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A health and safety representative has not been assigned to the nitrate facility and consequently, monitoring, investigations and inspections were not performed. This included the monitoring of health and safety controls such as ensuring emergency eye wash and showering stations were functioning, first-aid kits were inventoried and health and safety products were not expired.
An information strategy to keep employees informed of existing and changing health and safety requirements, issues and implications was not in place.
Roles and responsibilities related to the property management of the nitrate facility were defined through a MOU between CRC and LAC. The MOU outlined roles and responsibilities related to fire prevention and fire alarms, as well as physical security and were consistent with the TB Fire Protection Standard and Standard for Fire Safety Planning and Fire Emergency Organization. As required by the previously mentioned standards, it was observed that fire protection equipment was inspected on a regular basis. We observed that fire extinguishers were tested and monitored on a monthly basis through evidence of a signed monitoring card on each fire extinguisher.
With regards to health and safety, supervisors are responsible for the health and safety of employees. 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 on a special project. Interviews indicated that LAC Management acknowledged these health and safety responsibilities. In addition, employees working at the nitrate facility had a list of contacts to help address issues/concerns, should they arise.
According to the Canada Labour Code Part II, a health and safety representative is required for each workplace controlled by the employer at which fewer than 20 employees3 are normally employed. A health and safety representative has not been assigned to the nitrate facility and consequently, monitoring, investigations and inspections 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. Without periodic monitoring of these health and safety controls and in the event of a fire or health and safety issue, controls in place may not be functioning appropriately.
Communication requirements were not in place to inform employees of existing and changing health and safety requirements, issues and implications; nor management’s requirement to notify health and safety personnel, such as LAC’s Occupational Health and Safety Officer, that employees will be working at the nitrate facility for an extended period of time.
The lack of defined communication requirements may result in employees not being aware of, or exposed to, new health and safety risks or fire hazards.
LAC should identify a H&S representative for the nitrate facility to ensure periodic monitoring of the health and safety controls.
The Analogue Preservation Branch should develop a strategy to inform employees working at the nitrate facility of existing and changing health and safety requirements related to nitrate material; and ensure that appropriate individuals are notified if employees will be working at the nitrate facility for an extended period.
Employees working at the nitrate facility were trained on health and safety policies and procedures, however the nitrate handling procedures provided to the employees was incomplete as it did not describe the procedures for the disposal of scrap nitrate.
Prior to beginning work at the nitrate facility, employees were trained on health and safety related procedures and risks specific to the nitrate facility and cellulose nitrate collection items. The employees working at the nitrate facility were provided with an orientation binder that included documentation on nitrate handling procedures, nitrate circulation procedures, nitrate facility security protocols, fire safety plan and facility evacuation procedures. These were readily accessible, as required by the TB Policy on Occupational Safety and Health. The review noted that the evacuation procedures were completed and included:
Our review of the fire safety plan and nitrate handling procedures noted that:
Through our review of the training material and interviews with employees working at the nitrate facility, awareness of the health and safety risks including fire safety and fire-evacuation procedures were apparent. This was further noted through a fire drill that was undertaken by CRC’s Fire Prevention Officer in June 2011. In addition, commissionaires employed by CRC to monitor the physical security of the campus were also trained.
Although the nitrate handling procedures were consistent with the NFPA 40 – Standard, the document was incomplete as it did not describe the procedures for the handling and disposal of scrap nitrate, as outlined in chapter 7 of the NFPA 40 – Standard. Interviews indicated that scrap nitrate is not currently being produced at the nitrate facility. 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.
The Analogue Preservation Branch should ensure that the nitrate handling procedures are complete, and include procedures for the handling and disposal of scrap nitrate.
Security cameras were not in place for an extended period of time and controlled access to the storage vaults was not functional at the time of the audit walkthrough.
The TB Accessibility Standard for Real Property outlines minimum requirements for accessibility of real property, which includes facilities such as the nitrate facility. Based on our review procedures, the nitrate facility is compliant with the TB Accessibility Standard for Real Property. The nitrate facility was assessed against the requirements of the standard.
The NFPA 40 – Standard for the Storage and Handling of Cellulose Nitrate Film outlines minimum safety requirements which include the storage and handling of cellulose nitrate-based film. A review of the nitrate facility was conducted by HRSDC Fire Prevention Services during the design phase and at the completion of the construction phase, at which point they confirmed the nitrate facility was compliant with the NFPA 40 – Standard.
Our audit focused on specific chapters of the NFPA 40 – Standard related to nitrate:
During the fieldwork phase of the audit, the audit team observed:
It was also observed that water and fire detection devices, including fire alarms and smoke detectors, existed throughout the facility. The audit procedures also included a review of the physical security of the facility. Physical security of the building is monitored by commissionaires employed by CRC. Commissionaires completed regular drive-by patrols of the facility during the daytime and regular walkthroughs of the facility during the nighttime. Access to the facility are controlled by passes and monitored by CRC whereby electronic passes were required to access the nitrate facility, employee working area, electrical room, mechanical room, vault area and cold-storage area.
At the time of the audit, we observed:
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.
LAC’s Security officer should ensure that compensating measures be implemented immediately at the nitrate facility, while cameras are removed and controlled access is not functioning, and kept until these controls are back and functioning as intended.
Temperature and Humidity Fluctuations
The cooling system for the cold-storage vaults was not operating as intended, resulting in 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.
To ensure that preservation and fire safety objectives were met, a review of the monitoring of issues, specifically temperature and humidity fluctuations was conducted. The industry standards used to assess existing temperature and humidity included:
The table below provides an overview of the different temperature and relative humidity levels for storing cellulose nitrate products by industry standard:
|Standard||Preservation||Fire Safety||Relative Humidity||Temperature||Notes|
|NFPA 40||X||N/A||21°C or less|
|ISO 10356||X||20%-30%||2°C max|
|IPI||X||30% - 50%||12°C||Satisfactory for extended periods|
|4°C||Comparable to ISO standards|
|0°C||Will provide extended lifetime preservation|
LAC determined that they would adhere to the NFPA 40 and ISO standards which prescribe 2°C temperature and relative humidity of 20%–30%.
Through interviews with key personnel, it was determined that the temperatures and relative humidity of cold-storage vaults and work areas were monitored by CRC and LAC. The CRC security desk was informed when the temperature of the cold-storage vaults exceeded 2°C by an alarm system that monitors temperature fluctuation. A process exists to inform LAC when temperature and humidity fluctuations occur over the accepted standards. Between June and October 2011, the nitrate facility experienced temperature and humidity fluctuations due to mechanical issues with the cooling system. The issues with the cooling system resulted in temperature and humidity fluctuations between 1°C to 9°C and 20% to 53% respectively. Throughout the period, different solutions were examined and put in place to resolve the issue.
It was determined that a mechanical issue caused the unexpected temperature and humidity fluctuations in the summer months (June to October). In November 2011, measures were taken by the project management team to permanently address the temperature and humidity fluctuations whereby an independent contractor was hired to undertake corrective measures on the mechanical system at an additional cost of $111,000. The project management team overseeing the repair of the cooling system should continue to monitor the temperature and humidity fluctuations and ensure that upon completion of the repairs, cold-storage vaults maintain expected temperature and humidity levels, including during the summer months. Similar to the issues at the previous Rockcliffe facility which was deemed inadequate and inappropriate for the long-term preservation of cellulose nitrate records, 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.
Although the fluctuations reached as much as seven degrees higher than the set temperature for the nitrate facility cooling system, the maximum ideal temperature that could be reached and still meet preservation objectives is 12°C. According to the Image Permanence Institute, 12°C is a satisfactory temperature for the preservation of nitrate film for extended periods.
The project management team overseeing the repair of the cooling system should monitor the temperature and humidity fluctuations and ensure that upon completion of the repairs, cold-storage vaults maintain expected temperature and humidity levels throughout the year.
3 Workplace with more then 20 employees requires a H&S committee.