Tailings Pond Emergency Response Preparation Gaps
Mark Gillan
Deputy Fire Chief (Ret.) at Saint John Fire Department, Director Emergency Solutions International
The preparation for and mitigation of incidents at Tailings Management Areas (TMA) is complex and requires a validated program that is commensurate with the risk. Our team is noticing higher regulatory scrutiny of Programs, Plans and validation exercise requirements across Canada and in the United States. This scrutiny is likely due to a number of incidents in North America lately where response has been perceived as ineffective. Regulators have adopted the Incident Command System (ICS) "Principles and Lexicon of Language" in North America. Emergency Solutions International seeing that when there are Exercises or Program Audits, if there has not been a shift to ICS by industry, their plans and response seem outdated or ineffective to the Regulator representatives and other parties brought in to assist.
Response to Tailings Management Areas is particularly complex and through the validation exercises that our team has run in North America, there are potential gaps which may lead to ineffective or failed response: 1) Approaching the incident as an engineering event and not an Incident Command System driven Incident 2) Not setting up a facility Emergency Operations Centre in the emerging threat or plan activation/response phases 3) Not setting up an Incident Command Post in the field to manage the incident 4) Not having Engineering and Operations Staff trained in the Incident Command System 5) Program not validated back to the CSA/NFPA 1600 Standard 6) Failure to run realistic full scale exercises including the full logistical movement of equipment 7) Lack of formalized communication from the site (ICP) to the Emergency Operations Centre and then to the Corporate Senior Leadership Team 8) Failed Crisis Communications strategy (no ICS Public Information Officer Training) 9) Contractors (Ops & Engineering) not included in ICS training or exercises 10) Freelancing by contractors and operators during the incident leading to safety issues 11) Unity of Command and Span of Control breaches as well as ineffective use of Unified Command
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There is clearly a significant amount of work being put into ensuring Tailings Management Areas are safe and protect the environment. Often times though, it is unclear to corporations if the response to these low probability high, complexity incidents would ensure that workers are safe, that the mitigation can be effective and that the management of the response will be perceived as effective in the eyes of the Regulator, the public, First Nations communities, Board and investors. We have seen that the application of the Incident Command System, quarterly drills, realistic annual validation exercises and CSA/NFPA Z1600 based Program analysis and Report Card can create confidence in the eyes of corporate leaders and the Regulator that preparation programs and response will be coordinated and effective.
Veteran | Public Info | Crisis Comms | DEM | Public Engagement M.D. Bruce & Associates Ltd.
2 年#8 regarding the lack of PIO training is a challenge across many industries (and orgs in general). We focus on the ops side, but don’t always train those who need to communicate about the incident. Working in crisis mode is different than everyday comms. Special skills are needed to perform effectively in the role. I have co-instructed the FEMA All-Hazards PIO course and this is something we emphasize with students. Industry also needs to focus on engagement with the community and risk comms in the preparedness phase. People need to understand the risks they are living within their communities and what actions to take if all those layers of protection are removed in a catastrophic worst-case scenario. This should be a company priority.
Would it be too bold to add updated resource and contact lists, strong connections, and pre-existing relationships with product and service vendors as part of the planning and preparation phase? Much of what is needed in these situations can be anticipated. Building and maintaining these connections in a central and shared location can save time, lives, and critical infrastructure, and benefit neighbouring municipalities and First Nations.
The Canadian Dam Association / L’Association canadienne des barrages has a working group dedicated to emergency management for dams. Their technical standard and associated training workshop are actively working to address the aforementioned gaps. A primary issue, however, is variance in regulation across Canada. Not all provinces require dam owners/operators to have emergency plans for dam failures, let alone test those plans or share them with external stakeholders. Without any regulatory requirements it's left up to individual owners/operators to maintain best practices (and insurance compliance), which includes ICS/IMS adoption.