Common Sense Approach to NERC CMEP
If you were asked today about a significant day in the past, would you be able to provide evidence of important operating practices from that day? Would you be able to produce evidence that important operating steps were taken?
We often encounter staff responsible for various parts of bulk power systems – power plants, electric systems, etc. Every day, NERC compliance and their ability to produce compliance evidence when audited are at the forefront of their minds. As we discuss their operating concerns, discussions can get into the weeds quickly, with people focused on a lot of low-level details that can cause analysis paralysis. If you step back from the challenges a bit, you can see that common sense can go a long way to improving an operation and laying a foundation for compliance. Here’s what we mean.
NERC is the North American Electric Reliability Corporation. It is the electric reliability organization (ERO) for North America, subject to oversight by the Federal Energy Regulatory Commission (FERC) and governmental authorities in Canada. NERC’s jurisdiction includes users, owners, and operators of the bulk power system, which serves more than 334 million people. That’s a pretty serious oversight responsibility.
NERC continually produces Rules of Procedure that are intended to ensure the safe and reliable operation of the Bulk Electric System (BES). Operators of the BES must stay up-to-date on these operating standards. Further, they must not only be following these operating procedures, they must be ready to show evidence that they are following these procedures, when audited.
Complying is a tough task involving a lot of details. However, NERC compliance is all about responsible operation. That core need is the same regardless of whether an entity is part of the BES or not. Material operations of all kinds face serious risks – risks to employee and public safety and certainly business/financial risks. If you take a step back, you will recognize that whatever your operating standards may be, you need to implement a strategy for complying with those standards, or at least a strategy for how you will provide evidence of compliance. The strategy should provide assurance that things that should and must be done are done, and the strategy should ensure that there’s solid evidence to prove it.
So, the bottom line is that any material operation that’s run by people needs a solid approach to documenting operating practices. The documentation should provide a chronology that contains the evidence of material operating conditions and actions taken throughout the business’ operating lifecycle.
If you were asked today about a significant day in the past, would you be able to provide evidence of important operating practices from that day? Would you be able to produce evidence that important operating steps were taken? Evidence that necessary inspections were performed in a timely manner? Evidence as to who was on shift? Evidence as to who was visiting the facility – potentially with photo identification? Evidence of observations either within or outside of expected normal operating ranges? Evidence that operators communicated important operating conditions one to another during shift turnover? Can you prove it? Would your evidence withstand auditing scrutiny? Can you prove the records are true and not manipulated?
Not that we’re wishing it on anyone, but let’s say something terrible happens, because sometimes bad things happen to even the best, most responsible people. If something bad happens, how can you prove that it wasn’t due to operational negligence?
It’s sometimes said that the best defense is a good offense. This is where laying a foundational practice of logging all material conditions and activities is something that can be your offense – your proactive step to ensuring that bad things don’t get blamed on good people. You need a good logbook that ensures that your operating records have integrity and that ensures that they are stored safely and cannot be falsified. You need logging system that is easy to use so that operators aren’t over burdened by their need to both operate and document their actions. You need a system that provides shift turnover procedures that ensure business continuity and that prove that operators communicate important details between shifts. You need a system that can keep track of visitors to your facility, and it should all be secure, easy to use and customizable to your specific needs.
With a logging system in place, you can use it as the foundation of your compliance plan. As you implement mandated operating practices you can have a standard practice of documenting your activities in your logbook. You will know where your evidence lies. It will be searchable, protected and will be ready when you need it to defend your good practices or reveal the weaknesses therein.
The bottom line is that NERC, as well as other governing organizations, is not trying to harm its constituents – it’s quite the contrary. When you take responsible steps to show that you are operating the way you should, it will go a long way to avoiding penalties and fines when audited. Let’s say something bad does happen. Let’s further say that some operating crisis causes something to not be done. Or let’s say that someone simply screws up. Humans make mistakes. Your best defense is being able to show that you regularly and repeatedly do your best to operate responsibly, following mandated practices. When the time comes, you will fair much better with mounds of documentation at the ready that demonstrates your effort than those who cannot quickly show the same. Not only that, improved communications is likely to help avoid mistakes, as well.
So, do sweat the details, but consider how adopting a standard electronic logbook might be the first thing you do as you consider all the operating practices and documentation you need to accumulate and retain. That first, common sense step will set you up for long-term success, as you begin and continue to add to its content.
There’s a frequent Nurtisystem commercial on TV that says “you eat the food; you lose the weight; it’s not that hard.” With a good logging strategy, “you log the activity; you prove compliance; it’s not that hard.”
See what the entire suite of LogBook products can do for you today. Adoption can be quick and easy. Reach out to us. We’d love to help.