Chapter 4 - Environmental, Health And Safety Management System

4. Environmental, Health And Safety Management System

4.1 Purpose

VBNC's EH&S Management System is intended to promote sustainable development.

This Environmental, and Health and Safety Management System (EH&S Management System) provides VBNC with the tools necessary to manage the environmental and health and safety components of the Project. VBNC recognizes the importance of EH&S Management Systems in the promotion of sustainable development and in the maintenance of a healthy environment, safe workplace and strong economy. The EH&S Management System is the principal mechanism by which VBNC will integrate design and engineering with the overall goal of maintaining ecosystem function and integrity.

The EH&S Management System has a life-of Project horizon.

The Canadian Environmental Assessment Agency (CEAA) prescribed that environmental assessment be applied as early in the Project's planning stages as practicable and in the same way that economic, social and policy factors have been applied in the past (CEAA 1994: 9). That is why the EH&S Management System has a life-of-Project horizon. VBNC has applied and implemented many of the elements of this EH&S Management System since early in the Project, for example, the exploration EPP (VBNC 1997a), and VBNC's extensive involvement with Aboriginal peoples and the public (Chapter 5). VBNC is fully committed to continually improve its EH&S performance through the development and modification of this EH&S Management System over the life of the Project.

4.1.1 Environmental, Health and Safety Plans

The EH&S Management System is made up of eleven integrated Plans.

The EH&S Management System comprises 11 distinct, but closely related, EH&S Plans. These Plans represent the way in which VBNC currently views the management of the relevant EH&S functions and requirements of the Project. Figure 4.1 shows the relationship of environmental assessment and design in the planning stage to the EH&S Management System and its components in the implementation stage of the Project. The EH&S Management System must be flexible and dynamic.

As an example of a successful application of this type of EH&S Management System, the proponents (Strait Crossing Inc. 1993) of the Confederation Bridge project demonstrated that the implementation of a life-of-project Environmental Management Plan early in the planning process represents an effective way of addressing the many environmental challenges that a large-scale project creates (Barnes and Pytyck et al. 1996). The Confederation Bridge Environmental Management Plan was not so much a rigid framework as it was a dynamic and adaptable management strategy.

Figure 4.1 Elements of the Environmental, Health and Safety Management System

Valued Environmental Components are those components of the environment which have been selected through a comprehensive issues scoping process in order to provide focus for the environmental assessment.

Figure 4.2 shows the key features of the EH&S Management System. This approach will lead towards the goal of sustainable development following a model of continuous improvement. The VNBC EH&S plans will be updated regularly but also at important milestones in the Project life, such as at the initiation of a new Project phase. Table 4.1 shows how each EH&S Plan relates to valued environmental components identified in Chapter 6, thus applicable Project phases are also indicated in Table 4.1.

For the Project, the Panel specifically identified a number of EPP and environmental management system needs. These needs are addressed through the implementation of several or all of the EH&S Plans which form the EH&S Management System. Table 4.2 lists the EPP and environmental management system needs identified by the Panel and relates these to Project design and the various EH&S Plans. Specific measures required to mitigate various EH&S concerns are described in detail in Section 4.16. Table 4.3 lists the commitments, policies and arrangements identified by the Panel in the Guidelines and relates these to Project design and the applicable EH&S Plans. The scope and content of the EH&S plans depends upon the Project phase (construction, open pit operations, underground operations and decommissioning).

Figure 4.2 Key Features of VBNC's EH&S Management System

Table 4.1 Relationship of EH&S Management System Components to Valued
nvironmental Components, By Project Phase

Valued Environmental Component	EPP	ERCP	OHSP	REC.P	HRP	IBP
Atmospheric Environment	C, O,D	A	-	-	-	-
Ice	C, O, D	A	-	-	-	-
Water	C, O, D,P	A	C, O, D, A	O, D, A	-	-
Freshwater Fish and Habitat	C, O,D,P	A	C, O, D, A	O, D, P, A	-	-
Marine Fish	C, O, D,P	A	-	-	-	-
Marine Mammals	C, O, D	A	-	-	-	-
Plant Communities	C, O, D	A	-	-	-	-
Waterfowl and Seabirds	C, O	A	C, O, D, A	-	-	-
Caribou	C, O	C, O, D, A	C, O, D, A	O, D, P,A	-	-
Black Bear	C, O	C, O, D, A	C, O, D, A	O, D, P,A	-	-
Species of Special Conservation Status	C, O	C, O, D, A	-	O, D, P,A	-	-
Historic Resources	C	C, O, D, A	-	-	-	-
Aboriginal Land Use and Culture	C, O	-	C, O, D, A		-	C, O, D
Employment and Business	C, O	-	-	-	C, O, D	C, O, D
Local, Regional and Provincial Economics	C, O	-	C, O	-	C, O, D	C, O, D
Services and Infrastructure	C, O, D	C, O, D, A	C, O, D, A	-	C, O, D	C, O, D
Family and Community	C, O, D	C, O, D, A	C, O, D, A	-	C, O, D	C, O, D
EPP = Environmental Protection Plan ERCP = Emergency Response and Contingency Plan OHSP = Occupational Health and Safety Plan REC. P = Reclamation Plan HRP = Human Resources Plan IBP = Impact Benefits Plan C = construction, O = Operation, D = Decommissioning, P = Post-decommissioning, A = Accidental events

Table 4.1 (Continued) Relationship of EH&S Management System Components to Valued Environmental Components, By Project Phase

Valued Environmental Component	ED&OR	AIP	PIP	M&F	AUD
Atmospheric Environment	C, O, D, A	-	-	C, O, D, A	C, O, D
Ice	C, O, D, A	C, O, D, A	-	C, O, D, A	C, O, D
Water	C, O, D, A	-	-	C, O, D, A, P	C, O, D
Freshwater Fish and Habitat	C, O, D, A	C, O, D, A	-	C, O, D, A, P	C, O, D
Marine Fish	C, O, D, A	-	-	C, O, D, A, P	C, O, D
Marine Mammals	C, O, D, A	C, O, D, A	-	C, O, D, A	C, O, D
Plant Communities	C, O, D, A	C, O, D, A	-	C, O, D, A	C, O, D
Waterfowl and Seabirds	C, O, D, A	C, O, D, A	-	C, O, D, A	C, O, D
Caribou	C, O, D, A	D	-	C, O, D, A	C, O, D
Black Bear	C, O, D, A	C, O, D, A	-	C, O, D, A	C, O, D
Species of Special Conservation Status	C, O, D, A	C, O, D, A	-	C, O, D, A	C, O, D
Historic Resources	C, O, D, A	C, O, D, A	-	C, O, D, A	C, O, D
Aboriginal Land Use and Culture	C, O, D, A	C, O, D, A	-	C, O, D, A	C, O, D
Employment and Business	-	C, O, D	C, O, D	C, O, D, A	C, O, D
Local, Regional and Provincial Economics	-	C, O, D	C, O, D	C, O, D, A	C, O, D
Services and Infrastructure	C, O, D, A	C, O, D, A	C, O, D	-	C, O, D
Family and Community	C, O, D, A	C, O, D, A	C, O, D	-	C, O, D
M&F = Monitoring and Follow-up ERCP = Emergency Response and Contingency Plan ED&OR = Education and Orientation AUD = Auditing and Continual Improvement Plan AIP = Aboriginal Involvement Plan PIP = Public Involvement Plan C = construction, O = Operation, D = Decommissioning, P = Post-decommissioning, A = Accidental events

Table 4.2 Relationship of EH&S Management Needs Identified by the Panel to Applicable Project Design Features and EH&S Plans

EH&S Management Needs Identified by Panel	EH&S Plans
	Design	EPP	ERCP	OHSP	REC. P
waste management/ minimization	X	X	X
acid rock drainage management	X	X	X
containment control and minimization	X	X	X
water supply and management	X	X	X
operating regime for tailings and waste rock ponds	X	X	X
fish habitat management (compensation plan)*	X	X	X		X
air emissions control	X	X	X	X
air traffic management	X	X	X	X
marine traffic management	X	X	X	X
human/wildlife interactions	X	X	X
accidental events	X	X	X	X
site rehabilitation	X	X	X		X
training and safety	X	X	X	X
* Compensation plan for habitat alteration, disturbance or destruction to be negotiated with DFO.

EH&S Management Needs Identified by Panel	EH&S Plans
	ED&OR	AIP	HRP	PIP	M&F	AUD
waste management/ minimization	X				X	X
acid rock drainage management	X				X	X
containment control and minimization	X				X	X
water supply and management	X	X			X	X
operating regime for tailings and waste rock ponds	X				X	X
fish habitat management (compensation plan)*	X	X			X	X
air emissions control	X				X	X
air traffic management	X				X	X
marine traffic management	X	X			X	X
human/wildlife interactions	X	X			X	X
accidental events	X	X			X	X
site rehabilitation	X	X			X	X
training and safety	X	X	X	X	X	X
* Compensation plan for habitat alteration, disturbance or destruction to be negotiated with DFO. EPP = Environmental Protection Plan REC.P = Reclamation Plan M&F = Monitoring and Follow-up ERCP = Emergency Response and Contingency Plan ED&OR = Education and Orientation AUD = Auditing and Continual Improvement Plan OHSP = Occupational Health and Safety Plan APP = Aboriginal Involvement Plan HRP = Human Resources Plan IBP = Impact Benefits Plan PPP = Public Involvement Plan

Table 4.3 Relationship of Commitments and Policy Needs Identified by Panel to EH&S Plans

Commitments and Policy Needs Identified by Panel	Project EH&S Plans Planning
	Design	EPP	ERCP	OHSP	IBP*
commuting and work rotation	X
hiring/training			X	X	X
orientation/human resources					X
health and safety	X	X	X	X
personnel movements		X
social issues				X
aboriginal travel/ hunting/resource use		X		X	X
non-aboriginal resource use		X
special work schedule for Aboriginal peoples					X
employee/employer relations
contracting and procurement					X
education and training			X	X	X
youth education/employment programs					X

Commitments and Policy Needs Identified by Panel	EH&S Plans
	ED&OR	AIP	HUM. RES.	PIP	M&F	AUD
commuting and work rotation			X			X
hiring/training	X	X	X	X	X	X
orientation/human resources	X	X	X	X	X	X
health and safety	X				X	X
personnel movements			X			X
social issues	X		X		X	X
aboriginal travel/ hunting/resource use	X	X	X			X
non-aboriginal resource use	X		X			X
special work schedule for Aboriginal peoples		X	X			X
employee/employer relations			X		X	X
contracting and procurement		X		X	X	X
youth education/employment programs	X	X	X	X	X	X
education and training	X	X	X	X	X	X
EPP = Environmental Protection Plan REC.P = Reclamation Plan M&F = Monitoring and Follow-up ERCP = Emergency Response and Contingency Plan ED&OR = Education and Orientation AND = Auditing and Continual Improvement Plan OHSP = Occupational Health and Safety Plan AIP = Aboriginal Involvement Plan IBP = Impact Benefits Plan PIP = Public Involvement Plan * Impact and Benefits Agreements are being negotiated with LIA and Innu Nation. VBNC's Aboriginal policy is in Appendix 4A.

4.1.2 Implementation

The EH&S Management System will be modified and will evolve through each Project phase; for example, when construction begins, permit conditions and monitoring of specific equipment will be incorporated in the EPP. Accordingly, the EH&S Management System and its EH&S Plans will be reviewed and updated annually to reflect the needs of the planned activities. Various EH&S Plans will be prepared in a manner that facilitates easy updating and document review and control, in order to meet the changing needs of the Project.

As appropriate, VBNC will make draft EH&S Plans and substantial updates of these available to regulatory authorities, LIA, the Innu Nation and other interested parties for review. Such plans will be discussed with the Environmental Monitoring Committee (Section 4.14) prior to implementation.

4.2 Corporate Commitment and EH&S Policy

4.2.1 Corporate Commitment

VBNC is fully committed to the implementation of its EH&S Management System by having clear goals that will enable VBNC to meet its corporate EH&S responsibilities. The goals included are the following:

VBNC will continue to improve its safety performance for all those connected with its operation (employees, members of community, customers and contractors);

VBNC will continue to improve its ability to satisfy and fully meet commitments and obligations to customers, owners, employees, government regulatory agencies and members of the community;

VBNC will conduct its operations with awareness and appreciation for environmental, health, and safety matters, and always seek to comply with all regulatory requirements;

VBNC will provide systems so that all employees know their responsibilities, have the appropriate resources to perform their assignments, have the authority to get the job done, and are prepared and able to meet their responsibilities successfully; and

line management responsibility includes the areas of environment, health and safety.

EH&S issues are an integral part of the overall corporate and management function of VBNC's goals.

4.2.2 Environmental, and Health and Safety Policy

One of the earliest policy statements issued by VBNC was its EH&S Policy (Figure 4.3). This statement of commitment to stewardship and overall performance complies fully with INCO corporate policy.

As a member of the Mining Association of Canada (MAC), VBNC subscribes to MAC Policy which promotes the consistent integration of environmental considerations with each member company's planning and operations. MAC has also developed an Environmental Management Framework that describes four aspects of environmental management: leadership and commitment; planning; implementation; and monitoring, assessment, and improvement. VBNC has used this framework in its planning to guide development of its policies and procedures.

Recognizing the important role of the Aboriginal people of Labrador, VBNC developed an Aboriginal policy (Appendix 4A). This policy establishes fundamental principles that are integrated throughout all activities of VBNC. In addition, an important component of VBNC's EH&S Management System is ongoing public involvement.

4.3 Roles and Responsibilities

As a wholly-owned subsidiary of INCO, VBNC is accountable to INCO, with the President of VBNC reporting directly to the chairman and CEO of INCO. INCO provides, through its corporate EH&S department, guidance and direction to all its divisions and subsidiaries with respect to their environmental, health and safety performance. INCO also conducts EH&S audits throughout all of its divisions and subsidiaries. The EH&S audit procedure identifies the audit protocol, action plan response, and verification procedures. The results of all audits are presented to the INCOs' Board of Directors.

The President of VBNC is responsible for the direction of VBNC's EH&S Management System and approves environmental policies and plans.

Figure 4.3 Environmental, Health and Safety Policy

An organization should focus on what needs to be done (the purpose) and have the commitment to take the appropriate action in support of the EH&S Management System. It should have the capability of performing in support of its objectives; and be continuously learning how to perform better in the pursuit of its objectives. It should be continuously learning how to improve its own management and learning process (Canadian Standards Association (CSA) 1994).

The VBNC organization structure is designed to provide the necessary resources for implementing the EH&S Management System. The reporting structure ensures all levels of management are aware of VBNC's EH&S performance. The relevant roles, responsibilities, and relationships of various positions within the VBNC organization structure are summarized below.

The VBNC President approves EH&S safety policies and directs the implementation of these policies and plans.

VBNC's officers, including the Vice President, Mine/Mill and the Vice President, EH&S, implement the policies and plans and report to VBNC's senior management on the implementation and status of environmental measures. Issues of non-compliance are addressed promptly and reported to VBNC's senior management and as appropriate, to INCO's Board of Directors.

Line Managers inform all employees of corporate EH&S policies, procedures and plans. Line Management is responsible for the EH&S performance of the people and facilities under their control.

Staff of the EH&S Department have the responsibility to obtain permits, advise on methods and procedures, assist in development and implementation of plans and procedures, coordinate audits as required, act as liaison with external stakeholders, provide technical support on monitoring and research, and report on performance statistics.

Contractors and sub-contractors are required to adhere to the EH&S performance standards and policies defined by VBNC and INCO. During contractor selection, VBNC and INCO will take into account contractor EH&S performance and whether contractors have an appropriate internal EH&S Management System.

VBNC, as operator of the Project, has assigned responsibility to INCO's Engineering Project Management and Technical Sales Group for engineering and construction management for the Project. INCO has contracted SNC-Lavalin to provide project, construction, and site management for the Project facilities. SNC-Lavalin is also responsible for the engineering, procurement, and technical management of the mill and associated infrastructure.

Environmental planning begins long before the first ore is extracted. From the outset of its planning for the Project, VBNC gathered a considerable amount of valuable environmental information from residents of communities on the North Coast of Labrador, from LIA and Innu Nation and from a detailed analysis of the results of environmental baseline studies. VBNC has used this information to help develop an EH&S Management System. This system is the foundation upon which VBNC has developed policies, management decisions, technical designs, equipment selection, and detailed work procedures for the Project.

All employees will be made aware of applicable procedures and their responsibilities for following EH&S procedures. Employees will participate in ongoing training courses and exercises related to EH&S issues and practices. Additional training needs will be identified and provided to all personnel whose work may involve special EH&S concerns, such as working adjacent to water courses. Records and documentation will be maintained for operational practices.

4.4 Environmental Assessment and Design

VBNC has been working in the Voisey's Bay area since 1994. As a result, VBNC has gained considerable appreciation for the people and the environment of the Landscape Region (defined in Chapter 2), the sensitivity and importance of Inuit and Innu culture and the relationship of Aboriginal peoples with the land, water and sea.

As VBNC's exploration activities continued, the EH&S needs of the Project increased. To this end, the EH&S Plans supported the exploration activities, such as the EPP for exploration and its associated Emergency Response and Contingency Plans (VBNC 1997b) and Aboriginal involvement in the Project. Since 1995, government involvement regarding site environmental issues have continued by, for example, the issuance of permits, approvals and authorizations for exploration and related work.

In the absence of an environmental assessment process prior to January 1997, VBNC established an Advisory Group of independent experts, to provide advice on the scope and extent of baseline studies.

Early in the planning stages, well before the Guidelines were established, VBNC initiated a wide range of environmental baseline studies leading up to the eventual preparation of this EIS and the evolving EH&S Management System needs. As a result of this effort, VBNC undertook an exhaustive series of studies in 1995, 1996 and 1997. These have been released as technical data reports. The environmental baseline studies represent VBNC's significant investment in data and documentation that have been included in this EIS. The design of these baseline studies for 1996 and 1997 involved extensive liaison with LIA, the Innu Nation, and government officials.

In parallel with the baseline studies, VBNC has undertaken a number of investigations of the engineering feasibility of the Project. These are described in the Project Description (Chapter 3).

As a result of these early and proactive planning and design activities, the Project Description (Chapter 3) contains a large amount of environmental design mitigation. Many of the potential environmental effects of the Project have been considered and managed by VBNC through an ongoing analysis of alternatives and information feedback (with government and with LIA and the Innu Nation). This EH&S Management System is founded on this important planning base as depicted in Figure 4.1 and Table 4.1. It is apparent, particularly in Table 4.1, that environmental design mitigation has been a crucial, early contribution to the EH&S Management System.