This paper summarizes a SCADA implementer’s perspective regarding the intent of the Pipeline Hazardous Materials Safety Administration’s (PHMSA) Control Room Management (CRM) rule. In addition, this paper provides a fresh approach to CRM, describing why companies should use the CRM process to go beyond compliance requirements and implement operating best practices that would significantly enhance operations reliability and pipeline safety.
CONTROL ROOM REGULATIONS BACKGROUND
What is the CRM rule? More importantly, what is PHMSA’s intent with this rule? One of PMHSA’s roles is to study pipeline incidents and make policy recommendations for improving pipeline safety. PHMSA has identified “people” as a critical element in pipeline safety. People are often involved in preventing pipeline events – sometimes causing them, sometimes worsening them and always striving to mitigate their adverse effects.
The rule passed by Congress in December 2009 and became effective February 1, 2010. To satisfy this rule, pipeline owners and operators with systems managed by controllers and using a SCADA system were originally required to have a compliance plan completed by August 1, 2011, and implemented by February 1, 2013. However, as a result of several pipeline incidents in 2010 which received national new attention, Congress accelerated the implementation date to August 1, 2011, for most items with a full implementation by August 1, 2012.
In investigating incidents, PHMSA has found that a pipeline controller (controller defined as the person seated in the chair facing the control system) may be qualified but is not always successful in managing abnormal situations or events. In fact, the controller’s ability to manage abnormal situations may be influenced by ineffective procedures, fatigue or even limitations in the SCADA system itself. To provide a balance between systems, implementation and procedures that help controllers be more successful, PHMSA offered the strategy “Prevention through People.”