The PHMSA audit process for control room inspections has matured as part of their three-year inspection initiative. For many operators, this means a greater need for PHMSA audit support to satisfy an inquiry.
The central challenge for operators is that PHMSA is going deeper into audits to verify compliance with the Control Room Management Rule (CRM Rule – 49 CFR 192.631 for natural gas and 195.446 for hazardous liquids).
In a recent interview at the AGA 2021 Fall Operations Conference, EnerSys General Manager Ross Adams shed light on the specific ways that PHMSA is taking a more thorough approach to the audit.
We encourage you to watch Ross’ interview with EnerSys CEO Russel Treat to learn more about the latest PHMSA audit trends. We also recommend preparing your control room for a future audit and taking the appropriate steps to ensure audit readiness through our support.
PHMSA Audit Support: What To Prepare For During the Audit
One of the key lessons about the current PHMSA audit process is that inspectors are looking more intently at your implementation of policies and procedures.
It’s not enough to have policies and procedures that align with the CRM Rule. You must also provide the appropriate documentation and records that validate that control room personnel followed the procedures.
You can see examples of this throughout the 2021 PHMSA Enforcement Actions that we captured in our recent article.
– Roles and Responsibilities: One operator had findings pertaining to their lack of implementation as required in 195.446 for the operation of a liquid pipeline.
PHMSA determined that the operator’s “procedures are inadequate to assure safe operation of a pipeline facility. Specifically, the written procedures did not adequately implement the requirement that operators define the roles and responsibilities of a controller during normal, abnormal, and emergency operating conditions.”
– Alarm Management: PHMSA determined that an operator’s procedures were inadequate because their ”alarm management plan does not adequately implement the requirement that operators review SCADA safety-related alarm operations using a process that ensures alarms are accurate and support safe pipeline operations.”
– General Requirements: A natural gas pipeline operator faced a proposed civil penalty for multiple CRM violations. One of the findings was due to the failure to implement controller training procedures when a controller is working in a control room that uses a SCADA system.
PHMSA noted that the CRM Rule requires operators to have and follow written control room procedures that implement the requirements of 192.631 in such a situation.
– These are just three examples of implementation issues that we identified in the 2021 PHMSA Enforcement Actions. There are many more examples that we identified across multiple sections of the CRM Rule.
That’s why it’s important for operators, control room managers, and regulatory managers to understand the issues that need to be navigated during the PHMSA audit process so that you can prepare for a successful audit.
PHMSA Audit Support: Consider a Pre-Audit Review
Our focus at EnerSys is supporting the control room. We help operators maintain safe, efficient, and compliant operations that comply with the latest PHMSA regulatory requirements.
We are currently focusing on providing pre-audit support for operators. Specifically, we recommend utilizing our ComplyMgr software tool, which can be used to conduct a Compliance Review of your CRM Program.
Starting with this approach creates a clear understanding of gaps in your Control Room program. It will also enable us to propose corrective action based on your operation’s compliance state so that you can bring your activity into alignment with the CRM Rule.
Then, when it’s time for the audit, ComplyMgr ensures that all documents are in place, that audit preparation and annual reviews are well documented, and that your team is always audit-ready.
As the PHMSA audit process continues to mature, you will face greater challenges validating compliance with the CRM Rule. Make sure you have the appropriate tools so that you can satisfy a PHMSA audit inquiry and pass the audit.
– Contact us today to schedule a pre-audit consultation and ComplyMgr demo. We will examine the current state of your control room and show you how our software helps identify compliance gaps. Through our support, you will be ready to achieve Natural Compliance in the control room.
Call us at 281-598-7100 to speak with EnerSys General Manager Ross Adams or VP Business Development Dale Schafer about PHMSA audit support. You can also reach us via email at sales@enersyscorp.com to schedule a consultation/demo.