Docstoc

Iam often asked and retained to assist

Document Sample
Iam often asked and retained to assist Powered By Docstoc
					REGULATIONS
                                     By David Stainrod,
                                     D.J. Stainrod and Associates

                                     David Stainrod has been providing technical fuel and inves-
                                     tigative consultation to governments on both sides of the 49th
                                     parallel. He is in charge of the PGAC’s technical hotline for
                                                                                                      ate clothing and safety gear for the areas of the
                                     members, has written several P•T•I training courses, and sits    storage/transfer facility to be visited.
                                     on many industry committees on behalf of the PGAC and its             Unannounced audits should be handled
                                     members. If you have any questions, please contact David at      in the same manner as scheduled audits.
                                     david.stainrod@sympatico.ca.                                     Once the inspector arrives and makes his/her
                                                                                                      intentions known, ask the inspector to wait a
                                                                                                      few moments while you begin the necessary

NAVIGATING TECHNICAL AUDITS                                                                           arrangements to accommodate the request.
                                                                                                           Finally, document the experience. Staff
                                                                                                      members that interact with the inspector


I
     am often asked and retained to assist        both parties. First contact is also a good time     should keep notes on non compliances found,
     propane companies in dealing with the        to ask the inspector if customer site inspec-       recommendations, and comments made by the
     results of government technical audits by    tions will be part of the audit. If so, agree on    inspector with respect to the audit findings.
the Authority Having Jurisdiction (AHJ). In       the number of inspections to be conducted in             At the end of the audit the inspector may
the propane industry, there are many AHJs         advance, to allow an opportunity to set up the      issue orders to have non compliant items
with which we interact, whether it is on the      appointments with the customers for the day         brought into compliance. It is my recom-
administrative, financial or technical side of    the inspector will be at your facility.             mendation that you ask for all orders to be
the business.                                          Customer site visits must be presched-         written; do not accept verbal orders. Verbal
    The ones we interact with most com-           uled with the customer. Have a staff member         orders are easily misinterpreted or forgotten
monly are the provincial AHJ that enforce         call the customer, explain the purpose of the       and provide no record for reference.
the Acts, Regulations and Codes under which       proposed visit, and obtain the customer’s per-           While AHJs are acting in the name of pub-
residential, commercial and industrial pro-       mission for the inspection. As a courtesy to        lic safety, it is important that you are aware
pane installations are installed.                 your customer, one company person and the           of your rights under the Act and Regulations
                                                  inspector should be the only people attending       under which the AHJs operate. All Acts and
Provincial AHJs play an important role in         customer site visits. It is very intimidating to    Regulations have provisions for appealing an
maintaining public safety. Depending on           a customer to have three or four people turn-       order or fees charged for an audit. If you do
where you live, AHJs require that:                ing up at their door and entering their home.       not agree with an order, or find that an order
• as a propane technician, you are certified           Secondly, resource the audit appropri-         or the fees charged are inappropriate, then
  to perform propane systems and appliances       ately with staff who are knowledgeable. For         you should appeal the order in writing to the
  installations;                                  example, an office administrator could handle       person designated in the Act.
• permits are taken out for propane installa-     requests to see vehicle files, customer files,           If an order is appropriate, then it is in
  tions you are installing;                       etc., and a plant person can accompany the          your best interest to address the non compli-
• your company is registered with the AHJ as      inspector around the storage/transfer facility.     ance as quickly as possible and comply with
  a contractor to install propane systems and     It is not necessary to have a senior manager or     the order.
  equipment;                                      propane technician accompany the inspector.              If you do not exercise your right to an
• propane installations comply with the rel-      Remember, the AHJ understands you have a            appeal when you believe an order or fee is
  evant regulations and codes;                    business to run, so there are ways to accom-        inappropriate, then the AHJ has no way of
• propane delivery vehicles are licensed; and     modate an audit by the AHJ with minimal             knowing your dissatisfaction with the work of
• storage/transfer facilities are licensed to     disruption to on-going business.                    its inspectors. The appeal process is industry’s
  operate.                                             When it comes to customer files, staff         way of providing the AHJ with an appraisal of
                                                  members must be aware of the fact that the          the inspectors’ work.
To fulfill their mandate, provincial AHJs         file may contain financial and personal infor-           It is the nature of an audit process to nar-
appoint inspectors to conduct field audits to     mation that your company must keep confi-           row in on the negative – the non-compliance
ensure that Act, Regulation and Code require-     dential. Ensure the staff member assisting the      – as that is what needs to be identified and
ments are being met, and that the necessary       inspector pulls files and provides the inspec-      fixed at the end of the day. The unfortunate
permits and licenses are in place.                tor with only the specific documents request-       result is that the process does little to high-
    My advice to propane companies, when          ed from the file. The inspector will normally       light or acknowledge the countless compli-
contacted by AHJ inspectors to conduct an         ask to see records of inspections and work          ant items that are apparent throughout your
audit, is to follow a few simple principles in    performed. Keep a record of all documents           business. It takes very few negative transgres-
order to make the most of the process with        that an inspector requests to keep. Do not          sions to erase a world of good, making it easy
the least disturbance to the business, and        give original documents; provide the inspec-        for an audit to end in a poor impression of a
especially to your customers.                     tor with photocopies.                               company’s performance.
    First of all, be prepared. A good start is         Thirdly, when the inspector arrives on-             However, an audit, if conducted properly,
to ask the inspector to specify precisely what    site, ensure they follow all of your company’s      can provide valuable information on the well-
the audit will involve and the time expected to   safety procedures while on company property.        ness of a company’s facilities and operational
complete the audit. If the timing of the audit    For example, have the inspector sign the guest      conduct – to both the AHJ and the company.
requested by the inspector conflicts with your    book, explain the facilities’ emergency evacua-     It is to everyone’s benefit to look for the posi-
business schedule, then request that the audit    tion procedures and designated meeting place,       tive in the experience, and capitalize on what
be scheduled at another time that works for       and ensure the inspector wears the appropri-        is revealed through the process.
8                                                                                                         PROPANE/CANADA - September-October, 2007

				
DOCUMENT INFO