This week’s Pipeliners Podcast episode features Jim Francis discussing this year’s AGA fall conference and its main takeaways, as well as comparing quality performance and risk performance and ways the oil and gas industry can learn from other established industries.
In this episode, you will learn about API 1173 and the ways it affected the industry, the importance of communication between different departments, and why policies and procedures should be viewed as performance documentation rather than compliance requirements.
PSMS Conversations Show Notes, Links, and Insider Terms:
- Jim Francis is the Vice President of SMS Consulting at ENTRUST Solutions Group. Connect with Jim on LinkedIn.
- ENTRUST Solutions Group provides comprehensive and dependable engineering, consulting, and automation services to pipeline companies, gas and electric utilities, and industrial customers.
- 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 annual AGA Operations Conference is the natural gas industry’s largest gathering of natural gas utility and transmission company operations management from across North America and the world. During the conference, participants share technical knowledge, ideas, and practices to promote the safe, reliable, and cost-effective delivery of natural gas to the end-user.
- 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.
- 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.
- KPI (key performance indicator) is a measurable value that is intended to show how well a business is adhering to its business model and strategies.
- 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.
- 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.
- Safety Management is a disciplined framework for managing the integrity of operating systems and processes that handle hazardous substances, preventing unplanned releases.
- Operational Qualification (OQ) involves testing the equipment to confirm that it operates as intended, within operating ranges approved by the manufacturer. This process must be performed after installation, significant maintenance or modifications, or as part of scheduled quality assurance testing.
- OQ (The Operator Qualification 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.
- Total quality management (TQM) is a management approach that focuses on continuous improvement. Organization engage all members to focus on improving processes and products to increase customer or user satisfaction.
- Energy Worldnet (EWN) delivers real solutions for Operator Qualification, Workforce and Data Management, Safety and OSHA Training, Compliance Services, and PSMS for the Pipeline industry.
- PHMSA (Pipeline And Hazardous Materials Safety Administration) protects people and the environment by advancing the safe transportation of energy and other hazardous materials that are essential to our daily lives. To do this, the agency establishes national policy, sets and enforces standards, educates, and conducts research to prevent incidents. They prepare the public and first responders to reduce consequences if an incident does occur.
- NTSB (National Transportation Safety Board) is a U.S. government agency responsible for the safety of the nation’s major transportation systems: Aviation, Highway, Marine, Railroad, and Pipeline. The entity investigates incidents and accidents involving transportation and also makes recommendations for safety improvements.
- DIMP (Distribution Integrity Management Program) activities are focused on obtaining and evaluating information related to the distribution system that is critical for a risk-based, proactive integrity management program that involves programmatically remediating risks.
- Corrective Action Preventive Action (CAPA) is the process used to examine and solve problems, identify causes, and takes any corrective actions, all in order to prevent any recurrences of the root cause.
- Pacific Gas and Electric Company (PG&E) incorporated in California in 1905, is one of the largest combined natural gas and electric energy companies in the United States.
- ASAP report (Aviation Safety Action Program report): The goal of the Aviation Safety Action Program (ASAP) is to enhance aviation safety through the prevention of accidents and incidents. Its focus is to encourage voluntary reporting of safety issues and events that come to the attention of employees of certain certificate holders.
- LDAR (Leak Detection and Repair) regulations require operators to craft a program that specifies the regulatory requirements and facility-specific procedures for recordkeeping certifications, monitoring, and repairs to prevent damage to people and the environment.
PSMS Conversations Full Episode Transcript:
Russel Treat: Welcome to the “Pipeliners Podcast,” episode 303, sponsored by Enersys Corporation, providers of POEMS, the Pipeline Operations Excellence Management System. Compliance and operations software for the pipeline control center to address control room management, SCADA, and audit readiness.
Find out more about POEMS at EnerSysCorp.com.
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 that appreciation, we are giving away a customized YETI tumbler to one listener every episode.
This week, our winner is Paul Judge with Northwest Natural. Congratulations, Paul. It’s about time you put in your application to win. Your YETI’s on its way.
This week, we spoke to Jim Francis with ENTRUST Solutions Group about the PSMS discussions here at the AGA fall committee meetings. I’m sitting here with Jim Francis with ENTRUST Solutions. You guys keep changing your name.
Jim Francis: No. We changed it once, just making sure it sticks. There’s a long history with EN Engineering. It’s one of those things. Get comfortable.
Russel: I know. Exactly. I’m sitting here with Jim, as you can tell. We’re at the AGA fall committee meetings. Jim’s spent more time doing it than I. We went to the PSMS workshop and then we spent some time in the quality management committee.
I thought it’d be good to get Jim who clearly is an expert… You should hear the conversation in the room, everybody asks a question, and they turn and they look at Jim. They do a presentation, they grit their teeth and are like, “OK, is Jim going to ask me a question?” Jim is the guru in this domain. Welcome back to the podcast, Jim.
Jim: Thanks, Russel. It’s great to be back.
Russel: I thought we’d talk a little bit about the workshop and what the workshop covered. It was a lot of information. From a high points perspective, what did you take away from the workshop?
Jim: What I appreciated about the way the workshop was structured. I thought the AGA did a great job of building upon itself. We started off with a broader topic. Then, I got to present. Then, each of the subsequent presenters added layers to it. They added a little more depth to the presentations and the topic.
I think the thing it starts to demonstrate is that we’re getting more knowledgeable about this. We’re getting more practitioners around all of this. We’re starting to get a little bit better at doing it. Each of us has a little bit of a different way. Now, it’s created a greater learning opportunity forward.
I think back eight years when we did the first workshop. Nobody knew what they were doing.
Russel: Yeah, and the attendance was a little different, too.
Jim: Yeah, vastly. It was a bunch of, largely, integrity engineers, or compliance specialists, or whoever. They had the RP stuck on their desk and said, “Go figure out what this thing is.”
Now, there’s executives in the room. There’s people at all layers. People who own very specific processes. People are trying to figure out how this makes a difference culturally with your company. That part of it’s great. I just appreciate the fact that it’s grown in that way.
Russel: I would say that’s where we’ve made the most progress, is that everybody’s leaning in. When did PSMS 1173 get published? What year was that?
Jim: I don’t know if it was officially 2015 or 2016? I know I have my first copy from 2015. I think I got it before it was actually published. I knew somebody…
Russel: You were working on the committee, so you got the prerelease.
Jim: No, I was not. I was not on the committee, but I knew somebody who was, and so… Yeah, that’s right.
Jim: It’s old news now.
Russel: Don’t let anybody know.
Jim: It’s funny, because I have a copy that has a printed name and whatever on there that says, “Do not distribute.” It’s not even my name, but I’ve been carrying it around for eight years.
Russel: Eight years that this standard’s been in place. It’s interesting to me, when you talk about the standards process, particularly new standards, how long it takes to write them, get them into a place where people understand them. It’s like a 10 to 15 year process before the industry gets any real lift. It takes a long time. It’s just the nature of things.
I wanted to talk to you a little bit about the presentation that you made. I’ve seen you make this same presentation. This is your mantra. This is the drumbeat, the Jim Francis PSMS drumbeat, if you will. You talk about, “We want to be the safest utility.” What does that mean?
Jim: To me or to the industry, because I’m not…
Russel: Probably both would be a good way to handle that.
Jim: It’s funny because I’m not really sure that we know the answer. When I wrote that, it was this rhetorical question or rhetorical response to it. I’ve heard people utter this many times. The response I normally get is there’s no response. I think it’s just because they’re still internalizing what it means to them.
A lot of times, we’re still measuring safety from the occupational health and safety perspective. It starts at serious incidents. It’s those kinds of things.
Russel: Slips, trips, and falls.
Jim: We’re getting way beyond that, but I don’t know that all the KPIs and the metrics and those sorts of things have caught up, as of yet. The AGA did some modifications to their benchmarking and the things that they’re issuing awards on last year, which I think is great.
Now we start getting more into the leading side. We get away from just the injuries. Those are still important. They’re a part of the equation, but it’s got to be some combination of culture, system performance, the outcomes and the things that you do, and the measurement and reduction of risk.
That’s what the RP is all about. 1173 is all about reducing risk. Once we can have that discussion and we can start to understand that, then we can start to see.
I do think it’s a little bit about how well the organization functions. That was the point of my presentation. Let’s now look forward to some point in the future where we start to understand, as a company or as an industry, the management system, not just the safety management system, but how, overall, companies function.
Russel: This is actually thematic, what I want to talk about in this conversation. To me, while that was embedded in the PSMS workshop conversation, it didn’t really show up until we got to the quality management committee.
I’m with you. I think that if we’re going to get a step change, an order of magnitude improvement in safety performance, it’s about management systems. I’m not talking about any particular piece of software. I’m talking about the structured approach to how you run your business. Every business of any size has a management system.
We have to rethink the ones that we have in the industry and think about what those management systems need to look like going forward. You talk about the strategic plan and the operating plan and the PDCA cycle and how all that comes together.
I think what I like about your presentation and I think one of the reasons you get quiet responses is you throw a really big net. You’re bringing up…When a company looks at that, they’re like…You cock your head. You think about, “What’s that really going to take?” It’s big.
Jim: I appreciate the fact that maybe the net is the reason why some people don’t ask questions. When I finished the presentation, it was like, “Somebody’s got to ask something.” I had to put some friends on the spot.
I think the challenge is… This is what we see when we go into a company to do gap assessments, a lot of times. I’m even thinking back on my own experience. Most of my prolific years of working at a utility were at Vectren.
The beginning of that time, we didn’t really have a great management system in place. We didn’t do corporate planning. We didn’t really have a corporate plan and a business unit plan and all the structure that drove the alignment between the corporate goals and the objectives and what the departments were doing.
Russel: Very few companies do.
Jim: There’s things that they do that they produce those sorts of things and the outputs, but the structure’s lacking. When I was preparing for this, one of the things I appreciated was…I read “Harvard Business Review.” They talked about the management system and the structure around it. They talked about having defined processes and procedures to drive it.
I found another article, more in the business consulting side, that had a very similar view. We preach this when we talk about 1173. You’ve got to build the processes and procedures to execute this in the right way.
Russel: I could go on about this forever. It’s very interesting. I’ll just share my experience. Historically, I started coming to these AGA conferences going to the measurement committees, many, many years ago. For the last 10 years plus, I’ve been going to gas control.
As our company’s grown and evolved and leaned more into the whole safety management stuff, I’ve started going to some of these other committees, this trip. I haven’t been able to go for the last couple of years because AGA and API were booking on top of each other.
It’s an area where I’m looking. There were a lot of questions that were coming up for me. I didn’t ask them in the room because I’m like, “I’m brand new here. I want to get to know people a little bit before I start doing that.”
People that listen to this podcast or know me personally are like, “Really, Russel? You’re being quiet? I don’t believe it.”
As I’m listening to all this, I’m trying to think about really what is our industry maturity level around all this. We’re still very, very new.
Jim: I agree. It’s funny. I was actually thinking about the cycle. We’re talking about eight years in, nine years in. Could you imagine if, in the integrity management world, when 2004 came out…We had a 10 year deadline to get all of the pipelines assessed.
If we had felt like where we’re at right now in terms of the maturity around that process and if we weren’t there eight years in, we’d be in a bit of a world of hurt from a compliance perspective. Everybody got on board. They figured out what they had to do. They got really intense about it. They put the resources into it.
I think perhaps because 1173 is a voluntary standard and because you’re starting to touch much more of the organization and the way your business functions with this, it makes it more complicated for folks. I think a lot of people who are in the room that are trying to run 1173, they don’t know that they can influence their executive team and the way that they operate the business.
Russel: Or they don’t know how. They don’t know what the mechanism is. I think you’re exactly right. That’s the exact same thing I’m seeing.
When you talk about an integrity plan or control room management, which I’m more familiar with, control room management was published in 2010. We’ve been under that for about 13 years. You have to take two years out because of COVID, or maybe three because of COVID plus Colonial blew everybody’s budgets up.
10, 13 years’ maturity into it, everybody did something day one. Now they’re trying to do the right thing. That’s different. You can do that in a departmental plan. I can get something in place, but it still takes the same level of time to do the right thing. I think 1173 and safety management is much more complicated because it’s cross departmental.
Jim: In the quality management committee, Lauren Anderson, she talked about NiSource’s journey. What I appreciated about her discussion is you could start to see all the connection points, too, and the complexity. She has a brain to be able to think systematically through it and how it does…
She spent as much time talking about the cultural implications and how you had to influence the organization as much as she did about the nuts and bolts and the processes that you put in place.
Russel: And the subtleties of how do you go into a department to do something new and inspect their work and get them to lean into it with you.
Jim: You’ve got to put it in their perspective. The front line guy needs to be as committed as the executive. They all have a different perspective on it.
Russel: Everybody needs to understand what we’re trying to do. Everybody needs to understand everybody’s role in trying to get it done. For me, it’s that whole management systems culture, the real cultural element.
The other thing about Lauren’s presentation was she was talking about the size of her organization and some of the things she’s picking up. They actually have tech writers. They’re writing the standards. They’re like, “Oh, you’re running the management system. Oh, that makes sense. You’re determining what needs to be in the management system and how to implement it and what’s the appropriate…”
We talk about inspection or auditing or that sort of thing. Really, it’s just governance. I’m just trying to make sure that what I’m trying to accomplish is actually what I’m accomplishing.
Jim: And, once again, at all those levels. Everybody’s got a role to play in it.
Russel: Exactly. There were a couple of other things that were interesting, the whole contractor conversation, what the contractors are doing. The thing that was surprising to me about that is the larger pipeline contractors are really leaning into this hard. They’re actually in front of industry. Their maturity levels are ahead of where the industry’s maturity levels are.
It came up. To me, again, it’s an interesting conversation about how we tend to have these presuppositions that our people, because they work for the pipeline, are better qualified than the contractors, because they don’t work for the pipeline.
Jim: I think, in the contractor space, it tends to be the fact that maybe they’re a little more narrowed in what they do. If I’m a construction contractor, I’m doing construction. I have all the tasks and all those things.
It’s not like it’s not complicated or there’s a lot of pieces to it, but they’re not doing engineering. They’re not doing finance. They’re not doing a regulatory strategy. They’re not doing all the things that a utility does.
Russel: There’s also a big difference between building and operating, a huge difference.
Jim: That difference, I think, allows them to be a little more nimble about getting to this, so their ability to focus their people in on the things that they’ve got to do and the tasks that they have to cover and making sure that those things are done safely.
Russel: It also becomes a value proposition for the contractor, from two perspectives. If I’m actually building management systems to execute my work, I’m going to drive efficiency. In contracting, you make your money by not spending the marginal dollar.
Jim: What’s interesting too… This is one of those things that I often have client conversations where you ask the question, “Why is it that you have a nice structure to hold your contractors accountable, but we don’t always apply that same principle or that same level of depth in the process to our own employees?”
In the quality committee, at the end, when they were talking about technical training, there was a lot of discussion about the OQ qualifications and some of the other things. It’s like, “Wait a minute. We’re not inspecting our employees, but we’re inspecting our contractors. Because they’re employees, we expect them to be perfect in what they do. They know all our processes and procedures.”
The reality is they’re up to the same, whatever, volumes and volumes and volumes of procedures. They can’t possibly know it all. Why do we not execute a quality process on our employees in the same manner?
There’s a little bit…We don’t want to offend them. The contractors have perhaps more to lose by not making sure.
Russel: I’m not as worried about offending the contractors, for sure.
Jim: Exactly right. I don’t know. It’s an interesting dynamic. I think there’s probably a way to solve that without…
Russel: I actually think these conversations are healthy. What they do is they expose the current culture that exists. They raise really relevant questions like, “Why is that different?” That’s a really relevant question. There’s probably some valid reasons. There’s probably some invalid reasons. We’ve got to get to those answers to know what it is we’re trying to measure.
Jim: I think back to my own experience being responsible for pipeline safety compliance. Whenever there was an incident, the question that we would get asked is, “How do you know that your contractors know your processes and procedures?” I don’t know that I ever got the question of, “How do you know that your employees know your processes and procedures?”
It was just a fascinating thing as I think back on it. Maybe because we had better control. They could see the technical training programs. They could see our policies. They knew exactly how they were getting to our employees, in some cases because the pipeline safety inspectors were former employees of ours.
Russel: I sat in the field operations committee because I wanted to hear the conversation about leak detection and repair. That was an interesting conversation. There’s a whole podcast there. I won’t go down that rabbit hole.
What was interesting to me is they were also talking about OQ and OQ challenges, particularly around, “How do I demonstrate span of control? How do I demonstrate that the people performing the work are qualified to perform that work?”
That seems relatively straightforward, but like everything else when you peel the layers back, it’s not. There was some really interesting conversation there about, “Is it the supervisor that’s the governance? Is it the crew boss that’s the governance? Is it the person doing the test? Where’s the governance? Where is the control?”
I guarantee you not every company does it the same. Everybody’s going to be doing it differently.
Jim: Yeah, we should have put the quality management committee and that committee together. We had a similar discussion late in the day when we were doing round tables. Same sort of thing came up.
Mike Eutsey with Montana Dakota Utilities, he’s got a longer history on the quality side. He starts to see how what he’s doing starts to affect that. Still, that question of, “Who’s leading in? How do you know you’re in span of control? Does your work management system enable that, or does it falls under that foreman, or that supervisor, or whatever?”
Russel: Exactly. My MBA was a typical MBA, but it had a focus in quantitative and quality management. We looked at TQM systems and manufacturing, in particular. When TQM was first rolling out into manufacturing, there was a lot of work to understand where the nodes were in the manufacturing process and then what was important about optimizing that node.
As they got that experience, they started to understand the impact of optimizing this node versus these other nodes. Then you get to the system. Where we are – I think – is we’re still trying to figure out what the nodes are.
Jim: Sam Foster and Jessica Hill, they did one of the presentations on risk management. They got to that a little bit. They did, I’ll say, a modified process hazard analysis where they’re not going through the same structure that you do in the chemical requirements, but yet they applied the same principles.
I think it’s to do exactly what you do. Start dissecting it at the node level so you can trace the process through, figure out where the risks reside within that, and then try to resolve, and mitigate, and improve upon your controls around it.
Russel: If we’re starting to get there in pipelining, then we’re starting to get to a level of maturity where we’re going to be able to see some transformational change.
Jim: Yeah, I agree.
Russel: Certainly, some of companies are getting there. It’s interesting. It’s all over the map as to where they actually are.
Jim: It’s funny, Becky Naslin and I were sitting at the committee meetings together. At some point…She’s relatively new to the gas side. She’s spent a long time on the electric side of the business. She came over to the gas side.
Right now, she’s like a sponge, learning all of this stuff. She asked the question of, “If we just had gone down the path of all having common processes…”
It’s like, “OK, yeah. That would have been great, but we would need to have started 100 years ago, actually documenting what we did.” Unfortunately, we all had our slight variation on the same theme.
Russel: The airline industry went through this exact same thing.
Jim: Yeah, exactly.
Russel: It took them 30 years to mature their program and figure out where the nodes are. We’re not the airline industry. There’s notable and material differences, but there’s a lot more similarities than there are differences.
Jim: That’s the beauty of the safety management systems and all these systems. The standards around quality management and safety management. They all say the same thing, essentially. You can pick up an airline safety management system. You can figure out how to apply it to pipeline safety.
Russel: Yeah, but the real value in the airline system is in the tech orders. I’m an Air Force guy. My first assignment, there was an aircraft incident. The lead incident investigator had the desk right next to mine. I learned a lot.
Jim: I bet.
Russel: In the aviation world, there’s a tech order for everything. Everything you do, there’s a tech order that explains how you’re supposed to do it because it’s super technical, super complicated. You’ve got to dot all the Is and cross all the Ts.
The tech orders are very detailed, “Here’s how you service this particular part.” In this particular case, it was an aircraft incident. It was an A-7, which had folding wings. The aircraft on takeoff rotated right. The pilot couldn’t correct it and ejected during takeoff. I was there. I actually saw the incident happen.
Anyway, to get to the bottom line, they found out that they didn’t service the pins. This is an aircraft that went to the logistics depot where they take it all apart, service everything, and put it all back together. Basically, they have the same airframe, but a new aircraft.
They didn’t service these pins. They went to the mechanic. Then they went to the tech orders. They figured out that it wasn’t in the tech orders to service the pins.
To think about where we are in aviation, how would we get there in pipelining? You think about that. How many tech orders would we need at that level of detail?
Jim: It’s an interesting issue. I think about my own career – I started off as a transmission engineer – the level of detail with which we created drawings and the material orders and all that sort of thing.
I look forward many years and even now, I see we’re trying to tell people exactly how you operate the system in which order and which valves you’re turning while you’re doing a construction project. 20 years ago, 25 years ago, we weren’t really doing that.
I think there’s more of an evolution around it. I think OQ has helped push some of it. In the quality management committee, EWN did a presentation where they talked about being more operator specific and aligned to the processes and procedures.
When OQ started, it was all like, “Let’s create a generic standard that you can measure people against.” That just really doesn’t fly. You meet a compliance requirement, but you don’t really meet the intention of what it’s trying to accomplish, which is to make sure your people are operating safely.
Russel: You move the needle, but only so far. Now, at least you know that everybody has a basic understanding, but it’s not until you understand how to do a particular job with a particular tool on a particular system that you’re really there.
Jim: I remember, many years ago, I had an executive vice president that I worked up through. His comment to me was, “We do not want to create a set of compliance standards that are so restrictive that we can’t meet them.”
You hear this from time to time. My response is, “So what if you put more detail than the compliance requirements in there?” That’s the right thing to do. That’s what we should be doing. We still have a little bit of that mentality out there.
Fast forward many years, the SMS and 1173 drives you to more of that structure. That’s the way you should be. Just in the way you described it, we haven’t quite gotten to that level of detail…
Russel: That’s an adversarial focus with the regulatory authority versus a collaborative focus. That’s a whole ‘nother conversation. That varies from state to state and from region to region within PHMSA and such.
I’m a firm believer that the minute you’re able to go three questions deeper than the auditor or the inspector, the inspector is going to lose interest. It’s like, “Clearly, you know more than I do. I’m moving on.”
Jim: I always tell my engineer friends, when they go to a commission hearing, as an example, “Look, you’re talking to lawyers and accountants. You know more than they do, so explain what you know.” At some point, they’ll back off. They’ll go, “OK, this person really knows what they’re doing.”
Russel: That’s right. They’re going to ask you all kinds of questions from all kinds of ways, many of which you’re going to think are silly. Again, they’re doing a different job. They’re managing a different problem. I did not manage to get to the NTSB presentation and the workshop. What was your takeaway from that piece?
Jim: One, first, I appreciate the fact that the NTSB actually comes in and shares a little bit about more current incidents. Historically, there was this lengthy delay by the time you might hear something. You’re waiting for their final report. That part of it, I thought was great.
What I would hope for, at some point…Sara Lyons talked about this. I’ve heard her present – I don’t know – four or five, six times. She seems to show up at every one of these. I appreciate the fact that they keep coming back. There’s a lot to be gained from what they know.
One of the things that struck me was that she talked about the thousands of incidents that the NTSB investigates, not pipeline, but all industries, a lot of them on the airline side. The one thing I hope, at some point, that we’re going to get to is they’re going to start talking about where they see the most common breaks in the system.
I don’t care whether it’s an airline, whether it’s a pipeline, whether it’s an automotive. There’s a system aspect of this, where they can start to see…We see the breakdowns at leadership commitment, or we see the breakdowns at the communication and the training pieces of it.
There’s something underlying those sorts of things that we can gain from as an industry, to start focusing our conversations.
I feel like we haven’t gotten to the point as an industry where we’re talking about the risks and the more specific details where we’re all standing in a room, going, “Oh, my God. We have this common issue. Now we’ve got an industry issue. Let’s start to address it in that way.”
Then the AGA can focus on others before it becomes a regulation. That’s what we’re trying to avoid, is the next regulation because it’s driven by some incident.
I think the NTSB has some insight there. I think the challenge…Like Sara said, she’s focused on the pipeline side. She doesn’t necessarily have the purview to all of it, but the NTSB as a whole does.
I think that’s where they’re part of the system. They’re part of it at the back end of it. On the other hand, they have value to bring to the thing. I appreciate when she comes and shares what she learns.
Russel: I find the NTSB reports fascinating. I have a whole premise about where we’re going to have to get to to really be moving the needle in safety.
One of those is I think we need to create a certified pipeline professional role that’s more about, “I understand all the incidents that have occurred. I understand what the corrective actions were and why. I’m certified in the knowledge of what goes wrong.”
In Canada, they do this thing. If you’re an engineer, you get a ring. It’s made from a bridge that failed. When you get your PE, they give you a ring. It’s to remind you that your decisions matter.
We talk about where the higher level of authority is. Is my accountability to my company, or is my accountability to my profession? We need a level of accountability to our profession. I think most engineers and pipeliners would have said that that makes sense. A lot of us feel that way.
It’s not something new, but I think part of this might be formalizing that a bit. That’s the way out in the future. I don’t see that happening anytime soon. I think that the stuff that the NTSB does lends itself to that kind of training because there’s so much value there.
Jim: Manson Seto came up and talked about the ORDC and what AGA is doing there. They’re really…
Russel: ORDC? You’re going to have to decode that for me.
Jim: Oh, my God. I can’t remember what they are… They’re basically looking at all of the data, all the incident data, all the things that have been reported. They’re trying to break it down and understand, “Where might we have some trends? What can we learn from that data to try to drive some critical thinking within the utilities and what they’re doing?”
I think about all the NTSB reports and the history there and somebody who can sit and read and dissect all of that at that level of detail. Once again, they can start getting at the systematic things that are broken within that, which may not show up easily in a number, in something that’s reported.
The context matters. That’s what I think a lot of these NTSB reports provide you, is the context necessary to understand why the result happened. Then you can start to connect it back to your system and the things that you’re doing.
Russel: I think that’s well said. I think that’s very well said. You’re right. I think any engineer in our business would say this. There’s a level of what we call engineering judgment that comes out of experience. I jokingly say, “What’s experience? Experience is what you get when you didn’t get what you wanted.”
What is wisdom, or, another way to say that, what’s engineering judgment? That’s learning the right lessons from the experience. We need a better way to learn from the experience of others.
I commonly ask people, when I’m doing training or workshops or something like that, “Are you familiar with the Bellingham incident? Are you familiar with Marshall? Are you familiar with San Bruno and Texas City?” and on and on, all these pipeline and gas industry events. It’s a little appalling how often people say no.
Jim: Think about our industry and how much it has turned over. I went to the DIMP committee. I did a presentation on the relationship between DIMP and PSMS. I look around the room. I go, “Some of these people, I probably hired.”
Many of them are probably five years out of college. They were not born, maybe, when…I sat next to somebody yesterday, and they said they were born in 1992. I’m like, “Oh, my God. That’s when I graduated from college.” I started my career…
Russel: You’re younger than me, buddy. It gets worse.
Jim: That history matters in why we do what we do. Resurrecting that and making sure people understand that…A couple years ago, I actually invited Bruce Brabec to my team’s safety meeting. It was my entire organization, 150 people that I worked with. Some of them are on the electric side of the business. Some are on the gas.
He was very gracious to come in and talk to us about his experience. He appreciated the fact that there was a group of people here talking about safety and pipeline safety and being very intentional about trying to drive risk out of the business.
He didn’t really have, necessarily, an appreciation for that’s what utilities are doing. We are spending our time on that, making sure people understand that. I was surprised at the number of people in the room that really didn’t understand the incident, didn’t remember it, necessarily.
Russel: That context is really, really important. Whenever I’m teaching technology, I always teach the history of fundamentals. I always teach history because it’s so important to understand where that technology came from in order to be able to work with and troubleshoot that technology.
Jim: I agree.
Russel: It’s the same thing with systems, the same thing with safety management. Talk to us about the CAPA conversations through the course of the workshop and the quality management committee. We should decode CAPA. That’s…
Jim: Corrective action.
Russel: Corrective action, preventative action.
Jim: I think a lot more companies have had a longer history at doing CAPA. I think somebody I forget who it was – they referenced maybe PG&E. I remember hearing PG&E, several years ago, after San Bruno, talking about their CAPA program. They would have 10,000 of them.
My God. That’s an overwhelming amount of information to be able to manage and things to be able to drive, but it’s a way for that localized reduction of risk, if you have a program like that. We’re starting to see more and more companies have that kind of program.
I think the opportunity here lies in how you connect those CAPA programs to your SMS risk management processes. They are sort of hand in hand, or they should be. I forget who was talking about it yesterday, or maybe somebody asked a question. They were starting to connect the dots between the two of them.
Once again, it’s a lot of data. It provides a lot of information to you. You can leverage that. Much like an incident, you can leverage that to start to really pick apart where you have systemic issues and the things that you’ve got to go resolve.
Russel: I wish I could remember the gentleman’s name. I brought on a gentleman who’s a pilot and had been involved in aviation safety management for 30 years. He talked about the aviation journey. He talked about how American Airlines was the first to put in what is now called the Aviation Safety Action Program, ASAP. Very similar to CAPA, but it’s industry wide.
American Airlines was the first to do it. They started capturing all this information. They shared it with the regulators. The regulators’ first reaction was Oh, my God. You guys are awful.” They said, “No, we’re not. Everybody has this going on, but now you’re seeing it. With everybody else, you’re not seeing it.”
When they were talking about the number of CAPA events, I’m thinking, “Hey, everybody has all that out there. The difference is you’re actually starting to get it accounted for and put a plan together to deal with it versus it’s there, and you don’t know, and you’re not doing anything with it.”
If you find 10,000 CAPAs, then you’ve got 10,000 things that could become an incident.
Jim: That’s right. I think this is another set of data…Think about the RDC and what they’re doing. Now, if you could layer a company’s CAPA program and the things that they get out of that with this data now…
Russel: That’s exactly what happened in aviation. American Airlines did it. They started getting some regulatory benefit because, as they started to share the stuff with the regulators, the rules changed and it became…There were less punitive actions occurring because the regulators wanted the data because they wanted it across the industry so they could help the industry get better.
I think we have the same kind of opportunity, but we also have the same kind of problem. One company had to do it. They had to start sharing their experience. They had to start sharing their experience with the regulators. That started getting to multiple companies. Now, that’s throughout the aviation industry. It’s standardized.
Every company has ASAP programs for each of its domains, pilots, maintenance, and so forth. The industry has CAPA programs. The top 50 or 100 things that are in each airline go industry wide. It’s a whole process that takes it all the way through. We’re a long way from being able to do that. This is the first step in a long journey.
Jim: We spend a lot of time talking about effectiveness assessments in the quality management committee. The connection between your CAPA program and your PSMS risk management processes and the program there, are you servicing the things that…?
If you’re starting to collect risk, are those same kinds of things showing up in your CAPA program? If they’re not, why not? There’s a disconnect. There’s an opportunity to leverage the data between the two of them to start to see where you have gaps within your own organization.
Russel: I absolutely agree. I want to transition a little bit and talk about the conversation in the quality management committee. There was a conversation going on about safety, risk, and quality performance and a lot of conversation about how are you trying to connect those two dots.
I found it really, really interesting. It’s a really good, healthy conversation to be having. Quality performance and risk performance are two sides of the same coin, just different ways of looking at the same problem.
Jim: Yeah. Look at your processes and how well they’re performing, or look at the outcomes and who’s being impacted by it.
Russel: Am I getting to the outcomes I want for performance? Am I mitigating the outcomes I don’t want for risk?
Jim: That’s why, in my presentation, I started going, “I hear more and more companies go, ‘I don’t have this quality program over here,’ or, ‘I have an environmental management system,’ or, ‘I have an…'” They operate them all independently in silos. They haven’t spent the time to see how they’re connected.
That’s one thing I appreciated about the quality management committee a couple years ago, lining all those standards up and saying how they aligned so that it becomes in your face. You should be able to connect the dots between the two of them.
The challenge we have is that so much ownership into a company’s program or a person’s programs that we hear people that they started with quality and they’re so leaned into that that they feel like this SMS thing is maybe a little bit of a distraction or it’s going to redirect what they’re doing, and they’ve got too much ownership in that.
They’ve got to drop the pride a little bit and say, “OK, let’s just constructively, let’s build these things between the two of us because, ultimately, there’s so much commonality. Let’s just make sure we’re building, once again, the management system for the company.”
Russel: Yeah. Maybe pride, maybe, “I fought so hard to get quality into my head space, I don’t have the energy to now put something new into my head space and completely restructure it.” The individuals that do that and do that quickly and easily are rare.
Jim: You know the quality and the safety piece go together. You fix one, you can fix the other or improve the other. They can’t be disconnected. I think I told the story – I don’t remember if it was in the committee meeting – I had a fairly high level executive tell me, “I don’t understand why safety and continuous improvement are together.”
It’s like, “Well, you can’t disconnect the quality of the processes that they do with the safety outcomes.” There’s more to be gained than just safety improvements. Performance, and productivity, all those things come along with it. They go hand in hand.
Russel: I don’t remember what the mechanism was or what the model was, but I remember a mechanism that I looked at in TQM that’s not unlike bow tie analysis, but it added an additional view where, on the horizontal axis, you had performance metrics. You were looking at lagging and leading indicators and the things that need to occur.
On the vertical axis, you were looking at risk and lagging and leading indicators of risk. That way, you were looking at it holistically versus, “I’m looking at risk. I’m looking at performance.” No, you need to look at both because it’s only one process.
Jim: It sounds like you need to do that at the next pipeline safety management system workshop, explain the relationship between the two of those.
Russel: I think I’d be down for that, actually. Actually, I think that would be good. That would be good homework for me.
Jim: Yeah. I think that would be a great way to connect people to the relationship between the two of them, especially when you start to see, “I’ve made improvements.”
The challenge sometimes is we don’t do a great job of measuring, saying, “Here’s the date. Here’s the time. Let’s put this thing on a timeline and understand where I made that change. How do I see the effects downstream of that?”
If you can connect the dots between I made an improvement in my quality process or I’ve made an improvement in risk …
Russel: I could get up in the attic and pull my MBA notes out.
Jim: Whatever it takes, right?
Russel: I kept all that stuff because I thought it was good.
Jim: That’s what we’re after. That’s why I love coming to these conferences. Maybe because I asked a question at everybody’s presentation…It’s just like, “How do we collectively get better at what we’re doing?”
Russel: You’re a change agent. You have a passion for what you’re doing. You’re a change agent. I think I am, too. I think that was really interesting.
I’ll tell you the other thing that came up for me as I was in the field operations committee. They were talking about LDAR. They were also talking about OQ. They were talking about tracking who’s qualified.
I was reflecting on the conversation in the quality management about inspecting the process. We have a tool that’s for field operations, but it grew up in the production side of the world. It’s very task centric, and asset centric. It’s not process centric.
If you take a tool that’s an asset tool and you think of it as a process tool and figure out what are the processes that I’m trying to track my performance against, that’s a pretty compelling idea in my mind.
Jim: Well, because it’s those processes or breakdowns in those processes that lead to the…
Russel: If you can build records, data…Here’s the record for the task. Then, here’s the record for the oversight of the task, because it’s the oversight of the task where you capture the org bits. Was everybody properly trained? Did they do a job safety review?
Jim: Did they execute the process in the way it was intended?
Russel: Right. Did they have the right tools? Were their tools all in proper conditions? All of that kind of thing that you really don’t want…You don’t tend to get that data from the people doing the work in the same way you get it from somebody who’s doing a quality inspection or a safety inspection.
Jim: We had some discussion at the end. I don’t remember if you were in there at that point. We were sort of talking about the next conference and maybe some ideas for presentations. We got into more of a, “Let’s talk about case studies. Let’s talk about some real examples,” like what you described.
If people could see and understand that because I think sometimes it’s hard for folks to understand all the things that need to be put in place to make sure that you’re driving that level of process around it.
Russel: It’s very hard. I’ve tended to get most of my success for change looking at something hypervertical, but the entirety of the verticality. I’m looking at it all the way. What does the C suite care about this particular thing? I’m looking at it all the way down to how we’re doing the work.
Generally, there’s a lot of learning that comes out of that. Most people in our world are not thinking that way. They’re thinking about, “How do I move this across the entire organization down?”
Jim: Back to the discussion I did with the DIMP committee. I’ve had a lot of opportunities to look at DIMP plans.
When you start to think about the requirements of 1173 and how you start to apply those…I had a slide in there where I used contractor safety as an example. In the DIMP world, because it is so heavily focused on risk, it has a lot of alignment. I believe that DIMP was intended to be more like what 1173 is, to get the risk out.
It became so asset focused…You look at a lot of DIMP plans. They don’t necessarily define well what the leadership commitment is. They don’t necessarily have governance around it. You get so focused on the compliance requirements, which largely aligns to risk management and to operational controls.
There are eight other elements that aren’t necessarily represented within that process that ought to be. I think that’s where we need to go back. If I’m a company, if I’m the guy who’s responsible for compliance at those companies, I’m going back through those programs and saying, “Let’s see how these elements of 1173 are defined in my plan.”
Once again, some people go, “Wait a minute. I don’t want to put it in there because it’s not a compliance requirement. I’m a little concerned about whether I get…”
Russel: As an industry, we have got to get past thinking about our policies and our procedures as compliance documentation. We need to think about our policies and procedures as performance documentation. Then, the records are there for compliance.
Jim: Somebody asked me that question, to some extent, where they were asking, “Wait a minute. I just went through an exercise of, essentially, inventorying all of the documents and records and all the other things associated with 1173. I feel like it’s just a bit of an overwhelming exercise.”
I’ve heard people say, particular executives, because they’re trying to absorb what 1173 means. It feels bureaucratic. It feels like you’ve got to have all of this. It’s a paper pushing exercise.
You still have to prove compliance. You’ve got to prove…The intent behind all that is to make sure your system functions and make sure that you’re actually meeting the intent, which is to drive risk out. The two have to be going hand in hand.
Russel: It’s fundamentally…It’s the mechanism for executing your strategic plan.
Russel: I have a strategic plan. I’ve got to take that strategic plan and turn it into policies and procedures and records that I can analyze to determine, “Am I achieving the goal?”
We do this in finance all the time and nobody even argues about it. Nobody would think to argue about it, but when you get to operations it’s like, “Yeah, but we need the systems, just like we need the accounting systems, to understand how we’re doing financially. We need operational systems to understand how we’re doing operationally.”
Jim: Yeah, exactly.
Russel: I think that’s a great place to leave it. Hopefully, this podcast is a benefit to the listeners. For any of the listeners that don’t get to come to these committees, you should figure out a reason to come because you learn a ton. You learn a ton. I get more value in a week than I would in four months of trying to figure this out sitting in my office.
Jim: I was pleasantly surprised the rooms were full.
Russel: They were very full. They were…
Jim: Which was great.
Russel: They were busily pulling in chairs for the PSMS workshop. All the committees were full. Everything needed extra chairs. That’s a great sign for the industry.
Jim: Yeah, I agree.
Russel: Jim, thanks so much for coming by. As always, it’s great to see you. I look forward to having the conversation again.
Jim: Yeah, thanks for having me again, Russel.
Russel: I hope you enjoyed this week’s episode of the Pipeliners Podcast and our conversation with Jim.
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Transcription by CastingWords