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On July 30, the National Transportation Safety Board (NTSB) issued a safety alert titled “Pipeline Safety Management Systems: Vital for the Safe Operation of Pipelines”. The NTSB is an independent federal agency charged by Congress to investigate transportation events and accidents. It typically issues “safety recommendations” as a result of a singular incident, but will occasionally issue “safety alerts” when they believe there is a topic or issue that is relevant to several of their investigations.

• Although PSMS have been adopted by operators representing 85 percent of industry pipeline mileage, many operators, particularly smaller operators, have not yet adopted PSMS.
• The pipeline industry continues to have accidents that could have been prevented or the consequences more effectively mitigated had risks been more thoroughly identified and addressed.
• Without full commitment from the pipeline industry to implement and mature PSMS, pipeline accidents will continue to occur and the industry will not be able to meet their goal of zero accidents, fatalities, and serious injuries.
• What the NTSB believes pipeline operators can do:
• Implement a robust PSMS as described in American Petroleum Institute (API) Recommended Practice (RP) 1173. API RP 1173 Pipeline Safety Management System Requirements provides guidance for operators to establish a system to continuously track and improve safety.
• For those who have incorporated PSMS into their practices, continue to improve operations and training. Pipeline operators with PSMS cannot be complacent. One of the hallmarks of a good PSMS is that it continuously evolves and improves safety programs.
• Support revisions to API RP 1173 and other guidance as it is developed to include small operators and contractors in their efforts to establish a PSMS. According to the 2022 Pipeline SMS Annual Report, “Last year also featured important initiatives to support small operator and contractor implementation of RP 1173 along their journey of continuous improvement and the combined vision of One Industry, One Team, One Mission, Pipeline Safety.”
• With a PSMS, operators can ensure pipelines are designed, constructed, operated, and maintained in a way that complies with more than the minimum safety standards found in regulations. Experience has shown that using a PSMS can be effective and result in significant reductions of serious pipeline accidents each year.

APGA's comments stated, "This alert is consistent with all previous messaging from both the NTSB and the Pipeline and Hazardous Materials Safety Administration (PHMSA) – PSMS is a critical tool in the industry’s efforts to eliminate pipeline incidents. Importantly you’ll note that the NTSB does not suggest that PHMSA incorporate API RP 1173 into federal pipeline safety regulations. The NTSB recognizes the challenges that small operators face when trying to implement PSMS per API RP 1173. The NTSB supports APGAs efforts to provide guidance for small operators within API RP 1173 and tools to assist the implementation of PSMS."

For questions on this article, please contact Erin Kurilla of APGA staff by email at ekurilla@apga.org.