July 2024, Vol. 251, No. 7
Features
Enhancing Contractor Safety: New API Assessment Program Targets Key Risks
By Colin Frazier, Director of System Programs, API
In the pipeline industry, contractors play an important role in maintaining and operating our nation’s network. They often assume the critical tasks of field operations and maintenance — physically demanding roles with substantial responsibility for operational safety and efficiency.
Contractors perform various functions, from construction and welding to inspection and maintenance. Their work is vital in construction activities, managing corrosion and preventing leaks. Often involving high-risk activities, such as excavating and working in trenches, they face a variety of work challenges:
- Frequently working in varied environments, which presents challenges distinct from permanent staff, who may operate in a single environment
- Sometimes lacking uniform training and oversight, compared to permanent employees
- Often working for different operators across their service area, which can lead to disparate safety practices
Recognizing that these key stakeholders did not have a common set of safety guidance to follow, API and the Pipeline Safety Management Systems Industry team discussed how to best bring the contractor community into the Pipeline SMS discussion. These factors led to the recent launch of the Pipeline SMS Contractor Assessment Program — a dedicated, contractor-focused program that addresses their specific needs.
The goal is to help improve safety practices for contractors across the industry, providing an assessment tool to help contractors incorporate API’s consensus safety management systems.
Need for Systems
Over the past two decades, the pipeline industry has modified its approach to safety. Driving some of this change, the National Transportation Safety Board (NTSB) issued a recommendation to API to publish a standard on safety management systems, tailored specifically for pipelines.
As a result of the recommendation and to increase safety across the pipeline segment, API published Recommended Practice 1173 (RP 1173), Pipeline Safety Management Systems (PSMS), establishing a comprehensive framework with 234 requirements that are key to effectively managing risk and preventing future incidents.
First published in 2015, this initiative advances the industry’s effort to mitigate risks and enhance the safety of pipeline operations. The NTSB closed the recommendation with the note that API’s efforts exceeded their expectations to provide comprehensive safety management guidance and implementation assistance to industry.
Acknowledging that implementing management systems across large enterprise organizations is no easy feat. API assembled a Pipeline SMS Industry Team, tasked with coordinating an industry-wide push for operators to voluntarily adopt the new standard.
The Pipeline SMS Industry Team is comprised of many allied trade associations, representing different subsegments of industry (AGA, APGA, INGAA, LEPA, API, GPA Midstream, DCA) as well as key industry leaders. As part of the coordinated industry implementation effort, API introduced the Pipeline SMS Assessment Program in 2020, providing pipeline operators with a systematic framework for getting feedback from industry experts regarding their efforts in implementing RP 1173.
Since the kickoff of the API Pipeline SMS Assessment Program, API has conducted 18 assessments for operators across the oil and gas supply chain, with participants ranging from large liquids transportation pipelines to local gas distribution operators. Participants get detailed feedback on their implementation and can use outputs from the assessments to inform their continuous improvement efforts and their implementation plans.
Assessment Program
Given the success of the API Pipeline SMS Assessment Program for Operators, API and the Pipeline SMS Industry Team are proud to announce the ability for pipeline contractors to also access our team of experienced safety management system experts, to conduct similar assessments for their safety programs. This program builds on earlier efforts that provided informal safety management guidance to contractors.
Recognizing the critical role of contractors who perform essential pipeline construction and maintenance, API worked with the Pipeline SMS Industry Team to publish Pipeline SMS: A Contractor’s Guide in 2022 (https://pipelinesms.org/contractor-guidance/).
The Contractor Guide acknowledges that RP 1173 is written for the operator of pipelines and focuses RP 1173’s 234 requirements down to 56 key requirements, where — depending on the Contractor’s work (the guide is both scalable and flexible, aligning with an organization’s unique size and scope of work)—they can focus their efforts on specific safety programs that can both improve their safety programs, as well as ensure appropriate alignment with their Operators’ SMS.
Using the Contractor’s Guide as the basis, the new API Pipeline Contractor Assessment Program allows contractors to verify their safety management system scope and get key assessment feedback on areas for improvement. The program also promotes consistent safety practices among contractors, ensuring conformance with appropriate RP 1173 requirements and a commitment to safety.
Scope, Focus
The API Pipeline Contractor Assessment Program specifically targets the unique risks and operational challenges faced by pipeline contractors, emphasizing the value of standardized safety requirements, based on industry’s previous work in Pipeline SMS for Operators.
The program focuses on the 56 common requirements identified by the Pipeline SMS Industry team and published in the Contractor’s Guide, such as leadership engagement, safety culture, reporting of incidents, risk management and others, depending on a contractor’s scope of work.
By concentrating on these common areas already being pursued by operators, the program aims to reduce risks that could lead to incidents, environmental damage and personal injuries, as well as to help align operator and contractor safety management programs.
As part of an assessment, contractors have a safety management professional come to their office location and work with key safety contacts to verify the scope of their SMS relative to their scope-of-work in the field.
Additionally, the safety management professional will discuss those requirements (from the Contractor Guide) that are in scope, providing them feedback on their implementation efforts and the efficacy of their programs, providing key feedback that can help mature their safety programs.
Additionally, the program emphasizes standardized practices, addressing inconsistencies across geographical regions, safety culture, training and leadership considerations. These uniform requirements, found in the Contractor’s Guide, ensure that all contractors have a published framework from which to work, which ensures they will be able to align with their customer operators.
Assessment Details
The API Pipeline Contractor Assessment Program underwent a deliberate development plan, including carefully designed pilot programs. These pilots assessed several contactor safety programs and practices in real-world settings and allowed API to verify that the proposed approach would be of value to these specific industry stakeholders.
Feedback from program participants helped shape the program’s final structure. The finalized structure involves a contractor engaging API, who will in turn match an API-vetted assessor (safety management-experienced professionals with at least 25 years’ experience with the company).
The contractor provides access to their internal safety-related processes and procedures to the assessor, prior to arriving on-site, allowing ample time for the assessor to review how their safety programs are supposed to function.
Once on site, the assessor spends two days working directly with contractor representatives, having a two-way dialogue to ensure contractor-specific concerns are captured and addressed as part of the assessment, as well as to ensure that the contractor’s safety programs fulfill the Contractor’s Guide requirements (56 in total), should they all be deemed in-scope, based on a contractor’s specific scope of work.
After the two-day assessment, contractors receive a detailed report, outlining their conformance to the requirements and a laundry list of considerations that can help improve and mature their safety programs. Once ten contractors have participated in the program, API foresees the ability to distribute benchmarking data to previous participants in the program.
Alignment, Integration
The Pipeline Contractor’s Assessment Program demonstrates API’s and the Pipeline SMS Industry Team’s commitment to creating a robust ecosystem, where operators and contractors alike can receive deep technical support for the implementation of RP 1173 and the Contractor’s Guide.
By standardizing safety practices and promoting consistent behaviors among pipeline contractors, the program mitigates risks and enhances the overall safety of pipeline operations. It also can be helpful to pipeline operators, as the effort necessary to integrate their contractors as part of the workforce will decrease. This underscores API’s commitment to safety and continuous improvement in risk management, paving the way for a safer, more efficient and sustainable future.
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