Strengthening fitness for duty: REGDOC-2.2.4
August 10, 2017
The Canadian Nuclear Safety Commission (CNSC) is proposing new regulatory requirements in REGDOC-2.2.4, Fitness for Duty, to provide reasonable assurance that workers who could pose a risk to nuclear safety or security at Canada’s high-security nuclear facilities are fit for duty and are not under the influence of alcohol or drugs.
In nuclear facilities across Canada, nuclear safety and security is reliant on human performance. Recognizing this, the CNSC requires nuclear power plants (NPPs) to implement and maintain human performance programs, including programs to ensure that workers are fit for duty. An important element of being fit for duty is being free from the influence of alcohol or illicit drugs while at work and the responsible use of performance-altering medications while at work. The CNSC is proposing to strengthen fitness-for-duty regulatory requirements in relation to the alcohol and drug policy and programs, and alcohol and drug testing, to improve oversight of fitness for duty and overall facility safety.
Fitness for duty
But what exactly is fitness for duty? Fitness for duty refers to a condition in which workers are physically, physiologically and psychologically capable of competently and safely performing their tasks. The implementation of an effective fitness-for-duty program provides reasonable assurance that workers have the capacity and are free of any impairment, and as such, do not pose a safety or security risk.
Within the CNSC’s existing regulatory framework, fitness for duty is part of the human performance management safety and control area (SCA), which is one of fourteen specific SCAs. This SCA covers all activities that enable effective human performance through the development and implementation of processes with the aim of ensuring that licensee personnel have the necessary knowledge, skills, procedures and tools in place to safely carry out their duties.
REGDOC-2.2.4, Fitness for Duty contains a number of requirements and considerable guidance related to medical, psychological and occupational fitness, as well as alcohol and drug use. These requirements differ by workgroup, as they are tailored to the worker’s job performance requirements. In safety-sensitive industries such as the nuclear industry, these programs provide reasonable assurance that workers are free of any impairment that could hinder their ability to safely and competently perform the duties of their position. Regulating fitness for duty is important because human performance is central to the safety and security of nuclear facilities. In fact, the International Atomic Energy Agency (IAEA) expects regulatory bodies to have fitness-for-duty requirements at nuclear facilities, including requirements on substance use.
Alcohol and drug policy, programs and testing
To provide reasonable assurances that workers at Canada’s high-security nuclear facilities remain free from the impairing effects of alcohol and drugs, the CNSC is recommending additional requirements that would strengthen existing fitness-for-duty oversight. For instance, workers in safety-sensitive positions at high-security sites will be subject to alcohol and drug testing. Random and pre-placement alcohol and drug testing will be limited to workers who have the most direct and immediate impact on safety and security. These improvement measures will help to:
- provide reasonable assurance that workers who could pose a risk to nuclear safety or security at Canada’s high-security nuclear facilities are fit for duty
- make fitness-for-duty requirements and guidance more transparent, consistent and comprehensive as part of the CNSC’s efforts to strengthen overall nuclear safety and security
- address the International Atomic Energy Association’s (IAEA’s) expectations, and ensure that international best practices in relation to alcohol and drug testing are met
REGDOC-2.2.4, Fitness for Duty was developed through extensive research, benchmarking and broad-based consultations with stakeholders. Public consultations were held in two phases over a four-year period from 2012 to 2016. Both public and stakeholder consultations have been extensive and meaningful. Comments received during the public consultation period, as well as more information regarding REGDOC-2.2.4, are posted on the CNSC’s website.
The findings from this rigorous process will be examined thoroughly before the Commission. Draft REGDOC-2.2.4, Fitness for Duty, will be discussed at a public Commission meeting on August 17, 2017. The CNSC encourages stakeholders and members of the public to get involved and participate in public Commission proceedings.
Taken together, REGDOC-2.2.4, Fitness for Duty, and REGDOC-2.2.4, Fitness for Duty: Managing Worker Fatigue (published March, 2017), will provide a comprehensive set of fitness-for-duty requirements and guidance to further strengthen nuclear safety and security. REGDOC-2.2.4, Fitness for Duty, will help ensure that human performance is not compromised at high-security facilities. These new requirements serve to minimize the potential for human error, thereby improving the safety of Canada’s nuclear facilities.
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