Articles
Lesson's learned from Citgo's recent PHMSA warning letter
October 13, 2024
On August 30, 2024, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a warning letter to Citgo Products Pipeline Company regarding several potential violations of the Pipeline Safety Regulations during an inspection of the Lakemont Pipeline System. While it’s easy to view such letters as just bureaucratic paperwork, they provide critical lessons for all operators in the industry. Let’s break down the key lessons learned from this warning letter, keeping in mind the specific regulations cited.
1. Importance of Post-Accident Reviews
The letter highlights that Citgo failed to conduct post-accident reviews as required by § 195.402(a) and § 195.402(e)(9). These reviews are essential for understanding how procedures hold up in real emergencies and for implementing necessary corrective actions.
Lesson: Operators must prioritize post-accident reviews to assess the effectiveness of their procedures and to learn from each incident. It's not enough to simply file an incident report; thorough reviews help to enhance safety measures for future incidents.
2. Adherence to Written Procedures
Citgo was found not to follow its own procedures for conducting annual firefighting extinguisher inspections, as stipulated in § 195.430(a). This regulation mandates that adequate firefighting equipment must always be in proper operating condition.
Lesson: It’s crucial for companies to not only have written procedures but to ensure that these are actively followed and documented. Regular audits can help identify gaps in compliance and ensure that safety equipment is maintained correctly.
3. Regular Manual Reviews
The letter indicates Citgo's failure to conduct timely reviews of its operations and maintenance manual, violating § 195.402(a). These reviews are intended to ensure that the manual remains effective and updated.
Lesson: Establishing a routine schedule for manual reviews—no more than 15 months apart—is essential. This not only ensures compliance but also helps identify any outdated procedures that may pose safety risks.
4. Periodic Effectiveness Reviews
Under § 195.402(c)(13), operators are required to review the work done by personnel to evaluate the effectiveness of their procedures. Citgo’s failure to do so over several years is a stark reminder that ongoing assessments are necessary.
Lesson: Regularly evaluating the effectiveness of operational procedures can uncover inefficiencies or issues before they lead to significant problems. It’s a proactive approach to safety management.
5. Emergency Response Training and Verification
Citgo also fell short in ensuring that its supervisors maintained knowledge of emergency procedures per § 195.403(c). The letter points out the absence of adequate training records for emergency response.
Lesson: Training is not a one-time event; it should be ongoing. Documenting and verifying training helps ensure that all personnel are equipped to handle emergencies effectively.
6. Testing Communication Plans
The regulation § 195.446(c)(3) requires operators to test their internal communication plans at least annually. Citgo’s failure to do this raises concerns about the adequacy of communication during emergencies.
Lesson: Companies must regularly test communication systems to ensure they function effectively in crisis situations. This can mean the difference between a minor incident and a major disaster.
7. Understanding Civil Penalties
The letter outlines potential civil penalties ranging up to $266,015 per violation per day. This underscores the financial implications of non-compliance with safety regulations.
Lesson: Beyond the obvious safety concerns, non-compliance can lead to significant financial repercussions. Organizations must take these regulations seriously to avoid penalties and maintain their operational licenses.
Conclusion
The warning letter from PHMSA serves as a powerful reminder of the importance of compliance with pipeline safety regulations. For operators like Citgo and others in the industry, the lessons learned from this inspection are invaluable. By prioritizing thorough training, adherence to procedures, and regular reviews, pipeline operators can not only enhance safety but also build a culture of accountability that ultimately benefits everyone involved.
