2024 PHMSA CRM Enforcement Actions

Initial Trends and Insights

Within the control room, controllers leverage technology and established procedures to monitor, analyze, and respond to evolving conditions, ensuring safe and reliable pipeline operations. The Pipeline and Hazardous Materials Safety Administration (PHMSA) plays a vital role in regulating and enforcing CRM standards, holding operators accountable for maintaining the highest levels of safety and operational integrity. This blog post offers an initial examination of the 2024 PHMSA CRM enforcement actions, including an overview of violation severity and a breakdown by sections of the CRM Rule. In our next blog post, we’ll dive deeper into the enforcement actions taken in 2024 and determine whether there are any significant trends or insights we can take away.

135 Enforcement Actions Identified Related to CRM in 2024

Overall Enforcement Trends

PHMSA’s 2024 enforcement activities related to Control Room Management reveal several noteworthy trends. While the total number of enforcement actions provides a general metric, the types of notices issued offer valuable insight into PHMSA’s regulatory approach. A substantial portion of enforcement actions in 2024 involved Notices of Amendment (NOA). This prevalence of NOAs suggests a focus on corrective action and collaborative engagement with operators to achieve compliance. Rather than immediately imposing penalties, PHMSA appears to prioritize the identification and remediation of deficiencies, reflecting a commitment to proactive safety enhancement.

CRM Enforcement Year-Over-Year

	2024	2023	2022	2021
Section A	10	13	66	25
Section B	24	13	25	14
Section C	25	33	38	22
Section D	8	7	8	11
Section E	33	23	50	37
Section F	6	4	11	3
Section G	4	2	5	3
Section H	19	23	25	38
Section I	3	1	1	0
Section J	3	11	11	10
Total	135	130	240	163

Over the past few years, there has been a significant decline in total values, dropping from a peak of 240 in 2022 to 130 in 2023, with only a slight recovery to 135 in 2024. The most dramatic reduction occurred in Section A, which fell sharply from 66 in 2022 to just 10 in 2024. Section H also saw a steady decline from 38 in 2021 to 19 in 2024. However, some sections experienced year-over-year growth, including Section B, which nearly doubled from 13 in 2023 to 24 in 2024, and Section E, which rose from 23 in 2023 to 33 in 2024 after a previous drop. While 2024 shows some signs of recovery in select areas, overall levels remain well below 2022, indicating a continued downward trend.

Key Areas of Regulatory Focus

An analysis of the specific sections of the CRM regulations cited in enforcement actions highlights key areas where operators appear to encounter challenges.

Section (c) – Providing Adequate Information

A significant number of violations pertained to Section (c) of the CRM rule. This section addresses the fundamental requirement for operators to equip controllers with the necessary information, tools, processes, and procedures to execute their responsibilities effectively. It encompasses critical elements such as point-to-point verification of SCADA systems and the regular testing of internal communication plans. The high incidence of violations in this domain suggests that operators may face difficulties in fully implementing and maintaining these essential safeguards. Rigorous point-to-point verification ensures that the information presented to controllers accurately reflects the real-time status of the pipeline. Similarly, robust communication plans are necessary for safe manual operation during periods of SCADA system outage or emergency scenarios.

Section (b) – Roles and Responsibilities

Another area of notable enforcement activity involved Section (b), which focuses on the definition of roles, responsibilities, and qualifications for control room personnel. These violations may indicate challenges related to documentation, training, or a lack of clarity regarding lines of authority within control room environments. Clearly defined roles and responsibilities are foundational to a well-functioning control room, ensuring that controllers understand their duties and are empowered to act decisively under a range of operating conditions.

Section (e) – Alarm Management

Section (e), which governs alarm management practices, also exhibited a high number of violations. This section addresses vital aspects of alarm handling, including the systematic review of alarm operations, the identification of off-scan points, the verification of alarm set-points, and the effective management of controller workload to prevent alarm overload.

Next Steps

This analysis provides an initial overview of the 2024 PHMSA Control Room Management enforcement data. A more comprehensive evaluation, incorporating a detailed review of individual violation data and a comparative analysis with data from previous years, is planned. We invite you to subscribe to our monthly newsletter for future updates and more focused discussions on specific areas of compliance.

In the interim, we strongly encourage pipeline operators to proactively assess their CRM programs, with particular emphasis on the areas highlighted by these enforcement trends. By prioritizing these key areas and continually strengthening their CRM programs, pipeline operators can enhance safety performance, mitigate risk, and ensure adherence to PHMSA’s regulatory requirements.

Contact us now to learn more about the ways that EnerSys can help.