Thinking Beyond the Word, Compliance

Transcription

1 Thinking Beyond the Word, Compliance A Pipeline Safety Behavior Shift For Gas System Operators Place your chosen image here. The four corners must just cover the arrow tips. For covers, the three pictures should be the same size and in a straight line. Pipeline Safety Seminar, Saratoga, NY - Sept 24, 2013 Bob Wilson & Art Shapiro

2 The Bar Has Been Raised NTSB criticized the Regulator / Operator relationship Policymakers demand greater accountability PHMSA is implementing the Pipeline Safety & Job Creation Act State Regulators are increasing their expectations WE NEED TO SHIFT FROM REACTING TO LEARNING 2

3 Renewed Focus on Doing Things Right Our compliance campaign Heightened expectations Raising awareness layers of protection Focus and ownership Thinking beyond the word, compliance Zero Violations behavior Dedicated compliance analysts, toolbox equipped New metrics 3

4 Interactive Industry Executive and Regulator Participation Regulator Participation Commissioner Paul Roberti, RIPUC NARUC Pipeline Safety Task Force Leader Sr. Executive Participation Bill Akley, Sr. VP, Operations Industry Leadership Tom Kiley, President & CEO Northeast Gas Association 4

5 Shared Goals Paul J. Roberti Commissioner Rhode Island Public Utilities Commission 5

6 It Can Happen Here San Bruno was a wake-up call What about right here at home? Lexington, MA Amityville, NY Other non-compliance lessons learned 6

7 It s About Everything We Do Bill Akley Senior Vice President U.S. Gas Operations, National Grid 7

8 Strategic Framework Enhancing Compliance Behavior Pyramid of Compliance Compliance Improvement Process Pipeline Safety, Beyond Compliance Changed Behavior Effective Efficient Sustainable Operationally Focused Resource-Intensive Behavior Change Accountability Focus, Ownership & Accountability Lack of Focus Limited Resources Lack of Focus Resource-Intensive Awareness & Layers of Protection Focus Compliance Resources Enhanced Operational Focus & Accountability Yields Compliance Success 8

9 Thinking Beyond Compliance Plan Education: E-learning module building towards improved pipeline safety Self Assessment Tool Kit: Getting back to Operational Basics Compliance Metrics: Focus on critical code sections right down to the yard level, ensure effectiveness of corrective action to avoid repeat violations MAKE THE TIME TO MAKE PIPELINE SAFETY COMPLIANCE A PRIORITY Personal Safety Process Safety Pipeline Safety 9

10 E-Learning Framework Connects the core principles of Pipeline Safety with Those of Personal Safety & Process Safety and introduces Layers Of Protection concept 10

11 New E-Learning Module 11

12 Building On Awareness Changing laws, and regulations require changes in policies, procedures, training, tools and materials 12

13 Understanding Layers of Protection 13

14 Taking Ownership & Accountability Engaging, provoking and challenging current thinking about pipeline safety compliance behaviors and accountabilities Encouraging operational ownership of the compliance process Linking actions with reactions and the consequences of Non-action 14

15 Doing the Right Thing Robert Clark A Mechanic, National Grid 15

16 Encouraging See-Something, Say-Something Behavior Living the values and holding ourselves accountable Working responsibly If something doesn t feel right or look right, STOP 16

17 Thinking Beyond the Word, Compliance Intent vs. the Letter of the Codes Procedures need to address the intent Procedures cannot try to exploit Loopholes When In Doubt, Common Sense Must Prevail Do The Right Thing 17

18 Reinforcing Concepts 18

19 What Are The Steps We Have Been Building Upon? 19

20 Industry Perspective Tom Kiley President & CEO, Northeast Gas Association 20

21 Recent Audit Experiences & Compliance Imperative The Reality Is That We Are All Human We will make some mistakes We will have some audit findings It s how we handle them that defines our character as a company and our regulatory relationships. 21

22 Recalibration of Compliance Resources with Proper Focus Need to adapt to changes in regulatory environment Need to re-think / recalibrate Adding focused resources within operations to ensure a Cradle To Grave approach to compliancedriven activities Driving a shift in our behaviors 22

23 The Compliance Puzzle Repeat Issues Recordkeeping Failure to follow procedures Inadequate procedure Training / OQ issues ALL WITHIN OUR CONTROL? 23

24 Compliance Analysts Embedded in Operations Compliance monitoring and improvement as a focused, dedicated, day job Armed with assessment toolkit Coordinated with QA/QC, auditing, regulatory, training, standards, etc. Monitoring metrics 24

25 Next Steps: E-Learning & Beyond Complete production by May 31st Develop complementary video version for Bargaining Unit employees Roll-out plan to all Gas Business Unit Employees by October 1 st Pipeline Safety campaign / integrated messaging with broader ethics compliance message Analysts engaged in operations Begin Living The Experience 25

26 Having The Courage To Take This Journey Success WILL be defined by our actions as a company and as an industry Behavior shifts do not happen overnight However, we must start somewhere National Grid s E-Learning program will be shared and can be adapted by other companies Core Principles Belong to ALL of Us! 26

27 Thank You The National Grid Thinking Beyond the Word Compliance E-Learning Module has been developed and produced in partnership with DScape Interactive. 27

28 Questions? Place your chosen image here. The four corners must just cover the arrow tips. For covers, the three pictures should be the same size and in a straight line. robert.wilson@nationalgrid.com arthur.shapiro@nationalgrid.com