On this episode of the Pipeliners Podcast, Mallory Gill of EnerSys Corporation, joins to discuss Pipeline Safety Management. 

The episode covers various aspects of pipeline safety management within the industry, such as maturity models, stakeholder engagement, leadership commitment, and the importance of implementing effective communication and feedback systems.

The conversation also emphasizes the significance of trust, competency, and agency in fostering a safety-oriented culture within organizations. 

Listen to the episode to learn more about the complexities and challenges associated with pipeline safety management, as well as strategies for continuous improvement in this critical area.

Pipeline Safety Management Show Notes, Links and Insider Terms:

• Mallory Gill is a Sr. Regulatory Analyst with EnerSys Corporation. Connect with Mallory on LinkedIn.
  • EnerSys Corporation is a frequent sponsor of the Pipeliners Podcast. Find out more about how EnerSys supports the pipeline control room through compliance, audit readiness, and control room management through the POEMS Control Room Management (CRM Suite) software suite.
• Pipeline Safety Management: The comprehensive approach to managing safety risks associated with pipeline operations, including the development and implementation of systems, processes, and procedures to ensure the safe and reliable transportation of hazardous materials through pipelines.
  • Pipeline SMS (Pipeline Safety Management Systems) or PSMS is an industry-wide focus to improve pipeline safety, driving toward zero incidents.
• 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.
  • Control Room Management is regulated by PHMSA under 49 CFR Parts 192 and 195 for the transport of gas and hazardous liquid pipelines, respectively. PHMSA’s pipeline safety regulations prescribe safety requirements for controllers, control rooms, and SCADA systems used to remotely monitor and control pipeline operations.
• Stakeholder Engagement: The process of involving individuals or groups who have an interest in or are affected by pipeline operations in decision-making processes, typically to gather input, address concerns, and build relationships.
• Maturity Model: A framework used to assess and measure the maturity of an organization’s processes, capabilities, or practices, typically based on a scale of levels or stages of maturity.
• Third-Party Assessments: Evaluations conducted by independent third-party entities to assess an organization’s compliance with regulations, industry standards, or best practices, often used to identify areas for improvement and benchmark performance.
• KPIs (Key Performance Indicators): Quantifiable metrics used to evaluate the performance and effectiveness of an organization, process, or activity, typically aligned with strategic objectives and used to track progress and make data-driven decisions.
• API (American Petroleum Institute) represents all segments of America’s natural gas and oil industry. API has developed more than 700 standards to enhance operational and environmental safety, efficiency, and sustainability.
  • API 1173 established the framework for operators to implement Pipeline Safety Management Systems. The PSMS standard includes 10 core elements. The API Energy Excellence Program followed this model to establish its 13 core elements.
    • The PDCA (Plan-Do-Check-Act Cycle) is embedded in Pipeline SMS (API RP 1173) as a continuous quality improvement model consisting of a logical sequence of four repetitive steps for continuous improvement and learning.
• 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.
• Dashboarding: The creation and use of visual dashboards or interfaces to display key metrics, trends, and data points in a clear and accessible format, typically used for monitoring and analysis purposes.
• Feedback Mechanisms: Systems or processes for soliciting, receiving, and acting on feedback from stakeholders, employees, or customers, often used to improve performance, address concerns, and foster engagement.
• Integrity Management (IM) (Pipeline Integrity Management) is a systematic approach to operate and manage pipelines in a safe manner that complies with PHMSA regulations.
• PHMSA (Pipeline and Hazardous Materials Safety Administration) is the federal agency within USDOT 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.
• Risk Mitigation: Strategies and measures implemented to reduce or eliminate potential risks and hazards associated with pipeline operations, typically involving preventive measures, controls, and contingency plans.
• Traceability: The ability to track and document the lineage, history, or provenance of data, processes, or activities, often used to ensure compliance, auditability, and accountability.
• Near Misses: Incidents or events that have the potential to cause harm or loss but are narrowly avoided or do not result in injury, damage, or adverse consequences, typically used as indicators of underlying safety risks and opportunities for improvement.
• Lessons Learned: Insights, observations, or knowledge gained from past experiences, incidents, or projects, often used to inform future decision-making, improve processes, and prevent recurrence of issues.

Pipeline Safety Management Full Episode Transcript

Russel Treat: Welcome to the “Pipeliners Podcast,” episode 325, sponsored by EnerSys Corporation, providers of POEMS, the Pipeline Operations Excellence Management System, operations, compliance, and safety management software for the pipeline operator to address safety program management, control room management, and field operations. Find out more about POEMS at enersyscorp.com. 

[background music] 

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 and to show that appreciation, we give away a customized YETI tumbler to one listener each episode. This week our winner is Jason Nickerson with Kendra Morgan. Congratulations, Jason. Your YETI’s on its way. To learn how you can win this signature prize, stick around until the end of the episode. 

This week, myself and Mallory Gill have a conversation about pipeline safety management. Hey Mallory, thanks for agreeing to come on the Pipeliners Podcast. 

Mallory Gill: Hi Russell, thanks for having me again. 

Russel: Why don’t you tell people who you are, what you do, and then we’ll dive into our conversation? 

Mallory: Sure. My name is Mallory Gil. I started with EnerSys Corporation about four years ago, working with our comply manager software, compiling code and regulation. That was a nice crash course in safety program management. 

Then worked for a couple of years with our CRM support and facilitator program, helping small to midsize operators with their compliance requirements for control room management. 

Then in the past eight months or so, I’ve transitioned to a role with our program suite tool set that’s aimed at more holistic pipeline safety management systems, process workflow, and stakeholder engagement, more compliance centric, and plan, do, check, act methodology and incorporating that into existing policies and procedures. Broadening the scope of our subject matter and our industry participation. 

Russel: For the listeners that don’t know, Mallory and I work together. She’s a key part of our team. She is young and full of energy and intelligence, and we often throw her into things we don’t understand and say, “Hey, Mallory, would you figure that out for?” That’s probably a more accurate description of your job, right? 

Mallory: Yeah. I was trying to make it sound a little more sophisticated, but I think that’s pretty on the nose. 

Russel: It’s a both and it’s not an either or. I wanted to have a conversation with you about pipeline safety management and capture it. We’ve been having this conversation as we work together and are working to support some of our customers. There’s a lot that we talk about that people that listen to this podcast would be interested in. 

Maybe a good place to start is to just talk about what is the current state of pipeline safety management within the pipeline industry? What’s your take on that? How do you get that take? 

Mallory: Sure. I can speak first to what the officially recognized state is per pipelinesms.org. They place the industry average at a maturity level of two or greater, which indicates that most operators have at least begun to develop their PSMS program. That they’ve started to incorporate PSMS into policy and procedure. 

I don’t position myself as a PSMS expert. I can only speak to my experience with the operators that I work with, and filling in the gaps, reading between the lines of what I see at our industry conferences, and what I’m seeing in practice. 

I would say that that approximation of maturity to or higher is a little bit higher than I would have expected. We’re starting to see with some of the midsize operators, a focus on adding PSMS to policy and procedure. 

I wouldn’t be surprised if the majority of the participants from the pipelinesms.org, those third-party assessments. If those are the larger operators. That’s certainly reflected in what we’re seeing at things like AGA. The PSMS implementation guidance is coming from the larger operators who potentially have more public pressure to implement proactive safety management systems and the management backing and the funding. 

As far as what I’m seeing in my day-to-day, I think it’s looking more like we’re starting to think about PSMS and attack this abstract concept, is what I call it most often. It’s still just a concept to a lot of operators. 

Russel: We ought to unpack a couple things. First thing is probably…I’ll do this. I’ll talk about the maturity model. You’re talking about the industry as a two or greater. If you go to the pipelinesms.org website and you look up the maturity model, they’ve got a one-to-five with one being the least mature and five being the most. 

There’s actually a zero. A zero is “I’m not doing anything.” One is “I’m starting to plan. I’m in the process of figuring out how I’m going to do PSMS.” Two is developing. I’m writing my process. My implementation is 50 percent or more complete. 

Three is “I’m implemented,” meaning my processes are developed. They’re documented. They’re in use. Four is sustaining. We have evidence that the processes are being used consistently. We’re assessing performance. Then five is “I’m implementing continual improvement.” 

What’s interesting to me about that maturity model is it talks about processes. I think when you get very deep into an organization at all, you’re not really talking process. You’re talking procedure. You’re talking to work we’re doing. The closer you get to the workers, the less aware the pipeline is about PSMS. I think that’s where we are. 

I think there’s a lot going on at the higher levels, which is why we’re at a two-plus, but we’re not to “The processes are in use, and we have evidence that we’re continually improving.” 

Mallory: I think there’s definitely some truth to that. It is easier to start at the high level and start to incorporate this commitment to a focus on PSMS in our policies, but the application and reality of taking PSMS culture and applying it in our day-to-day activities, I imagine, is much more challenging. 

Also, looking through the report that pipelinesms.org released in 2022, the focus has been on implementing stakeholder engagement. That was also one of the primary challenges, was stakeholder engagement. 

I wouldn’t be surprised if that weren’t just…There may be formal mechanisms that we’re using now to engage with our stakeholders, but potentially the quality of the material that we’re getting from our stakeholders…Are we asking the right questions? What kind of data are we receiving? 

How are we incorporating that culture of self-reporting in a way that’s…How are we incentivizing that? How are we ensuring that we’re resolving disposition and resolution of that information as it comes in? The management burden of then saying, “We have this stakeholder engagement. Here is how we plan to address it. 

Russel: I think that’s absolutely correct. The other thing you mentioned as we were preparing for this was that, so far, API has been doing an annual report on pipeline SMS and an industry “Here’s where we’re at.” The last one was for 2022. At that time, I think you said, over the course of the previous two years, there was a total of 12 third-party assessments that API was using to get its numbers? 

Mallory: Right. From 2020 to 2022, there were a total of 12 third-party assessments that are informing the industry averages and the benchmarking data that pipelinesms.org is releasing. Six of those assessments were in 2022 alone, so about six third-party assessments per year for various operators. 

Like I said before, I don’t know that this presentation speaks to the size of the operators that it’s assessing. The assumption is that if we’re performing an assessment, that we’re at least at a maturity level that enables us to look at policy and procedure and implementation. 

The way that I read this is we’re not doing planning assessments. We’re doing implementation assessments. You can’t do an implementation assessment until you’re at least at a maturity level of two, referring to the model, two being developing, but even two to three, developing and implementing a PSMS program. 

If you’re in your planning, your starting stage of one, I don’t know how you would do a third-party assessment unless it were a planning assessment of… 

[crosstalk] 

Russel: You have to be at least at the end of two before you can do an assessment. You’ve got to have all your processes written. Then you can do an assessment and understand where you’re at. If you’re not even there, it’s probably not even worthwhile to do an assessment because you know you’re a one or a two. 

Mallory: Taking that statistic with a grain of salt, I would be surprised if the actual industry average were two or greater. To pipelinesms.org’s credit, they are focusing on increased industry participation in these assessments. 

I would certainly be interested in seeing what the pre-work is for conducting a third-party assessment of PSMS. At what state do you have to be in your implementation or your development of your program to have an effective assessment? 

Russel: That gives me a great idea for something we need to do for a future podcast. I need to reach out to API and see if we can get somebody to come on and talk about the 2023 report when it comes out. I would expect that, at that time, we’re going to see a lot more third-party assessments having been completed. 

One of the things that was very interesting to me at last year’s API conference was they did a workshop at the beginning on PSMS. They completely filled the room, to the point that they were bringing in chairs. There’s people standing along the walls and all of that and a lot more engagement and a lot more detailed questions being asked. 

It was clear to me, just based on that level of people, that there’s more people leaning into PSMS. It was also clear in some of the other conversations around the room that when they really start getting into the “Do we have evidence? Do we have information we can use to improve,” people are really struggling with that now. They’re really struggling with that. 

Mallory: I was a wall stander in that particular AGA presentation. I think I know the one you’re talking about. I would be curious to hear what the theme was of the feedback that you were hearing from that. 

My takeaway was that it was a lot of “How are you defining your KPIs? How are you measuring them?” Not only “How are you defining KPIs,” but “Are the KPIs that you’re defining correct? Are they the correct KPIs? Should we be shifting? How do we start to improve KPIs?” Our ability to sustain and improve the program is only as good as what we’re measuring, was my takeaway. How are we actually… 

Russel: That was thematic throughout the conference. It was thematic in the PSMS workshop. It was also thematic in the committee meetings. I saw stuff on that in control room, quality management, field operations, and I can’t remember. 

That conversation was certainly thematic about what are the KPIs, how do we get the KPIs, are we all looking at the same things, should we be looking at the same thing, that kind of conversation. 

One of the things that I think is a risk we have as an industry, that if we don’t begin to answer some of those questions, we’re going to see the industry stall at a maturity of three. To sustain the momentum or build the momentum, we’ve got to start answering some of those questions. I think it’ll be very interesting, as we go to API and AGA this year, where that conversation is. 

Mallory: I agree. 

Russel: I would expect there to have been some progress made. I think the other thing that’s interesting to talk about is that one of the elements is leadership commitment. The reason for leadership commitment is we have a need for a cultural shift around what’s going on with PSMS and how people think about it. 

What are you hearing? What are you experiencing as you’re working with operators? What’s your take on that? 

Mallory: The operators that I’m fortunate to be working with, people care about safety, generally. I have a generally positive outlook on human beings. People care about safety. They care about the people that are working for them. They care about reducing incidents and protecting the environment. That’s a general sentiment that I see shared across the industry. 

I think one of the challenges in getting a really effective safety culture is how management responds to what the boots on the ground are telling them. First, the challenge is how do we incentivize and reward unbiased feedback from the people performing the day-to-day activities. That’s its own challenge. 

Then, once we get that feedback, what do we then do with it? How do we process it? How do we become transparent enough in our leadership, in our management, that we can move from implementing safety management systems to improving our safety management culture. 

That’s the feedback that we see in these…The testimonials, as I’m reading through this pipeline SMS presentation from 2022, is that the successful operators are the ones who change the company culture and that the people performing day-to-day activities are being proactive about managing risk and managing incidents. There’s a burden then on management to reward that and respond in kind. 

If you’re suddenly aware of the gaps in your own safety, there’s a large responsibility then to mitigate those safety concerns and respond to the people giving you that feedback. 

Russel: Yeah. I’m going to use some language that’s probably a little outside of the pipeline world, but what you have to do is you have to turn this into a healthy conversation. The aspects of a healthy conversation is I have to be telling you what I believe to be true. 

You have to be looking at that and providing me feedback about what you believe to be true about that. That needs to happen quickly. If I’m holding back or if I’m being cautious or am I concerned how you’re going to take the information I’m giving you, that’s a problem. 

Likewise, if you’re not open and asking questions seeking to understand as you get that information, from an assumption of…There’s value here. I need to extract the value. Then you’ve got to feed that back to the people that were giving you the input. They’ve got to know that this was received. It was heard. It got into the conversation. 

Culture, as I understand what’s in PSMS in terms of leadership commitment, is I’m going to dedicate the time and the resources and the effort to do these things. The real culture we’re looking for is a whole conversation that happens within the company, around getting better and getting safer. 

I think we’re moving there, but I think we’ve got a ways to go yet. I don’t think there’s resistance, so much as there’s confusion. 

Mallory: I think what you’re getting at is exactly what I’m interpreting as well. The tenets of the PSMS 1173 framework, it’s really all aimed at improving trust between management and the people performing the work. Creating such a healthy working environment that safety is just the byproduct of the culture that’s been created within your organization. 

KPIs are great, but we should also focus on a lot of soft skills KPIs, like how effective is our communication? I’m a communication major, and I believe very much in the power of effective communication. I think what you’re saying, Russel holds a lot of water. 

Russel: The other thing that resonates for me, Mallory, is your conversation, it’s about trust. I think you’re right, but I don’t think it’s trust as it goes to integrity, it’s trust as it goes to competency and capability. 

There was a great book. I don’t remember who wrote it. I’ve got in my library here at the house someplace called “The Speed of Trust.” There’s two reasons that people don’t trust you. Either you don’t do what you say you’re going to do… 

They both boil down to you don’t do what you say you’re going to do, but they come from either I don’t have the capability or the competency, or I don’t have the integrity, right? You have to have both those things. 

In this case, I think the trust we need is more around the competency and the capability. That has to do with maturing just our whole ability to do PSMS and have this conversation become a proper and effective part of how we conduct our business every day. 

Mallory: Totally. 

Russel: That is not an easy thing to do. That takes decades. I did an episode quite a ways back, probably a year and a half ago with a gentleman from the airline industry that was very involved in the airlines safety management program from inception. He talked about the journey they went through and some of the challenges they have. 

We’ll link that episode up. I don’t remember at the top of my head, but we’ll link that episode up in the show notes, if people are interested in going back and listening to that. It goes to this point of building that capability and competency. If I don’t know who to talk to, or if I don’t know who to give or how to give feedback, that impacts trust. 

Mallory: Yeah and you’re hitting on another point, which I think is agency. Not only integrity of trust. I’m receiving this feedback. You trust that I’m hearing it as it was intended and that I have good intentions about what you’ve told me. 

Also, are we giving the people managing these safety conversations and the key members of the team who contribute to culture, are we giving them enough agency that they can then be competent and capable of taking this feedback and doing something tangible with it and improving… 

[crosstalk] 

Russel: Define, for the listeners, agency. What do you mean by that? 

Mallory: Agency. It’s one of those words that I use a lot. It means a lot of different things, I suppose. I would say, in this particular context, agency means, to me, clearing the path for allowing change. 

That can look like funding. That can look like prioritization of the priorities as it relates to safety culture, giving these initiatives priority, and allowing them to do what needs to be done in order to mitigate some of the risk that’s identified. There’s probably a better definition. 

Russel: What I hear when you say, “Agency” is the equipping necessary to be effective in the role. 

Mallory: Thank you. 

[crosstalk] 

Russel: Part of that is training. Part of that is budget. Part of that is your authority within the organization. It’s also partially about mindset, like “I am the person that can make a difference.” The reality is we can all make a difference. 

When you look at process safety management in things like refineries and petrochemical, that agency, everybody has the ability to stop work. That’s a way to give people agency. 

Mallory: Thank you for saying, “Authority.” Authority is the word that was eluding me, but definitely. The agency isn’t just in management, like you said. The agency should extend to the entirety of the organization in such a way that people feel like they have the authority to operate safely and to report unsafe conditions. 

Russel: That doesn’t necessarily mean top-down authority. In this case, very much, it means bottom-up authority. 

Mallory: Completely. 

Russel: That’s an important distinction to understand what you mean by agency. The real agency you need, if you’re going to have real safety impact, is those closest to the work, those closest to the pipe. They’re the ones who can really make the difference. They’re the ones, by their daily decision-making, will impact, in a material way, safety performance. 

Mallory: Completely. That can talk to the challenge, both the initiative and the challenge of stakeholder engagement. 

Russel: The last thing I want to talk about as we’re going through all this is I think one of the things that the industry need is systems. Obviously, we’re a software company. We’re investing. We’re trying to figure all this out as it relates to systems. 

You and I had a very interesting conversation, at length, about some specific things we’re working on internal to our company, around the systems we have versus the systems we need to fully do this. 

I don’t think anybody currently has off-the-shelf solutions, from a systems standpoint, for doing PSMS. It’s too big. It’s too complex. I don’t know that any one person is going to be able to do it. What are your thoughts about the systems? What are people really needing? What’s needed and required at the current state of the industry? 

Mallory: It’s a great question. It is kind of the question. I agree with the sentiment that an off-the-shelf solution for PSMS would not be as effective. It sounds nice and it would be great if something like that could just be released and solve all of our problems around implementing PSMS. 

I think the reality is that we need processes that are flexible, that are dynamic, and that are accounting for new information. It’s really more about being agile with things like KPIs that we’ve already talked about. 

Measuring effectiveness and then also measuring whether the KPIs that we established early on in our implementation of PSMS, are they still the KPIs we should be monitoring? For me, what PSMS process looks like is a lot of self-assessment. 

It’s a lot of measuring, finding our metrics, and then reviewing them very religiously and determining if they’re effective, and being very intentional in the KPIs that we’re capturing. Like we said, not just risk data, not just incident data, but disposition and resolution data. 

Maybe even identifying what some of the soft skills are that we can do to improve the integrity of our application. 

Russel: Yeah, it’s really interesting. The conversation in industry has been very focused on KPIs, and I think that the industry is going to figure that out within existing tool sets. That’s data collection and dashboarding fundamentally. It’s a radical oversimplification, but that’s basically what that is. 

As I’m having this conversation, what’s coming up for me is what’s really required is a system for communicating. I have to have a way to provide feedback and then I need a mechanism for processing that feedback and cycling it back. 

The stakeholders got to be able to push the information up and the management folks, the folks that are doing PSMS, need to be able to analyze that data and push the answers back. One of the KPIs is how much of that data am I getting? How quickly am I turning it? 

Really that gets to the muscle and the key capability and competency that’s really going to be transformative from a PSMS standpoint. That’s a theory. I stated all that like it’s fact. Just to be clear, that’s a Russell Treat theory. 

Mallory: I’ll hit you with another. We said before this, that this was going to be a very accessible conversation because neither of us are experts necessarily. Yes, I think exactly that and full system through, implementation to policy and procedure, that there’s trace ability of what we’re doing with our stakeholder engagement, how that’s impacting execution of activity, how that’s impacting policy and procedure. 

We see that with integrity management operators, certainly what we call programs and activities to reduce risk. It’s not a completely foreign concept, right? If you work in any form of risk mitigation. That we’re tying specific programs and initiatives to near misses or incidents or areas of risk. 

It might just be expanding how much data we’re collecting and the nature of the programs and activities that we’re using to mitigate this risk. 

Russel: What’s clear to me is there’s a lot of work to be done in this area. 

Mallory: Yes. We’re at a place where it’s important to, we say this all the time internally, but it’s important to drive out ambiguity and just start somewhere. Start somewhere, implement, and adjust. I hope that the next time we have a conversation like this, we’ll have some very tangible data to draw upon, and some lessons learned from our own implementation of PSMS. 

Russel: Yeah, I would think in another year we’ll have some learnings from some learnings from the things that we have going on that we’ll be able to share. A lot of that’s very R&D-ish at the moment. 

Mallory: Yes, definitely. 

Russel: Listen, hey, thanks for coming on. For the listeners, Mallory doesn’t really like doing this. She’s really good at it, but she’s not really a fan of being a guest. She probably wouldn’t be here if she didn’t work for me, but I’m really glad she’s here. Thank you Mallory for showing up and really appreciate your contribution. 

Mallory: Yes. Thank you, Russel. I enjoyed being here. Thanks for having me. 

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

If you’d like to support the podcast, please leave us a review and you could do that on Apple Podcasts, Google Play, Spotify, wherever you happen 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 either 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.