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Audits and Evaluations

Nitrate Film Preservation Facility

Introduction

Background

As part of its mandate, Library and Archive Canada (LAC) is responsible to preserve the documentary heritage of Canada for the benefit of present and future generations. A portion of the collection includes film and photographs which were produced on cellulose nitrate-based film until the 1950s. The nitrate collection is composed of approximately 5,575 film reels and 600,000 photographs, which LAC has been storing at the Rockcliffe site1, since 19752.

In March 2001, the Nitrate Film Storage Facility was given Preliminary Project Approval since the Rockcliffe facility was deemed inadequate and inappropriate for the long-term preservation of potentially volatile cellulose nitrate records. In 2003, the Auditor General issued a report noting the poor quality of facilities housing LAC collections, further supporting the ongoing need to improve the preservation of cellulose nitrate collection.

Following the results of the Auditor General’s report and the Department of National Defence’s decision to dispose of the Rockcliffe site, LAC and Public Works and Government Services Canada (PWGSC) explored possible alternative accommodation solutions for the nitrate preservation facility. On June 5, 2008, LAC received Effective Project Approval (EPA) for the construction of a new nitrate film preservation facility in Shirley’s Bay, at an estimated substantive total project cost of $17.9M (excluding GST). The Strategic Planning, Infrastructure and Operations Branch was responsible for the oversight of this project for LAC.

Construction of the new facility began in July 2009 and was completed in the fall of 2010. An issue with one of the two heating and ventilation air-conditioning units serving the storage vaults was discovered during the commissioning of the mechanical systems. This issue delayed the move of nitrate holdings until February 2011. Once the issue was resolved and the preservation environments in the storage vaults were shown to be stable, the nitrate holdings were moved to the new facility. The move took place from February 15 to February 25, 2011.The construction project was deemed a success as the project objectives were met under the approved budget. The nitrate facility was operational in March 2011. The Analogue Preservation Branch is responsible for the preservation of the collection at the nitrate facility.

A Memorandum Of Understanding (MOU) for Campus Site Services was signed between LAC and the Communications Research Centre (CRC). This MOU describes the agreement made between LAC and CRC for the provision of support services such as facility management and security at the new facility. The MOU describes the scope and general terms and conditions with respect to the delivery of, and cost recovery for, support services provided by CRC.

There have not been any previous audits on the nitrate facility. Human Resources and Skills Development Canada (HRSDC) Fire Prevention Services conducted a review of nitrate facilities plans and design prior to construction and performed a review/inspection of the nitrate facility following the construction phase. HRSDC deemed the nitrate facility compliant with National Fire Protection Association (NFPA) 40 – Standard for the Storage and Handling of Cellulose Nitrate Film and other applicable fire codes.

Risk Assessment

A risk assessment was conducted during the planning phase of the audit to ensure the audit focused on the areas of most significance. The following risks were identified:

  • Roles, responsibilities and accountabilities related to health and fire safety of the nitrate facility may not be clearly defined, communicated and understood.
  • Ongoing health and fire safety monitoring of the nitrate facility may not be conducted.
  • Adequate planning for fire safety may not be established, communicated and understood.
  • Senior management may not receive timely and accurate information related to existing or emerging preservation, health or fire safety issues.
  • The nitrate facility may not comply with the minimum requirements for the accessibility of real property.
  • Cellulose nitrate-based documentary heritage may be deteriorating at a more rapid rate than anticipated as a result of temperature fluctuations.

Objective and Criteria

The objective of the audit was to determine if the requirements outlined in the Treasury Board (TB) submission for the construction of the new cellulose nitrate facility were met.

The audit criteria for this engagement were:

  • An effective health and safety oversight structure including defined roles and responsibilities has been established and meets the requirements of applicable regulations and standards.
  • Health and safety guidance documents, training and awareness programs are in place, appropriately communicated and reflect applicable regulations and standards.
  • Monitoring and reporting mechanisms are in place to help ensure health and safety measures are functioning as intended, preservation objectives are being met and arising health and safety or preservation issues are appropriately responded to.

The audit criteria were derived from the results of a preliminary risk assessment, industry standards, legislation and TB policies related to the storage of cellulose nitrate records and occupational health and safety, which are listed in the next section.

Scope

The audit scope focused on assessing compliance with:

  • the NFPA 40 – Standard for the Storage and Handling of Cellulose Nitrate Film;
  • ISO 10356 Standard – Cinematography, Storage and Handling of Nitrate-base Motion-picture Films;
  • Treasury Board Accessibility Standard for Real Property;
  • Canada Labour Code – Part II which describes health and safety roles and responsibilities for employers, employees health and safety committees and health and safety representatives;
  • Treasury Board Policy on Occupational Safety and Health;
  • Treasury Board Standard for Fire Safety Planning and Fire Emergency Organization; and
  • Treasury Board Fire Protection Standard.

Methodology

The audit fieldwork was conducted in accordance with the TBS Policy on Internal Audit, which stipulates that the Institute of Internal Auditors’ standards apply to the Public Service sector. These standards require that the audit be planned and performed in such a way as to obtain reasonable assurance that the audit objective is achieved.

The fieldwork was conducted between February and March 2012. The audit included procedures that were considered necessary to assess compliance with relevant policies and standards. The audit procedures included:

  • a review of the fire safety plan and evacuation procedures, fire drill report, nitrate handling and circulation procedures, nitrate facility security protocol, LAC occupational health and safety policy, the MOU between CRC and LAC;
  • a review of the process to monitor temperature and humidity of acclimatization and cold-storage vaults;
  • a visit to the nitrate facility to assess the facility against fire safety and cellulose nitrate storing standards and requirements; and,
  • interviews with Project Leads, management and other key personnel.

1 Owned by the Department of National Defence until December 2005.

2 Treasury Board Submission for the funding for construction of a nitrate preservation facility.

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