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The development of regulatory requirements to manage alcohol and drug use in Canada's high security nuclear facilities

Abstract of the technical poster presented at:
Issues of Substance Conference, Canadian Centre on Substance Use and Addiction (CCSA)
November 25-27, 2019

Prepared by:
Aaron Derouin and Lynda Hunter
Canadian Nuclear Safety Commission


Learning objectives:

To develop an understanding of how Canadian Nuclear Safety Commission (CNSC) staff developed regulatory requirements within REGDOC 2.2.4, Fitness for Duty, Volume II: Managing Alcohol and Drug Use.


Fitness for Duty (FFD) is an important element within the CNSC’s regulatory framework. The CNSC promotes stakeholder consultation when developing regulatory requirements.


To demonstrate how the CNSC’s transparent approach to stakeholder consultation resulted in the approval of REGDOC 2.2.4.


In 2009, the Commission tribunal requested clarity on the topic of FFD. As a result, CNSC staff completed extensive benchmarking, developed a conceptual framework, and published a discussion paper, titled, DIS-12-03, FFD: Proposals for Strengthening Alcohol and Drug Policy, Programs and Testing. The development of REGDOC 2.2.4 began following an analysis of comments received on DIS-12-03. In 2015, the CNSC published Draft REGDOC 2.2.4 and sought further stakeholder feedback.


In August 2017, CNSC staff presented a revised version of Draft REGDOC 2.2.4 to the Commission, which was later accepted and published in November 2017.


From a human reliability perspective, FFD-related impairments are associated with an increased probability of failures in the execution of safety-related tasks. The recent legalization of cannabis has elicited safety concerns from many Canadian employers across various safety-sensitive industries. The Commission’s decision to approve REGDOC 2.2.4 underscores the importance of taking all reasonable measures to ensure that workers at Canada’s high security nuclear facilities remain free from the influence of alcohol and drugs.

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