Media - Pipeline SMS

NTSB turning to voluntary recommendations

NTSB turning to voluntary recommendations

Mike Soraghan, E&E News Reporter

COLUMBUS, Ohio — Safety watchdogs at the National Transportation Safety Board (NTSB) are starting to favor recommending voluntary measures to industry rather than demanding regulatory changes, an agency pipeline official said.

“With NTSB regulatory recommendations, we’re getting diminishing returns,” Robert Hall, the agency’s director of railroad, pipeline and hazardous material investigations, told a conference of state pipeline officials here. “There is definite shift in the NTSB to move toward industry recommendations.”

Hall made his remarks at the end of a series of presentations to the state officials about “safety management systems,” an effort to get companies to move past minimum regulations and instill a culture of safety.

He traced the trend back to an 800,000-gallon pipeline spill near Kalamazoo, Mich., in 2010, which was followed a few weeks later by a fatal pipeline blast in San Bruno, Calif. In its report on the spill, NTSB recommended that the American Petroleum Institute (API) develop a safety management system for pipelines.

It was a “deliberate move” to make the recommendation to industry, Hall said, rather than federal pipeline regulators at the Pipeline and Hazardous Materials Safety Administration (PHMSA).
That resulted in API’s new Recommended Practice 1173, which according to API literature “establishes a pipeline safety management systems (PSMS) framework” for operators.

PHMSA officials have been promoting the safety management system concept at the national meeting of the National Association of Pipeline Safety Representatives, being held here at the Columbus Zoo and Aquarium. But Alan Mayberry, a top career official, stressed that the agency doesn’t intend to add the voluntary guidelines practice to agency regulations.

“We believe in it so much, we don’t need to regulate right now,” said Mayberry, associate administrator for pipeline safety. “We want people to want it and not force it down throats.”
He noted the agency could still order compliance with the standard as part of a corrective order.

But some pipeline officials have taken a skeptical view of “SMS,” as safety management systems are called. Some see it as simply another buzzword. Others fear it’s destined to be incorporated into federal regulations.

“The underlying concern is that someday this is going to be a regulation,” said Leo Haynos, chief of gas operations and pipeline safety at the Kansas Corporation Commission.

But Massoud Tahamtani, director of the Virginia State Corporation Commission Division of Utility and Railroad Safety, said SMS helps to forestall federal regulations by making accidents less likely.

“When bad things happen, we lose control,” Tahamtani said. Pointing to Hall, he said an accident could lead NTSB to push for stricter federal rules.

Hall said NTSB has been happy with the results of its recommendation to API.

“It’s working from our perspective,” he said. “I don’t see us changing with the next big accident.”

NTSB did recommend regulatory changes to PHMSA after the 2010 pipeline spill. But Hall said the request to API was a key recommendation.

Some aspects of an oil pipeline rule expected later this year grew from the Michigan spill, such as requirements for leak detection. And Hall noted that NTSB is still pushing for a recommendation derived from the San Bruno tragedy to remove a “grandfather clause” exemption and require older pipelines to undergo certain types of pressure testing.

But the length of time it takes to change regulations has NTSB looking for ways to make faster improvements in safety, Hall said.

“They’re hard to get done,” he said, “and you’re getting to more prescriptive, tiny little things that you’re asking to change.”

Vectren’s Safety Journey from Concept to Reality

Case Study: Vectren’s Safety Journey from Concept to Reality

December 2016

By Nancy Conder, Manager of Quality Assurance, Vectren, Evansville, IN

It is the year 2014: The industry has lived through several significant safety incidents over the last couple of years. San Bruno, CA and Marshall, MI occurred just a few short weeks apart in 2010. The East Harlem, NY incident had just occurred.

Vectren had its incident in New Albany, IN in 2011, and we know that situation could have created another national headline. So, in the three years since, the company has fortified its existing programs, enhanced procedures, improved training programs, minimized deficiencies in data and records, and modernized its gas infrastructure to meet or exceed compliance and integrity requirements.

However, by contrast, employee safety results have plateaued. With its culture of continuous improvement, Vectren engages a third party to assess the current pipeline safety program and culture, and to recommend improvements.

What began as a single assessment started Vectren’s journey into the world of risk-based business. Social media has been a flurry of commentary and finger-pointing related to incidents over the last several years. The natural gas industry has officially entered into the world of risky business.

This voyage is not for the docile or meek. Every now and then you are just going to need to say, “What the heck?” or maybe some other favorite phrase out of frustration. Saying it gives you freedom. Freedom brings opportunity. Opportunity makes your future.

Recognizing an issue and its potential impact (realized or not) is a first step. How each company chooses to respond will determine its future. Vectren’s future is clear – the relentless pursuit of the safety of our workforce, assets and the public through the implementation of a safety management system (SMS).

Scope

An SMS is a systematic, deliberate approach to managing the safety of the workforce, the public and the company’s asset. It focuses on identifying and reducing risk. It is not the flavor of the month. It is where conversations about risk are intentional and occur at all levels of the organization. It is not a software package. It is all employees being empowered to raise a concern and taking action to mitigate a potential problem. It is continuously improving our processes, procedures, performance and culture. It is not a project with an implementation clock. It is an ever-evolving journey to zero incidents.

Method to Madness

Vectren uses the structured problem-solving methodology – plan-do-check-adjust PDCA) – as the foundational approach to implementing the elements of the API Recommended Practice 1173 Pipeline Safety Management Systems (API RP1173). This methodology can be applied to the SMS as a whole as well as the individual elements and the processes within the system.

The PDCA principle is at the core of Vectren’s SMS. It is designed to encourage and executing strategies and plans in line with guidelines, checking those actions for conformity and using the results to adjust the next generation of plans. This cycle is iterative and maintained to achieve continuous improvement.

Using the recommendations from the third-party assessment of Vectren’s safety and compliance cultures and the published first edition of API RP1173, the gap assessment and the SMS project plan was built. Following the PDCA cycle, Vectren began with risk management as it links key processes, operational controls, performance measures and mitigations, establishing a foundation from which to build the SMS.

Risk management leads budgeting, strategic and business unit planning processes. The entire PSMS-recommended practice is about the identification, awareness and reduction of risk. Vectren targeted activities in the elements of operational controls, safety assurance and management review that would build upon the risk-management foundation.

Vectren felt these elements would encourage and foster the most engagement, progress and empowerment. The company has continued the cycle to cover all of the elements within the PSMS-recommended practice. We did not recreate the wheel.

We leveraged existing processes like those used for integrity management, employee injury prevention, operator qualification and apprenticeship training, management of change, damage prevention, quality management, pipeline modernization, emergency response and compliance monitoring. We leveraged lessons learned from contacts in other industries such as pharmaceuticals, aviation, transportation, and medical devices.

Vectren leveraged existing Six Sigma continuous improvement and quality tools like value-stream analysis, Kaizens, structured problem-solving, peer-risk modeling and bow-tie analysis. These tools visually displayed the current state of affairs, allowing the voices of internal and external stakeholders to be heard.

Our Mental Picture

What is your mental picture of safety? Is it wearing personal protective safety gear and going home the same way you came to work? Is it following a safe job procedure? Or is it more than that? What if that picture looked more like a slideshow or maybe even a collage like this one?

Safety is no longer just employee safety but the safety of our contractors, assets and those who live and work near our assets. Safety is whatever we need it to be and it’s everyone’s responsibility.

Employee engagement is the key to any great safety culture. Vectren will drive opportunities to engage employees at all levels with a systematic process. In 2016, as part of a continuous improvement event, Vectren’s employees redefined the structure of the safety meetings and specifically defined how our workforce was to be engaged in these meetings. Standard work instructions and agenda templates are used with local visual management boards to monitor and measure progress in remediating those employee safety concerns.

Vectren continues to implement a multi-tiered SMS governance structure. It provides intentional and regular communications regarding risk identification and reduction strategies. This tiered model allocates resources to support engagement from our workforce and creates a feedback loop that extends from our frontline employees to our board of directors, starting with educational sessions and governance meetings held on a routine basis.

Near-miss reporting, through an anonymous web-based portal, promotes sharing of lessons-learned. This allows employees and contractors to report safety-related experiences or observations so that everyone can learn from those near misses. Near-miss reporting is available for any activity related to our workforce, assets or the public.

Vectren continues to foster relationships with regulatory agencies by using SMS and our ComplySMART© principles. Regular conversations about the company’s progress and path-forward vision have created opportunities for collaboration and support in both states in which we operate.

SMS in Action

Involving workers in safety-related planning and decision-making, and empowering them to speak up when they identify hazards will help bridge the communication gap between workers and management. It also will build mutual trust and promote a shared belief that a positive safety climate is integral to getting the job done.

The SMS in-action investigations and local SMS meetings provide an excellent chance to involve employees on a regular basis. Bargaining and non-bargaining employees participate in the discussions about the work taking place, types of hazards involved and how these can be reduced or avoided. The workforce is encouraged to participate in these discussions, ask questions, highlight concerns and share ideas.

The in-action investigations involve teams that determine the scope of the issue identified, the desired mitigation plans then established with identified controls. Progress is tracked through quality assurance/quality control functions and communicated through the SMS scorecards and governance discussions. On-spot and management recognitions are given for those willing to highlight and address concerns through this process.

Challenges

Have you ever been given an opportunity so bold and dynamic that you froze in panic? You don’t know where to start, or which way is up. Developing an SMS framework may feel like that at times. Remember that it is a journey. It is an exercise in changing a culture, regardless of how far along you are in your SMS maturity, who employs you, or what your role is in that organization.

Aim for progress vs. perfection: Progress is fluid while perfection is rigid. Perfection can be exhausting while progress is invigorating. Perfection tends to focus on the flaws while progress highlights the strengths and the “aha moments” of realization.

Keep it simple! Understand the current state for each of your stakeholder groups. Make the elements and the action items relatable to them. Make it personal and easily explained. Envision trying to explain SMS to a group of sixth-graders.

Since most companies already have some portion of each element of API RP1173, you may get questions like, “Don’t we already do this stuff?” The audience may ask, “How is this different than enterprise risk management or integrity management?” Think of a grilled cheese sandwich. SMS is the cheese. It is the melted center that sticks to each piece of toast. SMS is flexible and connects very specific quantitative assets or people-related risks to high-level qualitative enterprise risks.

Beyond 2016

As we venture into 2017, Vectren will be entering its second SMS risk management cycle, updating its risk register to reflect new information and mitigation activities. The company will be completing the check-and-adjust cycles for all the essential elements described in API RP1173. The quality assurance, quality control (QA/QC) testing and process effectiveness sampling programs will be initiated with necessary resources and training. As part of the adjust cycle, Vectren will expand the SMS scope beyond natural gas facilities to include electric generation, transmission and distribution assets.

Vectren and the utility industry as a whole must keep in mind that SMS is a continuous journey. There will be days for taking baby steps forward to the goals and objectives, but several days will involve adult-sized steps backward. Those hiccups are learning and growth in disguise. The journey is not about the destination, but the experience along the way.

Author: Nancy Conder is the manager of Quality Assurance for Vectren where she has worked for four years. Prior to working in utilities, Conder was in the pharmaceuticals, and pulp and paper industries in leadership roles with a focus on regulatory compliance, project management and engineering. She holds a bachelor’s degree in mechanical engineering from the University of Evansville and a master’s degree from Murray State University.

Washington Gas sees standards as tools

‘Excited’ about safety management systems, Washington Gas sees standards as tools

August 8, 2016
By Sarah Smith

No gas utility or pipeline wants to make headlines for the wrong reasons.

The process of keeping their systems safe and reliable in the Northeast, however, is a sometimes decades-long slog through century-old systems that can test even the best operators and contractors.

At Washington Gas Light Co., rules and standards that promote a more holistic approach to risk evaluation have helped pave the way for regulatory approval of safety programs that the company hopes will “continuously improve” its systems.

“Pipeline safety is the protector or the foundation of customer and public safety,” said Tracy Townsend, Washington Gas’ vice president of construction, compliance and safety.

In an interview in Springfield, Va., Townsend said she has seen a material uptick in pipeline safety-related activities in recent years. Much of that increase, she said, was driven by a heightened focus on tying together disparate sets of information that made clearer what risks existed on a system.

One of the latest major additions to the suite of big-picture pipeline guidance is safety management systems — comprehensive business programs designed to help entities understand and mitigate risks. The American Petroleum Institute adopted safety management systems as recommended practice, or RP 1173, in mid-2015.

“I’m excited … 1173 is going to give us an opportunity to be very documented and structured and disciplined,” Townsend said. “We are actually participating in the pilot program for [pipeline safety management systems], so we will be voluntarily implementing elements of 1173 prior to it being mandated.”

She drew some parallels between safety management systems and the distribution integrity management, or DIMP, regulations that the U.S. Pipeline and Hazardous Materials Safety Administration finalized in late 2009.

DIMP gave Washington Gas a clear mandate for holistically evaluating risks and a template for persuading regulators and legislators of the need for expedited system upgrades.

“Our DIMP plans are certainly the basis for those accelerated replacement programs. We did all of the analytics on knowing your system, and so we identified things as risks or threats,” Townsend said, noting that Washington Gas’ work with regulators and legislators has helped get accelerated pipeline-replacement programs approved.

RP 1173 goes beyond a company’s physical system, though. It incorporates elements of safety culture as well, and was designed as an iterative, introspective process. Townsend said she does not yet know what new priorities she will be able to present to state regulators as a result of the recommended practice.

“I’m sure there will be things that will be a result [of RP 1173],” Townsend said. “We’ll take a look at things we already have in play, and we’ll do a gap analysis and then we’ll chart a course of action associated with that gap analysis.”

Progress and planning

Across the company’s three jurisdictions — Washington, D.C., Virginia, and Maryland — Washington Gas is working on a series of accelerated pipeline-replacement programs.

With 14 years left in the company’s Virginia pipeline-replacement program, the utility is slated to replace roughly 400 miles of main and more than 97,000 service lines, while in Maryland, the company has 20 more years to replace 557 miles of main and nearly 64,000 services lines, Townsend said. In D.C., the company’s accelerated work is just beginning. Washington Gas is in the first year of a 40-year program and plans to replace about 490 miles of main and 36,000 service lines.

In fiscal 2016 alone, Washington Gas intends to replace 50 miles of main and about 12,000 service lines, she said.

From 2004 to 2014, the company’s miles of at-risk pipe — unprotected steel, iron and copper — fell from 2,520 to 2,355, representing a 6.5% decrease, while the utility added 5,588 miles of plastic pipe, reflecting a 42.7% increase in plastic mileage.

Problem prevention

Some high-profile incidents have revealed that knowing a pipe’s characteristics does not necessarily ensure its safety. The 2014 New York City gas explosion in Consolidated Edison Co. of New York Inc.’s Harlem service territory involved a 2011 plastic pipe. The National Transportation Safety Board found that a faulty plastic pipe fusion was largely to blame for the incident that killed eight people.

In March, a Seattle gas explosion that injured at least nine people happened on Puget Sound Energy Inc.’s system, which does not include any unprotected steel or iron lines.

Townsend said WGL Holdings Inc. subsidiary Washington Gas takes a number of steps to avoid introducing problems into the system amid the massive pipeline-replacement push. In addition to long-term partnerships with contractors and a focus on operator qualifications, the utility also has a system for non-punitive reporting that allows workers to raise concerns without facing retribution, she said.

“It’s my job to figure out how we’re going to continuously improve in pipeline safety,” Townsend said.



Industry Embraces New Pipeline Safety Framework July 8, 2015 – The American Petroleum Institute announced a new pipeline safety management system standard. This new standard which was built on the industry goal of zero incidents was created with engagement and guidance from the National Transportation Safety Board (NTSB), the Pipeline and Hazardous Materials Safety Administration (PHMSA), and other key stakeholders to further enhance pipeline safety.

“Pipelines are safe and efficient, but we are always looking for new ways to make them better, which is why industry is embracing this new standard,” said API Midstream Director Robin Rorick. “It’s also a great example of what can be done when industry, regulators and all key stakeholders work together to achieve a common objective, which is to protect the public, the environment and provide the fuels Americans need.”

API developed and published Recommended Practice 1173 under its American National Standards Institute (ANSI) accredited process and is the American National Standard (ANS) on the subject of pipeline safety management systems. API’s rigorous process is open, transparent and ensures that the best minds from government, academia, the public and industry fully participate in the development of API standards.

“We continue to be committed to safety and this standard raises that bar even further,” said Rorick. “This new standard gives operators a holistic framework to identify and address safety concerns for a pipeline’s entire life cycle.”

API thanked the NTSB and PHMSA for their guidance and cooperation in creating RP 1173. The RP will build upon existing safety requirements to further monitor and measure the effectiveness of pipeline activities with a “plan, do, check, and act” philosophy that requires periodic reviews and applies changes or corrections to activities as needed.



API RP 1173 and Pipeline Safety Management Systems were also featured in a July 2015 article on www.PipelinesInternational.com titled “A New Standards for Achieving Zero Pipeline Incidents.”



AOPL Press Release: Pipeline Operators Announce New Pipeline Safety Tool July 8, 2015 – Today, pipeline operators announced successful completion of a new, jointly developed tool to improve pipeline safety. The API 1173 Recommended Practice for Pipeline Safety Management Systems will provide pipeline operators a comprehensive way to make safe operations and continuous safety improvement a constant focus of their operations.

Used successfully in the aviation, chemical production, refining, and nuclear power industries, safety management systems provide a formal framework to monitor, measure and improve safety performance continuously over time.

After a pipeline incident in Marshall, MI, the U.S. National Transportation Safety Board recommended the pipeline industry build on the success of other industries and develop its own safety management system. Pipeline operators and regulators worked together over 2 years through sometimes contentious discussions to agree upon the final document text. The final document achieved consensus agreement of participating regulators, operators and members of the public that adopting this recommended practice would represent a step change in pipeline safety improvement.

“The liquids pipeline industry is embracing pipeline safety management systems as a comprehensive and holistic way to improve pipeline safety even further,” said Andy Black, Association of Oil Pipe Lines President & CEO.

The recommended practice was formally adopted under the American Petroleum Institute standard setting practice accredited by the American National Standards Institute and meeting essential requirements for openness, balance, consensus and due process. The focus now shifts to implementation where the pipeline industry will encourage, educate and assist its member operators with their own implementation of the recommended practice.

Participants developing the API 1173 Recommended Practice for Pipeline Safety Management Systems included: Alliance Pipeline, American Gas Association, American Petroleum Institute, American Public Gas Association, Arizona Corporation Commission, Association of Oil Pipe Lines, Buckeye Partners, City of Ellensberg, WA, Enbridge Pipeline, Explorer Pipeline, ExxonMobil Pipeline Co, Interstate Natural Gas Association of America, Kinder Morgan, National Association of Pipeline Safety Representatives, Pacific Gas & Electric, Public Representatives Stacey Gerard and Bill Hoyle, Southwest Gas, Spectra Energy, U.S. National Transportation Safety Board, U.S. Pipeline & Hazardous Materials Safety Administration, and the Virginia Corporation Commission.

Media

On July 2, 2014, PHMSA held a public workshop to discuss key concepts underlying Pipeline Safety Management Systems. This workshop expanded on concepts explored in the first Pipeline SMS workshop — held in February 2014 — by detailing how those concepts are advanced in the emerging standard. Watch NTSB Chairman Chris Hart’s speech on the importance of safety management systems and its value to the pipeline industry in the video below. To learn more, visit PHSMA’s YouTube channel to view the entire conference.

Endorsements

“We’ve come to realize that safety management systems are crucial to long term success and attaining the goals that the public and most of the operators and industry have demanded, which is zero incidents.” – Jeff Wiese, U.S. Pipeline and Hazardous Materials Safety Administration (PHMSA)

“SMS has generated wide support in the aviation community as an effective approach that can deliver real safety and financial benefits” – U.S. Federal Aviation Administration (FAA)

“Safe workplaces are most efficient, more productive, and the substantial costs of injuries and occupational illnesses should be significantly reduced by implementing a safety management system.” – Rochester Institute of Technology (RIT)

“Industry companies report the following returns from their investment in process safety:

  • 5% increase in productivity
  • 3% reduction in production costs
  • 5% reduction in maintenance costs
  • 1% reduction in capital budget
  • 20% reduction in insurance costs.”

American Institute for Chemical Engineers (AICHE)

“A safety management system enables you to better comply with regulations and other requirements, will help your business minimize injuries and occupational illnesses (or both), and it will help keep your business costs down.” – Rochester Institute of Technology (RIT)

“According to the Liberty Mutual Research Institute for Safety, for every $1 invested in safety, there is between a $3 and $6 savings.” – National Safety Council

“For such an investment, the benefits include: (a) more opportunities to achieve business objectives such as improved process availability, fewer unwanted incidents, and increased market share; (b) greater changes to motivates, educate, and retain employees; (c) greater likelihood to manage the public image and be viewed as a good neighbor, noble employer, a reliable supplier, and a strong competitor; and (d) more opportunities to gain a competitive advantage and lead the industry.” – American National Standards Institute (ANSI)

Implementation of a SMS can also generate a variety of other benefits beyond safety. Some of those benefits as described by those industries are listed below:

  • Reduced administrative costs (per Center for Chemical Process Safety, Canada National Energy Board).
  • Reduced insurance and liability costs (per Center for Chemical Process Safety, American Society of Safety Engineers, US OSHA).
  • Improved employee morale, loyalty, retention and worker health protection (per Center for Chemical Process Safety).
  • Enhanced company image for employee, to the community, clients, customers, and stakeholders (per Center for Chemical Process Safety, National Safety Council).
  • Reduced costs from injuries and illnesses (per Liberty Mutual Research Institute for Safety, National Safety Council).
  • Improved relations with OSHA and other regulatory agencies (per Rochester Institute of Technology).
  • Similar businesses/activities can learn how they can do better (per Center for Chemical Process Safety).
  • Competitive advantage due to reduced costs and better use of capital and resources (per Center for Chemical Process Safety, National Safety Council).
  • Improved level of compliance to regulations and conformance to company requirements (per Rochester Institute of Technology).
  • Informed decision-making (per Center for Chemical Process Safety).
  • Employee involvement (per Center for Chemical Process Safety).