What “Shall Consider” Really Means
A student told me this story:
I was sitting at my desk, minding my own business and staring up at the righthand corner of my office. My boss, who was walking by, stopped, looked at me with a slightly annoyed expression and said, “What are you doing?” I calmly responded, “complying with the Z662 requirements”, and showed her a clause that stated, “Shall Consider”. She was not amused. She asked what I was considering exactly, and when I told her it was just “technical stuff” she smiled and said,”that’s great!. Please remember, to properly comply with the Z662, you will need to provide me written records of the exact STUFF you considered, the criteria you applied, and the conclusions you came to. After I have reviewed and signed off, they will become part of the project file. If you can have it to me by the end of the day will be fine.”
The student then asked me, “Where does Z662 say you have to document considerations? I couldn’t find it anywhere.”
It may be a stretch but think back to fifth grade. In the first math class the teacher explained that things would be different this year. Simply providing the correct answer would no longer get you full marks. You would now have to show your work. The purpose for this approach was twofold. It provided a verification that the prescribed method was being used as well as a record that allowed errors to be identified and corrected.
The Z662 is a “show your work” kind of document. Specifically, under managed or quality systems, we use documents and records for the same reason as the math teachers. The prescribed approach is achieved through our policies, procedures and work instructions and the primary tool for review and continuous improvement becomes the records. This approach is used successfully in, among others, the aviation and nuclear industries. It provides a significant increase to the safety of the systems by allowing professionals to apply their competencies on a situational basis as opposed to a one size fits all prescriptive requirement.
Now apply this to the “Shall Consider” clauses. If I don’t document my considerations and the reasons that I determined something was, or was not appropriate, I lose the ability to have my work reviewed, I have no way to conduct assessment and make continuous improvements in the future and if the outcome is not what I expect, I have no evidence to show that I complied with the requirements in the first place.
The Z662 recognizes that the design, construction and operation of pipeline systems are not cookie-cutter type processes. Each pipeline will have very distinct and unique features requiring the application of competent judgment on an individual system by system basis. Under the managed processes mandated by the Z662’s Safety and Loss Management System requirements, many clauses direct the user to consider options, circumstances or specified variables, based on their individual system needs. Clauses that include the word “Consider” are providing users with the authority to make the best decision for their pipeline circumstances. This authority can only be used under clear and well defined procedures which, under the requirements of the Z662, require records for review, verification and auditing functions.