Impact Of New PHMSA Control Room Management Rules

A Review Of The Amended 49 CFR Parts 192 And 195
By Douglas H. Rothenberg, Russel W. Treat and Ardis Bartle | April 2010 Vol. 237 No. 4

The Pipeline Inspection, Protection, Enforcement and Safety Act of 2006 (PIPES) mandates that the Secretary of Transportation issue regulations on control room management (CRM) requiring a human factors plan that assures control systems are matched to human capabilities and limitations, including fatigue management.(1)

Support along very similar lines for improving the safety and reliability of both liquids and gas pipelines was expressed in a letter to the Department of Transportation (DOT) from the American Gas Association (AGA), the American Petroleum Institute (API), the American Public Gas Association (APGA), the Association of Oil Pipe Lines (AOPL), and the Interstate Natural Gas Association of America (INGAA).(2)

The content of the recent amendments is a result of the National Transportation Safety Board (NTSB) investigations into real accidents and incidents that befall pipeline operations. In the process of investigating mishaps, NTSB identified key root causes and then proposed five areas for potential improvement:3 controller display graphics, alarm management, controller training, controller fatigue and leak detection.

DOT has approved and issued specific revisions to the law. The new regulation amends 49 CFR Parts 192 and 195.4 The regulation contains specific requirements for operators to design and operate their enterprise-wide SCADA to take specific account of what is needed by the controller to properly do the job of keeping things operating safely and responsibly. The amendments require the following: (a) understand and manage fatigue, (b) provide effective operating and safe maintenance procedures and training, (c) match the control room environment and equipment to the human capability, (d) provide effective controller warning and guidance of abnormal operation specifically addressed to alarm system improvements, and (e) establish and enforce an effective change management process.

Our discussion is to assist pipeline operators to focus on how each organization can best prepare for the required changes.

This article is not intended to provide legal advice or recommendations for compliance to any regulatory requirement. The purpose of this article is to provide general information to the technical public for that public’s awareness and to assist in safer and better operation of pipelining enterprises.

As of the effective date, these regulations apply to (1) existing facilities, (2) existing facilities that undergo modification, and (3) new facilities. An exception is noted for human machine interfaces (HMI) that are not modified, replaced, or installed new. Liquefied natural gas (LNG) facilities are not covered by these amendments. Thus, there are no changes to 49 CFR Part 193.

The regulations apply to both owners and operators of liquid pipelines and gas pipelines. All control rooms are covered that contain equipment that permits the manual intervention of the operation of the pipeline. This includes local control rooms or panels to the extent that the safety effects of operational error are similar to regular control rooms. Control rooms and control areas that are “view only” are exempt. Also, gas pipelines that service less than 250,000 customers and/or lack compression equipment are subject to the requirements only for fatigue management, validation, compliance and documentation.