Pipeline operators have many tools at their disposal to support pipeline safety and compliance. However, we have found that many operators have not implemented the appropriate tools or have gaps in their toolset to achieve what we call natural compliance.
Why is natural compliance critical? Natural compliance occurs when pipeline personnel perform their daily tasks using tools designed to streamline their work, and where those tools natively create and store records so they are available for audit and analysis. Basically, “I do my work, while records are created automatically in the background.”
The records are created with links to the relevant internal policy & procedure, industry standards, and PHMSA requirements. Arriving at this desired outcome requires tools that pipeline personnel find easy to use, and support management processes such as scheduling and review.
Having the appropriate tools will allow you to monitor duties in the control room by comparing actual activity against the expected activity, verify that control room personnel have performed their tasks in a naturally compliant manner, and then produce detailed and accurate records when your operation or control room is subject to an inspection or audit.
It’s a picture of naturally flowing into regulatory alignment as part of normal operations. The key is assessing your tools and then closing any gaps to establish the best framework for your operation.
What Tools Does the Control Room Need to Achieve Natural Compliance?
Consider these five tools that should be optimized for pipeline operations:
- Control Room Management Plan (CRMP).
- Procedures on how to follow the CRMP.
- Documentation that proves you are following the plan.
- Culture that creates accountability.
- Software to support natural compliance.
1. Control Room Management Plan
The CRMP should be continuously reviewed and updated to keep up with external and internal changes. In fact, pipeline operators are required to review and update their CRMP every 12 months to ensure compliance with the latest regulations and audit protocols.
– Externally, your CRMP should incorporate the latest rulemakings (federal and state) and industry standards that affect activity in the control room. For example, any new updates or changes to the PHMSA Control Room Management Rule (CRM Rule), such as the recent clarifications for Team Training and Roles & Responsibilities.
– Internally, your CRMP should be updated to reflect operational changes such as the addition of new pipeline assets or other assets coming under federal jurisdiction that will require additional oversight in the control room. You should also consider updating the CRMP to reflect any material changes to O&M and Emergency Response.
Tools: You need the appropriate tools to monitor relevant external and internal changes, implement changes to the CRMP, and then communicate changes to control room personnel so that they can continue to perform their tasks in a naturally compliant manner. This is especially critical in the current environment because PHMSA has made it a point of emphasis to review and evaluate each operator’s CRMP during upcoming inspections.
2. Procedures to Follow the CRMP
It’s one thing to develop a CRMP in alignment with the CRM Rule and other industry regulations and standards. It’s another thing to develop the appropriate internal policies and procedures that guide the actions of personnel in the control room.
PHMSA requires that each pipeline operator must have and follow written control room management procedures to ensure safe operations. Furthermore, the procedures must be fully integrated into operations and available to guide control room activity.
There are many examples of PHMSA dinging operators for not having the appropriate CRMP documents available to control room personnel. Operators should make the CRMP available at each console, available to each controller, and they should use the CRMP to provide adequate training to ensure controller alertness during normal, abnormal, and emergency operating conditions.
Tools: Operators need the appropriate tools to distribute the CRMP, support the creation and updating of policies and procedures, communicate changes to the CRMP, and support training efforts to ensure that personnel have up-to-date knowledge of processes and procedures in the control room.
3. Documentation of Following the Plan
Documentation is critical to prove that compliance is happening naturally in the control room. Otherwise, you cannot prove that your operation is doing what you said you would do.
The key documents that need to be optimized for compliance and safety purposes include:
- Shift notes capturing control room activity during each controller shift.
- Shift Handover (SHO) notes logging the information passed between controllers during a new shift.
- AOC’s capturing Abnormal Operating Conditions and their disposition.
- Alarm Management to capture analytical reports, their analysis, and next actions.
- Compliance deviation notes capturing the key reasons why a controller deviated from procedures, who authorized the deviation, and the outcome of the deviation.
Tools: If you have not already, your operation should move away from paper documentation to electronic logging. This way, documents can be stored in a centralized location that can be created, stored, accessed, and shared in an efficient manner.
4. Building the Appropriate Culture
Now is a great opportunity to build a culture of accountability. This requires a top-down approach to hold personnel accountable for understanding the CRMP and following the procedures. It cannot be an infrequent situation where managers and supervisors check in every once in a while, lose interest, and personnel return to their old habits.
A proactive approach is required to help personnel understand their role supporting pipeline safety and compliance, provide continuous training on how to follow the plan, and then review activity to strive for greater performance.
The goal is not to force personnel to go out of their way to follow a prescribed set of rules and regulations. That’s unnatural and could lead to safety and compliance issues trying to force-fit actions. Instead, you should continue to strive for changes to behavior and thinking that are aligned with policies and procedures. This way, when personnel perform their tasks, it will occur in a manner that is naturally compliant.
Tools: Operators have the opportunity to leverage the thinking behind Pipeline SMS (Pipeline Safety Management Systems) to support culture change in the control room. Specifically, using key methods such as the Deming Method (Plan-Do-Check-Act), Six Sigma Model, and Risk Management approach. I recommend reading my recent article in Pipeline & Gas Journal regarding the applicability of these tools.
5. Software to Support Natural Compliance
One of the key challenges for operators and control room managers is not having the appropriate software tools at their disposal to support natural compliance.
Perhaps you are currently using multiple pieces of software to update your CRMP, communicate changes to procedures, document activity, and support the culture. Or, you are missing software to support each of these areas. Regardless of your situation, you may find yourself tabbing through multiple screens or applications, unable to retrieve appropriate documents, and struggling to match up records from one piece of software to another.
This situation paints a picture of needing one, cohesive software platform to support your control room.
Tools: We recommend utilizing the software tools available in the EnerSys POEMS Control Room Management Suite (POEMS CRM Suite). The CRM Suite includes software tools to support e-logging, shift handover, and reporting to comply with recordkeeping and reporting requirements. Plus, we offer tools to support workload scheduling, responding to potential HOS deviations, and monitoring workload to ensure that controllers can safely respond to alarms in each operating condition.
Talk to EnerSys About Your Control Room Tools
After reading this information, you likely have an idea of where you need to implement new tools or close gaps in your control room. We would like to have a conversation with you and your team to discuss your current toolset and how we can provide support.
Our goal is to help your operation and control room embrace available tools to achieve natural compliance. This way, you will be equipped to constantly monitor activity, hold personnel accountable, build the appropriate safety culture, and validate activity during an inspection.
Contact us today for a free consultation about your control room. We are also available to provide an educational demonstration of our POEMS CRM Suite to further discuss our software tools. We can be reached by phone at 281-598-7100, by email at firstname.lastname@example.org, or by contacting us through our website form to start the conversation.