COMPLIANCE SERVICES – AUDITS AND TRAINING
Heath Services offers a suite of professional services to support companies in achieving compliance with gas legislation, including the auditing of gas assets in the field and the building of documentation to allow auditing of equipment and assets, provide equipment traceability and to demonstrate compliance with legislative requirements.
We offer analysis of current asset management systems and documentation to identify areas of non-compliance. We suggest improvements for systems and assist in building system infrastructure enabling attainment of full compliance, complete with plans and timelines.
Compliance Services offered by Heath Services include:
- Compliance Inspection
- Gap Analysis
- Risk Assessment
- Safety Management Systems
COMPLIANCE INSPECTION SERVICES
Compliance Inspection Services are designed to ensure that the client is fully aware of the areas in which they may be failing to meet enforced legislative requirements for the processing, storage, transport and distribution of fuel gas.
Many gas production and/or gas consuming sites are built over a number of years/phases and over this time, records and data can be misplaced or not maintained appropriately. The purpose of a Compliance Inspection is to establish a baseline of assets, what is on your site and relevant conditions and a gap analysis of required documentation.
A core element of our Compliance Inspection Service is to audit the equipment/assets on site to check their compliance with relevant standards. Equipment might include: well heads, metering skids, gas fired devices using more than 50GJ/hr, gas flares and others. This work is detailed and involves the collection of asset data such as; serial numbers, manufacturers details, model number, test criteria of model, heat batch numbers, P&IDs and approvals (materials and equipment).
We do this to ensure the traceability of your assets over time. The information gathered is included in a database that can be updated. Should any equipment be replaced or repaired, this data can be added to the record and be accessible for any future audits.
We can use this data to ensure that equipment is within its test date for items such as PSVs, schedule maintenance and build a matrix of the assets on site that details overarching compliance requirements, identifies any compliance gaps. We use this information to develop strategies to achieve compliance.
A forward-looking plan on how to achieve compliance, including what testing is due and when, forms part of the deliverables for a full Compliance Inspection. This plan can then be integrated into ongoing routine maintenance works and can provide a compliance achievement plan for any inspection authority.
GAP ANALYSIS CONSULTING
The Gap Analysis is a document, procedure and process audit. While this is often called an Audit, it should not be confused with the asset Audit.
Its purpose is to identify existing documents and procedures and assess them against the mandatory requirements of the SMS or SAOP requirements.
The audit will also identify any missing materials that would be required to be compliant with both the Petroleum and Gas (Production and Safety) Act 2004 and AS4645.1:2008 and the requirements of the Formal Risk Assessment and the SMS/SAOP criteria.
This work is a desk-based activity and requires detailed and thorough document reviews and organisation of paperwork to support compliance inspection and testing, to ensure all mandatory support documents are in place.
Upon Gap Analysis completion we will have clearly identified what current documents we have to build the SMS or SAOP from and what paperwork, procedures and systems are missing or need amendment to meet the requirements of the SMS or SAOP.
The deliverable from the Gap Analysis will provide the client with a detailed plan of paperwork that exists, is missing, is in need of update, review and approval or needs to be fully implemented.
RISK ASSESSMENTS
Heath Pipeline Services offer Formal Risk Assessments for Operating Plants.
Formal Risk Assessments of Operating Plant and facilities can be completed either as part of development of Safety Management Systems or for other safety related functions is a mandatory requirement for most facilities.
The requirement is outlined in the Petroleum and Gas (Production and Safety) Act 2004 for Queensland (in section 675(1)(e)) and is also called for in AS/NZS 4645.1:2008 in section 2.3.1 where it calls for a formal safety assessment.
The purpose of the formal safety assessment is to identify hazards, determine the threats from these hazards, assess the risk of these threats and determine the level of control required to meet the acceptable risk level.
Where a risk is above the acceptable risk level, controls shall be established to reduce that risk to at least the acceptable level using the hierarchy of effectiveness of controls –
(a) elimination;
(b) physical controls;
(c) procedural controls;
(d) reduction; and
(e) mitigation.
The hazards identified on site, from this work, are formally documented and this becomes the site Hazard Register as required in section 675(1)(e) of the Petroleum and Gas (Production and Safety) Act 2004 and in section 2.3.2 of AS/NZS 4645.1:2008 where the requirement is to identify hazards related to the gas distribution network and these must be “formally identified”.
To meet compliance with AS4645.1:2008 this Formal Risk Assessment must be reviewed every 5 years or after any design change or “substantive” change to the operating environment. As part of this review the previous risk assessment needs to be verified for its validity and a review of any hazards or incidents that have occurred since the last review.
Our Risk Assessors are fully qualified and experienced in the gas industry. We have undertaken risk assessments of Natural Gas, LNG and LPG facilities and operations across Australia.
SAFETY MANAGEMENT SYSTEMS
The development of Safety Management Systems (SMS) as described by the Petroleum and Gas (Production and Safety) Act 2004 and/or AS4645.1:2008 requires experience and HPS consultants have more than 10 years of building these types of framework documents.
The document is a mandatory requirement for any facility with Operating Plant or if the gas consumption is above 50GJ/hr.
Operating Plant as defined in the Petroleum and Gas (Production and Safety) Act 2004 can include distribution networks (embedded networks) so this would include facilities that individually meter tenants on their facilities for gas consumption and bill for this usage directly.
Under AS4645.1:2008 the requirements are very similar to the Petroleum and Gas (Production and Safety) Act 2004, where a Safety and Operating Plant (SAOP) is required. In Queensland the management and implementation of the Safety Management System falls to three mandatory posts; Executive Safety Manager (ESM) – the most senior representative of the company, the Operator – a person appointed by the ESM, Site Safety Manager (SSM) – appointed by the Operator and responsible for the day to day application of the SMS.
The appointment of the posts of Operator and Site Safety Manager should be an “appropriately qualified person” and the responsibilities of the SSM fall back on the Operator in their absence.
This typically means the SSM and Operator need to be formally trained in the responsibilities of the role and the requirements of the site to be compliant with the SMS. HPS can provide this training either on site or off site to ensure that the appointed staff meet the requirements of being “appropriately qualified”.
The SMS itself is a framework document that details the documents, procedures and other systems that control safety on site for employees and contractors with respect of the gas assets and their associated risks on site. These documents and procedures are not created as part of the SMS but drawn from existing policies and procedures that should already exist on site.
Where such documents do not exist, they can be developed by HPS but this typically is outside the scope of the SMS works.
