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Recap of DCA Webinar With Steve Allen

Wednesday, September 2, 2020  
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DCA Webinar With Steve Allen:
How & Why Contractors
Should Embrace PSMS & QMS

On Wednesday, July 29, Steve Allen, Executive Director of Pipeline Safety for ENERGYworldnet, hosted a webinar for DCA members to discuss Pipeline Safety Management Systems (PSMS) and Quality Management Systems (QMS).  He started with a question: Have you ever been driving along and seen a gas meter or a regulator on the side of the road not adequately protected from traffic?  If so, did you contact anyone about it?  Something as simple as missing traffic cones is a perfect example of poor safety management.

As with too many safety initiatives, the history of PSMS starts with a disaster.  In 2010, a pipeline owned by Enbridge, Inc. ruptured near Marshall, Michigan, spilling more than a million gallons of diluted bitumen from Canada’s tar sands into the Kalamazoo River.  An investigation by the National Transportation Safety Board (NTSB) found that the accident resulted from a complete breakdown of safety checks and procedures within the company.  As a result of the investigation, the NTSB recommended to the American Petroleum Institute (API) that it develop a safety management system standard specific to the pipeline industry.  The recommended practice that API developed was titled API RP 1173 Pipeline Safety Management Systems.

So, what exactly is PSMS?  Allen defines it as a holistic, systematic framework to help reveal and manage risk, and a set of management tools to promote learning and improvement.  It is a cyclical process that is never “complete.”  API outlines 10 key elements that are critical to the pipeline safety management process:

1. Leadership and management commitment
2. Stakeholder engagement
3. Risk management
4. Operational controls
5. Incident investigation, evaluation, and lessons
6. Safety assurance
7. Management review and continuous improvement
8. Emergency preparedness and response
9. Competence, awareness, and training
10.  Documentation and record-keeping

While a PSMS is focused on managing risk, Allen says that a QMS is focused on consistently fulfilling requirements.  In response to the high growth in pipeline construction since 2007, the Pipeline and Hazardous Materials Safety Administration (PHMSA) identified construction quality as a source of ongoing concern in the wake of incidents like the Enbridge spill and prompted API to develop a recommended practice.  API RP 1177 Recommended Practice for Steel Pipeline Construction Quality Management Systems was released in November 2017.  Allen also recommended the 2016 American Gas Association (AGA) white paper Contractor Construction Quality Management Guide and the Pipeline Construction SMS created by DCA and AGA as guidance for contractors to develop their own SMS and QMS.

Allen made clear that the dynamic between operators and contractors is a primary factor in ensuring safety.  API RP 1173, Section 8.4 puts the onus on operators who employ contractors to define communications, procedures, and other expectations.  PHMSA expects operators to:

  • Know the risks
  • Be aggressive
  • Focus on continual improvement
  • Demand excellence

The reality for operators, however, is that 50-75% of their workforce is contractors, meaning many of their core competencies are outsourced.  Contractors are by default the eyes and ears of the operators and the first line of defense against risk.  Even if the responsibility for SMS falls on the operator’s head, it would be wise for contractors to voluntarily implement their own SMS before it crosses the threshold from recommendation to the law.

Allen went on to detail one operator’s approach to implementing PSMS, including adopting a series of “shall” statements, performing contractor-gap analyses and cost-impact analyses, and mapping “shall” statements to individual safety plans.  He also highlighted the difference between safety climate and safety culture; safety climate refers to the promotion of personal occupational safety, while safety culture is focused more on group safety performance and avoiding major hazards in the first place.  Allen asserted that PSMS cannot exist without a positive safety culture, and he offered several methods for assessing the safety culture at your company, including:

  • Reviewing existing policies and procedures for their emphasis on safety.
  • Conducting employee perception surveys.
  • Observing how employees perform in the field.
  • Analyzing the results for alignment with best practices.

After a brief discussion of positive and negative indicators, Allen displayed an example of a safety portal digital dashboard showing safety culture assessment statistics, scoring, etc. as an example of how to track improvements.

Above all, Allen wanted his audience to “walk away with action,” encouraging contractors to:

  • Familiarize yourself with your current safety systems.
  • Gather your “shall” statements.
  • Identify gaps.
  • Develop plans to bridge those gaps.
  • Seek continual improvement.
  • Communicate with operators and seek their input.

The webinar concluded with a short Q&A session.  One listener asked if contractors working for multiple operators might need to have multiple PSMS for each one.  Allen answered that yes, the situation would be similar to operator qualifications (OQ), but that the DCA SMS template was designed to help make the process easier.  He noted that more big operators were paying closer attention to their contractors and heading in the direction of requiring some sort of SMS.  Finally, in response to another question, Allen pointed out that PHMSA would prefer to keep PSMS as a recommended practice rather than making it a requirement.  He thought that new regulations were probably not likely within the next five years, but that could change, so it is in contractors’ best interest to be prepared.