Follow us on LinkedIn and @RFirst_Corp onTwitter #RFWorkshop Forward Together • ReliabilityFirst
Understanding the Enforcement Process Patrick O’Connor – Counsel, RF Maxwell Reisinger – Associate Counsel, RF
Objectives Gain a better understanding of the life cycle of a violation Provide clarification on each step in ReliabilityFirst’s Enforcement Process • Explain and define commonly used terms in the Process Give tips for effective Self-Reports, Mitigation Plans, and Evidence Verification submissions 3 Forward Together • ReliabilityFirst
Enforcement Philosophy Message • Focus on reliability through a commitment to continuous improvement, strong management practices, and effective compliance programs Actions • Incent desired behavior ‒ Penalty offsets ‒ Favorable processing treatment (e.g., Compliance Exception) • Discourage undesired conduct ‒ Monetary penalties ‒ Sanctions ‒ Enhanced compliance monitoring 4 Forward Together • ReliabilityFirst
Lifecycle of a Violation 5 Forward Together • ReliabilityFirst
PV Identification & Screen 6 Forward Together • ReliabilityFirst
Risk Assessment & Mitigation Review 7 Forward Together • ReliabilityFirst
Disposition 8 Forward Together • ReliabilityFirst
Ineffective Self-Report Example 9 Forward Together • ReliabilityFirst
Effective Self-Report Example 10 Forward Together • ReliabilityFirst
Ineffective Mitigation Plans 11 Forward Together • ReliabilityFirst
Tips for Effective Mitigation Plan Milestones 12 Forward Together • ReliabilityFirst
Tips for Evidence Submissions Quality of Information • Start with a narrative description • Organization is key • Clarity • Focus on two-fold task of mitigation Overall Strategy • Opportunity to improve overall reliability, security, and resilience 13 Forward Together • ReliabilityFirst
Questions & Answers Forward Together ReliabilityFirst 14 Forward Together • ReliabilityFirst
Recommend
More recommend