Greetings, David,
Thanks for your note below. I tried to ring you, but you were out. It wasn’t clear to me whether you still want additional – digital copies – of the MSDS sheets for the Knife Lake spring programme, or if the sheets submitted are OK for now, with the proviso that you would like digital, up-to-date sheets in future revisions, new submissions, etc.
Yes, I’m aware of the time factor on MSDS sheets, but I try to use the sheets that are submitted by the contractor, to save time – I’m sure Tahera does the same, hence the fact that some are dated. In future, I’ll ensure that the most up-to-date sheets are used. (I believe that the fuels sheets were all up-to-date, as I endeavour to get brand-specific MSDS, as fuels of the same general composition may differ slightly due to proprietary additives, thus affecting possible treatment of a worker, should a mishap occur, etc.
Field managers receive hard copy, so that the sheets are readily at hand for both employees and drillers. If an incident were to occur, it might be problematic to find the CD, open the file, read off it or print it out (if there is a printer), etc. MSDS sheets are provided (by me) in at least 2 forms, on of which is hard copy. In my several decades of experience, I have learned that there is a direct correlation between difficulty of access and the propensity of field people to seek access.
One more question, though off topic: Will you be attending Yellowknife Geoscience Forum (16-18 November)? It would be nice to chat, if you are. I have a more long-range question, which could be discussed then.
Regards,
-- ssp
-----Original
Message-----
From: David
Hohnstein [mailto:Tech2@nwb.nunavut.ca]
Sent: 02 November
2004 11:24
To: Standafer Pfister, Shirley
Cc: Phyllis Beaulieu
Subject: Re: Query-Revised Spill Plan
Letter-NWB2KIK0405
HI Shirley,
I guess to start off with, thanks for the email and I appreciate your patience.
One of the main comments and recommendations from DIAND is always, that the Spill Plan should include all the necessary information to make it a stand-alone document that can be referenced without the need to have on hand all the information submitted with the application. In other words, the information should be available on site, and to the person(s) in charge, in order to readily understand a spill situation when and if it occurs. Unfortunately, some duplication may occur. If you haven't seen any of the comments submitted during the review of the application and Spill Plan, they are still available on the NWB ftp site at:
In followup to your questions,
(2) "potentially sensitive areas" would be at a minimum, a map and description of the area indicating water resources, sensitive wildlife habitat, migratory bird nesting areas etc, that may be affected in the event of a spill.
(6) MSDS's; Please, please, please don't send any more hard copies.. :-) Electronic versions are available and more suited for the NWB's reference and filing. (copies of the page with the new revision date on it may be all that is necessary). Item 6 was included in the request as there were several MSD sheets included in the application that were beyond the regulated (WHMIS) timeframe of 3 years. This isn't necessarily a NWB concern but a "right to know" information concern for workers (and of course, those responding to a spill). Generally, the newer, updated data sheets contain more information on the hazards and safety concerns with the products. I'm not sure why there are so many out of date MSDS's around (Tahera included some in their application that were last revised in '92) as it is law that manufacturers revise their data sheets to maintain the 3 year refresher, and make them available when purchasing products. There are online resources (the CCOHS has the most widely used; subscription required) that have this information available for most petroleum products and chemicals..
(3) I do acknowledge the section you refer to (3.3) which mentions that there was no camp involved and includes the fuel amounts to be stored at the drill site, however this information is hidden well within the plan and is under the heading "General Equipment and Proximity", which might the place to look at if response personnel were looking for fuel inventory at the site.
I do realize that the current 2004 programme has long since past, however I do believe that getting the main components of the Spill Plan in place will reduce the need for changes in the next program which should be minimal as to the description and product inventories.
If you have any further questions, please give me a call at your earliest convenience.
Regards,
David
----- Original Message -----
Sent: Monday, November 01, 2004 1:51 PM
Subject: Query-Revised Spill Plan Letter-NWB2KIK0405
Greetings, David,
Thank you for your letter of 01 November, referencing the Knife Lake Spill Contingency Plan, revised 08 April 2004.
Perhaps you can clarify a few points for me: Your item (2): Can you clarify “potentially sensitive areas”? All potential use areas for the spring 2004 drilling were identified on the map accompanying the Project Description. Your item (6): MSDS sheets in hard copy were supplied with a hard copy of the revised Spill Plan in early April 2004, via courier. Assuming the NWB received this courier package, do you require yet another copy? Your item (3): Here, I would reference Section 3.0 of the Spill Plan, which states (3.3.) that there was no camp associated with this drill programme, and that maximum drum storage was 25 Jet-B and 15 diesel per week during the programme.
Whilst I shall endeavour to comply with your requests after the fact – the programme having concluded approx. 08 May 2004 – I would note that the Spill Plan was originally submitted in November 2003 with a detailed Project Description, which Description was intended to be a document complementary to the Spill Plan (and vice versa), and which contained a great deal of information about the proposed programme, its authorisations, etc. Since all of the application documents were submitted together, as a single submission, it was intended that they be understood as a whole, with a view to limiting duplication of information between the companion documents.
As the Kikerk/Knife Lake 2004 work programme concluded 6 months ago, you must understand that the information supplied now will be in respect of that programme, i.e., a programme which ended 6 months ago. It is anticipated that the Spill Plan would be revised again in advance of the next work season (potentially, 2005); however, our plans for 2005 are not yet known.
Regards,
-- ssp
Shirley Standafer-Pfister
Lands and Government Relations Manager
De Beers Canada