Compliance with pipeline regulations cannot be forced. It also cannot be masked. Pipeline operators are either compliant or they are not.
Think of it this way. Regulatory compliance is best achieved when it is the natural outflow of the actions, attitudes, behavior, and culture of your operation.
It’s analogous to what separates a good baseball hitter from a great baseball hitter. A good hitter will think about the end result of trying to hit a home run, resulting in the occasional homer but also a lot of strikeouts. A great hitter will think about doing everything fundamentally sound to make great contact and then oftentimes hitting a home run as a natural outflow of their approach at the plate.
What does it look like for operators to put in the work that leads to natural compliance? Consider these critical elements that go into the right approach to ultimately arrive at regulatory compliance.
1. Policies & Procedures Set the Foundation
Every operator has a set of policies and procedures that guide activity in the control room, in the field, and in the overall operation. Not every operator uses the policies and procedures correctly, however.
– Some operators have not updated their policies and procedures to ensure compliance with the latest regulations, to take into account the latest technology, or to capture changes in your systems or capabilities.
– Other operators have their policies and procedures set to the side in a printed handbook that is rarely referenced by personnel. It’s simply collecting dust and not an effective tool to set the foundation for compliance.
– Still other operators rely on their personnel passing along oral accounts of how to follow the policies and procedures. “This is what I was taught, which is what the person who taught me was taught, which may or may not have been sourced in the policies and procedures.”
The answer to all three common scenarios is utilizing the policies and procedures in a proactive manner to ensure that all personnel are keenly aware of the expectations to follow the policies and procedures and then to be held accountable for following the policies and procedures.
Understandably, this won’t happen overnight. There are steps to take to begin changing attitudes and behaviors toward following policies and procedures that will lead to natural compliance.
2. Set the Plan for How Compliance Will Be Supported
Once policies and procedures are updated, communicated, and presented to all personnel, there needs to be a process for supporting the change.
First, the message needs to be disseminated from the executive level to the managerial level to the controller level. This top-down approach also includes the necessity for executives and managers to follow up on adherence, hold discussions, review metrics tied to compliance, and continue to ask questions.
A common scenario is operators update their policies and procedures, communicate the changes, build excitement, and then fail to set the follow-up action steps. Personnel will eventually return to the path of least resistance doing things how they always were done if they sense that they won’t be held accountable.
The best practice is not just to communicate the changes, but to present the action steps that will be taken to review and discuss adherence to the policies and procedures.
That means no excuse of things got too busy or there just isn’t enough time or we can’t get everyone together in the same room. Put in the time! Be proactive! Make it a priority! Then, prepare to review whether your operation is naturally compliant with regulations.
3. Review Whether Natural Compliance is Happening
Once attitudes, behaviors, and actions begin to shift toward following the updated policies and procedures, you will notice that your operation begins to naturally align with regulations.
It’s about building a culture of compliance where your team performs the tasks they need to do and because the team is following the policies and procedures, compliance just happens. It is organic, natural compliance outflowing from the operation’s everyday activity.
Returning to our baseball analogy, the home run happens because personnel follows their instruction of how to make great contact with the baseball.
In pipeline operations, the key is reviewing the metrics that point to whether the actions taken in the control room and throughout the operation naturally lead to compliance.
If the metrics indicate there are lapses or gaps, then executives and managers need to proactively address what’s happening. Continue to build that feedback loop, hold regularly-scheduled meetings to discuss control room activity, and establish action steps to close the gaps. Don’t let the gaps widen until you have to return to square one of rebuilding attitudes, behaviors, and actions.
Why Focus Inwardly on How to Create Natural Compliance?
To broaden this discussion out to why natural compliance is so important, pipeline operators are uniquely positioned to deliver critical resources for people, businesses, and communities. That comes with considerable responsibility to achieve business goals with no harm.
Taking the steps necessary to achieve compliance is important in and of itself. However, the “why” behind the idea of creating natural compliance is safety. That’s ultimately why policies and procedures exist and why they should align with industry regulations to ensure the safe and reliable transport of resources through pipelines.
As the industry continues to move forward to the “zero incidents” goal in 2019 and beyond, we believe it is critical for operators to pursue the idea of natural compliance. Let this be the battle cry for your operation, then let regulatory compliance flow out of your everyday activity.
EnerSys offers two-fold support to help operators achieve their business objectives while also building a culture of compliance.
– We offer industry-leading software, the POEMS CRM Suite, that helps operators measure operational effectiveness (supporting business objectives) while also ensuring regulatory compliance (alignment with regulations).
– We offer compliance and consulting services that support the strategic planning, implementation, execution, and review of activity in the pipeline control room. We understand the unique needs of pipeline operators and can recommend strategies that ultimately lead to natural compliance.
To inquire about utilizing our software, compliance, and consulting capabilities to support your operation, contact our team today. We would be glad to schedule an educational demo or phone call with your team to discuss our solutions.