The National Transportation Safety Board (NTSB) has released its latest “Most Wanted List” containing transportation-related safety recommendations. This affects pipeline operators who are responsible for the safe transport of hazardous material, as regulated by the Pipeline and Hazardous Materials Safety Administration (PHMSA), a division of the Department of Transportation (DOT).
One recommendation in particular from the 2019-2020 Most Wanted List caught our attention because of the focus on emergency response.
From the list of transportation safety improvements, R-14-014 calls for emergency planning and coordination in communities where product is transported.
While this specific item is addressed at railroads transporting hazardous material, there is strong application to pipeliners. The key is being aware of the importance of emergency response to protect people and communities.
The Facts on This NTSB “Most Wanted List” Item
Safety Recommendation R-14-014 is a recommendation to the DOT to: “require railroads transporting hazardous materials through communities to provide emergency responders and local and state emergency planning committees with current commodity flow data and assist with the development of emergency operations and response plans.”
The recommendation was issued in August 2014 following an accident in New Jersey in November 2012. In the accident, a train derailed over a bridge, causing product to be spilled into a creek and cause harm to area residents.
- 28 residents sought medical attention
- $451,000 in equipment damage
- $30 million worth of damage related to emergency response and remediation
In summary, the NTSB report identified the following safety issues that contributed to an escalation in damages.
- Training and qualification of train crews for moveable bridge inspection
- Firefighter training and qualifications
- Railroad operator’s safety management
- Timeliness of hazardous materials communications to first responders
- Failure of incident commanders to follow established hazardous materials response protocols
- Inadequacies of emergency planning, emergency preparedness, and public awareness for hazardous materials transported by train
R-14-014 is currently in limbo as an open recommendation following an “unacceptable response” from the DOT/PHMSA to the NTSB.
In July 2016, PHMSA issued a Notice of Proposed Rulemaking (NPRM) proposing revisions to regulations that would expand the applicability of comprehensive oil spill response plans. [Docket Number: PHMSA-2014-0105]
However, the NTSB wrote in their response that they believe “the NPRM does not go far enough toward providing emergency response planning assistance.” The NTSB’s response continued: “As the organizations that introduce such hazards into communities, railroads must take a more active role to protect those communities from the consequences of railroad accidents involving hazardous materials.”
How Does This Response Apply to Pipeline Operators?
While not directly aimed at pipeline operators, R-14-014 can be viewed as a reminder about the importance of establishing emergency plans, training personnel on how to follow policies and procedures during an emergency operating condition, and communicating incidents to the appropriate authorities.
In April, I will be presenting a whitepaper on this topic during the 2019 API Pipeline Conference and Control Room Forum as part of our Spring 2019 tradeshow exhibition schedule.
The whitepaper covers how to optimize your alarm management program to support alarm response and then emergency response if there is an escalation.
The critical elements of optimizing alarm management in the control room to support emergency response include:
- Planning alarm response before the response is required.
- Performing alarm rationalization and emergency response planning.
- Setting alarm limits to identify when alarm response has turned into emergency response.
- Making resources available to controllers to contact authorities, first responders, and third parties.
- Training controllers on how to view and interpret data to achieve situational awareness.
- Clearly communicating the plan throughout the operation to minimize consequence.
Work with EnerSys to Support Emergency Response
Our goal is to help pipeline operators achieve more effective emergency response. Whether its through an educational whitepaper or our software tools, such as the ALMgr component of the Control Room Management Suite, we are focused on pipeline safety.
We want to help operators and control room managers better manage the alarm rationalization process, assist controller response time, and analyze the results to improve efficiency. We also want to hear from operators and control room managers on your challenges supporting emergency response.
To have a conversation with our team to discuss challenges and potential solutions, please contact us through one of three options. Complete our Contact form, email us directly at email@example.com, or call us at 281-598-7100 to have a conversation with a member of our team.