During a recent discussion, it was suggested to me that some organizations may not be following the current requirements, (CSA Z662 – 11, clause 10.12.1) established for making temporary repairs. Apparently, there are still some people in the field who believed that bubblegum and duct tape constitutes a reasonable temporary repair under pipeline regulations. It Does Not! The administration of a temporary repair requires an Engineering assessment and documentation in accordance with the Safety and Loss management system. Monitoring and records of temporary repairs must also be linked to the Integrity management system (pre or post conclusion). All temporary repairs must also comply with the pipeline regulations of the appropriate AHJ .
Because of some upcoming issues, now might be a really good time to conduct an internal audit, or review, to ensure that your organization has the proper temporary repair procedures in place. Proper procedures would include documentation and records. The forthcoming issues are both Provincial (specifically in Alberta) and Federal.
With extra attention being paid to the provincial government over some very public incidents in the past few years, a review of the regulatory system was conducted. The government recently released the findings and identified that the codes and standards, as well as the regulatory requirements in Alberta are acceptable. The opposition parties were very quick to point out that the review did not check to see if Pipeline Construction, Pipeline Inspection and Pipeline Repairs were actually complying with requirements. I am fairly confident in predicting that the government will very quickly direct AHJ’s to do additional, or more detailed audits and reviews to verify the level of compliance by industry participants.
The second wave is coming at a Federal level. The Senate wants to do some auditing of its own and has directed a review of the oil and gas transportation systems in Canada to ensure public safety. This will no doubt include a targeted review of compliance with pipeline standards and regulations, based on some recommendations published in 2011. Accordingly industry can expect additional scrutiny in compliance verification at the federal level.
You need to know how you stand before the external auditors and/or reviewers arrive. Are you actually complying with the requirements or just imagining it?
A quick and easy way to do this is to conduct an internal audit (or review) of your repair systems, procedures and records. This will give you a clear indication as to your level of comprehension, and implementation of the standards and regulations. It will also quickly identify if your S&L (Safety and Loss Management) and IM (Integrity Management) program is being conducted effectively.
Here’s what I recommend be done by your IM department:
Conduct an internal audit (or detailed review) of all temporary repairs conducted in the past 10 to 15 years.
Break the records into two groups based on repairs conducted pre- and post-publication of the CSA Z662-07. That is the issue where clause 10.12.1 was introduced to clarify the intent and procedure for all temporary repairs.
For the temporary repairs conducted prior to publication of the 2007 edition, ask the following question:
Are any of the temporary repairs still in place?
A yes is BAD!
A no is GOOD!
The requirements for temporary repairs that were specified in the 2007 edition of the CSA Z662 are not retroactive. They do however clearly establish the intent that should have been implemented by this point. A properly functioning IM system will have captured this and made sure that it was dealt with in an appropriate manner. Accordingly if you have pre 2007 temporary repairs that are still in place, your IM system is likely not functioning properly, and you are not complying with the intent.
For post 2007 repairs the objective will be to verify full compliance to the prescriptive requirements. The question you want to ask:
Do we have any temporary repairs, conducted post 2007, that are not under the supervision of engineering assessment?
Again a yes is BAD!
A no is GOOD!
When the requirements were clarified in 2007, one of the elements was a requirement for mandatory engineering assessment and involvement for ALL temporary repairs (even if pipeline welding is not involved) and for any temporary repairs remaining in place longer than one year the engineer must verify the suitability of the repair with follow-up assessments.
From an audit perspective (internal or external), the answers to these two questions tell a very big story about the company’s understanding of, and compliance with Canadian pipeline requirements.
If your systems are inadequate, you need to discover this and begin taking action before the AHJ does. This demonstrates comprehension and competence in working with the Codes, Standards and Regulations.
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