During this year’s SGA Operations Conference, our team heard from pipeline operators about their company’s challenges pulling together records for a PHMSA audit.
Our team was involved in conversations, especially during the SGA Gas Control meeting, about how to simplify the recordkeeping process to demonstrate compliance with the Control Room Management (CRM) Rule.
One of our team members, Regulatory & Software Support specialist Ross Adams, attended the SGA Ops conference and will be providing answers to your pressing audit questions to help you understand how to make the audit process easier. Our goal is to help you understand how to get all of your compliance records ready at your fingertips and organized in a way that will show the auditor your proof of compliance.
Question: How Can We Catch Up to the Original CRM Rule and Recent Addendums?
Answer from Ross Adams: We’re seeing that the industry is working diligently to catch up to not only the original CRM Rule, but especially this year’s addendums to the rule.
Specifically, the challenges are identifying “others” who have authority to direct or supersede the technical actions of a controller (Roles & Responsibilities), as well as the necessity of implementing a team training program for those who are reasonably expected to collaborate with controllers in the control room.
There’s a lot of catch-up going on, there’s a lot of diligent work happening, and a lot of ideas being shared. What we’re seeing is that not only are operators seeking to reach a place of compliance, but they’re asking a lot of questions such as, ‘How do I make this effort to seek continuous improvement in my CRM Rule compliance an easier task?’
This points to the use of software. It points to the integration of resources, streamlining the means of documentation, and achieving interoperability by having all of your tools talk to each other to eliminate gaps in communication.
Question: How Should I Account for Deviations?
Answer from Ross Adams: After digesting presentations at the conference and conversations with operators, and even considering my own interpretation of the CRM Rule, I have identified three different types of deviations that operators are concerned about.
1. A deviation in terms of how you write your policy compared to the PHMSA expectations.
2. An operational deviation when personnel do not follow what you put in your policies and procedures.
3. An Hours of Service deviation that is pertinent to your Fatigue Management program.
Each of those deviations requires evidence and proper documentation to satisfy an audit.
What’s important is that you document deviations in accordance with the requirements of the rule, that you are aware of how those deviations affect your operating condition, and that you consider whether you are able to operate in a safe and effective manner. If not, then how are you mitigating the risks of a deviation? Essentially, if there is an increased level of risk, then it becomes a safety-related issue.
Then, the question becomes how are you documenting these deviations to ensure that you can satisfy an audit inquiry?
Question: How Should I Approach the Use of Software to Support An Audit?
Answer from Ross Adams: For the most part, the industry has identified software as the solution to support an audit. Not that many control rooms make their documentation by hand anymore, but there is a growing issue of control rooms using multiple tools to try to produce and manage records.
Then, there’s the situation where some companies have developed advanced software for the purpose of CRM compliance. However, many companies only focus on one particular area of the CRM Rule, such as alarm management.
Ideally, operators should consider a holistic approach to CRM software tools. There is a level of documentation and familiarity with the tools that can be achieved so that when you are facing an audit, you won’t have to scramble for records. You won’t have to put two or three people in a room trying to sort through hand and digital records. You’ll just be able to pull those records up in a way that’s quick and efficient, and demonstrates that you’re committed to compliance.
At a foundational level, you should look for something that’s easy to use and a one-stop shop. No one wants additional passwords they have to memorize, but, even more importantly, you have to consider that your controller’s job is to ensure the safe operations of the pipeline.
If controllers are having to flip back and forth to gather data in abnormal or emergency operating conditions, if it’s difficult to find and effectively log actions, or if controllers cannot find older logs that can help make decisions in the present, that’s something that you need to address through more effective use of software.
How Does EnerSys Help Operators Utilize Software for an Audit?
Answer from Ross Adams: EnerSys has taken a holistic approach to the control room in terms of compliance and control room management through our POEMS Control Room Management (CRM) suite.
Additionally, the software allows for easy integration of people and teams to utilize the tools in the software. Operators should be excited to have access to tools that can link teams together — the control room and the field, the control room and management, etc. — and then close the loop on required tasks in a way that brings the control room to the center of operations.
Our team appreciated the opportunity to be involved in critical discussions at the SGA Ops Conference to find solutions to PHMSA audit preparation. To have further discussions about implementing a holistic software solution to make compliance records more easily accessible, please complete our contact form, email our team at firstname.lastname@example.org, or call us directly at 281-598-7100.