PHMSA updates Control Room Management FAQ’s

PHMSA has revised or added several control room management frequently asked questions related to shift schedules and testing of backup manual operations plans.

C.14 With respect to testing and verification of backup manual operations, is the intent to test every manual operation or to test the capability to execute the backup plans, procedures, and processes?
Operators must test and verify that its internal communications plan can effectually implement backup manual operations in the event of a SCADA system failure. The test and verification process must be designed to confirm that the operator has adequate personnel, procedures, processes, communications infrastructure, and manual command-and-control capabilities to assure safe, reliable operations and pipeline integrity when operating manually. Such testing should (i) verify the sufficient and timely deployment of qualified personnel to field locations necessary to adequately operate equipment and monitor pipeline integrity, (ii) establish, supplement, and/or verify performance of its communications or command center, and (iii) exercise critical decision-making processes. Testing and verification should address all types of actions necessary to mobilize manual operations. Testing and verification should be performed on at least a representative sampling of the processes and equipment intended to be used during backup operations.
[§§ 192.631(c)(4) and 195.446(c)(4)]

D.14 If an operator doesn’t have shift lengths, schedule rotations, and maximum limit on hours of service explicitly noted in their fatigue mitigation related procedures, is an operator’s actual shift schedule and related records adequate to demonstrate compliance with (d)(1) and (d)(4)?
No. The rule requires operators to have written procedures that implement the fatigue mitigation requirements. PHMSA would expect an operator’s fatigue mitigation related procedures to describe the bounding parameters in shift lengths and schedule rotations, and maximum hours of service limits they have established as the general framework for their program. PHMSA would then expect to see examples of actual schedules, timesheets and other records to show how those procedures are implemented, including if/how any changes to those schedules are managed in the context of the procedures. Schedules and timesheets alone are likely not adequate, as they are subject to change in the case of call-outs, vacation, etc. and would only give a certain snapshot in time. Written procedures would provide the framework in which those schedules can be changed and managed to reduce the risks associated with fatigue.
[§§ 192.631(d)(1) and (d)(4) and 195.446(d)(1) and (4)]

D.15 Does the information presented in the other CRM FAQs and inspection criteria account for schedules of 7 consecutive day or night shifts followed by 7 consecutive days off, generally referred to as 7 on/7 off type shift schedules?
Control Room Management regulations do not exclude the use of 7 on/7 off type schedules. The regulations do, however, require the implementation of methods, including establishing shift lengths and schedule rotations, to reduce the risk associated with controller fatigue for any and all schedules. As part of fatigue mitigation strategies, PHMSA expects operators to have a scientific basis for the schedules and limits they select, and consider circadian effects, different types of shifts, the need for rest, and other factors highlighted by relevant research. As part of an overall fatigue mitigation program, operators need to take into account the relative fatigue risks of whatever schedule and limits they select, and ultimately be able to demonstrate how either the limits they select reduce the risk of fatigue, or how fatigue mitigation tactics (countermeasures) and other aspects of their overall program are sufficient to reduce the risk for fatigue.

There is an increased risk for fatigue as the number of successive shifts increase, particularly successive shifts involving night work. PHMSA’s CRM website is a resource for information about fatigue management and related mitigation strategies. FAQs provide some reasonable limits to consider, along with shifts/times where fatigue risks are elevated and where fatigue mitigation tactics should be implemented. Still other FAQs provide some examples of fatigue mitigation tactics (countermeasures.) The level of risk appears to increase in shift plans with periods that approach 7 successive shifts in a row, particularly if the 7 successive shifts all involve night work.

If an operator chooses to use limits past those recommended in FAQs and Inspection Guidance material, including 7-on/7-off schedules, an operator would need to provide sufficient justification on how their overall program reduces the risk for fatigue. Such justification may require different or additional countermeasures or a more comprehensive fatigue risk management approach.

There are a number of trade-offs in considering any schedule rotation, including 7-on/7-off type schedules. In addition to other guidance already provided, a white paper entitled “Shift Plans with Seven Consecutive Shifts (Miller, April 2012)” discusses the pros and cons behind such schedules, including some countermeasures that should be considered above and beyond those already included in other FAQs.

Operators should expect that inspectors would be more inquisitive about how they protect against fatigue risks on the 6th and 7th successive days of work (if day only), and on the 4th through 7th successive nights of work.

[§§ 192.631(d) and 195.446(d)]