One of the most important safety aspects of control room management is performing accurate point-to-point (P2P) verification between the control room and the field. P2P verification is also important from a compliance standpoint because of the scrutiny during a PHMSA audit.
The key for pipeline operations is blending the needs of P2P verification for pipeline operations, safety and compliance purposes. We call this achieving natural compliance — where compliance happens naturally as routine work is performed and the systems automatically create records to support the audit.
Ultimately, the burden falls on control room managers and operators to ensure that pipeline control room procedures are aligned with operations, safety, and compliance requirements. This ensures that the activity in the control room happens naturally in a safe and compliant manner.
Consider This Checklist Review of P2P Verification
A good starting point for ensuring natural compliance is performing a checklist review of these elements involved in point-to-point verification.
1. Are Your Procedures Aligned with the CRM Rule?
The PHMSA Control Room Management Rule (CRM Rule) provides detailed guidance on how to ensure that internal procedures align with external safety guidelines.
Specifically, the CRM Rule FAQs clarify that operators should develop point-to-point verification procedures “with a view toward the most rigorous and all-encompassing verification that is practical.”
- Rigorous. Be thorough. Leave no stone unturned reviewing your control room procedures to ensure that you are focused on safety in a naturally compliant manner.
- All-encompassing. Review your procedures end-to-end. Find the starting point in the field and trace back to the actions taken by a controller to ensure there are no gaps.
- Practical. PHMSA makes provisions for operators to perform verification within the confines of their budget and size. Be conscious of the effort and resources required to verify alignment with the CRM Rule.
2. What is the Quality of Your Communication?
Your internal procedures should outline the process for communication between the control room and field personnel or field devices.
- How are controllers communicating with field personnel performing on-site checks and reviews? How is this communication being recorded?
- How are controllers communicating with field devices, and vice versa, to understand what’s happening in the field? How is this communication in the SCADA system being recorded?
Procedures should outline the steps for initiating communication, channels for having the actual communication, how the communication is being recorded, and what the outcomes were from the communication.
When you perform a checklist review of the communication aspect of P2P verification, identify whether there are gaps in communication. Address these gaps by having conversations and training to ensure that personnel understand their role in performing work that ensures safe operations.
3. Are You Meeting the Requirement for Adequate Information?
The PHMSA Control Room Management Rule (CRM Rule) outlines a critical concept in point-to-point verification: adequate verification records.
Specifically, the CRM Rule FAQs provides guidance on what adequacy looks like: “The requirement is to verify all safety-related points in the SCADA system. This would also include calculated (software generated) points that are safety-related. Safety related points often, but do not necessarily, have alarms associated with them.”
PHMSA identified points that may be considered safety-related that should be verified. The list includes main line valves, pressure and flow rates, tank levels, PLC/RTU communication status, emergency shutdown status, detectors, power supply indicators, and more safety points.
Then, it’s the responsibility of the operation to verify these factors:
- The actual physical location and sequence among other devices.
- The data captured in the SCADA system and used to present information to controllers.
- The accuracy of control or alarm functions from a point in the field.
4. Are You Keeping Reliable Records of P2P Verification?
Your system is required to confirm certain inputs and outputs from each field instrument. You are also required to verify the reliability of the information captured in the SCADA system and presented to the controller.
Furthermore, PHMSA expects very detailed records to be captured to ensure safety:
- Document actual field parameters and corresponding SCADA display information.
- Record the dates and names of individuals involved in verification.
- Check alarm set-point values.
The details help your operation demonstrate “thoroughness and authenticity” when validating that the control room following proper procedures to perform P2P verification.
5. Are You Testing P2P Verification?
Another critical checklist review is testing whether your team is equipped to perform point-to-point verification in the event of a SCADA system failure or during downtime performing a SCADA system update.
PHMSA clarified in the CRM Rule FAQs that the point is to ensure that your operation can “implement backup manual operations” to continue operating safely.
PHMSA further adds that the test and verification process “must be designed to confirm that the operator has adequate personnel, procedures, processes, communications infrastructure, and manual command-and-control capabilities to assure safe, reliable operations, and pipeline integrity when operating manually.”
What should be included in your testing?
- Verify sufficient and timely deployment of personnel to the field.
- Ensure that personnel can adequately operate equipment and monitor pipeline integrity.
- Verify performance of control room communication.
- Exercise critical decision-making processes.
- Authenticate a representative sampling of the processes and equipment to be used during backup operations.
Proving that your operation is fully capable of remaining operational during SCADA downtime is important for passing an audit. The intent, as stated by PHMSA, is to ensure that “communication plans will be effective during an actual emergency involving loss of all SCADA system functions.”
Work with EnerSys to Support P2P Verification
Whether you recently faced an audit or have an upcoming audit, point-to-point verification should be at the top of the list for review.
Overall, though, P2P verification should be viewed as a safety issue, not just a compliance issue. When you focus on safety first, then compliance happens naturally as a function of following the pipeline control room procedures.
We would appreciate the opportunity to talk to your team about supporting P2P verification. Whether you need assistance with procedure alignment, communication, adequate information records, reliable recordkeeping, or testing verification, we are available to help on a consulting basis.
Additionally, we offer software in our POEMS CRM Suite specifically designed for point-to-point verification. Our PointMgr module is a valuable add-on to the CRM Suite that streamlines the verification process, creates proper documentation, and stores the results to be retrieved during an audit.
Talk to our team today about scheduling a control room consultation or an educational software demo of the PointMgr module. We would appreciate the opportunity to help you assess the needs of your control room to achieve compliance naturally.