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Pipeline Safety Management Benchmark Study, Adoption of API RP 1173

In July 2015, the American Petroleum Institute (API) published Recommended Practice (RP) 1173 to address an industry need for Pipeline Safety Management Systems (PSMS). This standard was an acknowledgment by pipeline transmission and distribution stakeholders that compliance with prescriptive regulations alone was not enough to protect public safety. The PSMS standard, API RP 1173 (1173), marked an effort to develop a more risk-centric and continuous, learning-based, performance model to elevate public safety as an organizational value. It leverages proven methodologies from years of learning in quality and safety programs and applies these learnings to address the uniqueness of the pipeline transportation industry and the interrelationship pipelines and distribution networks have with the communities they serve. Some of the basic elements of 1173 address:

  • Managing the safety of complex pipeline operation processes.
  • Coordinating actions to address multiple, dynamic activities and circumstances.
  • Achieving continuous assessment and improvement of the management system and individual elements.
  • Implementing or improving PSMS in a flexible, scalable way that accounts for the size and current state of operators.

As of November 2018, adopting a PSMS program remains voluntary for those regulated at a federal level in the U.S. The Pipeline and Hazardous Materials Safety Administration has always maintained that they prefer this approach, but caution that Congress may act if safety incidents continue to occur, especially ones that impact public safety and security. However, leaders in several state regulatory agencies have stated they are not optimistic a voluntary response will yield the results needed. There are already several cases of PSMS adoption being required through enforcement actions and corrective action orders to individual operators.

Following the natural gas incidents in the Boston area in September 2018 that received national attention, the governor of Massachusetts issued a press release announcing that all operators in the state would be adopting 1173 as a “first in the nation” program. The Massachusetts Department of Public Utilities “requested” all operators in the state conform to 1173’s requirements, and the Northeast Gas Association affirmed its membership would comply.

Since 1173 was published three years ago, it has become a touchstone for the regulatory community. Every state commission in the nation is well-versed in its contents, and many are beginning to act to ensure its adoption through enforcement. The legislation will not be far behind. At a federal level, the warning has already been issued; Congress will most likely act if there are other significant events related to the industry.

Charting implementation progress

A benchmark study by Mosaic was conducted to evaluate the degrees of implementation. To date, operators have stepped into this voluntary standard in many ways, at varied paces, and with different stories to tell of their successes and ongoing challenges. This benchmark study did not identify “best practices,” as no one solution applies to all organizations. Every company has a unique blend of assets, cultures, organizational structures, experience levels, and other differentiating variables. Instead, the study focused on:

  1. How companies are approaching the 10 elements of 1173; The factors that influence the scale of an organization’s response to 1173.
  2. Where the industry is at maturity-wise relative to the standards outlined in 1173.
  3. Common challenges organizations are facing with either the implementation or continuous improvement of their PSMS.

Study overview

Sixteen operators participated in the benchmark study, including eight combined utilities (four with transmission), three gas utilities, three midstream gas pipeline operators and two liquid products pipeline operators. Of the companies that participated, only one rated themselves at the Improving level of maturity — API’s highest rating. Over half are still in the Planning and Developing phases. Interestingly, companies that have been doing PSMS the longest reported that at one point in their journey, they were further along than they are now because they are revisiting many of the elements.

One-quarter of the companies that participated in the benchmark are integrating PSMS as a program under existing, integrated management systems. All these companies are on the higher end of the maturity level and have been practicing management system methodologies for several years. Two-thirds of the participants are implementing PSMS independently whether they utilize management systems elsewhere in their organization or not. Two companies are still undecided about how PSMS will fit in the context of other organizational systems. All companies using more than one management system, integrated or not, use a matrix that tracks alignment between the programs and elements of 1173.

Most benchmarked companies have a single group or individual responsible for the strategic oversight of PSMS with the decentralized implementation of individual elements distributed across operating companies, business units or shared services functions. Almost half of the operators interviewed have ultimate ownership of PSMS residing in operations, with the other half almost equally split between engineering and shared services organizations.

Key findings

  1. The most common approach to PSMS and 1173 is programmatic. Most companies integrate all 10 elements under one framework, set process standards at the organizational level to ensure continuity, and assign individual departments to execute program elements and activities. Separating strategy from implementation appears to be the most effective and efficient way to spread the ownership of PSMS from the top to the bottom of the organization, and drive execution of the program as it evolves.
  2. Companies use numerous approaches to implement PSMS elements. Some companies are taking an element-by-element approach, selecting the most critical elements, and working on those. Others are working on all 10 simultaneously, but acknowledge that some require more effort and not all are at the same level of maturity. For operators with 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 its 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 dedicating resources. The first begins with a gap assessment. The second is when allocating for program development, especially when the effort requires more than adapting existing practices. The third occurs 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 rank leadership and management commitment as essential to program success. Operators who have been exercising management systems the longest identify strong leadership and management commitment for accelerating and sustaining the success of the program. Examples of success include adopting a common language around risk management 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. Companies 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 for PSMS reported having significant issues determining the appropriate scope.
  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.

Call to action

As an industry, we are almost four years into the PSMS journey, but the results of this benchmark study indicate that we still have a long way to go:

  • 30% of operators are still in the very beginning stage of maturity.
  • Some operators are doing nothing.
  • 40% of operators have allocated only one full-time resource to PSMS.
  • 63% of operators report limited leadership support of PSMS.

Management systems are a proven methodology that have been used to improve safety and quality outcomes for years. We only have to look as far as the airline industry to see what a positive impact it has had on the transportation industry. It’s been over three years since the publishing of PSMS guidance.

As the operators of pipelines, distribution systems, and related facilities, we must look in the mirror and answer some tough questions:

  • Have we done enough?
  • Are we where we want to be?
  • Are we safer and more confident that we are preventing incidents in our systems?
  • What is keeping us from doing more?
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