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:

  1. 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.”
  2. Do you have a process to determine when/if a deviation is appropriate for your program?
  3. What problem is your deviation addressing?
  4. What section(s) of your program will be impacted by the deviation?
  5. Are you able to articulate clearly why the baseline requirement cannot or does not work for your program?
  6. How did you conclude that a deviation is necessary for your program?
  7. 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.