FORT WORTH, Texas—After a pipeline rupture in 2010 spilled more than 26,000 barrels of oil from a creek flowing into the Kalamazoo River in Michigan, the National Transportation Safety Board (NTSB) recommended that the American Petroleum Institute (API), in coordination with the Pipeline and Hazardous Materials Safety Administration (PHMSA), industry leaders and the public, form a stakeholder group. The result: Recommended Practice (RP) 1173. Its main goal is to provide guidance to pipeline operators for developing and maintaining a pipeline safety management system.

API RP 1173 is expected to be finalized by the end of May and “builds upon and augments existing requirements and is not intended to duplicate requirements of any other consensus standards or regulations,” according to the API.

Mary Campos, vice president, exp Energy Services Inc., a pipeline consultancy, presented 10 steps to achieve a safety management system (SMS) incorporating RP 1173 practices in the session titled “Getting Ready For The New Order” for attendees of the Midstream Program of Hart Energy’s DUG Permian Basin Conference and Exhibition on May 19.

Campos’ background is in environmental biology, permitting, compliance and management. She has been working with the pipeline industry for more than 18 years in providing life-cycle pipeline management services, including the permitting, environmental management and operational compliance of key infrastructure projects throughout North America.

“The key program elements of RP 1173 are what everyone does every day. It is not new,” said Campos. She explained that the programs that feed into it are part of the compliance that operators manage daily.

She articulated the 10 steps to a successful SMS along with how to build a roadmap to help operators further refine and grow programs and build upon them.

Leadership and management commitment: This defines who is responsible, who is accountable, who to call when things go wrong and when things go right.

Stakeholder engagement: Defining all the internal staff that will make your program stronger and manage your pipeline. “It’s important that companies identify these stakeholders so they know what their job needs to be every day,” Campos said. This also means to look externally and beyond emergency responders. This includes schools and residents who may be impacted by the pipeline being in their backyard. Again, she emphasized, it’s part of what pipeline operators do each day—public awareness programs.

Risk management: Campos explained that it’s more than third-party damage and incident response; it’s about a more holistic approach to defining risk. It’s understanding operator risk that ties to training. “Understanding the who, what and why of how the pipeline is managed as well as the workers who are around the pipeline, not just the staff workers but the contractors who are hired, as well as the environmental aspect of risk management. It’s about taking those risks, combining them, to make the program stronger.”

Incident investigation: There has been a lot of focus on incident investigation, evaluation and lessons learned over the years, Campos explained. This step takes it to the next level. “If an incident occurred, why did it occur? And did those same conditions exist elsewhere on the pipeline that you can take and learn from to correct and mitigate before it becomes another incident,” she noted. It’s taking the information, building on it and making the program stronger as a result of it.

Safety assurance: A critical tool in safety assurance is audits. Whether third-party or internal, audits help to identify potential areas of improvement, she explained. They help to make programs stronger by building on what is already there.

Management review and continuous improvement: It’s taking those areas of improvement and communicating them out to your stakeholders so that you’re learning and the program is getting stronger.

Emergency preparedness and response: This involves data integration to build stronger programs. Taking the current programs and getting them to talk. “A good example is an integrity management program that has critical high-consequence elements to it. Taking that information and combining it with an emergency plan could be so powerful because now the programs are talking together. It’s not just about identifying the high consequence areas (HCAs), but it’s working with the emergency response side to understand where the HCAs are to protect it first in the event of an incident.”

Competence, awareness and training: This is a key element we’ve heard about again and again. Understanding who the stakeholders are and what makes them qualified to be performing the different elements of pipeline management and communicating that out. It ensures the right people are in the right roles.

Documentation and record-keeping: The importance of keeping pipeline records, the history of spill records and the incident reports associated with that. The qualifications in training: Ensuring that the people working on the different elements associated with the safe operation of your pipeline are the right people to be doing that.

Management of change: Campos said there is so much consolidation in the industry with acquisitions and newbuilds that it’s important to manage systems change and elements change. “How is that information taken from the person who made the change straight to the top of the other programs that it relies on, like the emergency management staff?” Taking that information and managing that change is critical to its success. Maintaining the physical, technical and procedural organizational elements that make a program successful are key to the process being successful, she said. “The history of who, what, when and why; it’s been a frequent theme as regulations have changed and incidents have occurred. It’s important to look at the history of where we’ve been and where we’re going,” she said.

“The action that PHMSA has taken on this occasion [API RP 1173] is to say, ‘the NTSB developed these recommendations, and we need it to come off with a recommended practice or industry standard focused on safety management systems. But we’re not going to promulgate this, we are going to put this in place because it’s the right thing to do, and it’s building on what operators already have.’” This has been developed with industry, stakeholders, regulators and key working groups. “It’s about building stronger programs, not starting from scratch,” Campos added.

Developing A Roadmap

Campos explained that a third-party audit process can help build a roadmap because it helps companies see areas of improvement. “By making the building blocks of the program stronger, the overall safety management system becomes stronger,” she said.

Campos last focused on The-Plan-Do-Check-Act (PDCA), a four-step model that focuses on some of the critical elements that have been discussed over and over again. Risk management in your planning process and understanding what the risks are, identifying them and coming up with the “do” part—is it emergency response, operator controls, training? What elements are going to make it stronger? And then checking and acting to ensure the overall program is a success because it focuses on continuous improvement and management review, and there is commitment from the top up, top down and bottom up that will make the program strong.

Contact the author, Theresa Ward, at tward@hartenergy.com.