It’s 2010, the scene – Talmadge Creek, Marshall, Michigan. Talmadge Creek is a tributary of the Kalamazoo River, a critical waterway that spans 10 Michigan counties and ultimately empties into Lake Michigan. On Sunday, July 25, an Enbridge pipeline ruptures and more than one million gallons of crude oil surge down Talmadge and into the Kalamazoo. The event becomes one of the worst inland oil spills of all time.
In the years following the river’s befouling, the National Transportation Safety Board (NTSB) and Pipeline and Hazardous Materials Safety Administration (PHMSA) both make several recommendations aimed at improving pipeline safety. The recommendations are directly influenced by the devastation in Michigan. One of the key ideas to originate in the aftermath of the spill is Pipeline Safety Management Systems (PSMS), a framework intended to help operators continuously improve safety efforts. Formalized in the 2015 American Petroleum Institute (API) Recommended Practice (RP) 1173, PSMS are currently voluntary, but should be taken a step further.
According to API, “a Pipeline SMS is an ever-evolving journey to zero incidents,” which is a goal shared by Pipeline Safety Trust (PST), the pipeline industry, and PHMSA. On its website, pipelinesms.org, API elaborates further on PSMS and states they are, “a systematic, deliberate approach to managing the safety of the workforce, the public, and the company’s asset.” API adds that utilizing PSMS allows operators to “continuously improve processes, procedures, performance, and [safety] culture.”
The central tenet of PSMS is a cycle referred to as “Plan-Do-Check-Act.” To ensure that a pipeline operator’s PSMS continues to develop and improve over time, a regularly reviewed guiding framework, centered around Plan-Do-Check-Act, is put into place. This framework looks different from operator to operator. API states that “PSMS helps operators understand, manage, and continuously improve their safety efforts at any stage of their safety program, at companies from 5 to 5,000 employees.”
PST believes that PSMS are just one part of the equation to make a meaningful difference on pipeline safety and that Congress can play a key role by making PSMS mandatory at the federal level. While PSMS is important, it should not be the sole solution for pipeline safety; improved regulations and financially meaningful enforcement are also needed.
We have a long way to go to realize our shared goal of zero incidents. Widespread adoption of PSMS is one element that can help us get closer.
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