Pipeline operators with federally-regulated pipeline assets are required to comply with several PHMSA safety programs. It can be challenging to ensure compliance with the pipeline safety regulations (49 CFR 192 for the transport of natural gas and 49 CFR 195 for the transport of hazardous liquids) for each of these programs:
- Integrity Management (IM) – DIMP for Distribution Pipelines, TIMP for Transmission Pipelines, and SIMP for Storage.
- Operations Maintenance Emergency (OME).
- Control Room Management (CRM).
- Public Awareness (PA).
- Damage Prevention (DP).
- Operator Qualification (OQ).
- Oil Pollution Act Facility Response Plan (OPA).
- Drug & Alcohol Testing (D&A).
That’s why we recommend utilizing a robust tool such as our POEMS® ComplyMgr software module to identify and correct gaps between your policies and procedures, implementation, and recordkeeping versus what PHMSA requires, plus prepare your operation for the audit.
ComplyMgr is a sophisticated method for gap analysis and audit prep that facilitates continuous improvement. Learn more about why we recommend this tool to support your company!
Why Use ComplyMgr for Pipeline Safety Regulation Compliance?
We understand you have options. There are basic tools that act as search engines for federal regulations. Mock auditors will offer to perform gap analysis for you. However, we use ComplyMgr to put it all together for you in a way that streamlines compliance, keeps you organized, provides you with a structured approach to prepare for the audit, and helps you realize safety improvements.
ComplyMgr allows you to efficiently compare your internal documentation against each pipeline safety program that is relevant to your operation. You can also utilize ComplyMgr to initiate corrective action and close gaps. We generate a Corrective Action Plan (CAP) within the software tool that provides a clear set of steps to close the identified gaps.
The plan is helpful for many companies that need to initiate change within their company. It can be used to achieve “buy-in” from management, especially when it comes to resource allocation to support the full scope of your compliance needs.
You’ll always be ready for a PHMSA audit by using ComplyMgr to support documentation and recordkeeping. We use a unique linking process that serves as an “audit cheat sheet” that enables a side-by-side comparison of internal policies and procedures against PHMSA audit questions.
During an audit, you’ll be able to easily locate and pull up applicable sections of your program documents using ComplyMgr as an audit cheat sheet. So, when the auditor asks, “Where in your policy have you addressed this audit question?” the answer is right at your fingertips, eliminating the hassle/stress of scouring policies and procedures on the spot.
To get you set up, our team will analyze your documentation and complete the initial link map. Then, updating links is simple and easy to manage. We build these connections in a user-friendly and structured manner that makes the audit a breeze. This way, you can prove that your safety programs align with regulations and that you are doing what you say you are going to do. Your auditor will appreciate the simplicity of the process!
How ComplyMgr Keeps You on Track with PHMSA Regulations
Each safety program’s related federal regulations, FAQs, and PHMSA audit protocols are built out in ComplyMgr. You will receive your own secure ComplyMgr database containing all relevant federal regulations for the safety program(s) that you manage, which can be searched within ComplyMgr at any time.
These documents also act as references during a Compliance Review, which is a unique type of gap analysis that we created to replace archaic audit prep methods. We use Compliance Reviews to perform a side-by-side comparison of each of your program’s documents against the PHMSA reference materials. This approach allows users to access corrective actions within the tool when performing annual program reviews. Using our linking process makes policy analysis more efficient.
No longer do you have to navigate all of the various PHMSA databases and search for the current versions of documents. Nor do you have to track these down in a hurried rush during the audit. Everything is accessible in ComplyMgr at the click of a few buttons.
Our team of subject matter experts (SMEs) can support this activity by performing on-site assisted compliance reviews. Our safety program SMEs have performed dozens of mock audits and assisted in PHMSA audits. We attend industry conferences to stay current on PHMSA initiatives and industry events so that we can continue to deliver exceptional support to companies.
During a compliance review, our SMEs will identify opportunities to optimize your internal policies and procedures, implementation, and recordkeeping. They will also help you prepare for the next phase of utilizing ComplyMgr to support continuous improvement.
Use ComplyMgr to Kick off the PDCA Cycle
A current point of emphasis in the pipeline industry is striving for zero safety incidents through the implementation of Pipeline Safety Management Systems (PSMS / API 1173) as a systematic quality management approach.
We subscribe to the theory that the Plan-Do-Check-Act (PDCA) cycle that is built into the PSMS framework is the ideal method to achieve continuous improvement on the path to zero incidents.
Operators can utilize ComplyMgr to initiate the PDCA cycle that will support the quality management of your pipeline safety programs and help you realize incremental improvements.
– Plan: use ComplyMgr to identify safety program gaps and develop a Corrective Action Plan (CAP) in the process.
This leads to the use of our other software tools and continued support from our deep bench of SMEs to provide your operation with 360 degrees of pipeline safety coverage.
– Do: use our ICAM tool (Integrated Compliance Activity Management) to execute processes in alignment with best practices and company policy. You can also generate records and dashboards that provide personalized overviews of program status as it relates to the completion of activities.
– Check: use our pSEc tool (Program Stakeholder Engagement Communications) to support stakeholder communication. You can gather feedback anonymously, which guarantees accurate and unbiased feedback from stakeholders. Plus, pSEc is easy to use, allowing compliance staff to efficiently manage and collect feedback.
– Act: use subject matter expertise from P.I. Confluence (PIC) and other experts from the EnerACT family of companies to update programs and close gaps.
– Refine: return to ComplyMgr to view progress, measure improvement, and continue to close pipeline safety gaps.
ComplyMgr provides a foundation – or a reference point – to see where you started, where you are improving, and where there is more work to do. This simplifies the process of ensuring alignment with pipeline safety regulations. It also shows PHMSA auditors that your operation is committed to closing gaps and improving!
Our Complete Support for Pipeline Safety Compliance
At P.I. Confluence, we put it all together for pipeline operators that need to comply with safety regulations and need reliable support that fits their operation.
– Software: Our ICAM and pSEc tools are fully configurable, off-the-shelf solutions that help facilitate continuous improvement when used along with ComplyMgr.
- Use ICAM and pSEc to ensure that procedures and processes are being followed.
- Utilize records generated through ICAM and pSEc to verify adherence to regulations during a Compliance Review via ComplyMgr.
- The result: Your operation realizes proven results by improving safety programs so that you are in Natural Compliance with regulations.
Plus, our tools are supported by ongoing account management to make your internal processes more efficient. This is all backed by our industry expertise.
– SMEs: Our company possesses expertise in specific areas of PHMSA pipeline safety regulations. Also, as a member of the EnerACT family of businesses, we have the ability to leverage our connections to provide additional expertise to operators.
- P.I. Confluence: we specialize in Integrity Management (IM), Public Awareness (PA), and Damage Prevention (DP).
- EnerSys Corporation: focuses on Control Room Management (CRM) to ensure that each operator is compliant with the PHMSA CRM Rule. Check out this information about how EnerSys used ComplyMgr to support an operator’s control room audit, which resulted in the operator having minimal findings.
- EnerACT: we have access to additional SMEs to support broader compliance with all safety programs.
The starting point is utilizing ComplyMgr to compare your internal compliance posture against PHMSA regulations. Because we have already built out all of the safety programs in this tool, we can easily get started on helping you identify gaps.
– Contact us today to schedule an educational demo of ComplyMgr. Let’s kickstart the process of improving your safety programs on the path to zero incidents.
