Illustration by Douglas B. Jones
The unshakeable values of safety and reliability have always been at the core of the natural gas industry. But in recent years, even as pipeline incidents decline, the systematic management of safety has taken on a new look and sophistication. Through pipeline safety management systems, gas utilities now have a flexible framework for pointing all their elements in the same direction, toward the infusion of safety into every corner of operations.
In this atmosphere, the phrase “pipeline safety” becomes “process safety” in some conversations. PSMS, as it’s known, is an “end-to-end viewpoint” that works to instill a safety mindset in every office and every employee, with “plan, do, check, act” procedures at each step, said Timothy Woycik, director of Process Safety at National Grid.
“We’ve been a gas company for 100 years, and the ‘plan’ and ‘do,’ we do really well,” he said. “The ‘check’ and ‘act’ is the continuous improvement part, and incorporating lessons learned into the next planning cycle is where that comes in. Did you do what you said you were going to do? How well did it perform? What are the lessons learned? The industry as a whole is in the same boat.”
It’s still early in the game, but today’s gas utilities are using 2015’s American Petroleum Institute Recommended Practices 1173 as a road map toward PSMS. In a regulated environment, the goal is “moving the needle” in the direction of continued safety improvements and performance that go above and beyond current requirements, said John L. Curtis, manager of Pipeline Safety Management at NiSource.
“The key for this to work is leadership’s commitment and support, which we have,” he said. “Without this sponsorship and support, it would be difficult to design and implement this program.”
Since API developed and released RP 1173, the American Gas Association has been conducting workshops and convening a pilot group of volunteer companies implementing the recommended practices.
AGA’s primary message is this: Systems don’t have to be built from scratch.
Gas companies “already have many of the pieces in place,” such as operator qualification programs, emergency management preparedness, incident response and investigation, and integrity management, said AGA Engineering Services Director Kate Miller. The 10 key elements of API RP 1173 create a framework that helps gas companies “raise the bar on safety” by blending those elements into one system, she said.
Companies can implement API RP 1173 “based on the approach that works for them,” said Megan T. Cyr, analyst for Compliance and Risk Management with Eversource Gas. “It’s scalable. It’s flexible. We can apply it to the company based on our needs, but still in a manner that complies with the recommended practices.”
Southwest Gas, one of two AGA-member utilities on the API RP 1173 development team, has a long-standing, proactive safety culture. API RP 1173 offers a comprehensive framework to “compare our existing policies, procedures and programs to find opportunities for enhancements,” said Doug Gapp, manager of Engineering Staff/Pipeline Safety Planning for Southwest Gas.
“Our first step was to formally establish an internal leadership commitment and vision to implement API RP 1173 at Southwest Gas,” he said. “With the full support of senior management, we began the work of a comparison analysis of Southwest Gas’ existing processes, programs and procedures to the recommended practice.”
As Woycik noted, however, installing recommended practices doesn’t provide the luxury of simply “putting a check mark beside them and saying, ‘Job done.’ ” Pipeline safety management forces continuous improvement through a “formal and disciplined approach.”
“It’s an evolution,” he said. “We have these programs in place. They’re functioning, but are they functioning as well as we want them to be? Let’s put them in the safety management system and use that approach to measure whether they’re meeting our needs.”
Gas companies “run the gamut” in their initial approaches, said Miller. All agree that commitment from company leadership is vital to success. NiSource, Eversource, Southwest Gas and National Grid—all members of the AGA pilot group—custom-crafted the launch of their PSMS:
NiSource is preparing to implement a PSMS in Virginia and will leverage that experience and apply lessons learned as it implements plans to roll out the PSMS to its six other state companies. The plan for Virginia is to address all gaps by the end of 2017, with program implementation during 2018.
“This effort is for the long term,” said Curtis. “It is going to be a journey. This is going to have a positive impact on how we operate as a business, how we reveal and manage risk, how we learn as an organization, and how we focus on continuous improvement to heighten pipeline safety and maximize system integrity.”
To date, Southwest Gas has identified 33 processes, programs and procedures for evaluation against API RP 1173.
“We are further drilling down into identified programs such as our pipeline integrity management programs, public awareness, damage prevention and certain code compliance functions to better align with the recommended practice,” Gapp said.
With National Grid, opportunities for improvement identified in the United Kingdom can be transmitted to the United States and vice versa, said Woycik. The same applies domestically and, as an added bonus, “makes any kind of interaction with any gas delivery company very, very simple and straightforward.”
“It’s beyond compliance,” he said. “We’re not talking about complying with a specific regional or national or international regulatory requirement. The management system approach in general is going to deliver whatever you desire and require. You can build a component or requirement into the management system in order to deliver compliance with whatever regulatory requirement you’re trying to achieve.”
The experts agree: PSMSs demand companywide buy-in and an organizational commitment to development, implementation and sustaining.
Through management of change, everyone comes to understand the concept and purpose of “plan, do, check, act,” the meaning of gaps and the value of filling them, and the roles all employees can play to support pipeline safety, said Curtis.
“If you just give someone the assignment to close a gap, that won’t get us to where we need to go,” he said. “NiSource tailored its change-management strategies to local needs to engage employees’ hearts and minds. As a result, many employees became our champions because they understood the benefits and value [PSMS] brings, and that it supported many of their own ideas for improvement.”
Eversource’s Cyr agreed that employees and contractors “know the areas for improvement. They’ve just never fully been given the opportunity or the resources to implement them, so this is our chance together to help strengthen these areas. Part of change management is empowering people to do what they’ve always wanted to do.”
Laying out the end-to-end process and the potential impact every task has on safe, reliable gas delivery illuminates “one of the biggest lightbulbs over people’s heads,” said Woycik.
“It’s about making people understand that decisions made in finance, decisions made in procurement, decisions made in the customer organization are really part of our process safety management, and they deliver pipeline safety outcomes,” he said. “That’s the importance of making sure we never lose connection with the idea of process safety, even though the outcome is pipeline safety.”
With seven legacy companies operating under the National Grid flag, Woycik preaches “patience and ‘planfulness.’ We talk about avoiding trying to drink out of a firehose. You have to break it down into bite-sized pieces and slowly evolve the different programs into a management system approach. Eventually, it becomes easier and easier, and it becomes more sophisticated.”
Southwest Gas recently elevated existing employee communications regarding safety with its “Walk the Talk” campaign. The initiative features email and video messages spotlighting relevant safety news and information “to further our company’s safety culture at every level,” said Gapp. “We have begun to raise awareness about pipeline safety management through meetings across our operating divisions, as well as related video segments, and will continue to educate employees as we develop a formalized communication process.”
Safety management systems yield measurable benefits—not only safer pipelines, but also reduced costs, improved morale, improved relations with regulatory organizations, competitive advantages and much more (find the full list at API/Association of Oil Pipe Lines’ Why a Pipeline SMS Will Benefit Pipeline Safety, www.pipelinesms.org/index.php/documents-tools).
As Curtis put it, mature safety management evolves into “a continuum” over time.
“When it’s working, you will minimize emergent and significant events,” he said. “Unanticipated events will happen at a lesser and less significant rate. The SMS is designed to learn from these events and prevent reoccurrence. You’re ineffective and inefficient when you’re spending a lot of time correcting problems, running from one thing to another thing. A mature safety management system will help you to spend more time systematically preventing and detecting issues before they become a problem—and that is a much safer and [more] predictable place for all of us to be.”
As National Grid undertakes a multimillion-dollar gas business enablement project, the act of changing processes, delivery and customer interaction “has process safety embedded in it,” said Woycik. “There’s a recognition that the reason we’re doing this is to provide safe and reliable gas service to the customer.”
A smoothly operating PSMS allows “reverse engineering” toward regulatory compliance, he added.
“There are so many different benefits to having that management system approach in place, because you can tailor those elements or those risk control standards to deliver the outcome you need,” Woycik said. “It’s a formal and disciplined and readily established approach that’s already there. You just need to flip a few switches to get what you need.”
In this new world of pipeline safety management, today’s continuous improvement replaces yesterday’s status reports.
“You can do a gap assessment in the beginning of the year, but as you go through ‘plan, do, check, act,’ you realize that some of these processes have changed since the initial gap assessment,” said Cyr. “The one thing that’s guaranteed at a utility company is that we are always changing.”
On the list of key drivers, minimizing liability sits below regulatory compliance and the need “to continuously measure and manage risks associated with design, construction, inspection and maintenance of gas pipelines,” said Woycik. “Without this formal, intentional system in place, we can’t get to that point where we’re constantly testing our risks, constantly managing those risks and constantly measuring whether those controls—the management system—are addressing the risk appropriately.”
Southwest Gas’ efforts discovered that continuous improvement “is embedded in some areas of the company more than in others.”
“Our initial comparison analysis of our safety practices was only round one,” said Gapp. “We anticipate conducting periodic reviews of the same programs, and likely others, as they are incorporated. We also plan to use an independent external audit of the pipeline safety management system implementation in the future to obtain feedback.”
In the end, officials agree, pipeline safety management comes down to the needs of customers, and the benefits accrue to gas companies.
“Isn’t pipeline safety the best service we can provide our customers?” said Cyr. “It’s the best assurance, too. Providing that type of service only helps the growth of the natural gas industry.”
