Compliance Oversight of Operators’ Integrity Management Program for Pipelines: A Risk Based Evaluation Approach Incorporating Safety Culture

Integrity Management Program (IMP) is a systematic and documented program for assuring asset integrity throughout the full life cycle of an asset. To ensure safe and reliable operation, the British Columbia Oil and Gas Commission (Commission) has been requiring its licensed pipeline operators through its regulations to develop and implement pipeline integrity management programs (IMPs) in accordance with Canadian Industry Standard CSA Z662. The auditing process, the collated results and findings from the IMP audit years (2011–15) were published in IPC 2016-64161[1]. Since 2016, the Commission has enhanced its IMP compliance assurance process, and aligned it with the management system approach using Deming’s model of plan-do-check-act (PDCA) for IMP components and incorporated a lifecycle approach that spans the entire lifecycle of a pipeline system from planning to abandonment. In addition, the Commission has adopted a multi-criteria decision-making approach when prioritizing which operators to audit. This method utilizes weighted rank approach and takes into account multiple factors, such as, previous IMP audit results, pipeline length and product, class location, incident frequency, and asset age. Through collaborative efforts with the University of British Columbia (Okanagan), an innovative risk based audit tool — Integrity Management Program Audit and Knowledge Tool (IMPAKT) has been developed to help evaluate the compliance of operators’ IMP in terms of the management system approach and its associated risk. This tool conducts three-dimensional analysis of IMP performance using the failure mode effect analysis (FMEA) technique and allows the Commission to generate a risk profile for each IMP component to determine which components are most critical, requiring immediate attention. The final audit results are presented as a Risk Priority Number (RPN), which is a product of severity, occurrence and action. An effective integrity management program requires a strong safety culture, therefore, safety culture aspects are incorporated into the risk based auditing tool, IMPAKT. This risk based evaluation process also allows the Commission to develop a compliance benchmark to make comparison between different operators’ IMP results for continuous performance improvement. This paper presents the innovative approach developed and implemented by the Commission for the IMP compliance oversight (auditing) process and implication of such changes.