BY COURTNEY PHILLIPS
One of the most effective and cost-efficient methods for collecting valuable knowledge on a particular topic is to attend a relevant discussion in company with one’s peers. Since the publication of API RP 1173 Pipeline Safety Management Systems, multiple conferences and workshops have been held for this exact purpose. After attending three notable safety management system (SMS) meetings this past year, I have assembled my key takeaways to share with others unable to attend.
A fundamental piece of advice was to not make the SMS a “thing” but make it the “way you work”. This is particularly true if you intend on harvesting the benefits of a holistic and systematic approach to safety. Another statement that pairs well with this advice is one that addresses a recurring question within the pipeline industry: “Why go beyond compliance?”. The answer is direct and frank…Volunteer to improve and be better; the actions taken will only be those that bring about improvement and benefit.
Key tips shared by operators advised companies to consider:
- Building a corporate level SMS, and not multiple management systems operating in silos
- Branding the corporate SMS
- Establishing a corporate SMS team composed of upper management, subject matter experts, and other relevant stakeholders to lead the effort in developing the SMS
- Establishing a dedicated safety department responsible for participating in the SMS development and ensuring ongoing execution
- Designing an initial framework of elements and expectations based on the necessary requirements and desired safety culture
- Conducting a baseline gap assessment
- Developing a detailed SMS improvement project plan, or SMS project charter, with activities clearly outlined providing leadership with an accurate roadmap that includes timelines and budgets
Common hurdles experienced by operators include:
- A lack of top management commitment and understanding of how the SMS will benefit the company
- Letting “perfect” be the enemy of “good”
- Insufficient resource allocation, both financial and staff
- Poor planning, communications, monitoring, control, or supervision
- Organizational deficiencies leading to blurred safety and administrative responsibilities
- Difficulties in maintaining SMS-related documentation, audit results, action item tracking, key performance indicator trending, etc.
Interestingly, unforeseen lessons learned were noted in areas where operators wrongfully perceived their strong points. The two “low scoring” SMS elements, when assessed against API RP 1173, but regularly perceived as operators’ strengths, were:
- Leadership and management commitment
- Risk management
Specifically, the absence of a holistic-based risk management practice that considers all types of threats (not only those prescribed for pipeline integrity), comprehensively addressing a suite of risk types (e.g. operational, process safety, environmental, reputational, and financial).
One final comment that I will add as a possible lesson learned: operators are discovering a significant amount of material that is required for a SMS already exists within their organization; these pieces just need to be organized, silos broken down, and potential gaps closed.
In summary, SMS is not a regulatory “check the box” requirement; it is not a “one size fits all” program; and it is not a “quick fix” approach to pipeline safety. SMS is a holistic and systematic framework of requirements demanding the integration of people, procedures, activities, and equipment in a way that reveals risks, encourages a learning environment, and manages safety to an acceptable level of risk.
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