May Pipeline Safety Tip

This month’s special:  2 hours free consulting via telephone or online meeting.

Over my career as a pipeline safety inspector I have reviewed thousands of gas operator emergency plan training records from over 50 operators.  Like other parts of pipeline safety code, many times the compliance effort was made but the records were incomplete.  Part 192 states:

192.615 Emergency plans.

(b) Each operator shall:

(1) Furnish its supervisors who are responsible for emergency action a copy of that portion of the latest edition of the emergency procedures established under paragraph (a) of this section as necessary for compliance with those procedures.

(2) Train the appropriate operating personnel to assure that they are knowledgeable of the emergency procedures and verify that the training is effective.

(3) Review employee activities to determine whether the procedures were effectively followed in each emergency.

Typical Findings:

RE (b)(2):

1. Many operators require annual review of their emergency plans with emergency response operators. Often records are:
   1. Missing employee attendance rosters for training sessions.
   2. Missing training dates.
   3. Records show emergency response personnel did not receive all the training stated in the emergency plan.
2. Plans that do not specify how training effectiveness will be determined.
   1. Exercises or drills to determine the emergency plan effectiveness are used but:
      1. There is no section like “hot wash” or “lessons learned” in the record to demonstrate the effectiveness of the learning.
         1. Hot wash or lessons learned section is in records but this was not reviewed with all attendees and/or all emergency response personnel.
      2. The plan specifies the type and number of exercises or drills to be completed annually but:
         1. Records show not all exercises completed.
         2. Operator states that all exercises were completed but records are missing.

RE (b)(3)

3. For incidents, records are missing a review of whether employee activities followed the emergency procedures. This was a very common finding.
   1. Sometimes the operator would state the review was done but not recorded; other times the review was not done.
   2. Again for actual incidents, a “hot wash” or lessons learned” section should be included in the incident report and should include a summary on whether employees followed procedures effectively.

I would be happy to review your emergency response plan and records and help you develop a system that records all required information.

This month’s special:  2 hours free consulting via telephone or online meeting.