Compliance with US health, safety, and environmental regulations by petroleum liquids pipelines can be complicated, according to Barbara A. Carroll, TEPPCO vice-president for environmental, health, and safety.
Competing, sometimes conflicting requirements from more than one agency often set up a nearly impossible situation for a company, she said. But usually, TEPPCO is "able to comply with the spirit of [competing] regulations U and let the agencies sort out [jurisdiction]."
The key to compliance, she said in an exclusive interview with Oil & Gas Journal, is the process.
Steps
That process must involve, first, making sure the company is aware of regulations. This part is more difficult than it appears on first glance, with several federal and state agencies promulgating and enforcing rules.
"We try to work with other companies, industry advocacy groups, and one-on-one" with regulators to make sure the company is aware of proposed new rules and changes to existing ones and can have some influence in their terms, she said.
Such awareness will support the company's permitting process, first by making sure it has all required and correct permits and secondly by making sure the language of the permit is flexible enough to cover the variety of operating parameters at TEPPCO's facilities.
Permitting is in fact the first of three steps in TEPPCO's own process to ensure it is in full compliance with all regulatory requirements.
But, said Carroll, "documentation is the name of the game: paperwork, paperwork, paperwork." Documentation communicates to all parties, within and without the company, that it is in compliance.
The second step involves compliance reporting, according to Carroll. The company's "Compliance Assessment Program" or CAPS "covers both health and environmental safety requirements." It allows facilities to track "on a daily, weekly, monthly, quarterly basis" their compliance with their permits.
It's very detailed and specific, said Carroll: For example, "once a month [company personnel must] sample the water in the dike before" discharging more. "Doesn't sound too exciting but if you discharge water with a sheen on it, you're in violation."
The final part of the compliance plan is assessment: "We go out and confirm compliance with a checklist.
"It's kind of like an open book test because we make the checklist available so anybody can go ahead and 'take the test' ahead of time, if you will, find any gaps. They make sure to close those gaps and track them and code them based on whether it's a regulatory compliance [problem], a company procedure [issue], or [an industry] best practice [deviation]," said Carroll.
"We track those [gaps] and they all have to be closed within a certain amount of time, depending on their degrees of importance."
The message, she said, is to "have a process and to work the process."
The process must be "communicated and communicated and communicated." It must be in a form that is "easily understood, easily communicated, and reiterated over and over again."
Communication must occur up and down the company's chain, said Carroll: from the board of directors to the operator "turning the valve and who's really responsible on a day-to-day basis for keeping us in compliance."
OQ Rule
Carroll focused, at one point, on the company's compliance with the US Department of Transportation's Operator Qualification Rule, which has caused companies considerable problems.
While many companies have focused on defining so-called "covered tasks," Carroll said "the big issue is documentation."
"To be able to say, to go back on such and such a day on such and such a year that such and such an employee did such and such a covered task, that he or she had passed, was qualified.
"How are you possibly going to keep up with that?" Carroll said TEPPCO has been looking at some software products that would actually exclude an operator from performing a task if his computerized documentation does not indicate he has been properly trained and certified.
