Is your pipeline operation safe and in compliance with the DOT requirements? Are you DOT audit ready? If not, do you have your “audit” piggy bank ready and waiting to write that big check or worse be shut down? God forbid there should be an accident, of any type; do you have your cadre of lawyers lined up?
Pipeline operations present risks not only to the operators and the contractors who work on and around them daily – we’re used to it. It can also be a risk for your mom and dad, my kids, my and brothers, sisters. It can be risky for your wife’s friends, aunts, uncles, grandmas and granddads that live in the surrounding communities where pipeline systems are located.
Not to sound too dramatic, but their lives really are in our hands. “Our” being operators, contractors, safety professionals, OQ trainer/evaluators and each and every person up and down the line that plays a role in managing America’s pipeline system.
I don’t have to tell you that pipeline operations are subject to very stringent DOT rules and regulations not only to make sure safe operating procedures are in place, but also to make sure the systems are properly designed and are using the right equipment throughout the entire pipeline system.
Every time I see another pipeline (liquids or gas) related incident splashed across the TV, I often am as angry and frustrated with the operator or contractor involved as I am the inspector. You can bet, just prior to the incident, the last inspector to visit the offices of the operator on whose line the incident occurred – one of three things happened:
1. Wink, Wink, Nod, Nod – Great Job!
I call these non-audits or social calls. Hey, they happen.
2. A fine here or a fine there for a missing “.” or uncrossed “t”
Otherwise referred to as a grammar lesson with a fine thrown in for good measure.
3. An audit with a significant or serious finding, with consequences ranging from large fines to line shut-downs, is a different animal altogether. These can play a pivotal role in which direction an operator takes their safety operations going forward. While follow-up is comprehensive on collecting fines and addressing noted findings the manner in which they are resolved can vary widely AND have a significant impact on whether or not ongoing corrections hold.
I call these the “Like a Box of Chocolates” audits, cause you never know what you are going to get. A serious finding is just that – serious. Irrespective of who found it, what it was, or even what the consequences were – how an auditor approaches the solution can make a huge difference.
“Lil Power Tripper” auditors often get results in a hurry, but the effects of their “dictated” resolutions are often short-lived, leaving behind a situation heavy on resentment and light on long-term solutions where similar, possibly even more serious issues could result.
Conversely, resolutions to findings that are well thought out and involve the operator in the process – so much so – that they feel a part of the solution or are invested in the solution generally come from the “I’m From the Government and I’m Here to Help” auditors (yea, I know . . . I am re-framing the term in a positive manner). These guys are few and far between, but what a blessing if you get these guys. They get it. They get that you have to comply with regulations but you also have to run a pipeline.
Pipeline operators must ensure safe operations of their pipeline systems. Specifically operators must conform to DOT Title 49 CFR Parts 190 to 195. Part 192 specifies the minimum safety requirements for gas pipelines and Part 195 specifies the minimum safety requirements for oil pipelines.
The Moral to the Story: Be Pro-active, not Reactive. Anticipate a DOT/PHMSA audit. Be acutely aware of the many “forms” they can take. If you get an auditor that does not initiate your participation in a resolution but seems to want to dictate, use the opportunity to actively involve yourself in the resolution. Show the auditor that you are serious about getting things done right.
Below are just a few of the multitude of tasks all operators should include in the safe operation of their pipeline systems to remain DOT/PHMSA audit ready:
- Develop, implement (as in – actually use), maintain and annually update DOT manuals, for pipeline operations, as well as Operations & Maintenance manuals (general and site-specific) for pipeline operations, gas gathering systems and compressor station operations
- Develop and have on hand a baseline assessment plan
- Perform a pipeline segment classification survey’s
- Conduct and document operator training and qualifications per DOT
- Develop, maintain and update a map of your entire pipeline system
- Conduct studies to identify and subsequently mitigate pipeline corrosion
- Ensure they conduct “mock” compliance audit to make sure the pipeline is designed and operating in accordance with DOT Regulations. This can be done in-house or outsourced to a third-party.
Last but not least, know where to go for assistance on the web. Here are a few useful links.
- “About” Pipeline and Hazardous Materials Safety Administration (PHMSA)
- Here is a link to Pipeline Safety E-Forms
- Regulation and Code Compliance Seminar Calendar
- Pipeline Safety Regulations
- For assistance with all things Pipeline Compliance and OQ: AYUDA Assessment Training Consulting and OQ LLC