PHMSA Advisory Bulletin: Pipeline Safety Management Systems
The Pipeline and Hazardous Materials Safety Administration (PHMSA) has issued an Advisory Bulletin for implementing Pipeline Safety Management Systems (PSMS). This Advisory Bulletin is based on Section 205 of the Protecting our Infrastructure of Pipelines and Enhancing Safety Act of 2020 (PIPES Act of 2020) and the National Transportation Safety Board’s (NTSB) Safety Recommendation P-24-002.
Studies have shown that PSMS programs can significantly reduce or prevent pipeline releases. PHMSA advises that PSMS programs should be implemented according to American Petroleum Institute’s Recommended Practice 1173, Pipeline Safety Management Systems (API RP 1173), to enhance pipeline safety and minimize potential consequences of releases.
Though a significant amount of existing pipeline mileage is covered by PSMS currently (approximately 85%), many smaller companies have not yet adopted the program. A release in San Pedro Bay, California on October 1, 2021, exposed this as a potential area of concern and resulted in the aforementioned NTSB Safety Recommendation.
Therefore, PHMSA recommends that pipeline operators, including small companies, should:
Implement a PSMS program that covers the essential elements listed in API RP 1173
Work to continuously evolve and improve the PSMS program
Maintain a positive safety culture that continually promotes diligence throughout the organization and addresses issues that can erode the safety culture
PHMSA, over the past couple years, has included a new screening question in their inspection question set reading “Has the guidance of ADBs (Advisory Bulletins) been implemented in relevant program areas?”. Operators can expect to be asked about this and other advisory bulletins in upcoming PHMSA and possibly state inspections.
For additional information regarding your current PSMS program, API RP 1173, or how to get started on a safety management system journey, please contact Elemental Compliance at https://www.elementalcompliance.com/contact. Click here to read the Advisory Bulletin.