ARCHIVED - Session 6 - Regulators’ Role, Responsibilities and Opportunities - Ken Paulson, Chief Operating Officer - BC Oil and Gas Commission

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Safety Forum - June 5-6, 2013

Ken Paulson, Chief Operating Officer
BC Oil and Gas Commission

Availability of integrity records is a problem as lines change hands. Is there a role for regulators in enabling record availability?

Availability of integrity records is a problem as lines change hands. Is there a role for regulators in enabling record availability? Yes but there is an even bigger role for the purchaser. Pipeline records should be transferred during a sale - this includes all of the required records under CSA Z662. In BC, Annex N is mandatory and as such the records required under an Integrity Management Program are mandatory as well and should be part of any sale. If a company purchases a pipeline with inadequate documentation, it is their responsibility to acquire the missing information - starting with a plan for how that will be done.

Does (should) the regulator have a role in driving safety culture & SMS performance beyond compliance? If so, is this possible?

My answer would be yes but the extent of the role is related in part to the regulatory mandate. Regulations generally establish the minimum acceptable requirements. Regulators can incent performance above minimum requirements but it must be done fairly and transparently.

Can anyone on the panel comment on integrating and developing one set of consistent pipeline regulations across Canada?

Interestingly, that's pretty much what we have today. CSA Z662 applies in every province and is the backbone of all pipeline regulations provincially and federally. Ideally, if every regulator’s requirements were met entirely by CSA Z662, the only regulation would be the adoption of that standard. Having said that, every regulator in Canada has a slightly different mandate and as such every pipeline regulation will be subtly different. I would add that technically, the requirements in Canada are very similar to those in the US as we have the same roots in ASME B31.4 and B31.8.

Management systems take the industry to the next level - prowell well-sm not reactive.

I agree but would add that they must be implemented and demonstrably effective.

Can the panel comment on the risk of regulation that can't keep up with technology holding back innovation?

I have never really seen this. The nearest example was one I raised at the forum with respect to GRI Wrap/Clock Spring. Even though this repair method was not included within the standard at the time its use was allowed as a trial by many regulators. In my opinion, CSA Z662 does not limit innovation - but it does place the responsibility on the engineer to ensure the innovation is safe and environmentally responsible.

If we have time to do just one thing in the next 6 months, what would be that one thing we should change or do better?

Take the time to read through the requirements for safety and loss management systems and honestly evaluate your company’s compliance. Then work on corrective actions and continuous improvement. If you are not already active in the many not for profit industry initiatives for knowledge sharing then get involved. Getting involved in CSA is a great place to start.

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