FEDERAL (Canadian OH&S News)
Canada’s nuclear regulator is proposing a fitness for duty policy that would see employees with unescorted access to protected areas of a nuclear power plant subject to a comprehensive set of random alcohol and drug tests.
The Canadian Nuclear Safety Commission (CNSC) in Ottawa has released a discussion paper on April 10 to solicit comments from stakeholders and the public. The paper outlines a three-pronged approach that would require nuclear power plants to establish policies to prevent, detect and remediate potential alcohol and drug use; introduce supportive measures to address substance use; and implement a random substance testing program for those with unescorted access to safety-sensitive areas of a nuclear power plant, with violations reported to the CNSC.
“Given the hazardous nature of work performed in these facilities, the CNSC considers that the entire protected area of each nuclear power plant is a safety-sensitive site,” the paper states. This would take into consideration all stages of a nuclear power plant’s lifecycle, such as construction, operation, refurbishment and decommissioning.
Aurèle Gervais, chief advisor of media and community relations for the commission, says the discussion paper is not in response to any evidence of safety issues. Since regulations require nuclear power plant licensees to have a fitness for duty program for certified staff, “the Commission Tribunal has often requested clarification on the measures that licensees have in place to address fitness for duty,” Gervais says.
Presently, the CNSC does not have explicit alcohol or drug testing requirements, but licensees are required under the Nuclear Security Regulations to maintain an awareness program in which supervisors receive training on how to recognize behavioural changes in workers, including impairment due to alcohol or drugs, Gervais adds.
Ontario Power Generation in Toronto, for one, has a fit for duty program that looks at whether or not an employee is fit for duty, including physical and emotional well-being. “Employees are trained to watch for their own signs of issues like stress,” manager of media relations Ted Grutzner explains.
Operator assessment provisions different
While nuclear operators have clear rules against possession or consumption of alcohol and drugs at work and employ various methods to assess if workers are impaired on the job, provisions — which range from medical examinations and supervisory observation to self- and peer-reporting — differ significantly from operator to operator. As well, the CNSC’s requirements “currently do not explicitly require licensees to be proactive in the area of substance use,” the paper added.
“Fitness for duty is one factor that affects human performance. An important element of being fit for duty is being free from the influence of alcohol, illicit drugs or performance altering medication while at work,” a CNSC bulletin notes.
A worker’s degree of fitness to perform assigned duties can be assessed by using a spectrum of determinants, the paper states, including medical, psychological, occupational fitness, behavioural performance and biochemical testing.
The CNSC recommends the prohibition of using or possessing alcohol or drugs by workers on duty be adopted by all nuclear power plants as a minimum requirement. This would require nuclear operators to take concrete steps to prevent employees from bringing, keeping or consuming alcohol and drugs or drug paraphernalia within the premises or on the grounds of a nuclear facility.
A host of support programs would also be needed to foster and enforce compliance. They include increasing worker awareness through training; providing access to employee assistance program for workers who need help; ensuring alcohol and drugs are specifically addressed in supervisory awareness programs; and implementing measures to investigate suspected workers.
Although the proposed initiatives are currently limited to nuclear power plants, the CNSC is open to the idea of expanding the scope to include other licensed nuclear facilities. “One of the aims of the discussion paper is to seek stakeholder feedback on the population of workers that should be covered by this policy,” Gervais says, adding that it is unclear at this point in time how many workers could be affected by the policy, if implemented.
Transportation, petroleum and mining are among the industries where random substance testing is currently in force.
Ontario Power Generation will review the document and submit its comments to the CNSC. “But we are not commenting until we’ve done the review and determine our path forward,” Grutzner says.
Submission of feedback closes on August 7. Comments by the public will be posted on the CNSC’s website and will be reviewed when formulating the policy. “The current plan is to issue the formal requirements in a draft document for public consultation in 2013,” Gervais says.