Enhanced Production Audit Program (EPAP)
iMEC Regulatory Compliance Services
iMEC is structured to manage your outsourcing requirements from measurement and reporting right through to declaration on a part time or full time basis. Through this process we will help you understand the following:
- The compliance expectations of your regulator
- What to consider in designing controls
- How to evaluate the effectiveness of controls
- How to maintain controls to ensure their continued effectiveness and reporting compliance
- How to implement EPAP, and use it for continuous improvement, year after year
- How to interpret and use the compliance assessment reports to identify and track issues
- How to make your annual declaration
The Purpose of EPAP
EPAP has been implemented through provincial government directives that apply to all operators across Western Canada who are subject to their reporting and measurement requirements. These government directives apply to conventional oil, heavy oil, crude bitumen and natural gas facilities, but not mineable oil sands.
Through EPAP, government regulators aim to reduce their reliance on substantive audits in favour of relying on each operator to self-report. A key aspect of EPAP is that each operator is to submit a formal declaration regarding the operating effectiveness of their controls in addressing the risk of noncompliance.
Operator Declaration Requirement
EPAP requires that each operator’s senior executives declare annually as to the state of their infrastructure (i.e. controls) ensuring compliance with measurement and reporting requirements. The declaration includes reporting on the existence (or absence) of controls, the extent to which controls have been evaluated, and the degree to which controls have been found to be effective.
Operators are expected to maintain sufficient documentation to support their design and evaluation of controls. While this documentation does not form part of the annual declaration, it may be requested by the regulator at any time.
Well-managed operators will already have controls in place to meet a variety of assurance goals. The regulator encourages operators to leverage relevant existing controls and evaluation procedures for EPAP purposes and to extend their control structures and environments to cover all measurement and reporting requirements.
A core component of EPAP is the reliance placed on the operator’s best judgment in determining whether their controls adequately address the risks of noncompliance.
Measurement and Reporting Compliance Assessment
EPAP conducts continuous monitoring of data submitted to the ERCB and provides monthly reports of indicators to all operators. An operator’s attention to these indicators is expected to result in continuous improvement in their level of compliance and so help in the management of their operations.