The Pipeline and Hazardous Materials Safety Administration (PHMSA) published final regulations on December 3, 2009, for control room management (CRM). Otherwise known as the CRM Rule, these regulations prescribe extensive safety and operational requirements for controllers and control rooms that remotely monitor and control liquid and gas pipelines regulated under 49 C.F.R. Parts 192 and 195.
This course will move beyond reviewing the content of the CRM Rule and its initial implementation and venture into the ongoing efforts required to continuously improve an operator’s operational effectiveness and compliance status, while also maintaining adequate levels of preparedness in the event of a state or federal inspection.
Attend this course to learn not only the importance of the CRM Rule and its effect on the control room but also the details of how operators are effectively—and sometimes ineffectively—responding to the requirements. From the background and history of the CRM Rule to the upcoming Gas Mega Rule, this course will help attendees to understand what is required of them.
Learning Outcomes
- Discover what led to the creation of the CRM Rule and the history of the rulemaking process
- Examine the content of the CRM Rule through a section-by-section approach
- Determine what PHMSA expects and what to expect from PHMSA moving forward
- Evaluate how other operators approach CRM and review how to prepare for an audit
THURSDAY, JANUARY 11, 2024
9:00 a.m. – 4:30 p.m. Central Time
Background and History
- Significant Pipeline Incidents and NTSB Recommendations
- The Rulemaking Process
The CRM Rule
- Cover Each Section of 49 CFR 192.631 and 49 CFR 195.446
- Letter of the Law
- Notable FAQs
- Where Other Internal Teams Can Help
- How to Address Policy
- How to Address Implementation
Audit Preparation
- Integrated Inspection vs. Control Room Inspection
- Initial Questionnaire
- GAP Analysis
- Corrective Action Plan
- How do Different Roles Help in Audit Prep?
- How to Best Equip Controllers
- Document Availability
Audit Experience
- What to Expect
- Enforcement Action and Response
- Review Enforcement Examples
What to Expect from PHMSA Moving Forward?
- Gas Gathering Rule
- Upcoming Audit Initiative
Available Resources
Ross Adams, General Manager, EnerSys Corporation
Ross Adams is an experienced regulatory compliance consultant and client success advocate within the oil and gas industry. His career began in the offshore sector, assisting clients with conforming to the Bureau of Safety and Environmental Enforcement’s 30 CFR 250.1902 Subpart S – Safety and Environmental Management Systems (SEMS) regulations. Grounded in the American Petroleum Institute’s Recommended Practice 75, this regulation is a comprehensive approach towards a proactive compliance culture for the offshore industry. Mr. Adams worked to ensure that clients were compliant with applicable regulations in the context of Personnel Training, Facility Inspections, Hazardous Material Communication, Spill Response, and Mechanical Integrity.
In recent years, Mr. Adams’ area of focus has shifted to the pipeline sector where he works side by side with operators to design, implement, manage, and continuously improve their compliance state as it pertains to 49 CFR 192.631 and 49 CFR 195.446, otherwise known as the Control Room Management (CRM) Rule. Mr. Adams has further demonstrated his knowledge of the CRM Rule via the design and execution of EnerSys’ Compliance Facilitator Program, Audit Support Services. Furthermore, Mr. Adams works diligently with Enersys’ client base to understand and meet their operational and CRM/Pipeline Safety Management compliance needs and to ensure they are maximizing their value received when using EnerSys’ CRM Suite of software tools.