The Basics of API - Pipeline Safety Trust

DNV GL © 2014 SAFER, SMARTER, GREENER DNV GL © 2014

Introductions & Expectations

1

Course focal points & format

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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.

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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

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PHMSA Introduction

8

Course goals and objectives


Basic structure, types, drivers & objectives

Introduction to Management Systems

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Key features of a Management System

A Management System refers to…

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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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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

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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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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

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t

Inte

gri

ty M

an

ag

em

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t

Qu

ality

Man

ag

em

en

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Kn

ow

led

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an

ag

em

en

t

Occu

pati

on

al

Safe

ty

Fin

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Business Management Systems

Op

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Main

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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

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Start

Step 1

Step 2

Finish

Inputs


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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“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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“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.”

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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

1980 1990 2000

HSE Management:

Demonstrated Factor of

5x improvement

Risk Management:

Additional 2x improvement

Behavior Management:


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:


Behavior Management:


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

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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


Group Exercise

Case study of an organizational failure


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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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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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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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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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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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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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.


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• 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


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Risk Management – ISO 31000 Process and API 1173

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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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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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• “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


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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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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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Safety Assurance





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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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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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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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• 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


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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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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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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


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Competence, Awareness, and Training

The training described here is specifically for competence and awareness of the


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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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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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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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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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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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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– “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


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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Documents

The Basics of API - Pipeline Safety Trust