Knowledge Gained From A Five-Year Regulatory Compliance Assurance Process For Operators' Pipeline Integrity Management Programs

Pipelines are the most efficient and common infrastructure for the transportation of oil and gas. For Canadian pipeline operators, CSA Z662 Annex N is considered the industry standard for the development and implementation of integrity management programs (IMP) which include essential elements of policy and commitment; planning (goals, targets, organizational structure, roles and responsibilities, hazard identification, risk assessment and control); implementation (management of change, training and competency, documentation and record management); checking and corrective action (inspection, measurement and monitoring, investigating and reporting incidents, and internal audits); and management review elements over the lifecycle of a pipeline asset. In 2006, the British Columbia Oil and Gas Commission (Commission) made CSA Z662 Annex N mandatory for pipeline operators within its regulation. This paper provides an overview of the Commission's compliance assurance process through the assessment of British Columbia's pipeline operators' IMPs and presents findings from the first five year (2011-15) assessment cycle. The analysis and trends of findings are presented in detail along with tracking of corrective actions. This paper also discusses knowledge gained from the compliance assurance process, along with the areas of proposed improvement to the current process for the next five year cycle. This includes alignment of the assessment process with the management system approach (using a risk based assessment process), improving regulation and the processes of compliance assurance and enforcement.