Implementing a Safety and Environmental Management System Within Canadian Regulatory Agency

The National Energy Board (NEB) believes that effective management systems are an integral part of managing safety and protection of the environment. Management systems allow for flexibility while ensuring that a comprehensive approach to managing risk is taken. This paper focuses on taking the systems approach to safety and environmental management in a quasi-judicial regulatory environment, particularly the NEB. The NEB is developing and implementing a Safety and Environmental Management System (SEMS) using the same “principle-based approach” as the internationally recognized ISO 14001 standard and OHSAS 18001 specification. It is the understanding of the NEB that it is the first regulatory agency in Canada to formally implement a safety and environmental management system to improve internal programs and processes. Under the goal-oriented Onshore Pipeline Regulations - 1999, the NEB requires pipeline companies to “develop and implement an environmental protection program to anticipate, prevent, mitigate and manage conditions that have a potential to adversely affect the environment”. While no regulations require the NEB to implement a management system, the NEB is proactively taking its own advice and meeting the same requirements of the companies it regulates. The development and implementation of the SEMS will help to consolidate and integrate internal NEB safety and environmental efforts as well as assist in clarifying their regulatory role, expectations, and responsibilities in regards to safety and environmental protection. The NEB has completed the first step of the development and implementation of the SEMS, including the development and communication of the NEB Environmental Policy and a draft of an integrated Safety & Environmental Policy; identification of objectives, targets and performance indicators; and improvements to existing programs and processes. The NEB Environmental Policy will be phased out once the integrated policy is approved and communicated. The second step includes conducting a detailed gap analysis to identify and prioritize areas for improvement as well as integrating the SEMS into the existing NEB business planning cycle. By fully incorporating the defined SEMS into the annual NEB business planning cycle, the management system approach will be used as the basis for setting internal safety and environmental priorities, work planning and continual improvement.