The Canada-Newfoundland and Labrador Offshore Petroleum Board (C-NLOPB) and the Canada-Nova Scotia Offshore Petroleum Board (CNSOPB) are inviting comments on the jointly developed draft Guideline for the Occupational Health and Safety Regulations (OHS Guideline). The draft OHS Guideline has been developed in the familiar format of the Drilling and Production Guidelines, with the regulatory text in bold italics at the start of each section, followed by the OHS guidance material relevant to the section.
Background:
Those working in the Canada-Nova Scotia and Canada-Newfoundland and Labrador offshore areas must understand and comply with the full occupational health and safety regulatory framework that applies. This regulatory framework begins with the mirrored federal and provincial versions of the Canada‐Nova Scotia Offshore Petroleum Resources Accord Implementation Act, Canada‐Nova Scotia Offshore Petroleum Resources Accord Implementation (Nova Scotia) Act, Canada‐Newfoundland and Labrador Atlantic Accord Implementation Act, and Canada‐Newfoundland and Labrador Atlantic Accord Implementation (Newfoundland and Labrador) Act (collectively referred to as the Accord Acts below). The mirrored federal and provincial regulatory framework continues with the recently published Canada-Nova Scotia Offshore Area Occupational Health and Safety (OHS) Regulations and the Canada-Newfoundland and Labrador Offshore Area Occupational Health and Safety (OHS) Regulations (collectively referred to below as the OHS Regulations).
Regulated entities are responsible to consult the entire OHS regulatory framework, consisting of the OHS provisions of the Accord Acts and the OHS Regulations. The draft OHS Guideline is intended to support regulated entities with their understanding of, and compliance with, the new OHS Regulations, and also to emphasize linkages between relevant guidance sections and the OHS provisions of the Accord Acts. Additional objectives of the OHS Guideline include:
- Providing clarity, where necessary, of the regulator’s interpretation of the regulatory requirement
- Providing commentary on good practise considerations for aspects of the regulation that are more goal oriented
- To support the expectation that Operators and Employers take a holistic consideration of related requirements within the entire legislative framework, drawing attention to related applicable requirements other sections of the Accord Acts, OHS Regulations and within the Part III regulations
- Reduce duplication with other existing guidelines, interpretation notes, directives and safety notices in relation to OHS topics
- Provide clarity on any additional expectations or notes with respect to any documents that have been incorporated by reference; and
- Incorporate lessons learned from OHS-related incidents, assessments, audits and inspections.
The two Boards are currently seeking comments on the draft OHS Guideline. Commentary should be limited to the guidance language; the text in bold italics in the guideline document is the language from the OHS Regulations and is not subject to review/comment as part of this consultation process. The deadline for comments is May 6, 2022.
Comments on these guidelines may be submitted via the following link.
Upon receipt, all submissions will be shared between the two Boards. It is not necessary to make separate comment submissions to each Board.
If you have any questions regarding this consultation, please contact the CNSOPB’s Chief Safety Officer at info@cnsopb.ns.ca or 902-422-5588.