Fitness for duty
Human performance is a key contributor to the safety of nuclear facilities. One factor that affects human performance is fitness for duty, which refers to a condition in which workers are capable of competently and safely performing their tasks. The adoption of measures that address alcohol and drug use or abuse is a key component of ensuring worker fitness for duty.
Draft regulatory document REGDOC-2.2.4, Fitness for Duty, was first presented to the Commission in August 2017. This document included requirements and guidance for managing worker fitness for duty with respect to alcohol and drug use and abuse, along with medical, psychological and occupational fitness requirements. These latter requirements have since been removed. Further to this revision, REGDOC-2.2.4, Fitness for Duty, was renamed REGDOC-2.2.4, Fitness for Duty, Volume II: Managing Alcohol and Drug Use.
Medical, psychological and occupational fitness requirements for nuclear security officers are covered in RD-363, Nuclear Security Officer Medical, Physical, and Psychological Fitness
Requirements and guidance of REGDOC-2.2.4, Fitness for Duty, Volume II
The requirements and guidance in REGDOC-2.2.4, Fitness for Duty, Volume II: Managing Alcohol and Drug Use, apply to high-security sites, such as nuclear power plants. In these facilities, certain workers identified as holding safety-sensitive and safety-critical positions will be required to submit to for-cause testing for alcohol and drug use under reasonable grounds and post-incident testing circumstances, as well as follow-up testing after confirmation of a substance dependency issue.
Only workers holding safety-critical positions are now required to submit to random testing for alcohol and drug use. In addition, job applicants for safety-critical positions are required to submit to pre-placement alcohol and drug testing once they have progressed through the previous stages of a job competition.
All of these requirements represent reasonable occupational and operational requirements for the applicable worker population.
The International Atomic Energy Agency (IAEA) recommends that all nuclear facilities have guidelines on fitness for duty related to substance use. A recent IAEA peer-reviewed mission also recommended that certain Canadian nuclear facilities have random alcohol and drug testing programs.
REGDOC-2.2.4, Fitness for Duty, was developed through extensive research, benchmarking and broad-based consultations with stakeholders. Public consultations were held in two phases from 2012 to 2016.
Consultation on the fitness-for-duty project began when the CNSC issued discussion paper DIS-12-03, Fitness for Duty: Proposals for Strengthening Alcohol and Drug Policy, Programs and Testing, for public comment. The discussion paper presented the CNSC’s broad view of fitness for duty and included specific proposals for alcohol and drug policies. Recognizing the need to balance nuclear safety and security with human rights, the CNSC also reached out to the Canadian Human Rights Commission to seek its views. CNSC staff considered all comments received during the public consultation on DIS-12-03.
The CNSC continued to engage stakeholders while the regulatory document was being developed. Presentations were made to the Canadian Nuclear Workers’ Council, the CANDU Owners Group, the Chief Nuclear Officers Forum and other organizations.
A draft version of REGDOC-2.2.4, Fitness for Duty, was issued for public consultation from November 9, 2015 to March 7, 2016, with a further period in April and May of 2016 to provide feedback on comments received. CNSC staff carefully reviewed and considered all comments.
Public Commission meetings
On August 17, 2017, CNSC staff presented REGDOC-2.2.4, Fitness for Duty, to the Commission and recommended that it approve the regulatory document for publication. As a result of the meeting and after further deliberations, the Commission directed staff to remove content concerning medical, psychological and occupational aspects of fitness for duty. To reflect this decision, the document was renamed REGDOC-2.2.4, Fitness for Duty, Volume II: Managing Alcohol and Drug Use.
On November 9, 2017, the Commission adopted the minutes of the August 2017 meeting, which included the approval of REGDOC-2.2.4, Fitness for Duty, Volume II: Managing Alcohol and Drug Use.
REGDOC-2.2.4, Fitness for Duty, Volume II: Managing Alcohol and Drug Use, is intended to form part of the licensing basis for high-security sites and will be incorporated into the licence conditions handbook (LCH) for each applicable licensee. Implementation plans and timelines that have been reviewed and accepted by CNSC staff will be included in the LCH. For fitness for duty, it is expected that these plans and timelines will allow for licensee consultations with impacted workers.