Preparation for a PHMSA audit does not happen overnight. In fact, it is a year-round approach that is tested when the PHMSA inspector knocks on your door.
Today’s pipeline operators need to be thinking about how to achieve natural compliance. “Natural Compliance” is the result of implementing procedures and systems in a way that as the work occurs, the compliance recordkeeping happens automatically and in the background — without impacting work efforts.
For example, in the pipeline control center, it’s ensuring that controllers, other control room personnel, control room managers, field personnel, SCADA/IT, operations, and the regulatory team are all on the same page about following policies and procedures. Said another way, they use systems to support work execution, and those systems record the activity, while ensuring alignment with regulations when performing tasks.
When each team member performs their job in the most effective, efficient, and safe manner — while the system simultaneously documents those activities in alignment with the policy and the procedure — then the overall objective of effective operation is achieved. That is natural compliance. The PHMSA audit is then a test that verifies that you achieved compliance naturally.
How To Ensure You Are Positioned for the PHMSA Audit
We believe there are seven elements that support compliance:
- Four elements are focused on adherence to PHMSA guidelines or industry regulations.
- Three elements are focused on the responsibilities of the pipeline operator to align with PHMSA expectations.
1. Governing Documents
The Code of Federal Regulations sets the standard for transmitting product through pipelines.
For example, CFR 192 governs the transmission of natural gas through pipelines and CFR 195 governs the transport of hazardous liquids by pipeline.
The regulations are administered by PHMSA and they prescribe safety requirements for controllers, control rooms, and SCADA systems used to monitor and control pipeline operations.
These governing documents set the standard for safe and effective transport of product by pipeline.
2. Industry Standards & Best Practices
The next layer of external adherence are industry standards and best practices. Organizations such as API, ISA, and AGA have gathered information on best practices for supporting safe and effective pipeline transport.
Many of their best practices are incorporated by reference into the governing documents such as CFR 192 and CFR 195. When an industry standard or best practice is incorporated into an official PHMSA document, pipeline operators need to take notice of the reference to ensure alignment.
3. Reference Documents
PHMSA has released documents such as Audit FAQs that act as a support piece for pipeline operators to pre-test the compliance of their operation.
The PHMSA Audit FAQs are not designed for you to review the answers, then work backwards to adjust operations in accordance with the FAQs. That would be unnatural compliance.
To achieve natural compliance, your operation should already be in the process of complying with governing documents, industry standards, and internal policies and procedures, then using the PHMSA Audit FAQs to validate activity. The order is important to support natural compliance.
4. Audit Protocol
Another important external element to prepare for the audit is the PHMSA Audit Inspection Form.
PHMSA has made public two sets of gas distribution question forms, one liquid distribution question form, one LNG question form, and one underground natural gas storage question form.
Your team should periodically review the question sets — along with the PHMSA Audit FAQ — to ensure that you understand how the audit will work, what will be required, what will be asked, what documents you need to produce, and how you can best prove natural compliance.
There is a line of demarcation that moves audit preparation from the PHMSA/regulatory side to the pipeline operator side of the equation.
The first important element for operators is validating your policies. For example, the Control Room Management Plan (CRMP).
The CRMP is the governing document that dictates actions in the control room. Operators need to be able to demonstrate that controllers, managers, and other personnel understand the CRMP, follow the CRMP, and record their actions in alignment with the CRMP.
Policies leads into procedures, which dictate how your team will act in accordance with the policy.
Typical documents that fall under the procedures category include Standard Operating Procedures (SOPs), Operations & Maintenance Manuals, and your Emergency Response Plan.
- SOPs capture best practices and proper decision-making to adhere to the policies.
- The O&M procedure manual should align with the CFR 192 and CFR 195 requirements for operations, maintenance, and emergencies.
- The Emergency Response Plan should capture how your operation will respond to abnormal and emergency operating conditions.
7. Forms & Evidence
The final piece of the puzzle to prepare for a PHMSA audit is to have completed forms, templates, and signature pages that document adherence to external regulations and internal policies and procedures.
The issue for many operators is reliance on pen and paper recordkeeping that leads to human error or illegibility issues. Other operators rely on fragmented, outdated software applications that do not talk to each other to produce the proper documentation.
Work with EnerSys to Support Compliance
EnerSys Corporation makes it easy to produce the proper records and validate compliance through our Control Room Management (CRM) software suite.
The individual modules in our software suite gather, capture, record, and present data from multiple sources in the control room. The data is then used in our ComplyMgr module to ensure that operators are in compliance.
- Traces operator procedures to audit protocols.
- Serves as data repository for relevant documents.
- Links internal procedures to external federal regulations and industry standards.
- Simplifies tracking regulatory changes to determine if policies & procedures require updating.
Overall, our software reduces the cumbersome process of preparing for a PHMSA audit. We help operators achieve natural compliance where every-day, day-in/day-out activity in the control room and the overall operation naturally leads to compliance.
Talk to our team about scheduling a phone call or an educational demo on our software suite. We would appreciate the opportunity to provide a compliance overview that captures how we can best support your operation.