While it would be ideal for controllers to follow the Hours of Service (HOS) plan every time during each shift in your control room, there will inevitably be exceptions or deviations.
The issue is that the HOS limitations for controllers are complex and do not fit every operation. You may feel frustrated trying to constantly adjust the schedule to avoid the last resort of HOS deviations.
Fortunately, the PHMSA CRM Rule makes provisions for “emergency deviations” when a controller needs to exceed the allowable number of hours worked during their shift or over a concurrent series of shifts to ensure safe operation of the pipeline system.
However, the pipeline operator is responsible for capturing HOS deviations in order to minimize the frequency of occurrences and to provide fatigue mitigation plans for the controller(s) impacted in the event of a deviation. Ultimately, capturing the HOS deviations is critical for mitigating fatigue risk and for compliance purposes.
Capture Hours of Service Deviations
PHMSA makes it clear in their FAQs that operators need to “maintain documentation that demonstrates any deviation from the maximum limit on controller hours of service (that) was necessary for the safe operation of the pipeline facility.”
Your documentation should include the cause of the variance and what steps were taken to mitigate the risk of fatigue. PHMSA is looking for operators to answer for whether you could have avoided the deviation and verify that this is not a habitual issue in your operation.
PHMSA also expects operators to document the deviation “at the first practical moment after the event” so that pertinent details are immediately captured. Answering the following questions will allow you to satisfy an inquiry:
- What was the reason for the exception?
- Why was the exception needed for the safe operation of the facility?
- What shifts were impacted by the deviation? (specific date and time)
- Which controllers or employees were affected?
- What was the work schedule before and after the exception?
- Were there any other fatigue risks associated with the exception?
- What countermeasures were employed to offset additional fatigue risks?
- Who approved the deviation — and at what time?
- Who will be reviewing the deviation — and at what time?
In addition to satisfying an inquiry from PHMSA, your operation is also expected to optimize fatigue management to reduce these occurrences.
Manage the Hours of Service Deviations
There are three critical components of managing Hours of Service deviations, according to the CRM Rule FAQs:
- Operators are expected to plan for anticipated emergency deviations in advance and evaluate the potential for additional risks of controller fatigue.
- If a deviation sets off a chain reaction of additional risks, you are expected to implement a corresponding plan for countermeasures and demonstrate how those measures offset the potential new risks.
- If your operation experiences the same type of deviation on a frequent basis, you are expected to review and update policies and procedures to minimize future occurrences.
To manage HOS deviations, operators are encouraged to create a form, audit response sheet, or a checklist that outlines the actions and decisions involved in a deviation.
- What events led up to the deviation?
- What actions were taken?
- What lessons did we learn upon review of the deviation?
The information gathered from your internal review is invaluable for continuing to reduce the number of deviations over time and remain compliant with the PHMSA guidelines.
EnerSys Simplifies the Process of Capturing and Managing HOS Deviations
EnerSys makes it easier for control room managers to manage the risks associated with controller fatigue. Within the POEMS Control Room Management (CRM) Suite is our FatigueMgr software tool that includes two critical components:
- Workload Analysis to evaluate each shift in real-time and analyze workload by employee or shift.
- HOS Scheduler to track hours of service, schedule controller shift times, and document off-shift hours.
The FatigueMgr tool enables control room managers to communicate vital fatigue mitigation tasks to the controller, document Hours of Service deviations, produce relevant reports to satisfy PHMSA inspections and audits, and better manage HOS to reduce the frequency of variances.
To see our software in action, we would like to schedule a brief, no-obligation demo with your team. To get started, please complete our contact form, email our team at firstname.lastname@example.org, or call us directly at 281-598-7100.