Incident Reporting Towards Data Driven Regulations

Transcription

1 Incident Reporting Towards Data Driven Regulations Risk, Data, and Program Management Overview & SMART form Demonstration Presented at the Dangerous Goods Symposium 1

2 Agenda Overview of Risk, Data, and Program Management PHMSA 2021 PHMSA s Mission & our Role Business Lines SMART Form Incident Reporting Overview SMART form purpose and goals Project Overview Interactive Demonstration Coming Attractions Quality Management Systems (ISO 9001) SMART form Enhancements 2

3 PHMSA 2021 VISION MISSION PHMSA: THE MOST INNOVATIVE TRANSPORTATION SAFETY ORGANIZATION IN THE WORLD PROTECT PEOPLE AND THE ENVIRONMENT BY ADVANCING THE SAFE TRANSPORTATION OF ENERGY AND OTHER HAZARDOUS MATERIALS THAT ARE ESSENTIAL TO OUR DAILY LIVES GOALS Promote continuous improvement in safety performance Invest in safety innovations and partnerships Cultivate organizational excellence and safety culture Build greater public and stakeholder trust Pursue excellence in our operations VALUES TRUST HONESTY RESPECT INTEGRITY VALUING PEOPLE EFFECTIVE COMMUNICATION 3

4 Mission Support The Risk, Data, and Program Management Branch supports PHMSA's mission and Vision by: Identifying information data sources and providing analysis that informs PHMSA decision making. Ensuring that PHMSA programs are having the intended outcomes and delivering a quality product. Contributing to the development of a strategic direction and the implementation of a data-driven safety agenda. 4

5 Structure Deputy Associate Administrator of Policy & Programs Standards & Rulemaking Engineering and Research Approvals & Permits Field Operations Within the Risk, Data, and Program Management Branch we address four primary business lines. These business lines support the various offices within PHMSA. The Risk, Data, and Program Management branch is unique because our stakeholders are both internal and external. Grants, Training and outreach Program Development Budget and Administrative Services Risk, Data, and Program Management Regulatory Support Risk Analysis Program Management Data Operations 5

6 The Team New Staff New Capabilities In the past year the Program Development Division and the Risk, Data and Program Management branch within it have increased our staffing and thus the capabilities and expertise we offer. In particular we have added permanent leadership in the form of a new director and branch chief. In addition our current roster of staff includes: Two Senior economists, Two data analysts A program analyst, and, A statistician. 6

7 Risk Analysis When considering risk (safety or programmatic) OHMS must focus on the elements of risk. It is also important to seek out the data that supports and informs each element. In its most basic form risk is composed of the following elements: Exposure The level of interaction with potential hazard. Safety exposure examples include ton-miles traveled or proximity to railways transporting hazardous materials. Programmatic exposure could include the size of a regulatory portfolio or number of facilities to inspect. Vulnerability - The characteristics and circumstances of a community, system or asset that make it susceptible to the damaging effects of a hazard. Safety vulnerabilities could include a packaging that is not adequately designed and programmatic vulnerabilities could include lack of resources or poorly defined processes and procedures. Consequences The extent of the impact of a given event should one occur. This is often defined through predictive modeling based on existing data (I.e. the U.S. safety record). ff xx = EEEEEEEEEEEEEEEE xx VVVVVVVVVVVVVVVVVVVVVVVV xx CCCCCCCCCCCCCCCCCCCCCC 7

8 Regulatory Support Risk, Data, and Program Management provides regulatory support in many forms including: Policy analysis (Pre-Rulemaking) Economic Analysis Environment Impact Analysis White Papers Research Projects GIS support Statistical Analysis OHMS follows OMB guidelines (Circular A-4 and NEPA requirements) in the development of our analysis 8

9 Program Management The Risk, Data, and Program Management branch provides integrated planning, development, and evaluation of programmatic activities for OHMS. This branch has assisted program offices develop meaningful Key Performance indicators (KPIs) to measure performance and foster continuous improvement. OHMS reviews these KPIs at Management Meetings and the Annual Death and Injury Briefing. Measurable Resources Targets Strategic 9

10 Data Operations Office of Hazardous Materials Safety Standards & Rulemaking Regulatory Support Data Operations Engineering & Research Approvals & Permits Field Operations Program Management Risk Analysis Outreach, Training, & Grants Program Development 10

11 Data Operations 10,000 8,000 6,000 4,000 2, Paper Reports 6,949 6,027 5,650 6,499 6,796 5,055 Online Reports 4,861 4,679 4,833 8,649 6,471 4,515 XML Reports 3,829 5,053 3,752 5,365 4,844 3,247 Number of Incidents DOT 's Completed By Source OHMS Process on average about 18,000 incident reports per year. Each of these reports goes through a rigorous quality control process. The Data operations team actively seeks other sources of data PHMSA can use to support our safety mission (Commodity Flow, production data, etc.) 11

12 Agenda Overview of Risk, Data, and Program Management PHMSA 2021 PHMSA s Mission & our Role Business Lines SMART Form Incident Reporting Overview SMART form purpose and goals Project Overview Interactive Demonstration Coming Attractions Quality Management Systems (ISO 9001) SMART form Enhancements 12

13 Incident Report Overview Incidents Think before you ship! 13

14 What is an Incident? An unintentional release of a hazardous material or discharge of hazardous waste; a cargo tank with a capacity of 1,000 gallons or greater containing any hazardous material that suffers structural damage to the lading retention system; or an undeclared hazardous material. 14

15 Incidents incidents. Immediate Incident Reporting The 49 CFR Section requires an immediate telephonic report be filed within 12 hours of certain hazmat A person is killed Injury requiring admittance to the hospital Evacuation of general public for one hour or more One or more major transportation arteries are closed for one hour or more Operational flight plan is altered Fire, breakage, spillage involving radioactive material Fire, breakage, spillage involving an infectious substance Release of marine pollutant in a quantity exceeding 450 liters for liquid or 400 kilograms for solids 15

16 Incident Reporting The 49 CFR Section requires that a report be submitted within 30 days of discovery of any of the following: Incidents An incident that was reported under An unintentional release of a hazardous material during transportation Release of a hazardous waste Undeclared shipment with no release is discovered A Specification Cargo Tank 1,000 gallons or greater containing hazardous materials that received structural damage to the lading retention system and did not have a release 16

17 Incidents Incident Reporting Exceptions You are not required to report a release of hazardous material if ALL of the following apply: The shipment is not being offered for transportation or being transported by air; None of the Criteria in (a) applies; The material is not a hazardous waste; The material is properly classed as an ORM-D, or a Packing Group III material in Class or Division 3,4,5,6.1, 8 or 9; Each package has a capacity of less than 20 liters (5.2 gallons) for liquids or less than 30 kg (66 pounds) for solids; The total aggregate release is less than 20 liters (5.2 gallons) for liquids or less than 30 kg (66 pounds) for solids; The material does not meet the definition of an undeclared hazardous material in 171.8; and The shipment is an undeclared material discovered in an air passenger s checked or carry-on baggage during the airport screening process. *Additional exemptions can be found in CFR D 17

18 Incidents How is a DOT Form filed? Paper forms can be submitted via postal mail or using a fillable Adobe Acrobat file Electronic submissions can be submitted via PHMSA S Website utilizing the online fillable form or authorized entities using extensible mark-up language (XML) files, which is a set of rules for encoding documents in machine-readable form 18

19 What Data Do We Collect Via the ? Who, What, Where, and When Characteristics of the release: Material Packaging Hazard Communication Handling Consequences Causation Compliance and non-compliance 19

20 Who must complete the Form? If a hazmat incident occurs, any entity in possession of the hazmat during transportation including loading, unloading and storage incidental to transportation must report the incident if certain conditions are met. The Entity having physical control of the shipment is responsible for completion and submission of DOT Form Carrier Shipper Facility Other 20

21 Form Did You Know? Recordkeeping You must Keep a copy or Electronic Image for Two years after the date you submit to PHMSA. Must be accessible through your company s principal place of business Must be made available upon request within 24 hours Form Updates A death results from injuries cause by a hazardous material Damages or related costs that were not known at the time the report was filed become known Misidentification of hazardous material or packaging information Revised estimates of damages, losses, and related costs result in a change of $25,000 or more or 10% of original cost estimates. 21

22 Incident Reporting Processing Not so Simple 22

23 Incident Reporting Processing Hazmat Accident National Response Center Reported Incident Un-reported Incident Scanning (I only) Data Entry (Select I reports) QC1/KOFAX (I only) QC2 (I, E, X) Completion Phase Report is scanned, validated, and uploaded to FYI or KOFAX. Data is entered into HMIS. Additional validation of data is performed, including characterto-character. Thorough validation is conducted. Includes analysis of data accuracy, anomalies, business rules, and consequences.* Incident report is made accessible in HIP and available to the public. KEY I = Paper Submission E = Online Submission X = XML Submission *Note: For incidents involving D&Is, CTMV rollovers, and public evacuations, additional validation is performed. 23

24 SMART form - BLUF Project Goal: Implement a new Reporting System with modernized capabilities that provide further automation and improved efficiencies and user experience for stakeholders Current System - Abandoned / incomplete reports - Linear data processing leads to bottlenecks - Business rules limited, leading to conflicting data points - Multiple reports for a single incident - User Guidance is separate document SMART form - Reduce the number of incomplete reports - Eliminate the need for multiple reports for a single incident - Business Rule Validations - Not just a face lift - It is an internal and external revamp - Improved Process Flow - Built-in Guidance (Tooltips) 24

25 Project Approach Agile Approach to Development 10 Week Discovery Phase Multiple requirements validation working sessions Concept discussions Gap Analysis Baseline Requirements List High Level Design Project Implementation Plan 3 Week Sprints Planned 15 Iterations (cycles) of 3 weeks each Identify priorities, build plan, implement and test Demo to elicit approval, recommendations and changes Release FY 17 Plan Implement Test Demo 25

26 Stakeholders Impacted SMART form Project benefits both internal and external stakeholders. Internally it provides improved process flow and automation. Externally it provides a better user experience. All stakeholders benefit from improved data quality. 26

27 SMART Demonstration Focuses on the external interface our public stakeholder will use to input incident reports. Accessed through the PHMSA portal This only tells half the story as this project also upgrades the internal interface. 27

28 SMART Demonstration Linear data processing that can lead to bottlenecks Improved Process Flow X X X 28

29 SMART Demonstration Current Form User Guidance User Guidance is a separate document 29

30 SMART Demonstration SMART Form User Guidance / Tool Tips Built-in Guidance Tool tip Help Instruction Booklet 30

31 SMART Demonstration SMART Form Business Rule Validation 31

32 SMART Demonstration SMART Form Business Rule Validation 32

33 SMART Demonstration SMART Form Multiples / Incident Shopping Cart Shipper Commodity Package 33

34 SMART Demonstration SMART Form Attachments / Supplemental material Add Attachments 34

35 Soft Validation 35

36 Hard Error Message 36

37 SMART Demonstration SMART Form Addition Enhancements Additional External enhancements System generated notification (7, 14, 21 days) to limit abandon reports. System generated notification (11 months after date of incident) to remind submitter of requirement to update Behind the Curtain enhancements Even more business rules built in Improve matching of potential reportable incidents and NRC incidents with forms Process flow tracking Improve automation of some tasks 37

38 SMART Form In Summary Aligns with agency strategic goals Reduce Government resources by decreasing processing time Enforces data correctness and data completeness, while allowing users to provide as much information as possible Is simple, comprehensive, intuitive, modern, flexible Enhances the Internal and External user experience by simplifying the process and improving efficiencies Provides role based security and access through the PHMSA portal Integrates with other PHMSA portal based systems (Special Permits, Case Management, HIP and so on) 38

39 What s Next SMART Form (Continued Enhancements) Incorporation of Customer Feedback and User Testing Increased back-end automation Other enhancements to be determined. International Standard Organization (ISO) 9001 Certification Data Operations is establishing an ISO 9001 compliant Quality Management System that will include a quality manual, standard operating procedures and business processes, process maps and responsibility matrices. Based on a strong customer focus, top management engagement, the process approach, and continual improvement through audits for nonconformities. OHMS expects this effort to improve processing times and efficiencies, resource use, stakeholder satisfaction, and data quality and consistency. Data Visualization and Analysis Efforts include a website enhancements to provide a more interactive experience for stakeholders, and targeted analysis on hazardous materials topics of interest. 39

40 Questions 40