For many years, pipeline operators have been required to communicate safety information to emergency officials; however, actually making a difference with this type of communication is dependent upon the driver behind the effort. Is the operator merely checking the box to meet a compliance requirement or is the operator effectively communicating the right information to the right people in a timely manner?
You Can’t Manage What You Don’t Measure
API (RP) 1162 established guidelines for pipeline operators to develop, manage, and evaluate their Public Awareness Plans. The Recommended Practice identifies audiences that should receive awareness messages, the content of baseline awareness messages, and the frequency of the messages for each audience.
Audiences defined in the RP include excavators, the affected public, emergency officials (including fire departments and police departments), and local public officials. API (RP) 1162 also states that operators should evaluate effectiveness to determine if the communications are reaching the audiences, if the audiences understand them and ultimately, whether behaviors have been modified.
Funded by PRCI, PipelineWatch.com is an information exchange portal whose objective is to transform public awareness into public engagement through improved communication effectiveness with all stakeholders along the ROW, particularly first responders. Using state-of-the-art Web-based technology, the fundamental design of PipelineWatch.com includes a two-tiered architecture offering integrated ‘public’ and ‘private’ access portals. This two-tier approach allows for customization specific to an operator’s facilities on the private side, while promoting collaboration among the various entities on the public side. Effective role-based collaboration is a key element missing in today’s environment.
The public access area contains general/common industry articles, public awareness messages, information, presentations, capability questionnaires and training focused on educating the various stakeholders as required in API (RP) 1162. This feature offers role-specific delivery utilizing a collaborative platform, ensuring consistent information and minimizing the volume and redundant information to all stakeholders.
The operator-specific private access portals have additional functionality in that they include a second layer of security and improved functionality allowing for the administration of “Real Time” information exchange specific to their systems. Both access levels of PipelineWatch.com offer effectiveness measurement by providing a brief questionnaire following each activity to gauge comprehension. When any user performs an activity (reads an article, completes training, etc.), the time spent on each activity is tracked.
Both durations and questionnaire results are then reported through state of the art dashboards which can be filtered to support any number of analysis parameters. As effectiveness is measured, gaps in the offering may be determined and addressed as part of continuous improvement.
Dependence on postal delivery statistics or polling type survey results to gauge effectiveness may be eliminated. Using PipelineWatch.com each operator will know which intended audience acted on the message, whether it was read and most importantly whether it was understood.
PipelineWatch.com offers other unique communication features including “Ask the Operator” to support one on one communications between each user and the pipeline operator, a configurable forum (blog) which enables communications between different members of any specific role, and a mechanism to allow operators to push specific messages to any role, specifically to those in the counties their pipelines traverse, and a county based calendar.
Finally, an identified site manager was developed for use by the stakeholders to assist operators in better understanding the environment along the right of way. All identified sites are geospatially referenced as opposed to being associated with any specific pipeline. Operators may optionally offer this feature on their private access site.
The PipelineWatch.com objective is to transform “Public Awareness into Public Engagement” and will help operators improve communications with all four stakeholder groups with the ability to measure effectiveness in all cases and to improve as required based on these metrics. PipelineWatch.com is scheduled to launch in early 2013.
Emergency Responder Communications
There are many challenges that operators and emergency officials face in effectively communicating with each other about pipeline safety. The primary challenge is associated with the fact that there can be many operators in a given area where a single emergency response group has jurisdiction. A large percentage of emergency responders are not aware of major pipelines in their jurisdiction, or, if they do receive any pipeline-related materials from operators, they are potentially overwhelmed with the mixed messages they receive.
What industry is lacking is a full-service strategy that includes the provision of information, training and communication tools allowing for the measurement of effectiveness and real-time communications with emergency responders in the event of an incident.
The American Gas Association has identified a number of key issues for structuring its emergency response communication plans:
* What mechanisms can be used to disseminate emergency response information?
* Should these mechanisms be different depending on the audience?
* What is the best way to prepare emergency responders for a pipeline accident?
* What is the appropriate way to gauge the effectiveness of the safety communications?
* How can emergency responders be encouraged to participate in training and/or meetings?
* What types of information can and should be shared in emergency response communications?
* What role should 911 play in communications with emergency responders?
Following San Bruno, PHMSA issued an Advisory Bulletin to operators of both natural gas and liquid pipelines (ADB-10-08), reminding them of their regulatory obligations to make their pipeline emergency response plans available to local emergency response officials. The Bulletin stated:
“To ensure a prompt, effective, and coordinated response to any type of emergency involving a pipeline facility, pipeline operators are required to maintain an informed relationship with emergency responders in their jurisdiction. PHMSA reminds pipeline operators of these requirements, and in particular, the need to share the operator’s emergency response plans with emergency responders. PHMSA recommends that operators provide such information to responders through the operator’s liaison and public awareness activities, including during joint emergency response drills.”
Most pipeline operators have indicated that sharing their actual emergency response plans with emergency responders is not a viable approach. These emergency response plans were written as a benchmark by and for pipeline operation personnel with information having limited value to the emergency responders. Expecting emergency responders to manage multiple plans is an ineffective approach in terms of accessing required information, in the event of an incident.
The information provided to emergency responders should be in the form of training and education or in real time in the event of an incident. For the latter, the information should only include what is necessary to ensure the safe and correct course of action is followed specific to the hazards that may be present. Having pertinent information in hand to take proper action is critical in any emergency situation.
Despite efforts by pipeline operators, several recent pipeline incidents have highlighted the need for better emergency responder communications and training. As a result of these incidents, the National Transportation Safety Board (NTSB) continues to issue recommendations regarding the pipeline operators’ failure to properly communicate with emergency responders.
For the Marshall, MI accident investigation, similar to the case findings of San Bruno, the NTSB ‘reiterated its recommendation’ to: “require operators of natural gas transmission and distribution pipelines and hazardous liquid pipelines to provide system-specific information about their pipeline systems to the emergency-response agencies of the communities [and] jurisdictions in which those pipelines are located.”
This information should include pipe diameter, operating pressure, product transported, and potential impact radius.” These recommendations influenced the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011, that mandated PHMSA to promulgate a rule that will require all pipeline operators to provide system-specific information to emergency responders.
In October 2012 PHMSA issued another Advisory Bulletin (ADB 12-09):
“to remind operators of gas, hazardous liquid, and liquefied natural gas pipeline facilities that operators should immediately and directly notify the Public Safety Access Point (PSAP) that serves the communities and jurisdictions in which those pipelines are located when there are indications of a pipeline facility emergency.
“Furthermore, operators should have the ability to immediately contact PSAP(s) along their pipeline routes if there is an indication of a pipeline facility emergency to determine if the PSAP has information which may help the operator confirm an emergency or to provide assistance and information to public safety personnel who may be responding to the event.”
Most pipeline related calls that emergency responders receive involve small distribution lines in homes or businesses; however, large-scale pipeline incidents on major transmission pipelines are not nearly as common, yet both can be potentially fatal.
Does a pipeline operator want to rely on the Public Safety Answering Point (PSAP) as the responsible party for the dissemination of information during an emergency? Is utilizing the PSAP the most effective way to communicate critical information? The PSAP solution is being proposed because, until now, there has not been a viable alternative.
Industry is responding to these requirements on a number of fronts; however, there has been no collaboration. The Interstate Natural Gas Association of America is working on establishing communications with emergency responders via an e-mail tracking system. Many operators have begun to develop their own approaches to further enhance their training of emergency responders; however, while these efforts add value, they only address one aspect of the issue and add to the confusion created with emergency responders receiving potentially inconsistent information from a multitude of operators.
Mock Incident Scenario Communications
Through the PipelineWatch.com platform, each operator will have the ability to provide site- specific mock incident scenario exercises (table top) for emergency responders to simulate a pipeline incident. The incident communications “Push” technology feature allows operators the ability to customize the type of materials provided to the first responders ensuring the right information is provided to the right person at the right time. The list of current emergency response personnel to be notified will be managed on a collaborative basis by the operators participating in the PipelineWatch.com service. Each operator will have visibility and edit rights to the list of emergency responders for each county their pipeline traverses in order to keep the list current.
Once the mock incident is initiated, a communication workflow commences to ensure each party knows the requirements of a safe response. The emergency responders will receive an email/text message with a link to the application, displaying the incident location and safe response details. As part of the initiation of the event the operator may select who will have the ability to track the response (operator/emergency responder/both). Placing various icons at the location of the incident captures time stamped responses to document the event response.
PipelineWatch.com also supports “Real Time” incident communications utilizing the same communications workflow. Participating operators are meeting with emergency responders to provide training and to initiate discussion on what information is to be included in the actual communications.
Gary White brings more than 35 years of experience in the industry to his role as president and CEO of PI Confluence, a Houston-based company. PI Confluence; Where Process and Implementation Come Together, was founded in 2003 upon receipt of a DOT grant to create ICAM; a Web-based platform to manage the activities associated with compliance to U.S. Gas Transmission Rule 49 CFR 192 Subpart O. ICAM supports program sustainability while assisting organizations with the management of the essential components of Quality (Plan/Do/Check/Act) through the management of Process, Workflow and Documentation. ICAM is the industry standard for integrity compliance management and documentation solutions.