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:
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.
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:
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.
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:
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: