As a result of the National Transportation Safety Board (NTSB) incident investigation following the Marshall, Mich., July 2010 pipeline spill, the NTSB recommended the development of a safety management standard specifically for the industry.
Industry leaders led the effort to form a team to accomplish this task, including representatives from the pipeline industry, industry trade organizations, the general public and federal and state regulators. The result was the creation of the American Petroleum Institute Recommended Practice (RP) 1173. RP 1173, was finalized in the second quarter and formally adopted in early July by the institute.
RP 1173 includes 10 key components in the development of a company’s safety management system (SMS):
1. Leadership and management commitment—top, down and back up;
2. Stakeholder engagement (external and internal);
3. Risk management (environmental, operational, worker);
4. Operational controls;
5. Incident investigation, evaluation and lessons learned (investigate, evaluate, learn);
6. Safety assurance;
7. Management review and continuous improvement;
8. Emergency preparedness and response;
9. Competence, awareness and training; and
10. Documentation and record keeping.

Building on today’s programs
The building blocks to a strong SMS are already in place. The requirements under the federal government’s 49 CFR 195 and CFR 192 compliance programs form the foundation to further improve upon. Some potential “connected” compliance program areas include:
-Integrity management planning;
-Operator qualification programs;
-Drug and alcohol planning;
-Public awareness planning;
-Damage prevention;
-Emergency response;
-Control room management;
-Operations and maintenance;
-Facility evaluations;
-Training programs;
-Spill response planning; and
-Spill management.
These key programs share common elements that need to be integrated.
Key stakeholders, internal and external, form the communication network to ensure success. Let’s review the 10 components of the new standard.
Leadership and management commitment: Commitment and accountability from the top down in an organization, along with understanding of the roles and responsibilities of all stakeholders, forms the basis for a successful SMS. Engagement by top management in the development, implementation, improvement and evaluation of the SMS is needed to ensure an effective program.
Stakeholder engagement (external and internal): Identification of stakeholders, both internal and external, is an important step in the development and implementation of the SMS program. Establishing a process for communication is key to ensure that the internal stakeholders are aware of their responsibilities, the SMS policy and their role in communicating with external stakeholders. It is important to establish two-way communication with external stakeholders, as they can provide feedback regarding the environment surrounding the facilities.
Risk management (environmental, operational, worker): The next step is to understand all the risks that exist in order to manage these risks and reduce any potential impacts associated with the risks to ensure the safe operation of the pipeline and associated facilities.
Using the risks identified and integrating them with potential operational controls can act to substantially eliminate potential impacts to stakeholders, both internal and external.
Incident investigation, evaluations and lessons learned: First, investigate and document. Documentation is the foundation for learning from the past and planning for a safer future. Building a robust safety management system that houses and integrates all the important data related to the safe management of pipelines forms the foundation for a successful operational compliance management program.
Some examples of key data are location of assets, operating history for each pipeline, history of spills/leaks, root cause of previous incidents and valve locations relative to high consequence areas. The use of geographic information systems helps to strengthen the bridge between engineering and environmental (internal stakeholders) allowing for an integrated system that “sees” the communities around the pipeline (external stakeholders).
Next, evaluate and learn. Knowledge is power. Using the history of the pipeline and applying that to not only understand root causes, but also having a process to incorporate that information to further strengthen the management program, is a valuable tool in effective safety management.
Safety assurance: A successful safety management system is built on the programs that drive it forward. For example, integrity management programs and emergency response programs are built on knowing the people and environment that infrastructure operates within and building a program that integrates that knowledge into a strong risk program and system of communication. Performing audits and gap analysis provide checks for continuous improvement.
Management review and continuous improvement: Understanding where the potential areas for improvement exist and developing recommendations identifying areas for improvement are the first steps. Using these pieces to map out how the key elements of compliance tie together and building a program that connects the pieces together establishes a foundation for improving upon success.
Potential areas of improvement, or gap analysis, provide opportunities to continually improve an SMS. Continuous improvement means commitment to always being better, working toward the goal of zero incidents.
Emergency preparedness and response: In order to effectively plan in the event of an unforeseen incident, operators build and own various emergency planning, response and training documents. These documents exist in various areas of operations management and provide a tool for training, risk communication, spill management, stakeholder training and long-term planning.
Using the valuable information gained in previous spills, daily management and stakeholder feedback, these programs can be further built on and improved.
Competence, awareness and training: Identifying the key stakeholders responsible for the management and operation of a pipeline and its associated systems is the first step in safe operations. Outlining their qualifications and training needs relative to their roles and responsibilities helps to ensure the right people are in the right roles. Operator qualification, integrity management programs and other key industry program form the base for understanding the who, what, when and why of pipeline and facility operations.
Documentation and record keeping: Effective management of change— learning from the past, continuous improvement and stakeholder engagement—all require a strong system of documentation. Keeping records up to date with processes implemented, lessons learned, historical equipment issues, line information, facility data and other critical pieces of data in the safe management of the system, including all pipelines and associated facilities, is critical. Having a robust data management strategy allows for lessons to be learned both externally and internally.

This puts the power into the hands of the industry to improve on its infrastructure management. Sharing current and past experiences will lead to more robust operational programs and more effective safety management. Knowledge is not useful if not shared with others.
Maintaining an effective management of change process is an essential component of the safety management system. The process should include technical, physical, procedural and organizational elements for temporary and permanent changes to the SMS program.
Adopting RP 1173
Operating a safe pipeline management system brings together all the risks associated with its management: operational, environmental and worker. It builds upon existing operator programs through the use of audits/GAP analysis to establish the baseline, outlining areas for improvement and integrating those “connected” programs. Stakeholder engagement at all levels—internally and externally—allows for a strong system of communication to ensure the who, what, when and why of pipeline operations are shared.
Documentation of all pertinent information, such as incident root cause analysis, procedural adherence, management of change, stakeholder qualifications, etc., is critical to a successful program.
The use of the Plan-Do-Check-Act model, illustrated in the adjoining graphic, as a tool in the planning process will provide the roadmap to success. Through the identification of potential areas of improvement in current key connected programs, the foundation will become stronger. This foundation will serve as the basis for the development and adoption of a successful SMS

Mary Campos is pipeline services director for GE Oil & Gas Digital Solutions.

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