ABSA’s Unique Approach to Pressure Vessel Safety Administration

Inspectioneering is constantly seeking new ideas and perspectives on asset integrity management. Sometimes they come from owner-operators, sometimes service companies, sometimes a different industry, and many times they come from a different country. One area we are particularly interested in is our friends up north in Canada. We recently had the opportunity to sit down with Michael Poehlmann, Technical Director at the ABSA, to chat about the industry, the ABSA, and what they are doing to improve mechanical integrity and pressure vessel safety in Alberta. We hope you find the discussion as interesting as we did. 

What is the Alberta Boilers Safety Association (ABSA) and what is your role within the organization?

MP: The Province of Alberta has a long history of pressure equipment safety dating back to 1897 when the first boiler laws were introduced to regulate the new technology of steam boilers.  Boiler inspectors were hired, and soon thereafter the Alberta Boilers Branch was established as the government organization that administered those laws.  This original model worked very well, but over time, a new model of program delivery was developed, and following extensive public consultation, ABSA became the successor organization to the Alberta Boilers Branch.  In 1995, the Government of Alberta made ABSA the Delegated Administrative Organization (DAO) responsible for the administration of pressure equipment safety programs for the province.  It is important to note that the Government of Alberta retains full responsibility and control of the laws, while ABSA’s role is program delivery.  ABSA is a not-for-profit organization reporting to a volunteer Board of Directors.  Board members are selected to represent pressure equipment industry sectors: petroleum and chemicals, power and utilities, pressure equipment manufacturing and educational institutions.  One Board member is appointed by the government.

The Alberta pressure equipment safety program has elements applicable to the full life cycle of pressure equipment: design, construction, installation, operation, maintenance and decommissioning.  The program also includes pressure equipment quality system auditing and worker certification programs for power engineers, pressure welders, welding examiners, and in-service inspectors.  ABSA employs 135 people, 100 of whom are technical staff.  My role at ABSA will be changing effective September 16, 2014.  Dr. Ken Lau, our long-serving Chief Inspector and the Administrator for the pressure equipment discipline in Alberta, is retiring and I will be succeeding him.  The position has two distinct functions.  Chief Inspector is a management position in ABSA, accountable to the General Manager and responsible for oversight of technical staff.  Administrator is a Ministerial appointment made under the Safety Codes Act, with powers, duties and responsibilities specified in the Act and associated pressure equipment regulations.  In general terms, the Administrator interprets rules and establishes policy; the Chief Inspector is responsible for program implementation.

What led you to this type of work?

MP: I had been working along quite happily as chief engineer at a power plant in the Northwest Territories and was recruited by the Chief Inspector of the Northwest Territories.  At the time, I did not know many jurisdictional boiler inspectors, so I consulted with several “old timers” I had worked with in the past and what they told me got me interested in the learning opportunities, challenges, and rewards that working in a public safety role might present.  So I decided to give it a try.  That was 26 years ago, and I have not been disappointed.

In general, how do you feel the industry is performing in improving their PSM programs?

MP: In the context of ABSA's scope of operations, oversight of some elements of what you would recognize as PSM is achieved through our owner-user Pressure Equipment Integrity Management (PEIM) program.  Owner-users establish and implement a PEIM quality management system.  Our requirements for a PEIM quality management system are described in the ABSA document “Owner-User Pressure Equipment Integrity Management Requirements” (document AB-512).  The requirements include what may be thought of as a sub-set of the elements described in the U.S. OSHA standards.  ABSA audits the owner-user’s system for accreditation, and monitors its performance.  This program has been very successful since it was first implemented in Alberta around 25 years ago, and has seen continual evolution to keep current with industry best practices.  System-wide safety performance of the PEIM program is very good as evidenced by the low number of pressure equipment accidents in Alberta.  Over the last three years, annual incident rates have trended down by over 50%.  In 2013, just 34 incidents were reported; unfortunately these resulted in 3 injuries.  It is noteworthy that during this same time period, the number of pressure vessels in service increased by 10% to 110,000 items.

What areas need the most improvement when it comes to mechanical integrity?

MP: There are many owner-users that do most things well.  However, we often observe system weaknesses in the areas of training and operating procedures.  While we are fortunate to have few pressure equipment failures in Alberta, insufficient training and deficient operating procedures are too frequently found to be causal factors leading to such failures.

Do you feel there is a lack of trust and cooperation between owner-users and regulators?

MP: No.  I do understand this may be the case in some jurisdictions, simply because people have told me so; but I do not believe that to be the case in Alberta.  Pressure equipment safety relies heavily on human factors, therefore trust is paramount.  ABSA's working relationship with owner-users in Alberta has very much been built on trust and strong connections with our industry partners from day 1, and this excellent relationship has been maintained and perhaps improved since the formation of ABSA.  In addition, the Alberta “enforcement” model relies heavily on persuasion through information and education.  That is, our technical staff, designated as Safety Codes Officers under the legislation, but more commonly referred to by the industry as Inspector, Auditor, Design Survey Engineer or Examiner, rely on an instructive approach.  We do not issue citations or fines.  We can issue an Order, which is enforceable by the law courts.  As a testament to our Safety Codes Officers’ success providing information and education, in ABSA’s twenty years of operations we have issued only 3 orders; none of which were issued to owner-user operators.  And to put that in perspective, in an average year, we audit 650 quality systems, register 8,000 designs, sign-off on 15,000 data reports for new vessels, and conduct 20,000 in-service inspections.

How would you describe the relationship between ABSA and most owner-users?

MP: Although ABSA has to exercise the regulatory role, I would describe the relationship very much as “partnership” as well.  We rely on the owner-users to do the right thing, and they rely on us to provide oversight, technical support, and advice that they are doing the right thing, and to provide input on continuous improvement.

You have a reputation for working hand in hand with owner-users to find solutions that are fair and beneficial to the industry. What measures have you taken to try and improve trust and cooperation?

MP: This is an area that we are very proud of.  Carrying on the practice that began long before the formation of ABSA, we (ABSA and Industry) have worked hard developing relationships and working collaboratively on pressure equipment safety program improvements.  An example would be the projects to develop and publish pressure equipment safety legislation compliance requirements and guidance documents.  Several inspection-based user groups have been established by industry inspectors.  These groups function primarily as peer networks, but also serve a valuable role by providing input as stakeholder representation groups.  Key groups are Alberta Refinery and Petrochemical Inspectors Association (ARPIA), Upstream Chief Inspectors Association (UCIA), Generation and Utilities Advisory Committee (GUAC), and the Contract Chief Inspectors Association (CCIA).  These user groups typically meet 3 – 4 times per year, and designated ABSA staff will attend the meetings to brief the group on ABSA matters that may affect them, and perhaps more importantly, to get their input and feedback on program delivery matters.  ABSA guidance documents (known as AB-500 series documents) have been developed with the input and consultation from these user groups.

How has your participation in industry organizations such as ASME, API and CSA improved your relationship with industry representatives?

MP: Participation in codes and standards development organizations is considered an important part of ABSA's work.  Industry benefits from our involvement in these activities in several ways.  First, we provide regular updates to the industry on the latest changes in the code and standards.  This is done formally through the delivery of annual Code Update seminars, which we have been providing for over 30 years.  These are well attended with typically 200 - 300 participants each year.  We also provide reports to the Boilers and Pressure Vessel Sub Council (BPVSC) and user groups throughout the year as information becomes available to us.  This provides industry opportunities to prepare for code changes.  It is also very beneficial to know a few committee members that can often help resolve disagreements about the application of rules among manufacturers, owners, and inspectors.  Our participation with the API Inspector Certification Program (ICP) for 8+ years has given us a great deal of confidence in the ICP, and that is important as API certification has become a key technical requirement for the Alberta inspector certification.  Alberta acceptance of the API inspector certification is beneficial to companies that have globally applied in-house standards for inspector qualifications.

Can you briefly describe ABSA’s regulatory system?  Is it more performance-based, as opposed to rule-based?  Do you feel that this is most effective?

MP: To be clear, it is the Government of Alberta’s regulatory system.  ABSA administers the program on behalf of the Alberta Government.  The regulatory system for pressure equipment establishes general responsibilities and duties for pressure equipment owners.  The laws contain administrative requirements and some technical requirements, with the bulk of technical rules established through the adoption of recognized national and international standards, including the CSA B51 Boiler, Pressure Vessel and Pressure Piping ode, the ASME Boiler and Pressure Vessel Code, and the ASME Pressure Piping Codes.  The approach with respect to in-service pressure equipment is very much performance based, resulting in less restrictive rules for owner-users with well-developed PEIM programs as compared to “junior” operators or owners of pressure equipment in public occupancy.  From a jurisdictional oversight perspective, this approach allows us to focus our resources with more direct inspection activities where the risk to public safety is greatest, while relying on audits and program monitoring for owner-users.  It is not unlike the way a well-managed PEIM program allows the owner-user to focus resources and plan turnarounds to manage the risks that present the greatest threats to their operations. 

Does ABSA reference the latest editions of industry codes and standards, such as API 510 and API 570, to keep their regulations current with RAGAGEP?

MP: ABSA references industry codes and standards such as API 510 and API 570 and the National Board Inspection Code, as and where appropriate.  However, these documents have not been adopted as law under the regulations.  Rather, the provisions of these codes and standards become Alberta pressure equipment safety program requirements through specific reference in requirements established by the Administrator.  This is another example of performance based rules; our legislation provides for the Administrator to establish compliance requirements and these compliance requirements can be made for specific owner types.  As explained above, the process of developing these requirement documents includes a great deal of stakeholder involvement.  We acknowledge and appreciate the great deal of expertise our owner-user partners bring to the process, and rely on their experience to help shape and establish requirements that reflect current industry best practices.

Does ABSA have an industry advisory board that results in active and on-going discussions with industry representatives on MI issues?  If not, is that something that has been considered?

MP: The simple answer is no, but the reality is the industry advisory role is achieved through a much broader consultative process than might be achieved with a single advisory board.  The Alberta pressure equipment safety program is administered with active input from industry representatives at many levels.  As mentioned above, our Board of Directors represent industry sectors and has a role of providing governance to the organization to ensure it remains relevant to protect public safety while recognizing industry needs and trends.  There is also the BPVSC, formed under the Alberta Safety Codes Council, an organization with responsibilities related to the public safety system in Alberta. The BPVSC’s primary purpose is to review, formulate, and recommend modifications to the codes, standards, and principles within the pressure equipment discipline; establish competency requirements for safety codes officers; and to hear and decide upon appeals of orders and written notices.  There are currently 13 members of the BPVSC, each representing a stakeholder group.  In addition to the stakeholder groups mentioned above, we have a number of active “task groups” comprising members from industry and ABSA, working on specific projects.  For example, our Inspection and Servicing Requirements document (ABSA document AB-506), In-service Pressure Equipment Inspector Certification Requirements document (ABSA document AB-526), and Owner-User Pressure Equipment Integrity Management Requirements (ABSA document AB-512) are each currently undergoing task group reviews.  In addition to all this formal consultation, our inspectors actively seek program input through one-on-one engagement with individuals and corporations during program delivery.  I believe the entire process provides a very robust system of active dialogue with the industry.

Are there any new rules on the horizon that could affect the way mechanical integrity programs are run?

MP: There are no major rule changes.  The next revision of the AB-506 document will include reference to and guidance on the use of API 510, section 9 for upstream exploration and production vessels.  This may affect the way some owner-users with significant upstream inventories manage this equipment.  Boiler operation is, as in all of Canada, a regulated activity in Alberta.  Persons responsible for the operation of boilers in Alberta must hold certification as a power engineer issued under the Power Engineers Regulation (PER).  Amendments to the PER were made effective December 2013, and these include provisions to reduce the requirements for power engineers operating boilers when the owner can meet a specific set of conditions, and addresses the operation in the PEIM program.