January 2020, Vol. 247, No. 1
Features
Where PHMSA’s Voluntary Information-Sharing Program Stands
Pipeline and Hazardous Materials Safety Administration (PHMSA) officials are apparently still interested in developing a voluntary information sharing (VIS) safety reporting program.
However, exactly where their effort stands – after three years of hard work – is perhaps best characterized by Winston Churchill’s reference to the old Soviet Union: “a riddle, wrapped in a mystery, inside an enigma.”
PHMSA’s Working Group’s sent a final report recommending such a program to Transportation Secretary Chao last April. The VIS Working Group was comprised of participants from two PHMSA standing committees: the Technical Pipeline Safety Standards Committee and the Technical Hazardous Liquid Pipeline Safety Standards Committee. Additionally, the Working Group included representatives from environmental and public interest groups. High-ranking PHMSA personnel served as staff. Alan Mayberry, PHMSA’s associate administrator for Pipeline Safety, was on the working group roster.
Mark Zuniga Sr. is vice president and CIO with UniversalPegasus International, Inc., a design and engineering firm, based in Houston, specializing in oil and natural gas delivery projects. Zuniga was part of the VIS Working Group from its start, serving on a sub-group focusing on IT and related architecture. The VIS would depend on “deidentified” reporting and reports sent within an electronic system.
Zuniga characterized the Working Group’s efforts to analyze and recommend a VIS program as highly valuable to future pipeline safety, to strengthening and developing industry based safety programs, which remain too siloed, and should be expanded. The Working Group used an airline industry program as its primary model.
“The pipeline industry can leverage those lessons learned,” Zuniga said. “There’s real opportunity for our industry to make some groundbreaking improvements in how we operate pipelines and that is going to be a direct benefit to all, not just the industry but the public and the environment.”
Zuniga described broad consensus among Working Group participants – again, a very diverse group, and said that the final recommendations applied across the industry.
He added, “A high-tide raises all boats in pipeline safety and it’s something that we (UniversalPegasus) certainly support.”
Diane Burman, a commissioner with the New York State Public Service Commission, served as the Working Group chair. In a letter sent with the Group’s final report, Burman wrote “a VIS framework aligns well with Pipeline Safety Management System principles, and if established, would be a ground-breaking initiative to advance safety in the pipeline industry.”
Indeed, the secretary and PHMSA followed up. In June, the Department sent Congress a draft PHMSA reauthorization bill. The text included a proposed “Section 5. Voluntary information sharing system” authorizing:
“PHMSA to establish a voluntary information sharing system to encourage collaborative efforts to improve inspection information feedback and information sharing, with the purpose of improving natural gas transmission and hazardous liquid pipeline integrity risk analysis. To encourage participation, the provision ensures that operators can provide the information in a confidential manner, without exposure to punitive measures.”
Six months later, however, it’s hard to assess where that promising start now stands. VIS is not mentioned within the draft bills subsequently taken up by House and Senate Committees.
PHMSA’s two technical advisory safety committees recently met on Nov. 14, in Washington. The meeting announcement referenced VIS, but, in fact, VIS was not on the agenda and from a review of the materials presented one could conclude that VIS was over and done with, or at least forgotten.
One source who was present told PGJ who was involved in VIS development said not only was VIS off the agenda, but it didn’t even come up as a discussion topic. That’s important to note because to get VIS off the ground, at least as proposed by the VIS Working Group, start-up requires some heavy lift by Congress on controversial issues. VIS will demand more teamwork, not less.
So, is PHMSA still active on VIS? If so, how?
Unfortunately, answers are difficult to decipher. For this report, PHMSA leadership wouldn’t answer any questions, in an interview or even via email, regarding next steps, if any, or where VIS implementation issues stand now. Similarly, Burman turned down an interview request.
As envisioned, an information sharing program would be extensive and complicated. But it’s grounded in some basic principles, and concerns:
That the program used by the US airline industry should be the model for pipeline operators. VIS supporters see a direct link between commercial airlines’ information sharing and the remarkable airline safety record for the past 20 years.
Secure protocols and a state-of-the-art information technology process would collect, “de-identify,” archive and disseminate risk information based on historic, real-time, or near real-time factors assessing pipeline integrity.
Information sharing will allow all pipeline operators to learn from multiple experiences by bridging data and information gaps. Operators with smaller systems and resources could leverage the knowledge and learnings of larger operators.
The Working Group’s report recognizes current information sharing within the pipeline industry. One concern, though, is that it is too siloed, not extensive enough. A VIS program, with de-identified information, opened up to everyone, could make all operators work smarter as they are provided alerts, warnings and advisories in advance of decisions about projects, processes and materials. The final report recommends building on existing VIS platforms.
Work by the Pipeline Research Council International (PRCI) – a nonprofit assisting the energy pipeline industry – is referenced in the Final Report submitted by the Working Group as a strong example to guide next steps. PRCI is developing a Pipeline Data Hub (PDH) to enable this sharing and leveraging the vast amounts of data developed via its research program (PRCI project NDE-4E “In-line Inspection Crack Tool Performance Evaluation.” (NDE is “non-destructive evaluation.”) Data was contributed from its members and the industry.
PRCI collected over 100,000 records from 10 pipeline operators with paired in-line inspection (ILI) and field validation measurements of key defects via NDE tools. This data was used to assess ILI tool performance for measuring axial crack features. For the VIS working group, PRCI’s project presents a range of key elements important for a broader data sharing initiative. Some of these important features include:
- Data specification – PRCI standardized the wide variety of terms that different companies use to reference common events or incidents;
- Data gathering protocols – PRCI made this easier and quicker for company personnel;
- De-identification techniques – PRCI’s reports scrubbed data, inadvertently included in primary reports, that could be used to identify a specific company.
Cliff Johnson, President of PRCI, explained that PRCI is in the early stages of developing the PDH and that the first stages will be available to PRCI membership. PRCI is still evaluating how and what information will be shared among a broader audience. Once PRCI’s first step works as planned, then they will scale up.
Johnson foresees an alert system working in real time as well as providing summaries of data, a system accessed electronically. This would be two-way, of course. In fact, it depends on two-way – pipeline companies will be encouraged to enter data or contribute information and observations that present clarifying and advisory messages and warnings to everyone across the industry, from private sector companies to public interest groups to regulators.
“It will take a while for us to reach this level of sharing and development,” Johnson said, noting that “it’s taken aviation 20 years” to reach their current high level of performance.
Importantly, the VIS will be established – if it starts, of course – as a voluntary sign-up. Johnson refers to a “coalition of the willing” at first, a core group of companies who already know the value of information sharing.
Establishing a VIS pipeline program will require a deliberate and centralized directive from top Agency officials and Congressional leaders. The program is ready to move. Leadership and next steps, though, still need to come into focus.
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