Pipeline SMS Element 5: Operational Controls
The Backbone of Safe Pipeline Operations
Keeping Pipelines Running Safely and Smoothly
On March 25, 2025, U.S. Transportation Secretary Sean P. Duffy, through the Pipeline and Hazardous Materials Safety Administration (PHMSA), urged all regulated pipeline operators to adopt Pipeline Safety Management Systems (PSMS), as detailed in a Federal Register advisory. This push, aligned with API Recommended Practice (RP) 1173, emphasizes a proactive safety culture--an evolution PHMSA Acting Administrator Ben Kochman says will drive the industry toward "zero incidents." I’ve covered the foundational elements of PSMS in previous articles: Leadership and Management Commitment (Element 1), Stakeholder Engagement (Element 2), Risk Management (Element 3), Incident Investigation (Element 4), and Training and Competence (Element 5). Today, we turn to Element 5: Operational Controls, the framework that ensures pipelines operate safely, reliably, and in compliance with regulations and industry standards.
Operational Controls, as outlined in API RP 1173, are the guardrails of daily pipeline operations. They translate the risk management strategies from Element 3 and the lessons from incident investigations in Element 4 into actionable, on-the-ground practices. With 3.4 million miles of pipelines crisscrossing the U.S., the stakes are high. A single misstep can lead to disasters like the 2022 Keystone Pipeline spill, which released 2,700 barrels of oil due to integrity failures… a preventable tragedy if robust controls had been in place, as I discussed in Element 3. Element 5 ensures operators have the tools, processes, and oversight to keep systems humming safely.
Let’s break down its four key components:
Operating Procedures
System Integrity
Management of Change (MOC)
Use of Contractors
5.1 Operating Procedures are the Playbook for Safety
Operating Procedures are the step-by-step instructions that keep pipeline operations consistent and safe. API RP 1173 stresses that these procedures must be clear, accessible, and regularly updated to reflect current risks and regulatory requirements. As I highlighted in Element 2, engaging stakeholders--field crews, control room operators, and even local communities is critical to identifying gaps in procedures. For example, a technician on the ground might spot a recurring valve issue that a boardroom executive would miss.
The Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) standard, specifically 29 CFR 1910.119(f), provides a framework for operating procedures that pipeline operators can adopt. OSHA mandates that procedures address normal operations as well as startup, shutdown, temporary operations, and emergency operations. For instance, startup procedures must outline steps to safely bring a pipeline online after maintenance, while shutdown protocols ensure controlled cessation of operations. Temporary operations, such as bypassing a section for repairs, require specific procedures to manage risks during the interim. Emergency operations procedures must detail actions for scenarios like leaks or ruptures, ensuring rapid and safe response. These requirements ensure that every phase of operation is covered, reducing the risk of oversight.
PHMSA’s upcoming Gas Pipeline Leak Detection and Repair rule, although currently on hold, will demand tighter protocols for identifying and addressing leaks, as noted in my Element 3 article. Operators must ensure their procedures align with such regulations, incorporating tools like advanced leak detection systems. Start by auditing existing procedures against API RP 1173, OSHA PSM standards, and PHMSA guidelines. Training is critical--ensure all personnel are competent in these procedures through assessments and ensuring all personnel are qualified/certified to operate the system. Validate the procedures in the field and update them based on feedback. Clear procedures don’t just prevent incidents--they give workers the confidence to act decisively when seconds count.
5.2 System Integrity and Protecting the Pipeline’s Core
System Integrity focuses on maintaining the physical and operational health of the pipeline. This builds directly on the risk management process I discussed in Element 3, where operators catalog hazards like corrosion or third-party damage and implement controls. Integrity management programs, such as those for oil and gas lines, are non-negotiable. The 2022 Keystone spill, a system failure I analyzed in Element 3, underscores the cost of neglecting integrity--environmental damage, economic loss, and eroded public trust. API RP 1173 calls for regular inspections, monitoring, and maintenance to catch issues like soil instability or equipment wear before they escalate.
PHMSA’s new proposed/on hold CO2 pipeline guidelines, mentioned in A New PHMSA Advisory to Enhance Pipeline Safety, highlight the need for integrity checks tailored to specific risks, such as geological hazards. Operators should leverage data from PHMSA’s National Pipeline Mapping System, as I suggested in Element 3, to inform integrity assessments. Continuous monitoring, paired with predictive analytics, can flag vulnerabilities early. For new PSMS adopters, start small: focus on one pipeline segment, conduct a thorough integrity assessment, and build from there. A strong system integrity program doesn’t just mitigate risks, it helps ensure reliability, a point Secretary Duffy tied to energy security in his March 2025 announcement.
5.3 Management of Change (MOC) and Navigating the Inevitable
Change is constant in pipeline operations… new equipment, updated regulations, or shifts in operating conditions. Management of Change (MOC) ensures these changes don’t introduce new risks. API RP 1173 emphasizes a structured MOC process: identify the change, assess its impact on safety, and implement controls before proceeding. This aligns with lessons from Element 4, where I noted that many incidents, like the 2021 San Pedro Bay release, stem from unmanaged changes, such as inadequate updates to operating protocols after equipment upgrades.
The OSHA PSM standard, specifically 29 CFR 1910.119(l), provides a robust MOC framework that pipeline operators can adopt. OSHA requires operators to establish written MOC procedures that address: the technical basis for the change; impact on safety and health; modifications to operating procedures; necessary training; and updates to process safety information. Before implementing a change, employees must be trained, and all affected documentation such as procedures, diagrams, and emergency plans must be revised. For example, if a pipeline operator upgrades a compressor station, OSHA’s MOC rules mandate a risk assessment to ensure the new equipment doesn’t compromise system integrity, followed by retraining operations and maintenance technicians on the new compressor and infrastructure.
Integrating OSHA’s MOC requirements into PSMS strengthens Element 5 by adding a layer of regulatory rigor. Operators should form an MOC team with cross-functional representation including engineers, compliance folks, reliability, and field staff to review changes. Document every step, from risk assessment to training, and audit the process regularly. This not only ensures compliance with OSHA but also builds on the transparency culture I discussed in Element 2, creating synergy and trust across the organization.
5.4 Use of Contractors and Extending Safety Beyond Your Team
Pipelines often rely on contractors for maintenance, inspections, or emergency response. API RP 1173 stresses that contractors must adhere to the same safety standards as internal teams. This ties back to Element 1, where I emphasized that safety culture cascades from the top. Leaders must ensure contractors are vetted, trained, and aligned with PSMS goals. A contractor who cuts corners can unravel years of safety progress, a risk no operator can afford, especially with PHMSA’s heightened scrutiny following Duffy’s advisory.
Contractor management starts with clear expectations. Include safety requirements in contracts, mandate PSMS training, and monitor performance through audits. As I noted in Element 4, incident investigations often reveal contractor-related gaps, such as the 2010 San Bruno explosion, where poor oversight contributed to the disaster. Engage contractors as stakeholders, per Element 2, by involving them in safety briefings and risk assessments. For new PSMS adopters, begin with a contractor safety checklist aligned with API RP 1173, and scale up as you refine your processes.
Tying It All Together
Element 5: Operational Controls is where PSMS turns strategy into action. It builds on the risk management foundation of Element 3 by implementing controls, leverages lessons from Element 4’s incident investigations to refine procedures, ensures competence through focus on training, and extends the safety culture from Elements 1 and 2 into daily operations. PHMSA’s March 25, 2025, advisory isn’t just a suggestion, it’s a preview of what’s coming. As I noted in A New PHMSA Advisory to Enhance Pipeline Safety, 86% of gas distribution operators already use PSMS, and PHMSA at some point will want 100%. Voluntary today could mean mandatory tomorrow.
For operators new to PSMS, start with a gap assessment against API RP 1173, as I recommended in Element 3. Focus on one sub-element… say, Operating Procedures, and build momentum. Train your team, engage stakeholders, and integrate OSHA’s PSM requirements for operating procedures and MOC to ensure safety at every step. Operational Controls is all about building and maintaining a pipeline system that’s safe, reliable, and trusted by the communities it serves. In an industry where one failure can echo for decades, Element 5 is your blueprint for getting it right, every day.
Free Resources
Pipeline SMS Contractors Guide
Getting Started with Pipeline SMS
Pipeline SMS Implementation Planning Tools
OSHA Process Safety Management (PSM) Regulations
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