NORTHWEST TERRITORIES & NUNAVUT CODES OF PRACTICE

In accordance with the Northwest Territories and Nunavut Acts; and Occupational Health and Safety Regulations

Personal Protective Equipment OPERATIONS

Code of Practice Personal Protective Equipment COMMERCIAL DIVING OPERATIONS

NORTHWEST TERRITORIES wscc.nt.ca Yellowknife Box 8888, 5022 49th Street Centre Square Mall, 5th Floor Yellowknife, NT X1A 2R3 Telephone: 867-920-3888 Toll Free: 1-800-661-0792 Fax: 867-873-4596 Toll Free Fax: 1-866-277-3677 Inuvik Box 1188 Blackstone Building, Unit 87 85 Kingmingya Road Inuvik, NT X0E 0T0 Toll Free: 1-866-678-2301 Telephone: 867-678-2301 Fax: 867-678-2302

NUNAVUT wscc.nu.ca Iqaluit Box 669, 2nd Floor Qamutiq Building Iqaluit, NU X0A 0H0 Telephone: 867-979-8500 Toll Free: 1-877-404-4407 Fax: 867-979-8501 Toll Free Fax: 1-866-979-8501 Prevention Services Industrial Safety: 867-669-4418 Mine Safety: 867-669-4412

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FOREWORD The Workers’ Safety and Compensation Commission (WSCC) produced this industry in accordance with subsections 18(3) and 18(4) of the Northwest Territories and Nunavut Safety Acts. The Code of Practice applies to all workplaces covered by the Northwest Territories and Nunavut Safety Acts and Occupational Health and Safety Regulations. The Personal Protective Equipment – Commercial Diving Operations code relates to section 4 and 5 of the Safety Act and sections 13,16, 23, 24, 26, 74 and 88, 89 and 90, 297 to 301, 303, 304 and 306 to 308 of the Occupational Health and Safety Regulations. This code is in effect as published in the in the Northwest Territories Gazette and Nunavut Gazette, in accordance with the Safety Acts and Occupational Health and Safety (OHS) Regulations. IN EFFECT DATES: Northwest Territories: June 1, 2015 Nunavut: May 31, 2016

Copies of this code are available online from the WSCC at: wscc.nt.ca or wscc.nu.ca

Acting Chief Safety Officer, WSCC

Disclaimer This publication refers to obligations under the workers’ compensation and occupational health and safety legislation as administered by the Workers’ Safety and Compensation Commission. To ensure compliance with legal obligations always refer to the most recent legislation. This publication may refer to legislation that has been amended or repealed. Check for information on the latest legislation at wscc.nt.ca or wscc.nu.ca, or contact WSCC at 1-800-661-0792. Copyright ©WSCC

TABLE OF CONTENTS FOREWORD...... 3 TABLE OF CONTENTS ...... 4 WHAT IS A CODE OF PRACTICE? ...... 5 INTRODUCTION ...... 6 REGULATORY REQUIREMENTS ...... 7 CSA STANDARDS ...... 12 APPENDIX A – OHS REGULATIONS...... 15 APPENDIX B – OHS REGULATION WRITTEN PLANS, RECORDS, AND LOGS ...... 18 ACKNOWLEDGEMENTS ...... 19

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WHAT IS A CODE OF PRACTICE? WSCC codes of practice provide practical guidance to achieve the safety requirements of the Northwest Territories and Nunavut Safety Acts and related Regulations. As per subsection 18(3) of the Northwest Territories and Nunavut Safety Acts, “For the purpose of providing practical guidance with respect to the requirements of any provision of this Act or the regulations, the Chief Safety Officer may approve and issue such codes of practice as he or she considers are suitable for that purpose.” WSCC codes of practice apply to workplaces in the Northwest Territories and Nunavut. The Chief Safety Officer approves codes of practice for use by all occupational health and safety (OHS) stakeholders. Codes of practice come into effect in each territory on the day they are published in the Northwest Territories Gazette and Nunavut Gazette. Codes of practice do not have the same legal as the Safety Acts and related regulations. A person or employer cannot face prosecution for failing to comply with a code of practice. However, in legal proceedings under the Safety Acts and related Regulations, failure to observe a code of practice may be a consideration when determining whether a worker or employer complies with the Safety Acts and related Regulations. Employers and workers should follow WSCC codes of practice unless there is an alternative course of action that achieves the same or better occupational health and safety outcomes.

 Provides practical guidelines.  Adapts to individual work sites.  May serve as evidence.  Should be followed unless there’s a better way.

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INTRODUCTION This code of practice provides basic guidelines to ensure worker safety in the workplace through the use of personal protective equipment (PPE). The code provides information on the regulatory requirement of standards related to commercial diving operations.

Definition Personal Protective Equipment means any clothing, device or other article that is intended to be worn or used by a worker to prevent injury or to facilitate rescue.

Diving work involves underwater , engineering, inspection, maintenance, repair, cleaning, salvage, search and rescue, and archaeological and marine research. The main occupational affecting diving include:  Working under overpressure  Set up of dive locations  Environmental conditions o Poor visibility o Cold o Water  Safety of equipment  Exposure to hazardous substances  Biological agents in polluted water  Excessive physical loads  Working hours and rest periods

The use of PPE does not prevent accidents or eliminate hazards. Make every effort to control all hazards at the source and take appropriate measures to reduce the risk to divers.

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REGULATORY REQUIREMENTS The Occupational Health and Safety Regulations identify when to use PPE. This code provides information on standards from the Canadian Standards Association (CSA). It is important be familiar with your requirements under the regulations and review the most up to date applicable CSA standard for specific details about best practice in PPE use.

Occupational Health and Safety Regulations Northwest Territories and Nunavut Part 3 GENERAL DUTIES General Duties of Workers 13. A worker shall, in respect of a work site, (a) use safeguards, safety equipment and personal protective equipment required by these regulations; and (b) follow safe work practices and procedures required by or developed under these regulations. Supervision of Work 16. (1) An employer shall ensure that, at a work site, (b) supervisors have sufficient knowledge of the following: (iii) the need for, and safe use of, personal protective equipment, Identifying Mark of Approved Equipment 23. (1) This section applies in respect of equipment and personal protective equipment that is required by these regulations to be approved by an agency. (2) An employer or supplier shall ensure that the approval of equipment and personal protective equipment by an agency is evidenced by a seal, stamp, logo or similar identifying mark of the agency indicating such approval, affixed on (a) the equipment or personal protective equipment; or (b) the packaging accompanying the equipment or personal protective equipment. Prohibited Use of Compressed Air 26. An employer shall ensure that no compressed air is directed towards a worker for (a) the purpose of cleaning clothing or personal protective equipment; or

Part 6 GENERAL HEALTH REQUIREMENTS Thermal Conditions 74. (4) If a worker is required or permitted to work in thermal conditions that are different from those associated with the worker’s normal duties, an employer shall provide and require the worker to use suitable clothing or other personal protective equipment necessary to protect the health and safety of the worker. Exposure Control Plan 88. (3) An exposure control plan must (i) set out the methods of cleaning, disinfecting or disposing of clothing, personal protective equipment or other equipment contaminated with an infectious material or organism that must be followed, and indicate who is responsible for carrying out those activities;

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Part 7 PERSONAL PROTECTIVE EQUIPMENT Suitable and Adequate Equipment 89. (1) If it is not reasonably possible to protect the health and safety of a worker by design of a plant and work processes, suitable work practices or , an employer shall ensure that the worker wears or uses suitable and adequate personal protective equipment. (2) If personal protective equipment will not effectively protect a worker, an employer shall, if reasonably possible, provide alternative work arrangements for the worker.

General Responsibilities 90. (1) An employer who is required by these regulations to provide personal protective equipment to a worker shall (a) provide approved personal protective equipment for use by the worker at no cost to the worker; (b) ensure that the personal protective equipment is used by the worker; (c) ensure that the personal protective equipment is at the work site before work begins; (d) ensure that the personal protective equipment is stored in a clean, secure location that is readily accessible to the worker; (e) ensure that the worker is (i) aware of the location of the personal protective equipment, and (ii) trained in its use; (f) inform the worker of the reasons why the personal protective equipment is required to be used and of the limitations of its protection; and (g) ensure that personal protective equipment provided to the worker is (i) suitable and adequate and a proper fit for the worker, (ii) maintained and kept in a sanitary condition, and (iii) removed from use or service when damaged. (2) If an employer requires a worker to clean and maintain personal protective equipment, the employer shall ensure that the worker has adequate time to do so during normal working hours without loss of pay or benefits. (3) If reasonably possible, an employer shall make appropriate adjustments to the work procedures and the rate of work to eliminate or reduce any danger or discomfort to the worker that could arise from the worker’s use of personal protective equipment. (4) A worker who is provided with personal protective equipment by an employer shall (a) use the personal protective equipment; and (b) take reasonable steps to prevent damage to the personal protective equipment. (5) If personal protective equipment provided to a worker becomes defective or otherwise fails to provide the protection it is intended for, the worker shall (a) return the personal protective equipment to the employer; and (b) inform the employer of the defect or other reason why the personal protective equipment does not provide the protection that it was intended to provide. (6) An employer shall immediately repair or replace any personal protective equipment returned to the employer under paragraph (5)(a).

Hand and Arm Protection 101. (1) An employer shall provide, and require a worker to use, suitable and properly fitted hand or arm protection to protect the worker from injury to the hand or arm, including (c) injury arising from prolonged exposure to water; and Part 20.

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Where Part 7 addresses the general responsibilities for PPE, Part 20: Sections 297-specifically addresses diving operations.

Part 20 DIVING OPERATIONS

Diver’s Tender 297. (1) An employer shall designate a worker as a diver’s tender to monitor the dive of a diver. (2) A diver’s tender must be competent in the operation of diving apparatus used for a dive, the diving operation in progress and the emergency and signals to be used between diver and diver’s tender.

Breathing Gas 298. (1) In this section, "mixed gas" means a respirable mixture, other than air, that provides adequate to support life and does not cause excessive breathing resistance, impairment of neurological functions or other detrimental physiological effects. (2) If air is used as the by a diver, an employer shall ensure that (a) the air is clean and wholesome and supplied in adequate quantity; and (b) a reserve supply of 2.5 times the air required for the operation is supplied. (3) An employer shall ensure that any air or mixed gas used as a breathing gas by a diver meets the approved standard for composition and purity requirements. (4) If a mixed gas is used as a breathing gas by a diver, an employer shall ensure that the procedures, schedules and tables used are appropriate for the mixed gas.

Diving Equipment 299. An employer shall ensure that , including breathing apparatus, compressors, compressed gas cylinders, gas control valves, gauges, reserve supply devices, pipings, helmets, winches, cables, diving bells or stages and other accessories necessary for the safe conduct of the diving operation, is (a) of approved designs, sound construction, adequate strength and free from obvious defects; (b) maintained in a condition that will ensure the equipment’s continuing operating integrity and suitability for use; (c) adequately protected against malfunction at low temperatures that could be caused by ambient air or water or by the expansion of gas; and (d) examined, tested, overhauled and repaired in accordance with the manufacturer’s specifications.

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Diving Base 300. (1) An employer shall not allow a diving operation to proceed unless a diving base is set up before and maintained during the diving operation. (2) While a diving operation is in progress, an employer shall ensure that the diving base is equipped with the following: (a) if scuba is being used, one complete spare set of underwater breathing apparatus with fully charged cylinders to be used for emergency purposes only; (b) an adequate quantity of oxygen for therapeutic purposes; (c) one shot-line of weighted 19 mm manila of sufficient length to reach the bottom at the maximum depth of water at the dive site; (d) a kit that is appropriate for the number of workers and the work site; (e) one complete set of decompression tables; (f) a suitable heated facility for the use of divers that is located on or as near as possible to the dive site; (g) any other equipment that could be necessary to protect the health and safety of workers.

Hyperbaric Chamber 301. (1) In this section, "Class A hyperbaric chamber" means a hyperbaric chamber that meets the requirements for a Class A hyperbaric chamber as set out in Canadian Standards Association standard Z275.1-05, Hyperbaric Facilities, as amended from time to time; "decompression limit" means the point in the descent of a diver, based on the depth and duration of the dive and determined in accordance with a decompression table, beyond which will require one or more decompression stops during ascent if the diver descends further. (2) An employer shall ensure that a Class A hyperbaric chamber in operable condition is on site if (a) a dive is planned that could exceed the decompression limit; or (b) the depth of a dive exceeds 50 m.

Section 302 (not listed here) addresses Diving Plans.

General Responsibilities of Diver 303. A diver shall (a) proceed in accordance with the general diving plan and the instructions of the ; (b) inspect his or her equipment immediately before each dive; and (c) begin each dive by submerging and checking all equipment to ensure that there are no leaks and that the equipment is functioning properly.

Diver’s Personal Log 304. (3) A diver shall record in the personal log, in chronological order (a) an entry for each dive that he or she has made, verified and signed by the diving supervisor and including (i) the type of breathing apparatus used, (ii) the breathing gas used,

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Free Swimming Diving 306. (1) In this section, "free swimming diving" means diving while using self-contained underwater breathing apparatus with the diver supervised but not tethered to the surface by a lifeline or float. (2) An employer shall ensure that free swimming diving is performed only if a dive cannot safely be accomplished in the tethered mode. (3) An employer shall not require or permit a diver to perform free swimming diving unless (a) the diver is accompanied by a tethered in-water standby diver or the buddy system is used; and (b) the employer has first ensured that conditions are such that the free swimming dive can be undertaken safely.

Scuba Diving 307. (1) An employer shall ensure that, during operations, a diver uses (a) open-circuit scuba equipped with a demand regulator and a tank with quick-release harness; (b) a reserve device or bail-out system; (c) a lifeline unless the buddy system is used; and (d) an exposure suit or protective clothing that is appropriate for the condition of work and the of the water. (2) An employer shall ensure that a diver using scuba equipment does not (a) dive to a depth exceeding 50 m; or (b) dive without a lifeline (i) under ice, or (ii) if hazardous conditions exist, including water currents, low visibility and adverse weather conditions.

Surface-supply Diving 308. (1) In this section, "surface-supply diving" means a mode of diving where the diver is supplied from the dive site with breathing gas from an umbilical; "umbilical" means a life support hose bundle comprising a composite hose and cable, or separate hoses and cables, that (a) extends from the surface to a diver or to a chamber occupied by a diver, and (b) supplies breathing gas, power, heat and communication to the diver. (2) If a diver is required or permitted to perform surface-supply diving, an employer shall ensure that (a) the umbilical incorporates a lifeline to prevent stress on the hose; (b) the connections between the airline and the equipment supplying the breathing gas to the diver are secured and properly guarded to prevent accidental disconnection or damage; (c) the air line is equipped with the following, in sequence from the surface connection: (i) a regulating valve that is clearly marked as to which diver’s air supply the valve controls, (ii) a pressure gauge that is accessible and clearly visible to the diver’s tender, (iii) a non-return valve at the point of attachment of the air line to the or mask; (d) the diver carries a bail-out system; and (e) the diver is equipped with a lifeline and an effective means of two-way communication between the diver and the diver’s tender referred to in section 297.

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CSA STANDARDS The Canadian Standards Association develops standards to address needs such as enhancing health and safety. To view CSA standards online see https://ohsviewaccess.csa.ca/ CSA Group test and certify products to Canadian standards and issue the CSA mark for qualified products.

UNDERSTANDING CSA CODING CAN/CSA Stands for Canada and the Canadian Standards Association. Z259.1 Lettering between CAN/CSA and the last two digits represent the internal CSA coding of the relevant standard. -95 The last two digits indicate the year issued.

Technological and research developments result in regular updates to standards. The end of the CSA reference changes to the year of the update. The current edition of the occupational safety code for diving operations is CAN/CSA-Z275.2- F11. This shows that it was amended in 2011. This is the standard that applies to the regulation. The current edition of CAN/CSA-Z275.4-12 is called the Competency Standard for diving, hyperbaric chamber, and remotely operated vehicle operations. It supersedes the previous editions published in 2002 and 1997 under the title Competency Standard for Diving Operations. The 2012 edition is the standard that applies to the regulation.

MAKE SURE YOU USE THE MOST UP-TO-DATE STANDARD.

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1. CAN/CSA-Z275.2-11 The CSA Z275.2, Occupational safety code for diving operations is part of a series of Standards on diving and systems covering hyperbaric facilities, occupational diving, and construction work in compressed air. This Standard addresses equipment requirements for the following diving systems:  SCUBA Diving Systems  Surface-Supply Diving Systems  Deep-Diving Systems  Diving in Contaminated Environments

2. CAN/CSA-Z275.4-12 The CSA Z275.4, Competency Standard for diving, hyperbaric chamber, and remotely operated vehicle operations supersedes the previous editions published under the title Competency Standard for Diving Operations. This Standard applies to occupational diving, hyperbaric facility, and remotely operated vehicle (ROV) operations conducted in connection with all types of work and employment. The Standard describes the requirements for minimum competency levels for all personnel directly associated with the identified techniques of diving or ROV operations. This Standard addresses competency requirements for the following types of diving:  Occupational (Open-Circuit) SCUBA Diving  Surface-Supplied Diving o Air: . Restricted Surface-Supplied . Unrestricted Surface-Supplied o Mixed Gas  o Bell Techniques o Saturation Techniques (SAT) o Atmospheric Diving System Techniques (ADS) The CSA Z275.4 Standard addresses the competency requirements for the following types of personnel associated with the diving techniques as specified in the standard:  Divers/Pilots  Tenders  Diving Supervisors  Hyperbaric Chamber Operators (HCOs)  Life-Support Technicians (LSTs)  Diving Medical Technicians (DMTs)  Specialists (DSSs)  Diving Physicians and Hyperbaric Physicians  ROV Pilots/Technicians

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The CSA Z275.4 standard does not:  apply to diving operations performed solely for sport recreation or sport recreation training.  include work techniques associated with operations.  include special competency requirements for unexploded explosive ordnance (UXO) diving operations (see CSA Z275.6 for such requirements).  apply to as defined in the Standard (refer to CAUS's Standard of Practice for Scientific Diving).

Source: CSA Group, CAN/CSA-Z275.2-11, CAN/CSA-Z275.4-12 https://ohsviewaccess.csa.ca/

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APPENDIX A – OHS REGULATIONS

The New Occupational Health and Safety Regulations are in effect in the Northwest Territories as of June 1, 2015 and March 29, 2016 in Nunavut. The Regulations PDF document is streamlined to make it easier to find information relating to specific workplace topics. TABLE OF CONTENTS The Table of Contents available at wscc.nt.ca under OHS Regulations Table of Contents gives an overview of the regulations. The OHS Regulations start with preliminary matters of interpretation and applications. They are organized into Parts to relating to types of requirements, for example, Part 2: REPORTING, and specific workplace topics, for example, PART 18: CONFINED SPACE ENTRY.

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A collapsed view of the table of contents shows the Parts and the numbered regulations sections that fall under each part.

PART Section INTERPRETATION 1 APPLICATION 2 PART 1 PRELIMINARY MATTERS 3-6 PART 2 REPORTING 7-11 PART 3 GENERAL DUTIES 12-36 PART 4 COMMITTEE AND REPRESENTATIVE 37-53 PART 5 FIRST AID 54-67 PART 6 GENERAL HEALTH REQUIREMENTS 68-88 PART 7 PERSONAL PROTECTIVE EQUIPMENT 89-110 PART 8 NOISE CONTROL AND HEARING CONSERVATION 11-117 PART 9 SAFEGUARDS, STORAGE, WARNING SIGNS AND SIGNALS 118-139 PART 10 MACHINE SAFETY 140-160 PART 11 POWERED MOBILE EQUIPMENT 161-176 PART 12 SCAFFOLDS, AERIAL DEVICES, ELEVATING WORK PLATFORMS 177-204 AND TEMPORARY SUPPORTING STRUCTURES PART 13 HOISTS, CRANES AND LIFTING DEVICES 205-232 Part 14 RIGGING 233-245 PART 15 ROBOTICS 246-253 PART 16 ENTRANCES, EXITS AND LADDERS 254-262 PART 17 EXCAVATIONS, TRENCHES, TUNNELS AND EXCAVATED 263-272 SHAFTS PART 18 CONFINED SPACE ENTRY 273-282 PART 19 WORK IN COMPRESSED OR RAREFIED AIR 283-289 PART 20 DIVING OPERATIONS 290-308 PART 21 CHEMICAL AND BIOLOGICAL SUBSTANCES 309-321 PART 22 CONTROLLED PRODUCTS AND WORKPLACE HAZARDOUS 322-338 MATERIALS INFORMATION SYSTEM PART 23 RADIATION 339-363 PART 24 364-379 PART 25 SILICA PROCESSES AND ABRASIVE BLASTING 380-392 PART 26 FIRE AND EXPLOSION HAZARDS 393-408 PART 27 EXPLOSIVES 410-414 PART 28 DEMOLITION WORK 415-423 PART 29 FORESTRY AND MILL OPERATIONS 424-444 PART 30 ADDITIONAL PROTECTION FOR ELECTRICAL WORKERS 445-462 PART 31 ADDITIONAL PROTECTION FOR HEALTH CARE WORKERS 463-475 PART 32 ADDITIONAL PROTECTION FOR FIREFIGHTERS 476-488 PART 33 REPEAL AND COMMENCEMENT 489-490 SCHEDULES

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Reading the OHS Regulations The OHS Regulations are available for download at wscc.nt.ca. The PDF has a searchable function that allows users to enter a topic and search the entire document for every instance of that word or phrase.

Searching the PDF: “SHIFT+Ctrl+f” Pressing the 3 keys together brings up a window to enter a topic. For example: “respiratory”

Every instance of the word appears in the search window. As you click through the instances in this window, the word is highlighted in the Regulations.

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APPENDIX B – OHS REGULATION WRITTEN PLANS, RECORDS, AND LOGS Documenting work activity helps ensure employers, supervisors and workers know and follow safe procedures; properly inspect and maintain equipment; and have appropriate training to perform their work. Documentation required by the Regulations must be written and available to workers at work sites and submitted to the Joint OHS Committee.

PLANS RECORDS

PART 3 Part 2 PART 13 GENERAL DUTIES REPORTING HOISTS, CRANES AND • Occupational Health and Safety Program • Annual Statistical Report* LIFTING DEVICES • Plan for the control of hazardous • Notice of Accident Causing • Log Book substances Serious Bodily Injury* PART 20 • Plan for training workers • Notice of Dangerous DIVING OPERATIONS PART 6 Occurrence* • Diver’s Personal Log GENERAL HEALTH REQUIREMENTS PART 6 PART 21 • Exposure Control Plan GENERAL HEALTH CHEMICAL AND PART 8 REQUIREMENTS BIOLOGICAL SUBSTANCES NOISE CONTROL AND HEARING • Cleaning and Maintaining • Precautions for Certain • Hearing Conservation Hearing Ventilation System Substances PART 9 PART 8 PART 23 SAFEGUARDS, STORAGE, WARNING NOISE CONTROL AND RADIATION SIGNS AND SIGNALS HEARING CONSERVATION • Records of Dose • Measurement of Noise Levels • Fall Protection Plan PART 24 • Daily Exposure Exceeding • Traffic Control Plan ASBESTOS 85 dBA Lex PART 18 • Inspection CONFINED SPACE ENTRY PART 9 • Labelling and Placarding • Entry Plan SAFEGUARDS, STORAGE, • Blasting Enclosures WARNING SIGNS AND PART 20 PART 26 SIGNALS DIVING OPERATIONS FIRE AND EXPLOSION • Designated Signalers • Diving Plan HAZARDS • Locking Out • Diving • Flammable or Explosive PART 11 Substance in Atmosphere PART 24 POWERED MOBILE • Hot Work ASBESTOS EQUIPMENT • Asbestos Control Plan PART 31 • Inspection and Maintenance ADDITIONAL PROTECTION PART 26 PART 12 FOR HEALTH CARE FIRE AND EXPLOSION HAZARDS SCAFFOLDS, AERIAL DEVICES, WORKERS • Plan ELEVATING WORK • Ethylene Oxide Sterilizers PART 32 PLATFORMS AND TEMPORARY ADDITIONAL PROTECTION SUPPORTING STRUCTURES FOR FIREFIGHTERS • Maintenance and Inspection • Plan for Response to Emergency Incident * Employer must submit to the Chief Safety Officer and provide copies to the Joint OHS Committee, removing names of the workers from the document. See Part 2 of the OHS Regulations for other reporting requirements. 18 | Code of Practice | Personal Protective Equipment – Commercial Diving Operations

ACKNOWLEDGEMENTS The Workers’ Safety and Compensation Commission (WSCC) of the Northwest Territories and Nunavut appreciate the participation of their stakeholders with Occupational Health and Safety developments. If you have any questions or comments, please contact Prevention Services at 867-920-3820. Related publications and the Safety Acts and related Regulations are also available on our websites. wscc.nt.ca wscc.nu.ca

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Code of Practice COMMERCIAL DIVING OPERATIONS