Introductions & Expectations

Course focal points & format

1 DNV GL © 2014 SAFER, SMARTER, GREENER

Welcome

 Instructor Introductions

 Emergency exit
 Mustering points
 Restrooms
 Other important information

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Please Introduce Yourself

 Name
 Agency and position/role
 Experience with management systems or elements of systems

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Input to the format to the course

 “Safe and effective pipeline operation requires awareness and management of

many linked activities, yielding complex processes… Managing processes requires
different techniques than managing individual activities.”

– Basically a high level document focused on the essentials and not the details of
“How to make it work effectively”
– Course input on the framework and elements of API RP 1173 has been taken
from the first edition, July 2015 as provided in this course.

– Course input on the basic elements is mainly taken (and acknowledged) directly
from presentations made at publicly available workshops and other meetings
and including those made by PHMSA, NTSB, NEB, FAA and others.

4 DNV GL © 2014
AGENDA
Not to be confused with a guide to answer phone calls, check email or work on reports. We are watching….

5 DNV GL © 2014 SAFER, SMARTER, GREENER

Agenda Day 1 – The Basics of API RP 1173

 Introduction from PHMSA

 Introduction to Management Systems
 Introduction to API RP 1173
 Elements of API RP 1173
 Applicability of API RP 1173

6 DNV GL © 2014
Agenda Day 2 – Auditing for Pipeline Management Systems

 Defining and Continually Improving a Management System

 Characteristics of Pipeline Safety Management Systems
 A Process-based Approach to Auditing
 Conducting Process-based Audits
 Conclusion and wrap-up

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PHMSA Introduction
Course goals and objectives

8 DNV GL © 2014 SAFER, SMARTER, GREENER

Introduction to Management Systems
Basic structure, types, drivers & objectives

DNV GL © 2014 SAFER, SMARTER, GREENER

Key features of a Management System
A Management System refers to…

what an organization to manage its processes and

does activities

meet the objectives the so that its products and

company has set services

10 DNV GL © 2014
Key features of a Management System
Fundamental to governing the way you work
 A Management System is a systematic
way to:
– Ensure compliance with laws and
regulations, and with company and
customer requirements
– Effectively manage risks faced by the
organization
– Communicate with stakeholders
– Ensure the effective operation of key
processes
– Drive continual improvement of
performance

A Management System defines…

Strategies Practices Responsibilities

for effective Business Management

11 DNV GL © 2014
Key features of a Management System
What makes Management Systems tick?

Leadership Involvement
of People

Process Based
Structure that drives
continual improvement

Risk Based

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12
Benefits of Management Systems

 Add rigor and assurance to ways risks are managed

 Pull together many similar programs with common ways of doing things like
incident investigations, management of change, audits, etc.
 Document what you will do and how you will achieve it
 Provide formality to learning from events
 Increase management, employee and stakeholder confidence in safer operation
 Improve procedures, practices, and processes
 Influence operational and business improvements
 Contribute to evolving values, attitudes and behaviors

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Management System Examples

 ISO 9001 – Quality Management Systems

 IS0 14001 – Environmental Management Systems
 OHSAS 18001 – Occupational Health and Safety

 API RP 75 – Safety and Environmental Management Program (Offshore)

 API RP 1173 – Pipeline Safety Management Systems
 API 1162 – Public Awareness Programs for Pipeline Operators
 API 1160 – Managing System Integrity for Hazardous Liquid Pipelines
 API Q1 – Specification for Quality Programs
 OSHA 1910.119 – Process Safety

 ASME B31.8S – Managing System Integrity of Gas Pipelines

 ISO 55000 – Asset Management
 ISO 31000 – Risk Management

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Terms and Definitions

 Accountability – Answerable for the correct and thorough completion of work

 Responsibility – Obligation to complete work
 Goal – Desired state or result
 Objective – Subordinate step that supports a goal
 Process – A series of interrelated or interacting activities or steps with anticipated
outputs applied in operation of a pipeline
 Procedure – Documented method that is followed to perform an activity under
controlled conditions to achieve conformity to specified requirements
 System – An integrated set of elements, including people, hardware, software,
information, procedures, facilities, services, and support facets, that are
combined in an organization or support environment to accomplish a defined
objective
 Conformance – Meets a specific requirement

15 DNV GL © 2014
Terms and Definitions

 Audit – An examination of conformity with this RP and implementation of the

PSMS
 Inspection – Demonstration through observation or measurement that an activity
or condition conforms with specified requirements
 Evaluation – When used as an alternative to an audit, it is an assessment of the
effectiveness of a pipeline operator’s PSMS and progress made toward improving
pipeline safety performance
 Effective(ness) – Extent to which planned activities are completed and planned
results achieved
 Safety Assurance – Demonstration of the proper application of the PSMS and
progress toward effective risk management and improved pipeline safety
performance
 Safety Culture – The collective set of attitudes, values, norms, beliefs, and
practices that an operator’s employees and contractor personnel share with
respect to risk and safety

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Continuous Improvement

Learn & Set Objectives

Enhance & Performance
Standards

Act Plan

Check Do Processes,
Measure, Procedures,
Monitor & Culture &
Review Behaviour
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Slide 17
DNV GL © 2014
HSE Management

Integrity Management

Quality
Management

Knowledge Management

Finance

Operations and
Maintenance

Occupational
Business Management Systems

Safety
Overall Business Management Umbrella & System Types
Management System Structure

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Generic Management Elements

 Leadership commitment
 Strategy and objectives
 Risk management
 Organization, resources and competence
 Documentation
 Planning, execution and monitoring
 Audit and review

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Leadership & Commitment – The Role of Senior Management

 Fundamental objectives of the SMS shall be expressed in a formal SMS policy,

which is approved and endorsed by senior leadership. The Policy emphasizes that
the SMS will be managed throughout the asset lifecycle.

 The leadership shall commit the organization to comply with all applicable legal
and regulatory requirements

 Leaders are aware of the threats facing achievement of the SMS objectives and
shall put in place controls to manage the identified threats

 Long term strategic objectives for the SMS should be put in place and should have
at least a 3 year horizon

21 DNV GL © 2014
People….your greatest asset

Overall…...COMMITMENT!!
Resources and Organizational Structure

Roles and Responsibilities

Performance Standards

Competency & Training

Contractors

Safety Culture
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What is an effective management system?

• Delivers the organization’s goals

• Exploits the available resources and capabilities
efficiently over their lifecycle
• Well resourced
• Aligned with the strategic opportunities and
constraints
• Sensitive to the operating environment
• Structured, sustainable, repeatable
• The organizational memory
• Continuously improving
• Risk-based
• Industry & Organization specific
• Creates accountability

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Process vs. Procedure Exercise – Changing a Tire

Inputs

Start

Step 1

Step 2

Finish

24 DNV GL © 2014
API RP 1173

What type of Safety Management System?

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Safety Management Systems –
Current Industry Climate

 NTSB, industry, and OPS have identified three critical causes of events:
– Insufficient hazard identification
– Inadequate/ineffective learning from events
– Weak process safety (operational safety) culture – still focus on occupational
safety

26DNV GL © 2014
NTSB* on Enbridge Marshall

 “….the NTSB characterized Enbridge’s

control room operations, leak detection and
environmental response as deficient and
described the event as an “organizational
accident”
 “This investigation identified a complete
breakdown of safety at Enbridge. Their
employees performed like Keystone Cops
and failed to recognize their pipeline had
ruptured and continued to pump crude into
the environment. Despite multiple alarms
and loss of pressure in the pipeline, for more
than 17 hours and through three shifts they
failed to follow their own shutdown
procedures”
* National Transportation Safety Board Press Release
July 10, 2012

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Organizational Accidents

 Rare events, but catastrophic in effect

 Consequences are widespread
 Multiple defenses are breached
 Multiple causes, involving many people
 Errors in judgment and decision-making present

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NTSB* on Enbridge Marshall

 “Clean up costs are estimated by Enbridge and EPA at more than $1 Billion
making the Marshall rupture the single most expensive onshore spill in US
history”
 “The investigation found that Enbridge failed to accurately assess the structural
integrity of the pipeline, including incorrectly analyzing cracks that required
repair. The NTSB characterized Enbridge’s control room operations, leak detection
and environmental response as deficient and described the event as an
“organizational accident”
 “This investigation identified a complete breakdown of safety at Enbridge.
Their employees performed like Keystone Cops and failed to recognize their
pipeline had ruptured and continued to pump crude into the environment. Despite
multiple alarms and loss of pressure in the pipeline, for more than 17 hours and
through three shifts they failed to follow their own shutdown procedures”
* National Transportation Safety Board Press Release July 10, 2012

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NTSB* on Enbridge Marshall

 “The NTSB attributed systemic flaws in operational decision making to a “culture

of deviance” which concluded that personnel had developed an operating culture
in which not adhering to approved procedures and protocols was normalized”
 “Inadequate training of control center personnel was cited as contributing to the
magnitude of the incident”
– “Had Enbridge operated an effective Public Awareness Program, local
emergency response agencies would have been better prepared to early
indications of the rupture”
– “Pipeline safety would be enhanced if pipeline companies implement Safety
Management Systems”

– * National Transportation Safety Board Press Release July 10, 2012

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NTSB Recommendations

 To the American Petroleum Institute:

– Facilitate the development of a safety management system standard specific
to the pipeline industry that is similar in scope to your Recommended Practice
750, Management of Process Hazards. The development should follow
established American National Standards Institute requirements for standard
development.

 To the Pipeline Research Council International:

– Conduct a review of various in-line inspection tools and technologies—including,
but not limited to, tool tolerance, the probability of detection, and the
probability of identification—and provide a model with detailed step-by-step
procedures to pipeline operators for evaluating the effect of interacting
corrosion and crack threats on the integrity of pipelines.

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NTSB Recommendations to API

 Implementation of SMSs in transportation systems by elevating SMSs to its Most

Wanted List.
 SMSs continuously identify, address, and monitor threats to the safety of company
operations 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 operations.
– Provide safety assurance by regularly evaluating (or auditing) operations to identify
and address risks.

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Types of Management Systems

 Enterprise Risk Management (ERM)

 [Process] Safety Management (PSM)
– 29 CFR 1910.119, (OSHA) Process Safety Management of Highly Hazardous
Chemicals
– 40 CFR Part 68, (EPA) Risk Management Plan
– API RP 1173, Pipeline Safety Management System Requirements
 Asset Risk Management (ARM)
 Asset Integrity and Process Safety (AIPS)
 Quality Management Systems (QMS)

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API 1173 Targets Processes for Safety Management

Effective safety management

systems ensure that a Risk-based
focus
systematic method is in place
to
 Identify and assess
(organizational) events that
have significant potential for
Effective mix
harm (e.g., fire, explosion, of controls
Safety
Management Fitness for
release) (asset,
System purpose
process,
Characteristics
people)
 Make decisions regarding
appropriate controls
 Implement systems to
monitor the success of
control measures
Recognition of
human factors
& behavior

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API RP 1173 Goals

“Pursuing the industry-wide goal of zero incidents requires comprehensive,

systematic effort… The elements of a safety management system address ways to
continually operate safely and improve safety performance.”
 Flexibility – Operators are intended to have the flexibility to apply this RP as
appropriate to their specific circumstances
 Scalability – The level of detail in each pipeline operator’s PSMS should be
appropriate for the size of their operations and the risk to the public and the
environment

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 “Personal Safety” vs. “Process Safety”

“Personal or Occupational safety “Process safety incidents can have

hazards give rise to incidents – such as catastrophic effects and can result in
slips, falls, and vehicle accidents – that multiple injuries and fatalities, as well
primarily affect one individual worker as substantial economic, property,
for each occurrence. and environmental damage. Process
safety… involves the prevention of
leaks, spills, equipment malfunctions,
overpressures, excessive
temperatures, corrosion, metal
fatigue, and other similar conditions.”

Source: Hopkins, A, Disastrous Decisions: The Human and Organizational Causes of the Gulf of Mexico Blowout

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Management Systems

 Typically, pipeline operators have many programs and processes that affect
pipeline integrity and safety (e.g., integrity management program, incident
investigation process, etc.)
 API RP 1173 relies on management systems as a way of ensuring operators are
tying together the programs and processes
 Systems provide a clear, structured approach to ensuring the following:
– Activities are carried out as required by processes and programs
– Corrective actions are put in place and followed-up to monitor their
effectiveness
– Monitoring, auditing, self-assessment and assurance are performed on both the
activities and the management system content

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Industry Challenges with Safety Management and Culture

 Understand difference between operational safety and occupational safety

 The need for a long term (multi-year) plan, what to prioritize and how to get
there
 The need for communication both up and down the organization.
 Creating a “blame free”/ “fear free” culture
 Ensure major hazards are understood in the same way by engineering and
operations
– Importance of risk awareness (preoccupation with what can go wrong)
– Insufficient awareness can lead to overlooking indications of larger concerns
– Lack of operational/process safety training can lead to increased incident
severity
– Fortunately, most people do not have personal experience of major incidents;
however, this can lead to a false sense of security
– Major incidents often have complicated precursors

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SMS Scope = Broader than Integrity

 The goal of a Safety Management System is to ensure that assets are designed
and operated safely. SMSs, such as those for PSM, focus on major process-related
events such as fires, explosions and the release of hazardous substances.

 An effective SMS should help the organization ensure that there is acceptable
levels of risk associated with
– The safety of personnel
– The environment
– Asset value

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API 1173 Elements

1. Leadership and Management Commitment

2. Stakeholder Engagement
3. Risk Management
4. Operational Controls
5. Incident Investigation, Evaluation, and Lessons Learned
6. Safety Assurance
7. Management Review and Continuous Improvement
8. Emergency Preparedness and Response
9. Competence, Awareness, and Training
10.Documentation and Record Keeping

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Process Safety and Occupational Safety

Performance in managing major

process hazards is not directly
linked to occupational health
and safety performance. Special
focus is required.

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Occupational Safety Performance

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Main Drivers for Safety Improvements

 DNV GL believe that 3 main drivers have contributed to improvements in safety

(especially personnel safety) in the past 20 years:
1. Formal safety management systems
2. Risk assessment
3. Safe behavior programs

Loss
HSE Management:
Demonstrated Factor of
5x improvement

Risk Management:
Additional 2x improvement
Behavior Management:
Additional 2x improvement

1980 1990 2000

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Major Accident Costs

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Where is the Next Step Change?

Current Approaches Proposed Approach

 More successful for personnel safety  More directed to Major Accident Risk
 Likely reached near its limit of improvement  Greater integration of HSE & Asset Mgmt
 Full implementation of Baker/CSM reports  Provides the next step change in safety
may only generate small returns for PSM  Using proven methodologies benefits of a
factor of 2-3 can be expected
Loss
HSE Management:
Demonstrated Factor of
5x improvement

Risk Management:
Additional 2x improvement
Behavior Management:
Additional 2x improvement

Process Safety/ Asset Integrity

Management:

1980 1990 2000

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DNV GL © 2014
Building Blocks

Design Integrity
“Build it right”

Operational
Integrity
SAFETY
PIPELINE

“Operate it right”
SYSTEM

PEOPLE
KNOWLEDGE
MANAGEMENT

Technical Integrity
“Maintain it right”
Integrity Triangle

Operational
CP
Design ILI Integrity
Integrity RBI
Inspection
1st line maint.

Technical
Integrity
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SMS Objective

1 2 3
Know which parts of Be compliant
Design, construct
these assets are safety with the relevant
and maintain assets
critical and to operate standards,
right to ensure
and maintain them frameworks and
sustained integrity
accordingly procedures

SMS is all about Designing it Right, Operating it Right and Maintaining it Right
with a sense of ownership and leadership in the way we operate our assets

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 Application: All Phases of Lifecycle

Concept Engineering & Change Decommiss-

Construction Operation
Evaluation Design Management ioning

Inherently safer Materials, design Materials Safe operating Physical, Effects

design codes, controls procurement, QA, limits, permits, hardware, up/downstream,
considerations and safeguards pre-startup check RBI, preventive & procedures, reuse of
corrective organizational, equipment
maintenance, temporary,
inspection, audits permanent

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Key Inputs into SMS

Corporate Regulatory
Requirements Requirements

SMS
Guidelines

Industry Best Other Industry

Practices Management Systems

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Guidance on Meaningful Metrics

 The program evaluation process should be formally controlled through, and be an

integral part of, the pipeline operator's QC/QA program
 The formal process should include management's commitment to monitor and
evaluate performance measures
 The program evaluation process is most effective when utilizing the four‐step
Deming Cycle activities of "planning, "doing,“
"checking" and "acting“
 Specifically, program evaluation is fundamental
process to facilitate continuous improvement

51 DNV GL © 2014
Meaningful KPIs

Leading Lagging
Causes Controls Consequences
• Behavior • Inspections • Injury rates
• Asset integrity • Investigations • Production downtime
• Design Reviews • Audits • Equipment
• Systems & • Procedures/permits availability
Standards • Rules & • Product losses
• Competency Regulations • Waste production
• Mental/physical • Training • Energy consumption
ability • Communications/ • Debt collection rates
• Compliance meetings • Profitability

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Process Safety KPIs – Some Examples

Leading: Lagging:
 PHA studies to plan  High potential barrier challenges in
 Critical Risk Areas identified (high in period
ALARP)  Barrier failures under challenge
 Substandard barriers under test  High potential loss of containment
 Risk reduction opportunities identified events

 Risk reduction actions not closed  Actual loss events (spills, fires,
explosions, toxic releases, etc.)
 Key PSM roles missing or vacant
 Actual losses (FAC, DAFWC, Volume
 Maintenance, Inspection & Testing
spilt, etc.)
performance
 Process operation outside safe
 Audit programme to plan &
operating limits
performance
 Unexpected shutdowns
 High potential emergency drills
completed

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Case study of an organizational failure
Group Exercise

DNV GL © 2014 SAFER, SMARTER, GREENER

Elements of API RP 1173
Ten essential elements plus two more…

DNV GL © 2014 SAFER, SMARTER, GREENER

API RP 1173 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

What Elements may already be in place?

Why?

56 DNV GL © 2014
Leadership and Management Commitment

 ISO 31000 Framework

– Mandate and Commitment
 ISO 55000
– Organizational Plans and Objectives
 29 CFR § 1910.119: Process Safety Management (PSM) of Highly
Hazardous Chemicals
– 1910.119(c) Employee Participation would apply to API 1173 Section 5.4.3:
Employees

57 DNV GL © 2014
 U.S. Department of Transportation
Pipeline and Hazardous Materials

What is the Leadership &

Safety Administration

Management Commitment Element?

• Requires the Operator to:
– Have a PSMS
– Establish Goals & Objectives
– Ensure that relevant processes and procedures are in place
• Outlines expectations for Top Management, Management and
Employees
• Emphasizes that leadership occurs at all levels
• Lays out recommendations for making communication, risk
reduction and continuous improvement routine
• Puts emphasis on promoting atmosphere of trust and
learning for a positive safety culture

PHMSA’S
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Web Conference Series 2014 5
API RP 1173 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

59 DNV GL © 2014
Stakeholder Engagement

 ISO 55000
– Stakeholder and Organization Context
 49 CFR §192.911 Elements of an integrity management program
– A communication plan required for addressing safety concerns raised by (1)
OPS; and (2) A State or local pipeline safety authority when a covered segment
is located in a State where OPS has an interstate agent agreement.
– Procedures for providing a copy of the operator's risk analysis or integrity
management program to (1) OPS; and (2) A State or local pipeline safety
authority when a covered segment is located in a State where OPS has an
interstate agent agreement.

 More Stakeholder Engagement is required to meet intent of API RP 1173

60 DNV GL © 2014
 U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration

What is the Stakeholder

Engagement Element?
• Requires the Operator to have a process and plan for
internal and external stakeholder engagement
• Focus on risk identification and management and safety
performance
• Emphasizes two way information flow and facilitation of
opportunities for getting acquainted using public events,
social media or other methods
• Must address process to provide high level view of
operations, current focus of risk management and
measures operator uses to gauge performance

PHMSA’S
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Web Conference Series 2014 6
Desired 2 way flow of internal information

Flow of information

Line Managers
Senior Mngrs

Workforce
Board

Accountable Responsible Facilitate Implement

• Sets strategy and • Set Performance • Allocate resources • Actually do it
goals Standards • Report performance
• Make funds available • Supervise activity
• Monitor performance

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External Stakeholders

API RP 1173, Sec. 6.3 External - “The pipeline operator shall maintain
a process and a plan for two-way communication with external
stakeholders. The process shall address providing information,
engaging regulatory bodies, and handling of feedback from
representatives of the public. The pipeline operator shall identify
external stakeholders through ongoing use of appropriate company
and public processes, events, social media, or other methods. The
objectives are to provide a means through which stakeholders can
acquaint themselves with the company and the company can be
acquainted with stakeholders who want to maintain an ongoing
dialogue regarding safety and asset related concerns”

63 DNV GL © 2014
API RP 1173 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

64 DNV GL © 2014
Risk Management

 49 CFR § 192
– Elements of the Integrity Management Program include Threat Identification,
Risk Assessment, and Preventive and Mitigative Measures
 49 CFR § 195
– Elements of the Pipeline Integrity Management in HCAs requires that a risk
analysis be performed to select Preventive and Mitigative Measures, as an input
to setting the integrity assessment interval, and as an input into the leak
detection evaluation.

 Meeting these regulations does not necessarily mean API RP 1173 is fulfilled
 API RP 1173, Risk Management, provides more detail about the risk management
process, goals and objectives.

65 DNV GL © 2014
 U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration

Element 3:
Risk Management
• The pipeline operator shall maintain (a) procedure(s) for
the performance of risk management. The operator shall
maintain a description of the assets comprising the pipeline,
including the surrounding environment, to identify threats to
pipeline safety.
• The operator shall analyze risk considering the threat
occurrence likelihood and consequence throughout
the pipeline lifecycle. The operator shall evaluate pipeline
safety risk and make decisions on how to manage it through
preventive controls, monitoring, and mitigation
measures. Safety assurance sub-elements, including
audits, data analysis, and performance evaluation are used
to monitor the effectiveness of risk management.
PHMSA’S
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 U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration

Risk Management
• Builds upon the fundamentals of risk management in
integrity management – “Know your system and recognize
potential threats”
• As well as international consensus standards such as ISO
31010 – Risk Management
• Starts with emphasis on data and data quality
• Risk Identification – “What Can Go Wrong?”
• Risk Mitigation
• Periodic Analyses – at least once annually
• Reporting to Top Management including risk analysis,
mitigation methods and intended effectiveness
PHMSA’S
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Web Conference Series 2014
Risk Management – ISO 31000 Process and API 1173
Communication and
Consultation /
Establish the Context

Data
Gathering
and Quality

Risk
Recording the Risk
Analysis Identification
Risk Management Assessment
Report and
Process Assessment
Risk
Management
Process

Risk
Periodic Prevention
Analysis and
Mitigation

Monitor and Review Risk Treatment

- 68 DNV GL © 2014
-
API RP 1173 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

69 DNV GL © 2014
Operational Controls

 Recall Module 8 – Operations Controls

 49 CFR § 192 and 49 CFR § 195.402
– Operating Procedures and Safe Work Practices
– Both require written operations and maintenance procedures
– System Integrity
– Both include some details on design, manufacture, construction, testing, and
maintenance
– MOC
– 49 CFR § 192 Integrity management program requires this process
– 49 CFR § 195 Control room operations require that changes that could affect
the control room be managed
– Use of Contractors

70 DNV GL © 2014
 U.S. Department of Transportation
Pipeline and Hazardous Materials

Operational Controls
Safety Administration

• “Operational controls” – used in other SMSs

• Operating Procedures – reviewed annually for
lessons learned
• Safe Work Practices – addressing situations
where stop work and procedural deviations are
encouraged.
• System Integrity – Life cycle view
• Management of Change – includes organizational
changes
• Use of Contractors

PHMSA’S
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Operational Controls

Safe Work
Practices

Review Test & Insp

Completion Operating Operational System Maint Proc
Content
Procedures
Controls Integrity
Installation
Manuf & Fab

Outsourcing
and
Contractors

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Operational Controls PHMSA QMS

 Det Norske Veritas (U.S.A.), Inc. (DNV GL) and the Pipeline and Hazardous
Materials Safety Administration (PHMSA) co-funded the project titled,
“Improving Quality Management Systems (QMS) for Pipeline
Construction Activities.”
– Goals:
– Develop guidance pertaining to issues related to construction quality of a new
pipeline
– Develop guidelines for a QMS for pipeline projects to provide greater
assurance of consistent and acceptable quality
– Suggest enhancements to regulations and standards to improve the overall
quality of new pipelines through application of the QMS
 A pipeline construction QMS works with the Safety Management System
– API 1173 8.3.2 Manufacturing and Fabrication
– “The pipeline operator shall maintain a quality control procedure to ensure
that materials and construction are in accordance with the design and
purchase specifications.”

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Operational Controls – PSMS

 API RP 1173 Section 8: Operational Controls

– 8.1 Operating Procedures –29 CFR § 1910.119(f) Operating Procedures would
meet this entire section.
– 8.2 System Integrity –29 CFR § 1910.119(j) Mechanical Integrity would meet
this entire section.
– 8.3 Management of Change – 29 CFR § 1910.119(l) Management of Change
would meet all of this section, except that acquisition of required work permits
would need to be added to the MOC procedure. 29 CFR § 1910.119(i) Pre-
Startup Safety Review would also fall into this section.
– 8.4 Use of Contractors –29 CFR § 1910.119(h) Contractors would meet this
section, except that the contract employer is responsible for training in work
practices, the MOC procedure as well as the applicable procedures for the work
being done would need to be communicated to the contractor.

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API RP 1173 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

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Incident Investigation, Evaluation, and Lessons Learned

 49 CFR § 192 and 49 CFR § 195

– Nothing specific about what should be included in investigations, evaluations, or
how to communicate lessons learned.
 29 CFR § 1910.119(m) Incident Investigation provides broad guidance on the
incident investigation process, which would not meet the guidelines of API RP
1173 Section 9 Incident Investigation, Evaluation, and Lessons Learned .

API RP 1173 Section 9 contains more structure

regarding investigation requirements, follow-
up and communication, and learning from
past and external events.

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Common Industry Challenges

 Hesitancy to report minor incidents and near misses

– Fear of the process and of discipline
 Inadequate definitions of incident and near miss
 Tendency to find human error as the root cause of an incident
– This is improving in many companies, but there is still improvement to be made
 Incidents are not analyzed by both actual and
potential impact
 Barriers are not formally evaluated during
investigations

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Ensure Success of Incident Investigation & Learning from Events

 Managers should strive to create a “no blame” culture in the organization to foster
high levels of event reporting
 Personnel should be particularly encouraged to report near misses, which offer
the greatest number of learning opportunities
 Investigations must uncover the basic causes of events before determining the
necessary corrective and preventive actions
 Actions must be tracked to completion and the results communicated to all
necessary stakeholders
 After a new methodology or process is implemented for investigating incidents, go
back to a selection of events that had high potential to be more severe, and
evaluate with the new method

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API RP 1173 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

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Safety Assurance and Management Review and Continuous
Improvement

 49 CFR § 192
– Integrity management program element is a quality assurance process as
outline in ASME/ANSI B31.8S, section 12.
 49 CFR § 192 and 49 CFR § 195
– Guidance on implementation of the integrity management program includes
guidance on performance measures
 A process that meets 29 CFR § 1910.119(o) Compliance Audits would provide a
basis for meeting the API RP 1173 Section 10.2.2 Audits. Review the audit is to
ensure it is updated to meet compliance with API RP 1173 as well as 29 CFR §
1910.119

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 U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration

Safety Assurance
The pipeline operator shall demonstrate the proper application
of its PSMS and progress toward effective risk management
and improved pipeline safety performance.

The pipeline operator shall use:

• Audits to ensure the PSMS conforms to the requirements
– including how it applies to service providers and contractors.

• Audits and evaluation methods to assess the

effectiveness of risk management and progress made
toward improving pipeline safety performance.

PHMSA’S
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 U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration

Safety Assurance Sub-Elements

1. Audit
2. Evaluation
3. Employee Reporting and Feedback
4. Analysis of Data
5. Performance Evaluation
6. Evaluation of Safety Culture
7. Evaluation of Maturity

PHMSA’S
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 U.S. Department of Transportation
Pipeline and Hazardous Materials

Management Review and Continuous

Safety Administration

Improvement
• Management review ensures the connection with
top management
• Continuous improvement is an important theme
• At least annually
• Inputs are work products of PSMS elements
• Yields a summary of effectiveness and
opportunities to continuously improve
• The RP explicitly addresses the need to evaluate
technology improvements

PHMSA’S
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Web Conference Series 2014
API RP 1173 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

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Emergency Preparedness and Response

 49 CFR § 192 and 49 CFR § 195

– Includes emergency response, training, and reporting, as well as requires drills
to be completed.
– Includes requirements to investigate to determine the cause of the emergency
and how to minimize reoccurrence
 29 CFR § 1910.119(n) Emergency Planning and Response refers to 29 CFR §
1910.38 which does not minimally require the many of the same elements
outlined in API RP 1173 Section 12 Emergency Preparedness and Response.

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 U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration

Not Just Spill Response

• spills
• releases
• weather events
• security threats
• fires
• utility losses
• pandemics
• civil disturbances
• look to what is included in O&M plans and review
when new threats identified
PHMSA’S
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 U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration

What should plans/procedures

include?
• internal and external notification requirements
• identification of response resources and
interfaces
• recognition and use of Unified Command/Incident
Command Structure
• safety, health, and environmental protection
processes
• communication plan
• training and drills, including involvement of
external agencies and organizations
PHMSA’S
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API RP 1173 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

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Competence, Awareness, and Training

 The training described here is specifically for competence and awareness of the
API RP 1173 Elements
 A program that meets 29 CFR § 1910.119(g) Training would apply for API RP
1173 Section 13 Competence, Awareness, and Training.
– However, to ensure API RP 1173 is met, a review to ensure training includes
newly emerging or changing risks, problems, or areas of improvement would
need to be done.

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Documentation and Record Keeping

 49 CFR § 192 and 49 CFR § 195

– Both require record keeping; however, additional records are required as they
apply to the elements of API RP 1173 for a Pipeline Safety Management System
 Having 29 CFR § 1910.119(d) Process Safety Information does not mean that
Section 14: Documentation and Record Keeping of API RP 1173 is met.
– However, if the operator has a system for validating, storing, and keeping
records, including procedures, drawings, safety policies and objectives, and any
other safety related documentation up to date as part of their Process Safety
Information, this may meet API RP 1173.

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 U.S. Department of Transportation
Pipeline and Hazardous Materials

Key Considerations
Safety Administration

• Section 13 and Section 14 support all others

 Train the desired methods and expectations
 Be competent in all aspects of the job
 Document all data relevant to PSMS operation
and performance

 PSMS structures its elements into the Plan, Do,

Check, Act cycle to assure
 Interconnected effort to achieve enhanced pipeline
safety
 A cohesive comprehensive approach to the goal
 Structured and intentional continuous improvement

PHMSA’S
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 U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration

Documentation and Records

 Data and communication drive the PSMS

 Data is the basis for decision making

 Documentation provides the dual purpose

of setting expectations and recording
results

PHMSA’S
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 U.S. Department of Transportation
Pipeline and Hazardous Materials

Documentation
Safety Administration

 Documentation falls in two major categories

 Communicate policy, objectives, and methods

 Pipeline safety policies and objectives
 Processes and procedures
 Roles in the PSMS or day-to-day operations
 Library for corporate learning

 Record progress
 Completion of required tasks(audits)
 Compilation of related data
 Communication of safety diligence
PHMSA’S
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What does API RP 1173 say about Safety Culture? (1)

Goal of the Document and its SMS Framework:

 “Safety culture is the collective set of attitudes, values, norms and beliefs that a
positive a pipeline operator’s employees and contractor personnel share with
respect to risk and safety”

 “A positive safety culture is essential to an organization’s safety performance

regardless of its size or sophistication.“

 “A positive safety culture is one where employees and contractor employees

collaborate, have positive attitudes towards compliance (meeting and exceeding
minimum standards): feel responsible for public safety, for each other’s safety
and for the health of the business and fundamentally believe in non-punitive
reporting.”

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What does API RP 1173 say about Safety Culture? (2)

 Example indicators of positive safety culture:

– Embraces safety as a core value ( personnel, public and asset)
– Ensures everyone understands the organization’s safety goals
– Fosters systematic consideration of risk, including what can go wrong
– Inspires, enables and nurtures change when necessary
– Allocates adequate resources to ensure individuals can successfully accomplish
their SMS responsibilities
– Encourages employee engagement and ownership
– Fosters mutual trust at all levels with open and honest communication
– Promotes a questioning and learning environment
– Reinforces positive behaviors and why they are important
– Encourages two-way conversations about learning commits to apply them
throughout the organization
– Encourages non punitive reporting and ensures timely response to reported
issues
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What does API RP 1173 say about Safety Culture? (3)

– “Adopting and implementing a SMS will strengthen the safety culture of an

organization”

– “A positive safety culture can exist without a formal SMS, but an effective SMS
cannot exist without a positive safety culture. Therefore, operators are should
actively work to improve and assess their safety culture”

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Some Commonality about what creates a positive Safety Culture

 An “informed” organization:
– Preoccupation with failure (and the right model to evaluate this)
– People have confidence and trust to report safety concerns without fear of
blame
– the organization is able to learn from its mistakes and adverse events (and
those of others) and take appropriate action to address lessons
– Errors and unsafe acts are not punished if the error was unintentional
– Anyone involved in the problem is involved in the solution
– People are capable of adapting effectively to changing demands

 “Committed Leadership,” eliminating or controlling:

– Tolerance of inadequate systems and resources
– Normalization of deviance
– Complacency
– Work pressure

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Industry Challenges with Safety Management and Culture

 Understand difference between operational safety and occupational safety

 The need for a long term (multi-year) plan, what to prioritize and how to get
there
 The need for communication both up and down the organization.
 Creating a “blame free”/ “fear free” culture
 Ensure major hazards are understood in the same way by engineering and
operations
– Importance of risk awareness (preoccupation with what can go wrong)
– Insufficient awareness can lead to overlooking indications of larger concerns
– Lack of operational/process safety training can lead to increased incident
severity
– Fortunately, most people do not have personal experience of major incidents;
however, this can lead to a false sense of security
– Major incidents often have complicated precursors

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Maturity Curve

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Work Group - Evaluate the Current State

What documentation already exists to support the SMS elements?

 Risk Management Program  Operational history
documentation  Operating procedures
 Manuals and materials related to HSE  Training materials
and Operational Safety
 Incident reports
 IMP/FIMP
 MOCs
 Equipment files/equipment criticality
 Start up reviews
information
 Organizational charts
 Inspection and maintenance reports,
procedures, plans and schedules  Personnel job duties and
responsibilities

Define existing operator activities that fall under the elements of the RP

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Applicability of API RP 1173

How will it be implemented?

DNV GL © 2014 SAFER, SMARTER, GREENER

Implementation Path Forward

 Comparison to existing codes and standards

 Incorporation of existing requirements into PSMS Elements
 Following major incidents or investigations
 Voluntary demonstration projects

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