Audit of NRCan’s Management Framework for Responsibilities under the Emergency Management Act (EMA) (AU1502)

TABLE OF CONTENTS

EXECUTIVE SUMMARY

INTRODUCTION

The Emergency Management Act (2007) requires that all federal departments and agencies prepare plans to deal with emergencies. Specifically, “All federal Ministers are responsible for developing, maintaining, testing and exercising emergency management plans to address risks in their area of responsibility.”^Footnote1 “In Canada, emergency management adopts an all-hazards approach to address both natural and human-induced hazards and disasters. The ultimate purpose of emergency management is to save lives, preserve the environment and protect property and the economy.^Footnote2” Under the Act, the Minister of Public Safety is responsible for exercising leadership for emergency planning across all federal departments.

Within that context, each Department is responsible for ensuring an appropriate departmental response and to provide support for situations related to their respective areas of responsibility. As such, NRCan has developed nine Emergency Management Plans (EMP) related to the following topics: Wildland Fires; Geological Hazards; Space Weather; Geomatics Support; Nuclear Explosions Monitoring; Nuclear and Radiological Incidents; Energy Supply Disruption; Offshore/onshore Oil and Gas Incidents; and Non-fuel Mineral and Metal Commodities and Production Shortages Support. (Appendix B provides a brief description of each EMP.) Accordingly, the Assistant Deputy Ministers of the Canadian Forest Service Sector, the Energy Sector, the Earth Sciences Sector, the Minerals and Metals Sector and the Corporate Management Services Sector within NRCan all have responsibilities of varying degrees related to these EMPs.

The Audit of NRCan’s Emergency Management Framework was included in the Department’s Risk-Based Audit Plan, and approved by the Deputy Minister on February 27, 2014. The audit was conducted during the period from June to September 2014.

The objective of the audit was to provide reasonable assurance on the overall adequacy of NRCan’s Emergency Management Framework. Specifically, the audit assessed:

• Governance and Accountability;
• Resourcing and Capability;
• Risk Identification; and
• Testing and Monitoring.

The audit scope addressed current NRCan Emergency Management Plans and their alignment with the Emergency Management Act and Public Safety Canada policies and standards that address emergency management in Canada. Specifically, the audit included EMPs in which NRCan has a primary role as well those where NRCan provides a support role such as technical or subject matter expertise, policy guidance or media relations assistance.

STRENGTHS

The Department has nine EMPs in place to support its EM related responsibilities and conducts tests on the majority of its EMPs on an annual basis. Departmental senior management is engaged through active involvement in training exercises, and have established clear accountabilities for areas of emergency management specific to sector Emergency Management Plans. A senior executive level committee is in place with Assistant Deputy Minister (ADM) representation and regularly scheduled meetings. The Department actively participates on inter-departmental working groups. Natural Resources Canada’s (NRCan’s) sectors allocate resources to develop, maintain and test EMPs to support the Department in meeting its EM mandate.

AREAS FOR IMPROVEMENT

Opportunities for improvement were identified to conduct updates for two Emergency Management Plans, clarify roles and responsibilities regarding the EM communications protocol; and improve monitoring and reporting to senior management. Lastly, there are opportunities to strengthen training by leveraging training opportunities provided through the table top emergency exercises.

AUDIT CONCLUSION AND OPINION

In my opinion, the Audit Branch can provide reasonable assurance that NRCan’s Emergency Management Framework is adequate to support its EM responsibilities. Specifically, the majority of Emergency Management Plans and related training exercises are updated and conducted on a regular basis.

Opportunities for improvement were identified to update two Emergency Management Plans, clarify roles and responsibilities regarding the EM communications protocol; and improve monitoring and reporting to senior management.

STATEMENT OF CONFORMANCE

In my professional judgement as Chief Audit Executive, the audit conforms with the Internal Auditing Standards for the Government of Canada, as supported by the results of the Quality Assurance and Improvement Program.

Christian Asselin, CPA, CA, CMA, CFE
Chief Audit Executive

ACKNOWLEDGEMENTS

The audit team would like to thank those individuals who contributed to this project and, particularly employees who provided insights and comments as part of this audit.

INTRODUCTION

The Emergency Management Act (2007) requires that all federal departments and agencies prepare plans to deal with emergencies. Specifically, “All federal Ministers are responsible for developing, maintaining, testing and exercising emergency management plans to address risks in their area of responsibility.”^Footnote3 “In Canada, emergency management adopts an all-hazards approach to address both natural and human-induced hazards and disasters… The ultimate purpose of emergency management is to save lives, preserve the environment and protect property and the economy.^Footnote4”

The Act, defines Emergency Management as ‘the prevention and mitigation of, preparedness for, response to and recovery from emergencies’ Under the Act, the Minister of Public Safety is responsible for exercising leadership for emergency planning across all federal departments. This responsibility includes the establishment of policies, programs and other measures respecting the preparation, maintenance, testing and implementation by a government institution of its Emergency Management Plans (EMPs).

Within that context, the Minister of Natural Resources is “responsible for ensuring an appropriate departmental response to situations for which emergency management responsibilities have been identified. The Minister must also respond to requests for federal assistance from municipal, regional, provincial and/or international governments or requests mandated by federal control of affected areas or memoranda of agreement or understanding.”^Footnote5 The Deputy Minister, as the chair of the Executive Committee, provides strategic-level guidance and oversight for NRCan emergency response decisions.

As described by the National Emergency Response System an emergency is “a present or imminent event that requires prompt coordination of actions concerning persons or property to protect the health, safety or welfare of people, or to limit damage to property or the environment.” The range of hazards and disasters that are relevant to emergency management include extreme natural events such as floods, hurricanes, forest fires, earthquakes or other events such as a leakage or explosion that occurs during the exploration or drilling for, or transportation of petroleum in an offshore area.

The activation of an EMP sets in motion a series of communications with other departments, and dependent on the event, with provincial, territorial and municipal authorities. The Public Safety Canada Communications Directorate coordinates emergency public communications activities for the Government of Canada between federal government institutions, with provincial/territorial partners, international partners, and with non-government organizations. The Communications Directorate also provides support and strategic public communications advice on issues relating to the public and media environment. Within Natural Resources Canada, these communications activities are executed and coordinated by the Public Affairs and Portfolio Management Sector.

NRCan coordinates its Emergency Management Program with the federal Government Operations Centre (GOC), a 24/7 facility housed within Public Safety Canada. The GOC is the federal government’s single point of contact for emergencies, and coordinates horizontally with other federal government departments, non-governmental organizations, the private sector and various local and provincial authorities.

Within the Department, the ADM of the Corporate Management Services Sector (CMSS) is responsible for implementing an effective and efficient Emergency Management Program, while the individual EMPs fall under the responsibility of the respective sector Assistant Deputy Ministers. The Security, Emergency Management and Intelligence Division (SEMID), within CMSS coordinates activities related to the departmental Emergency Management Program. SEMID also has other responsibilities in addition to emergency management, such as Intelligence, Business Continuity Planning and security (i.e. physical security and information security).

AUDIT OBJECTIVE

The objective of the audit is to provide reasonable assurance on the overall adequacy of NRCan’s Emergency Management Framework. Specifically, the audit assessed:

• Governance and Accountability;
• Resourcing and Capability;
• Risk Identification; and
• Testing and Monitoring.

The audit criteria are presented in Appendix A.

AUDIT CONSIDERATIONS

A risk-based approach was used in establishing the objectives, scope and approach to this audit engagement. The Corporate Risk Profile for NRCan includes the following operational risk statement: “There is a risk that NRCan is unable to effectively carry out its mandated emergency management accountabilities^Footnote6.”

During the planning for the audit, a further refinement of the above risk was developed through consultations with senior management. A summary of the specific risks taken into consideration to develop the audit areas of focus are provided below:

• In terms of the alignment of NRCan’s activities with central agencies, there is a risk that program activities and priorities are not aligned with TB and Public Safety Canada requirements for Emergency Management.
• There is a risk that the accountability framework among stakeholders (including third parties) is not sufficiently defined to provide clarity of roles and responsibilities for NRCan personnel and other entities implicated in support or leadership roles for response and recovery activities.
• There is a risk that the Department has not considered additional training and resources, if required.

All departments are required to have an established “all hazards”^Footnote7 approach to identify risks pertaining to Emergency Management. Failure to utilize a comprehensive analysis of risks pertaining to “all hazards” could impede the successful coordination, response and recovery from an emergency due to not having an established plan in place.

SCOPE AND METHODOLOGY

The audit focused on current NRCan Emergency Management Plans and their alignment with the Emergency Management Act and Public Safety Canada policies and standards that address emergency management in Canada. Specifically, the audit included EMPs in which NRCan is the designated lead agency as well those where NRCan provides a support role such as technical or subject matter expertise, policy guidance or media relations assistance.

The audit did not assess the Department’s ability to respond to an emergency impacting its assets, personnel and/or other security related matters, but rather focused NRCan’s emergency management role in a government-wide context driven by its responsibilities within the Emergency Management Act.

The audit did not assess Public Safety Canada or other partner government department’s emergency management programs and/or policies. As such, all recommendations resulting from this audit are directed exclusively to NRCan’s management. Considering the horizontal nature of this audit topic; however, the audit team coordinated with Public Safety’s internal audit function to conduct interviews with some Public Safety employees.

In addition, the audit did not assess the technical components and adequacy of the departmental Emergency Management Plans.

The audit methodology was based on Treasury Board Policy on Internal Audit and Government of Canada Internal Audit Standards and included:

• Interviews with the key personnel responsible various aspects of Emergency Management;
• Reviewing key documents and relevant background documents;
• Reviewing the processes and practices of internal controls; and
• Reporting the results and findings.

CRITERIA

Audit criteria used in the audit were developed from the key requirements of the Emergency Management Act (Government of Canada, 2007), Treasury Board of Canada’s Core Management Controls and relevant associated policies, procedures and directives. Please refer to Appendix A.

FINDINGS AND RECOMMENDATIONS

CONTEXT

Effective emergency management planning is a complex process and requires coordination and collaboration from multiple federal government departments and agencies, as well as provincial and municipal governments and other stakeholders. Considering the horizontal nature of emergency management, our audit provides assurance on the EM activities that fall under the responsibilities of NRCan and not on government-wide planning.

Considering the horizontal nature of this subject, the audit team conducted interviews with representatives from Public Safety Canada (PS). Public Safety is the lead federal government department responsible for providing government-wide leadership and oversight of emergency management (EM) activities for federal entities. Each federal department and agency is required to prepare and submit a Strategic Emergency Management Plan (SEMP) to Public Safety Canada every two years. The SEMP is a strategic document which provides an overview of an entity’s EM strategy and describes NRCan capabilities for the implementation of measures associated with emergency management.

In 2014, Public Safety Canada conducted an internal audit of Emergency Management Planning^Footnote8, which reported that government-wide structures were in place to lead EM across the federal government; however, they “are in need of improvement – both from an efficiency and effectiveness perspective”. Regarding monitoring of other federal institutions, the audit also found that "EM planning is done in a fragmented and, in some cases, insufficient fashion”, with recommendations made specifically to strengthen Public Safety’s (PS) government-wide monitoring mechanisms.

Although information regarding the roles and responsibilities of Public Safety provides context on the horizontal nature of EM planning, this audit focused exclusively on NRCan’s Emergency Management Framework to support its EM related responsibilities. Within NRCan, although the audit identified opportunities to strengthen certain aspects of EM planning related to management oversight and communications, the audit found that the core fundamentals were in place for the framework to meet the Department’s mandated responsibilities. 

Specifically:

• Sectors have allocated resources enabling NRCan to develop, update and test its nine Emergency Management Plans in place to address EM preparedness, mitigation, response and recovery under its responsibility;
• Emergency Management Plans are updated and tested regularly, as the majority of EMPs were updated and tested in 2013; with two EMPs last updated and tested in 2012;
• Senior management is engaged in EM planning through active participation in a department-wide ADM-level committee, as well as providing leadership and active participation to exercise and test Emergency Management Plans; and
• The Department regularly participates at inter-departmental committees to ensure collaboration and coordination of EM activities.

The following sections provide details on specific aspects of NRCan’s Emergency Management Framework. These sections include findings and recommendations to strengthen some processes; however, as the core fundamentals of EM planning were found to be in place within NRCan, the audit has concluded that NRCan’s EM framework is adequate to support Emergency Management areas which fall under its responsibility.

GOVERNANCE AND ACCOUNTABILITY

Summary Finding

NRCan has an adequate governance structure to support its Emergency Management mandate. Senior departmental management is actively engaged in various emergency management activities and there are clear accountabilities for specific areas of emergency management as described in the Emergency Management Plans. The audit identified opportunities to strengthen oversight committees through more regular meetings and timely reporting and to leverage other departmental resources and committees to address the reduced capacity of SEMID.

Supporting Observations

Government-wide EM Planning and NRCan

The Departmental EM Program adheres to the “whole of government” approach which is outlined within the Federal Emergency Response Plan^Footnote9 (FERP). Public Safety developed the FERP to enable a coordinated approach for the Government of Canada’s response to an emergency. The FERP identifies the Minister of NRCan as the “Minister with primary responsibility for support functions during emergencies where energy production and distribution are key elements.” There are currently 13 Emergency Support Functions (ESFs) identified by the federal government.  

Natural Resources Canada is named as the primary department for matters related to Energy Production and Distribution and plays a support role in seven other areas^Footnote10. As such, the Department has developed two EMPs to address responsibilities where it plays a “primary” role^Footnote11, as well as seven other EMPs where it provides “support”.

NRCan coordinates its Emergency Management Program with the federal Government Operations Centre (GOC), a 24/7 facility housed within Public Safety Canada. The GOC is the federal government’s single point of contact for whole of government emergencies. The GOC coordinates horizontally with other federal government departments and agencies, non-governmental organizations, the private sector and various local and provincial authorities for matters related to the activation of departmental EMPs.

Oversight by Public Safety of the NRCan Strategic Emergency Management Plan (SEMP) is evidenced by ongoing SEMP review by Public Safety Canada. NRCan adheres to the prescribed two year cycle for SEMP preparation and the departmental SEMP is current.

The Department participates on inter-departmental working groups including two committees at the DG level - the Director General Emergency Management Policy Committee (DG EMPC) and Director General Event Response Committee (DG ERC). Both committees support the interdepartmental Assistant Deputy Minister Emergency Management Committee (ADM EMC) and Deputy Minister Emergency Management Committee (DM EMC). The departmental Emergency Management Program supports the Deputy Minister, as well as the ADM and CMSS DG representatives who participate on these committees respectively.

Oversight

Within NRCan there are two key EM committees that play a critical role towards ensuring adequate oversight, coordination and cooperation to manage the department-wide Emergency Management Program.

The first is the Emergency Management, Security and Business Continuity Planning Committee (ESBC). This ADM level committee is co-chaired by the ADM CMSS and the ADM Earth Sciences Sector (ESS) with the objective of providing overall guidance and oversight to NRCan’s broader emergency management, security (including cyber security) and business continuity planning activities. Responsibilities related to EM include oversight with regard to the development of plans and preparedness of NRCan to address national or local emergencies requiring a contribution from NRCan for prevention, monitoring, and response.

The second key committee is the Emergency Management Working Group (EMWG). This committee is co-chaired by the CIO and DG-ESS with the objective to support NRCan’s EM Program and ESBC through horizontal collaboration on EM policies, plans, procedures and activities. Responsibilities include on-going review of EM risk management, develop, review and update EMPs, coordinate testing and report to ESBC on status of EMPs and testing.

The audit found that both ESBC and EMWG have sector representation from across the department, including personnel from SEMID. The audit noted; however, that although ESBC was attended by ADMs, EMWG representatives were often at the working level with minimal emergency management planning experience. Furthermore, the EMWG has only met on four occasions since September 2012, although their mandate was to meet on a monthly basis. As such, the EMWG does not convene with sufficient frequency to provide an effective challenge function to sector personnel tasked with the preparation of EMPs.

With regards to testing EMPs and related table top exercises which are tests on EMPs conducted by sectors to ensure the adequacy of any given EMP, oversight by either committee was also found to be minimal. Specifically, although ESBC discusses table top exercises through post-mortems, neither they nor EMWG conduct front-end reviews and endorsement of Sector EMPs; nor do they provide ongoing reporting to ESBC on the status of EMPs and testing activities. In summary, neither committee reviews, endorses or approves sector EMPs.

In recent years, a change in capabilities has resulted in SEMID shifting in focus from operational support (assistance in the maintenance of, planning and exercising of EMPs) to more administrative support (very high level monitoring of EMPs). As a result, SEMID continues to play a key coordination function; however, SEMID’s resources have been reduced by approximately 43% since 2009-10. Although duties have been adjusted and distributed across the Department’s Sectors to manage through these changes, the reduction have ultimately resulted in:

• A lack of capability to review EMPs and collaborate with sectors regarding testing and operational knowledge sharing;
• A diminished capacity to conduct in-depth review of EMP content as was done prior to the resource reductions; and
• The inability to provide and share with sectors the horizontal knowledge acquired from table top exercises and confirm that lesson’s learned are documented through ‘After Action Reports’, including the implementation of corrective actions, as required.

In response to the resource constraints identified above, SEMID’s emergency management resources have shifted focus from operational support as specified in the SEMP (i.e. assistance in the maintenance of, planning and exercising of EMPs) to more administrative functions such as the scheduling of committee meetings and coordination of agenda items.

Similarly, the previous Departmental Emergency Operations Centre (DEOC) Concept of Operations was based on having 4 FTEs in the DEOC during an emergency; however, this has recently been reduced to 1 FTE. The DEOC serves as the Department’s ‘command centre’ during a crisis to monitor developments and media reports, coordinate continuity of mission critical functions, liaise with other federal government departments agencies and to provide information to brief the Minister and other senior department officials. As a result of resource reductions, maintaining a 24/7 DEOC operation for a period in excess of three days could be challenging.

Leveraging Tabletop Exercises for Training

Audit interviews indicated that resource constraints have contributed to concerns within NRCan regarding the scope and breadth of emergency management training that is available. The audit noted that Tabletop Exercises (TTX) have emerged as a dual function activity.

Primarily the TTX are intended to provide a facilitated review of an emergency situation in an informal atmosphere. They are a mechanism to solicit conversations and problem resolution, outside the pressures of a real emergency. All participants assess the scenario to identify any gaps or weaknesses in response activities with the objective of strengthening the sector’s EMP.

Secondly, in the absence of formal training, the Tabletop Exercises have become the sole source of EM training at NRCan. This is problematic because Tabletop Exercises are specific to each sector EMP, therefore, apart from SEMID personnel, operational staff from outside sectors do not attend. When the only participants at the TTX are from a single sector, this constrains the horizontal sharing of EM knowledge between sectors.

In both functions outlined above, the discussions undertaken as a part of the TTX are significant because neither SEMID nor Public Safety provide an external 3rd party review on the quality of the TTXs or assess the consistency of the TTXs performed within the department.

Audit interviews indicated that some discussions have been held to assess reductions in the frequency of the TTX at NRCan due to resource pressures. In the event that the frequency of the TTX are reduced, this, in combination with the absence of formal training, may contribute to a diminished departmental EM capacity.

The audit identified opportunities to further enhance the value of the TTX by ensuring that observers from multiple sectors participate and attend these exercises and not simply those who are responsible for a specific EMP. This could strengthen TTX activities, as it would include additional training topics such as the Incident Command System and GOC operations.  Furthermore, this multi-Sector approach could allow for more effective coordination of resources across NRCan to identify and share “best practices” in EM between sectors.

MANAGEMENT INITIATIVE

Management is restructuring the Emergency Management, Security and Business Continuity Planning Committee. The review of the governance structure is scheduled to be presented at a fall 2014 ESBC meeting. The modified frequency and mandate of the committee of the ESBC and the proposal to endorse materials submitted to it would provide the ESBC with a venue to provide oversight of EM program activities. This may provide a more proactive means to promote discussion at the executive level on Emergency Management.

RISK AND IMPACT

A reduction of resources within SEMID, combined with a lack of an oversight and review of Sector EMPs could impact the quality of EMPs and the Department’s ability to meet its obligations during a national emergency.

RECOMMENDATION

1. Assistant Deputy Ministers of Corporate Management Services Sector (CMSS) and Earth Sciences Sector (ESS), as co-chairs of Emergency Management, Security and Business Continuity Planning (ESBC), should re-assess the roles, responsibilities and expectations of Emergency Management Working Group (EMWG) to ensure that it adequately supports ESBC in its oversight role, including ensuring adequate review, endorsement and testing of Emergency Management Plans (EMPs).
2. Director, Security, Emergency Management and Intelligence Division (SEMID) in consultation with sectors identify opportunities where Table Top Exercises (TTX) could be leveraged as training for NRCan staff involved in emergency management activities and ensure that sufficient staff from the Sectors and/or CMSS are trained to manage the Departmental Emergency Operation Centre (DEOC) operations to improve sustainability during an emergency situation.

MANAGEMENT RESPONSE, ACTION PLAN AND TIME FRAME

Management agrees.

In response to recommendation 1, a new governance structure was approved by the Deputy Minister on November 12, 2014. A key feature of the revised governance structure is the creation of a Director General (DG) level committee which replaces EMWG. ESBC is being replaced by the Assistant Deputy Minister – Security, Emergency Management and Intelligence Committee (ADM-SEMIC). The DG committee is called DG-SEMIC.

Position responsible: Assistant Deputy Ministers of CMSS and ESS

Timing: DG-SEMIC’s first meeting is December 10, 2014.

Management agrees.

In response to recommendation 2, as part of the forthcoming Functional Guidance: Emergency Management, a new requirement will be that TTX’s will be held in the DEOC (either physical or virtual based on region). The Functional Guidance is a new approach at NRCan.

Position responsible: Director, SEMID

Timing: Functional Guidance: Emergency Management to be issued by March 2015.

RISK IDENTIFICATION

Summary Finding

NRCan’s Strategic Emergency Management Plan is informed by an ‘all-hazards’^Footnote12 risk based approach and addresses most central agency requirements. The audit identified an opportunity to complete a risk assessment to ensure there are adequate resources (assets and personnel) related to EM functions.

Supporting Observations

The sector operational Emergency Management Plans are informed by the department's Strategic Emergency Management Plan (SEMP). A component of the biennial review of the SEMP is the completion of an All Hazards Risk Assessment exercise (AHRA), which ensures that appropriate and sufficient resources are available to fulfil the department’s ‘whole of government’ emergency management mandate. The last AHRA performed in the autumn of 2012 included inputs from the following sectors:

• Canadian Forest Service
• Earth Sciences
• Energy
• Minerals and Metals
• Science and Policy Integration

The risk assessment is brought forward to the ESBC for endorsement prior to identification of sector operational emergency management plans required to be in place to address identified risks. Public Safety Canada has conducted two reviews of NRCan's Strategic Emergency Management Plan over the past 5 years. These assessments resulted in six recommendations for improvement, for which the majority have since been implemented.

The outstanding recommendation from Public Safety regarding risk identification, relates to the creation of an EM inventory to track all assets and personnel required for EM functions. An EM inventory would assist the department in identifying current capabilities thereby enabling a comparison to required needs and the identification of capability gaps that may exist. An EM inventory is a prerequisite for a comprehensive capability based all-hazards risk assessment.

MANAGEMENT INITIATIVE

SEMID is currently developing a functional planning guide that will assist in the preparation of the SEMP and other emergency management planning documents. This guide will require sectors to take an inventory of their emergency management response capabilities and related gaps and will be part of the risk validation process to be completed by April 2015.

RISK AND IMPACT

Without a comprehensive complete EM inventory, the department cannot determine if the correct and sufficient resources are available and mitigate any identified deficiencies required to fulfil the department’s ‘whole of government’ emergency management mandate. A comprehensive complete EM inventory would help ensure targeted resources and arrangements are in place in advance to aid in responding or contributing to the whole of government coordination of events.

RECOMMENDATION

3. Assistant Deputy Minister Corporate Management Services Sector (CMSS), should ensure that the preparation of the Strategic Emergency Management Plan (SEMP) 2015-17 includes a capability based all hazards risk assessment (gap analysis).

MANAGEMENT RESPONSE, ACTION PLAN AND TIME FRAME

Management agrees.

In response to recommendation 3, the Functional Guidance: Emergency Management will include a requirement for a capability based all hazards risk assessment (gap analysis). In addition, the 2015-17 Strategic Emergency Management Plan (SEMP) will include a capability based all-hazard risk assessment, as required by the Federal Policy for Emergency Management.

Position responsible: Assistant Deputy Minister CMSS

Timing: Functional Guidance: Emergency Management to be issued by March 2015

Timing: All hazards risk assessment to be completed as part of the 2015-17 SEMP by March 31, 2016

TESTING AND MONITORING

Summary Finding

Overall, the majority of NRCan’s Emergency Management Plans are regularly reviewed, updated and exercised. The audit identified that this was not the case for two of the nine EMPs. In these instances, the plans were not always completed in a consistent and timely manner; and that monitoring of these activities was not reported to senior management on a regular basis.

Supporting Observations

Emergency Management Plans

NRCan has nine emergency management plans in place to address the Department’s mandated responsibilities under the Emergency Management Act. The EMPs are prepared by subject matter experts within the sectors, and are based on key pieces of legislation governing NRCan's emergency management mandate, the departmental annual all-hazards risk assessment exercise, and the authority and guidance from the Strategic Emergency Management Plan (SEMP).

NRCan’s emergency management practice requires sectors to review EMPs annually and update them, as necessary. EMPs were once co-written by SEMID and sector staff, but SEMID no longer performs this function and EMPs are updated unilaterally by the sectors. Although updated EMPs are approved by their sector ADMs and submitted to SEMID for records management purposes, SEMID does not conduct a review of the EMPs. Furthermore, ESBC does not receive updates on the progress of EMPs from either SEMID or EMWG on a regular basis.

The audit found that although seven of the Department’s EMPs have been updated within the past year, the EMPs for Energy Supply Disruption and Onshore-Offshore Oil and Gas Incidents (both from Energy Sector) were both out of date. The last updated version of these two EMPs is dated 2012, while the department-wide SEMP was updated in April 2013. Therefore, any new changes or revisions from the SEMP have not been implemented or reflected in these two EMPs and other changes, such as Sector personnel with key responsibilities may also be out of date.

Furthermore, although the audit did not test the quality of the technical components and adequacy of the departmental EMPs, the audit did note that accountabilities related to EMPs were often complicated involving joint responsibilities with other government departments and partners. For example, accountabilities related to the EMP for Onshore-Offshore Oil and Gas Incidents are quite complex and involve multiple stakeholders from both public and private sectors, industry associations, and regulatory bodies. Additionally, the location of the emergency is linked to jurisdictional accountabilities that are coordinated through various petroleum boards and can include Aboriginal Affairs and Northern Development Canada.

Roles and Responsibilities of each department for any given EMP may vary depending on circumstances surrounding the event. Although each EMP reviewed included a brief section related to the role of other stakeholders, the audit found these to be limited in detail. These sections would be particularly beneficial to ensure clarity of accountabilities during a crisis particularly if the department experiences turnover of key positions with EM responsibilities.

In addition, the audit found that the EMPs, although regularly reviewed and updated, did not reference the Crises and Emergency Communications Protocol (the protocol) developed by the Public Affairs and Portfolio Management Sector (PAPMS). The primary objective of the protocol is to promote the organizational, decision-making, information-sharing and strategic approaches to allow NRCan to respond to the communications demands of a crisis or emergency situation.

Overall, the audit found that there was a lack of knowledge of the protocol within the individual sectors. In general, staff responsible for specific EMPs were not informed or aware of the Crisis and Emergency Communications Protocol and how it is to be implemented in the event of an actual emergency. Accordingly, there was no reference to the protocol within any of the nine EMPs reviewed.

Table Top Exercises

NRCan exercises its emergency management plans by conducting Table Top Exercises (TTX) to test the performance and effectiveness of the plans and processes. As per the SEMP, ESBC approves the calendar of TTX, which are planned and scheduled by the sectors.

In the past, TTX were planned by SEMID and the sectors; SEMID no longer oversees this task. Additionally, there is no documented methodology that sectors must follow when planning TTX, aside from having SEMID and PAPMS representatives present.

After completion, a summary of the Table Top Exercise is presented at ESBC, including feedback from the exercise, lessons learned, and any identified corrective action. The outcomes from the exercise contribute to the ongoing update and improvement to the EMP and the underlying Standard Operating Procedures (SOPs).

In fiscal 2013-2014, while all nine EMPs were scheduled to be exercised, only seven of nine exercises were conducted. The exercise for the Wildland Fires EMP was expanded to a national exercise and postponed to fiscal 2014-2015. The Energy Supply Disruption EMP was not formally exercised. The audit team has been advised that for 2014-2015, all nine EMPs are scheduled to be tested/exercised.

Similar to EMPs, the audit found that ESBC does not receive updates from either SEMID or EMWG on the completion or postponement of scheduled EMP exercises.

RISK AND IMPACT

A lack of oversight and central guidance on sector emergency management activities, could expose the Department to a risks related to effective and consistent emergency management planning, potentially impacting its ability to meet obligations during a national emergency. Similarly, the absence of awareness and references to the protocol within the EMPs, could lead to inconsistencies between the identified communication strategy in each EMP increasing the likelihood of conflicting messaging during an emergency.

RECOMMENDATION

4. Director, Security, Emergency Management and Intelligence Division (SEMID) should:

1. provide regular reports to Emergency Management Working Group (EMWG) and annual reports to Emergency Management, Security and Business Continuity Planning (ESBC) regarding the status of Emergency Management Plans (EMPs) updates and related testing to ensure committee members are provided with the necessary information to enable their respective oversight and monitoring roles; and
2. Work with Sectors to ensure that updates to EMPs consider clarifying roles and responsibilities between Natural Resources Canada (NRCan) and other federal government departments, as required, and are documented accordingly.

5. Director SEMID, Director SEMID, in collaboration with Public Affairs and Portfolio Management Sector (PAPMS) and a strengthened EMWG, review and validate the communications protocols to be used for specific sector EMPs and obtain ESBC endorsement.

6. The Assistant Deputy Minister Energy Sector (ADM-ES) should ensure that both ES emergency management plans are:

1. reviewed and exercised on an annual basis; and
2. updated biannually with the departmental Strategic Emergency Management Plan and ensure future versions consider clarifying roles and responsibilities between NRCan and other federal government departments, as required, and are documented accordingly.

MANAGEMENT RESPONSE, ACTION PLAN AND TIME FRAME

In response to recommendation 4a., Regular updates and status will be provided at the appropriate level in the new governance structure.

Position responsible: Director, SEMID

Timing: To be determined based on the annual EMP updating schedule.

In response to recommendation 4b., EMPs will be reviewed to ensure clarification of roles and responsibilities.

Position responsible: Director, SEMID

Timing: To be determined based on the annual EMP updating schedule.

Management agrees.

In response to recommendation 5, the Functional Guidance: Emergency Management will incorporate communications protocol requirements.  The Function Guidance will be endorsed by the appropriate level in the new governance structure

Position responsible: Director, SEMID

Timing: Functional Guidance: Emergency Management to be issued by March 2015.

Management agrees.

In response to recommendation 6, ADM-ES is committed to reviewing and exercising its emergency management plans on an annual basis and updating these plans biannually in conjunction with updates to the departmental Strategic Emergency Management Plan.   

Energy Sector completed a review and exercise of its emergency management plan for Onshore-Offshore Oil and Gas incidents in June 2014. Updates to the plan were made in November 2014 to incorporate lessons learned and to better clarify roles and responsibilities of NRCan and its federal partners in responding to an incident.

In September 2014, Energy sector underwent a comprehensive peer review of its emergency response plans for Energy Supply Disruptions as part of its membership obligations as a member of the International Energy Agency (IEA). Energy Sector is also currently reviewing and developing a table top exercise to test its Emergency Management plan for Energy Supply Disruptions. ADM-ES will ensure that the plan will be tested and updated with lessons learned and feedback from the IEA’s peer review by January 31, 2015.

Following these updates, ADM-ES will ensure that both plans are reviewed biannually to ensure contact information and other details remain current, in addition to carrying out annual exercises.

Position responsible: ADM-ES

Timing: January 31, 2015

APPENDIX A – AUDIT CRITERIA

The objective of the audit is to provide reasonable assurance for the adequacy of Natural Resource Canada's Emergency Management Framework. Specifically, the audit assessed; Governance and Accountability, Resourcing and Capability, Risk Identification, and Testing and Monitoring.

Lines of Enquiry	Audit Criteria
There is an adequate governance structure in place, including clear and well-defined accountabilities, as related to Emergency Management.	Governance 1.1 It is expected that there is a well-defined and applied governance regime at the branch, department and government level that enables information sharing, coordination, communication of direction and oversight (of both branch and government results).
	1.2 It is expected that emergency management plans and procedures are consistent and in compliance with Treasury Board and departmental policies, standards, and guidelines, as well as those of Public Safety Canada.
	1.3 It is expected that NRCan has operational plans/work plans and objectives to achieve its emergency management mandate.
NRCan has appropriate resources to fulfill its Emergency Management responsibilities.	Resourcing and Capability 2.1 It is expected that resources are allocated to ensure that NRCan has the capability to deliver on the requirements of the Emergency Management Act.
	2.2 It is expected that the sectors allocate their resources in a manner to ensure there is capability to meet the requirements of their respective EMPs.
	2.3 It is expected that NRCan has established and uses a risk-based approach to identify the resources needed and to coordinate the response and recovery from emergencies.
	People and Knowledge 2.4 It is expected that emergency management preparedness provides employees with the necessary training, tools, and resources to deliver on their mandate.
	Roles and Responsibilities 2.5 It is expected that there is an organizational structure in place that adequately manages resources and clearly defines roles, responsibilities, accountabilities and delegations for emergency management that is communicated to staff.
NRCan uses an “all hazards” risk-based approach which is aligned with central agency requirements, and adjusted as appropriate.	Risk Identification 3.1 It is expected that the emergency management program is designed and funded using a risk-based all-hazards approach, and includes prevention and mitigation, preparedness, response, and recovery.
	3.2 It is expected that emergency management plans are subject to a review and challenge function to ensure ongoing validity against a changing environment.
Effective and timely oversight of Emergency Management activities are in place to support decision making and to ensure the adequacy of the EMPs.	Testing and Monitoring 4.1 It is expected that NRCan has a systematic approach to conduct exercises in areas related to the defined NRCan areas of risk.
	4.2 It is expected that management has oversight practices and procedures in place to measure and evaluate the performance and effectiveness of the emergency management plans and processes that will support decision-making and accountability.
	4.3 It is expected that emergency management plans are periodically exercised through simulation to assess the organization’s ability to effectively implement them. Feedback from these exercises is recorded and informs ongoing improvements to the Emergency Management Plans and underlying Standard Operating Procedures.

* The criteria have been developed from the key requirements of the Emergency Management Act (Government of Canada, 2007), Emergency Management Planning Directive (NRCan, 2009), Treasury Board of Canada’s Core Management Controls and relevant associated policies, procedures and directives.

APPENDIX B – SUMMARY OF EMERGENCY MANAGEMENT  PLANS

Emergency Management Plan: “a program, arrangement or other measure for dealing with an emergency by the civil population; or for dealing with a civil emergency by the Canadian Forces in accordance with the National Defence Act.” (Source: Emergency Management Act)

The following EMPs, based on the Federal Emergency Response Plan, identify departmental roles where NRCan has a Primary or Support Role.

Primary Role

Energy Supply Disruption: “The purpose of NRCan’s EMP: Energy Supply Disruption is to guide the departmental and sectoral operational response to a nationally significant electrical, oil or natural gas supply disruption. This EMP guides NRCan and Energy Sector operational decision-making in response to nationally significant energy supply disruptions or to international energy supply disruptions that have an impact on Canada.” ^Footnote13

Offshore Oil and Gas Incidents: “The purpose of NRCan’s EMP: Offshore Oil and Gas Incidents is to guide the departmental and sectoral operational response to an emergency that occurs during the exploration or drilling for, or the production, conservation, processing and transportation of petroleum in an offshore area.”^Footnote14

“The Minister, Natural Resources shall be prepared to provide advice, guidance and assistance relating to an offshore oil and gas incident to the Governor in Council, other government departments and agencies, and the public and private offshore oil and gas stakeholders.”

“In the event that the offshore oil and gas incident also results in a nationally significant energy supply disruption, then EMP: Energy Supply Disruption may need to be activated in addition to this plan.” ^Footnote15

With that said, it should be noted that responsibilities regarding oil and gas incidents may vary, depending on the circumstances and nature of the situation. Although NRCan’s EMP was developed to address its ‘primary role’ regarding offshore oil and gas incidents, other federal government may have the primary role for similar incidents, such as spills from ships in Canada’s marine environment. As described in Chapter 1 – Oil Spills from Ships in the Commissioner of the Environment and Sustainable Development’s 2010 Fall Report, Transport Canada sets guidelines and establishes the regulatory framework for preparedness and response to ship-source spills and also certifies private sector response organizations. The Canadian Coast Guard is the lead federal agency for responding to spills and is responsible for ensuring an appropriate response takes place; and Environment Canada is the federal authority for providing environmental advice when a spill happens^Footnote16. Based on the nature of the event, another department may be the lead regarding an oil or gas spill incident.

Support Role

Wildland Fires: “NRCan – CFS’ EMP provides a description of wildland fire disturbances, our responsibilities, state of preparedness, mitigation strategies, and recovery plans. Our response to wildland fires involves a range of information gathering and analysis, as well as provision and dissemination of scientific and technical expertise related to the specific disturbance. The plan details how the departmental and sectoral emergency management structures will be activated and provides the operational decision making process that will take place in response to domestic wildland fires and/or international requests for emergency assistance in the suppression or management of wildland fires.”^Footnote17

Geological Hazards: “The purpose of NRCan’s EMP: Geological Hazards is to guide departmental and Earth Sciences Sector emergency management of earthquakes, tsunamis, volcanic situations, and landslides affecting Canada.”^Footnote18

“NRCan’s primary response to earthquakes, tsunamis, and volcanic situations is continuous monitoring and notification of significant events within Canada. For earthquakes, tsunamis, volcanic situations, and landslides, ESS subject matter experts can provide analysis and interpretation of seismological, vocanological, geological, and geotechnical data and information to emergency management organizations, critical infrastructure operators, media, and the general public.”^Footnote19

Space Weather: “The purpose of NRCan’s EMP: Space Weather is to guide departmental and Earth Sciences Sector emergency management of space weather events affecting Canada.

Space weather refers to a suite of processes emitting energy from the sun as electromagnetic radiation and/or electrically charged particles. The radiation and particles interact with Earth’s geomagnetic field and outer atmosphere affecting a variety of technologies, infrastructure, and activities including, but not limited to, satellite operation, radio communications, magnetic surveys, directional drilling, navigation via GPS and magnetic compass, power lines, and pipelines.”^Footnote20

Geomatics Support: “The purpose of NRCan’s EMP: Geomatics Support is intended to guide departmental and Earth Sciences Sector management of requests for geomatics support.

Situational awareness is a critical component of the decision-making process during emergencies and is facilitated by the availability of geospatial data produced through geomatics, the science and technology of gathering, analysing, interpreting, distributing and using geographic information. Geomatics encompasses a range of disciplines that can be used to create detailed maps, remotely sensed imagery, and geospatial analyses of the physical world. NRCan’s geomatics expertise allows the department to support emergency management efforts through the provision of mapping, remote sensing, and geospatial analyses products and expertise.”^Footnote21

Nuclear Explosions Monitoring: “The purpose of NRCan’s EMP: Nuclear Explosions Monitoring is to guide the departmental and Earth Sciences Sector operational management of requests for confirmation or assessment of declared or suspected nuclear explosions or other events of interest.”^Footnote22

“NRCan operates a network of sensor systems for nuclear explosion detection. Sensor data are used to confirm or assess declared or suspected nuclear explosions or other events of interest. NRCan also provides data to the Comprehensive Nuclear Test Ban Treaty Organization (CTBTO).”^Footnote23

Nuclear and Radiological Incidents: “The purpose of NRCan’s EMP: Nuclear and Radiological Incidents is to guide the departmental, Energy Sector, Earth Sciences Sector, and Corporate Management and Services Sector operational emergency management of nuclear and radiological incidents affecting or potentially affecting Canadians.”^Footnote24

“NRCan supports implementation of the all-hazards Federal Emergency Response Plan (FERP) led by Public Safety and the Federal Nuclear Emergency Plan (FNEP), an event-specific plan that is integrated with the FERP, led by Health Canada for nuclear and radiological incidents affecting, or with the potential to affect, Canadians. Such incidents include, but are not limited to, nuclear facility emergencies and the potential, accidental, or deliberate release of radiological material. NRCan’s response is coordinated in close consultation with its portfolio partners, the Canadian Nuclear Safety Commission and Atomic Energy of Canada Limited.”^Footnote25

Non-fuel Mineral and Metal Commodities and Production Shortage Support: “The purpose of NRCan’s EMP: Non-fuel Mineral and Metal Commodities and Production Shortages Support is to provide government emergency planners with an overview of the mechanism for assigning priorities to industrial projects. This will ensure that scarce industrial inputs are used, in the first instance, to satisfy essential emergency requirements in an emergency and to identify a step-wise action plan to respond to departmental and/or federal government responsibilities in an international and/or civil war emergency situation. This plan identifies actions and responsibilities that should be initiated to support Canadian and allied industries’ access to strategic mineral and metal products.”^Footnote26

“NRCan supports implementation of the all-hazards Federal Emergency Response Plan (FERP) led by Public Safety and the Federal Emergency Management Plan (FEMP), an event-specific plan that is integrated with the FERP. Such incidents are limited to civil emergencies defined as international or war emergencies that seriously endanger the lives, health or safety of Canadians and is of such proportion as to exceed the capability or authority of a province or sovereignty, security and territorial integrity of Canada. NRCan’s response is coordinated in close consultation with its portfolio partners.

NRCan may be required to respond to civil emergencies through provision of the following capabilities:

1. To coordinate the sourcing of critical non-fuel minerals and metals required for domestic/allied production;
2. To direct the establishment and allocation of an inventory of strategic mineral commodities that may be required for domestic production, including defence-resource allocations.”^Footnote27