Chasing Perfection: The Proactive IMP PDCA (+E) Review

Aiming for zero — zero leaks, zero ruptures, zero third party damage hits, zero-harm to the public may be considered by some to be unrealistic, but it is definitely a goal worth chasing. Striving for this level of perfection is key in achieving pipeline operational excellence and avoiding operational mediocrity. Central to safe operations is a pipeline integrity management plan (IMP) that establishes processes for assessing and mitigating risk within a framework structured to ensure the long-term integrity of pipeline system assets. When properly implemented in compliance with regulation and industry practice, an IMP will reduce both the likelihood and consequences of incidents. It remains the cornerstone in the management of pipeline risk and safety performance and is critical in preventing system failures, injuries, property damage, and other serious consequences. But a sustainable process for managing risk and improving performance must go beyond relying on regulatory compliance and following generic industry practices. In this respect, too often IMPs are judged only from a compliance perspective that provides little insight into how well the IMP is being executed or whether the management systems are actually effective. Integrity management can also be examined in context of the larger corporate culture and with the specific corporate processes that impact employees’ decisions and behaviors in ways that transcend procedures printed in a manual. A culture of adherence to compliance as an ultimate goal can lead to complacency, and a company cannot achieve a zero incident level adhering only to regulations. The focus on meeting regulatory requirements should be replaced by an integrated broader view on risk management derived in part from emerging industry best practices and standards. Benchmarking against these standards can establish a performance baseline, identify opportunities for improvements, set targets, measure performance, and instill a continuous improvement process. An approach to assess the degree to which an IMP is regulatory compliant, technically adequate, implemented and effective is to apply a “Plan,” “Do,” “Check,” “Act” (PDCA) based approach. This framework, while confirming basic regulatory compliance, also allows an operator to determine the degree to which the IMP is being executed in alignment with corporate management system objectives and accepted best practice guidelines relating to the 4 P’s — “People, Process, Product and Performance.” When applied as the basis for an extra stage “E” review, this PDCA process helps determine the health and risk-reducing “effectiveness” of the IMP through application of record reviews, subject matter expertise, supporting personnel interviews, industry consensus standard benchmarking and assessment of lagging and / or leading indicators as follows: • Are the workflows required to satisfy IMP objectives and the corresponding personnel accountabilities clearly defined? • Are technical procedures in place to meet IMP objectives and satisfy IMP work flow requirements? • Are the procedures adequate, up to date and readily available to integrity management personnel? • Have the procedures been effectively implemented? • Are records indicating work flow process completion available? • Is a management of change process embedded within the procedure and work flow process? • Is there a process to receive input from personnel to provide suggestions for continuous improvement? • Is the IMP as structured and implemented in alignment with corporate management system and enterprise risk management objectives? • Is the IMP effective in reducing pipeline risk and providing a sound and defensible basis for risk-based decisions and investment planning? Traditional integrity management provides focus on assessing risks and addressing those risks through mitigation activities, while ensuring compliance with laws and regulations designed to continually improve safety. The challenge today is to go beyond determining if an IMP is simply in compliance. An effective risk management system is one where there is a strong safety culture; decisions at all levels of the organization are based on an understanding and consideration of risks; there is continuous monitoring of risk levels and adjustment of responses; and continuous improvement is embedded in the procedures and processes.