With POEMS, EnerSys has created an implementation process that strikes a balance between an off-the-shelf approach and the unique needs of pipeline operators. Although the compliance process will be unique for every pipeline operator, the basic sequence is the same for all: Assess – Implement – Operate – Refine.
Focus on Operations First
Operators must have a documented plan to be in compliance with CRM regulations, 49 CFR Parts 192 and 195. To simplify the audit process, the operator should have a mechanism to easily provide documentation showing performance against the CRM plan. Although most pipeline operators have an operating approach in place, it may not be universally understood and well documented.
The POEMS process begins with a structured approach to examine existing compliance, followed by appropriate modification or replacement of control room operating plans, procedures, and policies. This approach is reinforced by the implementation of software tools that support compliance and streamline record keeping.
Defining Current CRM Status, Setting Expectations
The first step in the POEMS process is a CRM Executive Presentation to all of the operator’s key personnel. This presentation is critical as it covers all the requirements of the CRM rule, the POEMS process, an introduction to the “why” and the human factors science behind alarm management and situational awareness—all designed to facilitate change with controller involvement and training throughout the process (Figure 2).
The CRM Executive Presentation is followed by a Kick-Off meeting to establish the scope of work, individual responsibilities, milestones, and project timelines.
Next, a Front-End Gap Analysis (FEGA) will determine the operator’s current state of automation, operating requirements, the level of compliance to the regulations and the operator’s current operating practice. The CRM FEGA uses the PHMSA inspection protocol, 49 CFR, and API guidelines as the team conducts a CRM assessment to capture compliance philosophy and current state information. The captured data then becomes the basis for establishing a compliance plan.The result of the CRM FEGA is a report highlighting how the operator’s plans, procedures, and policies compare with the inspection protocol. The report will give the operator a priority plan to implement the changes required to meet the regulations. Following completion of the CRM FEGA, and where implementation or update of the SCADA system is required, the company performs a SCADA Assessment FEGA. The SCADA Assessment identifies the current state of the company automation infrastructure then identifies and quantifies scope of the change required from a SCADA / HMI perspective.
Following the FEGA, orientation workshops are conducted to introduce the client to the core concepts behind a high performance PHMSA-compliant control room. This is also when the customer’s team is introduced to the POEMS operating philosophy, high-performance HMI philosophy, and alarm management philosophy. At this stage, workshops are conducted to create the design for customer-specific POEMS implementation.
benefit: with all stakeholders attending the fega and orientation workshops, everyone is on the same page, the priorities for change and the effort required are understood.
Implement |Part 1
Updating Control Room Plans, Policies, and Procedures
The operator must have a Control Room Management Plan (CRMP) to meet the requirements of 49 CFR. The results of the FEGA will prioritize development and modification of policy and procedures to ensure a full implementation of the CRM rule.
This effort will identify all gaps into the plan and ensure full compliance to the PHMSA CRM audit protocol and the standards incorporated by reference, including:
- API RP 1165, Recommended Practice for Pipeline SCADA Displays
- API RP 1167, Pipeline SCADA Alarm Management
- API RP 1168, Pipeline Control Room Management
The CRMP is developed after the Procedures Workshop. The CRMP gives an overview of how to safely and efficiently control and monitor pipeline systems remotely in compliance to 49 CFR Parts 192.631 and 195.445 (Figure 3).
PHMSA places great importance on a properly documented CRMP. Established by senior leadership, the CRMP sets the context for all decision making as the CRM compliance plan is defined and implemented. Having a thorough understanding of the CRM rule and the documentation requirements minimizes both risk and resistance to change. The CRMP covers the following topics:
Roles and Responsibilities. This is the starting point for development of all other procedures and where opportunities are identified for efficiency in use of human resources.
Adequate Information. Addresses how controller shall stay apprised of the operating condition.
Fatigue Mitigation. Demonstrates how your company educates control room personnel about the risk of fatigue, recognizes fatigue, mitigates fatigue, and utilizes controller shift schedules for minimal fatigue.
Alarm Management Plan. Provides guidance for the implementation of advanced alarm management.
Change Management. Demonstrates how changes to control room operations are managed and governed by effective processes and procedures.
Operating Experience. Addresses how controllers gain and share operating experience, and assures that that experience is not limited to normal operations.
Training. Provides for training requirements and documentation of training.
Compliance Validation and Deviation Management. Defines the mechanism for assuring compliance, and defines the mechanism for deviation from the requirements of the control room management plan when operating conditions dictate.
Next Up Implement | Part 2
Find out more on how POEMS can impact your Pipeline Control Room