Implementation of RP 1173 API Tools. TGA Transmission Roundtable November 2018 Rick Lide Director Program Development and Audit

Transcription

1 Implementation of RP 1173 API Tools TGA Transmission Roundtable November 2018 Rick Lide Director Program Development and Audit

2 Introduction Pipeline Safety Management System (RP 1173) Implementation is Happening! There are FREE Tools and Guidance Available!

3 RP 1173 Overview Safety Management System Designed for the Pipeline Industry. Blends Well With Other Safety Management Systems: OSHA PSM, EPA RMP. SEMS. NEB SOR/ Responsible Care

4 RP 1173 Overview First Issue July Management System Elements: Leadership Commitment, Stakeholders, Risk Management, Controls, Investigation, Audit/Assessment, Management Review, ER, Training, Documents It is NOT a Regulation. Regulatory Compliance is the Minimum.

5 Why is There an RP 1173? Referenced Events: Kalamazoo, Michigan. San Bruno, California. Yellowstone, Montana. Mayflower, Arkansas. More Recent Events: Shelby County, Alabama Tekameh, Nebraska Lawrence, Massachusetts Midland, Texas Prince George, British Columbia

6 Implementation Steps Decision by Senior Management. Gap Analysis of Existing Safety Management System. Development of Action Plans for the Gaps. Prioritize Gap Closures. Second Decision by Senior Management. Start Closing Gaps.

7 Implementation Steps Initiate the PLAN-DO-CHECK-ACT Cycle.

8 How to Get Free Tools

9 How to Get Free Tools

10 Gap Analysis Looks and Feels Like an Audit. Can Comparing Existing Systems to the 234 Shall Statements. Implementation Tool Pulls 71 Shall Statements. Selected for Continuous Improvement. One Question May Represent Several Shall Questions.

11 Gap Tool

12 Gap Tool Example Evidence Actual Evidence (list the relevant documents / procedures) Gap (Y/N) Description of Gap or Gaps Use additional rows for each Potential Description of Potential Action(s) to Close Gaps. Use additional rows for each Potential Required (R), Priority (H,M,L) Owner List or statement of the PSMS goals. List of measureable objectives for the PSMS. Corporate communications. Corporate HSE Manual. EXAMPLE Annual letter to employees from the organization's president restating the HSE goals of no accidents, injuries or releases to the environment. Sustainability Report contained specific safety initiatives. N A procedure that describes how regulatory and legislative requirements are identified, applicability to the organization is determined, how the requirements are implemented within the organization. EXAMPLE Organization has a person monitoring regulatory activity and uses bulletins from AOPL, API and XXX Consultants for legislative activities. Y No documented process or procedure. No process for translating requirements into internal procedures and instructions No process for monitoring compliance to applicable regulatory requirements. Prepare a procedure that documents the process of monitoring regulatory and legislative activity for environmental, personal safety, occupational health, security, pipeline, transportation and other applicable regulatory issues. Prepare a procedure to convert applicable legislative and regulatory requirements into procedures and instructions. The procedure will include: 1. Process to determine applicability to the organization. 2. Process to determine regulatory requirements. 3. Process to identify regulatory tasks. 4. Process to communicate and assign regulatory tasks. 5. Process to prepare instructions or procedures for completing the tasks. Prepare a procedure for monitoring compliance to regulatory requirements including: 1. Documentation of completion of regulatory requirements. 2. Review of completion documentation. 3. Process for addressing identified regulatory noncompliance. R R O

13 Implementation Tool Gap Tool Measures: Number of Open and Closed Gaps. Number of Open and Closed Actions. Does Not Tell You If the PSMS is Working. Measures Implementation Status. 0 to 4 Scale. 0 Learning (Have not Started). 1 Planning (Started but Identifying the Gaps). 2 Developing (Started and Closing the Gaps). 3 Implemented (Gaps are Closed). 4 Sustaining (Program is Working).

14 Implementation Tool API RP 1173 Requirement Level 0 Level 1 (Learning) (Planning) Has top management established and documented the goals and objectives for the PSMS? Level 2 (Developing) Level 3 (Implemented) Top management has identified and documented its goals and objectives for the PSMS. Level 4 (Sustaining) The PSMS objectives are measureable and consistent with overall safety policies and objectives. There is evidence that top management is measuring the performance of the organization against the PSMS goals and objectives. Interviews with employees demonstrate that the PSMS goals and objectives are known/understood or the employees know how to find them. Level Assignment (0-4) 3 Has management documented a process for addressing regulatory and legislative requirements for pipeline safety and their impact on the PSMS? A process for addressing regulatory and legislative requirements has been established and documented. The process includes instructions on how to identify existing and new requirements, their impact on the PSMS, as well as how to assess compliance to the new requirements and to address compliance issues. There is evidence that the impact of the regulatory and legislative requirements and their impact on the PSMS are identified, evaluated, documented, and incorporated into the PSMS. Interviews with a cross section of the organization demonstrate applicable regulatory and legislative requirements are understood by those who are impacted by such requirements. 0

15 Status in a Glance: Bar Chart. Pie Chart. Stacked Bar. Implementation Tool

16 Evaluation Tool The Most Complicated Tool. Use the Same 0 to 4 Scoring System. Area to Document Comments on Status. Links the 71 Continuous Improvement Questions to the 234 Shall Questions. Get a 0 to 4 Score for each PSMS Element.

17 Evaluation Tool

18 Evaluation Tool

19 Evaluation Tool

20 Summary PSMS is Going to Stay. Having a PSMS in Place and Working Will Improve Performance (ask the Chemical Industry, the Insurers, the Passenger Airlines, the Nuclear Industry). Take Advantage of the Free Tools.