Originally published March 19, 2020. Revised March 21, 2020 | Russel W. Treat
In the 48 hours since first writing this article, we continue to get new information. Key changes since the last update are the additions of guidance for business continuity through the pandemic. We will continue to update this article to support those working to meet the challenges presented by the COVID-19 health crisis.
The 24/7 pipeline control room has unique constraints and requirements to support pipeline operation and safety. By their nature, control rooms teams generally work together in relatively confined spaces, share workspaces, and often have a constant stream of stakeholders and support personnel moving throughout the control center.
While this information generally applies to personal hygiene, workspace hygiene, social distancing, and continued operations for the 24/7 control room, the information presented below can be used to support decision making for other critical operations.
The Reality of COVID-19
As we have collectively become educated on COVID-19, there are two critical reminders that we would like to point out:
There are a substantial number of people who have been or will be infected that will never have symptoms. Some individuals, such as the high-profile case of NBA star Donovan Mitchell, did not even feel sick.
Then, on the other end of the scale, other individuals will have very severe symptoms, such as the elderly, individuals with underlying health conditions, and other at-risk individuals.
Because COVID-19 can affect anyone and can result in a broad spectrum of outcomes, it is imperative for individuals to take extraordinary precautions.
In the case of the 24/7 pipeline control room, there is a unique challenge of preventing the spread of COVID-19 in a shared workspace environment when individuals are co-located with others. This risk is combined with the need to ensure continuous, safe 24/7 operation of the pipeline systems, which is a critical part of the nation’s infrastructure supporting our ability to respond and recover.
Preventing the Spread of COVID-19 in the Control Room
The World Health Organization provided “Advice for the Public” to help prevent the spread of COVID-19. Further, the U.S. Department of Labor has published a document providing guidance on preparing workplaces for COVID-19. To the best of our ability, we have summarized these recommendations as they apply to the pipeline control room.
1. Focus on hygiene. Cleanliness is of utmost importance. This includes control room personnel washing their hands regularly for 20 seconds, using hand sanitizer, and practicing other good hygiene habits. The control room should consider deep environmental cleaning and disinfection of work areas, common areas, and access points daily. In addition, each controller should implement personal practice to be safe and resilient.
2. Use Lysol on shared surfaces. We recommend that each member of the control room take personal responsibility to spray their work surface upon start and end of shift. Lysol is a good preventative to kill viruses that live on surfaces. When used, Lysol should be sprayed lightly and allowed to let dry. Do not wipe up. Pay particular attention to the keyboard, mouse, and phone.
3. Use rubber gloves. You have probably heard or read the advice to avoid touching your face or skin during this time. One way to reduce the risk of infection is to use rubber gloves when performing cleaning activities or wiping down surfaces. This way, you can use and discard the gloves after each use, helping reduce the risk of the virus entering through your skin. As an additional precaution, gloves can be used throughout the shift to prevent transmission from surface to skin. Of course, this benefit is lost if you touch your face.
4. Stagger shifts or workplace environments. We recommend splitting up teams and using back-up control rooms to prevent the spread of COVID-19 to the entire team. Consider placing one team in the primary control room and another team in the backup control room. This way, if one team gets infected, only half of the workforce is out of commission. If possible, you might consider creating additional separation between workstations.
5. Minimize controller physical interactions. We recommend limiting control room access only to controllers, and those with a critical need to share the same space. Anyone that can interact remotely should do so, even the control room manager and SCADA support personnel.
6. Consider UV lights. Ultraviolet lighting can act as a disinfectant for viruses and bacteria. For example, UV lighting is used by hospitals in surgical rooms to help kill bacteria, viruses, and other contaminants. The World Health Organization does not recommend using UV lighting on skin, though, as this can serve as an irritant. Only use on surfaces.
Business Continuity Considerations
When developing your control room business continuity plan, consider the risks to continued operation, and the action required.
- Preparation. What are the first steps to prepare for the possibilities below?
- Controller Sequestration. What happens if you are required to sequester the control room team? In this case, you may need to bring in extra food, provide sleeping arrangements, showers, and so forth.
- Facility Lockdown. What happens if the landlord closes the building, and your team does not have access to its control room due to contamination?
- Work from Home. What is required technically, procedurally, and training-wise should controllers be required to work from home?
- Controller Exposure. What actions are required if a controller is exposed? How is the response different if that exposure occurs at work versus outside of work?
- Third-Party Access. What actions are required when a person other than the controller requires access to the control room, such as SCADA, IT, and cleaning personnel?
The information contained in the following is derived from research and conversations with control rooms already implementing plans. Each control room operation is unique, and should adapt this information to make it appropriate to their needs.
A first step is to request that all controllers create an inventory of the items they might require should the facility be sequestered (isolated from outside contact) for an extended period. Things such as personal hygiene items, prescriptions, sleep apnea devices, eye wear, etc. that are required should the facility be isolated for an extended period.
The second step is to create a list of those items that would be required for extended operations and room sanitation without easy access to immediate resupply. Items such as toilet paper, tissues, paper towels, wipes, Lysol, and so forth.
The third step would be to create a list of those specialty items required to maintain strict hygiene in the control room. Special cleaning supplies and special PPE such as gloves, masks, goggles, and gowns.
Fourth, a list of those items that would be required in the event of a control room sequestration requiring controllers to live at the control room for an extended period, considering arrangements for cots, linens, showers, food, rest and so forth.
Fifth, determine policy for work from home should it be required. Ensure that all controllers have appropriate equipment, all equipment is tested, and controllers are able to effectively connect and perform tasks from the house. It is important to note when implementing an operate from home approach, most operators do not allow control actions other than for emergencies, and then often only by authorized personnel. Rather, the controller monitors from home and processes alarms, then communicates with field operations who perform control actions manually.
Sixth, determine what immediate actions should be taken to minimize risk of exposure for the controllers, including the following;
- Stop all meetings with outside persons
- Stop all discretionary travel
- Prohibit access to the control room for non-critical personnel
- Implement hygiene protocols
Finally, verify that any backup control rooms are fully operational and available should the primary control room become unavailable.
Considerations for Controller Sequestration
Sequestration is the act of isolating the control room from outside contact. Therefore, the first question is under what circumstances would sequestration be required? Said another way, what would be the trigger for sequestration? Considerations could be:
- Controller with positive diagnosis of COVID-19, or some percentage of staff with a positive diagnosis.
- Staff is reduced to some specific level.
If the decision is made to sequester, then consider what will be required to support those personnel including arrangements for sleeping, showers, food, off duty time, and connection to family. Each operation will have different needs and constraints. To work through the planning, consider the following.
- Housing (Sleep, Shower, Laundry, Off Duty Time)
- If in a large building, is there unoccupied space that can be set up for housing?
- If in a remote facility, can a mobile home or RV park be created?
- If a hotel is nearby, can an arrangement be made that provides for team isolation, such as renting out the entire hotel, or an entire floor. In this case,
- it might make sense for the facility to be used for other critical workers such as field operators.
- Provide on-site laundry.
- Ensure stable wideband internet to support connection to family and access to off duty entertainment.
- Provide the ability to prepare food.
- Start with a two-week food supply on hand.
- Consider special requirements for food handling.
- Personal Items
- 2 week supply of medicine for each controller.
- Essential personal items such as eye wear, sleep apnea devices, etc.
For larger operations with multiple control rooms and multiple backup facilities, each facility will likely have its own unique plan for sequestration.
Considerations in Case of a Facility Lockdown
A Facility Lockdown occurs when access to the control room is prohibited. This could occur as a result of a landlord decision, facility contamination, or other act of god. Planning for this eventuality should consider first, what happens upon lockdown, and then what is required before return to use.
Upon lockdown, the operator would enact one of the following;
- Work from a backup site
- Controllers work from home
- Manual field operation
- System shut in with remote monitoring
Return to Use
Prior to a return to use, a team should perform deep environmental cleaning and disinfection of all control room work areas, common areas, and access points.
Considerations for Controllers Working from Home
Should the operator implement “controllers work from home,” then the following should be considered.
Method of Operation
Primarily, this decision is related to what actions the controller will perform when working from home. When working from home, there is additional risk related to data delivery and security, therefore most operators elect to limit controller actions to monitoring and alarm processing. Prohibiting electronic control actions, and requiring manual control action by field operators.
In some cases, operators will allow electronic control action for certain individuals with advanced qualifications, or in the event of emergency response to perform actions such as shut down.
Operators should consider what additional training is required, and what additional abnormal operating conditions (AOCs) might be relevant to controllers operating from home.
Each operator will have unique networking, cyber security, SCADA, and communications infrastructure capabilities and constraints. Should an operator determine that “controller work from home” is part of its continuing operating plan, then IT and SCADA personnel should become involved as early as possible. In particular, attention should be paid to both availability of Internet connectivity and appropriate bandwidth at each controller home, and that company cyber security policy is implemented. All equipment should be in place and functionality verified in advance of any work from home order.
Additionally, an assessment of the home power reliability should be made with a contingency plan for loss of power. This might include battery back up, UPS, and/or generators.
When working from home, there are two considerations. First, how do I provide reliable and streamlined normal communication, and second, how do I ensure controllers can always be contacted?
With regard to normal communication, the ideal approach is to forward calls placed to the control room console to the controller at their home. This can become complex given the number of remote locations involved. There are phone company services, phone system features, and other software applications that can simplify call forwarding. Ideally, all calls are routed to the controller’s remote location using either their computer or a VOIP phone set issued by the operator.
Finally, the operator should put in place appropriate measures to ensure controllers can always be contacted. These measures should consider check-ins and a mechanism for keeping remote staff contact and location information current.
Considerations for Sustainable Staffing in the Control Room
Critical to the pipeline operation’s ability to continue to operate through this crisis is its ability to sustain an appropriate staffing level in the control room team. The COVID-19 crises present a risk of staff attrition in the control room. Therefore, the operator should consider how it might sustain operations in the event of staff attrition.
- What persons recently worked in the control room, but have moved to other positions in the company?
- Can their qualification be extended, and/or renewed?
- Can I create a reserve staff and rotate them through the control room to maintain their qualification?
- What persons in engineering and/or operations could be quickly qualified as a controller?
- How might existing resources in the control room be redeployed?
- Can unqualified controllers in training, perform training from home?
- Can supervisors, trainers, etc be deployed to the console?
- Can controllers be moved between control rooms?
- What functions in the control room do not require qualification, and can be performed by others?
Considerations for Minimizing Controller Exposure
COVID-19 is highly contagious and is primarily spread person-to-person either through close contact (within about 6 feet), or through respiratory droplets produced when an infected person coughs or sneezes. The primary mechanism for spread of the virus is when these droplets are inhaled. It may be possible that the virus can be spread by touching a contaminated surface then touching your mouth, nose, or eyes.
Any interaction between the controller and outside parties present a risk of infection. Therefore, the goal would be to have as little outside interaction as possible. Operators should consider the following as appropriate to their unique requirements and constraints;
- Ask controllers to minimize contact with outside persons
- Separate controllers working on shift by at least 6 feet
- Modify shift handover procedures such that it does not require direct contact within less than 6 feet. Ideally, this should be handled as a screen share meeting.
- Ask controllers to perform their own cleaning to minimize contact with outside parties
- In the event of any exposure, require controller to work from home.
- Implement alternate shift schedules that allow some controllers to work from home.
- Require that controllers in training work from home.
- Divide the control room team between primary and back up control rooms.
- Sequester the control room team.
Considerations for Third-Party Access
In addition to the measures elaborated in the “Preventing the Spread of COVID-19 in the Control Room” at the beginning of this article, special consideration should be given to the measures required when outside personnel are required to access the control room. These persons could include Supervision, SCADA Support, IT Support, and cleaning personnel. Operators should consider the following as appropriate to their unique requirements and constraints:
- Require that all support personnel work from home.
- Control access to the control room. Only authorized persons, and generally only controllers on shift.
- Control access to the building, only critical employees following an appropriate protocol.
- For those requiring special access:
- Assign a controller to the task of “special admissions” to the control room.
- Ask screening questions including, “Do you have a fever?” “Have you been sick?” and “Have you been around anyone who is sick?” If the answer to any of these questions is “Yes,” then deny access.
- Take temperatures. If the person’s temperature is above 100.4, deny access.
- Require anyone granted access to don gloves and mask.
Special Considerations for Operations During the Pandemic
It is possible that normal operations may be impacted by the pandemic. To that end, operators should consider the following:
- Review current policy and procedure related to normal, abnormal and emergency operations. Does the pandemic itself or any modification to control room operation require modification to this policy and procedure?
- At what point would an operation shut down be appropriate based on lack of demand, lack of business need, or lack of qualified personnel?
- In the event of an operational shut down, what modifications might need to be made to startup procedures?
A Final Note
PHMSA has provided guidance to state regulators regarding COVID-19. PHMSA instructed the States to continue to execute their safety oversight mission, to address any emergent need for waivers, and to follow CDC recommendations to minimize COVID-19 exposure.
On Friday, March 20, 2020, PHMSA issued a Stay of Enforcement in which PHMSA recognizes that pipeline operators may find it extremely difficult to meet regulatory requirements because of personnel and resource constraints related to the National Emergency declared by the President on March 13, 2020.
The notice states that PHMSA does not intend to take any enforcement action with regard to OQ and CRM requirements and will consider using discretion with regard to drug testing requirements. Finally, PHMSA directs operators that determine they cannot comply to provide notice to the appropriate authority.
Operators should capture information that would assist to document the impact of COVID-19 on operations, operator response, and any deviation to regulatory requirements. Collected information might include:
- Employees sequestered due to contact, including time sequestered and impact to the employee’s ability to perform their job functions
- Employee illness
- Activities deferred
- Additional costs such as PPE, cleaning, employee time, contractor time
Much of this information was collected from operators and industry associates such as the AGA. If an operator requires assistance to access additional information and/or supplies such as PPE, we would encourage that operator to use their industry associations to support that advocacy.
We know this is a challenging time for our country and the oil and gas industry. We will continue to update this information as the situation evolves. Let’s work together to take preventative measures to help stop the spread of COVID-19 and enable our critical operation to support the response to the COVID-19 crisis.
If you have questions, or if EnerSys can assist in any way, please reach out to us through the Contact Us page on our website.