Steve Allen, Executive Director, Pipeline Safety, ENERGY worldnet, Inc.
There’s something I’ve been thinking about quite a lot lately. It’s an important topic that is beginning to gain traction in our industry: Contractor Pipeline Safety Management Systems (PSMS) Programs.
In recent months, more and more pipeline operators have started consulting with their contractors and involving them more heavily in their own PSMS and programs. This is a really good thing since contractors, who provide services related to new construction, operations, and maintenance activities, make up a very large percentage of many operators’ workforces. Contractors identify risks and view things from a prevention and mitigation perspective. These ‘boots on the ground’ partners are on the front lines for operators and want to help them identify and avoid risks to ensure lasting pipeline safety. In return, operators are well served by engaging their contract partners regarding PSMS intentionally – and early on – in their PSMS journey.
From an overall pipeline safety perspective, safety begins long before a pipeline or its components are constructed. Pipeline design, material specification and manufacturing, quality control, material handling, and quality construction procedures are just some of the considerations. Plus, the qualifications of individuals who construct and inspect the pipeline are major considerations. Many operators rely on their contractor partners to perform many of these activities, so communication is mission critical.
The American Petroleum Institute Recommended Practice 1173 (API RP-1173 “Pipeline Safety Management Systems” – July 2015) requires operators to engage and communicate with their contractors related to the following important responsibilities:
· Scope of work
· Accountability and authority for managing outsourced activities
· Incorporating lessons learned into daily operations
· Training and orientation on safety policies and practices
· Evaluating contractor safety performance
· Communicating risks at the worksite
· Communicating management of change procedures
That’s a lot of responsibility for operators. And it’s all important information to relay to contractors.
Closely related to PSMS, in my opinion, are quality management systems (QMS) regarding pipeline construction. The American Gas Association Whitepaper (“Contractor Construction Quality Management Guide” – November 2016) takes a pretty deep dive into this topic and provides guidance to contractors for the implementation of Quality Management Programs focusing on the construction of Pipeline Facilities. The Whitepaper is broken down into broad categories, including Project Initiation, Project Preparation, Inspection, Documentation, and Performance Measurement. Each of these categories directly relates back to concepts developed in API RP-1173.
Similarly related to PSMS is the American Petroleum Institute Recommended Practice 1177 (API RP-1177 “Construction Quality Management Systems” – October 2017). RP-1177 addresses many relevant aspects of the pipeline construction process through Activity Quality Plans (AQPs). AQPs are documents that “…establish procedures, minimum personnel qualifications, roles and responsibilities, inspection methods, and record requirements of construction activities.” AQPs identify quality objectives and risks associated with various construction tasks and provide suggested controls to help ensure that objectives are achieved, and risks are prevented or mitigated.
All three of these guiding documents provide excellent information and support for the development of high-quality contractor PSMS and QMS programs – programs in which communication plays an important part.
It is also imperative that operators communicate with and fully involve their contract partners in the area of safety culture. A contractor employee’s ability and willingness to say something, after they see something (without fear of reprisal) is of paramount importance to ensuring an overall positive safety culture – and ultimately overall pipeline safety. And that’s the most important thing.
In my opinion and experience, operators will find that engaging their contractors in the development and coordination of PSMS and QMS will yield demonstrable gains in pipeline safety and performance. I applaud those operators who have already engaged their contractor partners with this endeavor. I also implore those who haven’t yet done so to jump in. You will be glad you did.
Steve Allen
Executive Director, Pipeline Safety
Energy Worldnet