pipeline assessment form guidelines

8/3/2019 Pipeline Assessment Form Guidelines

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Pipeline Integrity ManagementProgram (IMP) AssessmentForm and Guidelines

October 30, 2007


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ALBERTA ENERGY AND UTILITIES BOARD

Pipeline Integrity Management Program (IMP) Assessment Form and Guidelines

October 2007

Published by

Alberta Energy and Utilities Board

640 5 Avenue SWCalgary, Alberta

T2P 3G4

Telephone: (403) 297-8311

Fax: (403) 297-7040

E-mail: [email protected]

Web site: www.eub.ca


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EEUUBB PPiippeell iinnee IInntteeggrrii ttyy MMaannaaggeemmeenntt PPrrooggrraamm ((IIMMPP)) AAsssseessssmmeenntt FFoorrmm aanndd GGuuiiddeell iinneess ((OOccttoobbeerr22000077)) 11

N.1 INTRODUCTION

This Pipeline Integrity Management Program Assessment Form has been developed to assist the AlbertaEnergy and Utilities Board (EUB) in performing assessments of pipeline integrity management programs(IMPs). The form follows the layout of Annex N in CSA Z662: Oil and Gas Pipeline Systems. Majorsections are numbered in accordance with Annex N, with the exception of Section N.2.

The key objectives of the assessment process are to

verify that the licensee has a documented pipeline IMP, verify that the licensee has identified and addressed the necessary components of a pipeline IMP in

relation to its specific pipeline system,

verify that the licensee has developed integrity plans and procedures in accordance with Annex N,and

document the results of the assessment to use in EUB field verification of the implementation of thepipeline IMP.

The sections within this form were directed by the topics outlined in Annex N. Using Annex N as areference would assist the person(s) filling out the form to achieve the best answer. Guidance is providedunder each question in the assessment form. This guidance is not intended to prescribe answers, and theanswers are not limited to the suggestions provided.

The licensees must identify the type of information and material necessary to fulfill the requirements ofAnnex N and address any deficiencies as part of the continual improvement of the licensees IMP. Thisassessment form should be used as a guide for the licensee to understand the types of information andmaterials needed to achieve the requirements. The EUB encourages the licensee to submit a completedEUB Pipeline Integrity Assessment Form if chosen by the EUB for an IMP assessment. This will allow theEUB to assess the IMPs of its licensees in a standardized manner.

For a successful program to be implemented, more than one person or one group within the companyneeds to be part of the assessment process. Any opportunity to have more than one person review or fillthis form would be the most effective in capturing the companys IMP.

In this form, company and operator are the licensee, and outside operator is a company operatingthe pipeline system(s) on behalf of the licensee.


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N.2 LICENSEE INFORMATION

Company or operator name

EUB business associate (BA)code

Head office address, phone andfax numbers

Name of primary contact(contact information should beadded to the list below)

Name(s) of person(s)completing form

Position incompany

Position inpipeline IMP

Contact information(address, telephone,fax, e-mail)

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N.3 DOCUMENTATION AND INFORMATION METHODS

This section describes the methods for collecting, documenting, and integrating information within theIMP.

QUESTION / Guidance Notes RESPONSE

How is the IMP documented?

A description of the document containingthe companys overall IMP.

How are the environmental protectionand public safety programs integratedinto your IMP?

A description of independent public safetyand environmental programs integratedinto your IMP.

Possible items to include in the answerare how environmental protection and

public safety are integrated into

- consequence and risk analysis

- operating procedures

- incident reporting

- change management proceduresHow are asset changes, such asdiscontinuation or abandonment of apipeline, contained in your integritymanagement documentation system?

A description of how asset changes are

integrated into your integrity managementdocumentation system.

Possible items to include are how assetchanges are integrated into

- consequence and risk analysis

- operating procedures

- change management procedures


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N.4 PIPELINE INTEGRITY MANAGEMENT PROGRAM SCOPE

This section provides general information that describes the companys pipeline system(s), includingwhere the pipeline information is maintained and documented. This section also includes a generaldescription of the unique aspects of the pipeline systems.


Provide a brief narrative of thecompany's pipeline system, describingthe capacity, purpose, substances,material, pipeline dimension, andcoating type and the physicalsurroundings along the pipeline route.

An overview of the pipeline system.

See CSA Z662, Annex B, Section B.5.2.2for possible items to include in theoverview answer.

What kind of system does your

company use to maintain pipelinesystem information, and where is thesystem located?

A description of the system used to keeppipeline system information and thelocation where the system is maintained.

Possible items to include in the answer:

- GIS-based system

- databases and spreadsheets

- maps and as-built information

- supervisory control and data acquisition(SCADA) system

- local or central offices where informationis maintained for the pipeline system

How and what unique aspects of thepipeline, such as age, location,substances, and past history, doesyour company include?

A general description of the uniqueaspects of the pipeline system that areconsidered when integrating into the IMP.A description of how the unique aspects

of the pipeline system are integrated intothe IMP.


- the pipeline(s), control valves, andsurface facility installations, if soequipped

- watercourses in proximity to the pipeline

- significant topographical features, suchas roadways and railways



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- the corporate boundaries of any city,town, or village in proximity

- any environmentally sensitive areas orspecial areas in proximity

- the physical and chemical properties ofthe substance transmitted

- consequence and risk analysis- operating procedures

- incident reporting

- change management procedures


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N.5 CORPORATE POLICIES, OBJECTIVES, AND ORGANIZATION

This section verifies that the company has set corporate policies and objectives for the pipeline IMP andthat there is corporate support for the program. To be effective, pipeline IMPs require a visible anddocumented commitment from senior management that outlines the companys responsibility to develop,implement, and maintain an adequate and effective pipeline IMP. The company must also identifypersons responsible for the pipeline IMP.


Describe your companys policies,objectives, and performance indicatorsfor its IMP.

The companys policy should describe aprogram, its purpose, and its objectivesand should contain a commitment to theprograms continual improvement.

The policy and objectives should include

- an appropriate purpose for an IMP

- a commitment to comply withrequirements

- a commitment to continual improvementof the IMP

- a framework for establishing a review ofthe objectives

- commitments that are communicatedand understood by the rest of thecompany

- measurable objectives established forrelevant functions and levels within the

organization

- objectives to be measured through thegoals described within the policy

- performance indicators, for example,failures reduced by what % in 2006

What are the most significantchallenges affecting the companysoverall performance associated withthe IMP?

Description of the company's challengesrelated to the IMP.


- unique workload issues

- staffing issues

- expertise challenges

- training challenges

- significant challenges with the conditionof the pipeline

- communication challenges



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- integrity management implementationissues

Who is responsible within yourcompany to communicate thefollowing:

a) pipeline IMP development andimprovement

b) records management

c) pipeline IMP planning and reporting

d) implementation of plans

e) integrity performance indicators

f) integrity program audits, reviews,and evaluations

A list of position and department titles thatare relevant to the integrity aspects listedin the question.

How are the people identified in thequestion above coordinating thecommunication throughout thecompany, including the groupsperforming the design, construction,operation, and maintenance of thepipeline?

This is a description of how the integritygroups communicate essentialinformation throughout the company.


- flow or organizational chart outlining

which individuals communicate withgroups on IMP

- communicating media, such as e-mail,conferences, meetings

- communication management plan;

- company-wide integrity status reporting,such as performance reviews andtrends

- company-wide notification system


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N.6 PIPELINE INTEGRITY MANAGEMENT PROGRAM RECORDS

Management of records is required to operate a pipeline IMP. This section verifies that the company hasprepared a method for managing the appropriate records related to pipeline design, construction,operations, and maintenance.


Describe what records are collectedregarding design, construction,operation, and maintenance.

Describe the types of records collected forthe administration of pipeline integrityactivities.

Consider including the items in CSA Z662and Section N.6.1.

How does your company managerecords for pipeline design,construction, operation, andmaintenance?

A description of the records systeminvolving the design, construction,operation, and maintenance aspects ofthe company, including how individualsaccess the system.


- pipeline system filing

- database systems

- field information collection system

- SCADA archiving operational historyHow does your company integraterecords that originate from anycontractors, outside operators, orpurchased assets?

A description of how third-party recordsare integrated into the correct recordsystem.


- procedures in integrating third-partydocuments

- contracts that establish the type ofinformation needed for the operatorsinformation system

- GIS and risk system access tothecompanys IMP records system

- integration system of operational reports



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Describe your document controlsystem for creating, updating,retaining, archiving, and retrievingrecords?

A description of the process andprocedures for creating, updating,retaining, archiving, and retrieving the

companys records.Examples of what could be included in arecords documentation system:

- archiving system for older records

- creation and implementation of recordtemplates

- timeline for initiating a record through toentering it into the companys recordsystem

- time periods for retaining records

- protection for record loss or damage- control of changes to record templates

- quality control on the informationcollected in a record

- record delivery to appropriate storageareas

- time period for retrieving records

- record availabilityDescribe your document controlsystem for creating, updating,retaining, archiving, and retrievingwritten procedures?

A description of the document controlsystem for written procedures.

Examples of what could be included in adocument control system:

- adequacy of record or document areapproved prior to issue

- records or documents are updated asnecessary and reapproved

- changes to the current revision status of

documents are identified- relevant versions of applicable records

or documents are available at points ofuse

- documents of external origin areidentified and distribution is controlled

- use of obsolete documents is preventedand ways to identify these documents, ifretained, are set out



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N.7 COMPETENCY AND TRAINING

This section verifies that the company has developed and implemented competency and trainingrequirements for company personnel, contractors, and consultants that are responsible for performing theelements (design, construction, and operations) of the pipeline IMP. It also verifies how documentation ofthese competencies are collected and maintained.


How does your company develop andimplement competency and trainingrequirements for

a) company personnel

This is a description of how the companydetermines when and what training isneeded for its employees.

Items to consider including in thedescription:

- training path for personneldevelopment

- review of personnel numbers,promotions and hires, transfers, andtraining schedules

- identification of covered tasks

- frequency of training classes based ondevelopment training plan

- frequency of training determined basedon a recertification, if within the

companys training plan- frequency of training determined based

on a requalification, if within thecompanys training plan

b) contractors

This is a description of how the companydetermines what training is needed for itscontractors.

Items to consider including in thedescription:

- requirements for qualification

- certifications

- performance evaluations

- safety requirements

- confirmation of performance in coveredtask

- current codes, standards, andregulations



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c) consultants

This is a description of how the companydetermines what training is needed for itsconsultants.

Items to consider including in the

description:

- requirements for qualification

- certifications

- performance evaluations

- safety requirements

- current codes, standards, andregulations

What methodology is used to evaluatethe knowledge and skills ofemployees, contractors, and

consultants?

A description of how the knowledge andskills of the employees are evaluated.

Items that could be considered in thedescription:

- qualification programs

- performance evaluations in coveredtasks

- certification programs, if stated in thecompanys training program, such asH2S Alive, CPR, Ground Disturbance

- lessons learned from failures

- examination in covered tasks

- practical assessments

- retesting intervals

- path to further improvement, if issuesin performance

Who is responsible for developing andimplementing training requirementsand training frequency?

A list of position titles and departmenttitles that is relevant to the training.

What methodology is used to verifythat the competency and trainingprograms are effective?

A description of how the trainingpersonnel determine whether thecompanys training programs are



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designed adequately to ensure that thetasks being performed on the pipeline aredone by competent employees.

Items that could be considered in thedescription:

- annual (or higher frequency) meetingson training development and needs

- review of training in relation to annualintegrity management review andimplementation

- review of training budget andresources for future

- evaluation of training programs againstcurrent codes, standards, andregulation

- analysis of total performance andassessments results

How is competency and trainingdocumentation collected andmaintained?

A description of the steps for tracking,collecting, and maintaining trainingrecords.

Possible items to include in thedescription:

- training records documentationprocedures

- training matrices- training personnel files

- internal training database system

- external training database system



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N.8 CHANGE MANAGEMENT

This section verifies that the company has developed and implemented a change management processand has developed procedures to identify and consider the impact of changes on the pipeline system(s).The process and procedures should include all technical and physical changes to the pipeline design,new construction operations, and maintenance.


How does your company monitor andanticipate changes within its pipelinesystem that might affect the integrityof the pipeline(s)?

A description of how the integrity of thepipeline is monitored and how changesare anticipated.

Possible items to consider including:

- SCADA

- results from inspection programs

- failure analysis and trending otherparts with similar attributes

- substance changes and the effects onpipeline materials

- deviation from integrity operating anddesign plan

- risk review

- how pipeline personnel recognize apotential natural hazard (e.g., training,

anticipating conditions, verifyinginspection results)

What does the change managementprocess consider?

A description of all possible scenarios forthe pipeline system that would initiate achange management.

Consider including the items in SectionN.8.1.What are the procedures forimplementing change management

throughout the company?

This should describe the procedures andsteps performed throughout the companyto implement a change management.

Possible items to consider including:

- change management proceduresmanual



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- change management groupresponsible for identifying andcommunicating with affected groups

- matrix outlining communication flowand responsibility

- a system for documenting andreporting change and the changeimplementation status

- corrective action systemHow do personnel know when changemanagement procedures must beinitiated?

A description of how a changemanagement is communicated to theaffected personnel to trigger theimplementation of the appropriateprocedures on the pipeline. A descriptionof how personnel can recognize a changeon the pipeline that should initiate achange management.

Suggested items to consider:

- e-mail update system

- initiate software system givingnotification

- deviation from normal operatingconditions

- communication changes to affected

parties- inspection and patrolling frequency

changes

- substance changes

- corrective actionsWhat changes to the design andoperation of the pipeline trigger thecompany to perform an engineeringassessment?

A description of the changes in designand operation of the pipeline that would

involve engineering assessments.


- substance change, with assessment ofpipeline material

- installation issues

- pressure issues

- tie-ins



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- acquisition of other pipelines

- hydrotesting results

- new integrity challenges

- class location changes

- activity near the pipeline

- deviation from the original design orconditions

- deviations from normal operatingconditions

How is the engineering assessmentintegrated into the changemanagement process?

A description of the engineeringassessment procedures that are initiatedthrough the change management

process.


- engineering review process

- status review meetings

- change controls and triggerscommunicated to areas affected



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N.9 FAILURE AND EXTERNAL INTERFERENCE INCIDENT INVESTIGATIONS

This section verifies that the company has developed effective procedures for investigating, reporting,and evaluating failures and external interference incidents. The company may wish to developprocedures specific to its pipeline system(s).


What procedures, includingdocumentation and communication,does your company have forinvestigating and reporting failuresand external interference incidents?

A description of the companys failure andexternal interference incident proceduresand how these procedures arecoordinated, from the initial failure orexternal interference incident to changesneeded to improve the effectiveness ofthe IMP.

Examples that could be used as a guidefor further description:

- communication procedures to report afailure and external interferenceincident

- failure and external interferenceincident record and documentationsystem

- failure and external interferenceincident investigation procedures;

- guidelines to reporting incidents topublic and regulatory bodies

- procedures for triggering analysis todetermine changes needed to improvethe pipeline IMP



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N.10 HAZARD IDENTIFICATION AND CONTROLS

This section verifies that the company has identified potential major hazards that could be a threat to thepipeline system(s).

QUESTION / Guidance Notes RESPONSEWhat are the major hazards to thepipeline system that your companyhas identified?

A description of the major hazards to thepipeline system or a pipeline segment thatyour company has identified.


- design issues regarding missinginformation, improper design andengineering, improper materialselection

- construction issues regarding missinginformation and improper constructionand inspection practices

- operator errors, including incorrectoperating procedures

- occurrence of failure and externalinterference incidents due toimperfections, such as corrosion,material, manufacturing, andconstruction

- environmental forces

- construction activity near the pipelineWhat methods are used to identifypotential major hazards?

A description of how potential majorhazards to the pipeline system areidentified. CSA Z662, Annex B, SectionB.5.2.3.2 could be used as a guide topossible methods of hazard identification.


- comparative methods

- structured methods

- methods that provide a logical pathwayto translate different release orinitiating events into possible outcomes

- information gathering, such asbrainstorming; interviewing; and



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strengths,weaknesses, opportunities,and threats analysis

- where records or information isincomplete, how potential hazards aredetermined



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N.11 RISK ASSESSMENT

This section verifies that the company has evaluated and reduced the risks to its pipeline system(s).


How does your company conduct arisk assessment?

A description of the companys methodand approach to performing a riskassessment of a pipeline segment orsystem.

This description could include how themeasures of risk are selected for the riskassessment and how the risk assessmentresults are validated. CSA Z662, Annex Bcould be used as a guide to possiblemethods of performing a risk assessment.

Additional suggestions that could be usedas a guide for further description:

- probability/impact risk rating matrix

- risk probability/impact scales

- data precision ranking

- interviewing

- sensitivity analysis

- decision tree analysis

- dynamic segmentation and analysis

- annual frequency and scale of releaseincidents

- likelihood of public harm per releaseincident

- potential extent of environmentaldamage per release incident

- validation of analysis by performingadditional observations and analysisabout the presence, location, andseverity of identified hazards orimperfections

- validation of analysis by performingadditional observations and analysis ofthe operating conditions

- a selection of a more rigorousapproach for the risk analysis andestimates based on high risk levels



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How does your company document therisk assessment?

A description of the documentation andrecords of the risk assessment.

What factors does your companyconsider in determining when toperform a risk reassessment of aspecific pipeline system or segment?

A description of changes to the pipelinesystem or discoveries that would trigger areassessment of the risk to the pipeline.


- changes in operational conditions

- failure and external interferenceincidents

- inspection results

- class change or populationencroachment

- pipeline upgrades

- an increase in perceived severity of theconsequences associated with aparticular hazardous event

How does the risk reassessment tieinto the change management process?

A description of the process ofcommunication those performing the riskreassessment use to initiate or respond toa change management.

The description might consider includingand expanding on the question listedbelow:

- How and what notification system isused to communicate a managementof change or risk reassessment?



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N.12 OPTIONS FOR HAZARD CONTROL AND RISK REDUCTION

This section verifies that the company has in place programs to eliminate or reduce the threats to thepipeline system(s) and reduce the potential consequences of the threats.

QUESTION / Guidance Notes RESPONSEWhat programs have been developedto reduce threats to the pipelinesystem, including threats of failureincidents, and to reduce theconsequence(s) identified from theanalysis of potential risks?

A description of additional programs orenhancements to existing programs toreduce threats to the pipeline system,including threats of failure incidents, andto reduce the potential consequences.


- external/internal corrosion program

- pigging program

- in-line inspection program

- repair program

- additional inspection and maintenanceprograms

- damage prevention program

- public awareness program

- training program- emergency response planningProvide in detail an example of aprogram developed to reduce threatsin the following:

a) design

b) construction

c) operations and maintenance

d) natural hazards

Provide sample details ofconsequence reduction.



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N.13 PIPELINE INTEGRITY MANAGEMENT PROGRAM PLANNINGThis section verifies that the company has a management program that includes the planning andscheduling of integrity management activities and a review of the results of such activities. The pipelineIMP should also include pipeline design and construction.

QUESTION / Guidance Notes RESPONSEHow are the integrity managementactivities determined and how isscheduling of various activitiestabulated, presented, and tracked?

A description of the program planning andscheduling of integrity activities. Thefollowing are suggested examples thatcould be used as a guide.

Tabulated:

- results from inspections triggered byhazard analysis

- analyzed inspection results ofdiscovered imperfections or pipelineintegrity issues and assigned severityof risk

- results from failures and externalinterference incidents of the operatingcompany and in the pipeline industryas a whole

Scheduled:

- inspection based on severity ofdiscovered imperfections or pipeline

integrity issue

- inspection frequency determined by theseverity of the risk to the pipelinebased on hazard analysis and thecertainty of the risk assessment

- inspections incorporated into otheroperational program schedules

- based on the evaluation of knownconditions, damage, or imperfections

Presented and Tracked:

- Excel spreadsheets- operational calendars

- operational binders containinginformation on what was performed onthe pipeline

- internal database system with accessfrom assigned personnel

- tracked by assigned personnel



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What steps are taken for consultingwith and informing appropriatepersonnel about activities that dealwith integrity issues and programs?

A description could cover

- reporting procedures being practisedby pipeline personnel performingprograms on the pipeline

- communication plan for integratinggathered integrity information intointegrity management system

- standard minimum integrity-relateddata to be collected during allprograms

- training personnel to recognize anintegrity issue while performingactivities on the pipeline (abnormaloperating conditions)

How does your company review andverify that the integrity managementactivities were effectively completed?

A description of how the company reviewsand verifies that the integrity plan wasproperly performed.

Consider including the items in SectionN.13.4.



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N.14 INSPECTIONS, TESTING, PATROLS, AND MONITORING

This section verifies that the company has developed documented procedures and established timing andfrequency intervals for monitoring and inspecting the pipeline(s).

QUESTION / Guidance Notes RESPONSEWhat documented methods andprocedures for conducting inspection,testing, patrols, and monitoringpipeline(s) are in place?

See the requirements in CSA Z662,Annex N, Clauses 9 and 10, and N.14.



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N.15 EVALUATION OF INSPECTION, TESTING, PATROL, AND MONITORING RESULTS

This section verifies that the company has documented methods to evaluate the results of the inspection,testing, patrol, and monitoring of the pipeline(s) and has processes in place to take the necessary actionsto address indications or imperfections that may lead to a pipeline failure.


How is the condition of the pipelineevaluated using engineeringassessment methods to determinewhether indications or imperfectionscould lead to failure and how are thecorrective actions developed?

A description of the method used todetermine whether indications orimperfections are injurious or noninjuriousto the pipeline using the engineeringassessment process. This question alsoincludes how the engineering assessmentresults are used to develop correctiveactions.

The description might include and expandon the questions listed below:

- How do inspection results trigger anevaluation of the condition of thepipeline?

- What methods are used to collect dataon an indication or imperfection?

- What engineering evaluation methods

are used (e.g., B31G; DNV-RP-F101;API 1102; CSA Z662, Clauses 4 and10.8)?

- How and when are corrective actionprocedures initiated by the operatingcompany as a result of the engineeringassessment?

If natural hazards are present, whatprograms are in place to monitor thecondition of the pipeline?

A description of the process involved in

monitoring for natural hazards, if present.The description might include and expandon the questions listed below:

- What types of inspections and patrolsare performed?

- What types of monitoring programs forslope movement are used?



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N.16 MITIGATION AND REPAIR

This section verifies that the company has developed and documented corrective actions to mitigate andrepair anticipated conditions or imperfections in the pipeline that could cause a failure with significantconsequence.


What types of corrective actions are inplace for anticipated conditions orimperfections that could cause afailure incident?

A description of the corrective actionprocedures developed by the engineer forknown or anticipated conditions orimperfections in order to perform themitigation and repair on the pipeline.

Items to consider include

- corrective actions designed andavailable to pipeline personnel asstandard procedures if discovery ofpipeline integrity threat

- adjustments to the operatingparameters of the pipeline

- repair procedures, such as grinding,pressure containment sleeve, orreinforcement containment sleeve

- pipe replacement programsHow are the mitigation and repairs onthe pipeline documented and madeavailable to the appropriate personnel?

A description of the repair reports thatmay be put into an internal system that isavailable to personnel responsible forpipeline integrity.



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N.17 PIPELINE INTEGRITY MANAGEMENT PROGRAM REVIEW AND EVALUATION

This section verifies that the company has developed a review and evaluation process to determine theeffectiveness of its pipeline integrity management program.


How does your company performreviews, and evaluations to determinethe effectiveness of the pipeline IMP?

A description of what methods andprocedures are implemented whenperforming a review of the IMP and theprocess used to evaluate whether the IMPis effective by determining the successesand failures within the program.


- How is the accuracy of the programevaluated?

- When are the IMP reviews conducted?

- How are the planned activitiesevaluated in accordance with the plansand procedures?

- What is involved in the auditingprocess?

- How are corrective actions identifiedand implemented?

- How are nonconformances identified ina timely manner?

- How were the recommendations fromthe previous IMP review and evaluationaddressed?

- What is involved in undertaking aperformance review of themanagement system for the IMP?

- What is the companys continualimprovement process?

How does your company select areaswithin the pipeline integritymanagement program for a review andevaluation of effectiveness?

A description of when reviews should beperformed on a pipeline system and thecriteria used to select the system. Thedescription should include the rationaleand method for choosing a pipelinesystem as a relevant sample to verify theeffectiveness of the IMP.



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The items below could be used as a guidein describing how a pipeline system ischosen for a review and evaluation:

- a process for identifying a pipelinesystem as a sample of the IMP

- an examination of the previous IMPprompting an audit

- an assessment of significant change inthe operating condition of a pipelinesystem

- an analysis of performance indicators

- an analysis of potential occurrence ofexternal interferences and failuresincidents

- an analysis of recent failuressuggesting an IMP audit on a particularpipeline system

How are the results of the review andevaluation of the IMP documented?

A description of what is documentedduring the review and evaluation.

The items below could be used as a guidefor describing what is included in thereview and evaluation documentation:

- integrity management policy andprogram

- record of responsible individuals in the

IMP

- all required IMP activities

- all corrective action items and majorand minor nonconformances

- risk criteria used

- record of the risk results andimplications

- audit results

- IMP review results

How are the results of the reviews andevaluations integrated into thecontinual improvement of the IMP?

A description on how the IMP is updatedbased on the results of the reviews andevaluations to increase the effectivenessof the program.




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- How are the corrective and preventiveactions used in the managementreview?

- How are the companys policies andprocedures adapted to the findings of

the review?- What would constitute a change in the

companys objectives based on thefindings?



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N.18 COMPANY MANAGEMENT RESPONSE

This completed form confirms that [Company] meets the requirements of CSA Z662,Annex N:

Pipeline Integrity Management Program.

[Company] does not meet requirements of CSA Z662, Annex N: Pipeline Integrity Management

Program.

Name (Print): Title:

Signature: Date:

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