For instruction on applicability analysis, click the following links or use the scroll bar to scan the page.
Performing an Applicability Analysis for a Regulation, Policy, or Permit |
Viewing and Defining Tasks for Compliance Scenario Requirements |
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The goal of an applicability analysis is to determine which requirements apply to a process unit or type of facility. If you operate your process units under different conditions, you can set up multiple applicability analyses for a single process unit and evaluate applicability for each. For example, if you have a reactor that produces two different products, you can evaluate the applicable requirements under each product's operating scenario. When you establish a facility type for a facility in your enterprise, such as a refinery or manufacturing unit, you can perform an applicability analysis for the facility.
Specify a process unit/facility type and scenario for an applicability analysis on the Compliance Scenario form and then use the form to complete the analysis and store your decisions. Use the Process Unit Compliance Scenario form for process units and the Facility Type Compliance Scenario form for facility types.
Tip: When you already know which rules apply to your operations
and only need to document positive and negative applicability, use the
Compliance
Applicability form. When you want the software to help you
identify if a requirement applies, perform an applicability analysis using
the Compliance Scenario form.
During the applicability analysis, you will also use other forms to specify values or select items that relate to the applicability analysis. For example, the Compliance Scenario Rules form can be used to set the applicability status for rules (regulations, policies, or permit requirement profiles).
The Compliance Manager module automatically selects potentially applicable rules when you establish a compliance scenario. For more information on the selection process, refer to Understanding Rule Selection for a Compliance Scenario. During the applicability analysis, review the rules to determine which apply. Specify applicability criteria and requirement citations for the rules that do apply. You can view operational data and process unit/facility type information, requirement text, and applicability criteria text to help you determine if a requirement citation applies.
Tip: Because the applicability status that you select for
a rule is assigned to the rule's citations, do not select the applicability
status for your citations first. If you do, the status that you select
for your rules will overwrite the status you have selected for the citations.
When you determine that a rule applies, any tasks defined for the rule's requirement are automatically copied to the compliance scenario. You can review and edit these tasks to tailor them to the scenario.
For your applicability analyses, use the Process Unit Compliance Scenario form to set up a scenario for all classifications of process units. For types of facilities established on the Facility Type form, use the Facility Type Compliance Scenario form. Both forms operate in the same manner; separate browse views (lists) are maintained for quick access to saved scenarios.
To establish a compliance
scenario
Use one of the following paths in the Navigation Tree to access the Compliance Scenarios list:
Click Data Entry > Process Unit Compliance > Process Unit Compliance Scenario.
Click Data Entry > Facility Type Compliance > Facility Type Compliance Scenario.
Click the New
button.
The Compliance Scenario form
is displayed.
Select an Enterprise
Entity, Process Unit
(or Facility Type),and Scenario from the list for each
field.
If a value is not listed, click the Ellipsis
button next to the field and add it.
Enter an Effective Date and End Date, or click the Calendar button and select the date.
Expand the Comments section when necessary and type any notes.
Click the Save
button on the form.
The remaining sections of the form are displayed.
Review and add information in the Rules, Parameters, Process Unit/Facility Type Properties, Applicability Criteria, Requirements, Tasks, and Compliance Categories sections.
Click the Save button on the form.
The software automatically selects potentially applicable rules for an applicability analysis and displays them in the Rules section on the Compliance Scenario form. For more information on how the software selects rules, refer to Understanding Rule Selection for a Compliance Scenario. You can use the check boxes in the section to filter the list of displayed rules. Check each box to display rules with that status. For example, click the Applies check box to display only rules for which the applicability status equals Applies.
Set the applicability status for each rule listed in the Rules section. Click the status link for a rule and open the Compliance Scenario Rules form. Select the new status and enter supporting information in the fields provided. The rule's citations will "inherit" the status that you select for the rule.
Tip: If you add a rule for a compliance scenario by assigning
a citation in either the Applicability
Criteria section or the Requirements
section, the rule will inherit the status you define for the citation.
To review rules for a compliance
scenario
Locate your scenario in the Compliance Scenarios list, click
the scenario link to open the Compliance
Scenario form, and expand the Rules
section if necessary.
The list in the Rules section
includes rules (regulations, policies, and permit requirement profiles)
that apply or potentially apply to the compliance scenario. Use the
check boxes to filter the list displayed based on status.
Review the list to verify that the applicability status of each rule is correct. The software assigns the Not Reviewed status as a default.
Click the status link for a rule
to open the Compliance Scenario Rules
form and review the rule information.
To change the applicability status, see To
Set the Applicability Status for a Regulation, Policy, or Permit.
Use the Compliance Scenario Rules form in conjunction with the Compliance Scenario form to complete a step in the applicability analysis. On the Compliance Scenario Rules form, you can set the applicability status of a rule (regulation, policy, or permit) for a compliance scenario. The status that you select for a rule on this form will be displayed in the Rules section on the Compliance Scenario form and is "inherited" by the rule's citations. When you evaluate the citations, you can accept the status or assign a different status. Applicability status options are Not Reviewed, Applies, and Does Not Apply.
On the Compliance Scenario Rules form, record who determined the status and the reason that the status was selected. Add notes and descriptions to support the status decision. Because rules change over time, you can evaluate and document applicability for each regulation version.
If you determine that an entire rule does not apply to the scenario, you can skip further review of its citations on the Compliance Scenario form. If you determine that the rule applies, review its citations to determine which apply for the scenario. If you are unsure, you should select the Not Reviewed status, and continue evaluating the citations.
Because you can create multiple applicability analyses for a process unit, you have the flexibility to assign a rule's applicability status differently for each scenario.
To set the applicability status for a regulation,
policy, or permit
Tip: If you open the Compliance
Scenario Rules form from the Rules
section of the Compliance Scenario
form, begin with step 3.
Use one of the following paths on the Web Control Panel to access the Compliance Scenario Rules list:
Click Data Entry > Process Unit Compliance > Process Unit Scenario Rules.
Click Data Entry > Facility Type Compliance > Facility Type Scenario Rules.
Locate your scenario on the Compliance Scenarios list and click the scenario link to open the Compliance Scenario Rules form.
Review the Status and select another one from the list when necessary.
Enter a Review Date for the day the applicability status was evaluated. The Calendar button is available to select the date.
Enter the name or position of the person who determined the applicability status for the rule in the Reviewed By field.
Review the Reason
for the status selected. Select one from the list when applicable.
If the reason is not listed, click the Ellipsis
button and add it.
Provide a Description of the reason chosen.
Enter a Start Date and End Date for the status selected, or click the Calendar button and select the date.
Type any notes in the Comments field.
Click Save.
The software automatically selects potentially applicable rules (regulations, policies, or permit requirement profiles) for an applicability analysis when you select a process unit/facility type and scenario on the Compliance Scenario form. Rules are selected based on permits defined for the process unit/facility type, citations defined by the process unit's/facility type's compliance categories, or citations defined by the user for a specific compliance scenario, as described below.
Permits defined for the process unit - Using the Compliance Manager module, you can document your permits and the requirements that you have defined for your permits. If many or all of a permit's requirements apply to a process unit/facility type, you can assign the permit to a process unit/facility type. The software will identify all the permit requirements as potentially applicable if you associate the process unit/facility type with the permit in the Permits section on the Process Unit/Facility Type form AND you associate the permit with a permit requirement profile in the Requirement Profiles section on the Permits form.
Citations defined by the process unit compliance categories - The software identifies rules as potentially applicable when you assign a process unit to the same compliance category as one or more of the rule's citations. For example, you might assign a stream boiler to the Boilers compliance category and also assign the Boilers compliance category to a requirement citation that describes boiler inspections under a regulation. When you set up a compliance scenario for the steam boiler, the software identifies the regulation with the boiler inspection requirement based on the compliance category selection.
Citations defined by the user for a specific scenario - A rule is identified as potentially applicable when you select one or more of its citations for an applicability analysis in the Requirements section or the Applicability Criteria section on the Compliance Scenario form.
When you set up an applicability analysis using the Compliance Scenario form, the potentially applicable rules will appear in the Rules section and any associated citations in the appropriate Requirements or Applicability Criteria section. When the software selects a rule based on a permit or a compliance category, it automatically assigns the Not Reviewed status as the default applicability status. However, when you add a citation to an applicability analysis, the software adds the rule and assigns it the same applicability status that you selected for the citation.
Enter operational data, such as temperature or flow rate, for a process unit/facility type in the Parameters section on the Compliance Scenario form. Use the data to help you determine if a requirement applies. For example, if a requirement only applies to stacks with an exhaust temperature above a certain level, record the temperature for the stack and compare it with the requirement to determine if the requirement applies. Because values for operational data may change over time, the effective date is important. For each parameter, you can enter multiple values and their effective dates, which allows you to retain a history and document a value for a point in time.
The compliance categories assigned to a process unit/facility type determine a default set of parameters, but you can add more parameters for an applicability analysis. For example, the storage tank compliance category might include parameters for temperature, height of liquid, chemical, and tank temperature. All of the process units assigned to the storage tank compliance category would have at least the default set of parameters available.
Click View Parameters to review existing operational data.
To add parameters and operational
data for a compliance scenario
Locate your scenario on the Compliance Scenarios list, click the scenario link to open the Compliance Scenario form, and expand the Parameters section if necessary.
Click Add Parameters to open the Compliance Scenario Parameters form.
Select a Parameter
from the list.
If the appropriate value is not listed, click the Ellipsis
button to add it. The Process Unit
Compliance Parameters form is used to add list values for a
process unit and facility type compliance scenario.
Click the Calendar button and select an Effective Date for the parameter operational data.
Enter a Value
and select a corresponding Unit
of measure from the list if applicable.
If a unit of measure is not listed, click the Ellipsis
button and add it.
Enter compliance scenario parameter Text and any Notes.
Click Save.
Repeat steps 2 through 7 to add other parameters and operational data.
Click the Save button on the form.
While you are performing an applicability analysis, it may be useful to refer to operational data for the process unit/facility type. For example, if a requirement applies to outfalls with a certain flow rate, viewing a process unit's flow rate could help you to determine if the requirement applies. You can view and edit operational data in the Parameters section of the Compliance Scenario form.
To display operational data, click View Parameters. The Compliance Scenario Parameters form appears. To close the form, click Close.
Properties are used to record characteristics of a process unit/facility type that do not vary over time, such as primary fuel type for a boiler or tank capacity. Viewing properties while you are performing an applicability analysis may help you to decide if a requirement applies. For example, if a requirement applies to boilers, you could view the primary fuel type to determine if the requirement applies. The Process Unit Properties section on the Compliance Scenario form lists the properties and the property values defined for the process unit. The Facility Type Properties section lists the properties and values defined for the facility type.
Click Define Properties to open the Process Unit form or Facility Type form where you can assign properties and specify property values in the Properties section.
Applicability criteria citations describe how you can determine if a requirement applies. For example, an applicability criteria citation might state that a requirement applies to tanks with a capacity of 40,000 gallons or more. When you perform an applicability analysis, you can evaluate applicability criteria to determine which regulations apply to the process unit/facility type you are reviewing.
The software automatically identifies applicability criteria citations that are assigned to the same compliance category as the process unit/facility type or that relate to a permit assigned to the process unit/facility type. The citations are displayed in the Applicability Criteria section on the Compliance Scenario form where you can select a citation, set its status to add it to the applicability analysis, and enter other information about the citation. For more information on how the software selects potentially applicable rules, refer to Understanding Rule Selection for a Compliance Scenario.
Review and select the correct applicability status of each citation, document who determined the status, and the reason the individual selected the status. Initially, a citation "inherits" the applicability status you assign to its rule on the Compliance Scenario Rules form. For example, if you assign the Applies status to a regulation, the citations for the regulation will also initially be defined as Applies. However, if you add a citation in the Applicability Criteria section on the Compliance Scenario form for a rule that was not selected by the software, the rule will "inherit" the citation's status.
You can use the check boxes in the Applicability Criteria section to filter the list of displayed citations. Click each check box to view only those citations with the selected status(es). For example, click the Applies check box to display citations with a status equal to Applies. (When no check boxes are selected, no citations will be listed.)
Use the following guidelines to help you make decisions:
View parameters and operational data in the Parameters section.
View process unit property information in the Process Unit Properties section or facility property information in the Facility Type Properties section.
View applicability text by clicking the citation link in the Applicability Criteria section. Click View Applicability Criteria on the Compliance Scenario Applicability Criteria Citation form to display the Citation Text form. Click Close to close the form.
To evaluate applicability
for applicability criteria citations
Locate your scenario on the Compliance Scenario list, click the scenario link to open the Compliance Scenario form, and expand the Applicability Criteria section if necessary.
Use the check boxes to filter the list. Click Does Not Apply, Applies, and/or Not Reviewed to view only the applicability criteria with the selected status(es).
View text for an existing applicability criteria citation by clicking the citation link and clicking View Applicability Criteria Text on the Compliance Scenario Applicability Criteria Citations form.
Change the applicability criteria
status by clicking the citation link, selecting a new status from
the Status field's list on
the Compliance Scenario Applicability
Criteria Citations form, and clicking Save.
You can also document who determined the status and the reason the
individual selected the status.
Add applicability criteria citations by clicking Add Applicability Criteria and following the steps below.
Select a Status from the list and enter the name or position of the person who determined the status in the Reviewed by field.
Enter a Review Date or click the Calendar button and select one..
Select the Rule, the Citation, the citation Effective Date, and the Reason for the status chosen from each field's list. If the applicable value is not listed, click the Ellipsis button next to the field and add it.
Enter a Reason Description.
Enter a Compliance Effective Date and Compliance End Date for the applicability criteria being added. The Calendar button is available to select the date.
Type any Notes and enter the Order Number that represents the applicability criteria citation's position among the list of citation line items in the Applicability Criteria section.
Click Save.
Click Close
to return to the Compliance Scenario
form.
Tip: When you save the compliance scenario, the rule
will also be added to the Rules
section if it was not already selected for the scenario.
Requirement citations describe what you need to do to maintain compliance for your process units. For example, a requirement might state that you must monitor and report the pH values of certain liquids in storage tanks. When you perform an applicability analysis you can evaluate the requirements and determine if they apply.
The software automatically identifies requirement citations that are assigned to the same compliance category as the process unit/facility type or that relate to a permit assigned to the process unit/facility. The citations are listed in the Requirements section on the Compliance Scenario form. You can select a requirement citation, set the status to add it to the applicability analysis, and enter other related information about the citation. For more information on how the software selects potentially applicable rules, refer to Understanding Rule Selection for a Compliance Scenario.
You should review and select the applicability status of each requirement. Applicability status options are Not Reviewed, Applies, and Does Not Apply. Initially, a requirement "inherits" the applicability status you assign to its rule on the Compliance Scenario Rules form. For example, if you assign the Applies status to a regulation, the requirements for the regulation will also initially be assigned the Applies status. However, if you add a requirement in the Requirements section on the Compliance Scenario form for a rule that was not selected by the software, the rule will "inherit" the requirement's status.
When you set a requirement's applicability status to Applies, any tasks defined for the requirement on the Requirement Citation Information form are copied to the Tasks section on the Compliance Scenario form.
Use the check boxes in the Requirements section to filter the list of displayed requirements. Click each check box to view only those requirements with the selected status(es). For example, click Applies to display requirements with a status equal to Applies. (When no check boxes are selected, no requirements will be listed.)
Click a requirement citation link to open the Compliance Scenario Requirement Citation form where you can set the applicability status and enter other related information about the citation. A description of the links on this form is provided below.
Click View Requirement Text to display the Requirement Text form.
Sometimes a requirement applies to a process unit/facility type because the process unit/facility stores or processes a certain material or material group. You can click Define Scenario Requirement Materials and use the Scenario Requirement Material form to specify a material.
Verify any tasks that the software copied to the compliance scenario based on applicable requirements. You can also establish more tasks, as necessary, to describe what you must do to maintain compliance with a requirement. Click Define Scenario Requirement Tasks and use the Scenario Requirement Tasks form to establish and review tasks for a requirement.
To evaluate applicability
for requirements
Locate your scenario on the Compliance Scenario list, click the scenario link to open the Compliance Scenario form, and expand the Requirements section if necessary.
Use the check boxes to filter the list. Click Does Not Apply, Applies, and/or Not Reviewed to view only the requirements with the selected status(es).
View text for an existing requirement citation by clicking the citation link and clicking View Requirement Text on the Compliance Scenario Requirement Citations form.
Change the requirement status by
clicking the citation link, selecting a new status from the Status field's list on the Compliance Scenario Requirement Citations
form, and clicking Save.
You can also document who determined the status and the reason the
individual selected the status.
Click Add Requirements to add requirement citations and follow the steps below.
Select a Status from the list. and enter the name or position of the person who determined the status in the Reviewed by field.
Click the Calendar button and select a Review Date.
Select the Rule, the Citation, the citation Effective Date, and the Reason for the status chosen from each field's list. If the applicable value is not listed, click the Ellipsis button for the field and add it.
Type a Reason Description.
Click the Calendar button and select a Compliance Effective Date and Compliance End Date for the requirement citation being added.
Type any Notes and enter the Order Number that represents the requirement citation's position among the list of citation line items in the Requirements section on the Compliance Scenario form.
Click Save.
Click Close
to return to the Compliance Scenario
form.
Tip: When you save the compliance scenario, the rule
will also be added in the Rules
section if it was not already selected for the scenario.
In the Tasks section on the Compliance Scenarios form, you can verify and add tasks for requirements that apply for the applicability analysis. Tasks are measurable activities that define how you will maintain compliance with a requirement.
When you set a requirement's status to Applies in the Requirements section, the software automatically copies any tasks defined for the requirement on the Requirement Citation Information form to the Tasks section on the Compliance Scenario form. Click the task link to open the Scenario Requirement Tasks form and view task details.
You can also establish tasks specifically for a requirement for an applicability analysis by clicking Define Scenario Requirement Tasks to add, remove, or edit tasks for a requirement using the Scenario Requirement Tasks form.
In the Comments section on the Compliance Scenario form, you can type additional information about the applicability analysis.
In the Compliance Categories section on the Compliance Scenario form, you can verify which compliance categories are assigned to the selected process unit/facility type. Consistency in assigning compliance categories will ensure that your lists of potentially applicable rules and citations are accurate and comprehensive.
To modify the compliance categories for the process unit or facility type, click Assign Compliance Categories to open the Process Unit for Facility Type form and assign compliance categories. The software automatically selects potentially applicable rules for a scenario based in part on compliance category assignments. For more information on how the software selects rules, refer to Understanding Rule Selection for a Compliance Scenario.
Note:
If you modify the compliance category selection for a process unit/facility,
the potentially applicable rules, policies, applicability criteria, and
requirements will also be modified. You should review the applicability
analysis for each scenario for the affected process unit/facility type.
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