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Compliance with PHMSA Regulations

This last month has been an extremely busy month and quite a change from last year. The month started with an Alarm Management Workshop in Salt Lake City and the development of an alarm philosophy for our customer there.

Then Harry, Dave and I spent two weeks in Lima, Ohio doing a staffing study and Work Team Design study for one of our existing refining customers. Having designed a central control room and introduced the site to management of organizational change, this refining customer is breaking the mold and moving forward with some of today’s best practices.

I went from there to Mobil, Alabama to one of our Petrochemical customers and had an enjoyable time working through the High Performance HMI Workshop and development of a Philosophy and Style Guide.  Steve Maddox spent the week with me on site as he learns our business and interfaces with our customers understanding their needs and helping them understand our service capabilities.

Dave and Harry went to a Pipeline customer and are helping them work through compliance with the new PHMSA Regulation.  We offer a full service but obviously specialize in the Human Factors requirements for the control room, the HMI and Alarm Management.  We have recently developed a Fatigue and Alertness Procedure and are developing a software solution for measuring the Fatigue Index.

I finished off the month working with one of our Affiliates, EnerSys.  We are working together to solve a customer’s compliance with the PHMSA Regulations.  It seems that this regulation is quite a shock to many customers.  Achieving good practice in alarm management is quite a challenge for an organization and many refineries and petrochemical plants have spent 10 years and have not achieved the recommended EEMUA 191 guidelines.  We need to understand why, and is it achievable?  The simple answer is yes it is possible, but there are no shortcuts to this process.  Many companies in the past have opted to ignore their responsibility and have put their hope in alarm management tool providers, who have limited operations knowledge.  They make a first cut and deal with alarm duplication and some basic configuration management which will only take you so far.  What is required is a detail rationalization of individual alarms based on detailed knowledge and understanding of the alarm categorization (safety, environment, equipment protection, and finally process alarms).

Most companies do not have a good alarm philosophy and have not done any documentation of their alarms with critical information such as cause, response and consequences statement.

The alarms are a challenge but good engineering practice and discipline have taken many of our customers to success.  But the alarms are just one of the many improvements required by the PHMSA regulation.  I am pleased to see that it is addressing an issue I see in every market especially the refining industry.  The API brought out RP755 which has been adopted by the Pipeline sector and ignored by everyone else.

We do see badly abused 12 hour shift systems, normally exploited by trade unions, which leads to out of control overtime, shift swaps to exploit maximum time off and the most overtime.  The result of this abuse is severe fatigue.  Most major companies do not want to even talk about this until they are forced to due to the Union Contract implications.  We have run fatigue index calculations and we see fatigue risk and risk indexes elevated to 3 times more than the norm.

Twelve hour shifts are bad enough and have been proven to introduce more risk than traditional 8 hour shifts.  Most of Europe has rejected the 12 hours shifts so where are we going with our bad practices?  If we want to continue to exploit the benefits of 12 hour shifts we MUST get them under control and start following industrial guidelines such as API RP 755.  I think this guideline does not go far enough; the PHMSA Regulation is very good and fully addresses the important issues.  But again this subject alone is a lot of work for the Pipeline companies.  Just getting compliance to the new Roles & Responsibilities is significant for many companies.

I was particularly disappointed with the PHMSA HMI recommendations.  They make a simple reference to an old API RP which has a new front end that covers the Human Factors practices for HMI.  It is well written but is not supported by the rest of the RP. The rest of the document is not compliant with the front end HF/E practices.  If anyone was trying to understand the HF/E part and read the rest of the document and examples they will be confused. Unfortunately, there is no ISA Standard or good EEMUA guideline to point to, unlike alarms the PHMSA section points to ISA SP18 and EEMUA 191.

Those of us who have grown up with OSHA PSM the PHMSA regulation makes a lot of sense and we have some solid solutions that can help customers comply.

We have been working closely with our Affiliates, Jack Pankoff with Production Excellence Inc., Doug Rothenberg with DRoth, EnerSys, and Lin Associates.  I am grateful to our affiliates for their friendship and their capabilities to help us provide unique and competent solutions for our customers.

EnerSys has developed a great SCADA solution based on the High Performance HMI and it includes some unique tools such as built in operator logbook based on PHMSA requirements for shift change. A good example of understanding the market is on-line alarm response sheets for each alarm.  It is worth seeing their demo in their Houston office which incorporates ergonomic sit/stand furniture, overview displays and advanced Yoking navigation schemes.

It was exciting this last month to see operators responding to the High Performance HMI.  They captured the vision and when our affiliate Lin & Associates finished the week off with a demonstration of their latest software applications I was proud to be a part of this process.