On July 8, 2015, the American Petroleum Institute (API) released the first edition of ANSI/API Recommended Practice (RP) 1173 Pipeline Safety Management Systems. As an ANSI designated standards document, the RP became the national standard for pipeline safety management systems (PSMSs) in the U.S.
Why is this document important for the public, state and federal regulators, and pipeline operators? Despite about 40 years of pipeline safety regulation and steady declines in significant pipeline incidents, too many accidents that have large impacts on the environment, the public and property continue to happen.
In July 2012, NTSB, in its report on the crude oil release in Marshall, MI, made a recommendation to API to develop a pipeline safety management system standard, like API RP 750 for Process Safety Management. With the support of all the national pipeline trade associations and their members, federal and state regulators and public pipeline and process safety experts, API undertook to create this RP in December 2012.
It was under development for more than two years and the work group that drafted it was reflective of all the stakeholder groups mentioned above. The work group reviewed standards, recommended practices and legal requirements that included many of the concepts embodied in the RP, learning from other industries that applied similar management system elements to successfully reduce safety-related incidents. The expectation is that this RP will provide the impetus for the next step change in U.S. pipeline safety performance.
The RP provides a framework for managing pipeline safety systems using an iterative management cycle that promotes intentional, regular review and continuous improvement of an organization’s safety programs. The document is not an occupational health and safety standard, but rather a “process safety” standard for energy pipeline systems under U.S. Department of Transportation (DOT) jurisdiction.
The document was written to be usable by operators of all energy pipelines and scalable to operators of all sizes. The framework may be applied to existing safety management systems to verify elements are in place and identify gaps, and it may also be applied in situations where an operator does not have a pipeline safety management system (PSMS) and intends to develop one.
DOT’s Pipeline and Hazardous Materials Safety Administration (PHMSA) was represented on the drafting work group. The agency’s Associate Administrator of Pipeline Safety, Jeff Wiese, said the agency does not plan to require the use of the RP, but will be watching to see that operators do use it to improve their safety performance.
The 10 elements of the RP are:
• Leadership and Management Commitment – without commitment at all levels within an organization, a PSMS will be unsuccessful. This includes executives, managers, line supervisors, controllers/operators and technicians. It also requires leadership whether formally delegated by management or informally accepted by individuals. Policies and goals must be developed and communicated, roles and expectations made clear and responsibilities, accountabilities and authorities must be defined, documented and communicated throughout the organization, to include top management, management and employees.
• Stakeholder Engagement – stakeholder engagement plans for internal and external stakeholders will define who stakeholders are and how the organization will gather information from and transmit it to them to assist in the identification and management of risk(s) and assessment and communication of organizational safety performance. Company personnel responsible for stakeholder communication and the types of information to be exchanged must be identified.
• Risk Management – this element provides for the gathering of information, identification of risks or hazards to be addressed and managed via the PSMS and putting in place policies and procedures to prevent and mitigate those risks. Continual and regular review of potential risks is required to ensure nothing is overlooked and that new or increasing risks are identified before they can become an issue.
• Operational Controls – written operating procedures that address safe work practices for operations, maintenance and emergency response activities must be put in place. These procedures must be reviewed at least annually to identify improvements and incorporate lessons learned. The operator must assure the integrity of its pipeline systems from manufacturing and construction through maintenance, periodic testing and inspection.
A procedure for management of change must be maintained that includes identification of potential risks associated with a change and whatever required approvals are needed prior to a change. Also, when a contractor is utilized for work. the operator must communicate to the contractor the requirements of its PSMS applicable to the contractor and its employees, with clear definition of accountabilities and authorities, how lessons learned will be fed back to the operator, training and orientation policies, evaluation of contractor safety performance and the communication of worksite risks and management of change procedures.
• Incident Investigation, Evaluation and Lessons Learned – This element requires investigation of incidents and near-misses. Causes, contributing factors, lessons learned, effectiveness of procedures employed during response and recommendations for improvement and transferring lessons learned to the risk assessment and control processes, must be identified and addressed. The operator must determine and document the response to each finding and lesson learned. It also requires the operator to look to external events that it might learn from.
• Safety Assurance – This element is where operators evaluate the application of the PSMS itself. Was expected progress made? The intent is to show proper application of the PSMS and improving risk management and safety performance. To accomplish this, the operator must conduct audits to examine conformity with its PSMS and the RP. Each element of its PSMS must be audited at least once every three years. Evaluations of operator risk management, safety performance, safety culture and PSMS maturity are required. Management must ensure that audit results are addressed in a timely manner and that results are included in the management review (see next element) and fully documented.
• Management Review and Continuous Improvement – this element requires regular management review of the operator’s PSMS and safety performance to determine if goals and objectives have been met. This review includes input from numerous sources, including investigation results, audit results, risk reviews, etc. The result is an assessment of the effectiveness of the PSMS. Recommendations for improvement are to be integrated into the next iteration of the management/planning cycle.
Management must improve upon the PSMS by incorporating the results of audits, assessments, data analysis and this management review. New technology must also be periodically evaluated for how it might enhance pipeline safety. Top management (executive) must annually review and approve the outputs of management reviews and all outputs shall be documented. Proper execution of this element ensures that review and improvement of safety systems is regular and intentional.
• Emergency Preparedness and Response – While the purpose of an SMS is to prevent incidents, it must be recognized they do occur and there must be procedures in place for responding effectively to them. Plans must be accessible and communicated to employees and contractors.
• Competence, Awareness and Training – any employee, including contractor employees, whose responsibilities fall within the scope of an operator’s PSMS must have the appropriate level of competence as demonstrated through education, training and experience. That includes training to enable the development and implementation of the PSMS elements. Training must include refresher training and raise awareness of opportunities for improvement. \
Training is required so that employees and contractors are updated and aware of the PSMS elements that affect their jobs, newly emerging or changing risks, problems implementing the PSMS, opportunities to improve processes and procedures and potential consequences of failure to follow processes and procedures.
• Documentation and Recordkeeping – all management systems place emphasis on proper documentation and recordkeeping and 1173 is no exception. Each operator must maintain a procedure for identifying, distributing and controlling the documents required by its PSMS and regularly reviewing and updating them. The procedure must include responsibilities for approvals of documents, as well. Documents that are specifically called-out in the RP include: statements of safety policies and objectives, procedures established under the PSMS, documents or records of PSMS-required work, regulatory or other applicable requirements and any documents the operator identifies as needed to show the effectiveness of the PSMS.
The RP also includes a section describing how a PSMS supports and is supported by a strong safety culture.
All of these elements, when applied to a pipeline system using an iterative management cycle, such as the Plan, Do, Check and Act cycle in the RP, and applied regularly and intentionally, will result in improved safety and fewer incidents. Additionally, an organization’s safety culture will be enhanced by employing a PSMS.
The next step for the pipeline industry will be to implement and track the use of PSMSs that conform to the RP across the industry and record and communicate the benefits. The PSMS RP holds the promise of yielding great safety strides for operators, regulators and, most importantly, the public.
Peter Lidiak was the Pipeline Director at the American Petroleum Institute from July 2005 through April 2015 and was closely involved in the development of ANSI/API RP 1173.