A strong EPAP program needs to be auditable. Subject to the same words that Ronald Reagan said during the cold war “trust but verify.”
Audit regulation, as with many other forms of regulation, consists of five general elements: the setting of standards, their formal adoption, their implementation in practice, the monitoring of compliance, and enforcement procedures.
Questioning the survival of an audit
Many EPAP evaluations are a box-checking exercise, at best a series of interviews and at worst just taking 30 minutes to submit a declaration into Petrinex.
Ask questions like:
- “What evidence exists that supports your respective controls are or are not functioning as designed?”
- “Is all this data historicized and available upon request if asked to produce it by the regulator (either the AER or MER)?”
- “Is the evaluation methodology clearly outlined?”
- “How was the sample set determined and who chose it?”
- “What is the industry experience of the auditor?
Formal Remediation Strategy
EPAP has been in place for over ten years in Alberta now and many operators still do not have a formal remediation strategy that is auditable. Not implementing a formal remediation plan if one or more controls are deficient, is a noncompliance (Both section 5 and NCE number 969 in Alberta point to this, along with section 5 of PNG076 in Saskatchewan).
If history indicates, an operator who does have a remediation strategy, is likely only embedded in someone’s mind, and not formally documented for audit. Blue Chip MRC is not a policing mechanism; rather we are here to assist companies with remediation, regulation, reporting, and related issues. As new laws and regulatory bodies continue to spread quickly throughout our industry and culture; we don’t have to agree with it or the politics behind some of it, but we can help you navigate it affordably, correctly, and in some situations, safeguarding you and your approaches from more scrutiny and penalties of an audit.
Blue Chip has interfaced with many compliance auditors at both the AER and MER and we understand what they are looking for. We can ensure that your EPAP evaluation and remediation plan are auditable and will survive that regulatory audit. It is not a question of if, but rather when someone will ask for it. Reach out and let us get into it with you. We genuinely want to help!
If you need help or direction to make sure your measurement and reporting practices are equitable and compliant, we can help you do it right. If you’re interested in learning more on this topic, with additional questions or discussions, please send me an email waynedunnington@bluechipmrc.com.
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Until next time…
