@menome/document-to-graph/tests/testSection6.txt

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6 Stakeholder Engagement
6.1 General
The pipeline operator shall maintain a process and a plan for communication and engagement with internal and
external stakeholders regarding risk identification and management, safety performance, and as appropriate, other
PSMS elements. The plan shall identify the organization’s stakeholders, both internal and external, and the
communication responsibilities of pipeline operator personnel.
Stakeholder engagement plans shall identify specific objectives and the personnel responsible for sharing and
receiving information. The operator shall identify the types of information to be shared and how it is valuable in
improving pipeline safety.
6.2 Internal
The pipeline operator shall establish processes to communicate the importance of meeting requirements of the
PSMS to appropriate functions within the organization. Employees and contractors shall understand the policies,
goals, objectives, and procedures pertinent to their work that are driven by the PSMS.
The pipeline operator shall maintain a process for employees and contractor personnel to raise concerns to
management and make recommendations for improvements in risk identification, prevention, and mitigation.
Management shall promote an environment encouraging two-way communication. Management shall also implement
a process for communicating and applying lessons learned.
10 API RECOMMENDED PRACTICE 1173
6.3 External
The pipeline operator shall maintain a process and a plan for two-way communication with external stakeholders. The
process shall address providing information, engaging regulatory bodies, and handling of feedback from
representatives of the public. The pipeline operator shall identify external stakeholders through ongoing use of
appropriate company and public processes, events, social media, or other methods. The objectives are to provide a
means through which stakeholders can acquaint themselves with the company and the company can be acquainted
with stakeholders who want to maintain an ongoing dialogue regarding safety and asset-related concerns. The
communication process should address a high-level view of company safety operations, the current focus of risk
management efforts, and measures the operator uses to gauge safety performance.
To the extent possible, the pipeline operator shall identify personnel who are available to the public to exchange
information regarding pipeline safety matters, particularly where stakeholders can provide the operator with
information about changing risk in the physical environment surrounding the pipeline. Operators shall develop and
execute plans to share safety performance with those that live, work, and play in proximity to their pipelines and
identify personnel who can receive input regarding concerns about information transparency.
NOTE 1 Examples include members of the public; local, state, and federal regulators; industry organizations; shippers;
shareholders; emergency responders; law enforcement; and others as identified by the company. This includes peer-to-peer
information sharing within the industry.
NOTE 2 Refer to API 1162, Public Awareness Programs for Pipeline Operators.
7 Risk Management
7.1 General
The pipeline operator shall maintain (a) procedure(s) for the performance of risk management. The operator shall
maintain a description of the assets comprising the pipeline, including the surrounding environment, to identify threats
to pipeline safety.
The operator shall analyze risk considering the threat occurrence likelihood and consequence. The operator shall
evaluate pipeline safety risk and make decisions on how to manage it through preventive controls, monitoring, and
mitigation measures.
NOTE 1 Risk management is used to understand and evaluate threats throughout the pipeline life cycle and their
interrelationships along particular pipelines. Risk management steps are undertaken to reduce risk and support achieving a goal of
zero incidents.
NOTE 2 The term “threat,” meaning threats to pipeline safety, is used in this document in a similar way that “hazard” is used in
other industries. The intent in identifying threats or hazards is to define “what can go wrong?”. Threats in this context are broader
than the set typically considered for pipeline integrity.
NOTE 3 The term “threat” can be applied broadly in a PSMS, such as a threat to a safety culture (NEB Statement on Safety
Culture), or a threat to the knowledge and experience of an organization through retirements and attrition. These threats can be
assessed using risk assessment and managed with prevention and mitigation measures.
7.2 Data Gathering
The pipeline operator shall maintain an inventory of the pipeline and environment in proximity to the pipeline that is
required to define safe operating conditions (e.g. maximum operating pressure [MOP] and maximum allowable
operating pressure [MAOP]) as well as maintenance. Recognizing that where there are historical gaps in data, the
operator shall work to close gaps through on-going work related to operations, maintenance, and pipeline integrity or
use conservative assumptions in setting operating parameters until a gap can be closed.
PIPELINE SAFETY MANAGEMENT SYSTEMS 11
These data serve as the foundation of risk management and shall include available data over the pipeline life cycle
and shall be updated based on work performed and as needed during the life of the pipeline. Incident data, including
the cause of incidents, shall be included as appropriate. The pipeline operator shall conduct a regular review to
identify data gaps and evaluate data quality as part of risk assessment, consistent with continuous improvement.
7.3 Risk Identification and Assessment
Risks to pipeline safety that could result in an unintended release or abnormal operating conditions shall be identified,
based on data and information, as well as knowledge and experience with similar facilities. The operator shall
maintain a process to identify threats that are posed by operations and the operating environment, including changes
in conditions that could occur between assessments. The process shall identify locations where multiple threats are
potentially interactive and thereby increase risk. In conducting an assessment of threats, operators should be mindful
of “what can go wrong?”.
Risk assessment shall consider the likelihood and severity of threats using any one of a variety of risk management
tools. Risk assessments shall be performed and updated as information and conditions change to identify and
understand the collective threats and support the selection of prevention and mitigation measures to minimize the
likelihood of the occurrence and consequences of an unintended release and the likelihood of abnormal operating
conditions.
NOTE Refer to ASME B31.8S, Managing System Integrity of Gas Pipelines, Section 5 and API 1160, Managing System
Integrity for Hazardous Liquid Pipelines, Section 7.
7.4 Risk Prevention and Mitigation
Risk prevention and mitigation measures to reduce the likelihood and consequences of a release shall be identified
and evaluated to improve situational awareness. Information to consider shall include, at a minimum:
a) learnings from internal and external events;
b) review of equipment operability, including control systems and materials;
c) review of procedures, authorities, responsibilities, and accountabilities;
d) review of training, drills, and scenario development;
e) review of incident response preparation, including response time adequacy and the ability to coordinate and stage
an incident command system with response personnel internal and external to the organization;
f) identification of areas of high consequence; and
g) in selecting measures to reduce risk, preference shall be given to prevention measures that eliminate or reduce
the likelihood and/or consequences of incidents. Operators shall implement the selected measures and evaluate
their impact on risk.
7.5 Periodic Analyses
Risk assessments shall be reviewed at least annually, and updated as warranted, using data and information gained
from operations and maintenance, inspection and testing, integrity-related work, and incident investigations.
7.6 Risk Management Review
Risk management results, including selected risk mitigation methods and their intended effectiveness shall be
reviewed, at least annually, with top management.