For many years, the pipeline industry has been very good at planning and doing. However, the industry has not been very good at formally checking and acting, which has increased the risk and consequence of safety issues in pipeline operations.
In this era of Pipeline Safety Management Systems (PSMS), operators need to be Planning, Doing, Checking, and Acting to support the quality management requirements that are integral to API 1173 framework for Pipeline SMS.
If you are not supporting the full Plan-Do-Check-Act cycle, then consider performing a PDCA check to determine where you need to close safety gaps.
Why Perform a PDCA Check to Support Pipeline SMS?
Historically, the majority of planning and doing in the pipeline industry was operational – or “on the pipe.” This created challenges when the Pipeline Integrity Management Rule for gas transmission pipelines was finalized in 2004. When the protocols for gas transmission first came out, they were labeled A-N.
- A-H were requirements associated with the pipeline.
- I-N were new requirements to the industry that supported organizational excellence.
Unfortunately, many operators have not embraced the importance of quality management reflected in the requirements.
Consider that the majority of major pipeline safety incidents over the last 20+ years have been attributed to some degree of organizational failure. That’s why after two high-profile incidents in 2010, the NTSB asked API to create a Pipeline Safety Management System framework for the industry.
The framework was completed in 2013 and incorporated the Plan-Do-Check-Act methodology. Many of the requirements in the API 1173 framework are the same as those original protocol requirements such as performance, recordkeeping, quality assurance, and change management.
However, considering the fact that the best practice was actually written by industry, the primary focus remained on Planning and Doing, which is what the industry is most comfortable with:
- Plan: 543 references
- Do: 779 references
- Check: 383 references
- Act: 238 references
Just planning and doing does not support operational excellence, nor does it reduce risk. Operational excellence and PSMS maturity is determined by how well operators Check and Act. This is why many operators have not been able to mature their SMS.
To take the next step, operators need to understand the quality management principles of PSMS that are built into the API 1173 framework so that they can perform a comprehensive PDCA check.
Understand the Content of Pipeline SMS
A word map of API 1173 reveals that the emphasis is on Process, Risk, Improve, and Safety.
This PDCA principle is at the core of all management systems. The objective is to require the following:
- Management of plans, procedures, and processes.
- Proper implementation of the plans, procedures, and processes.
- Development and analysis of leading and lagging indicators as measurements of performance.
- Corrective actions to be taken if, when, and where necessary to improve plans, procedures, processes, execution, and performance analysis.
This cycle is iterative and is necessary to achieve continuous improvement. A simple gap analysis of the requirements might be a way of confirming what your PSMS contains. However, it does not support the objective of PSMS, which is to prevent and mitigate organizational failure through the systematic application of the PDCA quality management methodology.
A check-the-box approach to the gap analysis of the requirements in 1173 is treating them as if they are prescriptive. However, the required application of PDCA is performance-based in nature. In a performance-based approach, the gap analysis should be to check your operation’s performance against the requirements.
To appropriately meet objectives, operators need to be measuring performance in each of the four aspects of the continuous improvement cycle: planning, doing, checking, and acting.
In most cases, the requirements contain varying combinations of PDCA. Additionally, many of the requirements target areas that may be considered the root cause of organizational failure.
However, as previously alluded to, the requirements tend to focus on planning and doing. When taking a broad look at the breakdown of the 1173 requirements in the form of “shall” statements, over 75% of these statements are related to Plan and Do, with only 10% associated with Check.
Understanding this, the questions that need to be asked are not “are the shall statements regurgitated in my PSMS?” Rather, for each element of the PSMS and each aspect of the pipeline life cycle, operators should be applying the PDCA methodology. Instead of just planning and doing, operators should be asking:
- What are we missing in terms of Checking and Acting?
- Are identifying areas of potential organizational failure?
- Are we taking corrective action to improve safety through risk mitigation?
Performing a PDCA check can help answer these questions. Utilizing software tools to support the often-overlooked Check and Act can also help close the loop of continuous improvement.
Use Tools to Support the PDCA Check
P.I. Confluence can help your operation perform PDCA gap analysis through the use of software tools. We help operators implement PDCA processes for each of their programs to ensure alignment with API 1173.
Specifically, our ICAM tool (Integrated Compliance Activity Management) enables you to achieve the following objectives:
- Perform the complete PDCA cycle.
- Implement process evaluations to support continuous improvement.
- Track implementation and supporting documentation of program activities.
- Satisfy federal requirements for Integrity Management.
Now is the time to advance your Pipeline SMS to support pipeline safety. We can help your operation reduce risk so that you can continue to operate safely. Contact us today to schedule a consultation or an educational demo of our software tools.
