About Pipeline SMS
Table of Contents
- Guiding Principles
- Pipeline SMS Membership
- Assessment Information
- Information Sharing
API Recommended Practice (RP) 1173, Pipeline Safety Management Systems (Pipeline SMS), was developed by pipeline operators, for pipeline operators. The framework is flexible enough to help those new to SMS, as well as those with sophisticated, existing systems. It is scalable to allow operators large and small to benefit. In all cases, a Pipeline SMS system similar to the RP framework will improve the safety culture essential to achieving maximum safety performance.
Pipeline SMS will continuously identify, address and monitor threats to the safety of company operations by doing the following:
- Be proactive.
- Document procedures and require strict adherence.
- Treat operator errors as system deficiencies and not as reasons to punish and intimidate.
- Require senior company management to commit.
- 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 aspects of operations.
- Provide safety assurance by regularly evaluating operations to identify and address risks.
The core principle, which is the “Plan-Do-Check-Act” cycle, requires operators to determine the steps needing to be taken, complete these, periodically review and if necessary, enact any changes or improvements. Ultimately, this requirement drives the industry towards its zero-incident goal by ensuring that the various components of the safety management system are regularly reviewed and continually evolving.
The API RP 1173 framework is detailed with flexibility to account for the current state of development of particular elements of management systems within a company. In cases where an operator is already operating under its own comprehensive Pipeline SMS, this framework serves as a basis of comparison and review between the industry recommended practice and the operator’s system. Other operators may have some number of individually established safety systems but no comprehensive Pipeline SMS. For them, the guidance in API RP 1173 provides a means to integrate and add to those efforts to establish a comprehensive system. Still, other operators may have no formal program, and for these, adoption of the framework would be a starting point to build a Pipeline SMS, while learning from more advanced operators. In all cases, operators are intended to have the flexibility to apply this RP as appropriate to their specific circumstances.
The details in API RP 1173 are also intended to be scalable for pipeline operators of varying size and scope. The number of employees at a liquid pipeline operator can range from a handful to thousands. A local gas distributor or municipal operator may have only a few employees. An interstate transmission pipeline company may have entire divisions of subject matter experts. The 10 essential elements comprising the framework apply to organizations of any size and sophistication. Specific application of those elements to the operations and processes of a given operator will reflect the scale of that operator. The framework elements and principles underlying it are broadly applicable, and strongly recommended, for energy pipeline operators of all sizes. The level of detail in each pipeline operator’s Pipeline SMS should be appropriate for the size of their operations and the risk to the public and the environment. For very small operators with a handful of employees, adoption of all provisions within this RP may not be practical. However, even small operators can build on the provisions given in the document.
Another critical facet of the RP will be the performance-based nature of its approach. Where many standards are prescriptive and provide a detailed checklist to complete, API RP 1173 provides a complete framework to meet the company’s safety targets. Operators then determine what specific tactics are needed to ensure success in the SMS implementation.
Pipeline SMS Membership
In July 2015, API published RP 1173 through the collaboration of industry, regulators and public advocates. Following this publication, an implementation plan kicked off, and this three-phase plan can be viewed here. Phase One in that journey is signaling company agreement to adopting API RP 1173 by signing the Pipeline SMS Commitment Letter. To date, almost 95% of liquids pipeline industry barrel miles have committed to Pipeline SMS.
The next step is companies’ commitment to participate in the API Pipeline SMS Group, through their signing the Pipeline SMS Group Membership Letter. This Group will educate stakeholders and enhance safe pipeline operations through the implementation and use of API RP 1173. Members will exchange ideas, information and lessons about the implementation of API RP 1173 in an effort to advance pipeline safety for individual companies and the industry as a whole. Over 91% have committed to joining the Pipeline SMS Group.
After API receives the completed Pipeline SMS Commitment Letter and Group Membership Agreement, the Pipeline SMS Group logo will be sent to the operator and can be used. API and AOPL will use Pipeline SMS Commitment Letters and Group Membership Agreements to develop aggregated statistics and information about industry-wide participation and communicate this positive effort to external stakeholders.
In Phase Two, implementation tools including gap analyses and assessment tools will be developed. Also in 2016, API is hosting several Pipeline SMS Workshops to educate the industry on implementation. Soon after in Phase Three, industry will begin the assessment process with three possible options: internal, peer-to-peer, or external.
The pipeline operator shall perform assessments to determine whether the operator’s safety management system is implemented, maintained and conforms to API RP 1173, Pipeline Safety Management Systems. It is critical that the operator ensures each of the Pipeline SMS elements are in place and effective, including identifying the criteria, scope, frequency and methods used to assess the application of and conformance with its Pipeline SMS and this RP.
An audit may be performed by external professionals or internal personnel not involved in the work of the Pipeline SMS or the operations being audited. Examples may include personnel of a separate operating unit, an organization’s compliance unit, an organization’s internal audit group, or external parties such as professional auditors, subject matter experts, or peer operators.
One essential element of API RP 1173 is “Incident Investigation, Evaluation, and Lessons Learned.” In this element, operators are required to establish a process to evaluate not only events they have experienced, but also, ones external to their companies. Operators should use this assessment to gain additional knowledge to improve their processes. While API RP 1173 and these requirements may be fairly new, learning and sharing has occurred in the pipeline industry for many years. However, a recent tool has been developed to further this dissemination of external event sharings. A repository of files, including presentations, spreadsheets, and videos, with valuable information detailing what companies learned from an incident and how they changed their operation to prevent something similar from happening launched in 2016. These teachings can be invaluable, as other operators can review and similarly, take action to prevent a related occurrence. All of these learnings can be found on API’s PIPES (Pipeline Industry Practical Experience Sharing) Portal . Recognizing the sensitivity of some of the sharings, PIPES is restricted to operators only. However, an industry willing to share and implement an effective Pipeline SMS ensures that increased knowledge is spread throughout and pipeline safety is improved.
Pipeline Operators: Sign in to PIPES
If you are not a pipeline operator but have questions about what the industry is doing to further information sharing, please contact PIPES@api.org.