In a 2022 PHMSA warning letter, an operator was cited for several issues that provide valuable lessons. The letter highlighted the need for clearly identifiable emergency shutdown devices (ESDs), conducting emergency response training within required intervals, providing public awareness materials in languages understood by non-English speaking communities, accurately identifying High Consequence Areas (HCAs), and implementing a risk-based integrity management program.
Key Punch-list Tips:
- Conduct a review of all ESD locations, ensure consistent signage/labeling, and provide hands-on refresher training.
- Implement a centralized system to track emergency response training and automate reminders.
- Identify non-English speaking populations, translate awareness materials, and explore diverse communication channels.
- Leverage high-resolution geospatial data and advanced modeling techniques for accurate HCA identification.
- Develop a comprehensive risk assessment framework, prioritize pipeline segments based on risk, and allocate resources accordingly.
By addressing these areas, operators can enhance safety, regulatory compliance, and effective risk management. Implementing a Management of Change (MOC) system, even if not required, is also recommended.
Read the full article on Premier Safety Resources blog here.
Email PSR to schedule a free consultation call or to schedule OQ's here.