Procedural controls

I reported recently on a couple of very nasty near misses, and if you look at the comments at the end of that post there is another scary story about someone who thought he did not need to follow the rules.  Recently there was a report of very similar near miss which was described like this:

The contractor moved cyclone fence (exclusion barrier) and dug 2 metres into a 3 metre no go zone with a 30 tonne excavator installing a drainage pit.    Works on this estate started approx three months ago with various locations marked out and fenced to avoid encroachment. The whole area is clearly signed and a lot of discussions were already carried out with the estate developer prior to approve the works in the vicinity, explaining the risk of pipeline failure and conditions of works.

So again some strange thought processes were used to conclude that all the precautions could be ignored.

In the same vein there seem to be numerous anecdotes of farmers and others who hang their jacket on the pipeline warning sign and proceed to dig right next to it.

I have referred semi-disparagingly here to people who used strange thinking and/or did not believe they needed to follow rules, but I think the real problem is just as much with those of us in the pipeline industry who don’t understand the reasoning that might be used by others who are different from us.

Not long ago I was fascinated by the book Everything is Obvious – Once You Know the Answer;  How Common Sense Fails, by Duncan Watts (an Australian physicist turned sociologist and head of research at Yahoo – interesting career path!).  At one point he says:

Plans fail … not because planners ignore common sense but rather because they rely on their own common sense to reason about the behaviour of people who are different from them

That statement seems to apply in spades to the problem of people who ignore all the measures that thoughtful and well-intentioned pipeline engineers and operators put in place in the hope of preventing pipeline damage.  Just because it is common sense to us doesn’t mean that everyone else will share the same interpretation of “common sense”.

For this reason I am keen to see what the pipeline industry can learn about how people outside the industry think about the procedural protection measures we use.  But regardless of that, incidents like these reinforce yet again the danger of believing that procedural controls provide complete protection.  Others think differently.

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2 Responses to Procedural controls

  1. Anonymous says:

    Could not agree more with the issue of procedural control and what appears to the pipeline engineering fraternity as common sense when it comes to dial before you dig or other such procedures, the most common threat to pipelines continues to be mindless third party activities above or adjacent to pipelines without regard to such protection measures. As a regulator I continue to be confronted with such incidents as reported to me by pipeliners operating in my state and it continues to be my biggest worry confronting me as a regulator when it comes to pipeline protection.

    Case in point here are the extracts below from my annual compliance report for 2011 (Petroleum and Geothermal Energy Act annual compliance report 2011). The first, relates to a pipeline encroachment incident resulting in contact with the pipeline which under the Petroleum and Geothermal Energy Act 2000 is classified as a serious incident and as a matter of policy I am required to publish all such incidents pursuant to our transparency policy and principle.

    The second details an aspect of our surveillance activities which addressed a matter relating council contractors failing to comply strictly with the dial before you dig requirements.

    Both these matters clearly demonstrate that the pipeline industry and regulators need to continue to reinforce the importance of procedural controls and maybe one day they will become common sense to all and not just pipeline industry.

    4.6 Unauthorised encroachment incidents
    On 6 October Epic Energy reported an unauthorised encroachment incident across the Moomba to Adelaide gas pipeline involving a third party contractor installing flowlines for Santos. The encroachment incident resulted in the contractor making minor contact with the gas pipeline, whilst potholing, that required coating repair.

    The primary root cause of this incident was failure of the third party contractor, through the relevant licensee (Santos), to follow correct procedures and protocols that are in place for notifying the pipeline operator of any proposed works across the pipeline easement.

    Epic Energy have re-communicated to both Santos and the relevant contractor the correct protocol when
    undertaking pipeline crossing works, including the need for Epic Energy supervision.

    3.10.2 Pipeline surveillance
    In November DMITRE officers accompanied APA Group personnel at a meeting with the Berri Barmera
    Council to reinforce the requirements and intent of ‘dial before you dig’ procedures in relation to
    undertaking any works within the vicinity of a high-pressure transmission pipeline. Further to the meeting, DMITRE reinforced the dial before you dig requirements and obligations of the council with these requirements in writing.

    Michael Malavazos
    Director Engineering Operations Branch

    Energy Resources Division
    Department for Manufacturing,
    Innovation, Trade, Resources and Energy

    T – +61 (8) 8463 3245
    F – +61 (8) 8463 3229
    M – 0401 121 666

    Level 6, 101 Grenfell St
    Adelaide, South Australia 5000

    GPO Box 1264
    Adelaide, South Australia 5001

    michael.malavazos@sa.gov.au
    http://www.pir.sa.gov.au/petroleum

  2. Peter Owbridge says:

    Having a building (three story) being erected at 3m into the easement and at 3m distance from the pipeline was a definitive wake up call as to how others perceive our “Procedural” Controls.

    Terms of the easement were explicit and the owner was well aware of them. Simply put; following an application for a building permit (at 3m from the pipeline and obviously sought from Council prior to obtaining authority from the pipeline licensee) it was deemed to be legitimate that the issued permit could over ride the terms. There was no recourse from Council isuing the building permit as they do not have to look at easements on Title which is left up to Legal Conveyancors under Common Law. However, the landowner did not approach his Legal Counsel as this was only for a building permit application and once received was deemed to be allowable.

    Following this incident the root cause was determined as there being no effective Procedural Control in place and that additional procedural control was required for the Council planners to be provided with the information they did not have to read when issuing permits or Resource Consents. To achieve this we set about obtaining a position of Requiring Authority (Local Authorities are Requiring Authorities and Infrastructure deemed critical can apply for status under the Resource Management Act) so that we could lodge a Notice of Requirement (NOR) to designate the pipeline corridor. The designation places the pipeline corridor on every District Plan Map which ensures a mandatory review by planners when issuing any pemits or resource consents. This designation took 4.5 years to accomplish and cost in excess of a million dollars.

    This additional “procedural” control does adress the root cause of the previous failure but as it is only Procedural must still be monitored for effectiveness on a regular basis and reviewed in our Safety Management System reviews

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