In the process of managing the control room on a daily basis, it is easy to lose track of where you and the control room stand in regards to complying with the PHMSA CRM Rule.
Ideally, you would like to perform a daily review of controller activity and regularly audit your team’s performance against your Control Room Management Plan (CRMP) and internal policies and procedures.
Additionally, it’s a good idea to periodically review the guidelines provided by PHMSA and the most recent FAQs to refresh your thinking about compliance. Consider taking these steps to evaluate your control room team performance and realize the ideal (and complaint) control room.
Step 1: Review the PHMSA CRM Rule
You probably read the CRM Rule backward and forward when it was released in 2011. However, it’s a good idea to go back through the key documents, FAQs, and supplementary whitepapers to ensure complete understanding.
Why is this important? As time passes, our recollection about the guidelines may shift to what we think is required compared to what it actually says. Or, how you interpreted a directive in 2011 may be different now based on changes to the industry, mainly because of technological advances
Additionally, as state auditors begin to take a larger role in compliance, being highly educated in the current rule and its interpretation can be an important asset to your operation.
It’s good practice to take time each year to re-review the CRM Rule text, along with PHMSA updates, and refresh your approach to the rule so that you can make necessary updates to your CRMP and internal procedures.
Step 2: Review the Latest CRM Rule FAQs
PHMSA issued new FAQs earlier this year that included precise deadlines to achieve compliance. If you felt overwhelmed by the latest clarifications released in January, you may have missed critical details.
Now that some time has passed, it’s a good idea to re-review the new FAQs concerning Team Training, Roles and Responsibility, and other critical areas. The full list of new FAQs that you should review include:
Roles & Responsibilities
- B.06: Who has the authority to direct or supersede the specific technical actions of a controller?
- B.07: What is the responsibility of individuals with authority to direct or supersede the specific technical actions of a controller?
- B.08: What qualifications are required for an individual to be authorized to direct or supersede the specific technical actions of a controller?
- B.09: When must operators define the roles, responsibilities and qualifications of others with the authority to direct or supersede the specific technical actions of a controller
- B.10: Must an operator establish roles, responsibilities, and qualifications of others with the authority to direct or supersede the specific technical actions of a controller if the operator does not intend to allow such individuals?
- G.04: Do the lessons learned in a training program apply to accidents/incidents/events in which an authorized individual directed or superseded the specific technical actions of the controller?
- H.05: Who is required to participate in control room team training and exercises?
- H.06: What skills should be included in control room team training and exercises?
- H.07: How should the training and exercises be conducted?
- H.08: When must team training and exercises be completed and how frequently must subsequent team training exercises be conducted?
- H.09: Does every team training exercise have to include a controller?
Compliance and Deviation
- J.05: What documentation is required for those authorized to direct or supersede the specific technical actions of a controller?
- J.06: What documentation is required for team training and exercises?
Step 3: Make a Checklist to Verify Compliance
After reviewing the CRM Rule guidelines and gaining a deeper understanding of the latest requirements included in the CRM Rule FAQs, you should consider creating a checklist to verify compliance.
A checklist has additional benefits of preparing your operation for an audit. By taking the time to review your control room compliance independent of an audit situation, you will already be prepared to authenticate your control room when you actually face an audit.
What should be included on your checklist? Consider including these verification categories:
- Are Roles & Responsibilities clearly defined and understood?
- Am I providing adequate information to controllers in the SCADA and HMI?
- Are controllers equipped to achieve situational awareness (SA)?
- Have I established a reliable Fatigue Mitigation process?
- Have I authenticated my Alarm Management program?
- Have controllers and other personnel completed a Team Training program?
- Do I have the ability to capture, document, and report compliance deviations?
- Overall, can I validate control room compliance when audited?
EnerSys Makes It Easier to Complete These Steps
EnerSys built an off-the-shelf software suite specifically to support control room managers to achieve compliance and manage the control room.
The POEMS Control Room Management (CRM) Suite enables managers to verify compliance by matching internal policies against the CRM Rule guidelines, generate reports that exceed PHMSA requirements, and house all documents in one location for easy access during an audit.
Our proprietary software handles the day-to-day, monthly, and yearly recordkeeping process to allow you to spend more time managing the control room and less time scrambling to find records, verify compliance, and update policies and procedures.
We would appreciate the opportunity to schedule a free, no-obligation demo to review the software capabilities that will enable you to run the ideal control room. To schedule a brief demo of the CRM Manager software, please complete our contact form, email our team at firstname.lastname@example.org, or call us directly at 281-598-7100.