Mary, the Regulatory Director for a mid-size pipeline operator, set out to create a Pipeline Safety Management System that was both simple and easy to use, and addressed the complexity created by multiple regulations and industry recommended practices they needed to meet. When Mary broke it down, API RP1173 contains 234 individual line item requirements grouped under 10 elements and 54 sections. CFR 192 or CFR 195, the federal regulations for gas and hazardous liquid pipelines, contain hundreds of requirements each. She had a go at mapping common relationships between these requirements and there were hundreds of relationships between them. "Try writing that into a manual", she thought!
While many pipeline operators choose to adopt industry standards and recommended practices like API RP1173, they soon realize that the list is long and they see the need to group them under common topics and activities that make sense to their business. As part of the Pipeline SMS Toolkit, we provided Mary with a template Pipeline SMS Framework of topics that was pre-mapped to API RP1173 and CFR 192/195. The Framework had 8 Elements covering these regulations, recommended practices and standards, and was organized into typical activity and process topics that make sense to pipeline operators. Furthermore, the Framework and mapping is contained within Octane software which enables the operator to customize the Framework and edit the mappings based on their own needs and interpretations of what's applicable to them. Additional regulations and standards can be added at any time.
Because the API RP1173 elements and requirements are mapped to the framework, Mary can now show how API RP1173 is integrated into their business and how they are conformant. It then became more obvious what current programs, processes and activities aligned with the Pipeline SMS Framework and what still needs to be worked on, which helped tune up their previous gap assessment actions.
You need simple, easy to understand language that you can adjust to your organization’s culture and terminology as required. The simplicity of this Framework and the Pipeline SMS Toolkit helps yield superior implementation and assessment results which makes Pipeline SMS performance reporting much more valuable. This approach provides you with an excellent generic starting point with a templated set of Elements and Expectations that then map to API RP1173 and CFR requirements to provide the detailed requirements. It is easy to become buried in details and complexity, and the SPAN Pipeline SMS Toolkit helps to avoid that.