5.1 Review and Evaluation Process

This document is subject to review and administrative amendments in collaboration with ministries and consultation with key interested parties. This process is the responsibility of Emergency Management Ontario. Interested parties are encouraged to review and evaluate this plan as they use it and to submit comments and suggestions where applicable.

During training or exercises, the PNERP and its supporting elements may be evaluated. Resulting lessons-learned should identify gaps or opportunities for improvement (OFI) as well as best practices.

Evaluation of PNERP related documents should not only assess whether they are complete, but whether they meet the overall goals of the program and international best practices. Gaps and OFIs should be addressed through a defined issue resolution process including the development of an after-action review (AAR) detailing recommendation on how the gap or OFI shall be resolved. The process should assign responsibility to an OPI and prescribe a timeline for resolution. Best practices should also be assessed for their potential to be incorporated into other aspects of the PNERP or within other response organizations.

5.2 Assessment and Benchmarking

Internal assessments of the PNERP are accomplished through internal reviews, audits, and lessons-learned from exercises.

External assessments of the PNERP are accomplished through external audits (e.g., Auditor General) or though assessment by an international body (e.g., IAEA).

PNERP benchmarking is accomplished through comparison with other response organizations or via lessons learned from real-world nuclear emergency responses.

5.3 Audits

Internal audits, external audits, and non-conformance reports will also identify gaps and OFIs. Provincial senior management shall ensure that issue resolution is monitored and that the OPIs adhere to prescribed timelines, effectively communicating progress and any potential for delay. Lead agencies, as identified in the PNERP, shall coordinate issue resolution with any additional agencies involved.

5.4 Change Validation

After-action plans and audits that result in updates to the PNERP shall be documented and trained during subsequent PNERP management courses. New policies, plans, procedures, and other supporting documents shall be tested during training and ongoing exercises. An internal EMO exercise (e.g., a tabletop exercise) shall be conducted specifically to evaluate the effectiveness of changes to the relevant documents. Evaluation of the exercise should aim at testing and evaluating the changes and making further updates as required to ensure the changes are valid and meeting their intended purpose. The new or revised policies, plans, procedures, and other supporting documents should not be tested for the first time in a full-scale exercise with external organizations playing.

5.5 Records Management

Records management within the PNERP shall comply with the Corporate Policy on Recordkeeping, Access and Privacy, the Freedom of Information and Protection of Privacy Act, the Municipal Freedom of Information and Protection of Privacy Act as well as the Personal Health Information Protection Act. Other organizations should comply with their applicable records management and privacy legislation.

Documentation associated with the management of the PNERP during the preparedness phase shall be maintained by the province for a period of ten (10) years (e.g., NEMCC meeting minutes, training records, personnel trained, exercises conducted, exercise evaluation reports, audit reports, AARs, etc.).

Records associated with an operational response to a nuclear or radiological emergency shall be kept indefinitely by the province (e.g., time of release for emergency bulletins, time of release for Incident Management System (IMS) documents, time and actioning of immediate actions and protective measures, logs for Provincial Emergency Operations Centre (PEOC) Section Heads, reports from the NGS to EMO regarding plant conditions, dose tracking of response personnel and dose management decisions, etc.).

Records associated with recovery operations shall be maintained indefinitely by the province (e.g., minutes of NEMCC meetings, dose rates in areas being mitigated and exposure records for mitigation effort workers, recovery plans, relocation plans (if required), etc.).