Waiting on the Final PHMSA Control Room Management Rule – October, 2009

After several years of discussions, debates, and dialogue, the final rule is likely to be issued before the end of 2009. No matter when the rule is issued, companies will still have an adequate amount of time to develop and implement a human factors management plan. The PIPES Act of 2006 specified that the plan must reduce risks associated with human factors, including fatigue, in each control center for the pipeline. The Act also states that each plan must include “a maximum limit on the hours of service established by the operator for individuals employed as controllers in a control center for the pipeline.”

The NTSB, in its comments (04-06-09) on the proposed rule, emphasized to PHMSA that “the rule should include language that emphasizes the importance to operators of these facilities of incorporating fatigue research, circadian rhythms, and sleep and rest requirements when establishing a maximum limit on controller shift length, maximum limit on controller hours of service, and schedule rotations.”

We believe that the final rule will contain more explicit guidance on the required elements of a fatigue risk management plan. As a result, our company will be furnishing tools that incorporate fatigue research and circadian rhythms to our clients. A fatigue risk management plan will require an accurate assessment, diligent analysis, careful design, and skillful implementation.

The other elements of the human factors management plan, outlined in the proposed rule, will also require careful attention. The emphasis on communication at shift change, between different parts of the organization and the control room, and the need for communication about changes demonstrate that many incidents and near misses are caused by lack of communication, miscommunication, and misunderstandings about the message. Providing adequate information will also require companies to ensure that the SCADA displays and alarm systems work well to ensure appropriate responses by the controller.

Do pipeline companies already have an “Operating Experience” program? Before becoming partners in Pipeline Performance Group, Charles Alday and Dr. Michele Terranova were instrumental in developing and implementing a successful “Lessons Learned” program for a major pipeline. Incident analyses were performed on all operating incidents and significant near misses. This best practice should be in place for pipeline safety and business economics reasons.

All rules have an emphasis on training, and the control room management rule is not an exception. We suggest that the development of an ongoing educational program about fatigue management and the other elements of the rule will be more effective than one time or occasional training events.

Waiting on the Final PHMSA Control Room Management Rule – October, 2009