PIPELINE SAFETY MANAGEMENT SYSTEM API RECOMMENDED PRACTICE (RP) - - PowerPoint PPT Presentation

PIPELINE SAFETY MANAGEMENT SYSTEM

API RECOMMENDED PRACTICE (RP) 1173

Steve Prue – Midwest Energy

APGA Operations Conference – Chattanooga, TN November 9, 2016

Marshall, M MI o

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San B Bruno P uno Pipel eline E ne Explos

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Septem tember er 9 9, 2011 11

History tory

Pipeline incidents in 2010 and 2011 revealed management system weaknesses as contributing factors. The NTSB Marshall, MI incident report stated: “Evidence from this accident and from the San Bruno accident indicates that company oversight of pipeline control center management and operator performance was deficient.” The agency found that a Pipeline Safety Management System would improve performance through top management leadership.

SMSs continuously identify, address, and monitor threats to the safety of company

• perations by doing the following:

 Proactively address safety issues before they become incidents/accidents.  Document safety procedures and requiring strict adherence to the procedures by safety personnel.  Treat operator errors as system deficiencies and not as reasons to punish and intimidate operators.  Require senior company management to commit to operational safety.  Identify personnel responsible for safety initiatives and oversight.  Implement a non-punitive method for employees to report safety hazards.  Continuously identify and address risks in all safety-critical aspects of

• perations.

 Provide safety assurance by regularly evaluating (or auditing) operations to identify and address risks.

NTSB Recommendations

The Goal is Improved Safety

Pipeline safety stakeholders in conjunction with the American Petroleum Institute (API) worked for over 2 years to develop a comprehensive framework of recommended practices for pipeline safety and integrity procedures across the United States. Result: New API Recommended Practice RP 1173 Pipeline Safety Management System specific to pipeline operators across the United States. Key components of RP 1173

• How top management develops processes to reveal and

mitigate safety threats.

• Provide for continuous improvement.
• Make compliance and risk reduction routine.

Direct Participants

• 4 – Liquids Pipelines
• 4 – Natural Gas Pipelines
• 1 – Municipal Distribution
• 3 – Trade Organizations
• 4 – Regulators
• 2-PHMSA
• 2-NAPSR
• 1 – NTSB
• 3 – Public – SME’s
• 1 – Contract Engineering
• 1 – Standards Organization
• * Plus alternates

Differences

There were differences between what (liquid) pipeline operators and small distribution utilities needed. This was brought into contrast when the pipeline operators stated: “We need full and comprehensive procedures for things like commissioning and decommissioning pipelines”.

Differences

There were differences between what (liquid) pipeline operators and small distribution utilities needed. This was brought into contrast when the pipeline operators stated: “We need full and comprehensive procedures for things like commissioning and decommissioning pipelines” Our response: For a small municipality the Commission Pipeline Procedure maybe as simple as “Open Valve” and for decommissioning “Close Valve”.

Eventually after many meetings a consensus was reached and API RP 1173 was published.

The Goal is Improved Safety

RP 1173: General

This recommended practice provides guidance to pipeline operators for developing and maintaining a pipeline safety management system (PSMS). It builds upon and augments existing requirements and is not Intended to duplicate requirements of any other consensus standard or regulation. While no one can predict future events, this RP was not developed with the intention of it becoming a regulation, it was the intention and hope of the committee, that RP 1173 will be widely accepted by industry and implemented.

The Goal is Improved Safety

RP 1173: General

Safe and effective pipeline operations requires awareness and management of many linked activities. These activities include but not limited to designing, constructing, operating, maintaining and managing the pipeline. While safety efforts may be applied individually to each activity more effective safety performance is achieved when viewing the linked activities as processes.

The Goal is Improved Safety

“Major accidents with high consequences rarely occur but when they do, the accident occurs because of an alignment of weaknesses or failures across multiple activities.” API RP 1173

The Goal is Improved Safety

RP 1173: Flexibility

• The framework is to be applied with flexibility to account for the current state
• f development of a particular element of management system within a

company.

• In a company with an existing comprehensive PSMS is can serve as a basis

for comparison and review between the RP and the operators system.

• In a company with a partial but not a comprehensive PSMS the RP will

provide a means to integrate and add to those efforts to establish a comprehensive PSMS.

• For those companies without any elements of a PSMS adoption of the RP

would provide to them a starting point from which they could build a comprehensive PSMS.

• In all cases, operators are intended to have the flexibility to apply this

RP as appropriate to their specific needs.

The Goal is Improved Safety

RP 1173: Scalability

• The framework of 1173 is also intended to be scalable for pipeline
• perators of varying size and scope.
• We recognize that the size of operators can vary from thousands

employed by the larger operators to only a few employees employed at a small LDC or municipal operator.

• The 10 essential elements comprising the framework of 1173 apply to
• rganizations of any size.
• The framework elements and the principles underlying it are broadly

applicable, and strongly recommended operators of all sizes.

• The level of detail in each pipeline operator’s PSMS should be

appropriate for the size of their operation and the risk to the public and environment.

• “For very small operators with a handful of employees, adoption of all

provisions within this RP may not be practical. However, even small

• perators can build on selected provisions herein.”

The Goal is Improved Safety

RP 1173: Safety Culture

• Safety culture is the collective set of attitudes, values, norms,

and beliefs that a pipeline operators employees and contractor personnel share with respect to risk and safety.

• A positive safety culture is one where employees and contactor

personnel collaborate; have positive attitudes towards compliance; feel responsible for public safety, for each other’s safety, and for the health of the business; and fundamentally believe in non-punitive reporting.

• Maintaining a positive safety culture requires continual diligence

to address issues including complacency, fear of reprisal, over confidence, and normalization of deviance.

• A positive safety culture can exist without a formal PSMS, but an

effective PSMS cannot exist without a positive safety culture.

Plan, Do, Check, Act – The Core of the Standard

Continuous Improvement is the Goal of the Standard

Inputs Asset Information Threats and Hazards Environment Outputs Mitigation Risk Reduction Reduction in Incidents

The Elements

• 1. Leadership AND Management Commitment

Top management shall establish goals and objectives. Commitment expressed as policy. Documented roles and responsibilities of management. Create a culture of two way communication throughout

• rganization and contractors of SMS commitment.
• 2. Stakeholder Engagement

Regulatory interaction. Public Awareness programs. Pipeline and Informed Planning Alliance (PIPA). State Pipeline Associations. Pipeline Association for Public Awareness (PAPA).

The Elements

• 3. Risk Management

Integrity management programs. Other relevant data sources.

• 4. Operational Controls

Procedures. Standards. Management of change.

• 5. Incident Investigation, Evaluation and Lessons Learned

Incident debrief. Procedure and components review/revision. Organizational communication as needed.

The Elements

• 6. Safety Assurance

Quality control activities. Key performance indicators. Operational Quality Assurance. Continuous improvement loop (activities and SMS).

• 7. Management Review and Continuous Improvement

Annual reviews by top management. Evaluate if performance goals and objectives have been met. Ensure risk management effectiveness and improvement. Recommendations for improvement are integrated into next iteration of PSMS plan.

The Elements

• 8. Emergency Preparedness and Response

Emergency response plan. Emergency response training facility. Liaison with first responders.

• 9. Competence, Awareness, and Training

All personnel including contractors have the necessary knowledge, skills, and experience. Provide training to enable development and implementation of PSMS elements. Establish a training schedule to ensure personnel and contractors are updated.

• 10. Documentation and Record Keeping

The Goal is Improved Safety

RP 1173: Essential Elements

• Leadership and Management Commitment.
• Stakeholder Engagement.
• Risk Management.
• Operational Controls.
• Incident Investigation, Evaluation and Lessons Learned.
• Safety Assurance.
• Management Review and Continuous Improvement.
• Emergency Preparedness and Response.
• Competence, Awareness and Training.
• Documentation and Record Keeping.

The Goal is Improved Safety

RP 1173: Essential Elements

• Leadership and Management Commitment.
• Stakeholder Engagement. – RP 1162 - Public Awareness?
• Risk Management. – DIMP/TIMP?
• Operational Controls. – O&M?
• Incident Investigation, Evaluation and Lessons Learned. –O&M?
• Safety Assurance. – O&M?
• Management Review and Continuous Improvement.
• Emergency Preparedness and Response. – O&M?, RP 1162?
• Competence, Awareness and Training. – O.Q.?
• Documentation and Record Keeping. – All the above?

API RP 1173

• RP 1173, will assist the operator by identifying and addressing

safety issues in a pipeline’s lifecycle, including the design, construction, operation, maintenance, integrity management and abandonment of pipelines at the earliest stage to prevent conditions that may ultimately result in an incident.

• The committee are confident that RP 1173 is an SMS that

enhances pipeline safety in a practical way while implementing guidelines for continuous improvement.

• All comments had been addressed but not necessarily

incorporated into the document. After the comment period, API members voted whether to accept or reject the document as a recommended practice applicable to all pipeline operators.

So Where Do We Go From Here?

RP 1173 says that “It builds upon and augments existing requirements and is not intended to duplicate (the) requirements of any other consensus standard or regulation.”

• What happens if we do not use RP 1173?
• Is this yet another rule/regulation we have to

follow?

• What do we need to do to get started on a

PSMS?

• So how does it fit together with what we already

have?

So Where Do We Go From Here?

What happens if we do not use RP 1173?

• Nothing – at the moment…

…(but) hope you never have an incident.

• Starting on a PSMS demonstrates the

commitment to safety by management and employees.

So Where Do We Go From Here?

Is this yet another rule/regulation we have to follow? “…this RP was not developed with the intention of it becoming a regulation, …”. No it is NOT another rule or regulation – yet! However, one person was heard to say “If they (companies) don’t do it, we’ll make them.

So Where Do We Go From Here?

We already have:

• RP 1162 and Public Awareness Plans.
• Operator Qualifications.
• Operations and Maintenance Manuals, which

should contain necessary procedures. (49CFR192.605)

• Transmission and/or Distribution Integrity

Management Programs and Plans (TIMP/DIMP). together with…

• RP 1173, PSMS, the recommended practice.

So Where Do We Go From Here?

So how does it fit together with what we already have? RP1173 states that it is an “overarching” document that pulls together much of what we already have. Many of the requirements can be addressed with policies and procedures already in existence. Let’s look at a couple of examples:

So Where Do We Go From Here?

Section 6 – Stakeholder Engagement “The pipeline operator shall maintain a process and a plan for communication and engagement with internal and external stakeholders”. This and the rest of Section 6 should be contained in a company’s Public Awareness Plan. We would need to do little more than reference this in the PSMS.

So Where Do We Go From Here?

Section 7 – Risk Management 7.1 General “The pipeline operator shall maintain (a) procedure(s) for the performance of risk management… 7.2 Data Gathering. 7.3 Risk Identification and Assessment. 7.4 Risk Prevention and Mitigation. 7.5 Periodic Analyses. 7.6 Risk Management Review. All the above should be part of any DIMP/TIMP program.

So Where Do We Go From Here?

What do we need to do to get started on a PSMS? We already have many of the processes and policies in place. The PSMS should show where there are gaps. There are two elements that need to be clear and have not yet been addressed. Lets have a look at those elements.

So Where Do We Go From Here?

RP 1173: Essential (missing) Elements Section 5 - Leadership and Management Commitment. Section 11 - Management Review and Continuous Improvement. Both the above are management processes which need to be addressed depending upon the size of the company. (NOTE - For some pipeline operators, top management and management are the same. – RP 1173 Section 3.1.20)

So Where Do We Go From Here?

RP 1173: Essential (missing) Elements Section 5 - Leadership and Management Commitment. 5.1 General. 5.2 Goals and Objectives. 5.3 Planning. 5.4 Responsibilities of Leadership. 5.5 Responsibility, Accountability and Authority. 5.6 Making Communication, Risk Reduction and Continuous Improvement Routine.

So Where Do We Go From Here?

Evidence that may address Section 5

• List or statement of the PSMS goals.
• List of measureable objectives for the PSMS.
• A procedure that describes regulatory and legislative

requirements.

• List of measureable high-level performance measures.
• List of managers, by PSMS element, responsible for

that element.

• Identification of the procedure owners in individual

procedures to be used in the PSMS.

• List of performance measures for each PSMS element.

So Where Do We Go From Here?

Evidence that may address Section 5

• A list of personnel responsible for each PSMS element.
• Role descriptions.
• Organizational charts.
• Table listing accountabilities, responsibilities,

authorities.

• Role descriptions.
• Evidence (letter or email, signoff on role description) of

communication to the identified persons.

• Communication plan or procedure.

So Where Do We Go From Here?

RP 1173: Essential (missing) Elements Section 11 - Management Review and Continuous Improvement. 11.1 Management Review. 11.2 Continuous Improvement. 11.3 Top Management Review. Let’s have a look at what may be the evidence for compliance with this element…

So Where Do We Go From Here?

Evidence that may address Section 11

• Management review procedure.
• Management review agenda and minutes.
• Annual safety performance reviews.
• Management review action item list.
• Revision history of PSMS procedures.
• Evaluation procedure.
• Engineering project reviews.

Carrying out a Gap Analyses will highlight any shortcomings.

What are the Areas Which May Cause Problems?

Section 10.2.2

“The pipeline operator shall perform audits to examine its conformity with this RP” and “An audit may be performed by external professionals or internal personnel not involved in the work of the PSMS or the

• perations being audited.”

…and “The operator shall assure that each of the elements of the PSMS is audited at least once every three years”.

What are the Areas Which May Cause Problems?

Section 10.2.2

The requirements for this part need some clarification. Does this mean:

• A person in the same crew can audit work as long as

he/she didn’t do the work (e.g. PE Fusion joint)?

• A person in a different crew can audit work as long as

he/she didn’t do the work (e.g. PE Fusion joint)?

• A foreman or supervisor can audit the work?
• Can state regulators audit the work? They already

audit many of the elements…

What are the Areas Which May Cause Problems?

Evidence that may address Section 10.2.2

• Audit procedure.
• Audit schedule.
• Evaluation procedure.
• Evaluation schedule.
• Risk management evaluation report.
• Process hazard assessments.
• Safety culture evaluation procedure.
• Safety culture assessment results.
• Culture assessment.
• Contractor's procedures/methodologies.
• PSMS maturity evaluation procedure.

A Problem Area Solution?

From the Introduction to RP1173

“For very small operators with a handful of employees, adoption of all provisions within this RP may not be

• practical. However, even small operators can build on

selected provisions herein.”

A Problem Area Solution?

From the Introduction to RP1173

“For very small operators with a handful of employees, adoption of all provisions within this RP may not be

• practical. However, even small operators can build on

selected provisions herein.” Judicious use of “not practical” and “selected provisions” may assist in being able to develop a PSMS that is of use without being onerous.

A Problem Area Solution?

From the Introduction to RP1173

“For very small operators with a handful of employees, adoption of all provisions within this RP may not be

• practical. However, even small operators can build on

selected provisions herein.” Judicious use of “not practical” and “selected provisions” may assist in being able to develop a PSMS that is of use without being onerous. Let’s look at the ten elements again…

The Pipeline Safety Management System

RP 1173: Essential Elements

• Leadership and Management Commitment. - Selected elements
• Stakeholder Engagement. – RP 1162 (Public Awareness)
• Risk Management. – DIMP/TIMP
• Operational Controls. – O&M
• Incident Investigation, Evaluation and Lessons Learned. – O&M
• Safety Assurance. – O&M
• Management Review and Continuous Improvement. – (*)
• Emergency Preparedness and Response. – O&M, RP 1162
• Competence, Awareness and Training. – O.Q.
• Documentation and Record Keeping. – All the above

(*) – Not practical, selected elements, needs clarification

The Pipeline Safety Management System

RP 1173: Essential Elements

• Leadership and Management Commitment. - Selected elements
• Stakeholder Engagement. – RP 1162 (Public Awareness)
• Risk Management. – DIMP/TIMP
• Operational Controls. – O&M
• Incident Investigation, Evaluation and Lessons Learned. – O&M
• Safety Assurance. – O&M
• Management Review and Continuous Improvement. – (*)
• Emergency Preparedness and Response. – O&M, RP 1162
• Competence, Awareness and Training. – O.Q.
• Documentation and Record Keeping. – All the above

(*) – Not practical, selected elements, needs clarification

The Pipeline Safety Management System

RP 1173: Essential Elements So from ten elements in the PSMS, we could conceivably have eight where we can reference existing regulations, codes, standards, and existing company policies and procedures. Selected parts of the remaining two elements can be applied to the PSMS, as the recommended practice says “The level of detail in each pipeline operator’s PSMS should be appropriate for the size of their

• peration …”

The Pipeline Safety Management System

The Way Forward Over the next few weeks, it is hoped that work will begin

• n producing a generic Pipeline Safety Management

System that companies can tailor for their own needs. Anyone wishing to take part in this working party should let John (Erickson) know. (JErickson@APGA.Org)

Any Questions?

PIPELINE SAFETY MANAGEMENT SYSTEM

Thank You

Steve Prue – Midwest Energy

APGA Operations Conference – Chattanooga, TN November 9, 2016