PLAN: Acceptable Deviations
API RP 1162, 3rd Edition, intentionally includes language about deviation from baseline requirements should an operator determine that a different course of action is needed for their program. Throughout the revision process, this discussion consistently raised the question: “How will I know if a deviation is justifiable?” or “How will state or federal inspectors view a deviation from baseline requirements?”
An operator finding themselves in that situation should consider the following questions:
- Have you defined “acceptable deviation” in your public awareness program? For example: “A change in requirements of a process or action in order to achieve [fill in the blank], meet program objectives, or advance safety.”
- Do you have a process to determine when/if a deviation is appropriate for your program?
- What problem is your deviation addressing?
- What section(s) of your program will be impacted by the deviation?
- Are you able to articulate clearly why the baseline requirement cannot or does not work for your program?
- How did you conclude that a deviation is necessary for your program?
- How does the deviation help you more effectively meet program objectives and/or advance safety?
We cannot forecast all questions an inspector may have about a deviation or pre-determine whether a deviation may be acceptable. However, the inclusion of a definition or process in your program for deviations will likely aid in those discussions with inspectors.