When it’s time for your control room regulatory audit, you do not want to be in scramble mode trying to gather information and records needed for the PHMSA inspection.
It is important to have a thorough and vetted process that is followed throughout the year as a part of standard daily operations to ensure that you can easily demonstrate compliance with PHMSA regulations. Then, when it is time for the inspector to review your control room, you will be able to produce the necessary information in an organized, complete and timely fashion.
How Can I Be More Proactive Preparing for the Audit?
There are proactive steps you can take throughout the year to prepare for the control room regulatory audit. Review whether these five items are on your checklist to ensure you pass the next audit.
1. Conduct a Mock Inspection
PHMSA has made their Control Room Management Inspection Form available online. If you have not already, download the form and keep it handy to be aware of what items apply to your control room.
Instead of waiting for the PHMSA inspector to conduct a review, perform your own internal audit. Walk through the 55-page form and make notes about your pipeline operation, identify items that are satisfactory or unsatisfactory, and record changes that need to be made to your Standard Operating Procedures (SOPs).
2. Monitor Adherence to Policies and Procedures
As the control room manager, it is essential to regularly monitor whether controllers are following the policies and procedures of the control room. This includes ensuring compliance with PHMSA 49 CFR Parts 192.631 and 195.446.
Key areas of interest are the shift handover process, fatigue mitigation, hours of service, and alarm reviews. The PHMSA Inspection Form includes an entire section on fatigue risk management that you should compare against your reports. The form also includes an important item about hours of service that you need to proactively address:
“If controllers are permitted to find their own replacement among available controller staff, control room managers should still be accountable for Hours of Service (HOS) requirements and limitations.”
3. Document the Results from Abnormal Operations
The PHMSA inspector will be interested in how your control room addresses abnormal operating conditions (AOCs). Is your control room equipped to provide controllers with a heads up? Are the controllers trained on how to react? Do you have proper recordkeeping to document each AOC from start to finish?
These questions highlight the importance of training controllers on situational awareness — i.e. understanding the operating condition (normal, abnormal, or emergency). Controllers should be trained on how to recognize their environment, understand the meaning of elements in this environment, process the variables in-play, and follow a procedure to properly reconcile the incident.
It is important to meticulously document these events so that you have accurate records to present to the PHMSA inspector during the audit.
4. Implement the Latest PHSMA Rules and Regulations
Government regulation is an ever-changing entity that requires a sharp focus on how the latest rules and regulations affect the control room. Be aware of how to implement these changes in your control room. This includes:
- Understand whether the latest recommendations apply to your control room
- Implement applicable changes into your policies and procedures
- Train controllers and other stakeholders on what changed
- Monitor the results of implementing the change
- Build reports on how the changes were carried out in the control room
The reports will be essential to document how you incorporated the latest government ruling into your control room procedures and implementation processes.
5. Communicate with Your Compliance Specialist
To enhance your preparation before a control room regulatory audit, communicate with your regulatory manager (RM) to assure alignment of understanding and expectations.
The RM in your pipeline operation will be able to assist in understanding the meaning of specific regulatory requirements, then determine their applicability to your operation. This will ensure that you can identify compliance issues that affect the control room, allowing you to make proper adjustments to your SOPs.
You do not have to go at the audit alone; utilize all available resources to ensure that your control room is compliant.
EnerSys Can Support Your Control Room Regulatory Audit Prep
EnerSys provides tools through our POEMS software solution to ensure that control room managers are audit-ready. POEMS users benefit from our approach to:
- Assess the needs of their pipeline operation
- Implement policies and procedures that align with PHMSA requirements
- Train controllers on how to perform their tasks in the control room
- Refine the process through continual learning
- Manage changes to policies and procedures
- Produce reports for the control room audit
My team would appreciate the opportunity to discuss your compliance needs in preparation for a control room regulatory audit. To get started, please complete our contact form, email the team at firstname.lastname@example.org, or call us directly at 281-598-7100.