module 0: introductions &...
TRANSCRIPT
DNV GL © 2014 SAFER, SMARTER, GREENER DNV GL © 2014
Introductions & Expectations
1
Course focal points & format
DNV GL © 2014
Welcome
Instructor Introductions
Emergency exit
Mustering points
Restrooms
Other important information
2
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Please Introduce Yourself
Name
Agency and position/role
Experience with management systems or elements of systems
3
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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
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AGENDA
5
Not to be confused with a guide to answer phone calls, check email or work on reports. We are watching….
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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
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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
7
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PHMSA Introduction
8
Course goals and objectives
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Basic structure, types, drivers & objectives
Introduction to Management Systems
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Key features of a Management System
A Management System refers to…
10
to manage its processes and activities
so that its products and services
meet the objectives the company has set
what an organization does
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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
for effective Business Management
A Management System defines…
Practices Responsibilities Strategies
11
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Key features of a Management System
What makes Management Systems tick?
Structure that drives
continual improvement
Process Based
Risk Based
Leadership Involvement
of People
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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
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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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Slide 17
Continuous Improvement
Plan
Do Check
Act
Learn &
Enhance
Measure,
Monitor &
Review
Processes,
Procedures,
Culture &
Behaviour
Set Objectives
& Performance
Standards
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Overall Business Management Umbrella & System Types
HS
E M
an
ag
em
en
t
Inte
gri
ty M
an
ag
em
en
t
Qu
ality
Man
ag
em
en
t
Kn
ow
led
ge M
an
ag
em
en
t
Occu
pati
on
al
Safe
ty
Fin
an
ce
Business Management Systems
Op
era
tio
ns a
nd
Main
ten
an
ce
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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
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People….your greatest asset
Resources and Organizational Structure
Competency & Training
Roles and Responsibilities
Safety Culture
Contractors
Performance Standards
Overall…...COMMITMENT!!
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• 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
What is an effective management system?
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Process vs. Procedure Exercise – Changing a Tire
24
Start
Step 1
Step 2
Finish
Inputs
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What type of Safety Management System?
API RP 1173
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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
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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
systematic method is in place
to
Identify and assess
(organizational) events that
have significant potential for
harm (e.g., fire, explosion,
release)
Make decisions regarding
appropriate controls
Implement systems to
monitor the success of
control measures
Safety Management
System Characteristics
Risk-based focus
Fitness for purpose
Recognition of human factors
& behavior
Effective mix of controls
(asset, process, people)
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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”
Source: Hopkins, A, Disastrous Decisions: The Human and Organizational Causes of the Gulf of Mexico Blowout
“Personal or Occupational safety hazards give rise to incidents – such as slips, falls, and vehicle accidents – that primarily affect one individual worker for each occurrence.
“Process safety incidents can have catastrophic effects and can result in multiple injuries and fatalities, as well as substantial economic, property, and environmental damage. Process safety… involves the prevention of leaks, spills, equipment malfunctions, overpressures, excessive temperatures, corrosion, metal fatigue, and other similar conditions.”
DNV GL © 2014
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
1980 1990 2000
HSE Management:
Demonstrated Factor of
5x improvement
Risk Management:
Additional 2x improvement
Behavior Management:
Additional 2x improvement
Loss
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Major Accident Costs
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Where is the Next Step Change?
Current Approaches
More successful for personnel safety
Likely reached near its limit of improvement
Full implementation of Baker/CSM reports
may only generate small returns for PSM
Proposed Approach
More directed to Major Accident Risk
Greater integration of HSE & Asset Mgmt
Provides the next step change in safety
Using proven methodologies benefits of a
factor of 2-3 can be expected
1980 1990 2000
HSE Management:
Demonstrated Factor of
5x improvement
Risk Management:
Additional 2x improvement
Behavior Management:
Additional 2x improvement
Loss
Process Safety/ Asset Integrity
Management:
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PEOPLE
Desig
n I
nte
grity
“Build
it right”
Opera
tion
al
Inte
grity
“Opera
te it
right”
Technic
al In
tegrity
“Main
tain
it
right”
KNOWLEDGE
MANAGEMENT
SYSTEM
PIPELINE
SAFETY
Building Blocks
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CP ILI
RBI Inspection
1st line maint.
Integrity Triangle
Operational Integrity
Technical Integrity
Design Integrity
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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
Be compliant
with the relevant
standards,
frameworks and
procedures
Know which parts of
these assets are safety
critical and to operate
and maintain them
accordingly
Design, construct
and maintain assets
right to ensure
sustained integrity
1 2 3
SMS Objective
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Application: All Phases of Lifecycle
Concept Evaluation
Engineering & Design
Construction Operation Change
Management Decommiss-
ioning
Inherently safer
design
considerations
Materials, design
codes, controls
and safeguards
Materials
procurement, QA,
pre-startup check
Safe operating
limits, permits,
RBI, preventive &
corrective
maintenance,
inspection, audits
Physical,
hardware,
procedures,
organizational,
temporary,
permanent
Effects
up/downstream,
reuse of
equipment
DNV GL © 2014
Key Inputs into SMS
SMS
Guidelines
Corporate
Requirements Regulatory
Requirements
Industry Best
Practices Other Industry
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
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Meaningful KPIs
Causes • Behavior • Asset integrity • Design Reviews • Systems &
Standards • Competency • Mental/physical
ability • Compliance
Controls • Inspections • Investigations • Audits • Procedures/permits • Rules &
Regulations • Training • Communications/
meetings
Consequences • Injury rates • Production downtime • Equipment
availability • Product losses • Waste production • Energy consumption • Debt collection rates • Profitability
Leading Lagging
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Process Safety KPIs – Some Examples
Leading:
PHA studies to plan
Critical Risk Areas identified (high in
ALARP)
Substandard barriers under test
Risk reduction opportunities identified
Risk reduction actions not closed
Key PSM roles missing or vacant
Maintenance, Inspection & Testing
performance
Audit programme to plan &
performance
High potential emergency drills
completed
Lagging:
High potential barrier challenges in
period
Barrier failures under challenge
High potential loss of containment
events
Actual loss events (spills, fires,
explosions, toxic releases, etc.)
Actual losses (FAC, DAFWC, Volume
spilt, etc.)
Process operation outside safe
operating limits
Unexpected shutdowns
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Group Exercise
Case study of an organizational failure
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Ten essential elements plus two more…
Elements of API RP 1173
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API RP 1173 Elements
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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?
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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
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
What is the Leadership & Management Commitment Element?
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• 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 Web Conference Series 2014
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API RP 1173 Elements
59
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
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
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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
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PHMSA’S Web Conference Series 2014
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Desired 2 way flow of internal information
Board
Accountable • Sets strategy and
goals
Implement • Actually do it
Facilitate • Allocate resources
• Report performance
• Supervise activity
Responsible • Set Performance
Standards
• Make funds available
• Monitor performance
Sen
ior
Mn
grs
Lin
e M
anag
ers
Wo
rkfo
rce
Flow of information
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External Stakeholders
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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”
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API RP 1173 Elements
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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
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.
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Element 3:
Risk Management
- 66 -
• 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 Web Conference Series 2014
DNV GL © 2014
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
• 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
Risk Management
PHMSA’S Web Conference Series 2014
DNV GL © 2014
Risk Management – ISO 31000 Process and API 1173
- 68 -
Risk Management
Process
Data Gathering
and Quality
Risk Identification
and Assessment
Risk Prevention
and Mitigation
Periodic Analysis
Analysis Report
Communication and Consultation /
Establish the Context
Risk Assessment
Risk Treatment Monitor and Review
Recording the Risk Management
Process
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API RP 1173 Elements
69
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
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
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Operational Controls
• “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 Web Conference Series 2014
DNV GL © 2014
Operational Controls
72
Operational Controls
Safe Work Practices
System Integrity
Outsourcing and
Contractors
Operating Procedures
Content
Completion
Review
Manuf & Fab
Installation
Maint Proc
Test & Insp
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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
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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 .
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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
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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
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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.
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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
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Management Review and Continuous 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 Web Conference Series 2014
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API RP 1173 Elements
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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
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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 Web Conference Series 2014
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API RP 1173 Elements
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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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Safety Administration
Key Considerations
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• 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
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Documentation and Records
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Data and communication drive the PSMS
Data is the basis for decision making
Documentation provides the dual purpose
of setting expectations and recording results
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Documentation
Communication of safety diligence
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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
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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
documentation
Manuals and materials related to HSE
and Operational Safety
IMP/FIMP
Equipment files/equipment criticality
information
Inspection and maintenance reports,
procedures, plans and schedules
Operational history
Operating procedures
Training materials
Incident reports
MOCs
Start up reviews
Organizational charts
Personnel job duties and
responsibilities
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Define existing operator activities that fall under the elements of the RP
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How will it be implemented?
Applicability of API RP 1173
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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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