To evaluate each PHMSA question will require the discussion of a number of background questions to support the auditor's evaluation of the operator's compliance. During the mock audit, I would ask a number of additional questions gathered from PHMSA inspection guidance, PHMSA Enforcement case findings and my own experience.
CRM, SCADA, and Leak Detection - Operating Experience
1. Reportable Incident (Review) Is there a formal, structured approach for reviewing and critiquing reportable events to identify lessons learned? (CR.CRMEXP.REPORTABLEINCIDENTREVIEW.P) 192.631(g)(1)
Operator does/does not incorporate a methodology to determine the
cause of the event. ____________
A root cause analysis process is/is not used when applicable. ____________
Secondary or contributing causes are/are not addressed. ____________
Event cause analysis includes analysis of the potential contribution of controller
or control room decisions/actions to the event. ____________
Operator’s procedure identifies the person to review control room involvement
in a reportable event ____________
Operator has a step by step procedure to evaluate control room involvement
in a reportable event ____________
Operator has a form to document the evaluation of control room involvement
in a reportable event ____________
Operator’s procedure includes examples of documentation required to complete a
form for evaluation of control room involvement in a reportable event ____________
Operator evaluates, identifies and addresses potential contribution of
erroneous training. ____________
The operator’s review and critique of actual failure experience critiques the adequacy of
SCADA design and performance of both the primary and back-up systems. ____________
Sat+ Sat Concern Unsat Not Applicable Not Covered
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