Archived – Audit of The Canadian Coast Guard - Environmental Response Services

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Project Number 6B091
Final Audit Report
March 18, 2010

Table of Contents

1.0 Executive Summary

1.1 Introduction

The Canadian Coast Guard (CCG) is the lead federal agency for the response component of Canada’s Marine Oil Spill Preparedness Regime.  Environmental Response Services ensures an appropriate level of preparedness and response capability for all ship-source and mystery source pollution incidents in waters under Canadian jurisdiction.  To that end, the CCG implements a consistent approach for responding to marine pollution incidents in all regions of Canada, by monitoring or managing clean-up efforts.

The specific mission objectives of Environmental Response Services are:

  • Minimize the impact of marine pollution incidents on public safety;

  • Minimize the environmental impact of marine pollution incidents; and,

  • Minimize the economic impact of marine pollution incidents.

Each of the five CCG regions applies these mission objectives in their day-to-day operations.  CCG Environmental Response Services headquarters provides the necessary policies, directives, guidelines and systems to support the nationally consistent application of these objectives in all CCG regions in Canada.  

1.2 Objectives and Scope

The audit provided assurance on the core management controls of Environmental Response Services through the following three objectives:

  • Ensure Environmental Response Services are provided in a nationally consistent manner.

  • Human resource practices support the implementation of nationally consistent Environmental Response Services.

  • Equipment required to deliver the Program and Life Cycle and Materiel Management Processes are in place to enable Environmental Response Services to fulfill its mandate.

The audit engagement examined Environmental Response Services from headquarters through to the regional level in the context of a national program audit.  Audit work was conducted both at the headquarters and regional level.  Work consisted of document review, interviews and data analysis.

1.3 Statement of Assurance

In our opinion, the auditors have examined sufficient, relevant evidence and obtained sufficient information and explanations to provide sufficient assurance on the reported opinion or conclusions.

1.4 Summary of Observations and Recommendations

Environmental Response Services responds to an average of 1,300 reported pollution incidents each year, however in the absence of nationally consistent standard operating procedures, a process to capture response information, as well as a process to monitor and review incident responses, there is no assurance that responses are being provided in a nationally consistent manner.  Two key components to incident response are people and equipment.  The Program does not have the human resource practices in place with respect to competency profiles and a national training strategy.  Life Cycle and Materiel Management Processes are also not in place.

As core management controls for Environmental Response Services are either out-of-date, not functioning or not in place, assurance cannot be provided that the conditions exist to enable Environmental Response Services to be provided in a nationally consistent manner.  Significant changes have occurred in the legislation and administrative orders governing the Program and the impacts of these changes to program governance have not been assessed and incorporated in the Program’s management control framework.

On January 21, 2010 the Commissioner, CCG announced that a project to examine the strategic direction of the CCG Environmental Response Services would be undertaken.  Recommendations have been developed to assist the Program in its review of program governance and the subsequent design and implementation of core management controls to enable Environmental Response Services to deliver nationally consistent program.  Specifically, it is recommended that:

  1. The Commissioner, CCG should ensure that program governance is reviewed, and ensure documents are complete, current and up-to-date given the legislative and administrative changes that have occurred. (high significance)

  2. The Commissioner, CCG should ensure nationally consistent, detailed standard operating procedures are developed, reviewed and updated. (medium significance)

  3. The Commissioner, CCG should develop and ensure a process is put in place to allow for monitoring and review of incident responses to ensure compliance to standard operation procedures. (high significance)

  4. The Commissioner, CCG should ensure: (medium significance)

    1. Competency profiles for all positions/functions are developed;
    2. Training requirements are defined for all positions/functions;
    3. A national training strategy is developed to ensure employees receive the required training and that course content remains pertinent; and
    4. A monitoring process is implemented for the national training strategy.

  5. The Commissioner, CCG should ensure that the Program develops a national equipment strategy including Life Cycle and Materiel Management processes in coordination with Integrated Technical Services. (medium significance)

2.0 Introduction

2.1 Background

Pursuant to the Emergency Preparedness Act (now the Emergency Management Act), federal Ministers have a statutory responsibility to ensure each department, agency or Crown Corporation within their area of responsibility has an emergency plan to deal with civil emergencies related to their area of accountability.  Federal government policy for emergency preparedness is to assign lead agency responsibility to the predominant department.

Through legislation such as the Canada Shipping Act, the Arctic Waters Pollution Prevention Act, the Oceans Act, the Marine Liability Act and subject to various interagency agreements, the Canadian Coast Guard (CCG) is the lead federal agency for the response component of Canada’s Marine Oil Spill Preparedness Response Regime.  CCG's Environmental Response (ER) Services monitors or manages the clean-up efforts for any ship-source or mystery pollution incident in waters under Canadian jurisdiction.

As described in program literature, ER Services' specific mission objectives are to:

  • Minimize the impact of marine pollution incidents on public safety;

  • Minimize the environmental impact of marine pollution incidents; and,

  • Minimize the economic impact of marine pollution incidents.

ER Services monitors and investigates all reports of marine pollution in Canada and in conjunction with commercial partners, uses its own resources, such as vessels and pollution countermeasures equipment as required, to respond.  When the polluter has been identified and is willing and able to respond, the CCG will advise the polluter of its responsibilities and, once satisfied with the polluter’s intentions and plans, will assume the role of Federal Monitoring Officer.  However, in cases where the polluter is unknown, unwilling or unable to respond, the CCG will assume the overall management of the incident as On-Scene Commander.  In all cases, CCG ER Services will ensure an appropriate response.

ER Services has approximately 80 personnel and deploys equipment in 12 staffed depots and 70 additional equipment depot sites across Canada.  ER Services maintains duty officers 24/7 (24 hours per day, 7 days per week) in all regions and deals on average with 1,300 reported incidents a year.  For the fiscal year 2008-09 the direct program cost was $9.8 million.  

ER Services operates at headquarters and in five Regions and in five Regions. Headquarters is responsible for developing national training plans, developing national exercise plans, coordinating national human resource plans, developing and maintaining the National Response Team concept of operations as well as developing guidelines, policies and levels of service. Regional activities consist of developing and maintaining human resource plans including retention and recruitment. Regions also conduct training and exercises. Regions in which there are CCG, ER Services are:  Newfoundland and Labrador; Maritimes, Quebec, Central and Arctic, and Pacific.
It should be noted that the audit team was advised by the Program officials that a number of initiatives were underway or planned to address some of these issues.

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2.2 Objectives and Scope

2.2.1 Objectives

A well designed and functioning management control framework helps to ensure that a program is being delivered in a nationally consistent fashion.  As the preliminary survey identified potential issues with some elements of the management control framework, the audit pursued this further to determine if ER Services were being delivered in a nationally consistent manner.  The preliminary survey revealed that two key elements to the delivery of the Program were people and equipment, and that the processes required to support these elements were either not in place, not current or not functioning as intended.  As such, the audit objective was to provide assurance on the core management controls of ER Services through the following three objectives and their supporting criteria:

  • Ensure Environmental Response Services are provided in a nationally consistent manner.

  • Human resource practices support the implementation of nationally consistent Environmental Response Services.

  • Equipment required to deliver the Program and Life Cycle and Materiel Management Processes are in place to enable Environmental Response Services to fulfill its mandate.

2.2.2 Scope

The audit engagement examined ER Services from headquarters through to the regional level in the context of a national program audit.  To answer the objectives, auditors considered the regulatory framework under which the Program is delivered; the Program Governance Framework; the required competencies; and the equipment requirements.  Work consisted of document review, interviews and data analysis. 

2.3 Methodology

Fisheries and Oceans Canada 2009-10 to 2011-12 Multi-Year Risk-Based Audit Plan identified the requirements for an audit of ER Services.  The engagement sought to provide assurance on the core controls supporting the provision of the Program components, taking into account the management model in place.

The engagement complied with generally accepted auditing practices and was conducted according to the Treasury Board of Canada Secretariat Policy on Internal Audit. The work included interviews with departmental officials responsible for the development of the Program along with officials responsible for the implementation and delivery of the Program. 

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3.0 Observations and Recommendations

A management control framework is the suite of controls management has put in place to enable the delivery of a nationally consistent program.  Controls are “any action taken by management, the board, and other parties to manage the risk and increase the likelihood that established objectives and goals will be achieved.  Management plans, organizes and directs the performance of sufficient actions to provide reasonable assurance that objectives and goals will be achieved.”1 There have been significant changes to legislation and administrative orders that govern ER Services in recent years, however the management control framework for the Program has not been reviewed and updated to reflect these changes.  The audit focused on whether the Program was being delivered in a nationally consistent fashion given deficiencies in the management control framework.

To assist management in preparing its management action plan, the audit recommendations have been labeled according to the following three categories to reflect its degree of importance:

  • High significance – major control weaknesses and/or unacceptably high level of risk;

  • Medium significance – control weaknesses affecting operational efficiency and/or credibility; and

  • Low significance – control or process weaknesses contributing to inefficiency.

The items recommended in this report have been brought forward to strengthen the management of the Program.

3.1 Consistency of Program delivery

Assurance cannot be provided that Environmental Response Services are provided in a nationally consistent manner.

ER Services is a national program with services provided in all CCG regions.  As a national program, it is essential that the Program be delivered in a nationally consistent manner.  To ensure delivery of a program in a nationally consistent manner, current, up-to-date documentation defining the mandate and vision for a program including such elements as guidelines, policies and levels of service should be in existence.

Implementation of nationally consistent programs was raised as an area of concern in the 2007 Office of the Auditor General Status Report (Chapter 4 – Managing the Coast Guard Fleet and Marine Navigational Services – Fisheries and Oceans Canada).  In this report, and in two previous reports, the Office of the Auditor General emphasized the need for the CCG to operate as one national institution.  The report made reference to the fact that there were inconsistencies in regional procedures, practices, and organizational structures.  Guidance from headquarters to regional operations was found to be lacking, out-of-date, or too general.

Implementation of a consistent approach for responding to marine pollution incidents in all regions of Canada is stated as the means by which ER Services fulfills its mission.  ER Services utilizes a National Response Team Concept of Operations to provide a framework for a coordinated national response to a marine pollution incident or natural or manmade disaster through the cascading of human and materiel resources from all CCG regions.  Regions utilizing a consistent approach would ensure the successful deployment of the National Response Team.

3.1.1 Program Governance

Pursuant to the Emergency Management Act (formerly, the Emergency Preparedness Act), federal Ministers have a statutory responsibility to ensure each department, agency or Crown corporation within their area of responsibility has an emergency plan to deal with civil emergencies related to their area of accountability.  Federal government policy for emergency preparedness is to assign lead agency responsibility to the predominant department.  The Canadian Coast Guard Marine Spills Contingency Plan is a key element in the department’s overall national emergency preparedness program. 

Through legislation such as the Canada Shipping Act, the Arctic Waters Pollution Prevention Act, the Oceans Act, and subject to various inter-agency agreements, the CCG has lead agency responsibility for ensuring responses to ship-source spills, mystery spills (where the polluter is unknown), and ship-source pollution incidents that occur as a result of loading or unloading to or from ships at oil handling facilities in waters of Canadian interest.

The Canadian Coast Guard Marine Spills Contingency Plan defines the scope and framework within which the CCG will operate to ensure a response to marine pollution incidents.  The Marine Spills Contingency Plan establishes the policies, procedures, management practices and controls that guide staff in accomplishing Program objectives.  The Marine Spills Contingency Plan is divided into three contingency chapters:  National; Regional; and Area. 

The current National Contingency Chapter in promulgation is dated 1998.   Since its issuance, significant changes have occurred in the legislation and administrative orders governing the Program.  The National Contingency Chapter has not been reviewed and updated to reflect these changes to program governance and it does not contain the response model that would be activated to manage CCG’s response to a large-scale or significant incident.  The following section provides an overview of the significant changes to legislative and administrative orders that have occurred. 

  • In 1993, the Canada Shipping Act was amended with changes coming into force in 1998 to incorporate the establishment of the Response Organizations capable of responding to oil spills up to 10,000 tonnes south of 60º north latitude, and ships as defined by the Canada Shipping Act2 that operate in Canadian waters south of 60º north latitude and designated oil handling facilities that must have an arrangement with a certified Response Organizations. 
  • In 2001, the Canada Shipping Act was once more amended with changes coming into force in July 1, 2007 to have the Minister of Fisheries and Oceans designate persons as Pollution Response Officers rather than Pollution Prevention Officers.
  • In 2003, an Order in Council (and the subsequent 2004 Order in Council) resulted in, among other things, the transfer of responsibility for many sections of the Canada Shipping Act, 2001 and associated regulations previously managed by CCG to Transport Canada.  Transport Canada became the lead regulatory/governance agency for managing Canada’s Marine Oil Spill Preparedness and Response Regime.  CCG remained the lead agency for responding to ship-source pollution spills.  This transfer of responsibility resulted in human and financial resources associated with policy and planning being transferred to Transport Canada.  It should be noted that despite the resource and policy gaps created by this transfer, CCG continues to response to an average of 1,300 reported pollution incidents each year. 
  • In 2005, the Canadian Coast Guard became a Special Operating Agency.  As part of the process, a standard organization structure was approved with transition to the new structure to begin in May 2009.

A key element of the management control framework for a program is its program governance documentation.  Based on the legislative and administrative orders governing a program, its program governance documentation is the means by which a program communicates its mandate and vision and is the foundation on which a program is designed.  Significant changes have occurred in the legislative and administrative orders governing ER Services and its Program Governance Documentation has not been reviewed and updated to reflect these changes.   As such, ER Services should review its program governance and ensure its documentation is complete, current and up-to-date.

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3.1.2 Regional Operations and Services

As a national program, regions should provide ER Services in a nationally consistent manner. To ensure national consistency, regional operations should be based on guidance and direction provided by headquarters.  To ensure consistency of regional operations, detailed standard operating procedures should be in place.  In addition, headquarters should have mechanisms in place to monitor regional compliance to policies and procedures.

The Marine Spills Contingency Plan also includes Regional Contingency Chapters that translate policy direction into operational measures appropriate to the geographic area.  The Regional Contingency Chapters are based on the National Contingency Chapter which has not been updated since 1998.  In addition, regions have updated their chapters at different points in time.  The lack of current, up-to-date national direction along with Regional Contingency Chapters updated at different points in time does not provide a foundation upon which to provide nationally consistent regional operations and services.

The audit examined, on a statistical basis, information related to incident responses recorded in the Marine Pollution Incident Reporting System, the system currently being used to capture incident response information. A sample of 105 regional incident responses was reviewed from calendar year 2008 operations to determine if regions were responding in compliance with standard operating procedures.  However, the audit team found that there were no nationally consistent, detailed standard operating procedures, only regional operating procedures that are not approved by headquarters.  Nationally consistent detailed standard operating procedures would assist the program in ensuring regional operations and services are nationally consistent.

Assurance cannot be provided that ER Services are provided in a nationally consistent manner given the lack of current, up-to-date national direction and procedures and that regional documentation has been updated at different points in time.  As previously stated, implementation of a consistent approach to responding to marine pollution incidents is a key element in ER Services implementing its mission and its ability to enact the National Response Team Concept of Operations.  Having core management controls in place to enable the delivery a nationally consistent program will also address concerns raised by the Office of the Auditor General.

Recommendation:

1.  The Commissioner, CCG should ensure that Program Governance is reviewed, and ensure documents are complete, current and up-to-date given the legislative and administrative changes that have occurred. (high significance)

2.  The Commissioner, CCG should ensure nationally consistent, detailed standard operating procedures are developed, reviewed and updated.  (medium significance)

3.1.3 Monitoring and Review of Incident Responses

To ensure regional incident responses are being delivered in a nationally consistent manner and in accordance with national policies and procedures, there should be a mechanism in place to allow for monitoring and review of regional incident responses.  To facilitate this review function, sufficient information must be captured detailing response efforts.

As detailed above, incident response information recorded in the Marine Pollution Incident Reporting System was reviewed.  The audit team noted that the information recorded in the system was insufficient to allow for review of incident responses.  CCG ER Services staff advised that the Marine Pollution Incident Reporting System was not intended to capture incident response information to allow for review of operations.  Implementation of a review and monitoring process would ensure the Program could assess regional compliance to national policies and procedures and ensure nationally consistent operations.  In addition, a review and monitoring process would provide information to allow program management to focus attention on identifying issues and risk mitigation allowing for improved program effectiveness and efficiency.

Recommendation:

3.  The Commissioner, CCG should develop and ensure a process is put in place to allow for monitoring and review of incident responses to ensure compliance to standard operation procedures. (high significance)

3.2 HUMAN RESOURCE PRACTICES

Human Resource practices could better support the implementation of nationally consistent Environment Response Services.

Employees involved in the delivery of a program should have the necessary knowledge, skills and tools to support the achievement of a program’s objectives.  It is through competency profiles and the development of a national training strategy that a program ensures all employees can effectively deliver the program in the prescribed manner. 

3.2.1 Training

Competency profiles and a national training strategy for all positions/functions within a program are essential to ensure the delivery of the program in a nationally consistent manner.  Competency profiles identify the knowledge, skills and tools required for a position/function.  When a program has developed competency profiles for all of its positions/functions, a national training strategy provides a comprehensive approach on how to ensure all employees receive the same knowledge, skills and tools and that these are maintained.  

Competency profiles do not currently exist for all positions/functions within ER Services.  As previously stated, significant changes have occurred in the program governance, including changes impacting human resources.  The designation used by ER Services personnel is set out in the Canada Shipping Act, which also stipulates that it is the Minister of Fisheries and Oceans who may convey this designation to employees. As a result of the amendments to the Canada Shipping Act 2001 coming into force, ER Services personnel previously designated as Pollution Prevention Officers under the old Canada Shipping Act received the new designation of Pollution Response Officers.  This change in designation better reflects the roles and responsibilities that remained with CCG subsequent to the Order in Council in which CCG retained the response portion of the Canada Marine Oil Spill Preparedness Regime. As such, these changes would necessitate the development of competency profiles which would provide the foundation on which training requirements would be established. 

Although the Program does provide training to employees, it is done on an ad hoc regional basis with no assurance that employees are being trained in a nationally consistent manner.  In addition, there is no national monitoring process to ensure employees have the required competencies and that they are kept up-to-date.  Course content has not been reviewed or modified to reflect changes resulting from the governance changes.  The CCG Business Plan 2008-2011 identified the need to develop and deliver Pollution Response Officers training courses to all ER Services personnel.  However, there is no national process in place to monitor employee training to ensure employees have received the required training prior to receiving the designation of Pollution Response Officer or that employee training remains current.

As stated in the National Chapter of the Marine Spills Contingency Plan, the Director, Environmental Response is responsible for establishing and monitoring training curriculum for Federal Monitoring Officer and On-Scene Commander.  A national training strategy does not currently exist for the program.  As well, there is no national process to monitor what training employees have received.  A national training strategy, including a monitoring strategy would help ensure all employees have the required competencies and that they are kept up-to-date.

ER Services utilizes a National Response Team Concept of Operations to provide a framework for a coordinated national response to a marine pollution incident or natural or manmade disaster through the cascading of human and materiel resources from all CCG regions.  The successful deployment of the National Response Team Concept of Operations is predicated on all members having the same knowledge, training and skills.  Without competency profiles upon which to define training requirements, a national strategy to deliver training and a process to monitor training received by employees, there is no assurance that all employees would have the same knowledge, training and skills. 

The Canadian Coast Guard College is the main operational and technical training facility for CCG.  Its mission is to train and develop marine professionals in support of CCG-mandated programs in marine safety, security, and environmental protection.  As CCG’s training centre of expertise, the CCG College aims to deliver quality, bilingual maritime training and services.  However, the relationship with the CCG College has not been formally established with respect to ER Services training requirements. 

Recommendation:

4.  The Commissioner, CCG should ensure that:  (medium significance)

  1. Competency profiles for all positions/functions are developed;
  2. Training requirements are defined for all positions/functions;
  3. A national training strategy is developed to ensure employees receive the required training and that course content remains pertinent; and
  4. A monitoring process is implemented for the national training strategy.

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3.3 Life Cycle and Materiel Management

Life Cycle and Materiel Management Processes are not in place.

In order for a program to function effectively and efficiently, processes and procedures need to be in place and functioning to facilitate Life Cycle and Materiel Management. A risk based process should be in place to determine equipment requirements and placement. All processes should be consistent with the Program Objectives.

3.3.1 Life Cycle and Materiel Management Processes

Life Cycle and Materiel Management (LCMM) is the management of all technical activities associated with equipment or systems through the four phases of its life cycle (conception, acquisition, in-service, and disposal) in an organized and standardized manner to ensure that physical assets continually meet their operational requirements.  Within CCG, the Maintenance Information Management System is the system to be utilized for LCMM. 

Although the Maintenance Information Management System is the CCG designated system for LCMM, it is not currently being used by ER Services.  ER Services has been relying on the Integrated Response Capacity Management System; implemented in 1994 to provide immediate up-to-date information on the operational status of ER Services’ pollution countermeasures equipment.  However, Integrated Response Capacity Management System was not implemented on a national basis as it was not operational in both official languages.  In addition, the system has not been funded since 1998-99, resulting in no maintenance or upgrades having been performed on the application.

A signed Memorandum of Understanding is in place with CCG Integrated Technical Services for LCMM; however it has never been implemented. Funding has been cited as an issue for implementation of the LCMM for ER Services.

Failure to implement the Maintenance Information Management System to facilitate LCMM has resulted in the Program not having current, reliable, up-to-date information on the operational status of its equipment. 

3.3.2 National Equipment Stategy

The CCG maintains specialized pollution response equipment as a safety net above the response capacity of the Response Organisation for south of 60º north latitude and is responsible to maintain a response capacity north of 60º latitude.  Risk-based processes should be in place to determine equipment requirements and placement and to ensure equipment purchases are in accordance with the Program Objectives. 

Equipment requirements and placement are determined on an ad hoc regional basis utilizing local knowledge and availability of equipment.  The last major investment in equipment in the program was as a result of the Government of Canada's Green Plan Initiative in the 1990’s. Since then, there has been no consistent, nationally coordinated investment in equipment.  Equipment acquisitions are on a regional basis and based on the availability of funding throughout the year. 

Given the significant governance changes that occurred over the years, and the lack of a LCMM process, the Program should develop a national equipment strategy along with the implementation of LCMM processes.  

Recommendation:

5.  The Commissioner, CCG should ensure that the Program develops a national equipment strategy including Life Cycle and Materiel Management processes in coordination with Integrated Technical Services. (medium significance)

4.0 General Conclusion

The audit has found that CCG's ER Services are constantly challenged to respond to a large number of incidents on an annual basis, amidst a number of strategic challenges.  These have a direct impact on the program's ability to deliver on its key objectives. 

Core management controls for ER Services are either out-of-date, not functioning or not in place.  As such, assurance cannot be provided that the conditions exist to enable ER Services to be provided in a nationally consistent manner.  Significant changes have occurred in the legislation and administrative orders governing the Program and the impacts of these changes to program governance have not been assessed and incorporated in the Program’s management control framework.

ER Services responds to an average of 1,300 reported pollution incidents each year, however in the absence of nationally consistent standard operating procedures, a process to capture response information, as well as a process to monitor and review incident responses there is no assurance that responses are being provided in a nationally consistent manner.  Two key components to incident response are people and equipment.  The Program could have more supportive human resource practices in place, with respect to competency profiles and a national training strategy.  Life Cycle and Materiel Management Processes are also not in place.

On January 21, 2010, the Commissioner, CCG announced that a project to examine the strategic direction of the CCG ER Services would be undertaken.  Recommendations have been developed to assist the Program in its review of program governance and the subsequent design and implementation of core management controls to enable ER Services to deliver a nationally consistent program. 

5.0 Management Action Plan

Recommendations

Management Action Plan

Status Report Update

Actions Completed

Actions Outstanding

Target Date

1. The Commissioner, CCG should ensure that Program Governance is reviewed, and ensure documents are complete, current and up-to-date given the legislative and administrative changes that have occurred.  (high significance)

 

  1. CCG Environmental Response (ER) Program will engage federal partners in the development and implementation of a governance framework, ensuring the framework is reflective of legislative and administrative changes that have occurred.
  2. CCG ER Program will establish internal ER program governance framework reflective of legislative and administrative changes that have occurred.

 

 

  1. December 31, 2010















  2. December 31, 2010

 

2. The Commissioner, CCG should ensure nationally consistent, detailed standard operating procedures are developed, reviewed and updated.  (medium significance)

 

  1. Revision and implementation of a National Environmental Response Strategy, which will include the development of nationally consistent standard operating procedures for the Environmental Response Program.

 

 

  1. March 31, 2011

 

3. The Commissioner, CCG should develop and ensure a process is put in place to allow for monitoring and review of incident responses to ensure compliance to standard operation procedures.  (high significance)
 

  1. Outline audit and review process to ensure compliance with national policies and procedures consistent with the performance measurement framework for the ER Program.
  2. Develop documentation and process to monitor compliance with national policies and procedures.

 

 

  1. September 30, 2011









  2. September 30, 2011

 

4.  The Commissioner, CCG ensure:  (medium significance)

  1. Competency profiles for all positions/
    functions are developed;
  2. Training requirements are defined for all positions/
    functions;
  3. A national training strategy is developed to ensure employees receive the required training and that course content remains pertinent; and
  4. A monitoring process is implemented for the national training strategy.

 

  1. Competency profiles for all ER positions and functions identified in the event of a major marine pollution incident will be developed.
  2. Training requirements to be defined within a National Training Plan for all ER positions and functions.
  3. National Training Plan to be developed to ensure employees receive the required training and course content remains pertinent.
  4. Implementation of Audit and review process (identified in Recommendation 3) will provide a monitoring mechanism for the national training strategy.

 

 

 

  1. March 31, 2011







  2. September 30, 2011





  3. March 31, 2012








  4. March 31, 2012

 

5. The Commissioner, CCG should ensure that the Program develops a national equipment strategy including Life Cycle and Materiel Management processes in coordination with Integrated Technical Services.  (medium significance)

  1. CCG ER Program, in coordination with Integrated Technical Services, will develop a National Equipment Strategy which will include Life Cycle and Materiel Management processes.

 

 

  1. Sept. 30, 2011

 

 


1 The Institute of Internal Auditors, International Professional Practices Framework, January 2009, p. 40.

2 ship as oil tankers of 150 or more tonnes gross tonnage, ships of four hundred or more tonnes gross tonnage that carries oil as cargo or as fuel, and two or more ships, each of whose gross tonnage is less than 150 tonnes, that carry oil as cargo, that are towed or pushed together and whose aggregate tonnage is 150 or more tonnes gross tonnage.