Pipeline Safety: Control Room Management /Human Factors                                                  “Final Rule Decem...
Presentation Objectives<br />Provide background information on development of the rule.<br />Present elements of “new” con...
Background on Rule Development<br />Pipeline and Hazardous Materials Safety Administration has been examining and evaluati...
Safety Rec. P-05-001 (NTSB) <br />Recommends that PHMSA:<br />Require operators of hazardous liquids pipelines to follow t...
Safety Rec. P-05-002 (NTSB)<br />Recommends that PHMSA:<br />Require pipeline companies to have a policy for the review/au...
Safety Rec. P-05-003 (NTSB)<br />Recommends that PHMSA:<br />Require controller training to include simulator or non-compu...
Safety Rec. P-05-004 (NTSB)<br />Recommends that PHMSA:<br />Change the liquid accident reporting form and require operato...
Safety Rec. P-99-12 (NTSB)<br />Urges PHMSA, to:<br />“establish within two years scientifically based hours of service re...
Safety Rec. P-98-30 (NTSB)<br />Urges PHMSA, to:<br />“assess the potential safety risks associated with rotating pipeline...
Reasons for NTSB Bulletins<br />The NTSB noted that scientific research has shown that certain sleep factors can affect fa...
Reasons for NTSB Bulletins<br />Recommendations resulted from the NTSB’s review of all transportation accidents reported t...
Reasons for NTSB Bulletins<br />Were there any pipeline accidents where Control Room issues could have contributed to the ...
Federal Most Wanted Transportation Safety Improvements<br />Reduce Pipeline Accidents Caused by Human Fatigue<br />
NTSB Most Wanted<br />No Federal hours-of-service regulations exist for controllers of pipeline systems<br />Regulations e...
PHMSA Bulletins <br />“Pipeline Safety:  Countermeasures to Prevent Human Fatigue in the Control Room”  ADB-05-06<br />“Po...
PHMSA & Industry Activities<br />Controller Certification Study<br />Participation with industry associations<br />API 116...
Congress<br />Pipeline Safety Improvement Act of 2002<br />Study control room operations<br />Operator Qualification Requi...
Notice of Proposed Rulemaking<br />PHMSA issued NPRM PHMSA-2007-27954 on September 12, 2008.<br />Received 144 comments, m...
Initial Summary Statements<br />Must define the roles and responsibilities of controllers…<br />And provide controllers wi...
Initial Summary (continued)<br />…manage SCADA alarms<br />…assure control room considerations are taken into account when...
Effective Dates<br />Final rule is effective February 1, 2010.<br />Develop control room management procedures by August 1...
Definitions in Parts 192 & 195<br />Important for determining if rule applies:<br />Alarm<br />Controller<br />Control Roo...
Definitions in Parts 192 & 195<br />Alarm means an audible or visible means of indicating to the controller that equipment...
Definitions in Parts 192 & 195<br />Controller means a qualified individual who remotely monitors and controls the safety-...
Definitions in Parts 192 & 195<br />Supervisory Control and Data Acquisition (SCADA) system means a computer-based system ...
Rule for Parts 192 & 195<br />If you have controller(s) in a control room monitoring and controlling with a SCADA system;<...
Control Room Mgt. Section<br />Written control room management plan<br />Define controller roles and responsibilities:<br ...
“Provide adequate information”<br />Implement API 1165 (partially for gas) whenever SCADA is changed.<br />Conduct point-t...
“Fatigue mitigation”<br />Establish shift lengths and schedule rotations that…provide time…to achieve 8 hours of continuou...
“Alarm Management”<br />Written alarm management plan<br />Review SCADA safety-related alarm operations using a process th...
“Change Management”<br />Establish communications between control room representatives, management, and field personnel wh...
“Operating Experience”<br />Incorporate lessons learned from operating experience into procedures and training.<br />Revie...
“Training”<br />Establish, then review annually and improve training program.<br />Responding to abnormal operating condit...
“Compliance Validation”<br />Submit procedures, when requested, to PHMSA or appropriate State agency.<br />
“Compliance & Deviations”<br />Maintain records for review:<br />Records that demonstrate compliance<br />Documentation to...
Summary<br />Was this rule necessary?  <br />Can this rule help improve pipeline operations?<br />Incidents and near misse...
2010 Pipeliners Club Crm Final Rule
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Overview of Control Room Management Rule

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2010 Pipeliners Club Crm Final Rule

  1. 1.
  2. 2. Pipeline Safety: Control Room Management /Human Factors “Final Rule December 3, 2009”<br />Pipeliners Club of Atlanta<br />January 11, 2010<br />
  3. 3. Presentation Objectives<br />Provide background information on development of the rule.<br />Present elements of “new” control room management rule.<br />Comment on ways to comply with rule, and go beyond compliance.<br />
  4. 4. Background on Rule Development<br />Pipeline and Hazardous Materials Safety Administration has been examining and evaluating and advising on Control Room operations for at least 14 years. (1996)<br />NTSB has been making recommendations about “human factors” for at least 12 years. (1998)<br />Pipeline Safety Improvement Act of 2002<br />Pipeline Inspection, Protection, Enforcement, and Safety Act of 2006 (PIPES Act)<br />
  5. 5. Safety Rec. P-05-001 (NTSB) <br />Recommends that PHMSA:<br />Require operators of hazardous liquids pipelines to follow the API Recommended Practice 1165 for the use of graphics on the SCADA* screens.<br />NTSB had performed a safety study due to leaks going undetected after indications of a leak on the SCADA interface.<br />New rule addresses this recommendation.<br />*SCADA = Supervisory Control and Data Acquisition<br />
  6. 6. Safety Rec. P-05-002 (NTSB)<br />Recommends that PHMSA:<br />Require pipeline companies to have a policy for the review/audit of alarms.<br />New rule addresses this recommendation.<br />
  7. 7. Safety Rec. P-05-003 (NTSB)<br />Recommends that PHMSA:<br />Require controller training to include simulator or non-computerized simulations for controller recognition of abnormal operating conditions, in particular, leak events.<br />New rule addresses this recommendation.<br />
  8. 8. Safety Rec. P-05-004 (NTSB)<br />Recommends that PHMSA:<br />Change the liquid accident reporting form and require operators to provide data related to controller fatigue.<br />This recommendation is being addressed in a change to accident reporting requirements for gas and liquids pipelines.<br />
  9. 9. Safety Rec. P-99-12 (NTSB)<br />Urges PHMSA, to:<br />“establish within two years scientifically based hours of service regulations…<br />that set limits on hours of service,…<br />provide predictable work and rest schedules…<br />and consider circadian rhythms and human sleep and rest requirements.”<br />New rule may or may not address this recommendation, depending on whether you are NTSB or PHMSA.<br />
  10. 10. Safety Rec. P-98-30 (NTSB)<br />Urges PHMSA, to:<br />“assess the potential safety risks associated with rotating pipeline controller shifts and…<br />establish industry guidelines for the development and implementation of pipeline controller work schedules…<br /> that reduce the likelihood of accidents attributable to controller fatigue.”<br />Closed May 3, 2006, due to P-99-12 being issued.<br />
  11. 11. Reasons for NTSB Bulletins<br />The NTSB noted that scientific research has shown that certain sleep factors can affect fatigue and performance, such as insufficient sleep, irregular schedules, and unpredictable schedules.<br />
  12. 12. Reasons for NTSB Bulletins<br />Recommendations resulted from the NTSB’s review of all transportation accidents reported to U.S. Department of Transportation (DOT) modal administrations over a 10 year period. <br />NTSB noted that it had issued over 70 fatigue-related safety recommendations that resulted from its investigations of major accidents, special investigations, or safety studies that identified operator fatigue as a causal factor.<br />
  13. 13. Reasons for NTSB Bulletins<br />Were there any pipeline accidents where Control Room issues could have contributed to the accident?<br />Several examples cited:<br />Colonial Pipeline 1996 (Controller fatigue)<br />Marathon Pipeline 1998 (SCADA & alarms)<br />Olympic Pipeline 1999 (SCADA maintenance)<br />Marathon-Ashland 2000 (Controller fatigue)<br />NTSB study “10 of 18 hazardous liquids accidents have potential Control Room involvement”<br />
  14. 14. Federal Most Wanted Transportation Safety Improvements<br />Reduce Pipeline Accidents Caused by Human Fatigue<br />
  15. 15. NTSB Most Wanted<br />No Federal hours-of-service regulations exist for controllers of pipeline systems<br />Regulations exist in other transportation modes.<br />Set working hour limits for pipeline controllers based on fatigue research, circadian rhythms, and sleep and rest requirements. <br />“Acceptable Response – Progressing Slowly”<br />
  16. 16. PHMSA Bulletins <br />“Pipeline Safety: Countermeasures to Prevent Human Fatigue in the Control Room” ADB-05-06<br />“Potential Service Disruptions in SCADA Systems” ADB-03-09<br />“Potential Service Interruptions in Supervisory Control and Data Acquisition Systems” ADB-99-03<br />
  17. 17. PHMSA & Industry Activities<br />Controller Certification Study<br />Participation with industry associations<br />API 1165 RP SCADA displays<br />API 1167 RP Alarm Mgt.(in progress)<br />API 1168 RP Control Room Mgt.<br />Battelle Human Factors Analysis<br />API Control Room Forums<br />SGA Gas Control Framework Document<br />AGA White Papers<br />
  18. 18. Congress<br />Pipeline Safety Improvement Act of 2002<br />Study control room operations<br />Operator Qualification Requirements<br />PIPES Act of 2006<br />“Reduce risks associated with human factors, including fatigue, for pipeline controllers and other employees.”<br />NTSB recommendations on display, alarms, and training<br />Issue regulations<br />
  19. 19. Notice of Proposed Rulemaking<br />PHMSA issued NPRM PHMSA-2007-27954 on September 12, 2008.<br />Received 144 comments, mostly from liquids and gas pipeline industry groups and companies.<br />Majority of comments said “withdraw the proposed rule and start over.”<br />Rule was not withdrawn, but PHMSA did take some comments into consideration before issuing the final rule.<br />
  20. 20. Initial Summary Statements<br />Must define the roles and responsibilities of controllers…<br />And provide controllers with the necessary information, training, and processes to fulfill these responsibilities.<br />…must also implement methods to prevent controller fatigue<br />
  21. 21. Initial Summary (continued)<br />…manage SCADA alarms<br />…assure control room considerations are taken into account when changing pipeline equipment or configurations…<br />…review reportable incidents or accidents to determine whether control room actions contributed to the event.<br />
  22. 22. Effective Dates<br />Final rule is effective February 1, 2010.<br />Develop control room management procedures by August 1, 2011.<br />Implement the procedures by February 1, 2012.<br />Plenty of time for compliance?<br />Most companies still have questions about what parts of the rule “really mean.”<br />
  23. 23. Definitions in Parts 192 & 195<br />Important for determining if rule applies:<br />Alarm<br />Controller<br />Control Room<br />Supervisory Control and Data Acquisition System<br />
  24. 24. Definitions in Parts 192 & 195<br />Alarm means an audible or visible means of indicating to the controller that equipment or processes are outside operator-defined, safety-related parameters.<br />Control Room means an operations center staffed by personnel charged with the responsibility for remotely monitoring and controlling a pipeline facility.<br />
  25. 25. Definitions in Parts 192 & 195<br />Controller means a qualified individual who remotely monitors and controls the safety-related operations of a pipeline facility via a SCADA system from a control room, and who has operational authority and accountability for the remote operational functions of the pipeline facility.<br />
  26. 26. Definitions in Parts 192 & 195<br />Supervisory Control and Data Acquisition (SCADA) system means a computer-based system or systems used by a controller in a control room that collects and displays information about a pipeline facility and may have the ability to send commands back to the pipeline facility.<br />
  27. 27. Rule for Parts 192 & 195<br />If you have controller(s) in a control room monitoring and controlling with a SCADA system;<br />Applies to natural gas pipelines, except<br />Distribution with less than 250,000 services, or<br />Transmission without a compressor station<br />Must still implement sections about fatigue, compliance validation, compliance and deviations.<br />Applies to hazardous liquids pipelines.<br />
  28. 28. Control Room Mgt. Section<br />Written control room management plan<br />Define controller roles and responsibilities:<br />Normal, abnormal, and emergency operations<br />Authority to make decisions and take actions<br />Controller’s role during abnormal operating conditions<br />Controller’s role during emergency operating conditions<br />Method of recording shift-changes and hand-over of responsibility.<br />I would also define roles and responsibilities of other jobs in relation to controllers so that every person understands roles and responsibilities.<br />
  29. 29. “Provide adequate information”<br />Implement API 1165 (partially for gas) whenever SCADA is changed.<br />Conduct point-to-point verification between SCADA displays and field equipment whenever something is changed.<br />Test and verify internal communication plan for manual operation of the pipeline.<br />Test any backup SCADA systems.<br />Implement section 5 of API RP 1168 to establish procedures for when different controller assumes responsibility.<br />Very specific in this section, because it is easier to be specific about SCADA systems & equipment.<br />
  30. 30. “Fatigue mitigation”<br />Establish shift lengths and schedule rotations that…provide time…to achieve 8 hours of continuous sleep. Work time + commute time<br />Educate controllers and supervisors in fatigue mitigation strategies and how off-duty activities contribute to fatigue. Regular, ongoing<br />Train controllers and supervisors to recognize the effects of fatigue. Recognize signs and risks<br />Establish a maximum limit on controller hours of service. Day, week, dayshift, nightshift<br />Less specific in “socio-technical” system.<br />
  31. 31. “Alarm Management”<br />Written alarm management plan<br />Review SCADA safety-related alarm operations using a process that ensures alarms are accurate…<br />Monthly identification of alarms that are off-scan, inhibited, false, etc. <br />Verify correct safety-related alarm set-point values and alarm descriptions annually.<br />Review alarm management plan annually.<br />Monitor content and volume of general activity directed to controller annually to ensure alarm response.<br />Address deficiencies in any of these items.<br />Specific again<br />
  32. 32. “Change Management”<br />Establish communications between control room representatives, management, and field personnel when planning and implementing changes. Document your plans and practices<br />Require field personnel to contact control room during emergency conditions or when making field changes. How will you “require?”<br />Seek control room or control room management participation in planning prior to implementation of significant pipeline hydraulic or configuration changes. What is “significant?”<br />Less specific, due to more “socio-technical” elements<br />
  33. 33. “Operating Experience”<br />Incorporate lessons learned from operating experience into procedures and training.<br />Review incidents that meet reporting requirements for contributions/deficiencies:<br />Controller fatigue<br />Field equipment<br />Operation of any safety device<br />Procedures<br />SCADA system configuration & performance.<br />Do you have operating experience system?<br />
  34. 34. “Training”<br />Establish, then review annually and improve training program.<br />Responding to abnormal operating conditions likely to occur.<br />Use of simulator or tabletop method for training controllers to recognize abnormal operating conditions.<br />Working knowledge of pipeline system…<br />Infrequently used setups and procedures.<br />Most companies have a training program.<br />
  35. 35. “Compliance Validation”<br />Submit procedures, when requested, to PHMSA or appropriate State agency.<br />
  36. 36. “Compliance & Deviations”<br />Maintain records for review:<br />Records that demonstrate compliance<br />Documentation to demonstrate that any deviations from requirements was necessary for the safe operation of a pipeline facility.<br />
  37. 37. Summary<br />Was this rule necessary? <br />Can this rule help improve pipeline operations?<br />Incidents and near misses are caused by any and all of the areas in the rule.<br />Most organizations are averse to learning.<br />Most organizations have a change management process, but sometimes do not manage changes well.<br />Is the final rule the “final” rule?<br />Believe SCADA and alarm management are.<br />Do not believe fatigue mitigation will be.<br />

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