In the 2019-2020 “Most Wanted List” released by the National Transportation Safety Board (NTSB), there is an important recommendation under the umbrella of Integrity Management (IM) that relates to compliance for pipeline operators.
The open recommendation from the NTSB to the Pipeline and Hazardous Materials Safety Administration (PHMSA), a division of the Department of Transportation (DOT), requests that PHMSA make a concerted effort to elevate the quality and thoroughness of inspections.
In summary, Safety Recommendation P-15-011 requests that PHMSA “develop and implement specific risk assessment training for inspectors in verifying the technical validity of risk assessments that operators use.”
In anticipation of this recommendation being finalized down the road, now is the time for operators to also raise their level of validation and compliance support to ensure they pass future inspections.
The Facts on This NTSB “Most Wanted List” Item
Safety Recommendation P-15-011 is related to a notice published by PHMSA in August 2018. In the notice, PHMSA sought public comments on a published report to support improvements to gas and liquid pipeline risk models.
In the report, “Pipeline Risk Modeling — Overview of Methods and Tools for Improved Implementation,” PHMSA and the NTSB identified general weaknesses in the risk models used by pipeline operators to perform risk assessments in their Integrity Management programs. [Docket Number PHMSA-2018-0050]
Simultaneously, PHMSA sought to increase the training of inspectors who are responsible for verifying the validity of the risk models used by pipeline operators. This way, inspectors can perform their inspection in a more reliable and efficient manner to validate compliance.
How Pipeline Operators Can Proactively Support Compliance
Pipeline operators should consider three important steps to prepare for a heightened level of inspection to ensure compliance. This way, your team will not have to spend even more time validating operations.
1. Perform Risk Assessment
Start with this step. Take inventory of your risk assessment models to ensure they are up-to-date with the latest PHMSA recommendations.
According to the Pipeline Risk Modeling Report released by PHMSA, operators should evaluate the major types of pipeline risk models and the effectiveness of each type in supporting risk assessments. The four major risk model categories include:
- Relative Assessment/Index
- Quantitative System
According to the report, each model category should be characterized by its model inputs, outputs, and algorithms. This evaluation helps determine the ability to ”support pipeline risk management decisions and regulatory requirements.”
2. Align Risk Model Types and Risk Management Decisions
Once you evaluate the four major categories of risk models, consider the decision-making that falls under each category.
The Pipeline Risk Modeling Report focuses on the applicability of the risk model categories to the risk management decisions within your integrity management program. PHMSA cited these typical decisions that affect operations:
- Risk Priorities for Baseline Integrity Assessments
- Identification of Preventive Measures and Mitigative Measures
- Evaluation and Comparison of Preventive Measures and Mitigative Measures
- Consideration of Threats and their Interactions in Risk Assessments
- Benefit-Cost Analysis for Risk Reduction Options
- Integrity Assessment Interval Determination
- Support of Continual Evaluation of Integrity and General Risk Management Decision Making
Operators should take steps to evaluate the condition of each decision.
3. Involve Personnel and Stakeholders in Decision Feedback
Operators should not go at it alone evaluating the condition of each decision within the IM program.
Operators should involve controllers, control room managers, compliance/regulatory teams, IT/SCADA teams, and executives to gather feedback about each critical decision within the risk model categories.
Take this proactive approach to ask questions, have critical conversations, evaluate data, share lessons learned, address the needs of each team, and record action steps. Then, meet again to build a robust feedback loop that drives toward continuous improvement.
Why go through these steps? The goal is to enhance your ability to prove the validity of the risk models used by your operation. Then, an inspector will be able to match up your risk models with the PHMSA recommendations to validate operations.
Work with EnerSys to Enhance PHMSA Documentation
There is a very important supporting step to validate operations. How will you prove the validity of your risk models, prove the validity of decision-making, and prove team alignment to perform critical tasks?
You need robust documentation. Specifically, pipeline operators need a central location for their documentation that can be easily presented to the PHMSA inspector to support compliance.
EnerSys developed a software solution to make this process easy. Within our POEMS software suite is the ComplyMgr module that serves as a data repository for all relevant documents. ComplyMgr also links operator documentation to audit protocols, federal regulations, and industry standards.
Essentially, ComplyMgr delivers high-level integrity management support, ensures that your operation follows best practices, and enhances your ability to pass the inspection.
To have a conversation about how our software supports inspections to achieve compliance, 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 talk to a member of our team.