Pipeline operators can expect to have their control room audited at some point in the next three years, which highlights the importance of control room audit readiness.
Following a recent AGA conversation with PHMSA, AGA communicated to its members that PHMSA plans to launch a new control room management inspection initiative beginning in 2020. PHMSA stated they will be calling operators in their database to gather information about control rooms.
This preliminary step is to help prepare for the inspections, not to collect data. Once the information is gathered, PHMSA will begin the process of inspecting control rooms in First Quarter 2020.
This development highlights the importance of audit readiness and being able to validate activity in the control room when the time arrives for an inspection.
What to Expect from the PHMSA 3-Year Plan
PHMSA is contacting each operator in their database to gather information about their operation, control room, and the control room size. These calls are designed to help PHMSA understand the scope of their initiative and strategically plan for inspecting each control room within the next three years.
Then, once the information is gathered, PHMSA will be contacting operators to schedule times to come on-site for a control room audit. By the time you read this information, you may have already been contacted by PHMSA to gather information and possibly had your inspection scheduled.
During the inspection, PHMSA will be utilizing their standard inspection guide, “Control Room Management Inspection Form.”
One of the main points of emphasis is that PHMSA wants to review and evaluate each operator’s Control Room Management Plan (CRMP). Even if PHMSA has already reviewed your CRMP and audited your control room, you can expect another comprehensive review in the next three years.
Finally, PHMSA is forming a control room team with experts in control room operations to conduct these audits.
The inevitability of a control room audit and the industry-wide emphasis on implementing Pipeline Safety Management Systems (Pipeline SMS) highlights the importance of control room audit readiness.
How to Ensure Control Room Audit Readiness
For control room managers and supervisors, we recommend three critical steps to ensure that your control room is ready for a PHMSA audit:
- Ensure compliance is happening naturally in the control room.
- Ensure recordkeeping is happening as tasks are being completed.
- Ensure software is producing accurate records to satisfy an audit.
1. The Importance of Natural Compliance
Natural compliance is a function of having the right team culture where control room personnel perform their tasks in a way that is naturally compliant with internal policies and procedures and external recommended practices.
In other words, control room personnel are “not performing for the test.” Rather, they are organically performing their work and completing assigned tasks in the natural course of a safe and efficient pipeline operation.
This leads to two important questions:
- Are your policies and procedures aligned with the industry standards?
- Do controllers and other control room personnel naturally follow policies and procedures?
As you can see, there are layers involved in creating a culture of natural compliance.
First, your policies and procedures need to be aligned with the industry standards. Once that box is checked, then you need to ensure that your personnel are trained on how to follow the policies and procedures. This includes a cultural element of explaining the “why” behind the importance of following policies and procedures, which drives toward creating new attitudes and behaviors responding to your internal guidelines.
Once the second box is checked on having the right team culture that supports adherence, then control room personnel will begin naturally complying with policies and procedures as part of their normal course of task work in the control room.
Completing these steps will help your control room prove compliance. This also leads into the next element of proper recordkeeping of the completed tasks.
2. The Importance of Recordkeeping
Control room managers need to ensure proper recordkeeping and tracking as tasks are happening naturally in the control room.
This includes electronically logging these critical actions in the control room:
- Shift Handover
- Incident logging
- Frequency of Abnormal and Emergency alarms
- Controller response times (ensuring adequate vigilance time)
- Hours of Service scheduling
- Fatigue Mitigation efforts
- Point to Point verification and communication
The challenge for many operators to ensure control room audit readiness is producing accurate records. Perhaps you have different software tools for each area of control room management, you utilize software applications that are incompatible with each other, or you use some form of manual recordkeeping in the process.
Records are only valuable if they can create meaning to someone reviewing the records. If you cannot produce accurate, timely, or reliable records to a PHMSA inspector, you should consider a different approach to the software you utilize in the control room.
3. The Importance of Software to Produce Records for an Audit
The solution we recommend is one off-the-shelf software suite that is specifically designed for control room management and is linked up to your activity in the control room to record activity as it happens. This means records are immediately produced, preventing delays or lost records.
Having one software solution ensures that all records are housed in a centralized database. This solves problems in a typical set-up where some records are stored in one software application such as SharePoint and other records stored in another application, making it difficult to link up data to produce desired records.
One software suite allows you to quickly produce requested records to satisfy the PHMSA inspector’s request.
Our company delivers the optimal solution for control room managers, the POEMS Control Room Management Suite (CRM Suite). The holistic nature of our CRM Suite ties together every critical aspect of control room management — alarm management, fatigue mitigation, point to point verification, compliance support, and audit readiness.
We built the CRM Suite for interoperability, where each module in the CRM Suite works in unison to produce timely, accurate, and reliable reports. Because of the advanced nature of our software suite, the CRM Suite goes further by producing reports that exceed the PHMSA reporting requirements to validate activity in the control room.
To ensure that your control room is ready for an audit, talk to our team about building a plan to achieve compliance naturally. Or, talk to us about how to migrate to the POEMS CRM Suite. We would appreciate the opportunity to discuss our software and support with your team. Contact us directly on our website, via email at firstname.lastname@example.org, or by phone at 281-598-7100.