Pipeline operators with PHMSA-regulated control rooms need to understand the value and importance of developing a robust Control Room Management program.
With the recent introduction of the final Gas Gathering Rule that brought thousands of miles of pipelines under federal jurisdiction, it is more important than ever for operators to take the appropriate steps to mature their control room operations.
Taking action now will also help bring your operation into natural compliance with the PHMSA Control Room Management Rule (CRM Rule – 192.631 for natural gas or 195.446 for hazardous liquids).
EnerSys can provide support through the development of a custom workflow that fits your budget, existing control room safety program, and current compliance posture. Through our support, we will develop the appropriate timeline for implementation that will most effectively provide value given your current control room resources.
Consider what two years with EnerSys would look like to bring your control room up to speed with today’s PHMSA regulatory environment.
Control Room Management Program: Your Current Capabilities
Before developing a workflow, we want to understand the current state of your control room operations.
- Do you have an existing Control Room Management program? Or, is this new territory because your assets just came under federal jurisdiction?
- Perhaps you already have a CRM program, but the program has not been sufficiently developed?
Uncovering the answers to these questions will help us understand the starting point for your operation. Then, we can collaboratively develop the appropriate workflow that will provide your operation and our team with a roadmap for success.
Our Typical Control Room Management Program Workflow
Consider this typical multi-phase workflow that we propose to pipeline operators to support their control room(s).
1. Identification and Analysis: Compliance Review Through ComplyMgr
The initial step in the workflow is the implementation of our ComplyMgr software tool for Control Room Management. This tool will be used for conducting a Compliance Review of your existing CRM program:
- Compare current policies and procedures against CRM Rule requirements.
- Perform interviews and observations to assess your compliance state.
- Look at policy vs. implementation to identify sources of potential non-compliance.
The first step helps establish a baseline for improvement. We do all the heavy lifting. Our team of CRM subject matter experts will conduct a preliminary analysis using ComplyMgr to identify any gaps in policy, implementation, and recordkeeping.
Starting with this approach enables us to propose corrective action based on your operation’s current compliance state. In doing so, we have a basis for determining what the goals should be. Then, we can prioritize corrective action and improvements moving forward.
2. Update Policies and Procedures
The next step is to close the policy gaps that we identified as part of the Compliance Review. This will help create a firm policy foundation. EnerSys will support your operation by updating the Control Room Management Plan (CRMP). We will ensure that the CRMP satisfies the following objectives:
- Aligns with applicable regulations.
- Covers the level of detail expected by PHMSA.
- Accounts for your operation’s current assets and facilities.
Our CRM subject matter experts will verify that your CRMP addresses all PHMSA regulations and best practices that are specific to your operation. This becomes the framework for continuous improvement moving forward.
3. CRM Program Implementation
After closing policy gaps, we focus on closing gaps in implementation and recordkeeping. This provides us with a strong foundation for Control Room Management program implementation. Our CRM Compliance Support program ensures that future gaps do not arise. The program assists in the following ways:
- Mitigate future CRMP gaps and general CRM gaps.
- Continue to equip the control room team with knowledge and skills to develop CRM ownership and expertise.
- Drive toward successful implementation of a thorough and compliant CRM program.
- Walk through all required monthly and annual activity outlined in the PHMSA CRM Rule.
This program is designed to ensure that your control room is always audit-ready without placing an undue burden on the control room staff. We will work with your team to facilitate ongoing compliance and instill a culture of discipline around the completion of monthly and annual requirements.
Using our Compliance Support program, we will collaborate with your team to execute a full calendar year of CRM program requirements, which includes regulatory required monthly alarm reviews, facilitation of fatigue and alarm program reviews, and documentation of annual activities.
Overall, consider the benefits of following our CRM workflow:
- Close gaps in policy, implementation, and recordkeeping.
- Meet all annual and monthly requirements.
- Utilize CRM subject matter experts to ensure compliance with PHMSA regulations.
- Instill a CRM-oriented culture.
Added Support in Our CRM Program
We offer additional support to enhance your compliance state.
– CRM Training. We can provide CRM Program training to key personnel. This includes helping communicate changes to affected control room personnel and support personnel (e.g. field operations and SCADA teams).
Personnel will have a clear understanding of the new and updated approach to Control Room Management compliance. Our goal is to achieve universal buy-in to foster the appropriate Control Room Management-minded culture in your operation.
– Transition to Facilitator Program. Ultimately, our goal is to transition operators to our CRM Compliance Facilitator Program where your operation takes ownership of the CRM program. We utilize the same framework as when our company leads the CRM Support program, but the EnerSys team shifts to more of a coaching role.
We typically reach this stage 1-2 years into the workflow, depending on the starting point for your control room operations. Through our collaborative approach, we still remain involved and accessible to support the latest needs of your control room. However, operators should have the tools they need to continue maturing the program. Taking this step will also prepare your operation for a successful control room audit.
– CRM Audit Support Services. When PHMSA provides notice of a control room audit, your operation will already be in a position of audit readiness. You will still need to perform a deep and thorough review of CRM compliance as part of audit preparation, but by owning the CRM program through our support, you will be able to gather appropriate documentation to satisfy each PHMSA inquiry.
Our approach during the CRM audit includes the following key aspects:
- Perform a compliance review to understand your current state and to identify blind spots from ongoing support.
- Close the gaps that we identify during the review.
- Support the audit work to prepare for the audit.
During the actual audit, we will come alongside your team to provide specific audit support services as needed. For example, we can help you answer questions from the PHMSA inspector, utilize our software to produce compliance records, and ensure that you can prove compliance with the CRM Rule.
Additional Options for the CRM Program Workflow
Once an operator’s CRM program is mature and in compliance with the CRM Rule, there are additional opportunities to improve control room operations. We can help your pipeline operation budget for the following:
- Alarm Management workshop.
- Software updates.
- Site visits.
- Reinforcement training to current personnel.
- Additional training for new personnel.
- Annual software maintenance.
Many operators find value in utilizing our Alarm Management workshop. We can help establish a foundation for rationalizing alarms and develop your Alarm Management program to align with the PHMSA CRM Rule requirements in Section E.
We utilize the ALMgr tool in our Control Room Management software suite (CRM Suite) to help operators maximize the value of maintaining their Alarm Management program. Our workshop includes the following:
- Guidance on the proper alarm rationalization approach.
- Support for developing the alarm operating philosophy.
- Training on alarm analysis using the CRM Suite.
- Preparation for ongoing alarm rationalization support.
Contact Us to Get Started on Our CRM Program Workflow
Whether Control Room Management is new to your operation or you need support taking the next steps with your existing Control Room Management program, we can provide targeted support.
Our team has specific expertise to support the control room needs of pipeline operators. By spending two years with EnerSys, we will ensure that your operation is on the right path to Natural Compliance with the PHMSA CRM Rule.
– Let’s get started with a consultation about the current state of your control room operations. Call us at 281-598-7100 to speak with EnerSys General Manager Ross Adams or VP Business Development Dale Schafer. You can also email us at email@example.com or complete our website contact form to get started.