NERC CIP Program Recovery
ScottMadden helps clients develop scalable, sustainable plans for producing and maintaining organizational alignment, utility-wide governance structures, and workforce development programs to achieve NERC CIP compliance and regulatory approvals.
Full Program Turnaround
Achieved zero regulatory findings during follow-up NERC CIP audit
Comprehensive Workforce Development
Trained and engaged more than 120 employees across compliance, engineering, cybersecurity, and operations to create a more sustainable program
Program Durability
Enabled self-sustaining compliance readiness by embedding recurring tasks into a work management tool and deploying structured job plans and training across the organization
Challenge
A large electric utility received an unfavorable audit that pointed to a significant programmatic breakdown and a lack of cultural understanding of NERC CIP compliance standards. Significant gaps existed in the organization’s roles and responsibilities to provide governance and oversight for the standards; procedures were not well maintained or did not exist; and the organization relied on manual methods to document and collect evidence. Operating and technical groups did not understand the NERC CIP standards, requirements, or the implications of non-compliance. Enterprise and business unit leadership were facing tight timelines to respond to audit findings and a situation where repeat issues would not be tolerated by the regulator or the board.
Process
- Established an operating model and organization for NERC CIP compliance
- Developed and updated NERC CIP documentation, including seven technical program documents, 11 new CIP procedures, and more than seven updated procedures
- Developed more than 25 PMs and entered them into the Maximo work management tool for recurring CIP requirements; allowed management visibility to oversee ongoing CIP tasks
- Developed eight template job plans with work instructions
- Prepared and issued computer-based awareness training for more than 800 workers, totaling more than 1,200 courses completed
- Delivered CIP technical instructor-led training at medium-impact facilities, providing direct training to more than 350 workers
- Provided initial training to compliance managers and compliance analysts
- Worked with operational leaders to self-certify that they knew how to execute work
Result
- The next NERC CIP regulatory audit contained zero findings for the business unit
- Developed the program in a way that engaged more than 120 employees, and the entire organization (compliance, engineering, cybersecurity, and operations) was able to self-sustain the program
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Let’s Work Together
We don’t solve problems with canned methodologies; we help you solve the right problem in the right way. Our experience ensures that the solution works for you.