Operator responsibility

8 June 2010 was the official opening of the Energy Pipelines CRC.  It was also the day we received news of a serious pipeline incident in Texas in which one man died and eight were injured.  On 31 August 2010 directions to the pipeline operator were issued by the Railroad Commission of Texas (which curiously enough regulates the oil & gas industry and has nothing to do with railways).  Those directions and the accompanying background information make interesting reading.

It seems clear that the RRC attributed blame to an individual pipeline operator (“operating specialist”) in the first instance and to his employer and its systems in the second instance.  The directions to the pipeline company allege the following violations (paraphrased):

  • Did not comply with the US federal pipeline regulations (specifically, the site of third party works was not inspected and temporary marking of the pipeline at the work site was not done before excavation began)
  • Did not ensure that pipeline personnel were qualified for their tasks (the operator was unable to use GPS to locate the pipeline)
  • Did not provide procedures for evaluating the qualifications of individuals (ditto)
  • Did not conduct post-accident testing of the operator for either alcohol or prohibited drugs within the prescribed time interval
  • Did not properly place pipeline markers (implying that the permanent markers were inadequate)

It is not clear why the “operating specialist” failed to fulfil his duties.  He couldn’t find the work site on the first attempt and made no effort to contact the excavation contractor for clarification but nevertheless marked the equivalent of a “dial before you dig” request as all clear.  There was much the same response to a second DBYD request issued a day later, except that the second response was nearly a week late.  The man responsible had 29 years in the pipeline industry and 8 years with this particular company.  I haven’t yet been about to find out whether the individual or company have been prosecuted.

I find this to be a salutary demonstration of the weakness of procedural controls.  Procedural controls such as warning signs and one-call systems have immense value but are not foolproof.  In this instance all the holes in the “Swiss cheese” slices lined up and the auger got through to the pipe, with disastrous effect.

It’s not unusual in safety management studies for people to want to put absolute reliance on procedural protection measures because the physical protection fall short for some reason (usually legitimate, often historical).  I strongly discourage that attitude where possible.

One one occasion when there was no alternative but complete reliance on procedural controls I persuaded the workshop to accept as a threat a change in management attitude that resulted in reduced commitment to the procedural protection measures.  However including that threat was only a token gesture, since at middle-level technical management we had no effective way of controlling the factors that could lead to that threat eventuating.

Anyway, the Texas auger incident serves as a useful reminder that both individual pipeline operations personnel and the companies that employ them have serious responsibilities to keep things safe.

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