Pipeline operators are required to be in compliance with a variety of detailed regulations. At EnerSys, we often talk about the concept of Natural Compliance as a means of ensuring that your operation is organically operating in accordance with these state and federal pipeline regulations. Specific to the pipeline control room, this would be operating in compliance with the PHMSA CRM Rule (49 CFR 192.631 and 195.446 Control Room Management).
In other words, you want to arrive at the point where as the work takes place in pipeline operations, then compliance naturally happens. There is no second step to create compliance records to satisfy a PHMSA inspection or audit. The natural output of the work is that the records required for compliance are automatically created, retained, and accessible.
It’s a game-changing concept for operators that want to ensure that they are continuously operating in compliance with regulations. There are requirements to arrive at this point, which I talked about in-depth with EnerSys General Manager Ross Adams in a recent edition of the Pipeliners Podcast. I encourage you to listen to the episode to grasp the full scope of the opportunity for operators to achieve compliance and safety goals through Natural Compliance.
What Are the Requirements to Arrive at Natural Compliance?
The primary requirement for Natural Compliance is having systems in place to cover each critical area of pipeline operations. Without systems, compliance doesn’t come naturally.
Systems enable your operation to determine whether you are set up correctly, to create structure around how you are operating, and then to follow through to actually perform the work. Consider these three key systems in pipeline operations that need to be optimized:
- Program Management system.
- Process Management system.
- Task Execution system.
Thought of another way, these three systems enable you to support the full Plan-Do-Check-Act cycle found in Pipeline Safety Management Systems (PSMS). Your Program system supports Planning, your Process system supports Doing, and your Task system supports Checking and Acting. Let’s examine these further.
1. What’s Required for a Program Management System?
A program management system allows you to capture your operation’s policies and procedures, and then ensure that each policy and procedure aligns with the requirements of applicable pipeline regulations (e.g. the PHMSA CRM Rule). This is the foundation to build on, and you want to have confidence that this foundation will put you in compliance with regulations once implemented.
This also extends to the pipeline control room. Operators need to establish programs, policies, procedures, and philosophies that align with CRM Rule requirements. This looks like having a system to ensure that your Control Room Management Plan (CRMP) and associated procedures are set up to comply with the control room rulemaking. This way, you’re not including something in your control room policy or procedures that is non-compliant.
2. What’s Required for a Process Management System?
Next is having an effective process management system to ensure that your operation has a plan to do all of the things that need to be accomplished. In other words, you have the policies and procedures as part of your program, now you need to be able to implement the plan and procedures that were previously defined.
Specific to the control room, you need to implement your plan to perform control room reviews, support Alarm Management, perform fatigue analysis, optimize the relationship between the control room and the field, track training sessions with control room personnel, share lessons learned, and plan for other control room activities required by the CRM Rule.
Process management is about making sure things in your overarching program are not missed and that procedures are being followed. This leads into the task management system, where the work is done.
3. What’s Required for a Task Management System?
The third leg of the stool is having a system to track that the appropriate actions were taken and that there was follow-through on the policies, plans, and implementation. Did you do what you said you were going to do and planned to do?
The additional aspect of this is making sure that your system is set up to adequately create records as the work is being performed. Then, the records will be available at a later time when asked to validate compliance with pipeline regulations.
Specific to the control room, your task system should be able to track activity and produce records that satisfy CRM Rule inquiries around topics such as alarm analysis, shift handover, shift scheduling, and fatigue management. The task management systems may also provide some groundwork for analyzing where there is a need for improvement.
Creating Alignment Around Natural Compliance
In our conversations with operators, we have seen that operators are stronger in some areas compared to others. Perhaps you have the ideal system for policies and procedures, but you do not have the appropriate system to support implementation. Or, you have a system to track the execution of tasks in the control room, but it’s not linked back to the first step of ensuring you have the appropriate policies and procedures in your CRMP plan.
All three legs of the stool need to come together in a structured manner, and each group involved in pipeline operations needs to buy into their role. This way, everything can come together to ensure that your operation is functioning like a well-oiled machine, all the way through to the control room.
A great example of this is Alarm Management. This is not just a control room activity; it requires interaction with other groups such as automation, facilities management, and SCADA. There are multiple layers of interaction required, which also means these teams could be using different systems to support their objectives.
Operators need to create alignment around how information is passed through to support safe and compliant operations by having the appropriate systems in place. Consider the application to Alarm Management:
- Program Systems: You need documentation around your alarm philosophy, which should be shared with each group in the operation. For the control room, you should include policies and procedures in your CRMP discussing Alarm Management.
- Process Systems: You need to ensure that your alarm policies and procedures are executable, have ownership, and can realistically be supported throughout the operation. This may require collaboration with other groups to ensure understanding.
- Task Systems: You need to ensure that everyone is on the same page about how to execute alarm-related tasks. For example, who is responsible for flagging bad actors and then sharing that with other teams to have that corrected? Then, what is the communication back to the control room to ensure the issue has been resolved?
When your operation is in alignment around how to advance from policies and procedures to implementation to execution, then you have arrived at the point of operating in a naturally compliant manner. This is the goal. Getting there requires having the appropriate systems in place.
Let’s Review Your Systems to Arrive at Natural Compliance
Over the course of reading this information and/or listening to my podcast discussion with Ross Adams, you may have made mental notes about strengths, weaknesses, or gaps in your operation’s systems.
We would certainly appreciate the opportunity to discuss the current state of your program, process, and task systems to identify opportunities for improvement. Then, through our assessment, we can provide recommendations on how to bring your control room into natural compliance with state and federal regulations.
Specifically, our Control Room Management software suite (CRM Suite) has the tools you need to centralize and organize all records required for conformance to the PHMSA CRM Rule. Implementing the right tools enables operators to streamline operations, monitor activity, and verify performance, which results in a healthy safety culture.
– Contact us today to discuss how we can help your operation. Through Natural Compliance, you can gain confidence that you are continuously operating in a compliant manner and are always ready for the audit!
Call 281-598-7100 to schedule an assessment of your systems. Ask for Dale Schafer or Ross Adams. Alternatively, email firstname.lastname@example.org or complete our website contact form to set out on the path to Natural Compliance.