PHMSA Enforcement Actions Review: It’s Time to Update Your CRMP

PHMSA publicly reports enforcement actions across all areas of pipeline operations, including the pipeline control room. Our team recently dug into the 2020 PHMSA Enforcement Actions related to violations of 49 CFR 192.631 and 49 CFR 195.446 control room management.

We found several infractions related to missing, inadequate, or incomplete Control Room Management Plans (CRMPs). We have concluded that operators need to spend time implementing, revising, or updating their CRMP to ensure alignment with PHMSA requirements and to support pipeline safety.

We can help by providing a Compliance Review to answer key questions of whether you are doing what you said you would do in your CRMP and if your CRMP is in compliance with PHMSA audit protocols.

First, it’s important to understand the current CRMP challenges for operators to get started identifying areas for improvement.

Current CRMP Challenges for Pipeline Operators

PHMSA reported the following CRMP violations in their 2020 Enforcement Actions report.

• Failed to have and follow a written CRMP that was referenced in an O&M manual.
• CRMP did not include a procedure for determining which pipeline facilities meet the definition of Control Room subject to 49 CFR Part 195.
• CRMP failed to define Roles and Responsibilities of controllers during normal, abnormal, and emergency operating conditions.
• Similarly, CRMP did not define “others” who have the authority to supersede the actions of a controller in each operating condition.
• CRMP did not include procedures for fatigue mitigation.
• An operator had procedures for fatigue mitigation, but controllers failed to follow the CRMP procedures.
• CRMP did not provide adequate information to control room personnel.
• CRMP did not provide adequate guidance on required documentation to validate deviations.
• CRMP did not provide adequate procedures for reviewing the operator’s training program to identify potential improvements.

Going back to the 2019 PHMSA enforcement actions, we found other examples of CRMP violations and issues.

• CRMP lacked requirements for the review and approval of deviations when the deviations could impact pipeline safety and the safe operation of a pipeline system.
• CRMP was inadequate because controllers lacked the necessary information to monitor and control all or part of a pipeline facility through the back-up SCADA system.
• CRMP needed to be amended to provide adequate guidance on how to demonstrate the reason for any deviation from procedures.
• CRMP did not provide adequate instruction to controllers on how to use appropriate fatigue measures when working during certain high-risk hours.
• CRMP did not establish a maximum limit on controller Hours of Services (HOS) to provide for an emergency deviation for the safe operation of the pipeline.
• CRMP did not provide parameters or thresholds for determining whether controllers had sufficient time to analyze and react to income alarms.
• CRMP was missing Alarm Management sections on maintenance, alarm philosophy, detailed design, and other topics.
• CRMP lacked adequate information to help controllers understand how to respond to each operating condition in the correct order.
• The operator of a pipeline facility failed to maintain adequate records documenting deviations from the CRMP to maintain safe operations.

What To Do About CRMP Violations and Challenges

As you can see from our list covering the previous two years, there are many different types of CRMP violations, some ranging from simple fixes to significant violations. For example, one operator’s lack of a CRMP, along with other non-control room violations, cost the operator tens of thousands of dollars in civil penalties.

For some operators, you may need to start the beginning of actually developing a CRMP. Perhaps your pipeline assets recently came under federal jurisdiction and now you need to build out a CRMP. We can help.

Or, you have a CRMP, but it has not been recently updated or you have not reviewed whether it is compliant with the latest PHMSA regulations. We can help.

Our Plan of Action to Address CRMP Challenges

1. We will perform a Compliance Review of your CRMP to measure the plan’s level of policy compliance, per the PHMSA audit protocol, to verify compliance. We will perform the CRMP analysis using our software module, ComplyMgr.

Our team will make observations, perform interviews, and review records to evaluate proper 192.631 and 195.446 control room management implementation. This helps answer the question: “Is what you are actually doing what you said you would do in your CRMP?”

You will receive a gap analysis report complete with a corrective action plan, as well as a baseline assessment from which to perform future compliance reviews, track progress, and measure continuous improvement.

2. We will leverage the capabilities of the Compliance Log in our CRMgr software module to provide you with the necessary tools to track compliance with both PHMSA 49 CFR Part 192 (transport of natural gas) and Part 195 (transport of hazardous liquid through liquid pipelines).

3. The combination of gap analysis using our software tools and support from our subject matter experts will enable your operation to implement or update a CRMP that satisfies each PHMSA requirement for control room management.

– Reach out to our team today to schedule a personalized CRMP compliance review. We will also schedule an educational demo of our ComplyMgr and CRMgr software modules.

Call us at 281-598-7100 and ask for Ross Adams to set up a preliminary consultation. Alternatively, complete our contact form or email us at sales@enersyscorp.com to get started.