Pipeline Risk Assessments and Recordkeeping
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Transcript Pipeline Risk Assessments and Recordkeeping
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Instilling A Culture of Safety
Alan Mayberry
Deputy Associate Administrator
August 19, 2014
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Past Events Shaping our Agenda
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
What is a Safety Culture?
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
A Good Safety Culture Doesn’t Happen by
Accident.
It is Instilled in the Organization by Management
and Evolves Over Time.
Evolution Requires Consistent and Constant
Management Commitment.
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Levels of Cultural Evolution
• Backward. Operational focus. Safety is an add-on
requirement. Demonstrate compliance. Try not to
get caught. Use risk assessment to demonstrate
acceptable levels of risk, and audits to verify
compliance. Why spend money on more
“programs”?
• Reactive. General compliance with current
processes and performance. Safety is important
after accidents. Fix the obvious problems that
external reviews/regulators require you to.
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Levels of Cultural Evolution
• Analytical. We have systems, processes, and
models in place. We make sure we follow our
rules.
• Proactive. We actively search for problems,
encourage early reporting of safety problems,
perform investigative risk analyses and
independent audits.
• Pervasive. Safety pervades the way we think and
work every hour of the day.
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Continuous Management
Commitment Drives Evolution
Pervasive
Proactive
Analytical
Reactive
Backward
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
A Safety Culture is one that goes beyond, or puts
aside for the moment, the natural organizational
or personal desires for self-esteem, selfpromotion, and self-defense and actively delves
into critical self-examination, honest selfevaluation, and humble self-improvement.
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Gas Transmission Serious Incidents
1991-2010
12
Number of Serious Incidents
10
8
6
4
2
0
Serious Incidents
Linear (Serious Incidents)
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Gas Transmission Serious Incidents
2001-2010
9
8
Number of Serious Incidents
7
6
5
4
3
2
1
0
2001
2002
2003
2004
Serious Incidents
2005
2006
2007
2008
2009
2010
Linear (Serious Incidents)
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Another reason you should care about
your industry’s safety culture:
The appropriate balance between
prescriptive and flexible regulations (or the
need to regulate in some areas at all) is
determined by how much faith the regulator
has in the industry’s commitment to safety
in the absence of prescriptive regulation (i.e.
the safety culture of the regulated industry)
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
RP 1173 Pipeline Safety Management
System Requirements
• PHMSA has participated in the development
and sponsored public workshops on PSMS
(and safety culture).
• Final version is expected to be promulgated in
the near future.
• Embraces and reinforces the major tenets of
safety culture.
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
RP 1173 Safety Culture Elements
• Leadership Commitment and Stakeholder
Engagement .
• Risk Management and Continuous
Improvement.
• Planning, Training and Preparedness.
• Incident Investigation and Evaluations.
• Assessments and Audits.
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
PHMSA’s Plans for SMS Rulemaking Totally
Depend on Industry’s Response to RP 1173
• We will monitor progress to see if industry
embraces and seriously implements RP
1173
• We hope serious management commitment
within the industry will obviate the need for
rulemaking
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Lessons Learned
• Important progress being made under Integrity
Management, but it is time for the next steps – IMP 2.0
• Clearly operators don’t know their systems as well as
they need to for successful risk management
– Verified records on materials, operational history
– Inadequate consideration of surrounding environment and
possible influences/interactions – simple risk models
• IMP has laid a good foundation that must be built upon
– Safety Management Systems – API RP 1173
– Safety Culture’s important contribution / empowerment
• Construction challenges remain – QMS+ coming soon
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Top Priorities for FY 2014
Anticipate & Avert High Consequence Events by:
i. Issue High Priority Rulemakings
ii. Improve State Program Oversight
iii. Implementing Congressional Act Mandates and Recommendations
iv. Identify and Promote a Suite of Meaningful Performance Metrics
v. Promotion of Pipeline R&D and Technological Advancement
Build & Broadcast Understanding of Safety Risks by:
i. Engage, Educate, and Empower the Public and ER Community (Damage Prevention, PIPA,
811, ER Training)
ii. IMP-2.0 – Sharpening Understanding and Communication
Catalog & Curtail Highest Risks by:
i. Improve Consistency, Unification and Data Driven Inspections for Federal and State Actions
ii. Develop and Deploy a Pipeline Safety Workforce Management Strategy (succession planning,
training, resource allocation)
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Rulemakings in Process
• Safety of On-Shore Hazardous Liquid Pipelines (NPRM stage)
• Safety of Gas Transmission and Gathering Lines (NPRM stage)
– Including Integrity Verification Process (IVP)
• Excavation Damage Prevention (Final Rule stage)
• EFV Expansion beyond Single Family Residences (NPRM stage)
• Operator Qualification, Cost Recovery and Other Pipeline Safety
Proposed Changes (NPRM stage)
• Rupture Detection and Valve Rule (NPRM stage)
• Miscellaneous Rulemaking (Final Rule stage)
• Plastic Pipe (NPRM stage)
• Standards Update (Final Rule stage)
• LNG (ANPRM or NPRM)
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Selected Issues in Play
• Aging infrastructure: rate mechanisms
• Data:
– “Meaningful” Metrics initiatives
– Establish few key performance indicators with stakeholders (aka “DQAT”)
•
•
•
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Methane emissions
Construction quality
Valve/Rupture Detection
LNG
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