By Richard Schlottman, NERC Reliability Specialist
All too often the effort required to maintain an effective NERC compliance program at the plant level may be time consuming and burdensome once combined with numerous other high priorities. Why is that so? As with any regulatory compliance program, how it is designed, implemented and used plays a big part in how successful it will be. Transparency in this case not only means being clear, concise or easily understandable, but also refers to how the program is incorporated into a plant’s operating philosophy, culture and staff participation.
The seamless integration of compliance programs into daily plant operations is something generally found in those facilities that have high reliability and availability and experience few if any environmental violations or reportable safety incidents. A culture of compliance is strong in these facilities and compliance is not viewed as an overwhelming burden. So why is it that NERC compliance may be viewed as such a struggle for some organizations? There may be more than a few factors why this is the case:
- Compliance from a distance: programs may be administered at the corporate level, and pushed down to the plant.
- Unclear procedures: procedures may be written by personnel that are unfamiliar with how plants operate and the primary duties of plant staff.
- Too many tracking tools: multiple compliance trackers may create confusion for personnel.
- Training programs: training may fail to meet the specific needs of plant staff, is too generic in nature, or is not effective to support day-to-day operations.
How then can transparency in NERC compliance programs be achieved? Here are some solutions that have been implemented at high-performing facilities that lead to transparency in compliance and support a robust culture of compliance:
- Local Compliance: ensure all compliance is owned by the plant, that each person is made aware of and included in all compliance activities. All plant personnel are accountable stakeholders and must understand how important their contributions are to successful compliance with regulatory requirements.
- Procedures: a facility’s procedures must be site specific, and clearly written in a concise and useful manner. Provide examples of how compliance can be achieved as well as examples of non-compliance (screen shots, trends, pictures, drawings and flow diagrams can help).
- Single program for compliance tracking: using the plant CMMS (or equivalent system) to track all compliance measures and activities is key. Creating work orders to track all critical tasks is crucial for maintaining compliance. The plant manager should be the only person permitted to close compliance-related work orders as (s)he is ultimately responsible for maintaining compliance.
- Training: conduct training that is specific to the plant, developed for relevant personnel skill levels, and clearly designed to enhance compliance through operating practices. Ensure trainers can convey the information clearly, concisely and in a timely manner.
To summarize, you can have a NERC compliance program that is transparent if designed, implemented and embraced by plant staff. It must align with how the plant conducts business daily and be highly visible to those accountable to the NERC Standards. When considering how to do this, managers should obtain the participation from their key stakeholders, as they will have good ideas of what can be done to ensure compliance and build the culture of compliance that is critical to the success of the plant.