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Fitness for Duty: A Canadian Nuclear Regulatory Perspective

Abstract of the technical presentation presented at:
Second International Conference on Physical Employment Standards (PES 2015)
August 23-26th, 2015

Published in: Applied Physiology, Nutrition, and Metabolism, 2016, 41 (6 (Suppl. 2))

Prepared by:
Aaron J. Derouin, Lynda Hunter, Patrick Adams, Richard Tennant
Canadian Nuclear Safety Commission


Fitness for duty (FFD) is an important aspect of human performance within the Canadian Nuclear Safety Commission’s (CNSC’s) regulatory framework. The CNSC’s approach to fitness for duty provides reasonable assurance that workers at Canada’s nuclear facilities have the requisite capabilities to safely and competently perform their duties, and as such do not pose a risk to their safety or that of others and the environment, or to the safety and security of the facility. The CNSC promotes stakeholder consultation and transparency as part of its development process for new or revised regulatory requirements. This submission describes the path to date in developing CNSC’s draft regulatory document on FFD, REGDOC-2.2.4, within this process. Current regulatory requirements for FFD are being consolidated and enhanced to ensure alignment and consistency with the International Atomic Energy Agency’s requirements and recommendations, and national standards (i.e., Canadian Standards Association-CSA, American National Standards Institute-ANSI, and National Fire Protection Agency-NFPA). The CNSC’s conceptual approach for an effective FFD framework across licensed facilities covers a broad range of FFD components (medical, psychological, occupational fitness, behavioural-performance, and biochemical substance testing) and circumstances (pre-placement, for-cause, etc.) across a diverse group of safety-sensitive positions, including: certified workers (RD-204), security personnel (RD-363 and REGDOC-2.12.1), industrial fire brigade/ emergency response team members (CSA N293-12 and NFPA 600-2010), and workers designated in minimum staff complement roles (G-323). Following extensive benchmarking and analysis of best practices from both national and international high-reliability organizations, and input from external experts, the CNSC published a discussion paper on FFD, DIS-12-03, Fitness for Duty: Proposals for Strengthening Alcohol and Drug Policy, Programs and Testing, and a What We Heard Report after a 144-day public consultation period. CNSC staff presented a broad and comprehensive approach to FFD in the discussion paper, with a focus on alcohol and drug testing. Based on feedback from stakeholders and the public, human factors specialists at the CNSC have worked closely with other CNSC specialists and site inspectors with expertise in emergency management, nuclear security, and nuclear facility operations to harmonize and enhance existing FFD requirements in a proposed regulatory document. In line with the CNSC’s strategy on developing new regulatory documents, REGDOC-2.2.4 on FFD will be available for stakeholder and public consultation prior to going before the Commission for approval.

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