In a recent industry meeting in a room full of pipeline control room managers, I was involved in a roundtable conversation about the operators’ recent audit experience. In almost every case, the operators had to take extra effort to collect, verify, and organize compliance documentation in advance of the audit. Some of the operators described this as a significant effort.
Today’s pipeline control room operators need a system to accurately record data, create logs, and generate and store reports that satisfy the requirements of a control room audit. With today’s available technology, there are many opportunities to advance the capabilities of your operation rather than to be bogged down scrambling to gather data when you receive an audit notice.
What exactly is PHMSA looking for when reviewing your data? Consider these vital categories of data collection and reporting that you should focus on so that you can spend more time achieving high-performance pipeline control.
Focus on Adequate Information for Your Control Room Audit
Records are a critical component of meeting the CRM Rule requirement for providing adequate information.
– Point-to-point verification: You need to be able to verify safety-related points in your SCADA system. This includes a process to “verify the actual physical location and sequence among other devices and equipment at the location and verify the data, information, and any control or alarm functions to/from the point are being accurately represented on all SCADA displays on which it resides.”
– Leak detection: Pipeline operators must be able to provide adequate information about their internal testing and verification in leak detection scenarios, especially if you lose critical functionality in your SCADA system. Specifically, PHMSA is looking for operators to verify “communication of pipeline operational data such as dial-in polling of field equipment, manually reading gauges, and field instrumentation.”
– Timeliness in verification: Another critical area where data supports your ability to provide adequate information is whether your control room is capable of completing point-to-point verification “in a timely manner.” What is PHMSA looking for?
- Data points already being used in the control room. These points used by the controllers “should be verified the same day a verification process became necessary.”
- Data points added or checked out as part of a system enhancement or replacement. These data points should be verified “before those data points are turned over to controllers for use.”
Data is a Critical Component of Alarm Management
Accurate data should support your alarm management system. PHMSA is looking to verify that controllers were provided with accurate and timely data in your SCADA system and HMI displays to react appropriately in each operating condition.
If you use an alarm management system that is independent of your SCADA system, then you need to be able to prove that both systems talked to each other to provide controllers with accurate data at the optimal time.
Additionally, according to PHMSA, you should periodically review the alarms “to reveal opportunities to improve your alarm management capabilities.” Leveraging the data generated by your system will allow you to find opportunities to continually improve and remain compliant.
Change Management is Supported by Data
From a compliance standpoint, the process of managing change in the control room is not satisfied by merely having emergency procedures. PHMSA requires that operators “develop documentation that identifies when and under what conditions the control room has been contacted by field personnel.”
To verify and authenticate this communication, PHMSA requires operators to record accurate data about incidents, accidents, and other events “to confirm that emergency contact to the control has been made as required.”
Be sure that you have the capability to quickly and easily pull the data to satisfy the requirement for change management. You do not want to be scrambling to look up records well after each relevant, risking inaccurate reporting for the audit.
How Do You Put All of the Relevant Data Together?
If you find yourself having difficulty gathering all of the relevant data for an audit, you should evaluate the condition of your internal systems. Are some aspects slow, clunky, or outdated? Do some systems not talk to each other? Do you have to rely on paperwork to support some areas?
Your systems should be optimized to generate the data you need, create logs that can be easily accessible, and generate reports that satisfy the PHMSA audit requirements.
Fortunately, there is an off-the-shelf software solution that enables you to organize your data for a control room audit. EnerSys offers the Control Room Management (CRM) suite to help operators comply with the CRM Rule without having to change your SCADA system or HMI.
The CRM Suite includes software components for control room management, alarm management, fatigue mitigation, point-to-point verification, and compliance management. Our software ensures adherence to the CRM Rule, the ability to quickly generate reports using your data, and more time to focus on growing the capabilities of your pipeline.
To see our software in action, we would like to schedule a brief, no-obligation demo with your team. To get started, please complete our contact form, email our team at email@example.com, or call us directly at 281-598-7100.