As part of our team’s review of the 2020 PHMSA Enforcement Actions pertaining to the pipeline control room, we identified a handful of fatigue management violations of the PHMSA Control Room Management Rule (CRM Rule).
The violations regarding Section D (Fatigue Mitigation – 49 CFR 192.631/195.446(d)) of the CRM Rule capture the various layers required to ensure compliance with the full requirements.
- Is your fatigue management program complete?
- Are your managers trained on how to support the program?
- Are your controllers trained on the effects of fatigue?
Gaps in any of these three layers could lead to pipeline safety risks, non-conformance with the CRM Rule, fines for your operation, and inefficiencies managing controller workload.
We will examine the key steps to take corrective action for each of these layers. Keep in mind, though, that operators should take a holistic approach to ensure that all fatigue mitigation activity is unified to support the control room. You don’t want to just correct one aspect and not optimize the others. Drive toward a stronger whole, but you can start by addressing each layer of fatigue management.
Fatigue Management Corrective Action: Do You Have a Plan?
One pipeline operator was cited by PHMSA as having an inadequate Fatigue Management manual or plan (FMP) because they missed a documentation and recordkeeping aspect as part of their risk and effectiveness analysis.
The key is buy-in and engagement. It’s one thing to have a fatigue management program outlined in your Control Room Management Plan (CRMP) or to have a manual for fatigue management. It’s another thing to actually review the plan, hold others accountable for following the plan, maintain proper documents and records, and review lessons learned to refine the plan.
You don’t just want to set and forget your plan where it collects dust on someone’s desk or sits unopened in your shared document storage system.
PHMSA noted in their CRM Rule FAQs that they recommend the use of a fatigue risk management system (FRMS) as a tool for implementing fatigue mitigation. PHMSA defines an FRMS as “an operator-defined process by which a company intends to manage fatigue risk with involvement by all stakeholders including senior management.”
Additionally, PHMSA stressed that success at this stage of fatigue management requires the involvement of top management, as it is challenging to implement fatigue management without top-down buy-in.
Management-led buy-in and accountability funnels directly into the next layer of optimizing fatigue management in pipeline operations.
Fatigue Management Corrective Action: Are Managers Trained?
One pipeline operator was cited by PHMSA for a CRM Rule Fatigue Management violation for failing to provide training to supervisors on how to manage fatigue in the control room. Specifically, the operator failed to provide training on these key topics:
- Fatigue mitigation strategies.
- How off-duty activities contribute to fatigue.
- How to recognize the effects of fatigue.
The key is to provide supervisors with the tools they need to strategically support the fatigue management program or plan, manage controller workload, and identify the signs of fatigue that could lead to an unsafe situation.
In the CRM Rule FAQs, PHMSA clearly identified the fatigue mitigation effort as the responsibility of a pipeline operator to determine the fatigue risks that exist and then take the appropriate steps to implement fatigue mitigation tactics to reduce those risks. This requires supervisors to understand how to take specific countermeasures when they identify fatigue-related risks in the control room. Some examples cited by PHMSA include:
- How to quantify the potential contribution of fatigue to incidents and accidents.
- How to apply employer-specific policies and procedures related to fatigue management.
- How to optimize fatigue mitigation strategies using fatigue modeling.
- How to account for individual-specific employee differences that may impact fatigue.
Part of the strategy is to think through different situations and requirements for each controller, then embed flexibility into the fatigue mitigation plan to account for individual differences.
There should also be a mechanism for communication and two-way feedback between supervisors and controllers to identify risks, address the risks, and come to a proper resolution that enables the controller to continue performing duties safely. This starts with providing intentional and continuous training to supervisors.
Fatigue Management Corrective Action: Are Controllers Trained?
One operator was cited by PHMSA for failing to fully train controllers on the effects of fatigue. According to the operator’s fatigue training records submitted to PHMSA, four controllers failed to complete one of two required training courses in a given year.
As noted earlier, fatigue mitigation should start at the top. To be effective in real situations, though, it requires buy-in from controllers to understand how to self-identify fatigue, report fatigue, play their part in documenting fatigue to support the control room supervisor, and be involved in the solution to resolve the situation. This requires regular training and education to ensure that controllers have the tools they need to support fatigue mitigation.
We often recommend a policy that allows controllers to self-report fatigue or to identify other controllers who are showing signs of fatigue — without fear of retribution. It’s similar to a stop-work policy in the control room. This creates an opportunity for employees to openly identify fatigue as part of a healthy work culture. Developing this type of culture will encourage controllers to willingly participate in your operation’s fatigue mitigation program.
In the CRM Rule FAQs, PHMSA provided clear guidance on the specific fatigue elements that should be included in a fatigue mitigation training and education program. PHMSA cited these example topics that apply to controller training:
- Sleep physiology, sleep hygiene, and sleep pathologies.
- Sleep deprivation effects on work performance.
- Time on task fatigue effects on work performance.
- How off-duty activities contribute to fatigue.
- Fatigue effects on highway driving performance.
We know this is especially challenging to monitor controller fatigue in the pandemic environment. Many controllers are working from home or performing tasks in some form of limited isolation where they lack common areas to mitigate fatigue. This can make it difficult to track, report, and document fatigue, while also taking countermeasures. That’s why training is critical to help controllers remain vigilant in a different environment, and why communication is essential to maintain line of sight between controllers and supervisors. Stay focused on training and communication to support safe operations.
Take a Holistic Approach to CRM Rule Fatigue Management
Each piece of the fatigue management puzzle is important. But, getting the overall puzzle correct is critical. That’s why we recommend taking a holistic approach to fatigue management to remain compliant with the CRM Rule, operate safely, and see positive results from your fatigue mitigation program.
For example, if you optimize training for controllers, but controllers are not held accountable for implementing what they’re trained on, then fatigue management will eventually become just another safety training topic with no teeth. Conversely, if management is completely bought into fatigue management, but the message does not filter down to supervisors and controllers, then you will continue to experience fatigue-related risks in the control room.
Fortunately, we have software tools to help your operation optimize fatigue management:
- The FatigueMgr module in our Control Room Management software suite (CRM Suite) helps operators manage the risks associated with fatigue in the control room.
- The CRMgr module in our CRM Suite allows controllers to log fatigue mitigation tactics, enabling them to actively participate in your fatigue mitigation program.
Combined with an effective fatigue mitigation program, the tools in our CRM Suite enhance compliance with the CRM Rule. We focus on helping operators take a holistic approach to fatigue management, while also providing supervisors with the tools they need to support controllers.
Utilize FatigueMgr and CRMgr for Fatigue Management
– Included in FatigueMgr are two important tools that support fatigue management:
- Workload Analysis provides control room managers with information needed to ensure the workload in the control room is evenly distributed, decide when to add additional consoles, and evaluate workload by employee or shift.
- HOS Scheduler tracks hours of service, controller shift times by console or controller, travel time, Shift Handover (SHO) time, controller’s quality of sleep, and time spent during off-shift hours for training, meetings, and development.
Management can view reports to validate compliance and ensure safe operations, supervisors can view controller activity in real-time to identify risk areas and take action in alignment with the fatigue mitigation strategy, and controllers can achieve adequate vigilance during their shift.
– Included in CRMgr is the opportunity to complete important actions that support fatigue management:
- Controllers can log fatigue mitigation records, which is very important to satisfy a future PHMSA inspection.
- Control room managers or fatigue risk managers can log fatigue training records.
- Managers can assign reading to controllers related to fatigue awareness and your fatigue policy.
We would appreciate the opportunity to show your team more about the capabilities of FatigueMgr and CRMgr in the CRM Suite. To schedule an educational demo or consultation with our team, call us at 281-598-7100 and ask for Dale Schafer or Ross Adams. Alternatively, complete our contact form or email us directly at firstname.lastname@example.org.