2010 Archaeology Audit Program Procedure Manual. June 2010

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1 2010 Archaeology Audit Program Procedure Manual June 2010

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3 Introduction and Scope... Audit Objectives... Audit Procedures Audit Overview Audit Roles and Responsibilities Determination of Audit Medium Process and Methodology - Non-Geophysical Projects Population Sample Size and Desired Audit Level Sampling Technique Process and Methodology - Geophysical Projects Population Sample Size and Desired Audit Level Sampling Technique Audit... Concluding Actions... Cumulative Recommendations Tables Table 1. Table 2. AAP Roles and Responsibilities... Module Descriptions Table 3. Findings Categorization Oil and Gas Commission 2010 Archaeology Audit Program Procedure Manual 3

4 Appendices Appendix 1 - Audit Questions Modules Non-Geophysical Audit Questions Module 1 - General Management System Questions... Module 2 - Archaeological Site Management Questions... Module 3 - Project Specific Questions... Module 4 - Field Audit Questions Geophysical Audit Questions Module 5 - General Management System Questions... Module 6 - Archaeological Site Management Questions... Module 7 - Project Specific Questions... Module 8 - Field Audit Questions Oil and Gas Commission 2010 Archaeology Audit Program Procedure Manual

5 1.0 Introduction and Scope The BC Oil and Gas Commission s (Commission) Archaeology Audit Program (AAP) was created as a necessary component of the performance-based regulatory approach to archaeology. Under a performance-based approach to archaeology assessments and review, oil and gas industry applicants are responsible and accountable for ensuring that planning and development activities comply with the Heritage Conservation Act (HCA). The BC Oil and Gas Commission Guidelines for a Performance- Based Approach to Archaeological Assessments (Guidelines) were designed for oil and gas clients to help them operate within a performance-based framework. Familiarity with and adherence to the Guidelines will ensure oil and gas operators in B.C. remain within legislative and regulatory requirements. An annual audit is conducted on randomly selected companies to evaluate the effectiveness of their archaeology management systems. The audit protocols contained within the Archaeology Audit Program Procedure Manual (Manual) are designed to assess oil and gas companies management systems through interviews, document review and field inspections. The audit is intended to identify opportunities for improvement as well as identify practices deemed to be proactive and innovative. The annual archaeology audit supports the Commission s commitment to continual improvement of processes. The audits are conducted by the Commission s Heritage Conservation Program staff, and are attended by oil and gas clients (auditees). Invitations are also extended to First Nations representatives from communities with interests in the audited locations. Subsequent to completion of the annual audit, a general report is published with findings and recommendations based on observed deficiencies and positive practices. Audited companies also receive an individual report with detailed recommendations specific to their archaeology management system. 2.0 Audit Objectives The AAP has two primary objectives: 1.Ensure that the client management systems are adequate for compliance with legislative and regulatory obligations. This is accomplished by examining and evaluating relevant documents and by conducting field inspections to confirm implementation of management systems. Through the document and field examination process, the annual archaeology audit analyzes the degree of compliance with legislation, guidelines, conditions, and other requirements for Commission industry clients operating in B.C. Any observations regarding compliance concerns are identified during the review, based on weaknesses or failures of the management system that may have led to the concern. The annual archaeology audit was not intended to be a compliance audit, however, it is the duty of the audit team to notify Commission enforcement staff of any breaches in legislation or policy, as outlined in section 1.5 of the Guidelines. Oil and Gas Commission 2010 Archaeology Audit Program Procedure Manual 5

6 2. Gather baseline data to establish procedures for best management practices for archaeology resource management within the oil and gas sector of B.C. Innovative and successful practices will be highlighted annually in the audit results report within the context of cumulative recommendations for improvement. The annual report recommendations should be used by all companies to continually improve their processes. 3.0 Audit Procedures The following sections detail the archaeology audit composition including participants, their respective roles and responsibilities, goals of the audit, processes and audit methodologies. The AAP will implement two concurrent audit streams. The larger stream will consist of non-geophysical projects such as wellsites, pipelines and facilities. The second stream will be comprised of geophysical projects. The two categories of project types have different application processes, creating the need for separate audit streams. The differences in each project type and geographical footprint and associated risk also create the need for separate streams. Separate samples will be randomly selected for geophysical and non-geophysical projects. Procedures common to both are described in sections 3.1 to 3.3. Procedures that are specific to each audit stream (i.e. non-geophysical and geophysical) are discussed separately in sections 3.4 and 3.5 respectively. The common audit procedures outline: the audit notification process the selection process the reporting out of results the audit structure the audit team roles and responsibilities the auditee roles and responsibilities the general audit code of conduct 6 Oil and Gas Commission 2010 Archaeology Audit Program Procedure Manual

7 3.1 Audit Overview The AAP Manual has been developed by the Commission s Regulatory Affairs and Stewardship Division Heritage Conservation Program staff. The Manual is revised annually to incorporate data gathered from each previous audit. A complete question set is provided as an appendix at the end of the Manual, allowing all companies to prepare for the archaeology audit. The Manual is published on the Commission website as a reference tool. Companies selected for the audit through random sample will be notified by letter. Participation in the audit is required. The letter will state the established time period for the audit and outline the stages of the AAP process. The notification letter will include a checklist, which outlines required documentation for the auditee to provide at the time of audit activities. There will be no grace period for documents missing at the time of the audit. Upon receipt of the selection letter, the company must contact the Commission immediately to schedule both the office and field audits. Contact information for scheduling audit appointments will be included in the selection letter. The AAP interviews and inspections will occur in northeastern B.C. during the allotted appointment time. The audit is separated into an office and field component and consist of interviews with key personnel responsible for the archaeology aspects of application processes and construction activities. The office component is designed to examine general management systems as well as specific document tracking, file retention and report submissions. Field inspections are file specific and include an interview with the construction supervisor and a brief document review. An actual inspection is conducted on any areas identified as having archaeology concerns to confirm mitigation recommendations have been implemented. The projects subject to field audit will be selected at the discretion of the audit team prior to or during the audit process. Companies will be contacted directly by the audit team to arrange for field audits. An interview with the field construction supervisor for the selected audited development is a required component of the field audit. Although welcome to attend, company directors, managers or administrative staff cannot substitute for the development supervisor. It is the responsibility of the oil and gas client to ensure that arrangements are made for the supervisor s attendance at the field audit. Failure to participate in any component of the audit will result in a rating of non-conformance. Upon audit completion, the audit team prepares preliminary audit conclusions, backed by audit evidence. If requested by either the auditee or auditor, the information is presented at a closing meeting with appropriate representatives from both parties present. The closing meeting provides an opportunity to discuss the accuracy of the audit evidence and issues related to the preliminary conclusions. The Commission audit team will record all its findings for analysis. This analysis will be used to produce audit reports. The Commission audit team will draft a formal written report to convey the final results of the audit. Oil and Gas Commission 2010 Archaeology Audit Program Procedure Manual 7

8 3.2 Audit Roles and Responsibilities The AAP is a systematic process that relies on the principles of independence and objectivity. Specifically, the following principles guide the conduct of this audit and the presentation of audit results: Auditors shall act in an ethical manner and make decisions applying due professional care based on evidence obtained during the audit. Auditors will not act outside of their areas of competence and knowledge. Auditors will be impartial and independent of the activity that they are auditing, and act without bias or prejudice. Confidential information reviewed or obtained during the audit process will be held in confidence by the auditors and only included in the audit report where the information is relevant to an audit finding. Audit results will be presented in a fair and accurate manner, and will truthfully reflect the audit activity and evidence. The AAP will be executed by the Lead Auditor, Audit Facilitator and an audit team comprised of Commission staff. The audit conclusions will be developed solely based on the audit evidence in a manner that may be reproducible by others based on the same audit evidence. Specific responsibilities for the respective parties are discussed below in Table 1. Roles Responsibilities Lead Auditor Assigns areas of responsibility to audit team members, including the sections of the audit protocol or areas of inquiry Conducts audits or portions thereof Oversees the conduct of the audit team members Determines audit results with Audit Facilitator based solely on the audit evidence obtained during the audit Manages all projects within which a non-conformance has been identified and discusses recommendations and remedial actions with auditees as required Reports any instances of legislation breach, trespass or permit condition breaches to the Commission s Manager of Enforcement and / or to the Archaeology Branch of the Ministry of Tourism, Culture and the Arts as appropriate Works with the Commission s Enforcement staff and Archaeology Branch as required to resolve non-compliance issues Reviews preliminary audit reports prior to issuance Table 1. AAP Roles and Responsibilities (continued on page 9). 8 Oil and Gas Commission 2010 Archaeology Audit Program Procedure Manual

9 Table 1. AAP Roles and Responsibilities (continued from page 8). Roles Audit Facilitator Audit Team Members Auditees Responsibilities Arranges logistics of individual AAP annual audits Conducts audits or portions thereof Coordinates the timely completion of the audit activities Determines audit results with Lead Auditor based solely on the audit evidence obtained during the audit Develops and submits a draft audit report to the Commission Executive and other relevant parties, including the auditee, as appropriate Discusses recommendations and remedial actions with auditees as required Discusses draft audit report with relevant parties and identify any required revisions Prepares final audit report for submission to the Commission Executive Publishes final audit summary report on Commission website Forwards copy of the final individual company reports to each auditee Review the sections of the audit protocols and other documentation or records relevant to their assignment(s) within the audit Assist Lead Auditor and Audit Facilitator in audit preparations, including gathering of required documents and preparation of site access information Conduct portions of audit as assigned by Audit Facilitator or lead Auditor Conduct audits according to set schedules, audit protocols and as assigned by Lead Auditor or Audit Facilitator Communicate concerns or other relevant issues to Lead Auditor or Audit Facilitator for resolution Participate in review of audit evidence, audit documents, data organization, and draft reports as required Will respond to the audit selection letter and schedule audits within the timeframe set out in the selection letter Cooperate with the Commission audit team Disclose all audit documents as requested and detailed in individual selection letters at the time of or prior to the audit Ensure appropriate personnel represent the company at the audit Disclose required information during the audit inquiry in a thorough, factual and accurate manner Review draft audit findings report and provide comments, additional information or clarification requests to the Audit Facilitator and / or Lead Auditor as appropriate Where a remedial action plan is required, the auditee will create and submit the plan to the Commission within the agreed schedule Oil and Gas Commission 2010 Archaeology Audit Program Procedure Manual 9

10 3.3 Determination of Audit Medium The Guidelines identify actions and requirements that need to be undertaken by oil and gas industry applicants in order to ensure compliance with legislative (Heritage Conservation Act) and regulator (Commission) requirements. The Guidelines do not specify a recommended management and control system to be used by the applicants in order to achieve this compliance. Using the results from each subsequent annual archaeology audit, the Commission Heritage Conservation Program staff has developed a list of preferred management practices. These are presented in the form of cumulative recommendations in the concluding section of the annual audit general summary report. The recommendations will also be included and updated in this Manual during the annual revisions. The audit questions are organized into four sets for both geophysical and non-geophysical projects. Each set of questions is called a module and each module is designed to examine specific aspects of the client s management system. In this Manual, Modules 1 to 4 are specific to non-geophysical projects and Modules 5 to 8 are specific to geophysical projects. The information gathered from each module helps identify gaps between the recommended approach and the approach used by the applicant companies. The results of document reviews, interviews and field inspections identify possible weaknesses that could cause a system failure. Module specifics are outlined in Table 2 and include the types of questions, objective of the questions, and the protocols for presenting the questions. Module Type General Management System Questions Archaeology Site Management Questions Project Specific Questions Field Project Specific Questions Objective To establish strength of applicants current management and control systems To ensure practices and procedures are in place to effectively manage archaeology resources Confirms presence of required documentation in auditee files for each project selected for audit and as indicated in individual selection notification letters Confirms management system plans are implemented in the field and that they are effective in carrying out archaeology mitigation requirements Protocol Each question will be answered once by auditee during the audit interview Each question will be answered once by auditee during the audit interview Questions are answered by the auditor for each file selected for audit All selected projects will have archaeological concerns (sites or areas to be avoided) and are chosen at the discretion of the Lead Auditor and/or audit team. Interviews and document reviews are conducted at the time of the scheduled field inspection Table 2. Module Descriptions General management system and archaeological site mitigation questions are only required to be answered once by each company selected for audit. These questions address the management and control systems employed by applicants / operators to determine if the systems are appropriately established to ensure compliance with the HCA and policies and procedures of the Commission. 10 Oil and Gas Commission 2010 Archaeology Audit Program Procedure Manual

11 Project specific questions are asked for each development selected for audit. The information gathered during the execution of these modules is designed to examine the extent to which management systems have been implemented and to what degree they are functioning. Project specific field inspections and questions provide further evidence regarding the effectiveness of management and control systems. The questions contained in each respective module are found in the Appendix of this Manual. 3.4 Process and Methodology - Non-Geophysical Projects The intent of the sampling methodology is to arrive at a random sampling of applicants with the probability of selection being directly proportional to the number of applications submitted by the company in the last fiscal year. The selection of projects for the office portion of the audit will be conducted randomly, but the field inspection projects will be chosen by the audit team. The field projects must be manually selected due to a number of variables that cannot be controlled through a random selection process, including archaeological values, small sample size, and accessibility Population Sample Size and Desired Audit Level The 2009 audit consisted of applications approved during the 2008 calendar year. The parent sample for the current year audit has been changed from a calendar year to a fiscal year application pool and will include applications approved during the 2009/2010 fiscal year (April 1, 2009 to March 31, 2010) plus the applications approved during the first three months of The current audit period is therefore January 1, 2009 to March 31, 2010 and constitutes a 15 month sample. The sample period was changed to the fiscal year to make the audit consistent with other processes and measurements of the Commission. During the 2009/2010 audit period, the Commission approved 3,030 applications (including applications for revisions and amendments) for 2,895 unique non-geophysical projects. These 2,895 approved projects came from a total of 122 applicants. In order to get an accurate representation of the parent population, the non-geophysical stream of the AAP will use an audit level of 10 per cent of applicants Sampling Technique The sample population will be randomized and samples will be drawn from the parent population until 10 per cent of applicants have been chosen. For each applicant selected, a sample of five projects will be randomly drawn from the parent population for the file specific component of the audit. If less than five projects have been applied for, all projects will be selected. Future audits will incorporate past audit selection and results to focus audit resources on applicants that have not been previously audited and to exempt applicants that have had consistently excellent audit results within previous years. Oil and Gas Commission 2010 Archaeology Audit Program Procedure Manual 11

12 3.5 Process and Methodology - Geophysical Projects As stated in section 3.4, the intent of the sampling methodology is to arrive at a random sampling of applicants with the probability of selection being related to the number of projects applied for that year. The selection of projects for the office portion of the audit will be conducted randomly, but the field inspection projects will be chosen by the audit team. The field projects must be manually selected due to a number of variables that cannot be controlled for during random selection, including archaeological values, small sample size and accessibility Population Sample Size and Desired Audit Level During the 2009/2010 audit period, the Commission approved 80 applications (including amendments) with 61 unique geophysical applications resulting in a parent population of 61 approved projects from 37 applicants. In order to get an accurate representation of the parent population, the geophysical stream of the AAP will use an audit level of 20 per cent of applicants Sampling Technique The sample population will be randomized. Samples will be drawn from the parent population until 20 per cent of applicants have been chosen. For each applicant selected, a sample of five projects will be randomly drawn from the parent population for the file specific component of the audit. If less than five projects have been applied for, all projects will be selected. Future audits will incorporate past audit selection and results into the selection process to focus audit resources on applicants that have not been previously audited and to exempt applicants that have had consistently excellent audit results within the previous years. 12 Oil and Gas Commission 2010 Archaeology Audit Program Procedure Manual

13 4.0 Audit During each document and management system review, the Audit Facilitator will report relevant findings that will be judged against the categories established below in Table 3. The finding of Good Management Practices is changed in the 2010 Manual to Exemplary Performance. Examples of practices are provided for each category. Upon completion, the tabulation of these findings will be used in the audit analysis. Finding Category Exemplary Performance (EP) Satisfactory (S) Opportunity for Improvement (OI) Description This rating category is assigned to companies with innovative, proactive processes or practices that exceed requirements such as: Conducting a project walk-through and orientation with construction crews to identify archaeology concerns and confirm approved mitigative actions Conducting a post construction field inspection to confirm mitigation strategies were employed Communication systems that are formalized and include details such as personnel assigned specifically to: track processes, ensure all requirements are met, deliver archaeology assessment and site mitigation strategies directly to field supervisor, and confirm regulatory obligations are met This rating category describes a management system with practices that address most aspects of archaeology resource management and reporting. The system is generally sufficient to support compliance with legal and regulatory requirements: Areas of archaeology concerns are identified on project plans and the location(s) is discussed by crews in a pre-construction meeting All regulatory and legislated archaeological requirements are met without incident Basic tracking systems for processes and requirements are in place This rating category describes management practices with weaknesses that could lead to system breakdown. A minimal effort has been given toward development of a specific management plan to manage archaeological resources or ensure compliance with legal and regulatory requirements. Examples include: Lack of pre-work meetings to discuss archaeology issues Appropriate archaeology documents are not provided in construction package for field supervisor Archaeology assessment reports are not tracked and/or have not been submitted to the Commission Lack of consistency in transferring archaeology assessment status or information to field supervisor Table 3. Findings Categorization (continued on page 14). Oil and Gas Commission 2010 Archaeology Audit Program Procedure Manual 13

14 Table 3. Findings Categorization (continued from page 13). Finding Category Non-Conformance (NC) Description This rating is used when regulatory or legal or other requirements are not met, or where the ability of the company to comply with said requirements is jeopardized. Examples of when this rating would be used include: Field inspection phase of the audit finds that Commission approved archaeologist recommendations for site mitigation were not adhered to Finding that written instruction from the Commission regarding any archaeological issues was not adhered to Any condition of approval for archaeology that is not adhered to Inability to provide applicable audit required documents Refusal of company to participate in the archaeology audit Non-response from company to audit selection letter Evidence from company personnel gathered during the audit Interview that reveals system failure or a process that is inherently negligent and will ultimately lead to non-compliance issues The results generated by the management and documentation reviews will be analyzed and summarized for each company subject to audit. Each finding will be described in sufficient detail to convey a full understanding of the results and will be supported by reference to the relevant evidence reviewed during the audit. Recommendations may be provided to any company where deficiencies or weaknesses were detected within their archaeology management system. Companies are encouraged to incorporate these recommendations to reduce the possibility of being subject to future audits. Additionally, audit result reports will remain on file and in the event of a future non-compliance situation, the investigation will take into consideration any lack of incorporation of recommendations, as well as how this may have contributed to the non-compliance. Finally, the audit report will identify any practices noted during the audit that represent innovative and proactive practices. The audited company will be afforded an EP rating and their practices will be incorporated into future Commission recommendations for management system improvement. 14 Oil and Gas Commission 2010 Archaeology Audit Program Procedure Manual

15 5.0 Concluding Actions The Audit Facilitator will develop individual draft audit reports within two weeks of completion of the annual audit activities. The draft audit reports will be submitted to the Audit Department, who after review will distribute the individual reports to the auditees and other relevant parties for review and comment. Each audit report draft will include: Executive Summary Background and Scope Audit Objectives Audit Sampling and Methodology Findings Determination Process Audit Findings Recommendations and Conclusions Oil and Gas Commission 2010 Archaeology Audit Program Procedure Manual 15

16 The Commission will require all comments on the draft audit report be submitted by the auditees to the Audit Department within two weeks of distribution of the draft report. These comments will be forwarded to the Audit Facilitator, who will complete the final audit report within a further two week period. The Audit Facilitator will submit the final audit report to the Commission Executive for distribution subsequent to review by the Lead Auditor. All audit working papers will be retained as a part of the audit record. The Audit Facilitator will prepare a report summarizing the findings of the individual audit reports. This report will be published on the Commission website, along with an information letter. Specific audit findings will be published, but the names of the companies subject to audit will not be included in the report. The publication will highlight good management practices identified during the audits and will help oil and gas clients to identify opportunities for improvement in their own archaeological management systems. In instances where non-conformances are found, the Commission will require the auditee to develop and submit for approval a corrected management system plan that addresses specific negative audit findings. This description will include specific actions, assigned responsibilities and timelines for completion. The auditee will notify the Commission of any deviations from the proposed schedule. The following section summarizes recommendations based on previous years audits. These recommendations will be updated annually. 6.0 Cumulative Recommendations In the spirit of continual improvement to business practices, the Commission suggests that oil and gas companies review recommendations for improvements to archaeological management systems provided here. The following recommendations were compiled from auditor observations from previous years audits and are designed to support information flow and tracking. Implementation of these recommendations will facilitate general system improvements. Some of the suggestions come from individual companies that demonstrated exceptional and detailed approaches to their management systems. 1. There should be an on-site construction supervisor to provide field orientation for ground crews prior to project start-up when archaeologically sensitive areas exist within a development. 2. Specific individuals should be assigned responsibility for ensuring all regulatory and legislated archaeological requirements are met within project developments. 3. Transfer and receipt of required paper documentation to construction crews should be made prior to project commencement. The documents should include archaeology reports and Commission accepted site mitigation strategies if applicable. The Commission issues a letter of acceptance for each archaeology site recovered during the course of an archaeological assessment. Receipt of this acceptance letter is required prior to job start-up and should be included with the archaeology report when transferring documents to construction supervisors. 16 Oil and Gas Commission 2010 Archaeology Audit Program Procedure Manual

17 4. Upon receipt of the audit selection letter, companies should contact the Commission to discuss scheduling. Participation in the audit is mandatory as the audit is a key process within the performance-based assessment system. Companies cannot remain in a performance-based system without participating in the archaeology audit. 5. Companies should develop a written archaeology resource management plan and formalize standard operating procedures already in use. The management plan should fully address and include the following: Relevant legislative and regulatory requirements. Processes for ensuring the completion of archaeological assessments and the timely submission of archaeological reports to the Commission. Checklists to ensure that all archaeological requirements are completed prior to construction activities. Processes for fulfillment of requirements surrounding archaeological assessment and site avoidance requirements should range from high level planning to individual task assignments. All staff, contractors and land agents should be familiar with the contents of a management plan. 6. Create or refine existing tracking systems to include project status and archaeology report submission dates. Emphasis should be placed on tracking and ensuring information regarding archaeology assessments and site management is accurately and graphically related to field staff. 7. Develop a communication record, summarizing dates and information exchange. A project communication record serves as a valuable reference for project details and transactions. As well, it is the basis for development or improvement of data distribution processes, as the record illustrates where any breakdown in communication may have occurred. Oil and Gas Commission 2010 Archaeology Audit Program Procedure Manual 17

18 Appendix 1 - Audit Questions In order to facilitate the AAP audit process, and to assist you in your preparations for the audit, please review the module questions located in this Appendix. Please bring any documentation that will help support answers to audit questions for both the field and the office portions of the audits, including archaeological reports, communication tracking records, training manuals, maps, s, pre-construction packages, et There will be no grace period for submission of missing documents subsequent to the audit. The Commission may request additional documents or follow up interviews if deemed necessary by the auditor. The field construction supervisor for a given development subject to audit should be the primary interviewee for the field portion of the audit. Non-Geophysical Audit Questions: Module 1: General Management System Questions - Non-Geophysical What is your title(s) and role(s)? As per sections 3.0 and there are times when it is not necessary to contract an archaeologist to complete the AAIF. In these instances, the agent / client may complete Section 1.0 and Section 5.0. Have you or your agent ever done this? Can you describe instances when it would be appropriate to do this? When the client / agent makes a determination of 100 per cent disturbance and there are no known archaeological sites within 500 metres of a proposed development, there is an option for the agent / client to complete sections 1 and 5 of the AAIF without consulting an archaeologist (refer to section and 4.2 of the Guidelines). Has a company representative ever determined that there is 100 per cent disturbance and completed the AAIF without an archaeologist? If the answer to (a) is yes, i. Does the company have access to the provincial archaeological site data? ii. How often are these records updated? If the answer to (a) is no, iii. iv. How is it determined whether archaeological sites are in conflict? Who is responsible for this part of the process? v. What are the qualifications of the person making the determination of 100 per cent disturbance? 18 Oil and Gas Commission 2010 Archaeology Audit Program Procedure Manual

19 4. Under a performance based system, clients and their agents are responsible for ensuring all archaeology work is completed prior to construction and that all required documents are submitted to the Commission. Do you have a written procedure or checklist that verifies compliance with the requirements as described in the Guidelines? If the answer to (a) is yes, i. What items are tracked and what tracking system is used? ii. Who has access to the information? If the answer to (a) is no, iii. iv. How does the company ensure that the guideline requirements are being followed? How is the information communicated amongst office and field? 5. What archaeology related documents are kept on file? Where are they kept? How is the pertinent information shared? 6. Is an AIA report received before instructions are given for construction to commence? If the answer to (a) is yes, i. Who receives and reviews the information prior to construction? ii. iii. What happens to the report and where are the results of the assessment recorded? Were the AAIFs and AIAs for this year s audit found easily in your records? If the answer to (a) is no, The Well Authorization or Pipeline Permit states that an AIA has to be completed prior to construction. How does the company ensure that this permit condition has been met? 7. Section 4.8 of the Guidelines requires that copies of the AIA reports must be submitted to the Commission. d. Are all reports submitted to the Commission? If not, how many reports are outstanding? How do you access this information? Who is responsible for ensuring report submission to the Commission? Oil and Gas Commission 2010 Archaeology Audit Program Procedure Manual 19

20 8. Misunderstandings that surround the completion of archaeological requirements are the result of poor communication between the agent/client and the archaeologist. Does the company maintain a communication log with the agent/client and/or the archaeologist? How is the log maintained (e.g. what software is used, what information is recorded)? If not, how many reports are outstanding? 9. What training is provided for staff and contractors with regards to compliance to relvant legislation, guidelines and company procedures? Is the training process formal and standardized? Module 2: Archaeological Site Management Questions - Non-Geophysical When an archaeological site is recovered during an archaeological assessment, how is it documented in company files? Who is responsible for submitting an Archaeological Impact Assessment report recommending mitigation strategies to avoid damaging an archaeological site, as per section of the Guidelines? How is the approval of site mitigation strategies by the Commission, as described in section of the Guidelines, documented in company files? Accidental site disturbance and trespass issues are the result of a breakdown in communication between office and field staff. Please explain how information regarding the following is transferred to construction crews: d. Requirement for an archaeological assessment Notification of completion of archaeological assessment Notification of archaeology site conflicts Instruction on Commission approved archaeology mitigation strategies When mitigation is required and has been approved by the Commission, what process is used to ensure the construction crew is informed and understands the mitigation strategy? Once construction has been completed, how does the company verify that mitigation strategies, such as site avoidance or special conditions for disturbance, were followed and that no other archaeological concerns were encountered? What is company procedure or policy in the case of accidental disturbance of archaeological resources, including burials? Is there a formal procedure in place? Who within the company would be assigned to investigate the incident? What is done with the results? 20 Oil and Gas Commission 2010 Archaeology Audit Program Procedure Manual

21 How does the company ensure that the archaeologist is qualified, as required by sections 3.3 and 4.5 of the Guidelines? Is a copy of the archaeologist s section 14 permit kept on file, and is the client certification page signed? Where is the permit kept? Who reviews it? Do you understand what the purpose of the client s certification page is? For applications that include a review corridor: How is the area within the review corridor assessed by the archaeologist? If the entire corridor is not reviewed, how is the review corridor managed? Module 3: Project Specific Questions - Non-Geophysical Does the file contain records supporting the decision for noting No Archaeological Potential on the AAIF? If an AAIF indicated the project was 100 per cent disturbed does the project file contain records supporting this determination as per section 4.2 of the Guidelines? Does the company have an AAIF on file? For files that require an Archaeological Impact Assessment (AIA): d. Has the field work been completed? Was the field work component completed prior to construction? Has the report been received by the oil and gas company? When was the report received? 5. If this project has an archaeological site located within the development area, the following documents should be available: Communications documents i. Mitigation discussion with the archaeologist ii. Mitigation approval by Commission iii. Communication to construction staff iv. Communication from construction crew Revised survey plans Documentation verifying successful mitigation Oil and Gas Commission 2010 Archaeology Audit Program Procedure Manual 21

22 Module 4: Field Audit Questions - Non-Geophysical 1. What is your title(s) and role(s)? 2. Do you know whether this project required an on-the-ground archaeological assessment before construction? How are you informed that an archaeology assessment is required on a project? Do you have the construction package containing all archaeology documents that you would normally receive prior to project start up? Can you provide these documents? d. e. d. e. f. Do you know whether the archaeology assessment for this project has been completed? How do you know? Is this information from the assessment communicated to you in a consistent manner? Can you describe how this communication takes place for each project? Who specifically would you contact if you had any archaeology concerns? Were any sites found during the assessment of this project? If yes: Do you know where they are? How have the sites been marked in the field? Do all members of the construction crew know where they are? How have they been informed? Are there records of how this information was related to the crew? Have the construction plans been revised to reflect site mitigation requirements? Can you explain the changes? Were you present while construction took place around the archaeology site(s) (or other area) to be avoided? If there is a review corridor, do the plans onsite show the latest revision of the review corridor, including areas that may have been excluded as having untested archaeology potential or sections that were to be removed around an archaeology site. Are there any training methods in place to help crews identify archaeology site or archaeology potential areas? If no archaeological sites were found on this project: Were any sites found during the assessment of this project? When archaeology sites are found in conflict with a proposed development, do you know how sites would typically be marked in the field? 22 Oil and Gas Commission 2010 Archaeology Audit Program Procedure Manual

23 d. How is the construction crew informed about archaeology sites or areas to be avoided? What types of records are kept of the information transfer to the crew? What would happen if artifacts or human remains were found during construction? Do you know what the penalties are for damaging an archeological site? During the course of the field investigation, can the auditor observe that: d. e. f. g. All sites were flagged? All mitigation measures are in place? Only those areas of the review corridor that were assessed were used in construction? Areas that were not subject to archaeological assessment were not used in construction? No cultural materials are visible in disturbed areas? Field observations match information presented in applicable documentation, e.g. AAIF, archaeological reports? Did field construction supervisor s understanding of field procedures correspond with office staff interview responses? (May be addressed after completion of field interview). Geophysical Audit Questions: Module 5: General Management System Questions - Geophysical 1. What is your title(s) and role(s)? 2. Who in your company is responsible for ensuring that archaeological requirements are met? Does the company assign responsibility for planning and completing the geophysical program to consultants or contractors? If yes, how does the company ensure that archaeological requirements are met? 3. How does the company determine when and if archaeological sites in conflict with the program have been flagged? Oil and Gas Commission 2010 Archaeology Audit Program Procedure Manual 23

24 4. Does the company provide their construction supervisor / contractor with a set procedure to relate archaeology site avoidance information to construction crews? What does that procedure look like? 5. Breakdown in communication between agent/client administrative staff and construction personnel is the leading cause of accidental disturbance of known archaeology sites and/or trespass issues. Please explain how information regarding the following is transferred to construction crews: Archaeology site conflicts and required site flagging Notification of completion of archaeology site flagging Searches for additional archaeology sites in instances where there is a time lag between application approval and construction Does the company have delegated administrative personnel / lands people for communicating information regarding archaeology sites to construction supervisors? For programs that have a Selective Post Impact Assessment recommended in the AAIF: Who determines whether or not ground disturbance has occurred and where a post assessment is required? How is this determination made? How long after construction completion does the assessment take place? 8. Does the company have a formal tracking system for outstanding archaeology work on a given program? How does the company ensure that the post construction assessment is completed? 9. Many of the problems surrounding the completion of archaeological requirements are the result of poor communication between the agent/client and the archaeologist. Does the company maintain a communication log with the agent / client and / or the archaeologist? If no, can each stage of the assessment process be verified? What is the process for ensuring that the archaeology reports are submitted to the Commission? What training is provided for staff and contractors regarding legislation (Heritage Conservation Act), Commission guidelines for archaeology and company procedures? Is the training process formal and standardized? 24 Oil and Gas Commission 2010 Archaeology Audit Program Procedure Manual

25 Module 6: Archaeological Site Management Questions - Geophysical Once construction has been completed, how does the company verify that site avoidance or other special conditions for construction were followed? If an archaeology site that was flagged for avoidance is damaged during construction, the company, not the contractor, is responsible for the disturbance. Who within the company would be assigned to investigate the incident? Is there a formal process in place for incident investigations? What is done with the results? What is company procedure or policy in the case of accidental disturbance of previously unidentified archaeological resources, including burials? Is it a formalized procedure? How is this information transferred to field crews? If an archaeological site is identified during the post impact archaeological assessment, how is it documented in company files? How does the company ensure that the archaeologist is qualified, as required by sections 3.3 and 4.5 of the Guidelines? 6. Is a copy of the archaeologist s section 14 permit kept on file, and is the client certification page signed? Where is the permit kept? Who reviews it? Do you understand what the purpose of the client s certification page is? Module 7: Project Specific Questions - Geophysical Does the company have an AAIF on file? If the approval conditions state that flagging is required for this program, is there a letter from the archaeologist confirming that the known archaeological site(s) in this program is (are) flagged prior to construction? If the approval conditions state that Selective Post Impact Assessment is required, does the file contain evidence that the assessment is complete? If the Selective Post Impact Assessment is complete, has it been submitted to the Commission? If the project was associated with known archaeological sites, do the construction plans contain accurate information about the location of the archaeological sites? If the project was associated with known archaeological sites, how did the company ensure that these sites were successfully avoided? Oil and Gas Commission 2010 Archaeology Audit Program Procedure Manual 25

26 Module 8: Field Audit Questions - Geophysical 1. What is your title(s) and role(s)? d. Do you have a construction package containing all archaeology documents that you would normally receive prior to project start up? Can you show me? Is the information package / information regarding archaeology in the program related to you in a consistent manner? Is archaeology discussed in a pre-construction meeting? Do you keep records of those meetings? Do you know whether there are any archaeological sites in this program area? Have all archaeology sites in the project area been located and flagged? How do you know (i.e. can you describe how) the information comes to you regarding the completion of flagging? If no archaeology sites are located in the program, is that documented somewhere? Can you provide this information? 4. Who would you talk to if you had any concerns about archaeology, such as location of a site, flagging of a site, et 5. The requirement for post-program archaeological work is triggered by ground disturbance. Are the locations of disturbed areas communicated to someone once construction is finished? Who is informed, and how? 6. During the course of the field investigation, can the auditor observe that: d. e. f. All sites were flagged? All mitigation measures in place? Only those areas of the review corridor that were assessed were used in construction? Areas that were not subject to archaeological assessment were not used in construction? No cultural materials are visible in disturbed areas? Field observations match information presented in applicable documentation, e.g. AAIF? 26 Oil and Gas Commission 2010 Archaeology Audit Program Procedure Manual

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