Emergency Response Task Force

First Quarterly Report and Recommendations

PRESENTED TO 
DIRECTOR GENERAL,
TRANSPORTATION OF DANGEROUS GOODS

November 17, 2014

Table of Contents

Executive Summary

The Minister of Transport announced the creation of the Task Force under the Transport Dangerous Goods Directorate (TDG Directorate) on April 23, 2014, to work on strengthening emergency response capacity across the country.

The Task Force’s main focus is the transportation of flammable liquids by rail. Its primary objective is to improve public safety at dangerous goods incidents involving flammable liquids transported by rail. The Task Force also has the mandate to conduct further research, assess, evaluate and make recommendations to advance and make improvements to the Emergency Response Assistance Plan (ERAP) program. The Task Force has generated much interest and stakeholder engagement from Transport Canada, the provinces, territories, First Nations and municipalities, the rail and petroleum industries, first responder communities and the public.

The Terms of Reference was agreed upon by Task Force members and signed by the Chair, Vice-chair and Director General, TDG on September 9, 2014.Footnote 1

The Task Force is supported by a Secretariat responsible for the coordination and facilitation of Task Force meetings and activities, including the Task Force website (https://www.tc.gc.ca/eng/tdg/safety-menu-1186.html). The website was launched in July 2014, and updated regularly in order to provide information on the Task Force, such as the membership list, an activity calendar, meeting agendas and decision records.

During its monthly meetings and weekly subgroup meetings, the Task Force discussed topics concerning flammable liquids incidents by rail, including emergency response, Incident Command Systems (ICS) and expanding on the Protective Direction 33 (PD 33) [http://www.tc.gc.ca/eng/mediaroom/protective-direction-33-7494.html]. To date, these discussions have led the Task Force in identifying the following key issues:

  • Awareness and training;
  • Lack of data;
  • ICS coordination challenges; and
  • Ethanol being transported to, or transiting through, Canada from a U.S. origin.

The Task Force addressed these key issues by proposing solutions in the form of recommendations for Transport Canada’s consideration, such as:

  • The inclusion of information on the Canadian ERAP program in the 2016 Emergency Response Guidebook in order to address the lack of awareness surrounding the ERAP program;
  • The exploration of further project collaboration opportunities with the Defense Research and Development Canada (DRDC)-Centre for Security Science (CSS) to address ICS coordination challenges when multiple agencies are involved in an incident, the lack of data and to increase awareness and training opportunities;
  • The addition of Ethanol being shipped as UN1987 as a classification requiring an ERAP under PD 33 to close a gap concerning Ethanol originating in the U.S. and being transported to, or transiting through, Canada; and
  • The creation of an ongoing Outreach and Awareness program to address topics relating to the ERAP program, the Canadian Transport Emergency Centre (CANUTEC), Protective Direction 32 (PD 32) [http://news.gc.ca/web/article-en.do?nid=829079], PD 33, the Task Force and the Transportation of Dangerous Goods (TDG) - General Policy Advisory Council (GPAC) to increase awareness and training opportunities.

In addition to the recommendations mentioned above, the Task Force has requested Transport Canada’s assistance in the collection and analysis of data that is required to pursue its work. The need for this information was identified in the ERAP Working Group report of January 31, 2014. The Task Force Secretariat has identified various sources of information, and work is now underway to collect and analyze the information with the support of the industry, as well as several branches within the Department.

Task Force members are committed to continuing their work, conducting further analysis and providing more recommendations to improve safety and emergency response to incidents involving flammable liquids transported by rail. The Task Force has a mandate of one year and is expecting to submit its final report to the Director General, TDG on June 30, 2015.

Comments from the Chair

The unprecedented growth in shipments of crude oil by rail has created new challenges in moving this product safely to market. Many initiatives are underway to reduce the frequency and severity of derailments including new railway operating rules, improved tank car design, review of classification standards, risk assessments and providing municipalities and First Nations with information on dangerous goods transported through their communities. Unfortunately, even the best efforts to prevent incidents cannot guarantee they will not occur. However, effective emergency planning, training and response are required to mitigate the effects of the incident.

The Task Force presents a unique opportunity for a broad spectrum of stakeholders to work together with a single objective of improving public safety at dangerous goods incidents involving flammable liquids. The Task Force will study and recommend improvements to the ERAP program and on how to better communicate to first responders, community leaders and the public, the services and programs provided by Transport Canada’s TDG Directorate and industry partners.

The Task Force has multiple subjects to consider and a relatively short time to provide Transport Canada with comprehensive and practical recommendations. The members have been very active and engaged as they have undertaken to define the issues, receive information and concerns from various stakeholders and begin the process of identifying how to best address these subjects. While some recommendations have already been approved by the Task Force for consideration by Transport Canada, there are many areas where more in-depth analysis and understanding of opposing or differing positions must be carried out. However, the main objective of the Task Force must continue to be: How can we improve the safety of Canadians and how can each stakeholder contribute to that outcome?

The following points highlight some of the strengths and capacities of key stakeholders that need to be made available, coordinated and deployed when a flammable liquids derailment endangers public safety:

  • The petroleum industry has expertise in working with flammable liquids as this industry understands their properties and behaviour in a fire or spill situation. They also have facility personnel with expertise in flammable liquid firefighting tactics and procedures. This type of expertise needs to be available to communities through the ERAP program.    
  • The railway industry has put significant effort into developing emergency response plans, providing railway dangerous goods specialists who are able to provide assessments of tank car damage, safety issues and procedures for working at derailments.    
  • Emergency response contractors have capacities for product transfer, remediation and restoration.   
  • Transport Canada has expertise available through Canadian Transport Emergency Centre (CANUTEC) and Remedial Measures Specialists (RMS) to provide advice and assistance to first responders.  
  • Communities can prepare for this type of incident by training and equipping first responders, including fire, police and emergency medical service, and by developing community emergency plans to protect residents.

If the Task Force recommendations are approved and implemented, there will be a high level of stakeholder participation, cooperation and deployment of resources in respond to an emergency. This collaboration will result in improving the safety of Canadians.

Comments from the Vice-chair

Building upon the Chair’s remarks and also considering Protective Direction 33(PD 33), the possible expansion of ERAP requirements to other flammable liquids as well as the establishment of the Task Force, many stakeholders have become re-engaged in the consultation process of determining what is an appropriate response to a dangerous goods incident. 

Significant changes to legislation have been made since the Grange Inquiry Commission’s (Report of the Mississauga Railway Accident Inquiry, December 1980) original recommendation that the “shipper” provide on-scene expert technical advice to authorities at a dangerous goods incident. For example, the Transportation of Dangerous Goods Act, 1992 (TDG Act) and Transportation of Dangerous Goods Regulations (TDG Regulations) now have requirements for an ERAP, a definition of a “shipper” as an “offerer” or “importer”, and allows for others to use a producer’s or manufacturer’s approved ERAP under specified conditions. Furthermore, environmental protection gained prominence against pollution and restoration became obligatory. Other examples of developments in society and industry over these years include:

  • Provinces, territories, municipalities and First Nations now have emergency plans and services such as pre-planned community evacuation routes, 911 and paramedic / ambulance services (EMS).
  • Organizations have developed or adopted recommended dangerous goods emergency response training and practices such as ICS and NFPA 472 Standard for Competence of Responders to Hazardous Materials/Weapons of Mass Destruction Incidents.
  • Industry experience with transportation emergency response plans whether in-house, mutual aid, collective and/or for hire (e.g. Transportation Emergency Assistance Program III [TEAP III], Eastern Canada Response Corporation Land Spill Emergency Planning [ECRC LSEP], Liquefied Petroleum Gas Emergency Response Corporation [LPGERC]) have improved their capabilities. 

These developments and others will be shared and examined in a comprehensive technical review to find the best practice for effective response to a railway flammable liquids incident. Using modern transportation risk assessment, incident hazard analysis and incident management systems along with increased awareness and the use of consistent terminology should lead to improvements for flammable liquids or other dangerous goods incident responses. Ultimately, the intent of the process is to provide Transport Canada useful insight and recommendations in the areas of regulation, policy, interpretation or guideline.

Background

Traditionally, most crude oil produced in North America was transported by pipelines. Because of the lack of pipeline or pipeline capacity, the transportation of crude oil by rail has become an important means of moving this product to refineries. Information from the Railway Association of Canada (RAC) indicates that shipments of crude by rail in Canada have risen exponentially since 2009. In its June 2014 Report, the Canadian Association of Petroleum Producers forecasts crude oil volumes transported by rail will increase from about 200,000 barrels per day in late 2013 to around 700,000 barrels per day by 2016.Footnote 2

The July 2013 incident at Lac-Mégantic confirmed the need to put in place initiatives intended to adjust the TDG program.

“On July 6th, 2013 a seventy-three (73) car Montreal, Maine & Atlantic train carrying Bakken crude oil rolled away from where it had been parked and derailed in downtown Lac-Mégantic. The train had been parked uphill of Lac-Mégantic, approximately eleven (11) km. west of town, at Nantes Quebec, before it rolled downhill into the town. The unmanned train derailed in an area near the grade crossing where the rail line crosses Frontenac Street, the town's main street. The equipment that derailed included sixty-three (63) of the seventy-two (72) tank cars as well as the buffer car. The nine (9) tank cars at the rear of the train remained on the track and were pulled away from the derailment site and did not explode.

The Lac Mégantic fire service responded to this incident and asked for and received mutual aid assistance from numerous fire departments in Quebec and the State of Maine. Hundreds of firefighters were eventually deployed for many days and most were volunteer firefighters. The large volume of fire and the heat generated created tremendous safety risks for these firefighters. Firefighting foam was brought from an Ultramar refinery in Lévis, Québec and was used to control the remaining fire and suppress vapors from unburned crude oil. The Chaudière River was contaminated by hundreds of thousands of liters of oil as was the sewer system and soil in the vicinity of the derailment.

This incident resulted in the death of forty-seven (47) individuals and destruction of the downtown core of the town. The financial costs will run into the hundreds of millions of dollars.

The tragedy in Lac Mégantic has focused attention on the impact of dangerous goods incidents on public safety. The incident in Lac Mégantic is so overwhelming in scale and devastation that it is difficult to comprehend how a small community can begin to cope and recover”.Footnote 3

Transportation Safety Board

On January 23, 2014, the Transportation Safety Board (TSB) issued the following additional Rail Safety Recommendations:

“2.2.1 TSB Rail Safety Recommendations, 23, January, 2014

As part of its ongoing investigation into the Lac-Mégantic accident, the TSB has identified three key safety issues that must be addressed to further improve the safety of the Canadian rail system:

  • vulnerability of Class 111 tank cars to sustain damage,
  • route planning and analysis for trains carrying dangerous goods, and
  • requirements for emergency response assistance plans.

2.2.2 Requirements for emergency response assistance plans (R14-03)

An Emergency Response Assistance Plan (ERAP) is required by the Transportation of Dangerous Goods Regulations for certain goods that pose a higher-than-average risk when transported in certain quantities. When there is an accident, the handling of these dangerous goods requires special expertise, resources, supplies and equipment. An approved ERAP will describe the specialized response capabilities, equipment and procedures that will be available to local emergency responders and will assist emergency responders in addressing the consequences of the accident.

The risks posed by specific dangerous goods are determined based on the properties, characteristics and quantities of the dangerous goods being transported. Importers, as well as persons who offer for transport a dangerous good that requires an ERAP, must have an ERAP approved by TC.”Footnote 4

Previous TSB Recommendation:

Following the TSB investigation into the 1999 derailment, collision and subsequent fire of a CN unit train carrying flammable liquid hydrocarbons in tank cars near Mont-Saint-Hilaire, Québec (TSB report R99H0010), the Board determined that a comprehensive emergency response plan, where roles, resources and priorities for emergency response are defined ahead of time, would enhance the emergency response and alleviate post-accident risks. The Board recommended that:

“Transport Canada review the provisions of Schedule I and the requirements for emergency response plans to ensure that the transportation of liquid hydrocarbons is consistent with the risks posed to the public.” (R02-03, issued June 2002)Footnote 5

The TSB also included the following in the 23 January 2014 recommendations:

The transportation of large volumes of flammable liquids, such as petroleum crude oil, does not currently require an ERAP. However, approved ERAPs would consistently ensure that first responders have access, in a timely manner, to the required resources and assistance in the event of an accident involving significant quantities of flammable hydrocarbons.

In November 2013, an Emergency Response Working Group (Working Group) was established by the Transportation of Dangerous Goods General Policy Advisory Council. The Working Group is chaired by the Canadian Association of Fire Chiefs and is tasked to examine the possibility of extending the ERAP program to include flammable liquids such as crude oil or to recommend other viable emergency response solutions to accomplish a similar goal of ensuring access to appropriate response capability and specialized supplies. The Working Group’s recommendations are expected to address short-term or longer-term solutions or actions that TC can take to enhance emergency response.

The Board acknowledges this TC initiative. Given the significant increase in the quantities of crude oil being transported by rail in Canada, and the potential for a large spill with the risks it would pose to the public and the environment, the Board recommends that, at a minimum:

The Department of Transport require emergency response assistance plans for the transportation of large volumes of liquid hydrocarbons.” (TSB Recommendation R14-02)Footnote 6

On April 23, 2014, Minister of Transport, Lisa Raitt, announced the issuance of PD 33 which requires that:

“No person shall offer for transport or import dangerous goods listed in 2) by rail, in a tank car, if one or more of the rail tank cars in a train are each filled to 10 per cent or more of its capacity, unless the person has an Emergency Response Assistance Plan (ERAP) approved in accordance with section 7 of the Act;

The dangerous goods to which this Protective Direction applies are: UN1170 ETHANOL, UN1202 DIESEL FUEL, UN1203 GASOLINE, UN1267 PETROLEUM CRUDE OIL, UN1268 PETROLEUM DISTILLATES, N.O.S., UN1863 FUEL, AVIATION, TURBINE ENGINE, UN1993 FLAMMABLE LIQUID, N.O.S., UN3295 HYDROCARBONS, LIQUID, N.O.S., or UN3475 ETHANOL AND GASOLINE MIXTURE;” Footnote 7

On the same date, the Minister announced the creation of the Task Force under the TDG Directorate to work on strengthening emergency response capacity across the country. The Task Force would be composed of representatives from municipalities, First Nations, first responders, railways and shippers. The TDG Directorate began work on establishing the Task Force and, by May 2014, had identified Transport Canada personnel to form a Secretariat to support the Task Force, located office space and drafted Terms of Reference for the Task Force. In June 2014, the Secretariat staff began work. Concurrently, the process to select a Chair and a Vice-chair to preside over the Task Force commenced.    

Chris Powers, with over 40 years of knowledge and experience in the management of career and composite fire departments, was selected as Chair and began work on June 16, 2014. A call to membership was launched to solicit members for the Task Force from a cross section of stakeholders. Invitations were sent to organizations represented at the TDG-GPAC with a specific interest in the transportation of flammable liquids by rail. The summer vacation period made contact and confirmation of membership a challenge but nevertheless there was a positive response and most stakeholders expressed an interest in participating on the Task Force. During this time, Louis Laferrière was selected as Vice-chair. His extensive experience has proven to be invaluable in providing in-depth knowledge of the industry sector and the ERAP program that has been in place and used successfully by other industry sectors for many years.

Over the subsequent weeks, a number of additional organizations either requested the opportunity to participate or were identified as sectors that should be included. As a result, the Task Force has continued to evolve and membership has grown from an initial estimate of 15 to 20 representatives to some 45 members plus delegated or alternate representatives on both the Task Force and its Subgroups. This level of participation indicates the importance in developing an effective ERAP program to a diverse body of organizations. The high level of interest and participation is a very positive reflection on the Task Force.

Please refer to Annex B for a complete list of Task Force members.

Terms of Reference and Work Plan

Task Force members, TDG-GPAC and Federal/Provincial/Territorial Task Force members received a copy of the draft Terms of Reference for review and input. Members of these groups suggested changes and clarifications which the Chair and Secretariat considered in preparing a revised document. Task Force members had another opportunity to review the Terms of Reference, and approved the revisions before the document was finalized. The Terms of Reference was agreed upon and signed by the Chair, Vice-chair and Director General, TDG on September 9, 2014Footnote 8

Concurrently, a high level work plan was being developed to reflect the various components included in the Terms of Reference, specifically elements of the ERAP program examination that need to be addressed in order to move forward with the project’s mandate. From this, subgroups were created to study and make recommendations to the Task Force on the elements identified in the Terms of Reference. The work plan also allowed for improved prioritization and time management.

As per the Terms of Reference, the Task Force will provide reports and recommendations to the Director General, TDG, including: three quarterly reports at the end of October 2014, January 2015 and March 2015, respectively, and a final report on June 30, 2015. 

Emergency Response Task Force Meetings

Inaugural Meeting (July 10, 2014)

Members of the Task Force have been meeting every month. The inaugural meeting occurred on July 10, 2014. During this meeting, members were welcomed by Director General, TDG, Nicole Girard, who talked about the importance of the Task Force initiative and its mandate. She also introduced the Chair, Chris Powers, and Vice-chair, Louis Laferrière.

Members discussed the draft Terms of Reference as well as membership status and participation. Members agreed to include a provision in the Terms of Reference allowing the review of the membership list to allow flexibility and adequate representation from all stakeholders.

Please refer to list Annex B for a complete list of Task Force members.

The Chair presented a high level work plan developed to reflect the various components of the Terms of Reference that would need to be addressed over the coming months. 

Second Monthly Meeting (August 14, 2014)

On their second monthly meeting held on August 14, 2014, the Chair suggested that the deliverables identified in the Terms of Reference and work plan be further broken down into categories, divided into manageable tasks, prioritized and carried out by subgroup working groups. Subgroups would allow the Task Force to start making recommendations for Transport Canada to action as soon as possible and as deliverables are completed. The work plan was discussed and approved by members who also supported the creation of the following subgroups:

  • Subgroup 1 will focus on building on PD 33 for the transportation of flammable liquids by rail as well as on the industry approach to emergency response.
  • Subgroup 2 will focus on incident command and management, including clarification of ERAP roles and responsibilities, and outreach strategies.
  • Subgroup 3 will focus on the potential expansion of the ERAP requirement to other flammable liquids transported by rail.

Subgroup members agreed to meet on a weekly basis and report to the Task Force at monthly meetings.

Two presentations were made:

  1. Fire Chief Denis Lauzon, Lac-Mégantic, presented a comprehensive review of the incident on July 6, 2013 and the multiple challenges experienced by the first responders and the community when faced with such a catastrophic incident.
  2. Spencer Buckland from LPGERC—now operating as Emergency Response Assistance Canada (ERAC)—presented an overview of the work done on the ERAC ERAP program. This program offers a cooperative approach in ERAP services provided by a number of companies to registered members.

During discussions, members acknowledged that the ERAP program is not well known or understood. CANUTEC indicated that the development of the 2016 Emergency Response Guidebook was currently underway and invited members to submit comments and feedback by September 18, 2014. 

Recognizing that the 2016 Emergency Response Guidebook is an opportunity to increase awareness on ERAPs:

  • Task Force members are recommending that Transport Canada support a request to include basic information on the ERAP program in the reference section of the 2016 Emergency Response Guidebook and mark products that are required to have an ERAP with a Canadian logo for ease of reference.

Third Monthly Meeting (September 11, 2014)

At this meeting, two presentations were made:

  1. Patrick Juneau, Special Advisor, TDG, informed the members of research that the TDG Directorate was conducting on the testing and evaluation of crude oil properties to better evaluate the various crudes.
  2. Monica Blaney, Chief of TDG Research and Risk Evaluation, presented the pilot project conducted in British Columbia’s Lower Mainland to map various transportation routes, origin and destination, facilities, etc. and how that project could assist in providing the TDG program with a comprehensive mapping of dangerous goods movements.

Subgroups presented their progress reports to the Task Force:

  • Subgroup 1 has been meeting weekly, on Fridays, since August 29, 2014 and will do so until mid-December 2014. The discussion focused on building on PD 33 for the transportation of flammable liquids by rail as well as on the industry approach to emergency response. So far, this subgroup has corroborated and validated the TDG ERAP review process for incident hazard scenarios involving a railway flammable liquids spill/fire.
  • Subgroup 2 has been meeting weekly, on Wednesdays, since August 27, 2014 and will continue until mid-December 2014. The discussion focused on incident management and command, including clarification of ERAP roles and responsibilities, and outreach strategies. So far, members have been working on identifying gaps and data needs and to assist with this task, a survey on roles and responsibilities has been completed by members.

The Task Force also identified that large quantities of Ethanol are being shipped either through or to Canada from the United States under UN1987. Since UN1987 is not captured in PD 33 and in order to ensure equitable treatment of both shippers in Canada and the U.S.:

  • Task Force members are recommending that Transport Canada proceed in including Ethanol being shipped under UN1987 as part of the primary ERAP requirements for Class 3 flammable liquids, and that Transport Canada proceed with advising those shippers that may be impacted by this recommendation so they may act accordingly with respect to ERAP requirements.

The Task Force members reached consensus on this recommendation with expressed support from the American Renewable Fuels Association.

Subgroup 3 will be examining and assessing options for the potential expansion of the ERAP requirement to other Class 3 flammable liquids as well. However, in order to facilitate the work of the Task Force and its Subgroups, there is a requirement to provide the necessary data and information on which the members can base their recommendations.

Recognizing that such data and analysis is crucial for the Task Force work, and as per the Terms of Reference:

  • Task Force members are requesting assistance from Transport Canada for the collection of the necessary data and information from various sources, and to facilitate analysis and distribution of the data and information to members of the Task Force.

 Members also discussed the mandate and work of the Defense Research and Development Canada – Centre for Security Science (DRDC-CSS), and the aspects of the Centre’s work that could be of benefit to the Task Force and Transport Canada. As a result:

  • The Task Force is recommending that Transport Canada work with the DRDC- CSS to:
    • Explore opportunities for collaboration on the existing CSS Eastern HAZMAT project;
    • Allow Transport Canada access to information from the Canadian Targeted Capability List-Canada, a framework describing the capabilities related to major all-hazards events;
    • Explore areas where CSS Operational Research Expertise can assist the Task Force in the areas of risk (human health/economic), multi-disciplinary information sharing (such  as the Multi-Agency Situational Awareness System [MASAS] and response standards);
    • Explore opportunities to engage with the CSS on their Incident Exercise program to improve the understanding of roles and responsibilities of various agencies and industry when responding to TDG incidents; and
    • The Task Force will explore possible scenarios to exploit the CSS’ exercise development and funding program. This program utilizes exercise of small and large scale, tabletop to full scale live exercises to develop and validate response planning. Exercises such as the current Transport Canada ERAP exercise series should be developed to practice and validate Incident Command Management and Structure, expanded ERAP, increased CANUTEC abilities etc. identified by the Task Force.

During this meeting, the Task Force Secretariat provided the following update to members:

  • The Secretariat confirmed the submission to CANUTEC of the Task Force recommendation no. 1—that Transport Canada support a request to include basic information on the ERAP program in the reference section of the Guidebook and mark products that are required to have an ERAP with a Canadian logo for ease of reference.
  • Following the request for data and analysis, the Task Force Secretariat also informed members that various sources of information were identified and advised that industry’s assistance may be required in collecting part of the data. With the support of the TDG Directorate and other Directorates within Transport Canada, work is now underway to collect that information.

Fourth Monthly Meeting (October 9, 2014)

The meetings of Subgroups 1 and 2 were rescheduled to occur every second week, rather than weekly. This change was necessary to give all participants and the Task Force Secretariat sufficient time to prepare for the meetings at a more reasonable pace.

Subgroup 1 continued discussing the PD 33 technical requirements and started identifying the expectations for an ERAP holder’s “Flammable Liquids Technical Advisor.” It was agreed that the development sequence for describing this and other positions would be to first create a job description, then identify competency criteria and finally, the associated training, experience and authorization requirements. Members also stated the need for a lexicon of terminology that would help provide consistency in the use of terms and references by various stakeholders.

Subgroup 2 continued to review various ICS that are currently used as standard practices by different jurisdictions and how a common system could be recommended for use across Canada. The necessity of training and exercises with all parties working together was recognized as critical to the effective implementation of an ICS at an incident. Members reviewed the TEAP III presentation on a Disciplined Approach to dangerous goods incidents and discussed possible modifications to make it specific for flammable liquids incidents.   

Members discussed the need to improve knowledge and increase municipalities and first responders’ awareness of the TDG programs. For example, members expressed the need for a better understanding of the following:

  • ERAP Program – What it is; how it is intended to assist first responders and communities; types of dangerous goods covered; how it is activated; etc.
  • RMS - Who are TDG RMS staff; what is their training and qualifications; what their duties are and their role at a dangerous goods incident.
  • CANUTEC – What it is; how it can be accessed; what services are provided; who are the CANUTEC advisors; their training and qualifications; etc.
  • PD 32 - The purpose and intent of PD 32 to assist municipalities in planning for dangerous goods incidents, and how to register to request the information.
  • PD 33 - Flammable liquids subject to PD 33 and the nature of the advice and resources to be made available under the ERAP required by PD 33.
  • Emergency Response Task Force – Its mandate, membership and activities.
  • TDG-GPAC - Its mandate, membership and activities.

Members of the Task Force acknowledged Transport Canada’s formal and informal outreach and awareness engagement efforts. However, recognizing the limited capacity for Transport Canada officials to participate in all possible opportunities for outreach and awareness, the Task Force is suggesting that information and training materials (e.g. PowerPoint, videos, hand-outs, pocket cards, web links etc.) on Transport Canada TDG services be made available to other stakeholders such as the Canadian National Railway (CN), the Canadian Pacific Railway (CP Rail) and the Railway Association of Canada (RAC) as well as the Federation of Canadian Municipalities (FCM), the Canadian Association of Fire Chiefs (CAFC), the Canadian Association of Chiefs of Police (CACP), etc. This material could be included when their respective members are making presentations to municipalities and first responders. The material could also be provided to the Provincial and Territorial Fire Marshals and Fire Commissioners, as well as Fire Service Training organizations to be included in fire department dangerous goods / hazmat training programs.

As a result,

  • Task Force members are recommending that Transport Canada further promote and improve knowledge and understanding of various aspects of TDG activities and programs with an Outreach and Awareness program as an ongoing activity that will address, among other topics, the following:
    • ERAP Program;
    • Roles of TDG RMS;
    • CANUTEC;
    • PD 32;
    • PD 33;
    • Emergency Response Task Force; and
    • TDG-GPAC.

Louis Marcotte, Chief of TDG Response Operations, provided an update of the approvals and status of the ERAP applications received by the Directorate. The TDG Directorate has received approximately fifty-four (54) ERAP applications. Of these, twenty-nine (29) were individual plans and twenty-five (25) were cooperative plans, meaning they share the same response organization. The vast majority of these applications were received in the week of September 15 to 19, 2014. An additional fourteen (14) cooperative plan applications are expected, as well as an unknown number of individual plans. 

He also informed members that Transport Canada is issuing approvals under one of these four scenarios:

  1. a sixty-day interim approval while Transport Canada reviews complete ERAP application submitted by September 20th;
  2. a six-month interim approval for plans which are substantially complete but for which a thirty-day action plan is required to be submitted for specific items partially addressed;
  3. a three-year interim approval (a site visit by Transport Canada will be required for the final approval); or
  4. a refusal (for incomplete ERAP submission).

He indicated that as of October 2014, Transport Canada has issued:

  • Thirty-two (32) 60-day interim approvals (all are individual plans);
  • One (1) 6-month interim approval that includes forty-seven (47) participants (all part of a cooperative plan);
  • One (1) interim approval (three years) [individual plan]; and
  • Two (2) letters of refusal have been delivered.

CANUTEC informed members that the recommendation for inclusion of information on Canadian ERAPs in the 2016 Emergency Response Guidebook continues to be included in possible updates for the new edition, and that discussions with American and Mexican counterparts were underway.

A comprehensive presentation on the U.S. Ethanol industry was made by Kristy Moore of the American Renewable Fuels Association. Approximately forty-five per cent (45%) of the Ethanol exported from the U.S. is shipped to Canada with an estimated ninety-nine per cent (99%) shipped as “Alcohol Not Otherwise Specified” under UN1987, as per U.S. regulations. Ms. Moore indicated she will attend the Task Force monthly meeting in November and provide additional information on the Ethanol Emergency Response Coalition’s training program which she indicated her association would be willing to share and translate into French for Canadian use.

Jim Kozey of CP Rail provided a presentation on the CP Rail Emergency Response Procedures and the extensive work done by CP Rail on providing specialized equipment at key locations across their network. The equipment includes semi-trailers with an impressive inventory of spill control and containment equipment, shipping containers with adsorbent materials, and a well designed series of foam firefighting trailers with hose adapters, pump, foam supplies and other accessories. These resources are available to other railways as part of a mutual aid agreement.

During the discussions, first responders acknowledged the availability of this equipment and resources during incidents for which they were grateful, while indicating that they did not always know how to use it, thus emphasizing the need for training.

Key Issues and Recommendations from the Task Force

As summarized in the previous section (i.e. Emergency Response Task Force Meetings), the Task Force monthly meetings and the subgroup meetings have resulted in many productive discussions. Task Force members have identified the following key issues:

  • Awareness and training;
  • Lack of data;
  • ICS coordination challenges; and
  • Ethanol transported to or transiting through Canada from a U.S. origin.

Task Force members are asking Transport Canada to consider the following recommendations as a starting point in addressing these key issues.

Recommendation No. 1 – 2016 Emergency Response Guidebook ERAP Information

Task Force members identified that there is a lack of awareness concerning the ERAP program amongst first responders and municipalities. Therefore on the need to increase ERAP program awareness, including those dangerous goods requiring an ERAP:

  • Task Force members are recommending that Transport Canada support a request to include basic information on the ERAP program in the reference section of the 2016 Emergency Response Guidebook and mark products that are required to have an ERAP with a Canadian logo for ease of reference.

Recommendation No. 2 – Opportunity for Collaboration with the Defense Research and Development Canada - Centre for Security Science (DRDC-CSS)

Task Force members addressed the challenges concerning the lack of awareness, training and the need to improve coordination during incidents involving multiple agencies amongst all the parties. The DRDC-CSS was identified as an organization that could provide support in information sharing in a variety of ways that can assist the Task Force and Transport Canada.

The CSS was established in 2006, via a signed agreement between the Department of National Defense and Public Safety Canada. The CSS’s primary responsibility is to lead the Canadian Safety and Security Program. The Canadian Safety and Security Program is a horizontal effort to strengthen Canada’s ability to cope with disasters, whether they are natural, caused by human error or by malicious intent. The Centre also manages the Emergency Responder Test and Evaluation Establishment.

CSS leverages expertise from all levels of government, industry, academia and emergency management organizations. CSS activities address a broad range of public safety and security priorities, including:

  • Chemical, Biological, Radiological-Nuclear and Explosives Threats;
  • Critical Infrastructure Protection (physical and cyber);
  • Surveillance, Intelligence and Interdiction;
  • Emergency Management Systems;
  • Public Safety Interoperability;
  • Domestic Operations Support; and
  • Emergency Responder Safety and Operational Effectiveness.

Through this collaborative approach, CSS engages partners in a broad range of activities, including projects, workshops and exercises. It also manages a vast network of national and international experts who work together through communities of practice.

In addition, CSS provides evidence-based advice and guidance to support planning, decision-making, operations, and the development of public safety and national security strategies and policies. This is enabled through a network of partners, as well as in-house expertise in capability-based planning, risk assessment, operations research, knowledge management, exercises and support to domestic operations.

Recognizing that there is an opportunity to review and improve ICS and Incident Management System (IMS) protocols during the transportation of dangerous goods incidents, the Task Force is proposing to further explore the opportunities to engage with the DRDC-CSS, on common areas of interest that would benefit the work of the Task Force and Transport Canada in its TDG program development efforts.

The Task Force is recommending that Transport Canada work with the DRDC-CSS to:

  • Explore opportunities for collaboration on the existing CSS Eastern HAZMAT project;
  • Allow Transport Canada access to information from the Canadian Targeted Capability List-Canada, a framework describing the capabilities related to major all-hazards events;
  • Explore areas where CSS Operational Research Expertise can assist the Task Force in the areas of risk (human health/economic), multi-disciplinary information sharing (such as the MASAS and response standards);
  • Explore opportunities to engage with the CSS on their Incident Exercise program to improve the understanding of roles and responsibilities of various agencies and industry when responding to TDG incidents; and
  • The Task Force will explore possible scenarios to exploit the CSS’ exercise development and funding program. This program utilizes exercise of small and large scale, tabletop to full scale live exercises to develop and validate response planning. Exercises such as the current Transport Canada ERAP exercise series should be developed to practice and validate Incident Command Management and Structure, expanded ERAP, increased CANUTEC abilities etc. identified by the Task Force.

Engaging with the DRDC-CSS would also help increase awareness and training opportunities.

Recommendation No. 3 - Ethanol U.S. Classification

The Task Force identified a gap in PD 33 relating to Ethanol being shipped to Canada from the U.S., and also through Canada as “bridge traffic” (i.e. from a U.S. origin and back into a U.S.) under UN1987. As a result, PD 33 captures Ethanol under UN1170 and UN3475, but does not capture UN1987.

As identified in subsection 4.2 of the ERAP Working Group report dated January 31, 2014, Ethanol represents a significant volume of flammable liquids being transported by rail. It is also recognized that “these “bridge traffic” rail movements need to be included in the risk assessment for those communities along the transportation route of these or other trains moving flammable liquids which do not originate or terminate in Canada”.Footnote 9

According to the American Renewable Fuels Association, forty-two per cent (42%) (174.1 million gallons) of Ethanol exported from the U.S. comes to Canada. The U.S. exports the most Ethanol to Canada compared to other countries. The Canadian Renewable Fuels Association has “indicated that over 1 billion litres of ethanol is imported to Canada each year primarily by rail.”Footnote 10

Consequently, in order to include Ethanol classified under UN1987, to ensure equitable treatment of both shippers in Canada and the U.S., and to ensure effective emergency response when responding to Ethanol incidents:

  • Task Force members are recommending that Transport Canada proceed in including Ethanol being shipped under UN1987 as part of the primary ERAP requirements for Class 3 flammable liquids, and that Transport Canada proceed with advising those shippers that may be impacted by this recommendation so they may act accordingly with respect to ERAP requirements.

Recommendation No. 4 – Outreach and Communications Opportunities for the Transport Canada TDG Directorate

Task Force members and other stakeholders have voiced their concerns over the lack of broader knowledge concerning the TDG program, and more specifically on the transportation of flammable liquids by rail. In light of the Lac-Mégantic tragedy and other dangerous goods incidents, there is a large audience that is looking for information on these subjects. There is also a need to correct misconceptions or misinformation as well as to highlight the actions taken by Transport Canada and the services and support that is readily available to communities.

  • Task Force members are recommending that Transport Canada further promote and improve knowledge and understanding of various aspects of TDG activities and programs with an Outreach and Awareness program as an ongoing activity that will address, among other topics, the following:
    • ERAP Program;
    • Roles of TDG RMS;
    • CANUTEC;
    • PD 32;
    • PD 33;
    • Emergency Response Task Force; and
    • TDG-GPAC.

To assist Transport Canada, members have provided suggestions of venues and events that would be of interest to, and reach, large and targeted groups of stakeholders. These suggestions have been collated by the Task Force Secretariat in a suggested calendar for possible conferences and activities for 2015-2016 for consideration as part of future TDG outreach and communication strategy.

These suggestions can be found as part of the Outreach and Awareness calendar in Annex C .

Request to the Task Force Secretariat for Data Collection and Analysis

The need for this information was first identified in the ERAP Working Group report of January 31, 2014, which stated:

The ERAP Working Group has discovered that there is an absence of data on the transportation of dangerous goods in Canada that is readily available for analysis. Transport Canada does not collect that information and while various producers, shippers, importers and carriers may have data specific to their operations it is not currently available to the ERAP WORKING GROUP. This means no one on the ERAP WORKING GROUP or at Transport Canada can quantify what dangerous goods are being transported, by what means and over what transportation corridors.

Without data on dangerous goods movements and volumes it is not possible to know what communities are at risk and to what degree. We don’t know if emergency response resources are located within reasonable distances to respond or what products would be encountered on a more frequent basis. While most crude oil by rail could be moving from various U.S. and Canadian oil fields to refineries or terminals for export in Canada, some or possibly a lot of the volume may be transiting through Canada from the U.S and back again into the U.S. or from Canada to the U.S.Footnote 11

In order to facilitate the work of the Task Force and its Subgroups, there is a requirement to access data and information on which the members can base their recommendations. Therefore, in accordance with the Terms of Reference, Task Force members are requesting assistance from Transport Canada for the collection of the necessary data and information from various sources, and to facilitate analysis and distribution of the data and information to members of the Task Force.

The Task Force Secretariat has identified various sources of information. With the support of the industry, TDG and other directorates within Transport Canada, work is now underway to collect that information.

Next Steps

It is expected that over the next quarter, a number of important recommendations will be presented to Transport Canada for consideration. Subjects identified for the Task Force to consider include:

  • Using a risk-based approach, examine and assess options for the potential expansion of the ERAP program to include Class 3 – flammable liquids, especially, whether to extend the requirement beyond those listed in PD 33.
  • Identify the ERAP program’s data needs and data gaps to continually monitor its effectiveness and provide the necessary information to ensure ongoing improvement of the program. Elements which may be considered include:
    • ERAP content;
    • Activation data;
    • Communities at risk; and
    • Local capacity.
  • Examine current ICS, encourage development of consensus changes amongst all stakeholders and make recommendations on a model for TDG incidents to ensure all stakeholders use a compatible approach.
    • (e.g. Unified Command, AHJ as Incident Command, the use of the Disciplined Approach chart to develop an Incident Action Plan, etc.)
  • Clarify roles and responsibilities across jurisdictions for planning and response in emergency situations.
  • Explore means to provide “Real-time” train consist information to first responders via CANUTEC.
  • Work with First Responders and industry to identify the expertise and equipment required to better support First Responders attending a flammable liquids incident.
  • Explore the requirements for First Responders training needs.
  • Assess availability of Material Safety Data Sheets related to goods listed in the train consist to First Responders.
  • Clarify and recommend how ERAPs can be activated and establish appropriate levels of activation in support of First Responders.

Conclusion

Considerable work has been accomplished to date, however much more remains to be addressed. Providing appropriate time frames for members to participate without overloading them is an important consideration and will be a factor in how future subgroups are structured and supported.  

The Task Force has requested that important data be provided to permit it to study and make recommendations that are based on proper analysis. Until this data is available, the Task Force will not be in a position to begin work on some areas identified in the Terms of Reference.

It is important that the Task Force members are made aware of the decisions made by Transport Canada on their recommendations.

The second Quarterly Report is scheduled for the end of January 2015.

Reference Documents

Document Date Author(s) Location(s)
Crude Oil Forecast, Markets & Transportation June 2014 Canadian Association of Petroleum Producers http://www.capp.ca/getdoc.aspx?DocId=247759&DT=NTV
Emergency Response Task Force Terms of Reference September 9, 2014 Transport Canada http://www.tc.gc.ca/eng/tdg/safety-menu-1196.html
Mississauga Railway Accident Inquiry 1981 Samuel G.M. Grange http://epe.lac-bac.gc.ca/100/200/301/pco-bcp/commissions-ef/grange1981-eng/grange1981-eng.htm
Protective Direction no. 32 November 20, 2013 Transport Canada http://news.gc.ca/web/article-en.do?nid=829079
Protective Direction no. 33 April 23, 2014 Transport Canada https://www.tc.gc.ca/eng/mediaroom/protective-direction-33-7494.html
Railway Investigation Report R99H0010   Transportation Safety Board of Canada http://www.tsb.gc.ca/eng/rapports-reports/rail/1999/r99h0010/r99h0010.asp
Rail Safety Recommendations R14-01, R14-02, R14-03 January 23, 2014 Transportation Safety Board of Canada http://www.tsb.gc.ca/eng/recommandations-recommendations/rail/2014/rec-r1401-r1403.asp
Railway Investigation Report R13D0054 August 19, 2014 Transportation Safety Board of Canada http://www.tsb.gc.ca/eng/rapports-reports/rail/2013/r13d0054/r13d0054.asp
“Assessment of the Response to Rail Safety Recommendation R14-03 – R13D0054 – Emergency Response Assistance Plans for transporting liquid hydrocarbons.” Rail Recommendation R14-03 2014 Transportation Safety Board of Canada http://www.tsb.gc.ca/eng/recommandations-recommendations/rail/2014/rec-r1403.asp?pedisable=true
Report and Recommendations of the Transportation of Dangerous Goods General Policy Advisory Council (GPAC) Emergency Response Assistance Plan (ERAP) Working Group Relating to Class 3 Flammable Liquids January 31, 2014 ERAP Working Group http://www.tc.gc.ca/media/documents/tdg-eng/5807-2014-3477-F-BT8821720-ERAP-WG-Report-and-Recommendations-FINAL-21-en-rev-AAA-rev.pdf

ANNEX A – List of Abbreviations used in Quarterly Report

CANUTEC
Canadian Transport Emergency Centre
CP Rail
Canadian Pacific Rail
CSS
Centre for Security Science
DRDC
Defense Research and Development Canada
ECRC LSEP
Eastern Canada Response Corporation Land Spill Emergency Planning
EMS
Emergency Medical Service
ERAC
Emergency Response Assistance Canada (formerly LPGERC)
ERAP
Emergency Response Assistance Plan
HAZMAT
Hazardous Materials (also see Dangerous Goods)
ICS
Incident Command System
IMS
Incident Management System
LPGERC
Liquefied Petroleum Gas Emergency Response Corporation
MASAS
Multi-agency Situational Awareness System
NFPA
National Fire Protection Association
PD 32
Protective Direction no. 32
PD 33
Protective Direction no. 33
RAC
Railway Association of Canada
RMS
Remedial Measures Specialist
Task Force
Emergency Response Task Force
TEAP
Transportation Emergency Assistance Program
TDG
Transportation of Dangerous Goods
TDG Act
Transportation of Dangerous Goods Act, 1992
TDG Directorate
Transport Dangerous Goods Directorate
TDG-GPAC
Transportation of Dangerous Goods General Policy Advisory Council
TDG Regulations
Transportation of Dangerous Goods Regulations
TSB
Transportation Safety Board of Canada
U.S.
United States of America

ANNEX B – List of Emergency Response Task Force Members and Observers

Membership Name Alternate(s) Representing
Chair Chris Powers   Transport Canada
Vice-Chair Louis Laferrière   Transport Canada
Member Michael Seth Blaine Wiggins
Arnold Lazare
Aboriginal Firefighter Association of Canada
Member Jim Bird Mark Jasper Canadian Association of Chemical Distributors
Member Mark Ford Murray Knowles Canadian Association of Chiefs of Police
Member Denis Lauzon
J.P. Cody-Cox
Gary Barnes Canadian Association of Fire Chiefs
(Canadian Volunteer Fire Services Association)
Member Brian Ladds
Kevin Clifford
  Canadian Association of Fire Chiefs
Member Blake Williams Michael Gadde Canadian Association of Petroleum Producers
Member Ted Wieclawek
Jim Jessop
Pierre YelleDenis Gannon Canadian Council of Fire Marshals and Commissioners
Member Bob Goodfellow  JC Morin Canadian Emergency Response Contractors Alliance
Member Adrian Michielsen   Canadian Fuels Association
Member Lee Nelson Danny Simpson Canadian National Railway
Member Jim Kozey Darlene Nagy
Glen Wilson
Canadian Pacific Railway
Member Fiona Cook   Chemistry Industry Association of Canada
Member Trudy Iwanyshyn Scott Davies Federal/Provincial/Territorial Task Force
Member Daniel Rubinstein   Federation of Canadian Municipalities
Member Brian Moore   International Association of Emergency Managers - Canada
Member Spencer Buckland   LPG Emergency Response Corporation
Member TBA   Paramedic Chiefs of Canada
Member Andy Ash Jean Pierre Couture Railway Association of Canada
Member Kristy Moore   Renewable Fuels Association (U.S.)
Member Bill Brehl Phil Benson
Rob Smith
Teamsters Canada
Member Clive Law Louis Marcotte Transport Canada - TDG
Observer Dennis Redford Laurie Boyle British Columbia Ministry of Environment
Observer Giulia Brutesco   Canadian Fertilizer Institute
Observer Mélanie Levac   Canadian Propane Association
Observer Geoffrey Wood Barrie Montague Canadian Trucking Alliance
Observer Dr. Glenn Millner James Panasiuk Center for Toxicology and Environmental Health (U.S.)
Observer David Matschke   Defense Research and Development Canada, Centre for Security Science
Observer Marc-Etienne Lesieur Simon Despatie Environment Canada
Observer Peter Grootendorst   Justice Institute of British Columbia
Observer Scott Davies   Manitoba Conservation and Water Stewardship, Environmental Compliance and Enforcement, Government of Manitoba
Observer Gilles Desgagnés Jacques Brouillette Ministère de la Sécurité Publique du Québec
Observer Brian Mullen   Public – Subject Matter Expert
Observer Ernie Wong   Public – Subject Matter Expert
Observer André Laflamme Josée Lamoureux Transport Canada – Marine Safety
Advisor Sara Devereaux   Transport Canada, Atlantic Region
Advisor Josée Boudreau   Transport Canada, Pacific Region
Advisor Paul Driver   Transport Canada, Prairie and Northern Region
Advisor Dan Olech   Transport Canada, Ontario Region
Advisor Eve Poirier   Transport Canada, Quebec Region
Advisor Fred Scaffidi   Transport Canada, HQ
Advisor Angelo Boccanfuso
Carieanne Picard
Nicolas Cadotte
Denis Foisy CANUTEC, Transport Canada
Advisor Peter Coyles   Transport Canada, Transport of Dangerous Goods
Task Force Secretariat Mylaine Desrosiers   Executive Director
Task Force Secretariat Kathie Keeley   Senior Policy Advisor
Task Force Secretariat Lindsay Jones   Policy Researcher and Advisor
Task Force Secretariat Chantal Roy-Dagenais   Special Projects Officer
Task Force Secretariat Francine Bigras   Executive Assistant
Director General TDG Nicole Girard   Transport Canada, Transport of Dangerous Goods

ANNEX C – Outreach and Awareness Calendar

Please refer to RDIMS 10063783 for the Outreach and Awareness calendar.

Footnotes

Footnote 1

Emergency Response Task Force Terms of Reference RDIMS 9971077 or www.tc.gc.ca/eng/tdg/safety-menu-1196.html

Return to footnote 1 referrer

Footnote 2

Canadian Association of Petroleum Producers. (June 2014). Report on Crude Oil, Forecast, Markets & Transportation, p.32.

Return to footnote 2 referrer

Footnote 3

ERAP Working Group. (January 31, 2014). Report and Recommendations of the Transportation of Dangerous Goods General Policy Advisory Council (GPAC) Emergency Response Assistance Plan (ERAP) Working Group Relating to Class 3 Flammable Liquids, p.8. http://www.tc.gc.ca/media/documents/tdg-eng/5807-2014-3477-F-BT8821720-ERAP-WG-Report-and-Recommendations-FINAL-21-en-rev-AAA-rev.pdf

Return to footnote 3 referrer

Footnote 4

Transportation Safety Board of Canada. (January 23, 2014). Rail Recommendations R14-01, R14-02, R14-03. http://www.tsb.gc.ca/eng/recommandations-recommendations/rail/2014/rec-r1401-r1403.asp

Return to footnote 4 referrer

Footnote 5

Transportation Safety Board of Canada. Railway Investigation Report R99H0010http://www.tsb.gc.ca/eng/rapports-reports/rail/1999/r99h0010/r99h0010.asp

Return to footnote 5 referrer

Footnote 6

Transportation Safety Board of Canada. (2014). “Assessment of the Response to Rail Safety Recommendation R14-03 – R13D0054 – Emergency Response Assistance Plans for transporting liquid hydrocarbons.” Rail Recommendation R14-03. http://www.tsb.gc.ca/eng/recommandations-recommendations/rail/2014/rec-r1403.asp?pedisable=true

Return to footnote 6 referrer

Footnote 7

Protective Direction 33 https://www.tc.gc.ca/eng/mediaroom/protective-direction-33-7494.html

Return to footnote 7 referrer

Footnote 8

Emergency Response Task Force Terms of Reference or http://www.tc.gc.ca/eng/tdg/safety-menu-1196.html

Return to footnote 8 referrer

Footnote 9

ERAP Working Group. (January 31, 2014). Report and Recommendations of the Transportation of Dangerous Goods General Policy Advisory Council (GPAC) Emergency Response Assistance Plan (ERAP) Working Group Relating to Class 3 Flammable Liquids, p.12. http://www.tc.gc.ca/media/documents/tdg-eng/5807-2014-3477-F-BT8821720-ERAP-WG-Report-and-Recommendations-FINAL-21-en-rev-AAA-rev.pdf

Return to footnote 9 referrer

Footnote 10

“Renewable Fuels Association: Industry Information, Safety Efforts.” Presentation from the American Renewable Fuels Association during the October 9, 2014 Task Force meeting (RDIMS 10034288)

Return to footnote 10 referrer

Footnote 11

ERAP Working Group. (January 31, 2014). Report and Recommendations of the Transportation of Dangerous Goods General Policy Advisory Council (GPAC) Emergency Response Assistance Plan (ERAP) Working Group Relating to Class 3 Flammable Liquids, p.20. http://www.tc.gc.ca/media/documents/tdg-eng/5807-2014-3477-F-BT8821720-ERAP-WG-Report-and-Recommendations-FINAL-21-en-rev-AAA-rev.pdf

Return to footnote 11 referrer

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