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Control Room Managers face a tremendous challenge ensuring they are not only compliant with PHMSA rules, but that they are adequately prepared for PHMSA audits. Ross Adams from EnerSys Corporation joins Russel to discuss this challenge.
Russel and Ross also discuss:
- How PHMSA works and what they are looking for in their audits.
- How the control room can be misunderstood or underrepresented in a company, and the challenges that reality poses.
- The need to not only be in compliance with regulatory requirements, but to have adequately documented compliance related tasks, and to have that documentation readily available.
- An ideal means of document storage and how that can make for a pain free audit experience.
- The challenges for operators posed in how PHMSA has released their requirements. More specifically the way that the FAQ and Audit Protocol expand our understanding of PHMSAs expectations.
- A general process for audit preparation.
- How CRM regulations are currently evolving and expanding due to industry incidents and NTSB recommendations, and what operators should be aware of in terms of upcoming deadlines.
- How the ComplyMgr tool and Compliance Facilitator Program can be used to promote continuous improvement in your compliance efforts.
Show Notes, Links, and Insider Terms
- Ross Adams works for EnerSys Corporation in regulatory compliance, specifically related to control room management.
- Find and Connect with Ross Adams on LinkedIn.
- The Macondo Incident of 2010 was a sudden explosion and fire at an oil rig in the Gulf of Mexico that resulted in the deaths of 11 workers and an ongoing oil spill into the Gulf. [Read the Full Report from the U.S. Chemical Safety Board (CSB)]
- PHSMA is the Pipeline and Hazardous Materials Safety Administration that ensures the safe transportation of energy and hazardous materials.
- BSEE is the Bureau of Safety and Environmental Enforcement that assesses, inspects, and regulates the latest technology used in offshore facilities.
- PHSMA rule 49 CFR 192 pertains to the transportation of natural and other gas by pipeline.
- PHSMA rule 49 CFR 195 pertains to the transportation of hazardous liquids by pipeline
- PHMSA 49 CFR 192 &195 FAQ
- PHMSA 49 CFR 192 & 195 Audit Protocol.
- The Marshall Incident of 2010 was a hazardous pipeline rupture and release in Marshall, Michigan. [Read the Full Report from the NTSB]
- PHMSA Control Room Management Fatigue Mitigation Powerpoint and Data on Compliance Cases (2014)
- API Pipeline Conference & Control Room Forum and Data on Compliance Cases (2017)
- The Pipeline Performance Group provides training, procedures, and education to pipeliners for control rooms and field operations, backup SCADA tests, evacuation plans, point to point tests, and alarm management.
- MAOP (maximum allowable operating pressure) was included in a bulletin issued by PHSMA informing owners and operators of gas transmission pipelines that if the pipeline pressure exceeds MAOP plus the build-up allowed for operation of pressure-limiting or control devices, the owner or operator must report the exceedance to PHMSA on or before the fifth day following the date on which the exceedance occurs. If the pipeline is subject to the regulatory authority of one of PHMSA’s State Pipeline Safety Partners, the exceedance must also be reported to the applicable state agency. [Read the Full Bulletin]
Russel Treat: This is Russel Treat. Welcome to the “Pipeliners Podcast,” episode number three.
Announcer: The Pipeliners Podcast, where professionals, Bubba Geeks, and industry insiders share their knowledge and experience about technology, projects, and pipeline operations. Now your host, Russel Treat.
Russel: Before we get started, I just want to tell all the listeners, thank you for listening. We want to express our appreciation to you for taking the time to listen to the episode and hopefully, to share it with your friends and those that you think might benefit.
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On today’s episode of the Pipeliners Podcast, we are very lucky to have with us, Ross Adams. Ross has a background in regulatory compliance. He works for EnerSys Corporation. He works in the role of regulatory compliance, specifically related to control room management.
Ross, welcome to the Pipeliners Podcast. We’re really glad to have you here. Why don’t you introduce yourself to the listeners, and tell them who you are, and a little bit about your background?
Ross Adams: Russel, thanks so much for having me. I really appreciate the opportunity and I look forward to talking with you a little bit about control room management.
Just a little bit of background on me. I graduated from Texas A&M in 2012. I spent a little bit of time working out in the field. You know a young guy has to get his boots a little dirty before he gets into the office. So,I worked in petrochemical plants and then took a job with a company called J. Connor Consulting. We specialized in safety and environmental management systems or SEMS. Really, what that is, is safety and environmental regulatory compliance for offshore oil and gas, a lot of that came from the Macondo Incident through the Bureau of Safety and Environmental Enforcement.
Then, had a wonderful opportunity to join EnerSys Corporation about six months ago, focusing on regulatory compliance around pipeline control room management.
Russel: Awesome. We should probably disclose that we work together because obviously, I work at EnerSys Corporation myself. I wanted to ask you just to start this all, how is control room management different from or for that matter, the same as what you were doing with J. Connor and when you’re working in SEMS?
Ross: That’s a great question. I think there’s actually quite a few similarities. Both are governed by governing agencies and so there’s patterns in between the two. The way that they handle the release of regulations, the way that they write regulations, the way that they manage regulations, and really, the way that they expect you to be in compliance with those regulations is similar.
I think their philosophy is the same in terms of how they grow as agencies. What I mean by that is both agencies, both PHMSA and BSEE, the regulation pertaining to what we’re working with and now with control room management, they’re both about the same age. So, what we’ve seen is a progression from, “Hey, we want to make sure that you guys are aware of what we’re doing and you have a plan.” The first round of audits and inspections really represents that and focuses on that.Then, moving down the line, you start to say, “Okay. Now, we want to make sure that you’re doing what you said you’re going to do.” I found that to be the case, as much with PHMSA’s as it was with BSEE. That certainly helped me in my ability to do my role with those similarities being true.
Russel: Yeah, so I think you make a really, really good point. I should mention just for the listeners. I know that when you start talking about this stuff, it can become full of jargon, PHMSA, and BSEE, and that sort of thing.
What we’ll be doing as we go through these episodes is we’ll have show notes and all of that will be on the show notes page. There’ll be a definition of what those terms are and a link to the websites, so you can find out more about them if that’s what you want to do.
PHMSA is the Pipeline and Hazardous Materials Safety Agency [Administration]. It’s part of the Department of Transportation. They had previously released a whole lot of regulations around integrity management, so inspection, cathodic protection, those types of things.
It was very interesting to me as I watched that at arm’s length, not really a core expertise of mine personally. I think the same thing happened there is that when those regulations first came out, they first went around in the first round of audits and they were what I would call a functional audit.
The auditors were looking to see, “Do they have the policy and procedure? Do the policy and procedure conform to what’s required in the regulation?” And then, after they’ve given the opportunity to the operators to mature their plans, then they start doing the next kinds of audits, which I would call the performance audit. Meaning, “Are you doing what you said you’re going to do?”
Probably more to the point is, “Are you keeping the records that prove you’re doing what you say you’re going to do?” because from an audit standpoint, that’s really what they’re looking for, right?
Ross: That’s right. When you look at the data that’s coming out from PHMSA regarding enforcement activity and audit results, what we saw early on is that most of the Incidents of Noncompliance or INCs had to do with Section A of the rule, which is procedures [General}, and not so much throughout the rest of the regulation.
Now, what you’re seeing in data as recent as the end of 2016 is that those INCs have started to spread out more and more. The challenge there is that (a) PHMSA is holding your feet to the fire quite a bit if you’re an operator and (b) for operators, the primary focus is to make money. Of course, the goal is to do that with a compliance mindset, to focus on continuous improvement. That involves documentation, which is not always easy to do, especially, in a control room when guys are focused on so many other things at a particular point and time.
Russel: Certainly, that’s my experience. I also think that in the pipeline industry, the control room is often misunderstood or it’s not fully understood throughout the company what the control room does. I mean, everybody knows that there’s this control center and it’s behind a locked door and that there’s people in there 24/7. But,I don’t think often that the company really understands what the control room does and what their role is. I personally define the role of the control room is to ensure on-time, on-spec delivery, and to do so safely. Another way to say that is without incident.
I think from my standpoint that one of the things that’s happening is that as these new rules are coming and beginning to rope the control room in, that now there’s another job that the controllers have and it’s certainly towards the bottom of their list. That’s keeping all the paperwork squared so that when the audit comes around, they can demonstrate they were doing their job in accordance with their policy and procedure. So, I guess the question I would ask you is what are you seeing control rooms do in order to keep that documentation?
Ross: Well, I’ve seen a few things. I’ve seen the old school mentality, which is to keep a lot of that documentation in paper format. But, that presents a lot of challenges. You have to know where it is. It has to be organized. And, a lot of times, paperwork has to go from one hand to another and has a tendency to get lost.
What I’ve seen with control rooms who have had success in compliance and documentation of compliance practices is that they’re using some sort of online or computer based program to drive their documentation storage.
Russel: I would agree with that. The way I interpret the rule is there’s not really anything that requires you to automate your recordkeeping. You can do it all in paper logbooks and word documents that you print out and sign and drop in a file folder. That’s all perfectly fine.
One of the big challenges with that is when the audit does come, getting your hands on the right piece of documentation can be challenging. One of the advantages of automating that if you do it well is that you can have all that stuff immediately at your fingertips.
Prior to joining EnerSys, what was your experience about… what kinds of tools were out there for compliance, and for recordkeeping, and so forth? Are there good tools out there to do what you’re talking about to keep the records in them and to make the audit easy to accomplish?
[Additional note from Ross after our recording:
Note: Many companies fall into the trap of automating their record keeping, but they do so in a way that becomes inefficient. For example, companies who multiple online locations to store specific types of documents (e.g. use their training providers website to store training completion certificates) wind up with the same challenges they would have had if they stored their documents in a paper format. In effect, they are merely replicating one of the key problems associated with paper records: that many records will be spread out and stored in multiple areas to the point that records are then hard to find and more likely to be lost. However, companies who store their information in a common repository, even if that means creating duplicate storage locations, will often have the most success having documents readily available in the event of an audit.]
Ross: Yes. The answer is yes. The industry I came from, that wasn’t so much present as it is in the midstream world, and I think that just has to do with the makeup of the industry offshore. A lot of small and independent operators, their focus financially is elsewhere. Compliance can be expensive. And of course, with where I was, that was our target, the demographic was small and independent guys. The majors all do a lot of that work internally, so the challenge is as much for them. In the midstream world there’s several programs out there.
We recently walked through an inspection from PHMSA with one of our customers and got some really tremendous feedback from the auditor. At EnerSys Corporation we have a program called POEMS that we use to facilitate a lot of that documentation.
Having all of that documentation readily available when the audit or when the inspector asks for it is key to making sure that there’s no pain for you or for the auditor. We got some great feedback. The level of organization and the ability to provide that document, make all that information readily available, was something that this auditor had not seen in other audits.
Russel: Right. Maybe you could talk a little bit to how much time you had to prepare and what was involved in doing that preparation?
Ross: I think the answer to that question speaks a lot towards something you mentioned earlier in terms of operators not fully understanding control rooms and what goes on in their control rooms. For this inspection it was an integrated inspection, which means that it’s not only the control room but it’s other areas of the company, it’s the field work as well.
That knowledge that the inspection was coming was a little bit slow to trickle into the control room. As soon as it got there, we got a call and were able to jump in and facilitate a lot of the work that needed to get done in preparation for that audit.
Russel: How did you go about doing that facilitation? What’d that look like?
Ross: It started with a gap analysis, which is really just a conversation. It’s getting to know where you are at your current state and then trying to figure out, “Okay, we have a pretty good understanding nowadays about what PHMSA is looking for, but that’s not always been the case. When the rule came out, it was just the rule, andthere were no supporting documents.”
Over time we’ve had FAQs and the auditprotocol released. That allows us to get a pretty clear understanding of what PHMSA is looking for in an inspection. What we do is we take the results of that gap analysis, and then we treat that as the baseline. Like I said, we know where we’re going and soe basically look at each element of the rule and figure out, “Okay, what is it that this particular operator needs to do?” A lot of that’s focused around the annual reviews and the monthly alarm reviews. For us, we worked with this client to make sure that those things were completed and adequately documented.
We use a lot of the tools that EnerSys Corporation can provide to facilitate all that and at the end of the day I feel like we were able to provide a lot of peace of mind for the operator.
Russel: Just to add to what you’re saying, in my experience the PHMSA regulations and the PHMSA audits are a little unique in the industry, a more broad industry than just oil and gas because there’s lots of industries out there that are regulated or fall under regulatory compliance issues or otherwise have to be ready for audits for whatever purpose.
I think what’s unique about PHMSA in the way they tend to do things is they publish an audit protocol. Then they publish frequently asked questions. Then, the audit is actually not to the rule as it’s written in the law, the 49 CFR 192, 195 text. The audit’s really more to the audit protocol.
I think sometimes that gets people a little twisted up maybe trying to understand, “Well, this is what the rule says, but the audit protocol says this,” and there are certain aspects of the control room management rule where they ask the same question different ways in different places. So, if you don’t understand what’s behind the question, it can be challenging to answer.
Here’s the big question. What’s coming? What’s new? What dothe operators need to be getting ready for in terms of what’s next in control room management in particular?
Ross: Well, I think that’s a really important question and I think the reason it’s important is because an operator’s primary focus is on trying to make money and do so with a compliance mindset. What that creates is an environment where you’re looking at the here and now. It always adds value to your company to be able to look for and say, “Okay. Well, how can we be prepared? What can we be doing now to try to stay ahead of the curve in terms of compliance?”
Something that’s happening right now and will continue to happen through the end of the year, in January of 2017 PHMSA had added to their 192 and 195 rules for control room management. There’s really two parts to it. The first part has to do with the roles and responsibilities section, which is Section B of the rule. Their focus there, coming out of the Enbridge incident, is that there are individuals in a corporation who may not be qualified as a controller but have influence over a controller due to their status in the company. That in normal operations but especially in abnormal or emergency operating conditions can create a lot of white noise for a controller and specifically when they’re trying to give instruction outside the scope of the rules and responsibilities that have been established in a control room management plan.
What the new rule addendum is focusing on is providing clarification on those additional roles and responsibilities andreally trying to protect the controller and control room manager from that white noise that can add to workload, and distractions in the control room and lead a controller to work or act in a way that they may not have otherwise given their qualifications and authorization as a controller.
That’s the first part. The second part has to do with the training section, which is section H. The new training requirements call for what’s called “team training.” Team training is relatively a new idea for PHMSA but it is one that’s seen in other industries that are either managed by DOT or, for example, airlines and railroad participate in team training.
What that focuses on is identifying different teams within your company that have impact or that a controller would work with. You have got your control room team, which may be your controller and your control room supervisor or manager, but you’ve got other teams. You’ve got your field team. You may have an IT team. You have a management team. And at different points throughout your operating cycle those teams have to interact with one another. What PHMSA is calling for is you to create training programs to facilitate those teams working together. Understanding roles and responsibilities is part of it, but it’s also adding comfort to the communication between teams.
When do we work together? How do we work together? Who leads when we work together? All of that’s leading to a safer operating condition for a company.
Russel: I try to read all of the incident reports. Whenever there’s a pipeline incident, and the NTSB publishes a report, I try to read the report. [laughs]
Sometimes, those things are really helpful if you’re having trouble getting to sleep at night, sit down and read…
Ross: [Laughs] No doubt.
Russel: …a NTSB report on a pipeline incident. [laughs] They’re always full of some really interesting information. One of the things the pipeline industry does well is that when they do have an incident, and they are rare, but when they do have an incident, they really, really work to learn from it and improve.
You mentioned the Marshall Incident that happened in 2010. We’ll put that NTSB report available online. We’ll link that up in the show notes, just if somebody else is having a problem with insomnia.
One of the things that I see a lot of operators do is that, generally, operations are governed through the control room in normal and abnormal operations. But, when there’s an emergency, the roles change fairly dramatically. A lot of times, the governance of the response to an emergency is in the field, orwith the operation’s management or with the operation’s leadership that’s directing field people, and then, the control room moves into a supporting role.
In the case of the Marshall Incident, there was a lot of difficulty in getting clear communication to people who had the knowledge and experience to make decisions about the type of situation they were having. Hence, the need for team training. I actually think the team training provides a lot of opportunity for the pipeline business, just as a general rule, because to the extent we can begin to operate more effectively as teams, we’re going to become better operators. We’re going to have fewer incidents. We’re going to have higher degrees of safety, and you’re going also find that that training will facilitate just your normal day to day business. I know, for example, that there’s already some companies that are doing this. I know that the Pipeline Performance Group is doing some things in this domain. Again, we’ll link them up in the show notes. There’s certainly a lot of opportunity here and some new things to learn.
This is something, Ross, you and I hadn’t had a chance to talk about, but one of the interesting things that is also in this rule is something called MAOP exceedances. When the pipeline reaches a pressure that is above its maximum allowable, what do you do, and what are the after actions, and how do you track that, and so forth?
Just to unpack that a little bit and talk about what can occur, I might have a 40-mile length of pipe that’s got pumps and pressures at either end of that 40-mile length, but I don’t have any pressures, or temperatures, or flows, signals at all between those two endpoints.
If I have some kind of abnormal operating condition that causes a hydraulic surge, you know a pressure surge, what I read at the instruments at the end of the line might not be reflective of what the absolute max pressure was in those places where I don’t have instrumentation, particularly, in a situation where the density of the product is changing or where there’s a lot of elevation change on the pipe.
Like a lot of other things in this domain, it seems, well, I just track these two pressures. If they get high, I do something with them. It’s actually it’s a little bit more complicated than that. Anyways, that’s also something else that’s in the rules that a lot of people are trying to figure out how they ought to be doing that.
Anyways, one last question for you, Ross. What are you working on these days? What’s next for you, in terms of things you’re trying to get done or accomplished for the industry or for your customers?
Ross: [laughs] That’s a long list. One of the things we’re focusing on is trying to lean into this idea of control room management and the compliance that surrounds that. We’ve been in a process recently where we’re doing all of our annual renewals anduite a few of our customers are communicating that they are either having their first PHMSA audit, or here in Texas a railroad commissioner audit, which would be a state audit. So, there’s a lot of question marks for them about how that process works.
One of the biggest challenges, and we touched on it earlier, is that when the rule first came out it was just a rule. It’s not universally the case, but it can be the case that an operator has designed their control room management compliance program around the rule and hasn’t really integrated some of those additional resources, such as the FAQs or the auto protocol and like you mentioned, the auto protocol is the key, whether you can answer those questions about your plan, and your procedures, and your implementation or not.
We’ve got a tool that we’re working on called ComplyMgr which allows you to take your control room management plan, and edit it, and put it in a screen view where you can compare it to the rule and to the auditprotocol questions. It also allows you, and this is my favorite part, to score that CRMP based on those audit protocol questions. So, you get a really solid feel for where you are in terms of compliance with your CRMP. Another thing we’re working on that takes the results of that ComplyMgraudit, if you will, is what’s called Compliance Facilitator. This, I really like because it adds a lot of value for folks, especially folks who may not have a compliance manager in house, but it’s also something that can be used in line with a compliance manager in house. And so, what this program is, is it’s taking your audit results. It’s taking a section of your CRMP. It’s taking a monthly or annual review, and it’s lining those up by the elements in the rule. So, for example, in month one, you may be focusing on alarm management, which means you may be doing your annual alarm review, focusing on your CRMP alarm management section. Then, any after action items regarding alarm management from your audit or from your annual gap analysis, it’s splitting them up. It’s reducing workload for your staff, if you’re an operator. It’s just facilitating a conversation about what have I done for this? What do I need to do for this? Then, just checking in and saying, “Here’s where I had success in performing that action, or here’s where my pain points were. How can I improve?”
It’s really capturing the philosophy of continuous improvement, and it prevents you from falling into a situation where you receive notice from PHMSA or another state agency that, “Hey, we’re coming by to check and see what you guys are doing.” Then, having to scramble to prepare for that all at the last minute.
It adds a lot of value, a lot of peace of mind. We’re really excited about where that can go for folks moving forward.
Russel: That’s one of the things I love about this business. You’ve got all kinds of nerds and geeks. We even got people who love compliance, who love to do compliance. That’s awesome.
By the way, Ross, I don’t know if I’ve ever told you this, but do you know what the two biggest lies are between the auditor and the operator?
Ross: No. I’m kind of nervous to find out.
Russel: Well, the two biggest lies between the operator and the regulator is when the regulator shows up and says, “We’re here to help,” and when the operator says, “We’re glad to see you.”
Ross: [laughs] I’ve never said that before.
Russel: I know, me neither, but it’s funny if you think about it. Look, I appreciate your participating with us and being on the podcast. I certainly hope that the listeners get some value out of all this.
If you’d like to make some notes or give us some comments, if you’d like to see Ross come back, or if you’ve got any particular questions you’d like to ask, please go to pipelinerspodcast.com and go to the Contact Us page and just drop your comments in. We really want to hear them.
The whole purpose of this is to try to put together content that’s valuable to pipeliners and helps them do their job and helps them do it with a higher level of professionalism and capability. Hopefully, you were able to take some things away from this conversation.
Ross, thank you very much. Look forward to having you back at some point in the future.
Ross: Thank you so much. Really appreciate it.
Russel: We’ll let you that you can register to win a customized pipeliners podcast YETI tumbler. Simply visit pipelinerspodcast.com/win. That’s pipelinerspodcast.com/win, W-I-N, to enter yourself in the drawing.
Russel: Thanks for listening, and we look forward to being with you next time.
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Transcription by CastingWords