With the new versions of CIP-004(-7) and CIP-011(-3) standards around the corner, some registered entities may be considering early adoption. If this is your entity, then you may have the question as to what this looks like in the MRO region.
If you are looking to opt in for early adoption of a revised standard, the first step is to notify MRO. An email to [email protected] should be sent with the following information included:
- Standard for early adoption including version
- Date requested for early adoption
- The date prior to the standard’s effective date when the registered entity wishes to begin its early compliance
- Registered entity contact(s) for any questions
- Note that the Primary Compliance Contact (PCC) needs to be included in all communications
An acknowledgement of the notification will be sent to the registered entity following MRO’s review of the request, which is expected to occur within one week of receipt. MRO’s acknowledgement represents formal notification that the registered entity is subject to compliance with the revised standard as of the early adoption date provided in the registered entity’s notification.
Note that self-reports and self-logs are only able to be submitted for currently enforceable standards within Align. Early adopters submitting a self-report or self-log against the standards or requirements as part of early adoption should indicate on the submission that the registered entity is an early adopter.
– Jess Syring, MRO CIP Compliance Manager