A recent PHMSA warning letter cited an operator for failing to test and verify their internal communication plan for providing adequate means for manual operation of their pipeline safely for 2019, 2020 and 2021. The regulations under 49 CFR 192.631(c)(3) require operators to test and verify this plan at least once each calendar year, but at intervals not exceeding 15 months.
Having a tested and verified communication plan is crucial for ensuring controllers can safely operate the pipeline manually if automated systems fail. Without an annual test, the plan's effectiveness cannot be validated.
Punch-list Tips:
- Schedule and complete an annual test/verification of your internal communication plan for manual pipeline operations. Document the date, participants, scenario(s) tested, and results.
- Review the plan after testing to identify any gaps or areas needing improvement. Update the plan accordingly.
- Train all controllers on the updated communication plan and have them demonstrate their understanding.
In addition to having an internal communication plan, take it a step further and ask yourself this: am I planning, tracking, and managing operational changes correctly to ensure this internal communication plan doesn't need revised based on new or proposed operational changes?
The warning letter emphasizes that failing to properly test and verify this plan can result in civil penalties up to the maximum allowed by law. Don't let this oversight jeopardize your operations - make sure your manual operations communication plan gets reviewed and tested annually.
As always, Premier Safety Resources is here for your pipeline safety consulting, training, and project management needs. Send an email to hello@psrok.com for any questions or to schedule a free consultation call. Click here to sign up for PSR's free newsletter, or visit our website here.