One of the most important aspects of the PHMSA Control Room Management Rule (CRM Rule) is following shift handover (SHO) requirements.
Shift handover is a critical area of control room management to ensure safe pipeline operations. Operators that take steps to streamline shift handover in accordance with API 1168 are better able to support safe operations.
The question is: how do you handle non-standard shift handover in the control room? Fortunately, there is guidance in the CRM Rule FAQs to help operators maintain safety and ensure compliance with the CRM Rule in these special situations.
Shift Handover for Unique Circumstances
Before diving into non-standard SHO situations, it’s important to remember that special situations do not mean deviating from control room policies and procedures. It’s the opposite. It means using your internal procedures to dictate how the control room should respond in each unique situation.
Situation #1: Control Room Monitoring Without 24/7 Supervision
For smaller or newer operators, you may not always have 24/7 controller supervision in the control room. The CRM Rule FAQs address this situation with guidance on how to structure shift handover procedures if you do not have 24-hour shift coverage.
The answer is that, yes, you should still have SHO procedures from one shift to the next, even if there is a gap of time between controller activity.
PHMSA further states that “anytime a controller completes his/her shift and/or control of the pipeline is transferred from one person to another person, shift hand-over requirements apply, even if there is a portion of time when the control room is planned to be unattended.”
This non-standard situation brings up the importance of your SCADA system.
When your pipeline operation hands off human control of the control room to a host, your SCADA system needs to be configured to be able to recognize a problem or an abnormal operating condition (AOC). This way, the individual(s) responsible for pipeline supervision can be alerted to a situation that requires their attention.
Why is this important for safety and compliance purposes?
- Safety: Configuring your SCADA system to support pipeline operations when a controller is not active in the control room supports pipeline safety.
- Compliance: A PHMSA auditor will evaluate whether the SCADA server time is synchronized with other sources of timekeeping used for operational records to validate that procedures were followed when the control room was unattended.
Situation #2: Starting A New Shift on a New Console
The standard shift handover process is for the outgoing controller to sit down with the incoming controller to review key activity during their shift, highlight current activity, and review future tasks during the incoming controller’s shift.
A non-standard situation is an incoming controller picking up a console that was previously not attended by a controller. We can find the solution for this situation in the CRM Rule FAQs about the importance of each controller completing their shift handover process even if no one will be following them. That way, when a controller picks up a console that has not been attended for a period of time, the information is still readily available.
The key is not to make assumptions. Shifts change. New personnel are introduced. Consoles are updated or re-located in the control room. No matter what changes operationally, the information in the most-recent Shift Handover records should be available on that console.
Situation #3: Temporary Shift Handover
PHMSA recognizes that shift handover does not happen in a vacuum. There may not always be a clean 8-to-5 shift for Controller A, followed by another clean shift for Controller B, and another clean shift for Controller C.
There are extenuating circumstances that may require temporary shift handover to another controller, a supervisor, or another control room personnel who has authority to perform the functions of a controller on a temporary basis.
The key is to go back to the control room procedures to dictate how to respond to each unique situation.
The CRM Rule FAQ guidelines provide detailed guidance on what is expected in these situations: “The operator’s procedures, training, and practices must address the appropriate level of hand-over of responsibility for short breaks, or other times, when the controller leaves the console.
“Operator guidelines should consider the controller’s proximity to the console, duration of absence, and the type of alarm interface (e.g., audible vs. visual alarms) in use. An operator’s program for cross-training controllers on multiple consoles can enhance flexibility to backup controllers for short breaks. Based on factors like these, an operator can have more than one strategy in place to ensure adequate console coverage is maintained.”
This non-standard situation highlights the importance of proactively focusing on procedures, training, communication, and recordkeeping.
- Does everyone involved understand the procedures for the situation?
- Is everyone trained on how to follow the procedures for the situation?
- Is the situation being effectively communicated to affected parties?
- Is there proper recordkeeping to record the actions taken during this situation?
When these elements are in place, controllers and related personnel understand exactly what their responsibility is in the situation. Taking these steps ensures pipeline safety, effective operations, and compliance with PHMSA requirements.
The Importance of Recordkeeping to Support Non-Standard SHO
Each of these non-standard situations in a pipeline control room boil down to recordkeeping. The accuracy and reliability of the SHO records are the difference in a safe and compliant pipeline control room.
EnerSys recognizes the importance of recordkeeping in the control room. We help small to medium pipeline operators utilize software to ensure accurate and reliable SHO recordkeeping.
Specifically, the CRMgr module in our POEMS CRM Suite helps operators support safe operations while achieving compliance with the CRM Rule:
- Supports structured shift handover and proper recordkeeping.
- Manages shift handover reports, plus incident logging, Hours of Service, and Fatigue Mitigation reports.
- Simplifies the audit process to provide PHMSA auditors with reports required by API 1168.
Talk to our team today about scheduling an educational demo of the CRMgr module. We would appreciate the opportunity to help you better manage non-standard SHO situations in the control room.