In July of 2015, the American Petroleum Institute (API) published Recommended Practice (RP) 1173 to address an industry need for Pipeline Safety Management Systems (PSMS). The motivation for the standard was an acknowledgment by pipeline transmission and distribution stakeholders that compliance with prescriptive regulations alone was not enough to satisfy their duty to protect public safety. As an industry collective, representatives came together to develop a more risk-centric and continuous learning-based model to elevate public safety to an organizational value, in the same way asset integrity and employee safety had been elevated in the past. The PSMS standard leverages proven methodologies from years of learning in quality and safety programs and applies these learnings in an elemental approach designed to address the uniqueness of the pipeline transportation industry and the inter-relationship pipelines and distribution networks have with the communities they serve.
The publishing of RP 1173 marked the completion of two years of regulator, operator, and stakeholder collaboration, including committee meetings, PHMSA workshops, revisions, balloting, and National Transportation Safety Board (NTSB) review. Since its publication in 2015, operators have stepped into their response to this voluntary standard in many ways, at varied paces, and with different stories to tell of their successes and ongoing challenges. This benchmark report does not attempt to identify “best practices” as there is no one solution that applies across the board to all organizations. Every company has a unique blend of assets, cultures, organizational structures, experience levels, and other variables that must be harmonized to define what is best for them.
The 2018 PSMS API RP 1173 Benchmark was commissioned by Mosaic—a national consulting firm that focuses on the utility and oil & gas industries—to provide insight into how companies are building and executing their Pipeline Safety Management Systems. 16 participating companies representing gas or combined utilities and pipeline operators consistently reported the following key findings related to their organizations’ responses to 1173:
1. The most common approach to PSMS and RP 1173 is programmatic, where all 10 elements are integrated under one framework, process standards are set at the organizational level to ensure continuity, and individual departments are tasked with executing program elements and activities at the operations level. This separation of strategy from execution appears to be the most effective and efficient way to ensure ownership of PSMS from the top to the bottom of the organization and drive the maturity and execution of the program as it continues to evolve.
2. There are numerous approaches being used related to the implementation of PSMS elements. Some companies are taking an element-by-element approach, selecting the most important elements and working on them a few at a time. Others are working on all elements simultaneously, acknowledging that some require more effort and not all are at them same level of maturity. For operators that have existing management systems that have been through several iterative cycles of development, implementing PSMS is viewed as an enhancement of what already exists. One company piloted a full implementation of their
PSMS at one operating company and is taking lessons learned from that approach to bring PSMS to others.
3. Money and resource allocation is a challenge for most companies. There are three distinct hurdle points operators face when deciding who and how much. The first is in the beginning, typically with a gap assessment. The second is when allocating for “to-be” program development, especially when the effort requires more than adapting existing practices. The third is when deciding on sustainment structures. All three require decisions on temporary (project) or permanent (programmatic) solutions, and the allocation of people, monies, and other resources to PSMS programs. Stalling often occurs if these allocations are not predetermined through program standards and agreed upon throughout the organization.
4. The most mature programs all rank Leadership and Management Commitment as the most important component of program success. For operators that have been exercising management systems the longest, all identified strong leadership and management commitment as an accelerator in the early stages, and as the cornerstone for sustaining the more mature parts of their programs. Examples of success include adopting a common language and practicing risk-based communication at all levels of leadership and management. For less mature programs, translating and operationalizing senior leadership’s commitment through the middle levels of management was often cited as a significant barrier to advancing maturity.
5. Management of Change (MoC) at the process level is less defined and less consistently executed than at the asset level, even among the more mature programs. Companies that are having the most success with MoC have started in areas that are less complex (e.g., standard operating procedures) where they can find success relatively quickly versus building an overarching corporate process and cascading it down. Organizations trying to leverage OSHA Process Safety Management MoC reported having significant issues determining the appropriate scope (where to draw the line) for application to PSMS.
6. No benchmark participant has deployed a comprehensive technology solution to manage and track PSMS activities and results. Companies use different tools for integrity management, risk modeling, and documentation, but there is no one technology being used to integrate management systems across the organization. Most participants reported an over-reliance on spreadsheets, distributed documentation practices, and manual processes to manage and track data.