Pipeline Safety: Guidance for Strengthening Pipeline Safety Through Rigorous Program Evaluation and Meaningful Metrics
Oct 15,
2014
Docket
Number PHMSA-2014-0086
Notice: Issuance of Advisory Bulletin
Summary: PHMSA published Advisory Bulletin ADB-2012-10 in the Federal
Register on December 5, 2012, to remind operators of gas transmission and
hazardous liquid pipeline facilities of their responsibilities under current
regulations to perform evaluations of their Integrity Management (IM) programs
using meaningful performance metrics. PHMSA is issuing this Advisory Bulletin
to expand that reminder by informing owners and operators of gas and hazardous
liquid pipelines that PHMSA has developed guidance on the elements and
characteristics of a mature program evaluation process that uses meaningful
metrics.
Billing Code: 4910-60-W
DEPARTMENT OF TRANSPORTATION
Pipeline and Hazardous Materials Safety Administration
[Docket No. PHMSA–2014–0086]
Pipeline Safety: Guidance for Strengthening Pipeline Safety
Through Rigorous Program Evaluation and Meaningful Metrics
AGENCY: Pipeline and Hazardous Materials Safety Administration (PHMSA);
DOT.
ACTION: Notice; Issuance of Advisory Bulletin.
SUMMARY: PHMSA published Advisory Bulletin
ADB-2012-10 in the Federal Register on
December 5, 2012, to remind operators of gas transmission and
hazardous liquid pipeline
facilities of their responsibilities under current regulations to
perform evaluations of their
Integrity Management (IM) programs using meaningful performance
metrics. PHMSA is issuing
this Advisory Bulletin to expand that reminder by informing owners
and operators of gas and
hazardous liquid pipelines that PHMSA has developed guidance on
the elements and
characteristics of a mature program evaluation process that uses
meaningful metrics.
FOR FURTHER INFORMATION CONTACT: Chris
McLaren by phone at 281-216-4455
or by email at chris.mclaren@dot.gov.
All materials in this docket may be accessed electronically at
http://www.regulations.gov. Information about PHMSA may be found at
http://www.phmsa.dot.gov.
SUPPLEMENTARY INFORMATION:
I. Background
PHMSA has long recognized and communicated the critical importance
of operator selfevaluation
as part of an effective safety program. PHMSA has promoted and
required the
development and implementation of processes to perform program
evaluations, including the
regular monitoring and reporting of meaningful metrics to assess
operator performance.
PHMSA further communicated this expectation in Advisory Bulletin
ADB-2012-10, which was
published in the Federal Register on December 5, 2012. That
Advisory Bulletin explicitly
reminded operators of gas transmission and hazardous liquid
pipeline facilities of their
responsibilities under current regulations to perform evaluations
of their IM programs using
meaningful performance metrics.
PHMSA has also recognized and emphasized the importance of
operator senior management
responsibilities to fully understand and acknowledge the
implications of these program
evaluations and to take the necessary steps to address
deficiencies and make necessary program
improvements. As these responsibilities are so important, PHMSA
requires senior executives of
operators to certify the IM program performance information they
annually submit to PHMSA.
As required by the IM rules, operators must have a process to
measure the effectiveness of their
programs; a process that determines whether the program is
effective in assessing and evaluating
pipeline integrity and in improving the integrity of pipeline
systems. Program evaluations can
help organizations make better management decisions and support
continual process
improvement. These evaluations should include an assessment
gauging how an operator’s
performance satisfies its identified safety performance goals.
Program and other evaluations may be conducted at different
levels, including the company or
corporate level, at a system level to gauge one pipeline system's
performance against that of
other systems within the organization or for selected assets with
similar characteristics. Effective
program evaluations should include all aspects of an operator’s
organization, not just the
integrity group.
Incident/accident investigations and abnormal operations and root
cause analysis frequently
reveal that management systems and organizational program
deficiencies or failures are
important contributors to pipeline accidents. For this reason, it
is important that program
evaluations also identify potential organizational or programmatic
deficiencies and failures that
could have the potential to lead to pipeline incidents/accidents.
Operators should take effective corrective measures addressing IM
program evaluation outcomes
to improve programmatic activity as well as pipeline system
performance and integrity. IM
program evaluation processes should be formally controlled by
operators and be an integral part of the operator's quality control and quality
assurance program. The formal process should
include management's commitment to monitor and evaluate
performance metrics.
Specific sections in the Federal IM regulations that directly
require the need for operator
program evaluation and the use of meaningful performance metrics
include the following:
• For hazardous liquid pipelines, §§ 195.452(f)(7) and 195.452(k)
require methods to
measure program effectiveness. Appendix C to 49 CFR 195 provides
specific guidance
on establishing performance measures, including the need to select
measures based on the
understanding and analysis of integrity threats to each pipeline
segment. API Standard
1160, “Managing Integrity for Hazardous Liquid Pipelines,” also
provides additional
guidance on the program evaluation process and the use of
performance measures in
improving performance.
• For gas transmission pipelines, §§ 192.911(i) and 192.945 define
the requirements for
establishing performance metrics and evaluating IM program
performance. The gas
requirements invoke ASME B31.8S-2004, Managing System Integrity of
Gas Pipelines.
Section 9 of this standard provides guidance on the selection of
performance measures.
• For gas distribution systems, § 192.1007(e) requires development
and monitoring of
performance measures to evaluate the effectiveness of IM programs.
An operator must
consider the results of its performance monitoring in periodically
reevaluating threats and
risks. Guidance from ANSI/GPTC Z380, “Guide for Gas Transmission
and Distribution Piping Systems, 2012 Edition” and Section 9 of ASME
B31.8S-2004, “Managing System
Integrity of Gas Pipelines” can also be used for the selection of
performance measures
that can be applied to gas distribution systems.
When performing routine pipeline system inspections, PHMSA noted
weaknesses in the
development and implementation of program evaluations, including
weaknesses in using
meaningful metrics to identify opportunities for program
improvements and corrective actions.
Additionally, NTSB Recommendation P-11-19, which was generated
following the San Bruno,
CA, failure investigation, recommended PHMSA develop and implement
standards for IM and
other performance-based safety programs that require operators of
all types of pipeline systems
to assess the effectiveness of their programs using clear and
meaningful metrics and identify and
then correct deficiencies.
In response to PHMSA’s self-identified concerns and the NTSB
recommendation, PHMSA
developed a guidance document titled “Guidance for Strengthening
Pipeline Safety Through
Rigorous Program Evaluation and Meaningful Metrics,” which is
available at
http://phmsa.dot.gov/staticfiles/PHMSA/DownloadableFiles/Pipeline/Regulations/IMPEG.pdf.
Major topic areas addressed in the guidance document include:
Establishing
Safety Performance Goals.
Identifying
Required Metrics.
Selecting
Additional Meaningful Metrics.
Metric
Monitoring and Data Collection.
Program
Evaluation Using Metrics.
The guidance document includes tables listing regulation-required
metrics and other
programmatic and threat-specific metrics that operators could
include in their documented IM
program evaluations.
Table
1 lists the IM-related metrics documented in pipeline operators' annual
reports.
Table
2 lists the threat-specific metrics required by § 192.945 for gas transmission
and
required by § 192.1007(g) for gas distribution systems.
Table
3 provides guidance for operators and inspectors to identify meaningful metrics
to
help understand and measure the effectiveness of the individual
program elements and
processes used in an IM program.
Table
4 provides guidance for operators and inspectors to identify meaningful
threatspecific
metrics that may be required to effectively measure the
performance of gas
transmission, hazardous liquid transmission and gas distribution
pipeline IM programs.
II. Advisory Bulletin (ADB-2014-05)
To: Owners and Operators of Natural Gas and Hazardous Liquid Pipelines
Subject: Guidance for Strengthening Pipeline Safety Through Rigorous
Program Evaluation and
Meaningful Metrics
Advisory: The Pipeline and Hazardous Materials Safety Administration
(PHMSA) is issuing this
Advisory Bulletin to inform owners and operators of natural gas
and hazardous liquid pipelines
that PHMSA has developed guidance on the elements and
characteristics of a mature IM
program evaluation process using meaningful metrics. This guidance
document titled “Guidance
for Strengthening Pipeline Safety Through Rigorous Program
Evaluation and Meaningful
Metrics,” is available on PHMSA’s public website at
http://phmsa.dot.gov/staticfiles/PHMSA/DownloadableFiles/Pipeline/Regulations/IMPEG.pdf,
and should be used when operators develop and perform IM program
evaluations. This guidance
document provides additional specificity to several of the topics
detailed in a previously issued
Advisory Bulletin, ADB-2012-10, “Using Meaningful Metrics in
Conducting Integrity
Management Program Evaluations.”
Operators under the current regulations are required to perform
program evaluations and use
meaningful metrics. PHMSA’s “Guidance for Strengthening Pipeline
Safety Through Rigorous
Program Evaluation and Meaningful Metrics” builds on existing
standards and regulations to
provide a more detailed and comprehensive description of the steps
involved in program evaluations as well as the selection of meaningful
performance metrics to support these
evaluations. The guidance expands and clarifies PHMSA’s
expectations for operator processes
when measuring IM program effectiveness.
PHMSA inspectors will use the program evaluation guidance within “Guidance
for
Strengthening Pipeline Safety Through Rigorous Program Evaluation
and Meaningful Metrics”
as criteria when evaluating the effectiveness of operator IM
program evaluations to assure
operators are developing sound program evaluation processes and
are developing and applying a
robust and meaningful set of performance metrics in their program
evaluations.
Authority: 49 U.S.C. Chapter 601 and 49 CFR 1.97.
Issued in Washington, DC, on October 09, 2014.
Jeffrey D. Wiese,
Associate Administrator for Pipeline
Safety.