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The Nitrate Film Preservation Facility Audit was part of the 2011/14 Risk-Based Audit Plan (RBAP) which was recommended for approval by the Departmental Audit Committee (DAC) and was subsequently approved by the Deputy Head in June 2011.
In June 2008, the Treasury Board of Canada Secretariat (TBS) approved funding to Library and Archives Canada (LAC) for construction of a nitrate preservation facility to safeguard Canada’s cellulose nitrate-based documentary heritage. It was stipulated in the Treasury Board (TB) submission that an audit be conducted when the project was completed, and a copy of the audit report be provided to the TBS.
The nitrate facility was operational in March 2011 and a Memorandum of Understanding (MOU) was signed between LAC and the Communications Research Centre (CRC) for Campus Site Services such as facility operations and maintenance and security at the new nitrate facility. The Analogue Preservation Branch is responsible for the preservation of the collection at the nitrate facility.
The objective of the audit was to determine if the requirements outlined in the TB submission for the construction of the new cellulose nitrate facility were met. Furthermore, following the risk analysis, the audit focused on Health and Safety oversight, handling procedures for nitrate documents and physical security at the nitrate preservation centre. The main observations are identified below.
Health and Safety
Generally, there are no permanent employees working at the nitrate facility, however, at the time of the audit, four employees had been working full-time at the nitrate facility for approximately one year. Supervisors of the employees working at the nitrate facility were aware and acknowledged their responsibilities for the health and safety of their employees. However, a health and safety representative had not been assigned to the nitrate facility—as prescribed by the Canada Labor Code—and consequently, monitoring, investigations, inspections and other responsibilities of the health and safety representative were not performed. This included the monitoring of health and safety controls such as the functioning of eye wash and showering stations, maintenance of first-aid kits on-site, and the expiry of health and safety products.
Also, there was no information strategy in place to keep employees informed of changing health and safety requirements, issues and implications. Nor was there a process to notify the LAC occupational health and safety officer that employees would be working at the facility for an extended period of time.
It is recommended that a process be established to ensure periodic monitoring of the health and safety controls at the facility and that an information strategy be put in place to ensure that the LAC Occupational health and safety officer is kept informed when employees are working at the facility to ensure the health and safety of these employees.
Nitrate Handling Procedures
The nitrate handling procedures were also reviewed and were found to be generally consistent with The National Fire Protection Association (NFPA) 40 – Standard for the Storage and Handling of Cellulose Nitrate Film, however the handling procedures were incomplete as the procedures did not describe the handling and disposal of scrap nitrate. There is currently no scrap nitrate produced at the facility but in the event that scrap nitrate is produced at the facility and needs to be disposed of, employees handling the scrap nitrate may not be aware of the required safety procedures to take and may expose themselves and other employees to health and safety risks.
It is recommended that the nitrate handling procedures are revised to include procedures for the handling and disposal of scrap nitrate.
Monitoring and Reporting
Monitoring and detection functions for vault temperature and humidity, physical security,water and fire detection existed throughout the nitrate facility. However, at the time of the walkthrough, the audit team observed that the controlled access to the storage areas (both acclimatization and cold-storage vaults) were not functioning, resulting in uncontrolled access to the acclimatization and cold-storage vaults. We also noted that security cameras (both inside and outside) had been removed for a period of approximately three weeks due to a system upgrade. When physical security measures at the nitrate facility are not functioning as intended or not in place, the nitrate collection may be subject to theft or damage.
It is recommended that compensating controls be implemented immediately, while the cameras are removed and access points uncontrolled.These compensating measures must be in place until the key controls are back and functioning as intended.
Monthly reporting captures temperature and humidity daily averages in the employee work areas and acclimatization and cold-storage vaults of the nitrate facility. Between June and October 2011, management was made aware of temperature and humidity fluctuations between 1°C to 9°C and 20% to 53% respectively. It was determined that a mechanical issue caused the unexpected temperature and humidity fluctuations. Measures were taken by the project management team to address the temperature and humidity fluctuations. Temperature and humidity fluctuations will have an impact on the preservation of the nitrate collection, including a more rapid decay of the collection and may increase the risk of fire.
It is recommended that the project management team overseeing the changes to the nitrate facility humidifier continue to monitor the temperature and humidity fluctuations and ensure that upon completion of the changes, cold-storage vaults are maintaining expected temperature and humidity levels.
The results of the audit indicate that the requirements outlined in the TB submission for the construction of the nitrate facility were met. However, areas for improvement were identified for:
Statement of Assurance
This audit engagement was planned and conducted to be in accordance with the Internal Auditing Standards for the Government of Canada.
In my professional judgment as Chief Audit Executive, sufficient and appropriate procedures have been conducted and evidence gathered to support the accuracy of the conclusions reached and contained in this report. The conclusions were based on a comparison of the situations as they existed at the time of the audit and against the audit criteria.
We wish to express our appreciation for the cooperation and assistance afforded to the internal audit team by management and staff during the course of this assurance engagement.