doc no. emp-prg-01 emergency management program · · 2017-08-026.3.3 post exercise debrief ......

Emergency Management Program

Doc No. EMP-PRG-01

Rev Status 02

Issue Date 2017-06-15

UNCONTROLLED IF PRINTED PUBLIC of 34

REVISION HISTORY

Rev No. Issue Date Brief Description of the Change

01 2017-01-01 New Document

02 2017-07-05 MOC 17-007 Removed Signature Block

MOC 17-008 Added Document Classification to footer

MOC-17-014 6.3.1 Addition of details around training of

Stakeholder Liaison;

6.4.2 Addition of Stakeholder Consultation (last paragraph)


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Table of Contents

1 Purpose ........................................................................................................................ 5

2 Process Scope ............................................................................................................... 7

3 Alignment to Codes/Standards/Regulations ....................................................................... 7

4 Policy and Commitment ................................................................................................. 10

4.1 Leadership Accountability ........................................................................................ 10

4.2 Policy and Commitment Statements ......................................................................... 10

5 Planning ...................................................................................................................... 11

5.1 Hazard Identification, Risk Assessment and Control .................................................... 11

5.1.1 OMS Process Linkages ...................................................................................... 11

5.1.2 EMP Incremental Requirements .......................................................................... 11

5.2 Legal Requirements ................................................................................................ 15

5.3 Goals, Objectives and Targets .................................................................................. 16


5.4 Organizational Structure, Roles and Responsibilities ................................................... 16



5.4.3 Emergency Response Structure .......................................................................... 17

5.4.4 Accountable Officer .......................................................................................... 19

5.4.5 Program Owner ................................................................................................ 19

5.4.6 Manager, Operations & Engineering .................................................................... 19

5.4.7 Director, Health, Safety, Environment and Security (HSE&S) ................................. 19

5.4.8 Manager, Public Relations .................................................................................. 20

5.4.9 EBPC Technicians ............................................................................................. 20

5.4.10 EBPC Employees .............................................................................................. 20

5.4.11 EBPC Contractors ............................................................................................. 20

5.5 Mutual Aid Agreements ........................................................................................... 20

5.5.1 Emergency Resources ....................................................................................... 20

6 Implementation ............................................................................................................ 22

6.1 Operational Control ................................................................................................ 22


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6.1.1 Abnormal Operations ........................................................................................ 22

6.2 Management of Change .......................................................................................... 23

6.3 Training, Competence and Evaluation ....................................................................... 23


6.3.2 Exercises ........................................................................................................ 25

6.3.3 Post Exercise Debrief ........................................................................................ 27

6.4 Communication ...................................................................................................... 27



6.4.3 Post Emergency Communications ....................................................................... 28

6.5 Document and Data Control..................................................................................... 28


7 Checking and Corrective Action....................................................................................... 30

7.1 Inspection, Measurement and Monitoring .................................................................. 30


7.2 Investigation and Reporting Incidents ....................................................................... 30


7.3 Internal Audits ....................................................................................................... 31

7.4 Records Management ............................................................................................. 31


8 Management Review ..................................................................................................... 32



9 Definitions ................................................................................................................... 33


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1 PURPOSE

EBPC has established the Operations Management System (OMS-SYS-01) and Protection

Programs in order to anticipate, prevent, manage and mitigate conditions that may adversely

affect the safety and security of the company’s pipeline, employees, the public, as well as

property and the environment. The Operations Management System (OMS) supports, guides and

aligns all EBPC Programs, including the Emergency Management Program (EMP), by providing an

overarching framework and a single set of building blocks – the overarching processes – that all

programs used to identify hazards, manage risks, train and manage workers, communicate,

manage records and documentation, monitor and evaluate progress and continually improve

performance. EBPC’s OMS integrates the company’s Protection Programs, ensuring that

emergency management goals, hazards, responses and other emergency management

considerations identified in the EMP are considered in the planning for all other programs.

The purpose of the EMP is to anticipate, prevent, manage and mitigate conditions during an

emergency that could adversely affect property, the environment or the safety of workers or the

public. The program is designed to apply the selected controls and recovery measures in the

event that upset or abnormal operating conditions, accidental releases, incidents and emergency

situations occur to minimize their impacts and prevent reoccurrence. EBPC has developed a

comprehensive Emergency Response Plan (EMP-PDR-01) and Crisis Management Plan (EMP-PDR-

02) that supports the achievement of this program’s purpose.

The EMP leverages the OMS, describing all tasks required related to emergency response

throughout the lifecycle of the pipeline, and adds emergency specific procedures, information and

references that guide EBPC towards meeting its goals for the program and the company. The

program is further linked to the company’s operations through the Pipeline Operations and

Maintenance Manual (POMM-PRG-01).


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1.1 Elements of the Emergency Management Program (EMP)


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2 PROCESS SCOPE

The scope of the EMP applies to all NEB-regulated pipelines and associated pipeline facility owned

or operated by EPBC (see Brunswick Pipeline System Overview in OMS-SYS-01 for more

information) and extends to all EBPC protection programs, as each program is interrelated. All

EBPC employees, consultants, contractors, and suppliers working within EBPC workplaces are

required to understand and follow the emergency requirements specified in the EMP.

EBPC's EMP is further supported and sustained by numerous partners and stakeholders including,

but not limited to, mutual aid partners, municipalities, local emergency responders, public

adjacent to the pipeline, and various government agencies.

3 ALIGNMENT TO CODES/STANDARDS/REGULATIONS

Table 1: Codes/Standards/Regulations

Regulation/Standard/Code

National Energy Board Onshore Pipeline Regulations (SOR/99-294)

Canadian Standards Association (CSA) Z662-15, Oil and Gas Pipeline Systems

National Energy Board Pipeline Damage Prevention Regulations (SOR/2016-124 & SOR/2016-133)

CSA Z246.2-14 Emergency preparedness and response for petroleum and natural gas industry

systems

CSA Z662-15 Clause 10.5.2.4

National Energy Board Act

National Energy Board Onshore Pipeline Regulations - Section 32-35- Annex A Section 1-8 (SOR/99-

294)

National Energy Board Administrative Monetary Penalties Regulations, (SOR/2013-138)

NEB Order MO-006-2016 Compelling Publication of Emergency Procedures Manuals (2016-04-05)

National Energy Board - Brunswick Pipeline CPCN Condition 3 - Commitments; A0Z5S3

NEB Order MO-002-2017 Compelling Publication of Emergency Management Program Information on

Company Websites. (2017-01-30)

CSA Z662 – 15, clauses 10.2.7 Exercises and Emergency Response Equipment

CSA Z662 – 15, clause 10.9.6.2 Pipeline valves that can be necessary during an emergency shall be

inspected and partially operated at least once per calendar year, with a maximum interval of 18

months between such inspections and operations

CSA Z731:2003 (R2014) Emergency Preparedness and Response

National Building Code of Canada, Chapter 4 of Commentary B, 2015

National Fire Code of Canada, 2011

Note: Detailed legal requirements included in EBPC’s Legal Requirements Registry


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Table 2: Industry Publications and References

Industry Publications and References

Emergency Response Incident Command System (ICS)

Incident Command Training

Canadian Energy Pipeline Association (CEPA) Emergency Response Plan (ERP) Disclosure Guidelines

(June 5, 2015): CEPA 2015 Filing at NEB

Table 3: Internal Company References

Internal Company References

OMS-SYS-01 Operations Management System (OMS)

OMS-PRO-01 Hazard Identification, Risk Assessment and Control

OMS-PRO-02 Legal Requirements

OMS-PRO-03 Goals, Objectives and Targets

OMS-PRO-04 Organizational Structure, Roles & Responsibilities

OMS-PRO-05 Operational Control

OMS-PRO-06 Management of Change

OMS-PRO-07 Training, Competence and Evaluation

OMS-PRO-08 Communication

OMS-PRO-09 Document and Data Control

OMS-PRO-10 Inspection, Measurement and Monitoring

OMS-PRO-11 Investigating and Reporting Incidents and Near-Misses

OMS-PRO-12 Internal Audit

OMS-PRO-13 Records Management

OMS-PRO-14 Management Review

OMS-PRO-15 Action Management

EBPC-POL-01 Safety Policy

EBPC POL-02 Environmental Policy

EBPC-POL-03 Security Policy

EBPC-POL-04 Records Retention Policy

EBPC-POL-05 Information Security Management Policy

EBPC-POL-06 Emergency Management Policy

EBPC-POL-07 Whistleblower Policy

HSM-PRG-01 Safety Management Program (Health & Safety)

EPP-PRG-01 Environmental Protection Program

IMP-PRG-01 Integrity Management Program

EMP-PRG-01 Emergency Management Program

SMP-PRG-01 Security Management Program

SPA-PRG-01 Stakeholder and Public Awareness Program

DPP-PRG-01 Damage Prevention Program

PCS-PRG-01 Pipeline Control System (Gas Control)

POMM-PRG-01 Pipeline Operations and Maintenance Manual

EMP-PDR-01 Emergency Response Plan (ERP)


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EMP-PDR-02 Crisis Management Response Plan (CMP)

EMP-FRM-01 Brunswick Emergency Time and Event Log

ICS 201 Incident Briefing

ICS 202 Incident Objectives

ICS 203 Organization Assignment List

ICS 204 Assignment List

ICS 205 Radio Communications Plan

ICS 206 Medical Plan

ICS 207 Organization Chart

Brunswick Pipeline Incident Org Chart

ICS 208 Safety Message-Plan

ICS 209 Incident Status Summary

ICS 211 Check In

ICS 213 General Message

ICS 214 Activity Log

ICS 215 Operational Planning Worksheet

ICS 215A Safety Analysis

ICS 216 Radio Requirements Worksheet

ICS 217A Communications Resource Availability Worksheet

ICS 218 Support Vehicle Inventory

ICS 220 Air Operations Summary

ICS 221 Demobilization Checklist

ICS 225 Incident Personnel Performance Rating

ICS 309 Communications Log


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4 POLICY AND COMMITMENT

4.1 Leadership Accountability

EBPC’s senior management, comprised of the Accountable Officer and their direct reports, has

established the OMS to ensure a shared corporate understanding of EBPC’s commitment to

continual improvement in the areas of safety, security, and environmental protection. These

senior managers, OMS Process Owners and Program Owners, are responsible for implementation

and continual improvement of the OMS and Programs, including providing feedback, as

necessary, to the Accountable Officer.

The Accountable Officer has designated the responsibility for the EMP to the General Manager

(Program Owner). The Program Owner is responsible for implementation and continual

improvement of the EMP including providing feedback as necessary to the Accountable Officer.

Any issue or concern with respect to the EMP which cannot be addressed or resolved by the

Program Owner will be brought to the Accountable Officer’s attention for final resolution without

compromising the requirements of the applicable codes, standards, current related Acts and

Regulations, good engineering practices and the requirements of this Program.

EBPC’s senior management acknowledges the importance of the EMP in achieving the goals of

EBPC’s objective of ‘zero incidents’, and as such, they are dedicated to providing the leadership

and resources necessary to foster a successful program.

4.2 Policy and Commitment Statements

EBPC’s senior management has established a number of corporate and program level policies

(see OMS-SYS-01 Section 2.4). Corporate level policies apply to all employees, contractors and

suppliers, and govern all programs. The policies that further shape the EMP are described below.

4.2.1 Emergency Management Policy

The Emergency Management Policy is a guidance document that establishes EBPC’s objectives

and commitment with respect to emergency management. For complete details, please refer to

EBPC-POL-06 Emergency Management Policy.

4.2.2 Management Commitment

EBPC is committed to enhancing the safety of its employees, public or residents, contractors and

business partners in the Emergency Planning Zone (EPZ), reducing property damage and

economic loss, and protecting the environment in the event of an emergency. An Accountable

Officer has been appointed that has the authority over the company’s human and financial

resources for ensuring that EBPC meets its obligations for safety, security, and protection of the

environment.

The EMP is designed to ensure that EBPC is ready to deal with any potential, imminent or actual

emergency. The EMP has the full support of EBPC’s Senior Management and shall be used by all

personnel and contractors engaged in the activities described in the document.


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5 PLANNING

The OMS processes outlined in the planning phase are designed to identify key inputs,

considerations and stakeholders that should be considered by programs during the planning for

their individual programs. The processes designed are not intended to prescribe the program

specific information to be used, but rather the approach to be used to define key program level

planning information to be used.

5.1 Hazard Identification, Risk Assessment and Control

5.1.1 OMS Process Linkages

EBPC has established and implemented a process, OMS-PRO-01 Hazard Identification, Risk

Assessment and Control, to guide the identification of hazards and potential hazards, the degree

of risk associated with the hazards and the implementation of control measures to prevent

and/or mitigate such risks. In addition, EBPC has established and maintains a hazard, potential

hazard, and risk registry (OMS-FRM-15 Hazard & Risk Registry), which lists all the hazards,

potential hazards, risks, and control measures addressed by the Programs within the OMS.

5.1.2 EMP Incremental Requirements

EBPC has identified the following five major scenarios for immediate action as part of their EMP

program. The scenarios include:

Facility/Pipeline Fire

Facility/Pipeline Explosion

Person Down, Rescue and Medical Situation

Natural Disasters

Threat of Aggressive Action/Bomb Threat

These hazards were identified through EBPC’s Hazard Identification, Risk Assessment and Control

process, where the EMP establishes appropriate controls and mitigations during an emergency

(see Figure 2). EBPC will follow the Assessment Matrix in Figure 3 to define the level of alert and

categorize the emergencies and corresponding responses.


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Figure 2: Integration of EMP

5.1.2.1 Emergency Management Program (EMP)

A program designed to ensure that EBPC has all necessary resources and infrastructure to deal

with any potential, imminent or actual emergency.

5.1.2.2 Emergency Response Plan (ERP) – See EMP-PDR-01

Applies to the logistics, detail steps, roles and responsibilities and procedures to be followed

during an emergency by EBPC employees and third party contractors who will be involved with

emergency response for the Brunswick Pipeline System, including any related projects.

5.1.2.3 Crisis Management Plan (CMP) – See EMP-PDR-02

Focused upon the Emera Crisis Management Team in the Emergency Operations Centre, provides

the management structure, key responsibilities, assignments, and crisis management procedures

to follow with a view to supporting the Incident Commander, informing the public and authorities

and managing the rest of the Emera Brunswick administrative functions during and immediately

after an emergency.

5.1.2.4 Incident Command System (ICS)

A standardized incident management system designed specifically to allow responders to adopt

an integrated organizational structure equal to the complexity and demands of any single

incident or multiple incidents without being hindered by jurisdictional boundaries.

Emergency Management

Program(EMP)

Emergency Response Plan

(ERP)

Crisis Management

Plan(CMP)

Emergency Operations

Centre(EOC)

Incident Command Post

(ICP)

Incident Command

System(ICS)


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5.1.2.5 Incident Command Post (ICP)

Under the responsibility and authority of an Incident Commander, is a real-time incident

management center at a safe location or facility, appropriate to the emergency or incident and

outside the EPZ for safety of first responders and emergency response team.

5.1.2.6 Business Continuity Plan (BCP)

Ensures that the necessary steps are taken to identify the impact of potential losses and maintain

viable recovery strategies and recovery plans for the continuity of services and operations. This

is contained within the CMP.

5.1.2.7 EBPC’s Emergency Operations Centre (EOC)

The EOC is where the Crisis Management Team (CMT) activities are coordinated, and is usually

established on a Level Two or a Level Three Emergency.

Figure 3: Assessment Matrix

Incident Classification and Response Table

Incident

Classification Evaluation Criteria Required Response*

Alert A heightened or emerging risk

or small incident that has no

probability of escalation.

Escalation is required if any of the

following criteria emerge:

Potential to affect operations

Potential threat to health and

safety of workers

Potential to impact company

property and/or the environment

Potential for public, media or

social media attention

The EBPC personnel will assess the

situation

The EBPC Personnel and the Manager,

Operations & Engineering will confirm the

Alert Level and determine if local First

Response Agencies need to be notified

Situation is continually assessed,

monitored and documented regarding

potential impacts or the possibility of

escalation

Initial creation of the Operational

Planning Worksheet and determine the

ICS positions to be activated based upon

the anticipated likelihood of escalation

If possible, actions taken to alleviate

heightened risk

Appropriate notifications and regular

situational awareness briefings made

with management staff and local First

Response Agencies as required

Level 1 An emergency incident which has a low potential to escalate but does

not meet any Level 2 or 3 criteria,

The EBPC personnel and the Manager, Operations & Engineering will alert the

Incident Commander to confirm the Alert


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but meets all or most of the

following conditions:

No effects outside company

property

No immediate threat to workers;

however, personal protective

equipment may be required

No immediate threat to the

public

Handled entirely by company

personnel

Environmental impact is minimal

and contained to company right-

of-way

Creates little or no media, or

social media interest

Level and determine if local First

Response Agencies need to be notified

Initiate the ERP

Establish a clearly designated Incident

Command Post and Staging Area

The Incident Commander confirms the

Level of Emergency with the On-Call

Crisis Management Team Lead and local

First Response Agencies

Incident Commander initiates ICS

Incident Briefing, Incident Status, and

provides a briefing to the Crisis

Management Team Lead

Appropriate notifications and regular

situational awareness briefings made

with management staff and local First

Response Agencies as required

Initiate, implement and continually re-

evaluate the Operational Planning

Worksheet based on incident needs and

objectives and determine the ICS

positions to be activated based upon the

current situation and anticipated

likelihood of escalation

Adequate equipment resources, security,

public protection, safety and

environmental measures are put in place

Additional resources, field emergency

responders or contractors may need to

be activated or placed on standby

The Field Emergency Response Team

prepares for possible Level 2 or Level 3

Incident response requirements

The Crisis Management Team may be

placed on standby

Situation is continually assessed,

monitored and documented regarding

potential impacts or the possibility of

escalation

Level 2 An emergency incident that does

not meet any of the Level 3 criteria,

but meets ANY of the following

conditions:

No immediate threat outside

company property, but

potential exists to extend

beyond property boundaries Requires involvement of

external emergency services,

Level 1 Incident Duties are continued

The Crisis Management Team and

Emergency Operations Centre are

activated

First Response Agencies and regulatory

agencies such as the NEB are notified

and given situational awareness updates

regularly

EBPC engages in Unified Command with

government agencies and local response agencies sending a representative to a

regional or municipal Emergency


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first responders, federal and/or

provincial/local agencies or

mutual aid partners

Environmental impact is

moderate and extends or could

extend beyond company right-

of-way

Creates local/regional media

interest

Operations Centre (if established)

The Field Emergency Response Team

and Crisis Management Team prepare

for possible Level 3 Incident response

requirements

Preparation and coordination with

Unified Command agencies regarding

any approved media releases

The potential need to evacuate or

shelter in place is evaluated and the

public within the emergency planning

zone is notified by first responders

Roadblocks are set up to isolate the

emergency planning zone through

Unified Command with possible

assistance of provincial aid and first

responders

Level 3 An emergency that meets ANY of

the following conditions:

Serious injury to company

personnel that results in EMS

transportation or a minor injury

to the public or ongoing threat

to the public

Extensive involvement of

external emergency services,

first responders, federal and/or

provincial/local agencies or

mutual aid partners

Ongoing uncontrolled release of

gas

Significant and ongoing

environmental effects

Creates national or

international media interest

Level 1 and 2 incident responses

continue

The company emergency response is

fully activated, including executive

notifications and involvement

EBPC continues to liaise under Unified

Command with key government

agencies and first responders and sends

a representative to a regional or

municipal Emergency Operations Centre

if established

Support activities required for a local

state of emergency if declared by the

Province of NB or a community adjacent

to the emergency planning zone

* This list dictates high-level response requirements for an incident based upon the

determined Level of Alert or Emergency. For greater detail regarding required response, refer

to ICS position specific requirements.

5.2 Legal Requirements

EBPC has established and implemented a process for identifying and monitoring compliance with

the legal requirements, OMS-PRO-02 Legal Requirements. The process describes how EBPC

resolves non-compliances as they relate to legal requirements, which includes updating its

management system and protection programs as required.

In addition, a Legal Requirements Registry has been established, the purpose of which is to

document legal requirements that EBPC must adhere to and show how they are integrated


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(concordance) with the OMS, protection programs and EBPC assets, including those requirements

related to safety, security, and protection of the environment. The Legal Requirements Registry

is a single, comprehensive list, inclusive of certificate conditions, orders and permits.

5.3 Goals, Objectives and Targets

Goals, Objectives and Targets (GOTs) are developed with respect to risks and hazards associated

with EBPC facilities and activities. EBPC leadership develops the GOTs as per established process

OMS-PRO-03 Goals, Objectives, and Targets. The objectives and targets are measurable and set

to ensure the goals for the prevention of ruptures, gas releases, fatalities and injuries and for the

response to incidents and emergency situations are successfully met.

The high-level goals that EBPC has set for its OMS are:

Zero fatalities

Zero injuries

Zero ruptures

Zero leaks

Zero spills

These goals established by EBPC senior management reflect the direction and desired outcomes

of EBPC’s policies, and provide the basis for EBPC’s commitment to continuous improvement in

safety, security, and environmental protection.

EBPC GOTs, including those set for all protection programs, are reviewed on a regular basis as

outlined in OMS-PRO-03, with a process established for developing and tracking preventative and

corrective actions should objectives and targets not meet the desired results set forth by EBPC.


GOTs for the EMP are set using OMS-PRO-03 and align with the high-level goals that EBPC has

set out for its OMS. The overall goal of EBPC’s EMP is to protect public safety and minimize

impacts to the environment by establishing a decision framework and action plan that employees

and contractors can use to quickly and effectively respond to an emergency.

On an annual basis, the Program Owner develops GOTs for the EMP and ERP with measurable

objectives and targets for continual improvement of the Brunswick Pipeline System.

5.4 Organizational Structure, Roles and Responsibilities


EBPC has a documented organizational structure that enables it to meet the requirements of its

management system, protection programs and its obligations to carry out activities in a manner

that ensures the safety and security of the public, employees, the Brunswick Pipeline System and

protection of property and the environment (see OMS-SYS-01).


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EBPC completes a periodic documented evaluation in order to demonstrate adequate human

resourcing to meet these obligations as per the established and implemented process OMS-PRO-

04 Organizational Structure, Roles & Responsibilities.


EBPC will ensure that a designated Duty Manager and one Field Technician are officially on call at

all times. Also, four additional EBPC personnel will be expected to respond to an incident

depending on its severity. All these personnel will reside within two hours or less of the rural and

urban facilities.

All these personnel will be trained in the emergency response (ICS) and an appropriate level of

operation and maintenance training to address any emergency situations at the facilities. The

mode of transportation will be truck, ATV, snowmobile, or helicopter based on the situation.

Duty Manager, Incident Commander or On-Call Technician will communicate with Gas Control as

well as first responders through use of cell phone, TMR Radio’s, land-line telephone and in person

at the Incident Command Post.

5.4.3 Emergency Response Structure

EBPC has adopted the Incident Command System (ICS) terminology for its Emergency Response

Team (ERT) structure for response to an emergency (see Figure 5 below). As such, the

organizational structure for the ERT can be scaled and tailored to the emergency. EBPC may

implement the ICS emergency response structure during an emergency depending on the

situation.

In case of an emergency, the first EBPC or response agency Supervisor arriving onsite assumes

the Incident Commander (IC) role until relieved by a more competent IC as determined by EBPC.

The IC will assign necessary resources based on the Assessment Matrix in Figure 3. The IC will

oversee the field response on EBPC’s behalf and will direct the activities of the ERT based on

available emergency responders, the Crisis Management Team (CMT), possible mutual aid

partners and assisting agencies.

NOTE: As the response unfolds, the role of Incident Commander will be determined by the type

of emergency. If an EBPC employee assumed the role of IC early in the incident and then a

multi-agency response was required, the role of IC may be better filled by the Fire Chief or a

Provincial Representative. The EBPC IC may become a member of the Unified Command or they

may assume the role of Operations Section Chief to lead the EBPC portion of the response.

For detailed roles and responsibilities, please see the Emergency Response Plan (EMP-PDR-01,

Section 4.3, Duties and Responsibilities).


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Figure 5: Emergency Organizational Structure

Incident Commander

Safety Officer

Liaison Officer

Information Officer

Operations Section Chief Planning Section Chief Logistics Section Chief Finance Section Chief

Resource Lead

Situation Lead

Demobilization Lead

Documentation Lead

Technical Specialists

Food Lead

Medical Lead

Communications Lead

Support Branch DirectorService Branch Director

Ground Support Lead

Facilities Lead

Supply Lead

Time Lead

Procurement Lead

Comp/Claims Lead

Cost Unit Lead

Role ________________

Role _________________

Role _________________

Role __________________

Role __________________

IncidentOrganizationChart

Crisis Team Lead

LegalFinance Communications

Deputy Incident Commander


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5.4.4 Accountable Officer

The Accountable Officer’s responsibilities include:

Annually updating and signing the Emergency Management Policy statement

Endorsing and supporting the EMP and the ERP

Ensuring EBPC is adequately staffed to respond to emergencies

5.4.5 Program Owner

The Program Owner’s responsibilities include:

Annually reviewing and updating the EMP, ERP, and CMP

Ensuring the EPZ Stakeholder List is updated annually in the Stakeholder Plan that is

kept current and maintained by a third party for EBPC.

Providing input to the Stakeholder and Public Awareness Program (SPA-PRG-01) as it

relates to the EMP, ERP and CMP per the Communication Plan

Being on a rotational call as Duty Manager

Potentially assumes the role of Incident Commander (IC) during an emergency

Ensuring EBPC’s compliance with the applicable regulations and standards for emergency

management

Maintaining up-to-date ERP Manual and Kits

Quarterly/Annually reporting on the GOTs and incidents

Employing or contracting the appropriate people and resources to support the EMP

5.4.6 Manager, Operations & Engineering

The responsibilities of the Manager, Operations & Engineering include:

Being on rotational call with the General Manager and Director, HSE&S as Duty Manager

Likely to assume the role of IC

Assuming other key roles in the ICS structure depending on the incident

Assisting with inventory management to ensure EBPC has the resources required to

respond to all emergencies

5.4.7 Director, Health, Safety, Environment and Security (HSE&S)

The responsibilities of the Director, HSE&S include:

Being on rotational call with General Manager and the Manager, Operations &

Engineering as the Duty Manager

May be required to assume the role of IC

Assuming other key roles in the ICS structure depending on the incident

Possibly being assigned the Health & Safety (Safety Officer) role within the ICS structure

in the CMT EOC or at the emergency site


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5.4.8 Manager, Public Relations

The Manager, Public Relations’ responsibilities include:

Responsible for the implementation of the Stakeholder and Public Awareness Program

(SPA) (SPA-PRG-01)] on an annual basis [the SPA Program Owner is the Manager,

Operations & Engineering]

Assuming the Information Officer (IO) role as a member of the CMT, working from the

EOC or when necessary, the ICP or reception centre, to provide strategic communication

to internal and external stakeholders.

5.4.9 EBPC Technicians

Likely to assume the role of IC as first on scene.

o If the incident escalates the role of IC may be better filled by a more competent

individual as determine by EBPC management.

5.4.10 EBPC Employees

With support of EBPC’s Management, employees shall:

Be responsible for implementing the EMP and its associated Plans (ERP and CMP) as it

applies to their duties.

5.4.11 EBPC Contractors

With support of EBPC’s Management, contractors shall:

Support EBPC as required and directed

5.5 Mutual Aid Agreements

In many operational areas of the Brunswick Pipeline System, formal and informal mutual aid

agreements may be arranged with CEPA members, third party companies, municipal and

government agencies. As mutual aid partners are developed, they will be made aware of the

hazards, their potential role, and company expectations during an emergency response.

With shared values of the protection of the public and the environment, the mutual aid partners

will train, organize and equip themselves to be interoperable.

5.5.1 Emergency Resources

All responders identified in the ERP shall be advised that they are on the emergency contact list

and know what is expected of them in case of an incident or emergency. The list shall be reviewed

at least once a year and updated whenever resources, organizational structures, procedures,

regulations or EBPC’s Hazard and Risk Registry (OMS-FRM-15) changes.

The EPZ personal information shall be accessible only by authorized personnel identified by EBPC.

EBPC will ensure that the list complies with applicable federal and provincial legislation regarding


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privacy and confidentiality of personal information. Any protected information that is not published

by EBPC will require an explanation to NEB as to why the information is protected.

Please see the Emergency Response Plan (EMP-PDR-01), Annex F for EBPC’s Emergency Equipment

List and Annex E Support Services


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6 IMPLEMENTATION

This phase is designed to outline the approach for executing EBPC programs, ensuring those

responsible (including both employees and contractors) for executing program requirements have

the necessary training, competence, awareness and understanding of their roles within the

management system. It also ensures that changes identified during the execution of the programs

and appropriate documentation required are in place.

6.1 Operational Control

EBPC has established and implemented a process (OMS-PRO-05 Operational Control) for

developing and implementing corrective, mitigating, preventive and protective controls associated

with the hazards and risks of operating the Brunswick Pipeline System. Further, EBPC has

procedures for coordinating, controlling and managing the operational activities of its employees

and other people working with or on its behalf (POMM-PRG-01 Pipeline Operations and Maintenance

Manual). Processes for informing employees and contractors of the practices and procedures

required to control identified hazards are established as described below.

6.1.1 Abnormal Operations

The EMP has developed corrective, mitigating, preventative and protective controls to address

upset or abnormal operating conditions, accidental releases, incidents and emergency situations on

the Brunswick Pipeline System as identified in the Hazard Identification, Risk Assessment and

Control process (OMS-PRO-01). These controls and recovery measures include the Emergency

Procedures outlined in Table 4.

Table 4: EMP Procedures

Procedure Number Title Purpose

EMP-PDR-01 Emergency Management Plan To provide emergency

response procedures that

must be followed to

effectively respond to any

incident/emergency involving

the Brunswick Pipeline System.

EMP-PDR-02 Crisis Management Plan To assist staff to effectively

manage communications

(internal and external) during

a crisis as per the Communication Plan.

For the purposes of implementing the EMP, the Management Team has incorporated the following

controls:

Emergency Response Plan (EMP-PDR-01);

Exercise and Validation (EMP-PDR-01);


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Continuing education through SPA-PRG-01, liaison and outreach activities with response

agencies, landowners and the public;

Mutual aid agreement with CEPA;

Arrangements with third party emergency response providers;

Emergency management training programs. This includes ICS-100 training for all

employees and ICS-200 Training for employees who will be assuming key roles within

the ICS structure;

Inspections and maintenance of emergency management equipment/spare parts.

Through training, readiness, and drills (procedures are outlined in EMP-PDR-01 Section 6.9 Hazard

Specific Response Procedures) the ERP team will be provided with the appropriate equipment

necessary to mitigate and minimize the emergency. ERP response procedures shall ensure that all

responders have an understanding of the response actions to minimize and mitigate the hazard.

Response steps outlined in this section are guidelines and may not meet the specific needs for all

response situations.

6.2 Management of Change

Management of change is critical to ensuring that changes are identified and implemented

efficiently, effectively and in a timely manner. EBPC has established and implemented a process,

OMS-PRO-06 Management of Change, which identifies and manages any change that could affect

safety, security or protection of the environment, including any new hazard or risk, any change in a

design, specification, standard or procedure and any change in the EBPC organizational structure or

legal requirements applicable to the Brunswick Pipeline System.

6.3 Training, Competence and Evaluation

EBPC has training programs and requirements established for its employees and contractors

related to its OMS and Programs. Specific training requirements have been established for each

EBPC role and are outlined in the EBPC training matrix (OMS-FRM-23 Training Matrix). A process

for developing competency requirements, including the identification and confirmation of applicable

licenses and certifications has also been developed to support EBPC’s training program (OMS-PRO-

07 Training, Competence and Evaluation).


EBPC will provide Incident Command Training (ICS-100) for all its employees.

In addition, the EMP has established drills that will be included in a training program for emergency

response throughout the lifecycle of the pipeline. This training program defines performance

indicators, frequency of exercises, liaison with applicable agencies, interaction with first response

agencies and EPZ residents, as well as preparedness to respond to the five potential hazards

identified in the Hazard Identification, Risk Assessment and Control (OMS-PRO-01) process and

included in Section 5.1 above.


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The EMP training will include:

Training on the emergency procedures set out in the ERP Plan

Training on procedures for the operation of all emergency equipment that EBPC

employees and contractors might use

Training on ICS

EBPC employees and contractors are required to complete all training and certification identified in

their roles and responsibilities within prescribed time periods. EBPC will maintain, track, and

document all training and certification for EBPC employees who are part of emergency response to

ensure that training is completed within the prescribed time periods. Any non-compliance or

unsafe acts will be documented and reported to the Risk Management Team who will investigate,

take corrective action (as required), and document.

EBPC develops a continuing education program for the police, fire departments, medical facilities,

other appropriate organizations and agencies and the public residing adjacent to the pipeline to

inform them of the location of the pipeline, potential emergency situations involving the pipeline

and the safety procedures to be followed in the case of an emergency.

EBPC implements its continuing education and liaison obligations with respect to Onshore Pipeline

Regulations (OPR) Sections 33, 34, and 35 through it Operational Management System, utilizing

both its Stakeholder & Public Awareness Program (SPA) and its External Communications Plan. The

SPA supports the EMP by guiding the implementation of these continuing education and liaison

activities in an effort to ensure a coordinated approach for all EBPC external communication.

EBPC has grouped emergency response stakeholders into stakeholder groups based on the roles

and responsibilities they would have in responding to a potential emergency on the Brunswick

Pipeline, their level of interest and influence with respect to the ERP (per the Stakeholder Register),

and the information these stakeholders require (per the Communications Requirements Matrix).

EBPC’s stakeholder analysis, per the External Communications Plan, determines the continuing

education and liaison activities the emergency response stakeholder groups receive.

These stakeholder groups are listed in EBPC’s Communications Requirements Matrix, and include:

Primary Emergency Response Stakeholders:

In the event of an emergency, these stakeholders would be first responders and as such

they have a high level of interest and a high level of influence over EBPC’s ERP.

Consequently, EBPC needs to manage this group of emergency response stakeholders

closely and provide information that ensures these stakeholders are aware of the potential

emergency situations on the Brunswick Pipeline and their specific roles and responsibilities.


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Secondary Emergency Response Stakeholders:

In the event of an emergency, these stakeholders would serve as supporting agencies.

EBPC has determined that this group of stakeholders has a low level of interest, but a high

level of influence over EBPC’s ERP. As such, these stakeholders require information that will

keep them apprised of updates to EBPC’s ERP. As warranted and based on the scenario,

some of these stakeholders may be invited to participate in an EBPC emergency response

exercise.

Tertiary Emergency Response Stakeholders:

In the event of an emergency, these stakeholders would serve as supporting communication

agencies. EBPC has determined that these stakeholders have a low level of interest, but a

high level of influence over EBPC’s ERP. As such, EBPC needs to coordinate any

communication to the public with these stakeholders in regards to EBPC’s emergency

response exercises.

The frequencies of communications deliverables are laid out in EBPC’s Communications

Requirements Matrix and vary according to stakeholder. For instance, Primary Emergency

Response Stakeholders receive an ERP Continuing Education Session every three years, beginning

in 2017.

6.3.2 Exercises

An exercise is a simulation of an actual emergency. It enables internal and external responders to

be trained properly by practicing their roles. EBPC will train its field and head office responders to

ensure that they are knowledgeable about emergency procedures and interoperability with

community responders. Verification of response preparedness and validation of planning

documents will be assessed through annual training exercises. Responder activities during an

exercise will be evaluated to assess the level of preparedness or the need for further training. In

addition to exercises, a debrief of activities will be reviewed following an emergency to determine

whether procedures were followed or a need for further training exists. Training will adhere to as

set out in the OMS OMS-PRO-07 Competency and Training Management

EBPC will cover the cost of training exercises for emergency response stakeholders.

Training exercises are an integral part of the training process and may involve regulatory agencies.

These exercises allow responders to practice their roles, validate interoperability and identify

opportunities to improve emergency preparedness. In the event of a real emergency occurring

during a training exercise, the code word or statement (Ex: “Real Event”, “This is not an

exercise”) will be used to shut down the training and initiate the response to the real event.

Training may include any of the following types of exercises and will be tracked in the internal

training matrix. Training/exercises defined:


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6.3.2.1 Drill

A drill can be used to train on new equipment or test new procedures and involves taking specific

components of the ERP and validating them for their effectiveness. A drill may be tested in the

field or in an office setting. Documentation of the drill design plan and report of outcomes or

lessons learned will be completed and acted upon. Retention of the report for audit purposes will

be for the life of the pipeline. Lessons learned will be represented as ongoing continual

improvement opportunities for the EMP and will be integrated into the OMS.

Examples of drills may include:

Testing the Emergency Call Out Process (On-call technician, Duty Manager and Gas

Control)

Testing the Crisis Management Team functions and responsibilities

Testing the Logistics Section

Fire Drill

6.3.2.2 Tabletop Exercise

A tabletop exercise is a facilitated analysis of an emergency in a conference room setting. It is

designed to elicit constructive discussion as participants examine and resolve problems based on

existing operational plans and identify where those plans need to be changed. A tabletop exercise

may be conducted annually and can also be used when new personnel are introduced to the EMP.

Meetings to plan for the tabletop exercise include department heads of the various departments,

responding agencies, local authorities, and possibly other oil/gas companies. A final report on the

lessons learned from the exercise needs to be completed and acted upon.

6.3.2.3 Functional Exercise

This can be a single or multi-agency activity designed to evaluate capabilities and multiple

functions using simulated response, without moving people or equipment to a real site.

A functional exercise may include:

An Emergency Operations Centre (EOC) Exercise – to test and develop communication

between different EBPC departments who will be part of an emergency response.

Communications include telephone lines, runners, radio phones, fax machines,

computers, etc.

Inter-organizational communication exercises – to accommodate external responding

agencies (e.g., local authority, health authority, non-government organizations, etc.).

Public Information Exercise – to coordinate with the media to disseminate factual and

timely information to Social and Traditional media

Security or Threat exercise

6.3.2.4 Full-Scale Exercise

This is an exercise in which multi-agency, multi-jurisdictional activities take place involving the

mobilization and actual movement of emergency personnel, equipment, and resources, as if a real

incident had occurred. Full-scale exercises are intended to provide a realistic simulation of an


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emergency and its response based on the Hazard Identification, Risk Assessment and Control

process (OMS-PRO-01) and should be conducted at least every three years. A full-scale exercise is

like a tabletop exercise with the exception that all required resources are deployed. The design of

a full-scale exercise must consider:

Resources required internally and externally

Safety of all personnel and any public members involved

Exercise objectives (Strategic and Tactical)

Notification of the exercise to everyone involved (e.g., public, media, response agencies,

regulatory authorities, etc.)

An emergency notification procedure in the event of an actual emergency during an

exercise

Cost of the exercise (also external agencies – meaning they need to budget for a Full-

Scale exercise plan)

A post Exercise Debrief shall take place and the outcomes and lessons learned from the exercise

would be completed and acted upon.

6.3.3 Post Exercise Debrief

A post exercise debrief must be completed after an exercise. Discussion and review by all

personnel involved in the exercise shall assist in assessing outcomes of the exercise design

objectives.

Lessons learned from exercises are a valuable source of evaluated information and reference data

for emergency planning. Outcomes and lessons learned may take the form of an After Action

Review report. Any outcomes that necessitate change to the EMP will be submitted to the Program

Owner for further action.

6.4 Communication


Stakeholder engagement and communication is an important element of OMS as it demonstrates

EBPC’s proactive commitment to continual improvement in safety, security, and environmental

protection. EBPC will engage internal and external stakeholders whose work is related to the OMS,

who live and work around the Brunswick Pipeline System, or who have an interest in them as per

OMS-PRO-08 Communication. To support external communications and engagement, EBPC has

established a Stakeholder and Public Awareness Program (SPA-PRG-01). Also, EBPC develops and

distributes emergency response information to their personnel, first responders and other

stakeholders as part of its OMS and EMP (EMP-PRG-01).


The SPA Program Owner will annually distribute information to all stakeholders identified on the

EPZ Stakeholder List and other stakeholders who work or do recreational activities in and round the


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EBPC Right of Way (ROW). These information packages are to keep the lines of communication

open and to update Stakeholders on EBPC activities.

The SPA Communication strategies will support the EMP. EBPC will use the SPA communication

processes to communicate with the public and media within the Brunswick Pipeline System’s EPZ in

the result of an emergency.

EBPC’s Primary Emergency Response Stakeholders are also consulted any time EBPC makes

material updates to its ERP. EBPC determined content requirements based on a stakeholder’s level

of interest and influence over the ERP.

6.4.3 Post Emergency Communications

6.4.3.1 Gathering of ERT and EOC Logs

Both the EBPC EOC Liaison and EBPC’s IC shall gather notes, ICS Forms, photos, Master Event Log

and position logs from all persons who responded to the emergency/incident so that they may be

reviewed for:

Debrief

Post Emergency Review

Required follow ups

Submission to regulatory agencies

6.4.3.2 Follow Up with Agencies, Mutual Aid Partners and Bystanders Who Were Notified

Follow up is required for all agencies, mutual aid partners, and bystanders that were contacted or

that responded during the emergency. Lessons learned, insights or observations shall be gathered

to help evaluate EBPC’s response to the emergency.

6.4.3.3 Follow Up with Residents, Occupants, Transients and Other Members of Public

All residents, occupants, transients or other members of the public that were contacted or

adversely affected by the emergency need to be followed up with immediately to determine

additional physical and/or emotional needs, financial losses, business continuity concerns, etc.

Each follow up needs to be documented and any concerns dealt with immediately.

6.5 Document and Data Control

EBPC has established and implemented a process OMS-PRO-09 Document and Data Control for

identifying documents and data required for Brunswick Pipeline to meet its obligations to conduct

activities in a manner that ensures the safety, security of the public, employees and the pipeline.

The process includes information on preparing, reviewing and controlling documents and data

including a process for obtaining approval by the appropriate authority.


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To ensure accurate and effective response capabilities are maintained, EBPC will conduct a review

of its EMP documentation on an annual basis at a minimum.

The following information pertaining to personnel training, meetings and exercises must be

documented and retained for the life of the pipeline:

Records of staff training

Within 60 days of an exercise, results to be maintained for assessment purposes which

include:

o Type of exercise

o Scope and objectives

o Persons involved

o Outcome (objectives achieved)

o Action plan, including timelines


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7 CHECKING AND CORRECTIVE ACTION

7.1 Inspection, Measurement and Monitoring


EBPC has established and implemented a process for inspecting and monitoring EBPC’s Brunswick

Pipeline System to evaluate the adequacy and effectiveness of the Programs and for taking

corrective and preventive actions if deficiencies are identified. The process considers legal

requirements as well as risks that have been identified as significant to the achievement of EBPC’s

goals and objectives, including those related to the safety and security of the public, company

employees and the pipeline and for the protection of property and the environment (OMS-PRO-10

Inspection, Measurement & Monitoring).

7.2 Investigation and Reporting Incidents

EBPC has established and implemented a process for the internal reporting of hazards, potential

hazards, incidents and near-misses (OMS-PRO-11 Investigating & Reporting Incidents and Near-

Misses). The process also includes conducting investigations where required or where hazards,

potential hazards, incidents and near-misses have or could have resulted in significantly

compromising safety or security of the public, company employees and the pipeline, and protection

of property and the environment.

EBPC’s incident reporting database is a reporting tool, accessible to all employees, for reporting

and tracking incidents or near-misses. The tool generates notifications to managers and leaders

whenever an incident is reported, and records immediate and root causes as well as corrective

actions to be applied. The Hazard Reporting Form (OMS-FRM-01) can be used by any employee for

reporting hazards, potential hazards, incidents and near-misses to their supervisor so that

corrective and preventive actions can be implemented where the database is not available. An

Incident Report Form (OMS-FRM-18) is also available to report information required for reportable

incidents.


7.2.1.1 Post-Emergency Review

After an emergency, feedback is requested from both EBPC responders and agency responder

Command Staff in order to identify areas of improvement. These areas of improvement will be

reviewed by the Program Owner, in conjunction with other relevant stakeholders as required, to

determine the appropriate corrective action and subsequent implementation.

7.2.1.2 Situational Assessment

During the post incident review, and as a result of the situational assessment, it may be necessary

to augment the EMP with a contingency plan and the involvement of other emergency responders.

The protective and corrective strategies identified should be captured in lessons learned. These

actions will be updated in the EMP during annual revision.


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7.2.1.3 Damage Assessment

Agencies or members of the public that have suffered injuries, casualties or damages shall be

followed up with by EBPC management (if appropriate to do so), to ensure their well-being. Names

of those affected will be tracked by Command Staff and a report will be provided to the CMT (i.e.

victims transported to hospital). This information would be acquired from the EMS or police

representatives.

On-site damages due to the emergency need to be secured, documented and monitored to prevent

further contamination, and avoid evidence from being altered. The EBPC Logistics Chief will

identify damage assessment experts who will carry out this assessment. These assessments are

crucial for settling any claims that may be made after the emergency and help EBPC allocate

necessary resources and funding to manage those claims.

7.3 Internal Audits

EBPC has established and implemented a process for conducting internal audits (OMS-PRO-12

Internal Audit) and for taking corrective and preventative actions if deficiencies are identified. The

audit process also identifies and manages the training and competency requirements for staff

carrying out the audits. Audits of this EMP must be completed at minimum every 3 years.

7.4 Records Management


EBPC has established and implemented a process (OMS-PRO-13 Records Management) for

generating, retaining and maintaining records that document the implementation of the

management system and its protection programs, and for providing access to those who require

them in the course of their duties.


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8 MANAGEMENT REVIEW


EBPC has established and implemented a process, OMS-PRO-14 Management Review, for

conducting quarterly management reviews of the management system and its protection programs

by a Management System Governance Committee. The management review process outlined

provides structured and systematic information to the EBPC Management System Governance

Committee to enable organizational decision making and to drive continual improvement.


EBPC senior management will review and ensure the suitability, adequacy, and effectiveness of the

EMP and its associated procedures (EMP-PDR-01 and EMP-PDR-02) annually or after a real

emergency has happened (whichever comes earlier).

The review should confirm:

a) That the EMP is fully implemented

b) That the EMP meets the operator's policy and objectives

c) That the EMP is adequate for its intended purpose

d) Where improvements are required in the EMP

The review will address the following subjects:

a) The state of preparedness for emergency response (e.g., emergency response plan,

training, and exercise reports)

b) Emergency response arrangements and information sharing with municipal emergency

service providers

c) Emergency communication plans (internal and external for surrounding communities)

Additional data sources available to assist the EMP review may include:

a) Security Risk Assessments

b) Security Incident Management

(Refer to the Security Program (SMP-PRG-01) for details)


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9 DEFINITIONS

Table 5: Definitions

Term Definition

Process Owner

Person who has the authority to determine how a process operates

and for the performance of a process in realizing its objectives

measured by key process indicators. They also have the authority

and ability to make necessary changes to process to ensure that it

continues to meet the business needs.

Program Owner

The person who has accountability for a program that is charged with

executing the process outlined in completing the work associated with

their program.

Functional Leadership

The person who is an organizational leader, who provides direction

and approval for the program and/or work that is driven by the

program within an organization.

Management System

Governance Committee

A cross-functional committee of senior organizational leaders, who

review Program and Process Level information as a basis to ensure

that the company meets the requirements of its Management System.

In utilizing the information, the committee will provide direction,

recommendations, prioritization and approval for recommended

improvements to programs and the management system as a whole.

Risk Management Team The EBPC Leadership team and subject matter experts from EBPC

staff.

Emergency Planning

Zone (EPZ) 800 meters from center of pipe (800 m on each side of the pipeline)

Emergency Response

Team (ERT) EBPC’s field response team

Incident Command (IC)

EBPC utilizes the ICS structure in responding and managing

emergencies. This structure is supported by 2 teams or groups:

a) Incident Command (also known as ERT)

b) Crisis Management Team (CMT)

The ERT consists of all relevant employees and third party contractors

of EBPC who will respond to an on-site emergency situation when an

Emergency situation is declared by the Incident Commander. This

team includes the following:

a) Incident Commander

b) Operations Section Chief


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Term Definition

c) Liaison Officer

d) Safety/Environmental Officer

e) Logistics Section Chief

f) Planning Section Chief

g) Information Officer or Communications Lead

h) Third Party Contractors (technical resources)

i) Government Agencies /Emergency Responders (for level 2 and

3 emergencies)

j) Scribes

Crisis Management

Team (CMT)

This team is responsible for Legal and Regulatory notifications and

administrative duties to support the Incident Commander.

The Director of Legal and Regulatory Affairs may serve as leader of

the CMT. He or she will be available to activate the CMT at all Alert

and Emergency levels during a crisis. If the Director of Legal and

Regulatory Affairs is unavailable, the responsibility for the CMT may

be delegated to the:

a) Director, HSE&S

b) Manager of Regulatory Compliance

c) Manager of Management Systems

Safety/Environmental

Officer

The Safety/Environmental Officer will ensure responder and worker

safety and will assess environmental issues for appropriate actions.

The Safety/Environmental Officer has the authority to order

discontinuation of any operation, which threatens the health and

safety of responders.

Duty Manager

Person responsible to be on call in case of emergency and could

activate the ERT. This role will be shared with EBPC’s General

Manager, Manager, Operations & Engineering and the Director of

HSE&S.

Information Officer

(IO)

This person is responsible to gather information and distribute it on

behalf of the EBPC. All communications will be approved by the IC.

doc no. emp-prg-01 emergency management program · · 2017-08-026.3.3 post exercise debrief ......

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