Is Your Pipeline Safety and Loss Management System Up to Code?

Is Your Pipeline Safety and Loss Management System Up to Code?

On June 24, the Alberta Energy Regulator (AER) presented an update regarding the Pipeline Safety and Loss Management System (SLMS). Their latest review shows that the majority of licensees don’t actually have an SLMS in place, even though CSAZ662 Clause 3 Appendix A states that all pipeline owners must do so to remain in compliance. Twelve companies voluntarily participated in AER’s 2018/2019 assessment, yet not one of them met the SLMS standards.

 

A company’s failure to comply with CSAZ662 by neglecting to develop, implement, and document their SLMS can lead to punitive actions by the AER and increased audit attention in other assessment areas.

 

“SLMS is an important and critical component to an effective pipeline integrity management program,” said Joey Kjelland, President of Ion Engineering, Inc. “But, the way the AER is implementing it creates confusion and lack of commitment from industry.”

 

The AER began to actively promote SLMS for adoption and implementation in 2016. But, many oil and gas companies still assume they don’t need to create a separate document fort he SLMS because all aspects of it are already covered in their IntegrityManagement Program (IMP), Pipeline Operations and Maintenance Manual (POMM), or Occupational Health and Safety (OH&S)management systems. Alberta’s oil and gas companies have already dedicated a lot of time and money to develop these manuals. But, it’s worth repeating that the AER requires the SLMS to be documented with a separate, overarching, in-depth document that includes 6 elements(Design, Materials, Construction, Operating, Maintenance, and Upgrading).

 

In addition to industry confusion over AER’s documentation requirements for SLMS, the AER hasn’t provided prescriptive audit criteria nor self-assessment tools for it, which would enable producers to ensure they’re in compliance.

 

“Industry is left to the inconsistent opinions of the AER auditors,” Kjelland said. “Pipeline audits conducted by various AER centres reveal significant assessment inconsistencies between different locations and auditors.Until the AER develops a clearer and more concise plan to evaluate the effectiveness of an SLMS program, industry will continue to question the added value of this management system and the validity of the auditing process.”

 

Kjelland notes that, in contrast, the BC Oil and Gas Commission (BCOGC) is much more prescriptive with its expectations and pipeline audit criteria. BCOGC also allows companies to create and submit a short overarching document that references their own manuals(rather than repeating that content in the SLMS document). Such references can address requirements of CSA Z662 Appendix A, including:

  • Engineering, Procurement and Construction company design requirements that cover off-planning/design/construction elements
  • EnvironmentalHealth and Safety and IMP/POMM manuals that cover off-organization, commitment, training, risk management, operations, and maintenance
  • Records database
  • Management ofChange program for critical changes

“Because BC companies can link to their existing documents and manuals, the BCOGC approach is easier for industry to maintain and access,” Kjelland said. “Under the AER’s directive, meeting SLMS requirements is going to be difficult to evaluate and expensive to manage.”

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