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The PHMSA-CRM rule can seem complicated and open to interpretation, but using the guidance of TiPS, Inc. industry experts and automation best practices, such as ISA 18.2, room for interpretation is minimized. It is advisable to follow the most stringent standard or best practice for compliance, safety, and exposure protection.

An effective plan needs to be long enough to contain all of the needed design decisions required for your entire alarm system. If you are a U.S.-regulated pipeline operator, you most likely know that following the release of ANSI/ISA 18.2 in late 2009, PHMSA amended its pipeline safety regulations to prescribe safety requirements for controllers, control rooms, and SCADA systems used to remotely monitor and control pipeline operations.

The goal is to enhance safety and performance of personnel controlling pipeline operations. The deadline to meet PHMSA’s alarm management requirements has been accelerated to August 1, 2012.

For a more detailed description, please download the first whitepaper of the PHMSA CRM Myths: Alarm Management Truth Detectors series.

This whitepaper is the final of a three-part series addressing commonly-held perceptions surrounding the PHMSA-CRM rule and alarm rationalization and documentation. Click here to download part one about deadlines, the definition of a control room, and SCADA systems. Part two discusses alarm management plans.

 While the CRM rule [49 CFR 192.631(e) and 195.402(e)] does not explicitly use the term rationalization, the process of rationalization is key to meeting the rule’s requirements.

  • Section (e)(5) requires that the operator “assure that controllers have sufficient time to
    analyze and react to incoming alarms.”
  • Section (e)(3) requires that the operator “verify that alarm set-point values and alarm
    descriptions are correct,” 

In addition, CRM Inspection Question E0-1a, issued June 17, 2011, specifically identifies alarm rationalization as a “critical topic” to be included in the operator’s alarm management plan