The ever-changing pipeline regulatory environment means that pipeline operators need to stay on their toes when it comes to their Control Room Management safety program.
The CRM Rule (49 CFR 192.631 for the transport of natural gas and 49 CFR Part 195.446 for the transport of hazardous liquids) includes specific requirements that operators must comply with as a normal course of operations.
The question is: how can an operator best prepare for the PHMSA CRM audit? Our theory is two-fold:
- Strive for Natural Compliance where systems, processes, tasks, and recordkeeping are set up in a manner where compliance happens naturally as the work is performed.
- Implement the Plan-Do-Check-Act cycle (PDCA cycle) in the control room to create more effective audits.
In this article, we will unpack the theory of implementing the PDCA cycle to support PHMSA CRM compliance. This follows up on our presentation during the 2022 API Pipeline, Control Room And Cybernetics Conference in May 2022.
During the presentation, EnerSys General Manager Ross Adams presented a real-world customer success story of an operator who successfully matured their CRM program using the PDCA approach over the course of a year leading up to a PHMSA inspection. We will share lessons learned and solutions to support your operation’s compliance state.
CRM Pipeline Regulatory Challenge: Identify Problem Areas
Before any work can be done to improve an operator’s CRM program, there needs to be a period of self-evaluation. Every operator is different. Some have been through mergers and acquisitions that introduced new pipeline assets. Other operators recently had their assets come under federal jurisdiction (e.g. the Gas Gathering Rule).
In the case of the operator that we supported, they went through corporate changeover and wholesale operational changes that affected their assets that were subject to the CRM Rule. As it so happens, the operator in question was not prepared for the changing pipeline regulatory environment:
- Minimal CRM expertise and understanding of the CRM Rule.
- Lack of corporate buy-in to the CRM Rule.
- Silos between various groups in the new corporate structure.
- Policies and procedures were bolted together by different owners over time.
- Poor record-keeping (paper, various storage locations, lack of detail, etc.)
- Ambiguity about roles and responsibilities due to corporate change.
Thanks to a prior relationship with the operator, we were able to identify a starting point to mature the operator’s CRM program in their new operating reality. We utilized the PDCA cycle to support this activity.
Utilizing the PDCA Cycle to Support PHMSA CRM Compliance
The Plan-Do-Check-Act cycle typically starts with Planning activities, as you would suspect. However, in the case of the operator that we supported, we started with the Check portion.
The value of starting with Check was to understand their current compliance state (baseline assessment) by performing a thorough Compliance Review.
- We used the detailed and revised CRM inspection questions.
- We assessed the operator’s CRM policies, practices, and record-keeping.
- We identified 188 areas for improvement out of 369 assessment points.
We then acted on the check by implementing a corrective action plan to close gaps. This required a plan or a system to execute and manage the corrective action (e.g. Planning). Indeed, our Check and Act fed back to the Plan stage in the PDCA cycle.
Our Planning efforts centered on establishing a solid CRM policy foundation. We introduced policy revisions and re-wrote their Control Room Management Plan (CRMP) to align with the language and structure of the CRM Rule. This helped in a few different ways to address the initial challenges:
- Set clear expectations for implementation (e.g. who owns what?)
- Used as a training guide to increase operation-wide knowledge of the CRM Rule.
- Broke down silos that existed across operations.
- Created alignment between the CRMP and CRM Rule to ensure audit preparedness.
With the foundation in place, we helped the operator advance to the Do phase of the PDCA cycle. This included implementing training, systems, and recordkeeping, which was supported by the use of our robust software tools to operate according to their plan.
This was a critical step because it’s not enough to simply have a plan for Control Room Management to satisfy a PHMSA audit. Every operator needs to be able to execute the plan – and record that you executed the plan – so that you can prove to a PHMSA inspector that you did what you said you were going to do.
Additionally, the entire cycle should be in perpetual motion by looking for ways to continuously improve control room operations. This can be achieved through a regular review of your compliance state and then using the gathered information to close gaps between policies, procedures, and implementation.
Take a look at the following diagram that captures this workflow from an assessment (Check) to a corrective action plan (Act) to CRM revisions (Plan) to operating (Do) to feeding back to the beginning.
Always Ready for the PHMSA CRM Audit Notification
A strength of our workflow is its flexibility to help operators respond to PHMSA notifications. What happens when PHMSA sends a notification that it’s time for an audit of the control room? Operators who have implemented the PDCA cycle are ready to spring into action.
The starting point is going back to the Check portion of the PDCA. In most cases, we help operators transition from policy corrective action to implementation corrective action (as seen in the second diagram below).
However, in the case of the operator that we supported, PHMSA notified the operator of a coming CRM inspection approximately nine months after our initial Compliance Review and approximately three months after the new CRMP was published. Therefore, we initiated our audit support program.
The CRM audit support program reset the PDCA cycle and included a few additional audit-specific support steps:
- Performed a compliance review (Check).
- Reviewed corrective action (Act).
- Polished the CRMP (Plan).
- Focused on closing implementation gaps (Do).
- Perform a final pre-audit review.
- Briefed the operator’s audit team on what to expect.
- Supported the audit itself.
Performing the compliance review again helped us understand progress from Year 1 to Year 2 and assess the operator’s current compliance state. This also helped everyone understand how the new CRMP impacted implementation and defined outstanding issues that needed to be resolved before the audit.
Following the PDCA cycle a second time, we re-polished the CRMP, closed implementation gaps, and used our software tools to generate records that were a natural extension of their compliance-ready operations.
Using Software for Natural Compliance and Implementing PDCA
Achieving compliance with PHMSA CRM Rule requirements is about more than just creating records. Record-keeping is merely the output of acting in a naturally compliant manner and executing the PDCA cycle to support the control room.
To reach this point, operators need systems and processes in place that have clear outputs. This way, you can generate records that are adequate for compliance with your CRMP (internal) and the CRM Rule (external).
We recommend utilizing our software tools to reach this desired state:
- POEMS® ComplyMgr to drive Control Room Audit Support: identify gaps between policy, procedures, and implementation, then automate control room compliance.
- POEMS CRMgr module in our CRM software suite: capture valuable operational and compliance-related activity in a manner that promotes Natural Compliance.
In the case of the operator that we supported through the full audit experience, we utilized our software tools to pull up each requested record upon request. This saved a considerable amount of time and highlighted the quality of the operator’s program.
Plus, because the operator’s CRMP was structured to match the CRM Rule, this created a very streamlined audit process. At one point during the inspection, the PHMSA inspector commented that it was as if they had been sitting in on PHMSA team meetings discussing exactly what to look for during an audit. This was a great reflection of our software tools that were clearly developed for ease of use and with the CRM Rule in mind.
The end result was a positive outcome for the operator:
- No surprises during the audit!
- No financial penalties.
- The audit protected the operator’s reputation and permission to operate.
- The audit shifted from a punitive experience to a learning experience for continuous improvement.
- The operator’s policies, procedures, and implementation were validated.
- The operator is positioned to continue maturing their CRM program.
Ultimately, what was learned from this audit experience? Our key takeaway is that Plan-Do-Check-Act is an effective approach to adequately prepare for a PHMSA CRM inspection. Additionally, having systems, software, and procedures in place to simplify execution will help operators reduce workload, effort, time, and audit findings.
Work With EnerSys to Support Your CRM Compliance Needs
The same opportunity is available for your operation by utilizing our workflow to achieve compliance. We help gas and liquid operators mature their CRM programs, utilize software to identify gaps and prepare for a PHMSA CRM audit, and complete the audit itself.
We invite you to start by downloading our whitepaper that captures the full story of our CRM audit support for a pipeline operator. The whitepaper expands on Ross’ presentation during the 2022 API conference by presenting step-by-step details of how we supported the operator.
Then, we invite you to schedule a consultation with our team to discuss the comprehensive support that is available to your operation. We will review the current state of your CRM program, implement the PDCA cycle to refine your program, and provide you with a roadmap to naturally align with CRM Rule requirements in today’s pipeline regulatory environment.