Human Factors and Safety Are Focus Of Proposed PHMSA Rule

By Charles Alday and Michele Terranova, Pipeline Performance Group | April 2009 Vol. 236 No. 4

“Why don’t you pipeline companies address controller fatigue?” That question was asked by a member of the National Transportation Safety Board (NTSB) in 2000 while discussing a pipeline accident with one of the authors. The authors can attest that reducing accidents caused by human fatigue is a task on the “NTSB Most Wanted List.”

Wording in the PIPES Act of 2006 indicates to the authors that regulations shall be issued that require operators of gas and hazardous liquid pipelines to evaluate and take measures to reduce risks associated with human factors, including fatigue, for pipeline controllers and other employees. Indeed, a proposed rule, “Pipeline Safety: Control Room Management/Human Factors” was issued by the U.S. Department of Transportation’s Pipeline And Hazardous Materials Safety Administration (PHMSA) in Sept., 2008.

Proposed Rule

What is a human factor? What measures can be taken to reduce the risks of human factors? What mandates does the proposed rule include that address human factors? The industry has addressed some of the issues through operator qualification, but the proposed rule outlines others.

The term human factors applies the knowledge of human capabilities and limitations to the design, operation, and maintenance of a system. When human factors engineering is integrated into all aspects of a pipeline system, the risks of accidents from human error can be reduced. The public, the employees, and the environment are safer. The company has a more efficient and effective operation.

Human factors examines the interaction between people and all of the factors around them – the environment, the procedures, equipment and other people. The discipline of human factors looks at the people, the job, the organization, the environment, and the resources. The goal is to improve the interactions.

The “tight coupling” of a pipeline system makes it vulnerable to an unexpected event or series of events. This is one of the reasons the proposed rule includes sections on SCADA displays, communications, management of changes, alarm management, shift exchange, learning from experiences, qualifications, roles and responsibilities, validation, as well as fatigue mitigation.

An accident usually has multiple causes, and a failure in one area can lead to a failure in another area. Organizations, jobs and individuals may function independently, but all the functions are connected and interdependent. The key aspects of human factors are related to the individual, the organization and the specific job (Figure 1, above).

Humans have certain capabilities and limitations for physical functions such as vision and hearing, but also for social, emotional, and cognitive performance (Figure 2). Each person in a company has physical, mental, intellectual and psychological strengths and weaknesses. Issues in personal lives and health also affect performance. Some of these factors are straightforward and easily measured, while others are difficult to measure or unpredictable. The proposed rule contains requirements for addressing the capabilities and limitations. For example, fatigue is an issue that affects all humans. That fact needs to be addressed through an evaluation of the shift work policies and practices, ongoing education, the responsibilities of the employee and the company, and communication during shift exchange, and in other ways. Ensuring that human capabilities and limits are not exceeded promotes a safe level of operations.