How do you assure procedure traceability (control room management plans, integrity management plans, etc.) back…
When I first discussed the concept of team training as an implementation requirement for pipeline operators, someone jokingly asked me if I was talking about having to do a ropes course. It was funny at the time, but as we dig deeper into the new Frequently Asked Questions (FAQs) released by PHMSA earlier this month, the analogy is not far off.
In actuality, team training for pipeline operators is a much more technical exercise that will require changes to your policies, procedures, and operations. It also requires additional cooperation with key stakeholders outside of the control room.
So, why is there a need to increase training for teams, not just individuals? In order to answer this question, we first need to understand the history behind the team training addendum to the CRM Rule (49 CFR 192.631 and 49 CFR 195.446).
Marshall Incident Set in Motion the Pipeline Operator Team Training Requirement
In July 2010, a pipeline ruptured in Marshall, Michigan, and spilled approximately 20,000 barrels of oil. After a two-year investigation, the National Transportation Safety Board (NTSB) determined one of the main reasons why the damage was so excessive:
“Inadequate training of control center personnel, which allowed the rupture to remain undetected for 17 hours and through two startups of the pipeline.” (NTSB PAR – 12/-01)
The NTSB’s Pipeline Accident Report and the corresponding recommendations (specifically Section 2.6 for Analysis on the Control Center and Section 4 for Recommendations) led the Department of Transportation (DOT) to release an Advisory Bulletin (ADB-2014-02) in May 2014.
Both documents called for pipeline operators to improve controller understanding of relevant roles and responsibilities (read our corresponding article on the Roles and Responsibilities FAQs), as well as for operators to increase their focus on training personnel not only as individuals, but as teams.
Then, on January 23, 2017, PHMSA turned these recommendations into a rule by publishing an addendum to the Federal Register. This addendum included the following team training subsection to the CRM Rule:
What Do the FAQs Clarify About Team Training for Pipeline Operators?
The addendum to the CRM Rule dictates that collaborative training exercises must take place. The FAQs released this month provide depth of understanding in regards to how collaborative training exercises should be implemented.
For example, if you were wondering who should be included in the training, the FAQs provide the answer: control room personnel and those teams (including the “others” established in Section (b)(5)) who would otherwise be expected to interact with controllers during normal, abnormal, or emergency operations.
In order for operators to sufficiently design, implement, and execute the policy, procedure, and exercises for team training, it is imperative that the operator has a full understanding of PHMSA’s expectations. Therefore, we recommend that you take a deeper look into these FAQs and what they mean for your control room. We also want to share a few of the highlights from our perspective.
Take note that the following list of FAQs for Team Training includes more than just FAQs for Section (h). Your policy changes should reflect as much:
- H.05 – Team training includes controllers, those who inform or influence the control room, and the “others” addressed in Section (b).
- H.06 – The list of skills to be covered by team training includes soft skills and company-specific procedural training with a focus on processes where roles and responsibilities may change.
- H.07 – Computer-based or on-the-job training is not sufficient. Team training should educate, and then put the education to use via exercises.
- H.07 – Information on the effectiveness of training should be collected and recorded for the purpose of improving training.
- H.08 – The objectives and content of team training must be set by January 23, 2018, with training being completed no later than one year from that date (i.e. by January 23, 2019).
- H.08 – The operator can set the frequency team training should be performed.
- H.08 – Interim team activities between team training sessions are encouraged.
- H.08 – Changes/additions/upgrades to the training program do not require retraining before the next regularly scheduled team training session.
- H.09 – Team training exercises must include at least one controller.
- J.06 – There are extensive documentation requirements for team training, including the collection of feedback from training attendees.
How Should Pipeline Operators Begin the Implementation Process?
Because of the quick turnaround from the release of the FAQs (Jan. 16) to the first implementation deadline (Jan. 23), you might be thinking that team training for pipeline operators is as difficult as navigating that ropes course.
Certainly, the CRM Rule and the new FAQs create a unique challenge for pipeline operators. First, operators must take a solid look at their current operations to determine how applicable these rules are to them:
- From your perspective, do you see “others” frequently superseding a controller?
- How many different groups or teams work together to support the control room in decision-making?
- Having reviewed the new CRM Rule and FAQs, have you noticed opportunities for improvement that specific team training exercises would remedy?
By reviewing your current operations, you should be able to chart your course. Keep in mind, it is no accident that the new team training requirements and the new roles and responsibilities requirements were released at the same time. They are meant to further provide a more holistic approach to safe and effective control room management.
By expanding the number of roles whose responsibilities must be defined, and by bringing everyone together to train as teams, you will be taking steps to protect your controller from white noise. Implementing this process will also ensure that your entire organization operates at peak performance when responding to normal, abnormal, or emergency operating conditions.
Utilize These Resources to Support Your Team Training Updates
Even if you were ahead of the curve incorporating the CRM Rule into your operation, you will probably need to incorporate additional details into your Team Training Program. The key to remember is this is about continuous improvement. Therefore, you should always be on the lookout for the following team training updates and resources:
- More information from industry experts
- New services and software to assist operators with compliance
- New audit protocol questions published
- Upcoming additions to the FAQs
Rest assured, compliance with the rule additions will become easier for operators. This will especially be true when the next set of audit protocol questions are released. Having that deeper understanding of PHMSA’s expectations will help shape your understanding of how to move forward.
In the meantime, act quickly to incorporate the new information presented in the FAQs. Also, be sure to listen to the Pipeliners Podcast, where I joined EnerSys CEO Russel Treat for a full episode discussing team training for pipeline operators stemming from the new FAQs.
At EnerSys, we would appreciate the opportunity to discuss your operation’s specific needs incorporating the new Team Training requirements. Additionally, we would like to discuss how our POEMS software solution, Audit Support Services, and Compliance Facilitator Program can support your overall operation.