Tales from DC: PHMSA Workshop of Safety Management Systems
On February 27, the Pipelines and Hazardous Materials Safety Administration held a workshop on safety management systems prompted by the API’s release of its draft draft recommended practice for pipeline safety management system requirements. An API presentation explains the context. This report is from the Law Offices of Adele Abrams, ASSE’s Federal Representative:
Jeff Wiese (DOT/PHMSA)
Ron McClain (RP 1173 Committee Chair)
James Watson (American Bureau of Shipping)
Debra Phillips (American Chemical Council)
Don Arendt (Federal Aviation Admin.)
Armando Martinez (Miami Air)
Nick Stavropoulos (Pacific Gas & Electric)
Bill Mooney (DuPont Chemical)
George Mortenson (Institute of Nuclear Power Operators (“INPO”))
Patrick Smyth (Canadian National Energy Board)
Tim Vogus (Vanderbilt University)
The Pipeline and Hazardous Materials Safety Administration (“PHMSA”) workshop, February 27, 2014, included a day of presentations about Safety Management Systems (SMS). The SMS presenters included safety professionals and government employees across a variety of industries, from aviation to nuclear energy. The workshop coincided with the release of the American Petroleum Institute’s (API) recommended practice draft for pipeline safety management system requirements.
This is the first edition of the recommended practice disseminated for public review and comment. It is officially referred to as API RP 1173. (Please see attached document) The committee members included industry stakeholders and government representatives from PHMSA. The comment deadline for API RP 1173 is April 11, 2014 before 11:59PM. Instructions for submitting comments are included in the draft document. The draft Recommended Practice is not for additional government regulations, but instead from the industry in order to implement SMS throughout oil, gas, and energy handling operations.
API RP 1173 Chairman Ron McClain gave a brief opening address regarding the goals and intentions of the RP 1173. The committee was formed to develop a SMS for pipeline operators, which would address challenges and needs specific to the industry. Chairman McClain stated several key components of the recommended practice: determine how top management develop processes and procedures to reveal and mitigate safety threats; facilitate continuous safety improvements; and make compliance and risk reduction routine and intentional. These driving influences were echoed by each speaker and presenter during the day.
The presentations described the steps to developing and maintaining effective SMS in the presenters’ industry groups. Debra Phillips, from the American Chemical Council, described the Reasonable Care program developed by the council and required to be followed by each member company. The council administers audits and compliance checks for its membership. Similarly, George Mortensen attested to the value and effectiveness of the Institute of Nuclear Power Operators’ (INPO) audits as essential in maintaining the nuclear power industries’ SMS. INPO was created by the industry following the events at Three Mile Island for the sole purpose of internally policing safety in the industry and pushing forward the safety culture.
Don Arendt of the Federal Aviation Administration discussed what he felt should be government’s role in maintain industry safety. Mr. Arendt stated that in his opinion the government’s role should be leadership in safety, and that the regulator must facilitate a safety environment. He expressed that safety must not be “supported” but “owned” by top management, and without that dedication SMS will not reach full potential. Armando Martinez, from Miami Air – a charter airline company, described the process through which he and his company have been implementing a SMS while working with the FAA. In addition to reductions in workplace incidents, Mr. Martinez also described financial benefits of SMS, including significant safety bonuses from insurance carriers, reductions in insurance premiums, and worker’s compensation payments.
Nick Stavropoulos, of Pacific Gas and Electric, elaborated on the integration of their SMS following major pipeline disaster. Mr. Stavropoulos described the challenges of changing the perception of safety in the organization. He insisted, like all of the other presenters, that top management is crucial to the success of any SMS. Additionally, Mr. Stavropoulos described the importance of getting the “on line” employees to buy into the system. This included meeting and working with the mid-level management in the company as well as the unions representing the workforce. One of his primary focuses when beginning the implementation was to improve the safety culture of the organization as a whole. Similarly, Bill Mooney of DuPont chemicals echoed the importance of a safety culture for a successful SMS. He quipped, that thinking up a SMS is the easy part. At DuPont the SMS is a well-established system, however, Mr. Mooney still emphasized the importance of top-down dedication from management to the SMS. Additionally, he emphasized the need for all employees to feel comfortable enforcing the safety protocols at all times with anyone on site.
Tim Vogus, from Vanderbilt University, discussed the importance of training and teaching in creating and maintaining a safe work environment. His research focused on the Health Care industry, specifically nursing departments in hospitals. Mr. Vogus emphasized that integrating new members into the work culture and properly training them can help to significantly reduce worker errors. Mr. Vogus further explained that when young nurses were paired with experienced employees after being hired, the younger nurses were more willing to participate in safety-related conversations and activities sooner, which led to decreased mistakes. Lastly, Patrick Smyth, Canadian National Energy Board, detailed the process through which they have attempted to develop and implement SMS through the energy industry.
Several core concepts were repeated and emphasized throughout the day, including:
1. Top management must be fully dedicated to the system;
2. All workers must feel comfortable reporting and participating in the system, non-punitive reporting is essential;
3. All workers must also feel responsible for overall safety, creating a healthy safety culture;
4. The organization must continuously strive to further safety and manage risk; and
5. Reviews and audits of the systems are critical to continued viability and success, and both internal or third party audits are effective.
Each presenter praised SMS as an effective means of maintaining workplace and public safety. Although the key elements of the systems may be present in each effective SMS, it is clear that the requirements and guidelines must be tailored to the target industry. That is the goal of API RP 1173, to create a SMS specific to the pipeline industry. This perception is further supported by the successful creation of industry specific systems by the American Chemistry Council and INPO. It is hard to argue the effectiveness of properly designed and implemented Safety Management Systems, especially when the industry as whole participates in the systems creation and supports its use.