How many DOT Pipeline Controllers have received a phone call or a visit from a non-control room staff member who directed you to perform a specific task that contradicted what you knew to be the right course of action? Or worse yet, as a control room manager, how many times have your controllers been delayed in responding to an abnormal or emergency situation due to input from non-controllers?
From either perspective, the answer is probably more often than you are comfortable with. This is especially concerning because you know that inefficient communication and lack of clarity around authority in decision-making has been noted as a major contributor to various pipeline incidents.
The pain that we are talking about can be summed up in the following way for control room managers: you know there is a fine line between respecting your corporate structure and protecting the authority of your controller. And, from the controller’s perspective, it is challenging to trust your experience and expertise when others are giving direction that may differ from what you believe is the proper action in a given operating condition.
PHMSA moved to remedy this issue affecting various roles in the control room and protect the integrity of qualified and authorized control room staff by expanding the CRM Rule in January 2017.
This expansion provided additional definitions concerning Roles and Responsibilities (Section (b) of the CRM Rule). Specifically, the addendum to Section (b) calls for operators to define the roles and responsibilities of those who have the “authority to direct or supersede the specific technical actions of a controller.”
Then, PHMSA issued a new FAQ (Frequently Asked Questions) earlier this month to clarify the rule as it relates to the “others” who have authority to supersede controllers. In other words, defining how a control room’s roles and responsibilities must account for these “others.”
How Do The New PHMSA FAQs Define Roles & Responsibilities?
It is important to understand that these new regulatory requirements are not just meant to make compliance more difficult. Instead, they part of an initiative to utilize lessons learned from across the industry to increase an operator’s ability to work safely and efficiently.
In this instance, the new PHMSA FAQs released this month were the latest step in a multi-year process to set clear definitions for individuals involved in the pipeline control room following the Marshall Incident.
- July 2010: A pipeline ruptured in Marshall, Michigan. This turned into the most expensive on-shore oil spill in U.S. history.
- July 2012: The National Transportation Safety Board (NTSB) issued its findings in a pipeline accident report and accompanying news release titled, “Pipeline Rupture and Oil Spill Accident Caused by Organizational Failures and Weak Regulations.”
- May 2014: The pipeline accident report and accompanying recommendations led the Department of Transportation (DOT) to release Advisory Bulletin (ADB-2014-02). The bulletin called for operators to improve controller understanding of relevant roles and responsibilities, as well as to increase their focus on training personnel not only as individuals, but as teams.
- January 2017: PHMSA released updates to the CRM Rule defining the roles and responsibilities of individuals with authority to override a controller.
- January 2018: PHMSA released the new FAQs to clarify roles, which will affect policy and procedure in the control room.
Furthermore, the Roles and Responsibilities updates to the CRM Rule and the new FAQs are not alone; they are part of a more holistic approach to control room management.
For example, the addition of subsection (h)(6) to the CRM Rule Training Section dictates that collaborative training exercises must take place between control room personnel and “others” — as defined in Section (b)(5) — who are expected to interact with controllers during normal, abnormal, or emergency operations. Now the question for operators is how the FAQs affect existing procedures.
How Are Policies and Procedures Affected by the FAQs?
Pipeline operators need to be able to sufficiently design, implement, and execute policy, procedure, and exercises for both expanded roles and responsibilities and team training. Therefore, it is imperative that you have a full understanding of how to meet PHMSA’s expectations.
We recommend that you take a deeper look into these new PHMSA FAQs and what they mean for your control room, but we also want to share a few of the highlights from our perspective. Take note that the FAQs for Roles and Responsibilities include more than just FAQs for Section (b). Your policy changes should reflect as much.
- B.06 – Operators are not required to have individuals with the authority to “direct or supersede specific technical actions of a controller,” otherwise known as “others.”
- B.07 – Directing or superseding a controller’s specific technical actions means claiming control, and therefore responsibility of, the controlled assets.
- B.07 – Procedures should account for when a controller disagrees with the orders/decisions/actions of an “other.”
- B.08 – Operator Qualification is required for “others” but only for the role as an “other” and not necessarily to the extent of a controller.
- B.09 – Roles and Responsibilities for “others” must be in place by March 24, 2017, where applicable.
- G.04 – Lessons learned reviews should cover events “others” superseded controller action.
- J.05 – Evidence that an “other” is presently qualified and authorized should be available to the controller in a clear manner.
What Should You Do Next to Adhere to the FAQs?
Whether or not your operation has already taken action to comply with the CRM Rule additions, the FAQs make it clear that changes will need to be made to your policies, procedures, and implementation.
However, it’s not all bad news. Implementing these changes will make for safer, compliant, and more effective operations, especially in an abnormal or emergency operating condition.
As more information comes out from industry experts, as new services and software become available to assist operators with compliance, and as the audit protocol questions are published, compliance with these rules will only become easier for pipeline operators.
In the meantime, act quickly to incorporate the new information presented in the FAQs.
How Can EnerSys Support Implementation?
Overall, the CRM rule and corresponding PHMSA FAQs are designed to educate operators on who is able to direct or supersede a controller, how that person becomes qualified and authorized, and the need for clear and commonly understood Roles and Responsibilities in the control room.
EnerSys stays on top of the latest requirements for control room managers. We embed this in our POEMS software solution, Compliance Facilitator Program, and CRM Compliance Support Services to ensure that pipeline operators remain compliant with updated policies and procedures.
Our team would appreciate the opportunity to discuss the new PHMSA FAQs, your concerns about policy and implementation, and our ability to provide audit support and/or compliance facilitation.