The Pipeline and Hazardous Materials Safety Administration (PHMSA) publishes an annual summary of enforcement actions taken against pipeline operators whose assets are subject to federal jurisdiction.
The PHMSA Enforcement Actions report represents a range of enforcement case types that PHMSA brings against pipeline owners and operators. Within each of these enforcement actions are categories of findings and violations.
Each year, we put together a thorough overview of the findings where we focus on issues related to Control Room Management, namely findings and violations related to the Control Room Management Rule (49 CFR 192.631 for the transport of natural gas and 195.446 for the transport of hazardous liquids).
Our goal in reviewing these cases is to shed some light on what PHMSA emphasized in the previous year and to bring attention to common issues the control room experiences. Ultimately, we want to help you begin the process of identifying gaps in your control room management plan and put you on a path to achieving Natural Compliance.
In our research of the 2022 Enforcement Actions, we identified a multitude of cases where a violation pertained to Control Room Management. The issues spanned a wide range of sections in the CRM Rule.
In this article, we will cover:
- An overview of the 2022 PHMSA Control Room findings broken down by
- CRM Rule Section
- Level of enforcement
- Particular areas of emphasis
- Your Operation’s Starting Point
In future entries in this series, we’ll break down each of the sections in greater detail to discuss implications as well as solutions to address the findings. Subscribe to our monthly newsletter to see when new articles are released, and contact us for more information on the solutions EnerSys provides.
Summary of Control Room Findings
CRM Rule Breakdown by Section
In reviewing the summary of PHMSA Enforcement Actions, we found a diverse range of findings and violations related to the CRM rule. In our research, we identified 240 related to the CRM Rule:
- A – General Requirements: 66 findings
- 51 NOA
- 10 Warning Letter/Item
- 2 Proposed Compliance Order
- 3 Proposed Civil Penalty
- B – Roles and Responsibilities: 25 findings
- 20 NOA
- 1 Warning Letter
- 3 Proposed Compliance Orders
- 1 Proposed Civil Penalty
- C – Adequate Information: 38 findings
- 14 NOA
- 12 Warning Letter/Item
- 8 Proposed Compliance Order
- 4 Proposed Civil Penalty
- D – Fatigue Mitigation: 8 findings
- 6 NOA
- 1 Warning Letter
- 1 Proposed Compliance Order
- E – Alarm Management: 50 findings
- 32 NOA
- 5 Warning Letter
- 8 Proposed Compliance Order
- 5 Proposed Civil Penalty
- F – Change Management: 11 findings
- 5 NOA
- 2 Warning Letter
- 2 Proposed Compliance Order
- 2 Proposed Civil Penalty
- G – Operating Experience: 5 findings
- 3 NOA
- 1 Warning Letter
- 1 Proposed Compliance Order
- H – Training: 25 findings
- 16 NOA
- 4 Warning Letter/Item
- 2 Proposed Compliance Order
- 3 Proposed Civil Penalty
- I – Compliance Validation: 1 finding
- 1 NOA
- J – Compliance and Deviations: 11 findings
- 1 NOA
- 5 Warning Letter/Item
- 3 Proposed Compliance Order
- 2 Proposed Civil Penalty
After reviewing and compiling all of the cases related to the Control Room, we found that almost half of all instances arose from Section A (General Requirements) or Section E (Alarm Management). While Alarm Management and Adequate information (Sections E & C respectively) were among the most-cited, many of the findings in Section A pertain to the Control Room. When reviewing the report, it’s important to parse out all of the reported findings in Section A to the appropriate elements – something we will dissect in a later entry in this series.
CRM Rule Breakdown by Level of Enforcement
Some minor findings resulted in warning letters or notices of amendment, but other violations resulted in proposed compliance orders or proposed civil penalties. Of the 240 individual CRM Rule findings and violations, these break down as follows:
- 41 issues identified in Warning Letters
- 149 issues identified in Notices of Amendments
- 30 issues identified in Proposed Compliance Orders
- 20 issues identified in Proposed Civil Penalty Orders
To better understand the implications of the various enforcements, read the PHMSA Enforcement Program overview from PHMSA for a breakdown of the program objectives and enforcement mechanisms.
Some of the findings in 2022 resulted in PHMSA issuing Proposed Compliance Orders and Civil Penalties to some operators. Over $1.3 million can be attributed to civil penalties levied against operators in 2022.
Your Operation’s Next Move
Our focus at EnerSys is helping your operation achieve Natural Compliance, where compliance happens as a result of the proper execution of the policies, processes, and procedures you have in place. This means that your operation is organically operating in accordance with state and federal pipeline regulations, specifically the PHMSA CRM Rule (49 CFR 192.631 and 195.446 Control Room Management).
EnerSys can help you get started with our Control Room Audit Services. We can perform a policy/implementation gap analysis to see how your policies and procedures line up with your execution to determine whether you are on the right path to Natural Compliance. We’ll work to close gaps and provide recommendations on how to bring your control room into compliance with PHMSA requirements.
Our next entries in the PHMSA Enforcement Actions Series will break down the control room findings by each section of the rule and include:
- Lessons Learned from 2022 Control Room Findings
- EnerSys Solutions for 2022 Control Room Findings
- How to Get Started on Your Path to Natural Compliance
EnerSys can help you with a pre-audit review. We can help determine the effectiveness of your current CRMP and help you start to close identified gaps. Call us at 281-598-7100 to speak with EnerSys General Manager Ross Adams or VP of Business Development Dale Schafer. You can also contact us via email at sales@enersyscorp.com or complete our website contact form to get started.
The mission of the Pipeline and Hazardous Materials Safety Administration (PHMSA) is to protect people and the environment by advancing the safe transportation of energy and other hazardous materials that are essential to our daily lives. PHMSA develops and enforces regulations for the safe operation of the nation’s 2.8 million-mile pipeline transportation system and the 1.2 million daily shipments of hazardous materials by land, sea, and air. Please visit http://phmsa.dot.gov or https://twitter.com/PHMSA_DOT for more information.