Enhanced Production Audit Program (EPAP)
The Energy Resources Conservation Board (ERCB) regulates the energy sector as authorized by various acts of the province of Alberta, Canada and the regulations under those acts. On December 16th, 2009 the ERCB issued Directive 076, commonly referred to as the Enhanced Product Audit Program (EPAP).
This directive applies to all Operators subject to Energy Resources Conservation Board (ERCB) measurement and reporting requirements and reporting to the Petroleum Registry of Alberta (PRA) and pertains to conventional oil, heavy oil, crude bitumen, and natural gas facilities. It does not apply to mineable oil sands.
The EPAP is designed to:
- Raise the level of assurance regarding Operators’ compliance with ERCB measurement and reporting requirements, and
- Raise the level of compliance with ERCB measurement and reporting requirements.
Through EPAP, the ERCB will reduce its reliance on substantive audits in favor of relying on the effectiveness of every Operator’s controls to improve compliance with ERCB measurement and reporting requirements. Operators are expected to design, operate, and evaluate controls that ensure compliance with ERCB measurement and reporting requirements and to maintain sufficient documentation to support their design and evaluation of controls.
EPAP’s process requires that each Operator’s senior executives submit an annual declaration attesting to the state of their controls designed to ensure compliance with ERCB measurement and reporting requirements. The declaration includes reporting on the existence of controls and the results of the evaluation of controls:
- Annual declaration: An Operator must submit a Declaration on ERCB Measurement and Reporting Requirements to the ERCB every year.
- Period covered by a declaration: An Operator’s declaration must cover the 12 calendar months ending in the Operator’s declaration month and must be received by the end of the month following the declaration month.
Recommended Actions By An Operator
An Operator must submit its first declaration within two years of the effective date of this directive or within two years of its first submission to the PRA, whichever comes later. Importantly, the ERCB encourages Operators to develop and test the declaration processes early. If the first declaration is made within the first year of the effective date of this directive or of the first submission to the PRA, noncompliance with any requirement in this directive will not be subject to Directive 019 enforcement for that first declaration.
Internal Audit Function:
The DoubleCheck™ EPAP Solution
EPAP is based on Operators evaluating their measurement and reporting controls across all facilities every year. This is a difficult task to perform manually with merely desktop applications such as Excel and Word. The DoubleCheck GRC & Audit Platform provides the comprehensive compliance and audit environment to manage to the required standards:
Disclosure regarding evaluations of controls: An Operator must declare the number of evaluations of controls conducted during the declaration period, the number of those evaluations where the controls were deemed successful, and the Operator’s assessment of whether or not the risk of noncompliance with the requirement is addressed.
Retention and provision of results: An Operator must prepare and retain for a period of three years documentation on the processes followed and the results obtained for each instance of evaluation of controls and provide these electronically on request to the ERCB through the EPAP system.
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