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ICAM for Gas Transmission
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ICAM is 100% configurable, allowing for the management, scheduling, tracking, documenting and reporting of activities associated with compliance. Each operator may determine the level of detail to be managed within the system.
Why the ICAM Solution?
Procedures and results are not enough. Whether guided by the protocols in the US or Annex N in Canada, the expectation is that integrity management needs to include who, what, when, where and why. If these items are in any procedure, it is probably a recent one that was developed in response to guidance that has been adopted by the regulators. Typical procedures include, scope, roles and responsibilities, definitions, tasks/steps, frequency and associated documentation.
* Does your organization have distinct procedures for the requirements of the aforementioned guidance?
* Are these set out as procedures or are they imbedded in your IMP?
* And in either case how can you demonstrate that they have been implemented, documented and are reportable?
The use of a process management system supports these requirements in the following manner:
1. Scope - with the platform you need to have the ability to manage documentation that details your company's positions. These positions might include policy, strategy and interpretation of the rule. They are one time statements that are not required to be repeated every time an integrity action is taken. They do however need to be reviewed on a scheduled basis and updated through an MOC process as required.
2. Roles and Responsibilities - The primary concern by PHMSA is accountability. They have proven that they do not want to see a group have integrity requirements as this inevitably leads to miscommunication and dropped balls. Within the web based integrity compliance activity management platform each integrity process (as defined by the operator) is assigned to a specific individual with optional routing for approvals based on the criticality of the activity. Using IMP software allows for reporting of all the activities that have been completed or have been scheduled and who the responsible party is. The use of a management system will ensure that no balls are dropped. In the event there is change in the organization chart; reassignment may be accomplished with the click of one button.
3. Definitions - as these are one-time items, they may be attached in the same fashion as reference documents to support the knowledge base for the individuals assigned integrity responsibility.
4. Tasks / Steps - one might consider a procedure of this nature a process document. As such within the integrity management system, the processes may be configured to reflect the actual work methods being employed by the operator. Each process may have tasks that confirm the integrity activity was completed and allow for the attachment of any associated supporting documentation. The task response options as well as the documentation requirements can be defined so that each integrity process is completed and documented in a consistent manner.
The tasks/steps associated with any process may serve different purposes.
a. Tasks may be specific to the integrity activity
b. Tasks may be of a quality control nature for the process
c. Tasks may be of a communication nature in that they require results to be communicated
d. Tasks may be of a record keeping nature to organize documentation specifically as it relates to the asset
the integrity process was scheduled on
5. Frequency - through the use of an integrity management system, all processes may be scheduled on a standalone basis, they may be scheduled as part of a sequential group and, each of these may be scheduled to repeat based on the required frequency of the activity, be it annually, every 7 years or in the case of some quality assurance metrics, every 6 months.
Through the use of repeating processes, the requirement to manage change (recognize and react to it) is facilitated
a. Annual change management of HCA
b. Annual change management of Threat Identification
c. Annual change management of Risk analysis
d. Annual completion of Preventative & Mitigative actions
e. Annual review of the processes implemented to determine the Performance of the integrity program
6. Documentation - the documentation associated with each task response may be configured for consistency purposes. Additionally, the report of the implementation serves as supporting documentation in an audit environment.
A typical report available through an integrity compliance activity management platform would include:
1. The Protocol Requirement being addressed
2. The reference documents that were available to the responsible party
3. The responsible party and any approvals
4. The asset the activity was performed on
5. The scheduled metrics such as start date, completion date, due date and the variance
6. The meetings, communications and lessons learned through the completion of the event
7. The actual task completed with their responses and associated documentation
8. And whether any management of change requests were submitted as a result of the completed activty
Integrity compliance activity management through a web based platform supports the requirements for the Soft protocols that are not on the pipe and in fact should be considered as part of each on the pipe requirement.
1. Quality Assurance - may be embedded as tasks/steps for any process or may be scheduled processes themselves.
2. Management of Change - tracked and managed following the completion of integrity activities, capturing the nature of the change, the analysis of implications, the management approval, the implementation and very importantly, the subsequent communications.
3. Communications - may be configured as tasks/steps in a process or they may be standalone activities with their own schedule such as internal integrity meetings.
4. Record Keeping - the reports of completed activities, the supporting documentation for any completed process, the notification and communications, the meetings captured, the lessons learned, the reference documentation and finally the dialog captured between the parties with responsibility and approval for any process ALL serve as records that may have historical value.
Please contact us to learn more.
