RCP's approach to audits and assessments is typically either consultative or enforcement oriented depending upon the client's needs.
- The consultative approach is typically viewed by clients as a cooperative effort that assesses regulatory compliance status in concert with operational and maintenance issues. This method provides feedback on existing management practices versus industry standards.
- An enforcement approach gives the client an idea of how well a facility can manage an agency audit and how likely it would be for an agency inspector to issue a Notice of Violation.
PHMSA Pilot Integrated Inspection (PII)
The PII protocols are very comprehensive, essentially encompassing several existing inspection protocols (pipeline integrity, operations & maintenance, operator qualification, public awareness, new construction, etc.) into one format. In addition, the PII includes several queries that are new or have not been included in previous routine inspection protocols. These inspection protocols have only recently been issued and only a handful of operators have gone through these inspections. Many more are schedule in the near future. RCP has the experience and resources to assist operators prepare for PHMSA Pilot Integrated Inspections.
Compliance Process Mapping
RCP has developed a tool called the Compliance Process Matrix which maps how each regulatory requirement is currently being managed. During the Compliance Process Mapping exercise, RCP will identify each regulated task, existing procedures, personnel assignments and responsibilities, task trigger mechanisms, recordkeeping mechanisms, and other key compliance elements.
When complete, the Compliance Process Matrix will not only identify existing process flow that is functioning properly, but more importantly, it will identify where the process deficiencies lie for each regulatory requirement. For example, your company may have great procedures in place, but inconsistent implementation at various field offices. The Compliance Process Matrix will clearly identify these deficiencies. This is a critical step in determining where to focus attention for program and implementation improvement.
Internal Compliance Audits
- Regulatory Compliance Check-Up's
- Check for Major Compliance Elements (Programs, Workflow Processes, Documentation, Training)
- Comprehensive Regulatory Compliance Audits
- Compliance program gap analysis
- Recordkeeping evaluation
- Field inspections
- Regulatory Agency Jurisdictional Determinations, Interpretations & Audits
- Integrity Management Program
- Operator Qualification
- Operations & Maintenance
- Public Awareness API RP1162
- Facility Response Plans
- US Coast Guard
- Dock Operations
- Oil Spill Response Plans
- Facility Security Plans
- Spill Prevention Control & Countermeasure Plans
- Air/Wastewater Permitting
- Facility Response Plans
- Risk Management Plans
- Process Safety Management
- Health & Safety Plans
- State-Specific Regulations
Agency Inspection Preparation & Post Inspection Support
Prior to an agency inspection, many clients contact RCP requesting a mock audit to help identify any significant issues that need to be addressed prior to the inspection. RCP conducts these audits of programs and records against the published federal and state inspection protocols. A thorough gap analysis and report is provided at the conclusion of the audit that includes any deficiencies and suggestions for improvement. This report also serves as a good reference during the agency inspection, since the agency inspectors will essentially be asking the same questions from the same inspection protocols that RCP utilized during the mock audit.
If an agency inspection identifies deficiencies or in their interpretation of the rules, feel there are some deficiencies, RCP can provide post-inspection support. RCP can quickly correct any procedural deficiency and help develop improved implementation methods to address the agency inspection closure notes or Notice of Amendment letter. If there are post-inspection responses or hearings, RCP is experienced in guiding companies through the process and preparing effective response strategies to bring outstanding inspection deficiencies to closure.
RCP's Compliance Management System is a web-based tool that effectively tracks any task to completion. One of the features of this tool is the Audit Tracking function. Any action item that arises from an internal or external assessment is loaded into the system. Assignments are made and due dates assigned. E-mail notices are sent to supervisors and management personnel to keep them 'in-the-loop' when tasks are pending, completed, or overdue. Customizable reports can be generated which show who is responsible for each task, what the driver is for the task, when the task is due, and whether the task was completed.