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November 18, 2020
EXP has been helping clients prepare for a changing pipeline environment since the Pipeline and Hazardous Materials Safety Administration (PHMSA) published changes to 49 CFR Part 192 and Part 195. With over 40 years of pipeline experience, EXP remains at the forefront of adapting to industry changes with innovative solutions and guiding clients to understand how changing regulations impact their business and diversified approaches to focus on interconnected solutions, especially as the industry stresses a culture of safety. To establish strategic and implementable programs for clients, owners and operators, EXP highlights data quality, management and integration as key focus areas driving recommended practices and the ability to meet PHMSA regulatory changes.
EXP’s safety and compliance experts, Vice president, Strategic Programs, Mary Campos, and Director of Integrity Management, Elaine Pacheco, provide insight on how owners and operators can position themselves for success in a changing industry by improving existing programs interconnected with PHMSA’s changing regulations.
How will the changes to 49 CFR Part 192 and Part 195, effective January 2021, impact owners and operators? Where should organizations focus their initial efforts to maintain compliance and the safety and integrity of their pipelines, and why?
With a comprehensive understanding of PHMSA’s updates, EXP sees the upcoming changes as an opportunity for operators to enhance existing programs to further their safety culture. The impacts on each organization will vary as they adapt to PHMSA’s regulatory changes. For example, one organization may already utilize seismic data as a risk factor in integrity management; therefore, the impact of this element is less intrusive for that organization. Conversely, the same organization may have a gap in its material and operational records for one or more of its pipeline networks. In this case, the maximum allowable operating pressure (MAOP) associated with that particular asset requires heightened attention.
EXP’s experts work with owners and operators to identify their needs and tailor an approach, procedures and strategize safety programs to ensure that their records are traceable, verifiable and complete – a measure needed to meet PHMSA’s requirements. It will be imperative for plans to clearly capture the interconnected functions which impact internal aspects of an organization, inclusive of safety, as they have cascading effects externally.
Phase 1 of the Part 192 update and the final Part 195 updates will require changes to operating procedures, data verification and reporting requirements. What opportunities do you see the industry leaning towards to meet this challenge?
As the pipeline industry strives for zero incidents, EXP sees an evolving need for integrated processes at the program level, with a focus on increased safety and minimized risk. Regardless of an owner or operators’ size and where one is in their safety journey, each will have unique needs with the pending changes.
By performing an assessment of one or all elements of the operator’s respective programs, an understanding of the most efficient and cost-effective path to meeting PHMSA’s requirements. This also provides operators a continuous improvement mechanism to enable the company to be compliant with regulatory authorities and drive excellence in safety performance within their organization.
For new companies or smaller localized operators, the opportunities exciting as well, because they start from a baseline and can tailor their program to captures the current requirements, incorporate resilient components and prepare to pivot towards future changes.
Organizations have an opportunity to improve how their data will be measured, captured and utilized by the business to ultimately improve financial risk, operational performance, safety and business resiliency.
Given the complex nature of the mentioned regulatory changes, how do you see the implementation of an integrated management system approach, like API RP 1173, helping operators improve the safety of their operations and reduce risk?
American Petroleum Institute (API) RP 1173 is a recommended practice that provides a framework for companies to follow as they develop their safety management systems (SMS) in order to manage risks and improve safety outcomes relative to their pipelines. Although not a regulation, and while there is no universal approach to safety management, RP 1173 details 10 key elements to form the backbone of a safety management system.
Historically, the implementation of SMS tends to strengthen an organization’s safety culture. The establishment or reinforcing of safety as a core value acts as a unifier to improve operational performance. The SMS, with all its individual elements and interlinkages, supports the culture and the culture in turn feeds back into the management system. As a result, the organization’s safety performance continuously improves and increasingly matures.
How can EXP support operators in addressing the changing requirements and implementing the recommended practices?
As advocates of safety and operational excellence, as well as active members of key industry organizations such as the Interstate Natural Gas Association of America (INGAA), Association of Oil Pipe Lines (AOPL) and the American Petroleum Institute, EXP is qualified to assist clients in technical support and in the development and implementation of systems to align with RP 1173. EXP utilizes a holistic approach wherein the ‘sum of the individual aspects is greater than the whole.’
Recognizing the vast differences in our client base, we understand that the level of assistance from EXP ranges from undertaking ‘cold eyes review’ of clients’ revised safety and integrity management systems to aiding in the design of concepts, strategies, plans, and compliant implementation.
Regardless of the situation, our aim is to deliver the ‘right-size’ solution to best meet our client’s needs.
EXP’s safety and compliance experts have extensive experience providing operators and clients with innovative, data-driven and compliant solutions. As part of EXP’s Energy Services team, they are instrumental in supporting clients in adhering to pipeline regulations, strategizing for upcoming regulatory changes and meeting their operator-specific safety program goals. To learn more about how EXP can help you with safety and compliance, contact Mary Campos or Elaine Pacheco.