Auditing Association of Canada Onshore Pipeline Regulations Management Systems and Audits

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1 Auditing Association of Canada Onshore Pipeline Regulations Management Systems and Audits Ken Colosimo Technical Leader Audits Operations National Energy Board

2 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

3 NEB - Who We Are & What We Do Picture of processing plant

4 NEB - Who We Are & What We Do We regulate for the life of the project Design and Approval Construction Operation Abandonment

5 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

6 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

7 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

8 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.

9 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

10 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.

11 NEB Protocol ACT PLAN Standard MS Cycle CHECK DO 11

12 2.0 Planning NEB Protocol ACT PLAN Standard MS Cycle CHECK DO Corrective Action

NEB Protocol 4.4 Records Management 5.1 Management Review 1.1 Leadership Accountability 1.2 Policy and Commitment Statements 4.3 Internal Audit 2.

13 NEB Protocol 4.4 Records Management 5.1 Management Review 1.1 Leadership Accountability 1.2 Policy and Commitment Statements 4.3 Internal Audit 2.1 Hazard Identification, Risk Assessment and Control 4.2 Investigation of Incidents, Near Misses and Non-compliances ACT PLAN 2.2 Legal Requirements 4.1 Inspection, Measurement and Monitoring 4.0 Corrective Action NEB MS Cycle 2.0 Planning 2.3 Goals, Targets and Objectives 3.6 Documentation and Document Control CHECK DO 2.4 Organizational Structure, Roles and Responsibilities 3.5 Communication 3.4 Training, Competence and Evaluation 3.3 Management of Change 3.1 Operational Control Normal Operations 3.2 Operational Control Upset or Abnormal Operating Conditions 13

14 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.

15 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.

16 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

17 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

18 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

19 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

20 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.

21 Questions 21

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