1. The document outlines an approach to compliance management that includes establishing standards and guidance, managing assets and their certification, conducting audits, and reporting. 2. Key elements of the compliance approach include developing a comprehensive suite of performance standards and guidance documents, maintaining an asset database to track certification and maintenance, conducting risk-based audits that range from deep to standard depending on the asset, and reporting results to management and boards. 3. A scoring system is presented to determine audit levels for different assets based on their severity, likelihood, and complexity, with higher risk assets receiving deeper audits.

1. 1. Aims and Objectives
IN STRICTEST CONFIDENCE
1

3. Compliance Simplified
3
Compliance
Assurance :
Asset Data
Standards
Process
Mgmt. Persons
Design Guides :
influence initial
compliance and
at refurbishment
Audit:
Quantitive Perf
Tech Qualitative
Mgmt. Groups
Duties
Understood
: Legislative
Reqs
Arrangements :
Contracts –
compliance
Performance Reqs
Resource
Database
Reporting

4. General H+S
reqs
Specific
Legislation
Business
Mandatory
Reqs
Business
Interpreted
Stds
Overall
Standards
Compliance
Handbook
TFM Contract
Specialists
Contracts
General
Performance
KPI
Quantitive
Qualitative
Audits
Software/
Database
Process
Handbook
Audit
Handbook
Capital/ LCR
delivered
Compliance
Management
Actions
Reporting
Menu
Management
and Board
Reports
New/Refurb
Design
Guidance
Management
Arrangements

5. The Compliance Approach
5
Compliance
Reports
Legal
Framework
Applicability
test to Business
Policy,
Standards,
Guidance
Supply Chain
Procured
Test and
Certification
Compliance
Database
Industry Stds
Current/Future
Operating
Conditions
Bus. Standards
Draft defined
Suite of P+S,
Guidance
Comprehensive
Design Guides
TFM
Contract
Specialist
Suppliers
Assets and
Frequency
maintained
Performance
and
Certification
Risk Based
Management
Dynamic
Supplier Mgmt.
Programme
KPI Mgmt.
Procurement and Process
Gaps reviewed and
closed
Structure, Database and
Audit Function Recommendations
as part of Compliance Review
Feedback
Loop
Process Review
and refinement as
function of
Compliance Forum
KEY - Activity Supporting Process
Key Process Step
Key Decision
Legislation and
ACOP Review
Board Reports
Assurance
Statement
BRE Exercise
Overall Review by Business –
Determination of
Operating Suite
Audit Function
Data/ System
Audits
Technical
Audit
Compliance
Forum
Independent
Compliance
Review
Compliance
Summaries
Compliance
Process

6. The Standards and Guidance Delivery Approach
6
Menu of reqd
P+S
Data Gather
P+S,
Guidance
developed
Stakeholder
Approval
Publication Training
Industry Stds
Current/Future
Operating
Conditions
Bus. Existing
Standards
Draft defined
Suite of P+S,
Guidance
Comprehensive
Design Guides
Impact
Statement
Responsibility
Matrix
Ownership/
Version and
Date controls
Database and
Protection
Guides and
Templates
Process
Mapping
KEY - Activity Supporting Process
Key Process Step
Legislation and
ACOP Review
BRE Exercise
Review
In use
Review
Change and
Date Triggers
Bus. Reqd
Operating
Standards
Guiding
Principles
Legislative /
Process
Updates
Business SME
Engaged
Supply Chain
Engaged

7. FireElectricalMechanical EnvironmentalBuilding
1. Earthing Systems
2. Electrical Installation
Inspection
3. Emergency Lights High
Voltage Installations
4. Lightning Protection
Systems
5. PCB’s – (old
switchgear)
6. Portable Appliance
Testing
1. Aircon – F Gas
2. Biomass Boilers
3. Cooling Towers
4. Dock Levellers
5. Gas Installation + Appliances
6. Legionella and Water
Hygiene
7. LEV Systems
8. Lifting Equipment (scissor
lifts, lifting beams etc)
9. Lifts
10. LPG – Fixed Systems
11. Microwave Ovens
12. Power operated shutter,
sectional and rapid roll doors
13. Pressure Systems and
Vessels
14. Traffic Barriers, Gates,
Hydraulic Ramps
1. Access Equipment- Fall
arrest etc
2. Asbestos Management
3. Eye Bolts
4. Fixed Ladders and
Gantries
5. Glazing Safety
6. Radiation Safety –
naturally occurring
radiation
7. Window Cradles
1. Control of Substances
Hazardous to Health (COSHH)
Regs 2002
2. Display Energy Certificate
3. Discharge Consents
4. Fuel Facilities and Adblue
5. Grease Traps and Dosing
Systems
6. Hazardous Waste
7. Invasive Weeds (principally
Japanese Knotweed)
8. Oil Interceptors
9. Oil Storage (>200 litres)
10. Oil Storage (Drums < 200l,
Intermediate bulk containers
<1000l)
11. Vehicle Washing and Cleaning
1. ASD Systems (very
early smoke detection)
2. Fire Dampers
3. Fire Detection and
Alarm Systems
4. Fire Doors
5. Fire Fighting
Equipment
6. Fire Risk Assessment
7. Gas Extinguishing
Systems
8. Hydrants and Fire
Risers
9. Pocket Vibrating Fire
Warning Systems
10. Refuge Areas and
Evac. Chairs
11. Smoke Control
Systems and Vents
12. Sprinkler Systems

8. L1 -High Risk , High
Impact – eg : Asbestos
,Legionella, Lifts,
Electrical
L2 – Medium Risk, eg :
gas , equipment,
L3 - Lower Risk , eg
glazing safety, radiation
safety
 Why ? – certain assets and
activities warrant additional audit
– risk, severity, likelihood and
complexity of delivery determine
the targets.
 Who ? – balance of internal and
external resource structured
through eg HV Mgmt. Team,
Compliance Forum,
 What ? – quantitive, qualitative,
methodology, training (int. and
ext.) recording, reporting ,
benchmark compliance.
Compliance Deep Audit
Volatile, subject to multiple
influences, based on 3rd party
assessed risk, complex layered
delivery with high risk of supply chain
failure – DEEP AUDIT NEEDED
Less complex delivery requirements,
more fully defined, less risk based
and less likelihood of process failure
by supply chain – STD Quantitive/
Qualitative Audit suffices?
Proposed Graduated Approach
Typically routine delivery
requirements , generic delivery
through supply chain/ PiC, low
likelihood of process failure. - – STD
Quantitive/ Qualitative Audit
suffices less frequently.

9. Heading Asset Element Severity Likelihood Complexity
Score/
Indicator L1 L2 L3
Electrical Earthing Systems 5 3 1 9 y
Electrical Electrical Installation Inspection 5 3 4 12 y
Electrical Emergency Lights 2 2 1 5 y
Electrical High Voltage Installations 5 3 5 13 y
Electrical Lightning Protection 5 1 1 7 y
Electrical PCB Old Switchgear 2 1 1 4 y
Electrical Portable Appliance Testing 2 1 1 4 y
Mechanical Aircon - F Gas 1 2 1 4 y
Mechanical Biomass Boilers 2 1 1 4 y
Mechanical Cooling Towers 5 4 5 14 y
Mechanical Dock Levellers 2 1 1 4 y
Audit LevelAudit Level Scoring
Audit Level Scoring