Onshore Pipeline Regulations - · PDF fileDesign and Approval ... Onshore Pipeline Regulations...
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Transcript of Onshore Pipeline Regulations - · PDF fileDesign and Approval ... Onshore Pipeline Regulations...
Auditing Association of Canada
Onshore Pipeline RegulationsManagement Systems
and AuditsKen Colosimo
Technical Leader – AuditsOperations
National Energy Board
Presentation Overview
• NEB - Who We Are & What We Do• Onshore Pipeline Regulations Evolution Management & Management System Requirements
• NEB Audits• Company Audits and Third-Party Audits
NEB - Who We Are & What We Do
Picture of processing plant
NEB - Who We Are & What We DoWe regulate for the life of the project
Design and
ApprovalConstruction Operation Abandonment
Onshore Pipeline Regulations Evolution
• Pre – 1999 Basically Prescriptive - Standard operational requirements:
design, construction, maintenance• 1999 Goal/Outcome Based - Management Programs guided by
non-mandatory guidance notes to encourage formal management systems
• 2013 Prescriptive Management Systems, Mandatory
Management Processes and Management Responsibility applicable to outcome based programs
Onshore Pipeline Regulations Evolution
• 2013 (cont’d) Expanded Programs (EM and Security) Safety Culture Continual Improvement Demonstrate Human Resource Levels NO GRACE PERIOD for implementation
Onshore Pipeline Regulations Management & Management Systems
• Management OPR now includes requirements for Company
management:• Accountable Officer Responsibilities MS and Programs Authority over human and financial resources Prepare policy statements and commitments Annual management review and report of
company performance in meeting section 6 obligations Reporting performance to the Board
Onshore Pipeline Regulations Management & Management Systems
• Management Systems Section 6.1 requires companies to establish,
implement and maintain management systems with specific characteristic and management system processes.
Onshore Pipeline Regulations Management & Management Systems
• Management Systems (cont’d) Systematic, explicit, comprehensive, proactive Integrated Applies to lifecycle of facilities Applies to management programs Ensures coordination between management
programs Right sized
NEB Audits
• NEB conducts compliance audits which measure compliance to OPR MS, Program and prescriptive requirements.
• NEB has published generic protocols which it uses to provide clarity with respect to its expectations and to organize the Board’s audits and reports.
NEB Protocol
11
PLAN
DOCHECK
ACT
Standard
MS
Cycle
NEB Protocol
12
4.0
Cor
rect
ive
Act
ion
PLAN
DOCHECK
ACT
2.0 PlanningStandard
MS
Cycle
NEB Protocol
13
NEB MS
Cycle
4.0
Cor
rect
ive
Act
ion
PLAN
DOCHECK
ACT
1.1Leadership
Accountability 1.2 Policy and
Commitment Statements
2.1Hazard
Identification, Risk Assessment
and Control
2.2 Legal
Requirements
2.3 Goals, Targets
and Objectives
2.4Organizational
Structure, Roles and
Responsibilities
3.1Operational
Control – Normal Operations
3.2Operational
Control – Upset or Abnormal Operating
Conditions3.3
Management of Change
3.4 Training,
Competence and Evaluation
3.5 Communication
3.6 Documentation and Document
Control
4.1 Inspection,
Measurement and Monitoring
4.2 Investigation of
Incidents, Near Misses and Non-compliances
4.3 Internal Audit
4.4 Records
Management
5.1 Management
Review
2.0 Planning
NEB Audits
• Audits are chosen utilizing a risk-informed process
• Companies are required to demonstrate that they have established, implemented and maintained the specific MS processes and programs required by the OPR.
• NEB approves and issues audit reports.• Board reviews audit and determines next steps.
NEB Audits
• The Board requires companies to develop and implement Corrective Action Plans to address all Non-Compliant findings.
• CAP implementation is verified by Board during scheduled Implementation Assessments.
Company & Third Party Audits
• Company Internal Audits (OPR sections 6.5, 53 and 55) OPR Section 6.5 Management System
• Establishment, Implementation and Maintenance of MS; Required OPR MS Processes; QA; and < 3 year interval
• Documentation of Deficiencies, C&P actions planned and taken Section 55 Programs
• MS Application; Program Development, Implementation and Maintenance; Program Management Outcomes; Program Applicability; and < 3 year interval
• Documentation of Deficiencies, C&P actions planned and taken
Company & Third Party Audits
• Company Internal Audits Section 53 Compliance
• Designed, Constructed, Operated and Abandoned in Compliance with Specified Requirements; OPR 6.5 (1)(h) List of Legal Requirements; Applicable Referenced Standards (OPR s. 4); and < 3 year Interval
• Documentation of Non-compliances, C&P Actions Planned and Taken
Section 4 Conformance (Compliance)• Ensure that the company is conforming to its designs, specs.,
programs, manuals, procedures, measures and plans
Company & Third Party Audits
• To Demonstrate Compliant Audits Companies Must: Provide Quality Assurance Program Documentation Provide Audit Process Documentation Provide Audit Records
• Especially Protocols and Worksheets, as used
Provide Corrective & Preventative Action Process Documentation
Provide Records of Implementation Of C&P Process
Company & Third Party Audits
• Board Directed Third-Party Audits Becoming more of a “common” compliance
assurance direction but is always considered a significant action
Used where deficiencies appear to be related to MS or where Board has ordered company to develop a MS or significant components of a MS and compliance needs to be verified.
Audits must meet Internal audit requirements
Company & Third Party Audits
• Board Directed Third-Party Audits (cont’d) The Board’s direction usually contains:
• Imposed Schedule;• Demonstration of competence to conduct audit;• Protocol Approval;• Coincidental Submission of Reports (NEB and Company);• Company pays;• Company is required to develop and submit CAP for
approval;• Board will verify the implementation of CAPs by scheduling
inspections, implementation assessments or conducting another audit.
Questions
21