ARCHIVED - National Energy Board Onshore Pipeline Regulations, 1999 (OPR-99) Final Audit Report for Integrity Management, Safety, Environmental Protection, Emergency Management, Crossings and Public Awareness Programs - Appendix V - Crossings Program Audit Evaluation Table

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Appendix V
Westcoast Energy Inc., carrying on business as
Spectra Energy Transmission (Westcoast)
Crossings Program Audit Evaluation Table

Table of Contents

1.0 POLICY AND COMMITMENT

1.1 Policy and Commitment Statements

Expectations:

The company shall have a policy approved and endorsed by senior management (the Policy). It should include goals and objectives and commit to improving the performance of the company.

References:Footnote 1

OPR-99 Sections 4, 47 and 48
CSA Z662-11 Clause 3.1.2

Assessment:

Westcoast senior management participates in several committees that oversee the development and implementation of the policies that frame the Environment, Health and Safety (EHS) Program. For the purposes of this audit, the Crossings Program is considered to be subsumed in the Safety Program. Westcoast management communicates the policy for EHS programs through an Operational Steering Committee. The EHS Policy is signed off by Spectra Energy’s President and Chief Executive Officer.

The Policy was available at all sites and staff interviews confirmed that employees are aware of its existence. A review of the Policy from the 2012 purpose statement is as follows:
“To achieve our purpose we manage risk in everything we do, by continuously improving on

  • Employee, contractor and vehicle safety;
  • Process safety;
  • Environmental Management;
  • Reliability; and
  • Cost management.”

While Westcoast was able to demonstrate that its Policy is signed off by senior management and communicated to employees, the audit found that “public safety” is not mentioned in the Policy. While it is understood that public safety is achieved when the goals listed are reached, the NEB Act and associated regulations clearly separate the safety of the public as a requirement.

Compliance Status: Non-Compliant

2.0 PLANNING

2.1 Hazards Identification, Risk Assessment and ControlFootnote 2

Expectations:

The company shall be able to demonstrate a procedure to identify all possible hazards. The company should assess the degree of risk associated with these hazards. The company should be able to support the rationale for including or excluding possible risks in regard to its environment, safety, integrity, crossings and awareness and emergency management and protection programs (management and protection programs). The company should be able to implement control measures to minimize or eliminate the risk.

References:

OPR-99 Sections 4(2), 37, 39, 40 and 41
CSA Z662-11 Clause 3.1.2(f)

Assessment:

Administrative assistants conduct the initial screening of crossing requests that are submitted through the One-Call system. Operations supplied them with criteria such as parameters for vehicle load versus amount of cover. For activity applications that are in closer proximity to the pipeline, they open a file and pass the “in conflict” requests to the Lands department for further evaluation. Depending on the level of expertise required to review the application based on factors such as proximity to the pipe and the nature of the request, the applications are addressed by either the Lands or Operations teams.

The hazard identification for third party crossing activity is incorporated and captured in the permitting process and outlined in the related documentation. The Land and Crossing Administrator assesses the application using information and formulas provided on the Source (Westcoast’s internal intranet site). Based on the assessment, they forward on the applications that require engineering assessments. All crossing requests are administered with permits. These permits include the instructions for conducting the work as well as the safety and contact information. The Lands and Damage Prevention groups also work with the Public Awareness group to identify and address potentially hazardous activities, such as deep tillage. Once identified, the groups work on a strategy to address the hazard with awareness activities or alterations to permit templates and information.

Westcoast was able to demonstrate that it has implemented a hazard identification process that is incorporated into its processing and administration of third party crossing applications. As well, the Damage Prevention and Lands groups work with the Public Awareness group in the identification of potentially hazardous activities.

Compliance Status: Compliant

2.2 Legal Requirements

Expectations:

The company shall have a verifiable process for the identification and integration of legal requirements into its management and protection programs. The company should have a documented procedure to identify and resolve non-compliances as they relate to legal requirements which includes updating the management and protection programs as required.

References:

OPR-99 Sections 4 and 6
PCR Part II Sections 4 and 5
CSA Z662-11 Clause 3.1.2(h)(i)

Assessment:

Westcoast monitors legal requirements through a subscription to Templegate Information Services Inc. and Cyber Regs, as well as membership in professional organizations such as CEPA and the Canadian Common Ground Alliance. Westcoast’s Regulatory Affairs group communicates regulatory changes via email to a list of group leads. It is then up to the recipients on the distribution list to identify any changes that are relevant to their respective operational processes. For example, according to staff, it was the Regulatory Affairs office that ensured that Westcoast complied with the Exemption Order Respecting Crossings by Agricultural Vehicles or Mobile Equipment (NEB M0-21-2010). Document review also demonstrated that regulatory references are identified in some Standard Operating Procedures (SOPs).

While the company was able to demonstrate that communication of regulatory requirements is occurring, and that personnel are incorporating new requirements into some of the procedures and templates, Westcoast did not demonstrate that there is an inventory of legal requirements or a formal process to verify whether the Damage Prevention and Crossing Programs are meeting all of the legal requirements.

Compliance Status: Non-Compliant

2.3 Goals, Objectives and Targets

Expectations:

The company should have goals, objectives and quantifiable targets relevant to the risks and hazards associated with the company’s facilities and activities (i.e. construction, operations and maintenance). The objectives and targets should be measurable and consistent with the Policy and legal requirements and ideally include continual improvement and prevention initiatives, where appropriate.

References:

OPR-99 Sections 47 and 48
CSA Z662-11 Clause 3.1.2

Assessment:

Westcoast sets goals at various levels of the organization. At the corporate level, set goals often include issues related to safety and operations. For example, one of this year’s corporate goals was for 100% of staff to complete the core safety training by 31 October 2012. Westcoast staff goals and targets are developed, in part, to reflect the corporate ones such as completing safety training. Goals and targets for employees are established in staff development plans then managed and tracked through performance management and tied to the organization-wide Short-term Incentive Pay (STIP) program.

Within the Lands and Damage Prevention groups, goals are established related to business and process improvements as well as meeting regulatory requirements. For example, following the issuance of NEB MO-21-2010, a depth of cover survey was included among staff goals for the year. The Lands and Damage Prevention groups also report the number of unauthorized activities to the Operations group to be included among its Key Performance Indicators. These teams work closely with the Public Awareness Teams in order to identify new potential audiences or hazardous activities. Document review confirmed that goals and targets are established relating to the Public Awareness Program staff and activity development.

Westcoast was able to demonstrate that there is a process for establishing goals, targets and objectives for its Lands and Damage Prevention Programs, and that related issues are monitored and measured, and used to form the basis of the plan going forward. Within the Lands and Damage Prevention groups, goals are established for the related programs annually and these goals contribute to staff performance reviews.

Compliance Status: Compliant

3.0 IMPLEMENTATION

3.1 Organizational Structure, Roles and Responsibilities

Expectations:

The company shall have an organizational structure that allows its management and protection programs to effectively function. The company should have clear roles and responsibilities, which may include responsibilities for the development, implementation and management of the management and protection programs.

References:

OPR-99 Sections 40, 47 and 48
CSA Z662-11 Clause 3.1.2(b)

Assessment:

The Team Leader, Public Awareness, Team Leader, Crossing Administration and Damage Prevention and the Manager of Lands, Field Operations all report to the Lands and Pipeline Safety Director. The third party crossing permits are managed in the Crossing Administration and Damage Prevention Team. The staff who manages and performs third party locates reports through the Manager of Lands, Field Operations. This team has staff in Vancouver, Fort St John and Prince George, BC, as well as contract workers in various locations around BC. The Team Leaders conduct annual reviews to discuss performance, goals and targets. The Team Leaders review the workload with the Director during their quarterly reporting.

Westcoast was able to demonstrate that it has a functioning structure to maintain the program as designed. With all of the third party contact points managed under one team, communication among the groups contributes to the ongoing functioning of all programs.

While each of these groups have distinct roles and responsibilities, they also have well established communication triggers for issues that affect the other areas and processes in place for regular review of the adequacy of each program.

Compliance Status: Compliant

3.2 Management of Change

Expectations:

The company shall have a management of change program. The program should include:

  • identification of changes that could affect the management and protection programs;
  • documentation of the changes; and
  • analysis of implications and effects of the changes, including introduction of new risks or hazards or legal requirements.

References:

OPR-99 Section 6
CSA Z662-11 Clause 3.1.2(g)

Assessment:

Management of Change (MOC) related to Lands and Crossings is managed out of Vancouver, British Columbia and MOC for asset changes is managed at local facilities. Its current MOC program has scoped in Public Awareness as a group that needs to be notified and evaluated for potential impacts when there are changes involving the assets, such as databases. The MOC Descriptions of Affected Applications, Systems, Documentation and Processes, describes the circumstances for involving the Public Awareness Program in the MOC. Review of the documentation provided indicates that the triggers for MOC and the Public Awareness Program mainly involve the Geographical Information System (GIS). While it is understood that changes to the GIS system database should be managed, it is not clear what other types of changes at Westcoast would trigger the MOC process and when the Lands or Damage Prevention Teams would be notified and considered in that change.

Interviews confirmed that Westcoast is in the process of developing and implementing an Operations Management System (OMS). Westcoast indicated that it intends to incorporate the MOC process into the OMS. Interviews indicated that public safety measures such as damage prevention and lands related matters had yet to be included in the scope as triggers for the new MOC.

Although there are aspects of a functioning asset- based MOC process in place, and improvements are planned, at the time of the audit, Westcoast failed to demonstrate that it has implemented a comprehensive MOC process that includes the appropriate triggers to include the Lands and Damage Prevention groups.

Compliance Status: Non-Compliant

3.3 Training, Competence and Evaluation

Expectations:

The company shall have a documented training program for employees and contractors related to the company’s management and protection programs. The company shall inform visitors to company maintenance sites of the practices and procedures to be followed. Training requirements should include information about program-specific policies. Training should include emergency preparedness and environmental response requirements as well as the potential consequences of not following the requirements. The company should determine the required levels of competency for employees and contractors. Training shall evaluate competency to ensure desired knowledge requirements have been met. Training programs should include record management procedures. The training program should include methods to ensure staff remains current in their required training. The program should include requirements and standards for addressing any identified non-compliances to the training requirement.

References:

OPR-99 Sections 28, 29, 30(b), 46, 47, 48 and 56
CSA Z662-11 Clause 3.1.2(c)(iii)

Assessment:

The Land Services Administrator tracks training for all employees in the Lands and Pipeline Safety Awareness Team using a Learning Management System (LMS) database. The training records for the Lands staff are managed in LMS by administrative staff in the Vancouver office. Expiration dates are put on required courses for Westcoast staff and the system sends out email alerts three months before the training has expired. Interviews confirmed that employees in the field offices were aware of LMS and the online courses available in that database.

All mandatory training is entered in the LMS database. Once leaders have met with staff to determine learning and development plans, all additional training is also included in the LMS. For instance, the Damage Prevention Team Leader requires her team to take Ground Disturbance level I and II training. This course is entered in the LMS and the training records are managed there. Other training is managed within the performance management and professional development process in Career Zone. For example, although there are no formal requirements for the Land Agents to have a professional designation, all current Land Agents are enrolled in International Right of Way Association (IRWA) courses in pursuit of the IRWA designation. While all Lands staff is subject to reviews and evaluations, contract land agents are not subject to the same reviews to ensure that they are performing in accordance with Westcoast standards and procedures.

While employees in the Damage Prevention and Lands Team are trained and evaluated on a regular basis, Westcoast could not demonstrate that there is a process in place to evaluate its contractors who conduct third party locates as required by CSA Z662-11.

Compliance Status: Non-Compliant

3.4 Communication

Expectations:

The company should have an adequate, effective and documented communication process(es):

  • to inform all persons associated with the company’s facilities and activities (interested persons) of its management and protection programs policies, goals, objectives and commitments;
  • to inform and consult with interested persons about issues associated with its operations;
  • to address communication from external stakeholders;
  • for communicating the legal and other related requirements pertaining to the management and protection programs to interested persons;
  • to communicate the program’s roles and responsibilities to interested persons.

References:

OPR-99 Sections 18, 28 and 29
CSA Z662-11 Clause 3.1.2(d)
PCR Part II Sections 4 and 5

Assessment:

Organization wide safety related communication takes place during mandatory safety stand down meetings and monthly mandatory safety meetings which are delivered to all sites simultaneously. There are also less formal town hall meetings to discuss safety topics which include third party issues such as call before you dig issues and agricultural practices. Employees also receive weekly safety reports by email that are posted on the Source and emails from Public Affairs.

Each of the Damage Prevention and Lands Teams provide the Director with weekly reports on workload and issues related to workload. Communication also takes place with related teams. For example, Land Agents attend weekly meetings with Operations to discuss potential land issues prior to any Operations and Maintenance (O&M) work.

Westcoast works with BC Common Ground Alliance and BC One-Call to organize contractor safety breakfasts, Digsafe BC! Workshops and other related trade shows to discuss general safety practices and regulatory requirements for working around federally regulated pipelines. They also place ads with safety messages in trade journals and community newsletters. The external website also contains readily available safety and contact information for landowners and other third parties. Communication with potential crossers occurs throughout the permitting process in order to ensure a complete permit. The Damage Prevention and Crossing Administration team includes the company’s written permission as well as the instructions for working near the pipeline such as whether or not a Westcoast employee has to be onsite during the work.

The Lands Team communicates with landowners regarding any O&M work that Operations has determined is required. Westcoast has contractors in the North East BC area to perform locates for third parties. To communicate with landowners regarding O&M projects, they provide a company contact. Any landowner issues or complaints are managed through the issue resolution process.

While communication with external stakeholders has established processes and triggers, the audit was unable verify that the Westcoast Internal and External Communication Performance Standard 6.0 (September 2006) is fully implemented and cross referenced to the OMS system to include and communicate all required crossings or damage prevention information to the appropriate levels.

Westcoast was able to demonstrate that it has established regular communication within the Crossings Program as well as triggers for communicating with other teams such as Operations and Integrity. Although communication is occurring within the Crossings Program, and there are triggers in place from the programs outward, Westcoast failed to demonstrate that there is an implemented internal communication plan for the organization that includes the Crossings Program in order to ensure that relevant information is communicated in a timely way to internal stakeholders.

Compliance Status: Non-Compliant

3.5 Documentation and Document Control

Expectations:

The company should have documentation to describe the elements of its management and protection programs- where warranted. The documentation should be reviewed and revised at regular and planned intervals. Documents should be revised immediately where changes are required as a result of legal requirements or where failure to make immediate changes may result in negative consequences. The company should have procedures within its management and protection programs to control documentation and data as it relates to the risks identified in element 2.0.

References:

OPR-99 Section 27
CSA Z662-11 Clause 3.1.2(e)
PCR Part II Sections 10 and 11

Assessment:

Westcoast employees store and use procedures and templates that are saved on the intranet site “the Source”. In order to facilitate access to the most current templates, the Damage Prevention Group has created a page to post all of the forms, policies and related links for their group. If changes or enhancements are made to any of the procedures or templates, the Crossing Administration and Damage Prevention Group uploads the new documents and announces the new versions by email. Field interviews confirmed that field staff was aware of the requirement to use documents from the Source to ensure that they were using the most recent versions.

Westcoast was able to demonstrate that it has implemented a process to maintain and communicate the policies, procedures and templates related to its Damage Prevention and Lands activities.

Compliance Status: Compliant

3.6 Operational Control-Normal Operations

Expectations:

The company should establish and maintain a process to develop, implement and communicate mitigative, preventive and protective measures to address the risks and hazards identified in elements 2.0 and 3.0. The process should include measures to reduce or eliminate risks and hazards at their source, where appropriate.

References:

OPR-99 Sections 21, 27 to 49
CSA Z662-11 Clause 3.1.2(h)
PCR Part II Sections 4 and 5

Assessment:

The Crossing Administration and Damage Prevention Group manages requests for permission submitted by third parties who are planning to excavate or build on or near the right of way as well as those parties who wish to arrange for crossing the right of way with heavy equipment. According to staff, this group receives and manages the requests it receives directly or through BC-One Call. Document review confirms that there are procedures that are available for employees to address the various levels complexity of the requests. Staff members follow set engineering criteria to manage the requests and issue the appropriate permits, or pass the request to the appropriate technical group. This group issues approximately 450-500 permits each year.

The Manager of Lands, Field Operations and his group conduct the field component related to third party crossing activities. Land Agents in this group are trained and accountable to perform locates, attend crossings, inspects the pipe prior to backfilling, as well as issue on-site approvals following the established criteria. This group also works with residents to arrange the removal of encroachments and notifies the surrounding residents, fire departments and municipalities when there is a planned flaring activity associated with regular maintenance.

Westcoast was able to demonstrate that its Damage Prevention and Lands groups have established policies and procedures that address the hazards and risks associated with third party excavation and construction activities as described in the NEB requirements.

Compliance Status: Compliant

3.7 Operational Control-Upset or Abnormal Operating Conditions

Expectations:

The company shall establish and maintain plans and procedures to identify the potential for upset or abnormal operating conditions, accidental releases, incidents and emergency situations. The company shall also define proposed responses to these events and prevent and mitigate the likely consequence and/or impacts of these events. The procedures must be periodically tested and reviewed and revised where appropriate (for example, after emergency events).

References:

OPR-99 Sections 32 and 52
CSA Z662-11 Section 10.5.2

Assessment:

According to the Lands and Pipeline Safety Awareness Crossing Administration and Damage Prevention –Roles and Responsibilities document, emergency response related activities are included among this group’s accountabilities. Interviews confirmed that Land Agents are also deployed for aerial surveillance to assist in the assessment of the situation following an emergency. They also work with the Public Awareness staff to communicate with the community regarding the state of remediation and when the system comes back online.

Emergency management related functions are incorporated directly into the responsibilities of the Lands and Pipeline Safety group, particularly for the Land Agents. The Land Agents are trained in Incident Command System, are part of the standing Emergency Response team, and are part of the team on call for emergencies 24/7. When incidents occur in populated areas, Land Agents use the information in the GIS database to determine the number of people, as well as if any residents requiring evacuation have disabilities and will require special attention. In addition, the Land Agents and Public Awareness employees participate in emergency training sessions and table top exercises, and also prepare and deliver community liaison awareness sessions.

Although the Westcoast emergency response program is discussed in further detail in Appendix IV of this audit report, the overlap of duties and substantial roles played by the Lands and Public Awareness Teams were reviewed and found to be in compliance with regulatory expectations.

Compliance Status: Compliant

4.0 CHECKING AND CORRECTIVE ACTION

4.1 Inspection, Measurement and Monitoring

Expectations:

The company shall develop and implement surveillance and monitoring programs. These programs should address contract work being performed on behalf of the company. These programs should include qualitative and quantitative measures for evaluating the management and protection programs and should, at a minimum, address legal requirements as well as the risks identified as significant in elements 2.0 and 3.0. The company should integrate the surveillance and monitoring results with other data in risk assessments and performance measures, including proactive trend analyses. The company shall have documentation and records of its surveillance and monitoring programs.

References:

OPR-99 Sections 36 and 39
CSA Z662-11 Clause 3.1.2(h)(i)
PCR Part II Sections 4, 5, 10 ad 14(1)

Assessment:

The Lands team participates in the right of way (ROW) inspections. Each section of the Westcoast system is inspected by helicopter monthly to monitor for unauthorized activity and potential environmental issues. In order to ensure that issues are identified, staff follows set criteria for the aerial inspections. In areas where Westcoast shares a ROW with Pembina, the companies alternate monthly aerial patrols and report accordingly. Interviews confirm that the Lands group attends the aerial ROW patrols and submits the reports regarding the state of signage, any unauthorized activity or encroachments noted, as well as the state of vegetation. Signage is maintained on an ongoing, as-required basis to ensure it is legible and visible.

Westcoast was able to demonstrate that it has processes and procedures in place for the surveillance and monitoring of its ROW.

Compliance Status: Compliant

4.2 Corrective and Preventive Actions

Expectations:

The company shall have a process to investigate incidents or any non-compliance that may occur. The company shall have a process to mitigate any potential or actual issues arising from such incidents or non-compliances. Such mitigation may include appropriate timing and actions for addressing the issues that arise. The company shall demonstrate that it has established a documented procedure to:

  • set criteria for non-compliance;
  • identify the occurrence of any non-compliances;
  • investigate the cause(s) of any non-compliances;
  • develop corrective and/or preventative actions; and
  • effectively implement the required corrective and/or preventative actions.

The company should develop procedures to analyze incident data in order to identify deficiencies and opportunities for improvement in its management and protection programs and procedures.

References:

OPR-99 Sections 6 and 52
CSA Z662-11
Clause 3.1.2(h)(i) PCR Part II Section 13

Assessment:

Westcoast has developed and implemented procedures for addressing the reporting requirements for unauthorized activities outlined in the PCR. Reporting templates are maintained by the Damage Prevention Team and available to all employees on the Source. All unauthorized activities are entered in the Incident Tracking Database to be managed until addressed.

The Damage Prevention Team is responsible for reporting these events to the Board as well as following up with the third parties. The Damage Prevention Team enters the unauthorized activity reports into the GIS database to link them to the section of ROW. The Damage Prevention Team also communicates with the Public Awareness Team in order to correlate awareness activities and unauthorized activities when appropriate. The Lands Team members are located throughout the province and can be involved when onsite follow-up and investigation is required.

Westcoast was able to demonstrate that it has a process to identify and respond to unauthorized activities, and that staff are aware of their roles regarding reporting and follow-up.

There is also a well-established feedback loop to analyze the events, and identify deficiencies and appropriate follow-up.

Compliance Status: Compliant

4.3 Records Management

Expectations:

The company shall establish and implement procedures to ensure that the records supporting the management and protection programs are retained, accessible and maintained. The company shall, as a minimum, retain all records for the minimum lengths of time as required by the applicable legislation, regulation and standards incorporated by reference into the regulation.

References:

OPR-99 Sections 41, 51, 52 and 56
CSA Z662-11 Clause 3.1.2(h)(iii)
PCR Part II Sections 10(c), 11(1) and 16

Assessment:

Westcoast maintains several databases related to the programs under the Director of Lands and Pipeline Safety. For third party crossing and damage prevention, related files and records are stored in the GIS database according to standards established by the Lands group. All records related to any third party crossing file are uploaded to GIS and available to all staff. Staff at all locations has read access to all of the layers of information. It is used to obtain a current snapshot, as well as a history of activity at a specific location. For instance, staff uses the GIS database to access records regarding O&M activities, unauthorized activities, as well as permits granted to the same piece of property along the ROW. The system has several layers of data entered so it is useful for many teams.

A review of the database entries showed that Westcoast enters all related permit applications, permits, correspondence, unauthorized activities, landowner complaints by the GIS coordinates. The result is that staff can obtain information as it relates to a particular section of its ROW.

Westcoast was able to demonstrate that it has implemented and maintained appropriate records management in accordance with the legal requirements.

Compliance Status: Compliant

4.4 Internal Audit

Expectations:

The company shall develop and implement a documented process to undertake audits of its management and protection programs and procedures. The audit process should identify and manage the training and competency requirements for staff carrying out the audits. These audits shall be conducted on a regular basis.

References:

OPR-99 Section 53
CSA Z662-11 Clause 3.1.2 (h)(iii)

Assessment:

Senior management of Spectra Audit Services is located in Houston, Texas. However, an audit manager and several staff are located in Calgary, Alberta. Calgary-based audit staff perform most of the Westcoast internal audits, sometimes with participation by Houston-based audit staff. The audits against program requirements occur on a regular basis and vary in size and scope. Interviews and document review confirm that all non-compliant findings are tracked, assigned to staff for completion, and reported to upper management.

While other operational programs are routinely reviewed, interviews confirmed that the Lands and Pipeline Safety Programs have not yet been included in an operational audit done by the audit team out of Houston. Also, according to staff there are no formal reviews of the Lands and Damage Prevention Programs to ensure that they are developed and maintained in accordance with the legal requirements.

Westcoast was not able to demonstrate that the requirements of the PCR have been scoped into any internal operational audits. Also, it did not demonstrate that the requirements of the PCR are included in its audit protocols for the audits regarding safety of the public in order to confirm compliance.

Compliance Status: Non-Compliant

5.0 MANAGEMENT REVIEW

Expectations:

Senior management should formally review the management and protection programs for continuing suitability, adequacy and effectiveness. The review should be based on appropriate documentation and records including the results of the surveillance, monitoring and audit programs. This review should be formal and documented and should occur on a regular basis. The management review should include a review of any decisions, actions and commitments which relate to the improvement of the programs and the company’s overall performance.

References:

OPR-99 Section 53
CSA Z662-11 Clause 3.1.2(h) (iii)
PCR Part II, Sections 4 and 5

Assessment:

According to staff, the Public Awareness, Lands and Damage Prevention Teams report results to the Director of Lands and Pipeline Safety. These reports form the basis for the programs going forward and are also discussed during performance reviews. Interviews with Senior Management confirm that reports of unauthorized activity trends are discussed at a senior management level. These reports are synthesized into management’s overall safety and performance reporting. Management from head office also conducts mandatory safety stand down meetings which often address topics related to third party damage prevention.

Senior management receives reports regarding the performance of the damage prevention related programs and includes public safety and damage prevention topics in its regular communications. While the Board acknowledges that there is communication occurring, Westcoast was unable to demonstrate that it has established the required processes that contribute to an adequate management review. As noted in element 2.2 of this report, Westcoast does not have a formal process of confirming that there is a current and complete inventory of legal requirements guiding the development and implementation of its Crossing program. Also, Westcoast’s internal audit process does not include an evaluation of compliance to the PCR which outline the requirements for addressing third party activities. Without this confirmation of compliance, senior management cannot verify that the Crossing program is operating in compliance with all of the requirements. As well, Westcoast’s policy and purpose statement does not explicitly include public safety, and so there is no clear line of sight from Westcoast’s policy to the Crossings Program. Therefore the Board is not satisfied that there are sufficient processes in place by senior management to allow for a formal and documented management review to ensure ongoing suitability of the Crossings Program.

Compliance Status: Non-Compliant

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