PSMS Lessons Learned – November 2024

Reducing Operational Risk Thorough Effective Oversight & Support

Effective oversight and support of the contractor workforce is a key strategy for reducing operational risk, by ensuring company procedures are consistently reviewed, followed, and enforced. This defense-in-depth support strategy is an essential layer-of-protection, helping to identify and address potential non-conforming work practices or other issues early. Regular quality inspections and continuous monitoring further strengthen this approach, ensuring that work is completed to the highest standards and in compliance with all relevant guidelines and regulations.

Description of Event:

During diagnostic testing of low cathodic protection reads, a Corrosion Technician identified multiple services that were missing an insulated coupling. All occurrences were “plumbers’ headers,” without a meter bar. An insulated coupling is needed to provide corrosion protection gas assets from stray voltage on the main and houseline. A contractor working on behalf of the Company installed storm hardening equipment in potential flood zone areas and failed to install the insulated couplings. The Operators internal staff worked together to remobilize the contractor to install the missing insulated couplings, investigate all previously completed jobs and to better understand why this non-conforming event occurred.

Root Cause(s) and Contributing Factor(s):

• Primary Causal Factor: Contractor failed to re-install insulated coupling on plumber’s header after storm hardening valve installation retrofit.
• Root Cause: Management System – Company O&M procedures were not followed, post installation inspection not conducted.

Key Corrective Actions:

• Contractor to conduct safety stand down with all crews to go over policies and procedures for installing storm hardening equipment.
• Contractor to increase oversight and Quality Assurance checks of crews installing storm hardening equipment.
• Operator to review contractor oversight protocols and consider increasing oversight over specific Contractor projects. Quality Assurance to increase site visits to assure compliance.

Key Lessons Learned:

• Providing oversight on contractor projects to ensure individuals are following procedures and policies is critical to the success of our Pipeline Safety Management System.
• Employees and Contractors need to routinely review Company procedures and policies to refresh crews and avoid complacency.
• Incorporate essential work practice reviews into Pre-Job Briefs as a layer of protection reminding crews of key work practice elements during work plan execution.

In summary, our safety culture mindset should encourage a defense-in-depth approach to ensuring work practice conformance including quality control inspections. We need to view the third-party work inspection process as a positive, behavior influencing practice and coaching opportunity rather than a punitive enforcement tool. From a PSMS perspective, we must work to encourage a safety culture of positive work practice behaviors, and the inspection process is an essential layer-of-protection to encourage positive behaviors as part of the plan-do-check-act process.