1. What are the steps for CSSD certification?
- A company applies directly to CSSD for certification for its shale gas operations in the Appalachian Basin – Certification is available for either Operational Excellence in Air & Climate, Water & Waste, or both.
- CSSD leads an intensive training and orientation course with the audit team and company representatives to cover the audit process, site visits, interviews and data collection.
- Auditor team conducts the full schedule of site visits, collects data and evaluates conformance.
- CSSD receives and reviews the audit report
- CSSD’s internal “Certification Decision Committee” reviews the audit report and judges eligibility for certification.
2. Why are there three separate certifications?
CSSD’s initial 15 performance standards were developed in two categories: Air & Climate and Water & Waste Management. Because these standards are forward leaning and center on continuous improvement and the development of leading industry practices, it is prudent to give companies the option of undertaking the certification process one category at a time. However, a companythat obtains partial certification is required to apply for full certification (all 15 standards) within 2 years and to obtain full certification within 3 years. Companies can also choose to undergo full certification across both categories at the same time. Regardless of approach, the performance standards are the same.
3. How will CSSD publicly report information?
For companies that earn certification a summary of a final audit report, prepared by the third party auditor and reviewed by CSSD, will be published on CSSD’s website. CSSD will also report annually on how many companies have applied for certification; how many have received certification; how many companies have applied for certification; and summary statistics on issues raised and resolved throughout all audits. CSSD will not disclose names of individual companies actively engaged in the evaluation process. It is up to each individual company to announce whether and when they have applied for CSSD certification.
4. How are auditors selected? And why was Bureau Veritasselected for this initial round of certifications?
- Auditing firms must meet CSSD’s accreditation standards as set out in “CSSD Auditor Accreditation Process” and CSSD Auditor Qualification” documents.
- Bureau Veritas (BV) has been a process partner in the development of the infrastructure needed to launch CSSD’s certification program. It is a global leader in risk management and the implementation and management of auditing systems, BV is exceptionally well qualified to help CSSD begin its evaluation, verification and certification process.
- All companies engaged in the auditing process will receive consistent review and assessment of their performance against the CSSD standards.
- In June, 2014 CSSD will select, through a “Request for Proposal”, an audit firm to perform CSSD audits over the following two years.
5. How does CSSD assure auditor performance?
CSSD will regularly review the output of auditors to verify that the evaluations and assessments continue to meet CSSD’s high standards. Several layers of checks are built in to this rigorous and well documented process to ensure that audits are consistently done and uphold the integrity of each of CSSD’s certifications. This includes review of each audit report prepared, as well as desk and field audits of the auditors themselves.
6. Once certified, how will companies be monitored to ensure conformity?
Companies agree to ongoing review to confirm their conformance with CSSD performance standards. These include both ongoing and annual desk and field audits following the same process used for the initial certification.
7. What happens if a company is certified and then found to be in “non-‐conformity?”
If a company is certified and in an ensuing follow-‐up audit is determined to no longer be in conformance, the company will have an opportunity to take specific corrective action. If acceptable actions are not taken after 30 days, the company will lose its certification.
8. How do these performance standards compare to regulations throughout the region?
The CSSD Performance Standards were developed to drive leading industry practices and to set a bar that goes above and beyond the regulatory requirements established by Appalachian states (specifically, Pennsylvania, Ohio and West Virginia) and the federal government. The goal is to ensure that each performance standard, on the whole, requires a level of environmental performance that exceeds the regulatory minimums established by the states and the federal government. We believe that by setting this high bar, CSSD serves as a complement to strong regulatory frameworks and can help inform ongoing efforts to ensure environmental protection. Just as operator field performance and regulatory frameworks must undergo a process of continuous improvement, so will the CSSD performance standards. With input from operators, regulators, CSSD auditors, environmental groups and other stakeholders, the CSSD Standards Committee will regularly review the performance standards – adding new standards over time, and updating the existing standards to ensure they continue to drive leading practices.
9. How are drilling services companies covered under CSSD’s standards?
The producer is certified for adherence to CSSD performance standards across all operations within the Appalachian Basin. While it is understood that producers utilize sub-‐contractors, it is the producer’s responsibility to ensure these contractors are operating in conformance with CSSD’s performance standards.
10. Is CSSD still a regional effort?
Yes, but interest in the CSSD model is gaining attention across the country, in Europe, and around the globe. The effort is serving as a model of how various interests can come together and find common ground, developing innovative solutions and processes for responsible shale development that can foster an industry culture around performance excellence.