This week’s Pipeliners Podcast episode features Ross Adams of EnerSys Corporation returning to the podcast to discuss Hours of Service considerations in the pipeline control room, especially during the holiday season.

In this episode, you will learn about how to manage or support Hours of Service in the current COVID-19 environment, how to support fatigue mitigation when controllers are working remotely, the importance of implementing safeguards when short-staffed, and the overall importance of supporting pipeline safety during the holiday season.

Pipeline Control Room Hours of Service: Show Notes, Links, and Insider Terms

• Ross Adams is the Regulatory and Software lead for EnerSys Corporation. Connect with Ross on LinkedIn.
  • Listen to Ross’ previous appearances on the Pipeliners Podcast.
  • EnerSys Corporation is the sponsor of this month’s Pipeliners Podcast episodes. Find out more about how EnerSys supports pipeline operations compliance, audit readiness, and control room management through the POEMS software suite.
    • ComplyMgr is a new software module from EnerSys that simplifies PHMSA compliance and streamlines the PHMSA audit process for pipeline operators. [Watch this video and consider scheduling a demo.]
• Pipeline and Hazardous Materials Safety Administration (PHMSA) is responsible for providing pipeline safety oversight through regulatory rulemaking, NTSB recommendations, and other important functions to protect people and the environment through the safe transportation of energy and other hazardous materials.
• The CRM Rule (Control Room Management Rule as defined by 49 CFR Parts 192 and 195) introduced by PHMSA provides regulations and guidelines for control room managers to safely operate a pipeline. PHMSA’s pipeline safety regulations prescribe safety requirements for controllers, control rooms, and SCADA systems used to remotely monitor and control pipeline operations.
  • Hours of Service (HOS) is captured in the CRM Rule under the Fatigue Mitigation section of the control room management regulations. PHMSA allows for an emergency deviation from the maximum limit on controller HOS, if necessary, for the safe operation of a pipeline facility. [Read More in Section D13 of the PHMSA FAQs]
  • Read Russel Treat’s lengthy article on COVID-19 Precautions & Business Continuity for the 24/7 Control Room.
  • Read a recap of the PHMSA Advisory Bulletin on COVID-19-related leniency for the pipeline control room.
• Alarm management is the process of managing the alarming system in a pipeline operation by documenting the alarm rationalization process, assisting controller alarm response, and generating alarm reports that comply with the CRM Rule for control room management.
  • Situational awareness is the controller’s ability to perceive environmental elements and events, comprehend their meaning, and project their status after a variable has changed.
  • Alarm rationalization is a component of the Alarm Management process of analyzing configured alarms to determine causes and consequences so that alarm priorities can be determined to adhere to API 1167. Additionally, this information is documented and made available to the controller to improve responses to uncommon alarm conditions.
• AGA (American Gas Association) represents companies delivering natural gas safely, reliably, and in an environmentally responsible way to help improve the quality of life for their customers every day. AGA’s mission is to provide clear value to its membership and serve as the indispensable, leading voice and facilitator on its behalf in promoting the safe, reliable, and efficient delivery of natural gas to homes and businesses across the nation.
• The Operator Qualification Rule (OQ Rule) refers to the 49 CFR Parts 192 and 195 requirements for pipeline operators to develop a qualification program to evaluate an individual’s ability to react to abnormal operating conditions (AOCs) that may occur while performing tasks.
  • AOCs (Abnormal Operating Condition) is defined by the 49 CFR Subpart 195.503 as a condition identified by a pipeline operator that may indicate a malfunction of a component or deviation from normal operations that may indicate a condition exceeding design limits or result in a hazard(s) to persons, property, or the environment.
    • Part 192, Subpart N is the minimum requirement for operator qualification of individuals performing covered tasks on a pipeline facility.

Pipeline Control Room Hours of Service: Full Episode Transcript

Russel Treat:  Welcome to the Pipeliners Podcast, episode 158, sponsored by EnerSys Corporation, providers of POEMS, the Pipeline Operations Excellence Management System, compliance and operations software for the pipeline control center, recently releasing ComplyMgr software to streamline audit readiness. Find out more about POEMS at enersyscorp.com.

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Announcer:  The Pipeliners Podcast, where professionals, Bubba geeks, and industry insiders share their knowledge and experience about technology, projects, and pipeline operations.

Now, your host, Russel Treat.

Russel:  Thanks for listening to The Pipeliners Podcast. I appreciate you taking the time. To show the appreciation, we give away a customized YETI tumbler to one listener every episode. This week, our winner is Byron Denis with Magellan Midstream. Congratulations, Byron, your YETI is on its way. To learn how you can win this signature prize, stick around till the end of the episode.

This week, Ross Adams returns to the Pipeliners Podcast. We’re going to talk about Hours of Service in the control room during the holidays. Ross, welcome back to the Pipeliners Podcast.

Ross Adams:  Hey, man. Thanks so much for having me. It’s been a while since I’ve been here, hasn’t it?

Russel:  Yes. In fact, I checked that before we got on the microphone here. You are probably one of the most active guests. You’ve been on the podcast four times talking about various control room things. The last time was July of 2019. That’s been nearly 18 months ago. The whole world has changed since then.

Ross:  It feels like about five years, doesn’t it?

Russel:  Exactly. What have you been up to in the last 18 months?

Ross:  I have been busy, thankfully. I consider that a blessing, certainly. At EnerSys, we’re doing all kinds of stuff in this period where not a lot of activity is going on in industry, but we’re able to prepare for when things come back.

I’ve been focusing on new products and new services, ways that we can support our customers in some really new and impactful ways. We’ve developed and put to market ComplyMgr tool, which really helps control managers and compliance managers and really anyone dealing with the various safety programs, create policies and procedures, perform gap analyses in accordance with the PHMSA integrated inspections.

Then out of those gap analyses, use the corrective action they’ve identified to improve those documents. This is a program improvement tool over time. That’s taking a fair amount of my energy. Then we’ve also spent a lot of time looking at our CRM suite and updating and improving a lot of the tools.

I think we had a great suite to begin with, but there’s always something else that you can be doing better. Just similar to operators and how they’re focused on continuous improvement, we are as well. A lot of our focus in updating the CRM Suite has been on our logbook functionality.

Even more so, on our more recent tool, FatigueMgr. FatigueMgr has two parts. One helps to manage workload analysis on an ongoing basis. The other has everything to do with hours of service deviation identification, mitigation, and recordkeeping, as well as controller scheduling.

Russel:  What a perfect segue, Ross. It’s almost like we talked about this before we got on the microphone.

Ross:  That may have happened. No comment.

Russel:  [laughs] I asked you to come on, and what I wanted to do is talk about Hours of Service. We’re calling this the holiday edition, because I think there’s some special requirements that need to be contemplated and managed for control rooms around the holidays.

People want time off. They want to be with their families. They’ve got extra things to do around the house. Of course, this year, we have an extra high bar of challenge, because a lot of control rooms are thinly staffed, due to all the COVID restrictions or people having contact with COVID.

Anyway, that’s what I wanted to bring you on to talk about is, to talk about what are the concerns around the holidays? I’ll just ask that question first. What are the key concerns around the holidays?

Ross:  Between the holidays and with COVID, an increased level of stress and activity, not just for the controllers, as many control rooms are short-staffed, or maybe they have some new or contract employees filling in.

Also, at home, because the inlaws are in town, or you’ve got a big, ol’ shopping list that you’ve got to take care of on your off-hours.

The ability to get your 8 hours of sleep, hit your 35 hour resets, and take care of yourself and your health in a way that allows you to come back to the console, be fit for duty, and maintain adequate situational awareness, so you can respond to those alarms, that’s hard to come by these days.

We want to talk about what that’s all about and maybe how we can help operators, control room managers, and controllers alike be aware and prepare for those realities.

Russel:  What are some of the strategies that people need to be thinking about as we approach the holidays?

Ross:  I think it’s, for me, a three-phased approach. One is, as it relates to hours of service, fatigue mitigation, and staffing and scheduling, one is culture. Having a good culture in your control room, where someone’s showing up to work and being recognized as potentially not being fit for duty due to fatigue, that’s not a punitive issue.

It’s almost, for me, and in the way that I write control room management plans, it’s almost like a stopware policy. It’s saying, “Hey, look, we’re not in the field, but we are in the control room. We have a lot of responsibility, and this person has arrived, and clearly they’re tired. They can’t stay awake,” or whatever it happens to be.

Let’s press pause, and let’s go through our process of either implementing some mitigating activities or maybe we find a replacement controller. Again, without any kind of punitive action against the person identifying or the person who’s affected by the fatigue. Culture is number one.

Number two, I think, is about practicing a proactive approach to mitigating the risks of fatigue and around hours of service. Getting adequate sleep, making sure that, when you’ve been off, and you’re about to go back on shift, that you’re doing the things that you need to do and would normally be doing to prepare, and taking care yourself.

I’ll be the first to admit, the people at the gym don’t recognize my face, but the people that sell big ol’ Thanksgiving turkeys do. Eating well, exercising, and good sleep hygiene and practices is important, but also making sure to manage the additional stress that comes with the holidays.

I mentioned having people in town, coming and going, and all the stress around the consumer elements of Christmas season are things to be mindful of.

Russel:  I think one of the things that’s important to think about is that stress can be because of struggle, but stress can also be because of good things. When you’ve got people in that you haven’t seen for a long time, and you want to see them, and you’re getting to celebrate with your kids, your family, and all that kind of stuff, that creates stress, too.

You want to be present. You want to be there. That’s good stress, but it does create a load that you need to recover from in order to be able to go to work. Particularly if you’re working shift work.

Ross:  Without a doubt. For control room managers, I think being mindful of that reality is important. I think, too, when you go to look at your scheduling, balancing when people are able to take time off is important.

Making sure that those schedules are set in advance, and that people can prepare to enter into those schedules in an effective way. Then if — out of the schedule making — because you’re short-staffed, or because you have some COVID issues, or because you have too many people taking time off, if you’re going to have hours of service deviations, recognizing those in advance.

Either working around them or properly mitigating for them is incredibly important.

Russel:  No doubt. I think you brought something up, and we ought to probably talk about this. I wrote a lengthy article about responding to COVID that I originally put out probably early March, and then I’ve updated that thing several times over the course of the year as we’ve matured in our understanding and how to respond.

What kind of effects are you seeing happen in control rooms related to COVID?

Ross:  The staffing issue certainly pertains to the COVID conversation, because we had the first wave and then maybe even a second wave. It’s hard to keep track. I don’t know if we’re on our second wave or our third.

Numbers are increasing in a lot of the country right now. Certainly, as folks got together for Thanksgiving and will again for the Christmas season, the risk is there. For the control rooms, being proactive and making sure that your employees are educated around taking precautions during that time is important.

Also, there are certainly control rooms right now that I know of who have controllers that came back from Thanksgiving, had a buddy or a family member that called them, a controller, and say, “Hey, I tested positive. You need to go get tested.”

Then all of a sudden, that person had been at work for two days, and so half your control room is out. Now may not be a bad time to revisit some of those original plans that we put together as we were entering into the COVID cycle and weren’t really sure how bad this was going to get.

We sat in on some great conference calls with, I believe, AGA and committee members.

Russel:  Yeah, the Gas Control Committee at AGA did some really good stuff in this domain, for sure.

Ross:  Absolutely. It may be a good time to revisit — if you brought on some contract workers, or maybe had trained some folks that aren’t normally controllers but are aware of and are familiar with what the control room does.

If you’d trained them, if you’d OQed them to act as controllers, or standing controllers, maybe it’d be a good time to give them a refresher, right?

Russel:  Yeah, I think probably one of the most important strategies going forward is going to be to have a control room reserve. Have people who are qualified and can work the consoles, if it’s required. Particularly people who were previously in the control room and moved onto other jobs in the company.

Keeping them qualified and having them available, because the amount of reserve you need now is substantially more [laughs] than the amount of reserve you would normally need.

Ross:  Right. It’s not just, “Hey, it’s deer season, and everybody wants vacation.” There are some real things that are keeping folks out of the control room.

Russel:  If you think about it, if a guy gets exposed, and then he doesn’t know for a few days, and he’s working, well, depending on when that occurs within the rotation, he could take out half of the people in the control room.

Not necessarily with them being sick, but just they have to isolate, get tested, and screened. That’s quite upsetting to a schedule.

Ross:  [laughs] We’ve seen that impact with our favorite college football teams with all the contact tracing, but certainly, it’s true in the control room as well. As it relates to all that, and if you’re having these reserves — I think that’s a good word for them — the question arises for me, what do you do around managing their hours of service?

We worked to implement this in our FatigueMgr tool, but I believe what’s true…This is a case-by-case basis, depending on how close these people are to the control room, how likely they are to actually have to work a console.

For those people on the consoles, obviously, they’re OQ’ed as controllers. We’re monitoring their hours of service. We’re scheduling them as part of our routine.

These folks that are next in line, that may potentially, due to a fatigue-related issue —    somebody called in, they’re too tired, vacation-related issues, or even COVID related issues — understanding where that person is in regards to their hours of service.

Hours of Service, as we know, isn’t just the time worked at the console. It’s any time worked for the company. Tracking that, being aware of where that person sits, and understanding “who can we call in to fill in?” presents the least amount of fatigue risk, it’s an extra level of detail, but it’s incredibly important.

Not just for compliance, but for the safe operations of your control room.

Russel:  Yeah, absolutely. I think the summary statement, if you’re going to have a reserve, you need to have that reserve ready to go, particularly during this period of time… [laughs] You’re probably right. The period of time probably starts with opening day and goes through closing day.

That’s the key part of the year, because during that period of time, you’ve got all the holidays in amongst all of that. That’s also the time of year when people get sick. They tend to get sick during that time of year.

Ross:  That’s right.

Russel:  Let’s talk a little bit about how is PHMSA viewing all of this? I know that PHMSA put out an advisory notice providing some leniency, given COVID and what operators were going to have to do in order to work through this unique time that we find ourselves living in. What kind of guidance are we seeing out of PHMSA about this subject?

Ross:  To be honest, the last thing I saw is what you mentioned, which is the Stay of Enforcement that they issued early on in the COVID season, if you will, probably April ish, March, April. The takeaway from that — and it’s been a while since I read it — but, for me, what I read was, “Listen, you got to keep doing what you’re doing, if you’re able to do it.”

If, for some reason, you are short-staffed, for whatever reason, especially as it relates to COVID, but there are some alternative approaches that you can take, some deviations, almost, if you will, to your normal practice that PHMSA would accept. For example, an annual alarm management program effectiveness review. Those are expected to be done annually, not to exceed 15 months.

If you’re short-staffed, and the person that’s normally responsible for that is having to work the console or do some other things, or maybe he isn’t even able to come into the office due to staffing restrictions and HR policies, then, as long as it’s documented, that work’s able to be pushed off, with the understanding that it needs to eventually get done.

It’s not, “Hey, you get out of jail free card for not doing anything,” it’s, “Think about what the impacts are of COVID and limited staffing numbers, and continue to do the best you possibly can. Then account for what you weren’t able to do up to your normal standard.”

Russel:  Yeah, right. Yes, exactly. That’s the way I would interpret it. It’s not a free pass, it’s, “We understand. Do the best you can, but you better be able to explain to us what you did and why.” Which goes to documentation.

If I’m going to have deviations, if I’m going to miss my alarm review, and it’s going to be 18 months instead of 15, I need to document that, and explain why, and what am I going to do to get back on schedule.

Ross:  Right. Certainly as it relates to Hours of Service, understanding the difference between a scheduled and an emergency deviation and documenting those deviations falls, for me, under the same logic.

PHMSA has some expectations for what information needs to be documented when you identify an Hours of Service deviation. Those can be found in the FAQs. I looked it up in advance just so I’d sound smart on the podcast, but D-13 would be a place to look. I know we put that in the show notes.

There’s six or seven things that PHMSA expects you to document, and one of those is the reason for the deviation. Certainly given all that we’ve talked about, the staffing issues, the holiday season, the vacation requests, and then COVID as well, can all be reasonable causes for our service deviations.

Again, it’s incredibly important for us to be scheduling well so that we identify those in advance. There’s some challenges for how folks normally go about doing their hours of service tracking in part because the technology hasn’t necessarily always been there, and so folks will either use spreadsheets or timesheets.

Looking at those over a period of time and then even projecting those out can be difficult or limited, especially as you start to want to talk about on any given day how many hours of service does a person have and who can I call in if I have to fill a role.

Again, if I was going to give some advice, it’d be to take a look at how you’re going about doing those kinds of activities, the scheduling, the hours of service management and tracking, whatnot.

Think about especially now that there’s some increased levels of pain given the holidays and COVID, how can we do this a little bit easier, a little bit better, and look at a little bit more information that we may not have been looking at in the past.

Russel:  One of the things that’s a best practice or good practice is certainly, just to lever off what you’re talking about, getting out in front of the schedule, the other thing you can look at is add to that some guidance and some, here’s how you’re going to be scheduled through this period of time, and here’s who’s taking time off, and so forth.

What’s your strategy as an individual to be able to get the rest you need to get? One of the challenges for shift workers is sleep is so critical. If I’ve got people staying with me and I’m a shift worker, that can be problematic.

It’s hard enough when people that you live with every day and understand that reality and support you. It can get quite difficult when there’s guests over and you don’t have that support, or they don’t have that experience or understanding in terms of what it means to support somebody who’s doing shift work.

Ross:  That’s an excellent point, especially if you’re working an inverted schedule to what some of these other folks are doing that are in your house. They’re cooking, and banging pots and pans, or watch the football game, whatever it is, and you’re trying to get your eight hours of uninterrupted rest to reset. It can be a struggle.

Russel:  Making sure that that is part of the conversation when you’re putting together schedules, and you’re working up time off, and you’re trying to manage fatigue, being proactive in that conversation. Shift workers understand this. A lot of what we’re talking about, they get it. This is really just a reminder that it gets easier if you think about it in advance versus you wait until you’re in the midst of it.

Ross:  For all that’s going on this year, just some reminders for things we already know are always helpful. I know they are for me. What I’d say some of the best practices if you will is, that I’ve seen, is where companies will put together some literature to actually send home with the controllers. Certainly this time of year it wouldn’t be a bad idea to put out some information that can help be a reminder for families and whatnot as well.

Russel:  The other thing we ought to talk about too in the PHMSA domain or the compliance domain would be repeat deviations. Being able to identify something that’s happening over and over again that is causing a deviation and coming up with either a mechanism to resolve it permanently or a mechanism to manage the risk through the period of time you’re going to have this persistent deviation.

If I have a large swath of my control room get knocked out for a while because of contact tracing with COVID, what am I going to do while I’m running short-staffed? What am I going to do if I’m running short-staffed with people who don’t have current experience, bringing in reserve workers that haven’t worked a shift in a while, that type of thing? What additional things do I need to do?

A lot of that from a fatigue standpoint is just how do you provide some resources to those people so they can ask questions and get answers versus being expected to know it and handle it themselves.

Ross:  That’s certainly true. We talked about PHMSA Stay of Enforcement, and I hinted at the concept of scheduled versus emergency deviations, and these repeat deviations are part of that conversation as well.

You’re always going to have emergency deviations where somebody gets sick or they have a family emergency and they’re not able to show up, or like we talked about contact tracing’s an issue, and so they can’t come to work.

For scheduled deviations, if you’re in a place where the last Friday shift of every month it’s the same person, and that person’s over, they’re over their hours of service every single month, this is very loose example, but certainly having a good awareness of what your schedules are and what your hours of service is for your control room, you know, control room managers know where that deviation occurs.

If that deviation’s happening on a frequent basis, and not necessarily short term because of again those extenuating circumstances, but long term similar to AOCs that occur in the same way, PHMSA’s expectation in my understanding is that you would identify that and you would work to resolve that repeat deviation.

If in an audit, they’re seeing documentation for the same person, or the same period of time over, and over, and over again, they’re going to ask some questions about it.

Russel:  I’ve heard of specific instances where you had a controller who was the guy who liked all the overtime and would get as much as they could take. Because of that, they end up being the one who’s always over on their hours from an Hours of Service standpoint. That’s the kind of thing that PHMSA will jump on.

Ross:  Without a doubt.

You touched on something else that I want to circle back to for half a second is getting the relief controllers or the reserve controllers additional information and training, that’s incredibly important.

We talked about culture, and we talked about proactive practices, but in terms of them actually showing up for work, and having to respond, and manage your assets in the field, and do so in a way that’s safe, the mitigation, the third element is the physical mitigation tactics that are available to people in the control room.

If they haven’t been trained on what those things are, and a normal controller in the scope of their year, they’re doing annual fatigue training and education, per the rule. Based on when you offer that, it may be that those reserve controllers miss them. They may not be fully aware of all the different mitigation tactics that are available.

That third element of mitigating fatigue other than culture and being proactive is having some exercise equipment available, having the TV available, having coffee close by, allowing for the ability for your controller to walk away from the desk, still maintain situational awareness, maybe they got push notifications on a tablet, or cell phone, or whatever it happens to be, but allow them to take a walk or talk to somebody different.

If you are short-staffed, and maybe you’re consolidating your consoles, and you’ve got one controller working night shifts over the holidays, maybe you work out a system where somebody’s checking in on them every once in a while and giving them a phone call, “how you doing?,” that kind of deal.

Russel:  One of the other situations too when you’re short-staffed, if you’re short-staffed because you have people that have to isolate out of the control room but are otherwise available to work, that’s something where you can rethink a little bit what are the responsibilities and normal and abnormal operations, and how you might divvy up work to people who aren’t actually physically in the control room but can take some of the workload off of what’s in the control room.

What the control room’s very good for is situational awareness and streamlined communications. That’s what it’s ideal for. Some of the other things that are analytical tasks, or support tasks, or that sort of thing, they don’t necessarily have to be done from the control room.

Ross:  That’s an excellent point. Your reserve controller doesn’t, with all that’s going on, their ability to perform those tasks may not be as effective as your veteran controller. Saying, hey look, that alarm rationalization task that our controller’s supposed to be doing while they’re on shift or whatever it happens to be, maybe that gets pushed off until the veteran comes back or someone else.

When we talk about fatigue and the burden of different tasks, we actually, you and I were talking about this earlier in the day, certain tasks have certain effects on people and are weighted differently.

Certainly if you’re just struggling to make sure that you’re maintaining situational awareness because you’re a little more green than the rest of your co-workers, there’s added stress to that. That’s just more noise.

I think a similar argument could be made for hey, if you’ve got all kinds of extra stress at the house or wherever it is, then that noise has to be considered as part of the whole formula as well.

Russel:  Absolutely. Let’s put a bow on this. We had talked about this before we got on the microphone, Ross, but the other thing to keep in mind here is that there’s really two aspects to this.

One is the letter of the law and all the things that you’re asked to do to comply with the control room management rule. The other thing is really what are the best decisions for health and safety for the people and for the safe operations of the pipeline.

What would you ask people to take away from this conversation that we’re having?

Ross:  I think you lined it out really nicely. On one hand, there’s the elements of the rule around hours of service, controller scheduling, fatigue mitigation, and staffing, that all pertains to this philosophy, where we want to make sure that folks are able to recognize or respond to alarms and be fit for duty.

At the end of the day, on the other hand, controllers are people. They’re commuting and the roads are getting icy in certain parts of the country, not down here in Houston, necessarily. We want our folks to be safe.

All the things that we do for our controllers that support their ability to get home safely, and to have a healthy and safe holiday season is what we want to do as a community of controllers and controller managers.

Russel:  Look, thanks for coming back. It’s been way too long. We need to have another conversation. I like talking about the control room. Those are my peeps.

Ross:  Absolutely. It’s a pleasure. We are always learning new things and developing new things, and so the ability to take what we’re learning and share them with your listeners is a privilege. I hope this was helpful.

Certainly, if folks have questions or some additional information that they’re looking for, then they’re welcome to reach out to you or to me. I look forward to those conversations as well.

Russel:  We’ll provide all that information on the website, in the show notes, and such. Great. Thanks for coming back on board. Ross, Merry Christmas.

Ross:  Merry Christmas to you, too. Take care.

Russel:  I hope you enjoyed this week’s episode of the Pipeliners Podcast, our conversation with Ross Adams. Just a reminder before you go, you should register to win our customized Pipeliners Podcast YETI tumbler. Simply visit pipelinepodcastnetwork.com/win to enter yourself in the drawing.

If you would like to support this podcast, please leave us a review on Apple Podcasts, Google Play, or whatever smart device podcast app you happen to use to listen. You can find instructions at pipelinepodcastnetwork.com.

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Russel:  If you have ideas, questions, or topics you’d be interested in, please let me know on the Contact Us page at pipelinepodcastnetwork.com or reach out to me on LinkedIn. Thanks for listening. I’ll talk to you next week.

Transcription by CastingWords