At New Century Software and Integrity Plus, we take pride in knowing that our teams are comprised of the most experienced and knowledgeable people in the industry. We strive to build our teams with people that understand the nuances of the pipeline industry, and have studied and grown their skillsets over time. This led us to think, how do our customers and others in the industry know they are getting the best solution and service from a qualified team? To help answer this question, we developed a three-part series, How to Spot an Expert. We’ll touch on DOT compliance consultants, risk and integrity management analysts, and GIS experts.
In the first of our three-part series, we’ll be focusing on the realm of regulatory compliance. To ensure safety and reliability, pipeline operators must show due diligence in developing, implementing and documenting pipeline safety programs that meet Federal and State regulations. From our perspective, there are three critical elements that every consultant should provide to help operators achieve their regulatory goals (and if your consultant isn’t doing these … you might want to start asking some questions).
Always Customize (Templates Won’t Work)
First and foremost, there is no “one-size fits all” integrity management program (IMP). If a consultant suggests that a pipeline operator follow a template or program without having conducted a thorough analysis of your operations, needs, gaps, and pipeline operations, they are not meeting the intent of the regulation. Part of the gap analysis and IMP development process is understanding how operators manage their day-to-day operations, and a DOT compliance expert’s job is to figure out how to work-in what needs to be done to ensure compliance while causing the least amount of disruption to workflows and processes. In our experience, when someone resorts to the “one size fits all” route or using a template, it’s because they do not understand the regulations enough to analyze them and apply them to specific and varying operations. For example:
You might be an operator with 10,000 miles of pipe and 20 employees managing and executing the IMP. Or you may be an operator with 2 miles of pipe and only 2 employees. Whichever best describes you, you have to meet the same requirements, but you don’t have to do it in the same way as the other example. Our compliance team’s job is to tailor the IMP to you in order to make it easy to implement while you manage your pipeline.
Our key take-away? It’s about figuring out the process, not just going through the motions. Take the time to figure out what works and what doesn’t for your pipeline.
Understand the Regulations and Have a Relationship with the Regulatory Agencies
When working as a middleman between operators and the regulatory agencies, there needs to be a true relationship on both sides of the spectrum. Building a relationship with regulatory agencies lends to open communication, allowing compliance experts to learn how best to present facts for interpretation, get quick responses for audits, and communicate needed fixes and gain acceptance for completed audits and IMPs. It’s a cooperative relationship that is beneficial to all involved, and can save time and money. This open dialogue also allows for more of an opportunity to develop the right fit for an audit and program, rather than being forced down a path determined by an agency. Part of building this regulatory relationship includes a real understanding of a regulation and its history while being able to interpret the intent and what the agency will be looking for in the grey areas. This takes the program, and your compliance, to a deeper level beyond just being a “check the box” methodology.
Hire the Right Person for the Job
When building our own compliance team, there are certain qualifications and qualities that we look for in each team member. The most important is breadth of experience. Has the person worked with regulators or operators, studied and interpreted advisory bulletins or inspections, or completed an audit? It is critical to see both the pipeline operator and regulatory agency side of things to get a real understanding of the final goal and the best way to get there, making this kind of experience invaluable.
A key part of this experience includes being able to demonstrate a true comprehension of a regulation by performing an audit or building out an IMP. The result should not simply be a regulatory regurgitation. The person should be able to work with an operator to mold the regulation to their operations and current programs. This is the uncommon skill of being able to see the big picture while also being able to focus in on every little detail. Overall skills that lend to this type of comprehension and attention to detail include: problem/puzzle solving, strong writing skills, and having a breadth of knowledge showing how an organization is intertwined. Does your DOT compliance consultant offer you that?
We want the best for our customers, and pairing them with the best qualified team is part of that. To learn more about our compliance team and the work they do, click here or . Be sure to check back next week for the second part of the series addressing risk and integrity management analysts.