The pipeline industry has traditionally been very good at planning and doing. However, they have not been so good at checking and acting in a proactive manner. Checking is required to identify areas for improvement and to drive corrective actions. The systemic application of a quality management methodology supports the reduction of risk leading to a higher degree of safety for operators.
Any program needs to be supported by planning, doing, and checking — and reinforced by the corrective actions taken. Think of it as a three-legged stool, where your programs — whether it’s public awareness, integrity management, or another program — are the seat of the stool. Plan, Do, and Check are the legs, connected by the Act, which are the rungs. The legs and rungs of a stool support the seat, just as PDCA supports your programs.
Why Implement a Quality Management Approach?
If you go back in time, the initial integrity audits were primarily “Plan” audits to ensure that the requirements of the regulations were acknowledged in a plan document, even though the initial protocols had requirements for the Processes (P) and Implementation (I) associated with each requirement. This continued through the first few audit cycles with actual implementation not being looked at.
Additionally, the regulations and the protocols included requirements for recordkeeping, communications, performance, quality assurance, and change management. These areas were typically only checked for inclusion in the plan as well.
Fast forward and the regulators introduced the Integrated Audit approach, which still has the requirements for Plan (P), Record (R), and Observation (O). If all three of these aspects are to be audited, the operator will need a plan, records of implementation, and will need to allow the regulators to actually observe the execution.
The challenge is that because regulators only checked each operator’s plans in the early days of the federal pipeline safety regulations, operators developed the habit of emphasizing their plans and not following through with the other steps in the cycle. The audits were Plan-based just making sure that each operator had a written and communicable plan, so there was no external incentive to advance the quality of programs.
Now, regulators are starting to check what operators have planned and done to support pipeline safety. It’s time to catch up. Operators need to take improvement steps to ensure that the three-legged stool is optimized for each program. When operators strive for continuous improvement in how they support each program, they will be best positioned to support the industry-wide goal of zero pipeline incidents.
Pipeline Operators: If It Wasn’t Documented, It Didn’t Happen
Great, you have a plan to support each program. But, are you checking whether employees, contractors, and other stakeholders actually followed the plan when they took action performing their tasks?
There may be a situation where an area of the plan is not aligned with the regulations. When that happens, an operator can usually explain the non-compliance issue and request an update to the plan to align with regulations. That may be an observation. But, what’s worse is that your plan says you will take a specific action, but no one actually did it. That will be a finding.
You do not want to be in a position where you did not do what you said you were going to do. Or, you don’t want to be in a position where you cannot produce records that prove that you did what you said you were going to do. You can claim that someone did something, but if a regulator asks you for proof that an individual did something in accordance with the plan and you can’t produce the record, then it’s as if it never happened. If it wasn’t documented, then it didn’t happen.
This points to the need for the Check to be optimized to make sure that each person followed the plan when they did something and that the action was recorded. This leads to what holds the stool together for each program: the Act.
How the Act Supports Pipeline Programs
The Act is a follow-up activity that strengthens the stool and is driven by the Check. In other words, the Act comes into play once the Check has been performed. But, if you don’t perform the Check, then you will not be in a position to achieve continuous improvement via the Act.
If you want to realize measurable improvement in pipeline safety, then your operation needs to be Checking on a regular frequency. Operators often Plan and Do to drive toward safety improvements, but when it comes to the Check, the recommendations are either not captured or not prioritized.
Regarding Checking and Acting, questions should be asked:
- How many times did your operation perform a Check on a regular frequency?
- Did you identify an action to take in response to the Check?
- How many times did you Act (develop corrective action) on the Check?
- How effective was the Act (corrective action)?
- Did you measure each activity to create a baseline for continuous improvement?
As you capture actions and results, the documentation provides a means to support the Check. Checking identifies areas where the results are not meeting expectations, driving investigation as a possible corrective action.
This is a continuous process. It’s a cycle and not a finite process. If you’re checking and acting, but you think you’re done after each activity, then you aren’t in a continuous process. Every act requires additional checks to determine the effectiveness of the corrective action. If an action is not effective, a new action needs to be implemented to correct the initial recommendation.
The goal should be planned Checks that result in opportunities to identify areas for improvement. Those improvements turn into prioritized corrective actions to improve operations. Having a mechanism in place to manage this continuous process supports cultural change that leads to new attitudes and behaviors. Having a culture that wants to continuously provide opportunities for improvement is how you realize safe operations. Pipeline safety — and the zero incidents goal — is the outcome of pursuing a culture of continuous improvement.
Utilize Tools to Support Your Pipeline Programs
As you strive for continuous improvement, P.I. Confluence can help operators support the entire stool for each pipeline program.
- Plan: We utilize ComplyMgr to determine whether your plan is aligned with appropriate pipeline regulations or whether you have any gaps. Then, through audit compliance support, we’ll help close the gaps in your program.
- Do: We utilize ICAM (Integrated Compliance Activity Manager) to support process management by making sure you have the appropriate processes to support the Plan. We take a synergetic approach to ensure that you are doing what you said were you going to do in your Plan.
- Check: We utilize pSEc (Program Stakeholder Engagement Communication) to check that the right people are doing the right thing in the right way at the right time. This supports the function of gathering stakeholder feedback from boots-on-the-ground workers and other stakeholders to execute the Act.
- Act: We support the full cycle with Management of Change to gauge performance and ensure that each Check is consistently being acted upon. The process evaluations include implementing a corrective action program, optimizing stakeholder engagement, and sharing lessons learned to support continuous improvement.
What happens when you take this approach to support each program? Ultimately, you are best positioned to drive toward safety improvements. Along the way, you realize these additional results:
- Support recordkeeping and quality assurance.
- Meet PHMSA requirements in all areas of pipeline operations.
- Support performance effectiveness requirements of API 1162.
- Build more consistent safety observations and reporting of events.
- More efficiently and easily capture suggestions and build feedback loops.
Don’t wait until it’s too late to optimize the three-legged stool for each program. You can meet regulatory requirements, minimize safety risks, and be ready for the audit through our combination of software tools and consulting expertise.
Contact us today to start a conversation about how we can support your pipeline operation by implementing a complete pipeline program management system. Let’s drive toward continuous improvement in your operation.
