by MCS Site Admin | Aug 24, 2020
Regulatory compliance has become a main stay in the business world as a way to institute adherence to common laws, regulations, and guidelines/specifications to business processes. Violations to these regulatory compliances often result in legal punishment. Regulatory compliance can be maintained in such areas as the following: Integrity Management Public Awareness Operator Qualification Operations and Maintenance Cyber Security Safety Control Room With regulatory compliance being incorporated into every part of business, companies are being faced with how to manage staying in compliance while maintaining business demands. A. Miller Consulting Services, Inc. (MCS) helps companies successfully manage regulatory compliance through the following areas: Gap Analysis/Recommendations Plan/Process Updates Records Management Audit Preparations Gap Analysis/Recommendations Performing a gap analysis between the existing documents (e.g., processes/plans, records, etc.) and the current regulatory question set allows MCS to identify existing gaps. MCS uses those gaps to create recommendations and action items to help the company identify areas where they can increase compliance and program effectiveness. Plan/Process Updates MCS uses recommendations and action items to help the company update its plans with the appropriate verbiage and update/add missing procedures/forms. MCS ensures that these updates are clear and concise. Records Management Regulatory compliance requires maintaining good records that are easily accessible and organized. MCS helps clients perform the following: Creates record books that are either electronic or are in hard copy. Makes sure the records are traceable, verifiable, and complete. Performs follow-ups for records that need missing or corrected information. Helps document inconsistencies. Audit Preparations Alexander Graham Bell said, “Before anything else, preparation is the key to success.” Allowing MCS to run a mock audit is the best way to ensure preparedness. Mock audits allow the following: Limits the risk and allows the company to identify and correct any problems before the audit begins. Enhances current policy and procedures for optimal performance. Ensures accessibility of records. Provides time to document any irregularities in program’s data and how the situation is being resolved. Prepares compliance personnel. Once the mock audit has been completed, MCS provides recommendations of what the company needs to address before the official audit. Conclusion MCS is committed to providing companies with its regulatory compliance expertise and services. Contact MCS Website: https://mcs.biz/ Email: mcs@mcs.biz Phone: 972-580-0812
by MCS Site Admin | Jul 15, 2020
So, you thought you were done with English when you left college, but now you have to maintain manuals, create reports, and maintain records for governing regulatory agencies? Or, your company has given you a set of procedural manuals from the company that it just acquired, and these procedural manuals need to be integrated into your company’s procedural manuals. How are you supposed to accomplish all of these tasks on top of the ones that you normally do? Technical writers are the answer for all of your documentation needs. They can help you create/maintain manuals and reports. They can also help you map information and then consolidate the information into new combined manuals. Style Good documentation needs to have a clear definition of the audience. However, the challenge of many documents today is that they need to be written for several audiences. The text needs to be written using the simplest and most direct language without the use of jargon or slang. Whether working with one subject matter expert (SME) or several SMEs, technical writers must adapt to ensure that the tone of the document sounds as if one person wrote the entire document all the way through. Where possible, the text should include diagrams or schematics that support the text. These graphics should be clearly referenced and captioned. Types Engineers are often tasked with writing a variety of technical documents such as the following: Procedures Specifications Reports Manuals Records Forms Presentations Invitations to Tenders Proposals Policies MCS’s technical writers are adept at helping your engineers or other employees to bring clarity to this text and ensure that it effectively communicates the technical details to the audience. Consolidation The task of combining multiple sets of procedures or documents can be a daunting task for some. The question for some is where to start. The first task is for the parties to agree upon a format and style guide for the new documents. Then, the technical writer can begin the task of mapping like content. Once the content is mapped, the new procedures can be created using the former documents. SMEs can review any remaining information that did not fit into the mapped sections and determine where the missing information needs to go. MCS’s technical writers ensure the final products are concise, consistent procedures that reflect the current company’s standards. Review Documents, especially regulatory ones, typically need to go through a review cycle. This review cycle can follow the process of first draft, revised draft, and final version. This review process allows for document improvement and project updates to be added. Updates should be documented in a Revision Log. Conclusion MCS is committed to helping companies with their documentation needs. MCS’s technical writers will produce quality documentation while freeing your engineers and other employees to continue to do their work. Contact MCS Website: https://mcs.biz/ Email: mcs@mcs.biz Phone: 972-580-0812
by MCS Site Admin | Jun 30, 2020
Operating a successful Control Room can be daunting. It begins with understanding the requirements of 49 CFR 192.631 and 49 CFR 195.446 and ensuring that Control Room personnel remain alert and have access to monitoring equipment that allows them to minimize safety risks and economic losses. Operators use the following nine elements to provide a successful Control Room and maintain safe operations of the pipeline. Roles and Responsibilities Operators must clearly define roles and responsibilities of their Control Room personnel, especially for the following: Normal operations Abnormal operations Emergency operations Shift Handover procedures Qualifications of personnel who can direct or supersede the authority of the controllers Adequate Information Operators must create and provide the tools, procedures, and processes necessary for Control Room personnel to have the following types of adequate information: Industry best practices Implementation of API RP 1165 whenever SCADA is added, expanded, or replaced Point-to-point verification SCADA system tests Internal communication plan testing and verification Backup SCADA testing procedures Fatigue Management Operators implement the following methods to reduce the risk of Controller fatigue: Establish shift lengths and schedule rotations to provide off-duty Controllers sufficient time to achieve 8 hours of continuous sleep. Educate Controllers and Supervisors in fatigue mitigation strategies and how off-duty activities contribute to fatigue. Train Control Room personnel to recognize fatigue. Establish a maximum limit on Controllers’ hours of service. Advanced Alarm Management Operators must maintain a strong Alarm Management Program. This program must provide tools to consistently and effectively help the Controllers with the safe operations of the pipeline. Operators must consider the following for the Alarm Management Plan: Review SCADA safety-related alarm operations Identify at least once a calendar month points affecting safety that have been taken off scan in SCADA, inhibited alarms, false alarms, and forced or manual values Verify the correct safety-related set point values and descriptions Review the Alarm Management Plan at intervals not to exceed 15 months Address deficiencies identified through the implementation of plan Change Management Operators must evaluate, manage, and implement changes to operating practices for all Company assets. It must also establish communications between Control Room personnel, management, SCADA support, and field personnel when planning to implement physical changes to pipeline equipment. Operating Experience Operators must ensure that they review incidents/accidents to determine if the Control Room contributed to the event and correct, where necessary, deficiencies related to the following: Controller fatigue Field equipment Operation of any device Procedures SCADA system configuration SCADA system performance Control Rooms must also include lessons learned from the Company’s experiences and implement these into the training program. Training Control Room training must review the training content to identify potential improvements at least once every calendar year. Training must incorporate the following: Response to Abnormal Operating Conditions (AOCs) that occur simultaneously Use of computerized simulator or non-computerized (tabletop) methods for recognizing AOCs Control Room roles and responsibilities under the emergency response procedures Knowledge of Pipeline System Periodic or infrequent pipeline operating set-up procedures Control Room team training that includes both controllers and other individuals Compliance Validation Operators must ensure that their procedures provide clear notification guidance to PHMSA and/or the appropriate state agency. Compliance and Deviations Control Rooms must provide the appropriate records that document current operating procedures and demonstrate that any deviation was essential for the safe operation of the pipeline. Good News Miller Consulting Services, Inc. (MCS) is committed to providing Operators with the technical documentation, regulatory compliance services, and data solutions needed to meet these nine elements. Its highly educated and knowledgeable consultants follow rigorous quality standards and proven methodologies that offer experienced documentation and audit support for Operators looking for additional help. Contact MCS Website: https://mcs.biz/ Email: mcs@mcs.biz Phone: 972-580-0812
by MCS Site Admin | Apr 11, 2017
MCS will be exhibiting at the 2017 AGA Operations Conference May 2-5 at the Gaylord Palms in Orlando, FL. Come visit us at Booth #1037 and try your hand at a game of Roulette. We’d love to discuss ways we can help streamline and audit-proof your regulatory programs!
by MCS Site Admin | Oct 5, 2016
MCS was thrilled to receive the 2016 Exceptional Performance award in Tesoro Logistics’ Small, Disadvantaged, or Diverse Business category. Tesoro provided the following statements: “MCS has proven time and again they are nimble enough to respond quickly to unforeseen and changing needs in Tesoro’s business. MCS is a crucial part of Tesoro Logistics’ regulatory compliance success during the fastest growth in the Company’s history.” Thank you Tesoro for this recognition and MCS will continue to provide superior support to Tesoro and our other clients! Click here for the article.
by MCS Site Admin | Oct 1, 2016
The Southern Gas Association (SGA) recently asked MCS’s VP of Consulting Services to be an instructor for their Southwest Regional Gas Conference and Expo. The workshop was about practical Project Management application for small and large projects. Audience feedback was positive and MCS looks forward to our next opportunity to partner with SGA.
