Comment Log Display

General Revisions(2)
Require schematics for refineries and oil and gas production
facilities
Schematics, in general, provide important information and lead to a
better understanding the complex operations at refineries and oil
and gas production facilities. Requiring schematics can
significantly improve a verifiers understanding of a facilities
operation and would assist in the development of appropriate
Verification and Sampling Plans.

Verification (1)
Change verification deadline from September 1 to August 1 
We believe the verification deadline of September 1 is important to
give the verifier sufficient time to conduct the analysis necessary
develop appropriate verification and sampling plans and complete
thorough facility evaluations and data checks.  While we believe
the suggested verification streamlining processes are positive
suggestions that will help the overall verification process, we do
not believe they provide sufficient streamlining to the
verification process to justify shortening of the verification
deadline by an entire month.   The areas that represent the largest
time sinks in the verification process are generally related to
expanded data sampling, additional data collection, and revisions
to reports based on identified non conformances.  In our experience
many facilities have large teams responsible for the facility
operations, data collection, and reporting and significant time is
necessary for the scheduling and collaboration necessary complete
the site visits, data gathering and report revisions.  Shortening
the season and changing the deadline from September 1 to August 1
may limit the verification process by affecting the quality of the
service and accuracy of data.