Site Specific vs Operational SMSs

In 2018 so far, I’ve facilitated a number of site-specific SMS workshops, required because of new developments near existing pipelines.  In AS 2885 terms, these are the “Land Use Change” and / or “Encroachment” safety management studies.

It strikes me how different these site-specific SMSs are, as compared to the 5-yearly operational ones.

With the operational SMS, third-party activity over the pipeline is a possibility, an imagination, a ‘scenario’ that we try to come up with, for the entire length of the pipeline.  We’re peering at satellite imagery or Google Earth trying to imagine if there’s a situation where a third party will be working near the pipeline.  And we’re reviewing existing operational information, inspection details, and past land access requests and DBYD records, and all that goes into the information gathering for an operational SMS  – it’s arduous and detailed work.

For a site specific SMS, it’s a little different:  we know there will be third party activity around and even over the pipeline – that’s why we’ve convened the workshop.  And we know where – it’s a known, defined location.  So there’s no speculation involved.  We know they are going to be there – and maybe even when.  And we know the characteristics of the pipeline there, at that defined location. We can therefore work closely with the developer to prevent unauthorised access. We can even stipulate to the developer the maximum size of excavator allowed on site for their development – which will, conveniently, equate to the size of excavator that has calculated out to be the one that won’t puncture the pipe.  Win!  (And yes, the developer can ignore it  – or, more probably, the sub-sub-sub contractor who actually does the work might not know about the imposed size limit-  but I’m putting that aside here, that’s about control effectiveness.)

For non-location specific threats like corrosion or poor operations procedures, the operational SMS needs to cover all of the possibilities here again.

But a land use change or encroachment? It’s fair to say that the controls  (cathodic protection, coating checks, operational procedures etc) for those identified non-location specific threats should be in place whether the development proceeds or not.  Sure, it’s worth checking the ILI survey to see if there are defects nearby that should be reviewed for repair/replacement before development proceeds, but corrosion as a threat because of a new development? I’m not sure there’s an argument there, and so it doesn’t need to be discussed at the workshop in depth.  And the proponent of the development is not responsible for corrosion control anyway (except in the case of a development causing interference to the CP system).

The 5-yearly operational safety management studies are long, arduous, deep and philosophical (to a point).  One of the purposes of the operational review is for the pipeline owner, operator and staff responsible for that pipeline to review and update what they know about the pipeline corridor, and what’s changed, and what might change.  It can be very judgement based, and requires all of the calculations for the entire pipeline and deep field knowledge about the entire pipeline including what size of machinery might be working around there.  Due to those uncertainties and the inability to definitely say whether these threats are controlled at a specific location, the risk assessment step comes into play, and then quite often the ALARP process as well.

Site-specific studies for encroachment (work on or near the pipeline) can be much more focussed and laser-eyes on the actual possible threats at that actual location – and hopefully that means that the threats can be judged to be controlled, due to the restrictions that can be placed on the developer.  So for an encroachment SMS for a specific construction activity, I might think there is rarely a need to go into the risk assessment step nor ALARP process.  The goal for encroachment is to do everything we can to control the threat, based on the known information about that particular situation.

Site-specific studies for land use change, where the location classification has increased to a higher consequence outcome should there be an event, will of course require some more work by the pipeline company to recognise the additional consequences and modify the pipeline.  But where the location classification doesn’t change, there’s less to focus on.  All controls should already be in place.

I’ll reiterate though that it is still essential to hold an SMS workshop with the developer as per the AS 2885.6 requirements, early in the development planning.  It is essential.  One of the key purposes of these workshops is to inform the stakeholder (developer) about the requirements to keep the pipeline safe.  This is achieved best in a workshop environment, not via letters or emails.

The recent series of workshop facilitations that I have been doing have not resulted in land use change (change of location classification).  The development was either already in a T1 area, or already had a secondary classification which put it in T1 requirements anyway. Or the protection measures were already in place in anticipation of development. I guess I’ve just been lucky so far, not having a contentious SMS workshop situation (yet).

Unless, perhaps, I have over-simplified this.  I’ll bet my next engagement will be a doozy, and I’ll have to come back here and re-write all this.  Because we always keep learning, don’t we?

And a lingering challenge that I’m aware of is that the developer gets an appropriate document from which they understand the summarised requirements that they need to adhere to.  A big long threat list / spreadsheet or SMS database, or an 80-page report, is probably not going to get the salient points across to an overworked developer who is mostly thinking about his profits.

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