during the Project.

    Hazard analyses are conducted in accordance with INCO guidelines, and relevant regulations. Teams of qualified personnel plan and conduct the hazards analyses, report the results, and follow-up on recommended control measures to reduce any risks to acceptable levels. The objective is to reduce the level of risk to make it as low as is reasonably practical. As a follow-up to the Hazards Analysis Report, individuals are assigned tasks and dates for completion to implement the recommendations.

    The principal safety hazards identified for the Project are discussed in Appendix 4D.

    Occupation-specific hazard analyses will be conducted by qualified on-site staff on a regular and on-going basis during the life of the Project in order to verify that risks are reduced to acceptable levels.


    During the period from May to July, 1997 VBNC trained 42 workers on-site in first-aid and CPR.

    In July 1997 approximately 75 workers participated in a Back Injury Prevention Seminar.

    VBNC has conducted employee training for ground search and rescue, fire-fighting and fire prevention/control, environmental awareness, and animal encounters. Specific response teams have been established and trained for ground search and rescue, fire-fighting, spill response, and medical response. Each employee will receive task training relevant to the particulars of the job as well as the necessary safety and health precautions. Additional training is planned regarding cold weather survival and ice travel, wildlife safety, emergency evacuation procedures, use of personal protective equipment, WHMIS, occupational health and safety hazards, motor vehicle safety, and fire preparedness.

    The potential loss of life and property due to fire is a concern, therefore, personnel will be provided essential fire preparedness training. This includes regular on-site training on the locations, types, and proper use of fire extinguishing equipment and fire drills.

    Personnel will receive annual WHMIS training appropriate to their work, as required by the Newfoundland Department of Mines and Energy and the federal Department of Human Resources Development. In this way, individuals will be knowledgeable about the Project's WHMIS program, be able to identify hazardous products and read a Material Safety Data Sheet (MSDS), and understand the proper use, handling, storage and disposal of the products, and first aid procedures. Mandatory training, as prescribed by the Province's Mining Safety Regulations, will continue to be conducted during all phases of the Project. Mine rescue teams will receive ongoing training, as required by the Province's Mining Safety of Workers Regulations.

    Workplace Monitoring and Control

    An Occupational Hygiene Monitoring Program will be developed for Project operations. The objectives of this plan are to identify hazardous conditions, assess occupational exposures to chemical and physical hazards, evaluate the effectiveness of work practices, and recommend safe work procedures.

    Engineering controls, administrative controls, and personal protective equipment are control measures implemented to protect worker health. Monitoring determines the need for these control measures. Engineering controls will be integrated into facilities/infrastructure. Controls to be considered at the design phase include substitution, changing the process, isolation enclosure, local exhaust, ventilation, dust suppression, and equipment redesign. Administrative controls may reduce overall worker exposure by adjusting work schedules, rotating job assignment, shifting work to other areas, and implementing written work procedures for hazardous jobs and hazardous material handling.

    Personal protective equipment includes hearing protection, respirators, eye protection, hand protection, emergency eyewash facilities, emergency showers, protective clothing, emergency cleanup equipment, and standard safety equipment such as safety glasses, hard hats, and hard-toed boots.

    Heavy equipment operation, blasting, drilling, and mineral processing will generate noise levels that may pose a potential occupational hazard to workers. Occupational noise is regulated by the Newfoundland and Labrador Occupational Health and Safety Act. Provisions will be made for a hearing conservation program that includes noise control, hearing protection, and baseline and annual audiometric testing and training.

    Control of worker exposures to welding fumes (including metal fumes, flux products, and welding gases) will be implemented in conjunction with a monitoring program for airborne contaminants. Worker protection, including welding shield, goggles, gloves, aprons, and respiratory equipment, will be provided.

    Medical Surveillance Programs

    VBNC has initiated a Medical Surveillance Program to track employee health during the course of employment.

    Since December 1996 all VBNC employees have taken a pre-placement medical examination.

    The Medical Surveillance Program has three components:

  • to determine the baseline medical condition of the employee as determined during the pre-placement examination;

  • the periodic surveillance examination that tracks employee health; and

  • injury and illness care and status assessment post-injury, including determination of disability and rehabilitation program elements.

  • 4.7.3 Implementation

    The OHSP will be implemented in a phased manner similar to that described for EPPs (Section 4.5.3).

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