To achieve compliance with the Control Room Management Rule (PHMSA 49 CFR Parts 192 and 195), pipeline operators must be able to demonstrate their adherence to the CRM Rule and explain any deviations, both from the rule and from their internal policies, if any.
Both aspects of demonstrating compliance and reporting deviations require accurate recordkeeping. In the words of PHMSA in their FAQs, the burden is on the operator to provide “sufficient details as a means to help demonstrate thoroughness and authenticity.”
Thoroughness is the need to capture as much relevant information as possible about events in your pipeline control room; authenticity is being able to “show your work” to prove that your team followed procedures and can explain deviations.
Pipeline operators already have systems and procedures in place to meet regulatory requirements. However, these elements were often put in place to capture evidence that demonstrates compliance; they are rarely optimized to minimize the recordkeeping burden or for using the evidence to demonstrate compliance during an audit.
Capturing evidence and preparing for a regulatory audit can be a heavy burden on operators, especially if you use outdated methods for recordkeeping, if your operation has overlooked training requirements, or if team members are overly burdened by the mechanics of recordkeeping. To rectify issues in your operation, consider streamlining recordkeeping to achieve CRM regulatory compliance.
Why Should You Streamline Recordkeeping to Support CRM Rule Compliance?
The goal for every pipeline operator should be to make recordkeeping happen in the background as a normal course of business.
You should reach the point that you immediately feel confident and prepared to share readily-available records when PHMSA sends an inspection notice, not in reaction mode thinking of how to gather up documents.
Essentially, the process of streamlining recordkeeping will help you avoid the scenario of trying to verify records from events that happened months ago or document a deviation without proper notes.
If activity in your operation is properly recorded and stored in real-time, then you do not have to worry about poor recordkeeping down the road or having to rely on a controller’s memory during an inspection.
This streamlined process will ensure that you can confidently produce appropriate documents, meet deadlines, and ultimately achieve compliance.
How Can Streamlined Recordkeeping Support Compliance Validation?
For the purpose of compliance validation, streamlined recordkeeping will allow you to match up activity with your internal control room procedures in real-time.
This real-time recordkeeping will allow you to produce accurate reports that satisfy the CRM Rule requirement to “demonstrate that required activities were satisfactorily accomplished.”
And, yes, electronic records are acceptable to demonstrate compliance as long as “they are maintained in a format that ensures the integrity, authenticity, and date of the records, and that they are readily retrievable and accessible for inspection.”
How Can Streamlined Recordkeeping Support Deviation Reporting?
For the purpose of deviation reporting, streamlined recordkeeping is essential for collecting and storing information in real-time that captures why a controller or other control room personnel deviated from the procedures.
Consider this example of what happens without streamlined recordkeeping: there was an hours of service deviation in December, but no records were created at the time. Now, you receive an inspection notice in May, and in the process of preparing for the audit, you identify the undocumented deviation. The event is straightforward enough to create the record of deviation, but how do you demonstrate that appropriate fatigue mitigation occured?
Without streamlined recordkeeping, you must ask those involved to think back in time to capture information about this event. Six months later, the annotations to the records may not make sense, or could be incomplete. There could also be conflicting accounts from the involved parties — e.g. controller or other individuals with authority — regarding the deviation and the mitigations activities.
With streamlined recordkeeping, all of the information from this example would have been verified and stored in real-time. Further, the deviation would have been flagged during the normal work process to assure timely follow-up. This allows operators to achieve CRM Rule compliance by documenting deviation while the details are fresh. In this way, the reason for the deviation can be fully captured and appropriate mitigation activities can be undertaken.
There are legitimate reasons why someone would supersede authority per the defined roles and responsibilities, or would deviate from policy. The issue is to capture the rationale, the details, and the required future action whether or not the individual made decisions within their proper “scope” of operational control.
The Software to Support Streamlined Recordkeeping
EnerSys developed the POEMS Control Room Management Suite (CRM Suite) to provide tools and applications for operators to ensure compliance with the CRM Rule.
Three specific tools in the CRM Suite ensure that operators achieve streamlined recordkeeping:
- CRMgr: complies with the CRM Rule through proper recordkeeping, incident logging, and creates compliance logs and custom reports to simplify the audit process.
- ComplyMgr: data repository for internal documents, traces procedures to audit protocols, links procedures to PHMSA regulations, and simplifies the process of updating procedures to match new PHMSA requirements.
- FatigueMgr: tracks hours of service requirements and flags deviations for the creation of deviation records and fatigue mitigation directions.
Do not go another year without streamlining recordkeeping so that you are confidently prepared for your next inspection.
To schedule a demo of the CRM Suite or further discuss how to streamline your records for CRM Rule compliance, please complete our contact form, email our team at email@example.com, or call us directly at 281-598-7100.