Safety Management Systems

1. Safety Management Systems Presentation to PHMSA Advisory Committees December 2012

2. Some history • The pipeline industry (both natural gas and hazardous liquids) has previously considered Safety Management Systems to assure that adequate processes exist to protect the public, the environment, employees and contractors. • Many operating companies have highly evolved processes to insure adequacy of its procedures, implementation and verification. • Unfortunately, several incidents in 2010 and 2011 revealed weaknesses in safety management processes and oversight as contributing factors.

3. NTSB Recommendations • NTSB made recommendations to the operators, PHMSA, and to API. The recommendation to API is on page 124 of the Marshall, MI report. • Facilitate the development of a safety management system standard specific to the pipeline industry that is similar in scope to your Recommended Practice 750, Management of Process Hazards. The development should follow established American National Standards Institute requirements for standard development. (P-12-17)

4. NTSB Recommendations • NTSB expanded on their recommendation to API (pgs116-117) • … The NTSB has advocated the implementation of SMSs in transportation systems by elevating SMSs to its Most Wanted List. However, the NTSB has not called for an SMS in pipeline operations. This Marshall accident and the 2010 pipeline accident in San Bruno, California, indicate that SMSs are needed to enhance the safety of pipeline operations. • Both the San Bruno accident and the Marshall accident involved errors at the management and operator levels in both pipeline integrity and control center operations. The delays in recognizing and responding to the pipeline rupture and the deficiencies in control center team performance were prominent aspects of both accidents. • SMSs continuously identify, address, and monitor threats to the safety of company operations by doing the following: • Proactively addressing safety issues before they become incidents or accidents. • Documenting safety procedures and requiring strict adherence to the procedures by safety personnel. • Treating operator errors as system deficiencies and not as reasons to punish and intimidate operators. • Requiring senior company management to commit to operational safety. • Identifying personnel responsible for safety initiatives and oversight. • Implementing a nonpunitive method for employees to report safety hazards. • Continuously identifying and addressing risks in all safety-critical aspects of operations. • Providing safety assurance by regularly evaluating (or auditing) operations to identify and address risks.

5. NTSB Recommendations (continued) • The evidence from this accident and from the San Bruno accident indicates that company oversight of pipeline control center management and operator performance was deficient. In both cases, pipeline ruptures were inadequately identified and delays in identifying and responding to the leaks exacerbated the consequences of the initial pipeline ruptures. • Therefore, the NTSB concludes that pipeline safety would be enhanced if pipeline companies implemented SMSs. • The API facilitates the development and maintenance of national consensus standards for the petroleum and petrochemical industry, including liquid and gas pipelines. In 1990, the API published API RP 750, Management of Process Hazards, which is an SMS for the refining and chemical industries. • Because of the improvements to safety that accrue from the use of a comprehensive SMS, the NTSB recommends that the API facilitate the development of an SMS standard specific to the pipeline industry that is similar in scope to the API’s RP 750, Management of Process Hazards. The development should follow established American National Standards Institute requirements for standard development.

6. Standard Development within API • Types of API Standards • Specifications • Recommended Practices • Standards • Codes • API follows an established standards development process that includes American National Standards Institute requirements for standard development since 1919 with its first standard published in 1924. • The development process is accredited by the American National Standards Institute and their requirements for standard development (An element of the NTSB Recommendation) • API’s Procedures for Standards Development are reviewed as part of ANSI’s organizational audit every five years

7. Identified Participants to Develop an SMS Recommended Practice • Ron McClain, Kinder Morgan Energy Partners, Chair • Mark Hereth, P-PIC, Content Editor • Scott Collier, Buckeye Partners • Mark Weesner, ExxonMobil Pipeline Company • Mark Willoughby, Enbridge Pipelines Inc. • David Ellingsworth, Marathon Pipe Line • Brianne Metzger-Doran, Spectra Energy • Tracey Scott, Alliance Pipeline • Scott Currier, INGAA • John Bresland, Public – Subject Matter Expert • Stacey Gerard, Public – Subject Matter Expert • Jeff Wiese, PHMSA • Linda Daugherty, PHMSA (alternate) • Steve Klejst, NTSB (Ex Officio) • Robert Hall, NTSB (alternate) (Ex Officio) • Kate Miller, AGA • William Moody, Southwest Gas • Robert Miller, AZ Corporation Commission • Massoud Tahamtani, VA State Corporation Commission Direct Participants 5 – Liquids Pipelines 3 – Natural Gas Pipelines 2 – Trade Organizations 3 – Regulators 1 – NTSB 2 – Public – SME’s 1 – Contract Engineering * Plus alternates

8. SMS Development Team Scope Develop high level guidance, specifically a Recommended Practice (RP 1173) to help operators build management systems that assure: • Definition of Leading Indicators Regarding Safety Performance • Sr. Management Roles in Oversight – Does Sr. Management have processes to know their level of compliance and integrity? • Appropriate Employee Involvement – Are all employees empowered to shut down the pipeline with concerns? Without repercussion? • Management of change – Required by PSM, good for all operations • Compliance (Operational and during construction) • Assurance of Pipeline Integrity (identification of risk, Sr. Mgt Involvement) • Establishment and adherence to operating practices • Maintenance • Audits and Assessment of Programs and Practices (Is what I think is happening, really happening?) • Continuous improvement (adjusting to what is found in assessments) that may be used to manage pipeline safety and system integrity systematically. • Any system should be limited to management, design, construction, operation, maintenance, integrity management, and training on line pipe and pipeline facilities. A key element will include processes to inform senior management on risks, the efficacy of mitigation of risk and ongoing reassessments. • The system must be flexible to allow companies with highly evolved management systems to build upon existing platforms yet structured enough to let companies start from scratch.

9. Many platforms already exist within existing industry standards and implemented corporate policies • Industry Standards already in publication • API RP 75 – MS for Offshore Operations and Facilities • API RP 750 – Management of Process Hazards • ANSI Z10-2012 Standard on Occupational Health and Safety Management • CSA-Z662-11 – Section 3.1Management Systems • Implemented Corporate Systems for Consideration • Marathon – Responsible Care Management System • Exxon Mobil – OIMS • Kinder Morgan – Operations Management System • ARCO – Operating Excellence Systems • INGAA – SMS White Paper • Sinclair Transportation – Safety and Health MS

10. Existing Standards Show Similarities

11. The Timeline Since the identified group has not yet met, a definitive and agreed upon timeline remains to be determined. Significant Dates include: • NTSB Report – Marshall, MI – July 10, 2012 • API Workshop on Management Systems – October 4, 2012 • Initial Meeting of SMS Development Team Members – December 18, 2012 • Time to conclude: 18 months to allow for development, drafts for comments, final version, API Balloting