Pipeline operators and control room managers need to take time to assess the impact of the new PHMSA final pipeline safety rules on control room workload.
You may be tempted to immediately hire more controllers to prepare for the impact of the new rules. After all, PHMSA is bringing 500,000 miles of pipeline under federal jurisdiction to improve safety, which likely includes your operation.
Before you hurriedly take action, though, take a step back. Perform a review of your operation to evaluate the true impact of the new safety rules in your control room. Let’s focus on five key items that should be part of your checklist review.
1. Assess Your Culture
Starting at the beginning, the goal for today’s pipeline operators should be achieving compliance naturally. Natural compliance is the result of implementing procedures and systems in a way that as the work occurs, the compliance recordkeeping happens automatically and in the background — without impacting work efforts.
Your culture is the engine that makes natural compliance happen.
- Do controllers follow policies and procedures?
- Are controllers performing accurate shift handover?
- Is controller workload monitored and optimized for performance?
- Does recordkeeping happen as the work is performed?
- Does all personnel understand and follow CRM Rule requirements for roles and responsibilities?
The culture in your control room influences whether the answers to each of these questions is yes. There is no room for “off the books” activity or “this is how we’ve always done it” attitudes.
Operators and managers need to be aware of gaps in the culture that need to be diagnosed, addressed, and closed to ensure alignment with guidelines for safe, effective, and efficient pipeline operations.
2. Review and Update Policies & Procedures
During your review of the culture, you may identify gaps in control room policies and procedures.
Perhaps your Control Room Management Plan (CRMP) needs to be reviewed and updated. Or, you may find that your Standard Operating Procedures (SOPs), O&M manual, and emergency response plans are inadequate for today’s pipeline operations.
As we covered in this article, the onus is on operators to ensure that internal documentation aligns with external sources such as governing documents from PHMSA and best practices from industry organizations such as API, AGA, and ISA.
Take time to review your internal policies and procedures against the external guidelines to ensure that your control room is prepared for the impact of the Gas Gathering Rule.
3. Review Controller Workload
After performing two critical reviews of your control room, then dive into the controller workload to assess the condition of the control room.
Although the CRM Rule does not establish a uniform benchmark for controller workload, PHMSA does have certain expectations for operators to “establish, annually evaluate, and document the substantive adequacy of controller workload criteria.”
What does “adequacy” look like?
- Job task analysis or related evaluations.
- Periodic analysis of controller workload.
- Review of workload when significant changes are being made.
- Other analysis to help operators recognize and react to changes.
Remember, the goal is achieving operational safety in an effective and efficient manner. Use the control room workload data to guide you on achieving this objective to evenly distribute the workload amongst controllers.
4. Assess Console Availability
If you determine that you need to hire additional controllers to support the increased workload, you may need to make another consideration of whether to introduce more consoles.
Every control room is different. In the best-case scenario when new controllers are added to the roster, you would only need to adjust the timing of shifts and stagger controller schedules. The key would be ensuring accurate and compliant shift handover.
On the other end of the spectrum, you may need to hire more controllers and introduce more consoles so that the control room does not become overwhelmed.
Again, focus on safety, efficiency, and effectiveness. Would a crowded control room impact safe operations? Would there be potential for gaps in shift handover if new consoles are not added?
We understand this is not easy on operators with restricted or set budgets. That’s why we encourage operators and control room managers to perform this review now so that you can prepare for the next round of budget review to request additional funding for additional controllers and possibly consoles.
5. Use Software to Help Manage the Change
During your review of the control room, you may encounter a situation where you’re not 100 percent confident in the data you are viewing.
Whether manual recordkeeping is affecting the reliability of the data or you are depending on data pulled from outdated pieces of software, now is the ideal time to find a reliable solution for more accurate recordkeeping.
We specifically recommend focusing on the reliability of your workload analysis and Hours of Service (HOS) scheduling.
These two pieces of the puzzle are critical to accurately assess whether the workload is evenly distributed in the control room, whether fatigue could be affecting controller performance, and how to structure shifts if new controllers and consoles are introduced.
If your current process or software for performing workload analysis and HOS scheduling is not reliable, then consider an alternative solution to truly gauge the impact of the new PHMSA rules on control room workload.
Talk to EnerSys About Software Support
We built an entire suite of software tools to support pipeline operators and control room managers navigate the ever-changing world of pipeline regulations.
FatigueMgr includes a Workload Analysis and HOS Scheduler component that provides control room managers with needed information to complete these objectives:
- Ensure workload is evenly distributed
- Understand when to add additional consoles
- Evaluate workload by controller or shift
- Schedule controller shift times
- Meet shift handover (SHO) requirements
- Incorporate time off for travel, training, and meetings
Talk to our team about scheduling a phone call or an educational demo to discuss the full POEMS CRM Suite or the FatigueMgr module. We would appreciate the opportunity to help you assess the needs of your control room to meet the challenge of the new PHMSA pipeline safety rules.