In my discussions with control room managers, I have come across two common concerns related to fatigue mitigation in pipeline operations:
- Are my controllers rested, focused, and alert to ensure a safe operation?
- Is my control room compliant with the PHMSA control room management rule for fatigue management?
Whether your concern is the alertness of your controllers, adherence to PHMSA safety regulations, or both, consider this strategy to enhance your management of fatigue risk.
Workload: What, Where, and When is the Work?
The first step in your fatigue mitigation strategy is defining workload. Every control room is different — and PHMSA allows for each operator to define their process to manage fatigue — but there are fixed requirements.
(PHMSA also recommends that control room managers involve top management in the definition process to achieve universal buy-in throughout the operation.)
According to PHMSA, your operation needs to establish written procedures that “describe the bounding parameters in shift lengths and schedule rotations, and maximum hours of service limits.”
Specifically, your operation needs to define on-duty vs. off-duty time and factor the distinction into the workload schedule.
- On-duty time consists of the controller’s standard tasks and activity, shift-change, meetings, training, and performance reviews.
- Off-duty time consists of the controller’s daily commute, personal activity after their shift, and sleep in-between shifts.
Specific to off-duty time, PHMSA provides for various commute times for individual controllers: “shorter/longer commute times or the availability of nearby sleep facilities may influence the appropriate amount of off-duty time.”
Your records should include schedules, timesheets, and supporting documentation that captures your operation’s adherence to on-duty and off-duty times. And, if there was a schedule change, you need to document whether the change fit within the parameters of the written procedures to mitigate fatigue risk and remain compliant.
Hours of Service: What are the Challenges and Solutions?
PHMSA clearly defines Hours of Service limits for controllers to mitigate fatigue in pipeline operations. The issue is knowing how to apply the rules to your operation.
The rules are straightforward if controllers work a traditional modified DuPont Schedule. However, the rules become more complex when a controller works a 7×12 schedule (seven 12-hour days).
In the event of non-traditional shifts, be mindful of the limitations enacted by PHMSA that require “reasonable maximum normal limits on controllers.” PHMSA breaks down the entire hours of service standards and off-duty time in their FAQs. This should be matched with your processes to ensure compliance.
The purpose is to ensure that controllers remain alert during periods of increased fatigue risk during a night or graveyard shift when there is a history of accidents occurring. And, if a controller is asked to break from the parameters, you must document the deviation.
“Operators who deviate from these parameters must be able to demonstrate why the variation does not elevate the risk of fatigue. Operators who deviate from these parameters must be able to demonstrate that adequate fatigue risk countermeasures have been deployed.” — PHMSA FAQs
Shift Handover: Be Fast, Comprehensive, and Compliant
The third important part of your fatigue mitigation strategy is the shift handover process, which needs to be efficient and compliant.
PHMSA recommends 30 minutes to one hour for a complete shift handover. However, many operators limit this to 15 minutes. Regardless, the time required for shift handover needs to be factored into your hours of service for both the departing controller and the incoming controller.
Specific to what should be handed over during the exchange, your operation needs to follow control room regulations to “define the information that will be transferred during shift turnover and the process by which this information is exchanged.”
The shift handover process even applies to pipeline operations that do not have 24-hour coverage. An example is a controller finishing their shift, a gap of time, and the same person picking up the next shift.
“Even if the same person is scheduled to return, the controller may unexpectedly have to be replaced as the result of illness or other circumstance that prevents the controller from returning to duty the next day as planned. Even if the same individual returns the next morning, the shift handover process will help ensure no critical information has been forgotten.” — PHMSA FAQs
This recommendation from PHMSA highlights the bottom line for fatigue mitigation in pipeline operations: do not make assumptions. Ensure that workload is defined, hours of service are followed, and controllers are trained to make clean handoffs to the next shift.
Fatigue Management: Consider Additional Countermeasures
PHMSA recognizes the variables of each control room. That’s why the operator and control room manager are responsible for “determining the fatigue risks that exist in its program, and appropriate mitigation tactics to implement given the operating environment.”
The approved mitigation tactics that serve as countermeasures to fatigue include the following:
- On-the-job napping during breaks
- Tactical caffeine use
- Standing desks or workstations
- Exercise areas
- Activities at specific times when the risk of fatigue is high
PHMSA also recommends establishing a process to follow when a controller self-identifies as fatigued or when the control room manager identifies that a controller is fatigued.
As part of continual learning, you should gather feedback from individual controllers on what countermeasures work and do not work for them. Then, continue to adjust accordingly for each controller and document the actions taken as part of your fatigue mitigation strategy.
How EnerSys Can Support Your Fatigue Mitigation Strategy
EnerSys recently introduced the FatigueMgr component of our POEMS software solution that helps manage the risks associated with fatigue in the control room.
Included in FatigueMgr are two vital components: Workload Analysis to evaluate workload by employee or shift and Hours of Service Scheduler to track on-duty hours, off-duty hours, travel time, and sleep.
The tools in FatigueMgr help pipeline operations achieve two goals of compliance with the PHMSA CRM rule and providing controllers with proper hours of service and rest in-between shifts.