BY MICHEL OLIVER

I have been thinking a lot lately about what motivates people, and specifically, what motivates a pipeline operator to dedicate their valuable resources – time, money and people – to a new program? 

It makes sense to me that no company, at least not one that expects to make a profit, will invest in a new program unless the benefits of that program substantially and measurably outweigh its costs. 

So, I’m thinking that maybe the three main drivers for starting a new program are safety, compliance and financial benefit. In other words, to justify a new program, it needs to help the company save people’s lives, demonstrate compliance with regulations, increase revenue or decrease expenditures. And ideally, it will do all of the above, right? But can you think of others?

I might be a little biased since I worked in pipeline control rooms for a few decades – and directly with PHMSA for a little while – but I believe that most of the programs prescribed by our pipeline safety regulations produce benefits that significantly and measurably outweigh their costs, and few more so than those required by the Control Room Management Rule.  

It has been my experience that most companies don’t think twice about dedicating significant resources to personnel safety – and for good reason – no one wants to see people get hurt. And if you fail to take personnel safety regulations seriously, your people can most-definitely get hurt, or worse. Additionally, there’s a good chance (at a minimum) that you will eventually be hit with some hefty OSHA fines. 

But it seems that some of those same companies do not dedicate the same level of resources to process safety management, and particularly, Control Room Management (CRM) requirements. Experience has shown that if you fail to take this element of process safety management seriously – well, in case you’ve not been paying attention for the last few decades – we’re talking about some potentially serious consequences.

So, this begs the question – Why not take process safety management, and particularly, the element of Control Room Management (CRM) requirements, more seriously?

Let us – for a moment – set aside the more obvious benefits of compliance with PHMSA’s CRM Rule. Forget that compliance will lead to a safer pipeline operation – which it will. And forget that compliance will keep the regulator from shutting down your operation or hitting you with a nice little fine.

Let us – instead – look at this from an employer/employee perspective. Let us ask – “What do I, as an employer, owe to my employees?” You know – beyond a safe work place and a decent paycheck.

  • – As an employer, are you obliged to define your employee’s role within the organization, along with their specific responsibilities and express authority to make decisions and take action? While you’re at it, should you also establish and help them maintain the qualifications they need to do their job?
  • – What about the information and tools your employees use to do their jobs as you have defined them – should you do what you can to ensure that the information is accurate and that the tools are fully functional? And, while you’re at it, should you try to ensure that any emergency alerts you send to your employees are meaningful and timely, and that there’s enough time for an appropriate response?
  • – Are you obliged to ensure that your employees get the initial and on-going training they need to do their jobs? Should you make sure that the training you provide is as effective as it can be?
  • – Do you think it might be beneficial to recognize any special job-related challenges that your employees might have – particularly those with safety-sensitive jobs who work extended hours – and to help them mitigate impacts to their personal safety and to the integrity of your continued operation?
  • – Do you owe it to your employees to discuss significant changes with them that will affect the job you have asked them to do or impact their ability to do that job?
  • – And finally, is it incumbent upon you, as an employer, to periodically assess your policies, processes, programs and procedures to ensure they are effective? Is this not especially wise in the wake of an operational event – to make sure that any causal or contributing deficiencies are addressed, and that your employees are trained to prevent or effectively respond to these events in the future?

I will assume that you have answered in the affirmative to each of these questions. I will also assume that you know by now that the obligations you have accepted are, in effect, what is required by PHMSA’s Control Room Management (CRM) Rule.

So – I will ask my question again – why not take process safety management, and particularly, the element of Control Room Management requirements, more seriously? Put another way – what are you waiting for?

Note: This is the first of what I hope will be a series of blog entries on gas and hazardous liquid pipeline operations, regulatory compliance – and more-specifically, on pipeline controllers, control room operations and the key elements of the Control Room Management Rule. If you have any questions or comments about this blog or would just like to talk about anything related – please feel free to reach out to me at: michel.oliver@g2-is.com