Managing Hours of Service (HOS) in the pipeline control room looks very different in 2021 than at the beginning of last year. The pandemic created new challenges around how to schedule shifts that protect the health and safety of controllers, how to support work-from-home scenarios, and how to ensure compliance with the PHMSA CRM Rule.
Think of it like this. How do you balance scheduling and staffing needs when one controller is working from home versus another controller who is commuting an hour to the facility to perform their duties at a control room console? Different situations require different approaches to ensure that all controllers have the proper support to achieve vigilance.
Given these unique circumstances, control room managers need tools to track vigilance time, activity in the control room, travel time, time off, and off-shift work. Without a clear view of Hours of Service for each controller, you will be unable to make critical decisions to support controller alertness, while also risking non-conformance with the CRM Rule.
What’s the solution? We recommend utilizing the FatigueMgr module in our software platform, POEMS CRM Suite.
Why the POEMS CRM Suite to Manage Hours of Service?
Within the POEMS CRM Suite, our FatigueMgr module supports Hours of Service deviation identification, mitigation, recordkeeping, and controller scheduling. Managers and supervisors are provided a fully-contextualized view of controller activity during their shift.
FatigueMgr also enables managers to take into account the amount of time required for travel time, shift handover, each controller’s quality of sleep, and time spent during off-shift hours for training, meetings, and development.
Essentially, the software module provides you with a holistic view of each controller’s on-shift and off-shift needs to ensure that controllers are fit for duty during their shift. This is critical to ensure controller alertness to respond to alarms and take appropriate action during each operating condition, which directly impacts pipeline safety.
– During a recent episode of the Pipeliners Podcast, Ross Adams and I discussed this very topic. Ross said it well that it’s about practicing a proactive approach to mitigate the risks of fatigue and around Hours of Service.
This looks like structuring shifts in such a way that controllers get adequate sleep, have appropriate downtime in between shift resets, and that their unique situations are considered during this era, especially when a controller is working from home versus working at the facility.
There are too many variables in-play to adequately manage Hours of Service without the support of software tools. Managers need tools to be able to continuously monitor, track, and review controller activity to ensure that controllers can maintain adequate situational awareness throughout their shift that enables them to respond to alarms.
Support CRM Rule Hours of Service Compliance and Deviations
Many pipeline operators and control room managers are concerned about how the pandemic affected their ability to comply with the Hours of Service requirements outlined in the PHMSA CRM Rule.
If you already took the step of ensuring that your Control Room Management Plan policy and procedures were aligned with the CRM Rule, then you should have had provisions for how to handle deviations that arose during the pandemic disruption. Specifically, the CRMP should:
- Include proper Hours of Service definitions.
- Outline proper deviation management steps.
- Outline the requirements for the review and approval of deviations.
- Include a time frame for when deviations should be documented.
- Detail a shift change method for controllers.
- Include parameters for determining if controllers have adequate time to react to alarms.
FatigueMgr supports this objective by helping you produce high-quality, consistent records for both policy and implementation. In other words, FatigueMgr enables you to validate that controllers did what you said you would do in your CRMP. And, in the event of a deviation, you can produce reports that capture the reason for the deviation, who authorized the deviation, and the results from the deviation.
– PHMSA specifically requires that “operators must maintain documentation related to the deviation; if there are any additional risks associated with controller fatigue because of the deviation, the additional risks must also be addressed.”
FatigueMgr enables pipeline operators to satisfy the PHMSA requirement of maintaining proper documentation and performing recordkeeping that captures why any deviation from your HOS policy was necessary for the safe operation of the pipeline facility.
During these challenging times of trying to proactively support Hours of Service in the control room, you need reliable software tools to help monitor and track HOS deviations and implement countermeasures until control room activity can return to normal.
Contact EnerSys to Schedule a FatigueMgr Demo
We optimized FatigueMgr to support the Hours of Service management needs in the control room. The module is available as a standalone software tool or as part of our entire POEMS CRM Suite, which includes other modules to support each critical area of the control room.
Whether you simply need FatigueMgr to support your HOS needs, or if you would like to add on FatigueMgr to your current use of the CRM Suite, we have a solution that will support your current needs.
– Reach out to our team today to schedule an educational demo of FatigueMgr. Call us at 281-598-7100 and ask for Ross Adams. Alternatively, complete our contact form or email us at firstname.lastname@example.org.