Strengthening fitness for duty: REGDOC-2.2.4

The Canadian Nuclear Safety Commission (CNSC) published new regulatory requirements in REGDOC-2.2.4, Fitness for Duty, Volume II: Managing Alcohol and Drug Use to provide reasonable assurance that workers who could pose a risk to nuclear safety or security at Canada’s high-security nuclear facilities are fit for duty and are not under the influence of alcohol or drugs.

In nuclear facilities across Canada, nuclear safety and security is reliant on human performance. Recognizing this, the CNSC requires nuclear power plants (NPPs) to implement and maintain human performance programs, including programs to ensure that workers are fit for duty. An important element of being fit for duty is being free from the influence of alcohol or drugs and the responsible use of performance-altering medications while at work. To improve oversight of fitness for duty and overall facility safety, the CNSC has strengthened fitness-for-duty regulatory requirements in relation to alcohol and drug policy and programs, and alcohol and drug testing.

Fitness for duty

But what exactly is fitness for duty?

Fitness for duty refers to a condition in which workers are physically, physiologically and psychologically capable of competently and safely performing their tasks. The implementation of an effective fitness-for-duty program provides reasonable assurance that workers have the capacity and are free of any impairment, and as such, do not pose a safety or security risk.

Within the CNSC’s existing regulatory framework, fitness for duty is part of the human performance management safety and control area (SCA), which is one of fourteen specific SCAs. This SCA covers all activities that enable effective human performance through the development and implementation of processes with the aim of ensuring that licensee personnel have the necessary knowledge, skills, procedures and tools in place to safely carry out their duties.

REGDOC-2.2.4, Fitness for Duty, Volume II: Managing Alcohol and Drug Use contains a number of requirements and considerable guidance related to managing and monitoring alcohol and drug use. These requirements are tailored to the worker’s job performance requirements. In safety-sensitive industries such as the nuclear industry, these programs provide reasonable assurance that workers are free of any impairment that could hinder their ability to safely and competently perform the duties of their position. Regulating fitness for duty is important because human performance is central to the safety and security of nuclear facilities. In fact, the International Atomic Energy Agency (IAEA) expects regulatory bodies to have fitness-for-duty requirements at nuclear facilities, including requirements on substance use.

Alcohol and drug policy, programs and testing

To provide reasonable assurance that workers at Canada’s high-security nuclear facilities remain free from the impairing effects of alcohol and drugs, the CNSC has added requirements that strengthen existing fitness-for-duty oversight. For instance, workers in safety-sensitive positions at high-security sites are subject to alcohol and drug testing. Random and pre-placement alcohol and drug testing are limited to workers in safety-critical positions who have the most direct and immediate impact on safety and security. These improvement measures help to:

• provide reasonable assurance that workers who could pose a risk to nuclear safety or security at Canada’s high-security nuclear facilities are fit for duty
• make fitness-for-duty requirements and guidance more transparent, consistent and comprehensive as part of the CNSC’s efforts to strengthen overall nuclear safety and security
• address the International Atomic Energy Association’s (IAEA’s) expectations, and ensure that international best practices in relation to alcohol and drug testing are met

REGDOC-2.2.4, Fitness for Duty, Volume II: Managing Alcohol and Drug Use was developed through extensive research, benchmarking and broad-based consultations with stakeholders. Public consultations were held in two phases over a four-year period from 2012 to 2016. Both public and stakeholder consultations have been extensive and meaningful. Comments received during the public consultation period, as well as more information regarding REGDOC-2.2.4, are posted on the CNSC’s website.

Taken together, REGDOC-2.2.4, Fitness for Duty, Volume II: Managing Alcohol and Drug Use and REGDOC-2.2.4, Fitness for Duty: Managing Worker Fatigue (published March 2017), provide an extensive set of fitness-for-duty requirements and guidance to further strengthen nuclear safety and security. REGDOC-2.2.4, Fitness for Duty, Volume II: Managing Alcohol and Drug Use will help ensure that human performance is not compromised at high-security facilities. These new requirements serve to minimize the potential for human error, thereby improving the safety of Canada’s nuclear facilities.