Pipeline operators face a unique challenge of ensuring that controllers and other essential staff members are prepared to identify, respond to, and resolve abnormal operating conditions.
By definition, an “abnormal” operating condition (AOC) occurs when an operation operates outside of the defined normal operating conditions. Abnormal operating conditions can happen at any time and may continue for a length of time. Without proper training, tools, and procedures, your operation could be vulnerable to increased risk.
Additionally, PHMSA implemented the Operator Qualification Rule (49 CFR Part 192, Subpart N and 49 CFR Part 195, Subpart G) to document whether employees have been “adequately trained to recognize and react” to AOCs.
To ensure adequate preparation and compliance with the OQ Rule, consider taking inventory of these three areas of your operation.
Review Your Abnormal Operating Conditions List
PHMSA is very clear that operators are “expected to develop a thorough list of AOCs, both task-specific and generic.” Additionally, the generic AOCs “should be maintained in a separate list and reviewed periodically.”
The time element of “periodically” creates room for individual application to your pipeline operation. Consider some of these events that should trigger a review of AOCs to determine if you need to make updates:
- Existing technology updated or new technology implemented
- Operations expanded to new site location(s)
- Discovery of gaps in your operation
- Introduction of new regulations since your last review
Provide Training to Recognize and React to AOCs
Training should not be limited to controllers on the frontlines of addressing abnormal operating conditions. PHMSA “strongly recommends” that “all qualified individuals be provided training in the recognition of, and appropriate reaction to, generic AOCs.” The team training requirements in particular should address AOCs.
New employees should certainly be provided training on AOCs as part of their onboarding. Also, as part of continuous learning, current employees should be provided regular training to maintain awareness of the latest situations that could affect their standard tasks.
The training should drive toward the ultimate goal of staffers being able to “demonstrate the knowledge, skill, and ability (KSA) to perform the task, but also be able to recognize and react to AOCs that the individual may reasonably be expected to encounter while performing a covered task.”
Analyze Reports and Implement Learning
In addition to reviewing the AOCs list and providing regular training, pipeline operators need to analyze incident reports and incorporate feedback to improve responses to AOCs.
The goal of conducting this review is to verify that controllers and other personnel are correctly responding to abnormal operating conditions and to determine if there are gaps in your operation that need to be addressed.
A gap could be as simple as more effective communication between controllers and other control room personnel involved in abnormal operating conditions to a more extensive gap that requires a new policy or procedure.
Overall, your review should satisfy the OQ Rule requirement to “ensure that the AOCs identified and used in evaluating individuals are current and representative of those that could reasonably be anticipated during performance of covered tasks.”
Consider the POEMS Alarm Management Tool to Enhance Response to AOCs
As part of the POEMS software suite, EnerSys created an AOC log within the CRMgr Logbook tool to support pipeline operators in their AOC response capabilities and adherence to PHMSA regulations.
The CRMgr tool helps operators retain awareness of AOCs across shifts and to manage the resolution of AOCs. The tool provides controllers with visibility to respond, record the results of each event, and create a path to identify and implement lessons learned.
The benefits of implementing this tool include:
- Create alarm response sheets to guide controller response.
- Improve response time to Plan, Do, Check, and Act.
- Analyze the results of each AOC event to improve operational efficiency.
- Generate monthly reviews and reports that comply with PHMSA regulations.
To schedule a POEMS demo or discuss how we can enhance your response to abnormal operating conditions, please complete our contact form, email our team at sales@enersyscorp.com, or call us directly at 281-598-7100.