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In January 2017, the Pipeline and Hazardous Materials Safety Administration (PHMSA) changed the scope of the regulations surrounding pipeline operators’ Control Room Management (CRM) programs. Let’s take a closer look at the new regulations changes for control room management.
THE FINAL RULE (FR) AND ITS NEW REQUIREMENTS
The new published Final Rule (FR), containing multiple areas of new regulations, specifically addressed two significant requirements for operators’ CRM programs.
The first required operators to immediately define the roles, responsibilities and qualifications of others with the authority to direct or supersede the specific technical actions of a controller. This final rule was effective March 24, 2017. From January 23, 2017 to March 24, 2017, the rule extended to each operator of a pipeline facility with a controller working in a control room, monitoring and controlling all or part of a pipeline facility through a SCADA system. They had to identify who the “others” were, what actions they may perform in their ability to supersede the actions of the controller, define what their roles and responsibilities are, and implement a qualification process to ensure those “others” were indeed qualified to take the actions they were taking.
A question that has been raised from this is: does this mean we should add another covered task to our Operator Qualification (OQ) program? This question brings up the fact that an operator should use the four-part test from the OQ regulation to determine if the “others” tasks fit into the definition of a covered task.
The second part of the new FR, as it relates to CRM, is the requirement in Subpart H of the control room management regulation addressing training. It states, the training program must include control room team training and exercises that include both controllers and other individuals, defined by the operator, who would reasonably be expected to operationally collaborate with controllers during normal, abnormal or emergency operations.
Operators must comply with the team training requirements under this paragraph by no later than January 23, 2018. As of September 2017, the industry has heard very little if anything as to what expectations PHMSA has regarding this new requirement. The CRM Implementation Team has a scheduled meeting near the end of September to address the FR language.
IDENTIFYING THE CONTROL ROOM PERSONNEL
This much is certain, the control room team must be identified, their roles and responsibilities established, and a formal training process implemented. In light of the requirement, the following team members should be considered.
- Persons responsible for reacting to and communicating with the control room about abnormal and emergency situations.
- Persons responsible for collaborating with controllers during normal operating conditions as it relates to the operating conditions of the pipeline facilities the controller is responsible for.
- Persons responsible for collaborating with controllers during abnormal operating conditions as it relates to the operating conditions of the pipeline facilities the controller is responsible for.
- Persons responsible for collaborating with controllers during emergency conditions as it relates to the operating conditions of the pipeline facilities the controller is responsible for.
- Management personnel that may have the company authority but not direct supervisory authority over the controller whose comments could be construed as direction or instruction; i.e. a VP or Senior Member of the Management Staff.
- SCADA team personnel responsible for programming, configuring, and implementing the SCADA system and its components.
GETTING THE TEAM READY
A training program designed and implemented to address the operators’ assigned roles and responsibilities for each of the team members will be necessary to meet the requirements of the new regulation. To accomplish this effort an operator will need to conduct an analysis of the defined roles and responsibilities to determine what tasks are being performed by the team members.
A comprehensive list of these tasks will then be used to create a training program that will ensure each team member is properly trained and capable of performing the job tasks that have been assigned to them. These tasks should be identified as they relate to the functions of the controller and the impact those tasks may have on the controller’s roles and responsibilities, as well as the potential impact on the safe operation of the pipeline facilities.
A properly created training program will address each task as a learning objective using both knowledge based outcomes and exercise based outcomes to ensure comprehension of the material. Portions of the course materials may be delivered via distance learning processes, but the majority of the training should be instructor led by an instructor familiar with the operator’s processes and procedures for the CRM program.
The NTSB recommendations to PHMSA that created this FR language referenced other modes of transportation that have controllers and control rooms and the team training processes they use to accomplish safe operations for their respective modes. The process defined above will accomplish what the NTSB has recommended and the intent of the PHMSA published FR.
If you have questions or need assistance with your “Team Training” program, please contact us today.