BY MICHEL OLIVER
In my first post, I tried to lay out a few reasons why responsible pipeline operators should implement the programs associated with PHMSA’s Control Room Management (CRM) Rule. Improved operational safety and demonstrable compliance with federal regulations are two very good reasons, but I tend to look at it from an additional perspective.
From my four decades of experience working in and managing control rooms, I learned to look at work processes, along with their associated policies, procedures and programs – from both an employee and an employer perspective. That is, to always ask and try to answer the question, “What does the employee need to do the job as defined by the employer?”
Which brings me to the topic of this post.
It seems obvious that before any employer can determine what an employee needs to do their job, they first need to define the job itself – specifically, they should define: what role or roles the employee fills within the organization; what responsibilities and accountabilities they will have; what authority they will have to make decisions and take unilateral action; what qualifications they must have to do the job; where they will work (their domain); and who they will need to interact with on a regular, on-going (and periodic) basis.
Consideration should also be given to job-specific challenges and risks – fatigue, security and communications, for example – and how any foreseeable changes in operational or environmental conditions might affect the need for temporary, impromptu changes in the employee’s responsibilities or authority.
Once established, the role definition should be formalized, periodically re-evaluated, and equally understood by employer and employee. Anyone who supervises, directs or works closely with the employee should also have some basic understanding of their role, their responsibilities and (especially) their authority.
The design and construction of the employee’s work environment, the information and tools they are provided, the policies and procedures they are required to follow, and the training they receive should all be based on their role definition. Some in the industry – including myself – call this “user-centered design”.
For those in the gas and hazardous liquid pipeline industry, this concept is codified in PHMSA’s Control Room Management (CRM) Rule – specifically in 49 CFR 192.631(b) and 195.446(b) – where pipeline operators are required to define the roles and responsibilities of their Controllers and others who have assigned authority to direct or supersede Controller actions.
So, while I do agree with PHMSA that it is vitally important to formally define the roles, responsibilities and authorities of pipeline Controllers and those who direct them, I also believe that role definition and the concept of “user-centered design” can (and should) be equally applied to all employees. Don’t you agree?
Note: This is the third in a series of blog entries on gas and hazardous liquid pipeline operations, process safety and regulatory compliance – and more-specifically, on Pipeline Controllers, control room operations and the key elements of the PHMSA Control Room Management (CRM) 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: firstname.lastname@example.org
PHMSA has finally taken the next step toward publishing the long-awaited Gas Pipeline Safety Rule – also known as the “Gas Mega Rule” – and, as it seems that the first installment of the new Rule could be published within the next couple months, I thought it prudent to at least attempt to discuss it now.
So – what’s in this new rule?
While the initial rule focused on gas transmission pipelines, it has since been expanded to include gathering lines to address outstanding mandates from the 2011 and 2016 Pipeline Safety Act reauthorizations.
If published as proposed, the new rule will double the size of the current Part 192 regulations. For this and a few other reasons, PHMSA has decided to issue the new rule in three parts.
It appears that the first part of the rule – which is currently awaiting OMB approval – will focus on those outstanding mandates, on new MAOP reconfirmation requirements and on an expansion of existing pipeline integrity assessment requirements – including some more prescriptive language, a redefinition of high-consequence area (HCA) and the introduction of a new category of “moderate-consequence area” (MCA).
It will also include provisions for material verification, incorporation of seismicity into data integration and risk analyses; an extension of reassessment intervals; and MAOP exceedance reporting.
We should expect the new MAOP reconfirmation and remediation requirements to be phased in, allowing operators one year to develop their plans and several years to complete their testing and/or replacement.
The second part of the rule will likely expand gas transmission integrity management program (IMP) requirements and should be expected by the end of this year. Provisions will include adjustments to pipeline repair criteria, inspections following extreme weather events, launcher/receiver safety features, increased assessment requirements, additional corrosion control requirements; and management of change elements.
The third part of the rule should address gathering pipelines and can be expected sometime next year. It will include new regulations for lines in Class I locations, new reporting requirements and a few new definitions.
So – are you asking yourself if you are ready for the new Gas Mega Rule – or, if not, what you should do to get ready?
Have you proactively reviewed and reconfirmed your MAOP, conducted additional risk analyses and testing, reviewed your records, identified your gaps and determined additional pipeline pressure and/or material testing requirements? Or – are you waiting to see what is published and what it will mean for you?
While the time for waiting may be running out, I think you can rest assured that you are not alone, that there is a lot of available help, and that together, we will get through this.
Note: This is the second in a series of blog entries on gas and hazardous liquid pipeline operations and regulatory compliance. 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: email@example.com