16 Stages of LDAR
to help you on your way to sustainable compliance
PLAN SCOPE OF WORK
- Facility Definition Process – A compliance review and a determination of the applicable rules, regulations and/or permitting requirements governing the facility.
DO THIS EARLY IN THE PROCESS
- Discover facility attributes that are regulated
- Determine all stakeholders who have a LDAR role
- Applicability Determination Process – Individual evaluation to properly define applicable compliance requirements.
- Based on defined goals, document where the program is applicable
- LDAR Program Definition Process – After identifying which equipment is affected where by the rules and regulations, consider other ways that the LDAR program can create value or achieve LDAR stakeholder targets.
FORMALIZE THESE ASPECTS INTO THE PLAN
- Identify stakeholders
- Define other LDAR program goals
- Agency & Regulatory Support Plan – Creates implements, and enforces specific laws dictated by regulatory agencies. Note that LDAR has gray areas.
HERE’S WHAT’S INVOLVED IN THE SETUP
- Training Program Management Plan – Incorporates training as a cycle including the steps of planning, implementation, and evaluation.
- Makes the implementation of training attainable
- Train all on their role
- Don’t assume LDAR Contractor trained
- Keep records to protect program
DETERMINE TASK REQUIRED
- LDAR Inventory Process – Complete LDAR inventory tracking.
- Create an inventory that identifies compliance method for each item
- Stay alert for errors
- Build inspection route efficiency
- Data Management Process – Daily database management by individual compliance reporting specialist specifically dedicated to your facility.
HERE’S THE VALUE
- Proper data management
PERFORM ROUTINE TASK & QUALITY CHECKS
- Inspection Process – Measuring, examining, testing or gauging all required M21 LDAR inspections and initial repair attempts when required OR company-wide, approved work-procedures to maintain compliance.
- Don’t get lost in the “trees” of inspection compliance
- Finding leaks is the goal
- Fugitive Emission Control Equipment – Acquiring and maintaining the latest technology for the field to ensure accurate results or a consistent evaluation of control equipment to reduce emissions.
- Ensure that equipment controlling fugitive emissions is maintained
- Leak Management Process – A plan that develops and controls the process to promote effectiveness and success in the LDAR program.
- The real purpose of LDAR is to reduce emissions
- Emission reductions happen here
- Work Procedures – A set of steps or series of practices that are carried out to ensure positive outcomes are achieved.
- Keep them simple
- Focus on tasks for a role
COMPLETE GAP ASSESSMENT
- Compliance Reporting Process – Producing reports confirming alignment with guidelines, regulations, and/or legislation.
DO THE FOLLOWING IN THIS ORDER
- Report what you must
- Document compliance
- Analyze, assess, evaluate and act on your data
- Management Of Change (MOC) Plan – A plan that is implemented to bring new and updated steps and processes to our organization OR approved MOC procedures that maintain compliance while correctly identifying facility changes.
- Ensure new components are added to program.
- Get stakeholders involved.
- Codify your plan
- Quality Management Plan – A sustainable Quality Control plan that considers the site’s particular conditions and available resources, and sets forth actionable steps that provide consistent deliverables.
HERE’S HOW TO MANAGE IT
- Check it
- Measure it
- Continuously improve it
IDENTIFY RISK EXPOSURE
- Risk Management Plan – A process used to foresee risks, estimate impacts, and define responses to issues.
KEEP IN MIND
- There is no perfect LDAR program
- Track and learn from mistakes
- Not everything is a deviation
- Consult and clarify deviations
- Health & Safety Plan – A program designed in accordance with legislative requirements that serves and protects
individuals in all matters of health, safety and wellbeing while they perform their tasks in the work environment.
KEEP IN MIND
- LDAR creates opportunities to avoid health and safety incidents
- Consider safety impact of LDAR Data