Every 12 months, pipeline operators are required to review and update their Control Room Management Plan (CRMP) to ensure compliance with the latest regulations and audit protocols.
For regulatory managers, the primary issue is not only authenticating the CRMP once per year but also ensuring that your operation is audit-ready.
In other words, it’s one thing to review and update the CRMP, but it’s another thing for you to be able to prove that control room personnel followed protocols, created accurate records, and can account for deviations.
How do you know that you have all of the boxes checked before facing an audit? Consider these critical steps, starting with understanding when it’s time to update your control room management plan.
Steps to Prepare for a PHMSA Audit
1. Understand when to update your CRMP. When it’s time for the 12-month review of your CRMP, start by reviewing the PHMSA website for any changes to the CRM Rule since your last review.
Consider reviewing the FAQs to identify what clarifications pertain to your internal plan. Some clarifications will not require updating your CRMP, while others will present a fresh challenge of implementing a change before a specific deadline.
You should also review the key documents — e.g. presentations, advisory bulletins, studies, and other documents — that could provide valuable guidance on how to update your CRMP to ensure compliance.
2. Validate that control room personnel followed protocols. As part of your regular activity as Regulatory Manager, you should review activity in the control room to ensure that controllers, control room managers, and other personnel followed proper protocols.
One of the big points of emphasis from PHMSA in 2018 was clarifying the Roles & Responsibilities of personnel in the control room, especially “others” who “have the authority to direct or supersede the specific technical actions of controllers” during normal, abnormal, and emergency operating conditions.
You should periodically review situations that called for “others” to direct the action of controllers to ensure that they followed the CRMP, took appropriate action, and that the events were properly documented.
3. Validate your records. Recordkeeping is critical to authenticate actions in the control room. The PHMSA inspector will expect to see detailed and accurate records that capture why certain actions were taken by a controller, who directed the actions, whether the actions aligned with the CRMP, and what the results were.
If control room personnel are relying on pen and paper recordkeeping or dated software, there is room for errors from inaccurate records, conflicting accounts, and memory lapses trying to explain what was recorded.
Then, when your regulatory team sorts through the records to prepare for a PHMSA audit, they will have a difficult time validating activity and providing the necessary information to the inspector.
This situation points to the need for smart software that can create the records and generate the reports that will satisfy the audit request.
4. Can you account for deviations? Another focal point for inspectors is reviewing “emergency deviations” that occurred in the control room.
Deviations such as Hours of Service (HOS) deviations for controllers are not ideal, which points to the need to have airtight recordkeeping to account for what caused the deviation, why the deviation was allowed, and what the results were.
PHMSA notes that operators must “maintain documentation that demonstrates any deviation from the maximum limit on controller hours of service (that) was necessary for the safe operation of the pipeline facility.”
Your role as the Regulatory Manager is to ensure that control room personnel are trained on how to adhere to the CRMP, that they understand the steps they must take before deciding to allow a deviation, and how to create records that capture why the deviation was the best decision in the particular operating condition.
Get Support to Check All the Boxes for Audit Support
Reviewing and updating your operation’s CRMP is a daunting task on its own. Then, ensuring that all personnel follow the protocol and support compliance is another critical task.
EnerSys makes it easier to check all of the boxes to ensure that your operation is prepared for an audit. Our Control Room Management (CRM) Suite software includes valuable tools to achieve and prove compliance:
- The ComplyMgr tool tracks regulatory changes to determine if policies and procedures require updating.
- ComplyMgr also takes your CRMP and matches each section to the regulations and audit protocols.
- The CRMgr tool supports compliance through advanced recordkeeping and custom reports.
- The FatigueMgr tool includes the Workload Analysis and HOS Scheduler components to track controller activity, document HOS deviations, and produce reports to satisfy the PHMSA audit.
Each of these tools is fully integrated with your operation to ensure that each activity is matched up against protocols and recorded. Then, you can use the records to generate reports that more than satisfy a PHMSA audit requirement.
To schedule a demo of the CRM Suite — specifically to see how the ComplyMgr tool matches up your CRMP with regulations to identify whether you need to update your control room management plan — please contact us today. To get started, complete our contact form, email our team at firstname.lastname@example.org, or call us directly at 281-598-7100.