Pipeline operators are required to implement and follow a Control Room Management plan under the PHMSA CRM Rule (49 CFR Parts 192 and 195).
The rule identifies what is required in Control Room Management (guidelines), but it does not provide the step-by-step process (guidance) for how to meet the requirements, much less guidance for implementing requirements cost-effectively.
The difference between guidelines and guidance captures the need for Control Room Compliance Assessment to determine whether your operation’s current state of compliance. Conducting this analysis is especially critical if you are in the middle of an audit, were recently audited, or have an upcoming audit.
4 Areas Where CRM Rule Compliance is Critical
EnerSys has identified four areas in the CRM Rule where you need to achieve compliance to pass your PHMSA audit.
Area #1: Verify the Effectiveness of Procedures
Each pipeline operator is required to have a Control Room Management Plan (CRMP) that conforms to regulatory requirements. Additionally, operators should draft Control Room Management Plans, Procedures, and Policies that capture the execution of the CRMP.
Control room gap analysis will highlight the current state of your existing procedures compared to the requirements of the CRM Rule.
If you discover gaps between the guidelines and your procedures, you can strategize next steps to bring your procedures into alignment. In addition to ensuring compliance in this area, taking this step will limit the cost of compliance implementation.
Area #2: Match the Environment to Personnel
Major pipeline incidents contributed to an industry-wide shift in thinking about the control room environment. Controllers cannot be expected to maintain situational awareness (SA) if they are over-worked, fatigued, distracted, and overloaded by information in the SCADA system and presented to them on the HMI display.
Pipeline operators need to be able to demonstrate a high level of attention to the control room environment, including focusing on Workload Analysis and Hours of Service scheduling. Conducting a compliance assessment will allow you to verify compliance with the guidelines, as clarified by PHMSA in this answer from their CRM Rule FAQs:
“The rule does not establish a uniform benchmark for controller workload. PHMSA expects operators to establish, annually evaluate, and document the substantive adequacy of controller workload criteria. Job task analysis or related evaluations are encouraged. Periodic analysis, annually and whenever significant changes are being made, will help operators recognize and react to changes.”
Area #3: Optimize Your Alarm Management
A third significant area for compliance is the effectiveness of your alarm management program.
Operators are expected to periodically review their alarm management program, including the alarm rationalization process. Through this process, operators are “expected to promptly correct specific issues” or deficiencies that could pose a safety concern.
Additionally, operators are expected to verify that controllers are following the written procedures for how to react in each operating condition. Specifically, PHMSA clarifies in the CRM Rule FAQs: “These written procedures must define exactly what controllers do in normal, abnormal and emergency operating conditions.”
A control room compliance assessment will reveal the strengths and weaknesses of your alarm management program to continue advancing the capabilities of your operation or take the necessary corrective steps to address weak areas.
Area #4: Document Your Activities
Even with perfect procedures and processes, if the pipeline operator does not document the activities they are performing under their plan, then an auditor will not consider the program compliant.
The question is how much documentation is required. PHMSA clarifies the guidelines in the CRM Rule FAQs: “PHMSA expects operators to have and maintain records to demonstrate that required activities were satisfactorily accomplished. Upon request, the operator must provide CRM procedures and associated documentation and records to PHMSA or the appropriate state agency for review to validate compliance.
“Any records intended to demonstrate compliance should include sufficient details as a means to help demonstrate thoroughness and authenticity.”
Clearly, documentation is critical. Creating the documentation in a streamlined way that minimizes controller workload and creates easily-retrieved electronic records is the ideal means to not only achieve cost-effective compliance, but also operations excellence.
EnerSys Equipped to Conduct Control Room Compliance Assessment
EnerSys supports small to medium-sized pipeline operators by conducting a control room compliance assessment to determine your level of compliance with the CRM Rule guidelines.
We will match up your CRMP with the CRM Rule requirements to identify the current state of your policies & procedures. Through this process, we will ensure that you have a roadmap to update your control room documents, enhance your control room environment, optimize your alarm management program, and create proper records.