Incident Reporting Towards Data Driven Regulations

Risk, Data, and Program Management Overview & SMART form Demonstration

Presented at the Dangerous Goods Symposium

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Agenda Overview of Risk, Data, and Program Management • PHMSA 2021 • PHMSA’s Mission & our Role • Business Lines

SMART Form • Incident Reporting Overview • SMART form purpose and goals • Project Overview • Interactive Demonstration

Coming Attractions • Quality Management Systems (ISO 9001) • SMART form Enhancements

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PROTECT PEOPLE AND THE ENVIRONMENT BY ADVANCING THE SAFE TRANSPORTATION OF ENERGY AND OTHER HAZARDOUS MATERIALS THAT ARE ESSENTIAL TO OUR DAILY LIVES

VISION

MISSION

Promote continuous

improvement in safety

performance

Build greater public and

stakeholder trust

Invest in safety innovations

and partnerships

Cultivate organizational excellence and safety culture

Pursue excellence in our operations

PHMSA: THE MOST INNOVATIVE

TRANSPORTATION SAFETY ORGANIZATION IN THE WORLD

GOALS

VALUES TRUST HONESTY RESPECT INTEGRITY VALUING PEOPLE EFFECTIVE COMMUNICATION

PHMSA 2021

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Mission Support

• Identifying information data sources and providing analysis that informs PHMSA decision making.

• Ensuring that PHMSA programs are having the intended outcomes and delivering a quality product.

• Contributing to the development of a strategic direction and the implementation of a data-driven safety agenda.

The Risk, Data, and Program Management Branch supports PHMSA's mission and Vision by:

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Structure

Deputy Associate Administrator of Policy &

Programs

Standards & Rulemaking

Engineering and Research

Approvals & Permits

Field Operations

Grants, Training and outreach

Program Development

Budget and Administrative Services

Risk, Data, and Program Management

Regulatory Support

Risk Analysis

Program Management

Data Operations

Within the Risk, Data, and Program Management Branch we address four primary business lines. These business lines support the various offices

within PHMSA. The Risk, Data, and Program Management branch is unique because our stakeholders are both internal and external.

The Team

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New Staff … New Capabilities In the past year the Program Development Division and the Risk, Data and Program Management branch within it have increased our staffing and thus the capabilities and expertise we offer. In particular we have added permanent leadership in the form of a new director and branch chief. In addition our current roster of staff includes:

• Two Senior economists, • Two data analysts • A program analyst, and, • A statistician.

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Risk Analysis When considering risk (safety or programmatic) OHMS must focus on the elements of risk. It is also important to seek out the data that supports and informs each element. In its most basic form risk is composed of the following elements: • Exposure – The level of interaction with potential hazard. Safety exposure examples include

ton-miles traveled or proximity to railways transporting hazardous materials. Programmatic exposure could include the size of a regulatory portfolio or number of facilities to inspect.

• Vulnerability - The characteristics and circumstances of a community, system or asset that make it susceptible to the damaging effects of a hazard. Safety vulnerabilities could include a packaging that is not adequately designed and programmatic vulnerabilities could include lack of resources or poorly defined processes and procedures.

• Consequences – The extent of the impact of a given event should one occur. This is often defined through predictive modeling based on existing data (I.e. the U.S. safety record).

𝑓𝑓 𝑥𝑥 = 𝐸𝐸𝑥𝑥𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸 𝑥𝑥 𝑉𝑉𝐸𝐸𝑉𝑉𝑉𝑉𝐸𝐸𝐸𝐸𝑉𝑉𝑉𝑉𝑉𝑉𝑉𝑉𝑉𝑉𝑉𝑉 𝑥𝑥 𝐶𝐶𝐸𝐸𝑉𝑉𝐸𝐸𝐸𝐸𝐶𝐶𝐸𝐸𝐸𝐸𝑉𝑉𝐶𝐶𝐸𝐸

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Regulatory Support Risk, Data, and Program Management provides regulatory support in many forms including: • Policy analysis (Pre-Rulemaking) • Economic Analysis • Environment Impact Analysis • White Papers • Research Projects • GIS support • Statistical Analysis

OHMS follows OMB guidelines (Circular A-4 and NEPA requirements) in the development of our analysis

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Program Management The Risk, Data, and Program Management branch provides integrated planning, development, and evaluation of programmatic activities for OHMS. This branch has assisted program offices develop meaningful Key Performance indicators (KPIs) to measure performance and foster continuous improvement. OHMS reviews these KPIs at Management Meetings and the Annual Death and Injury Briefing.

Measurable

Strategic

Resources Targets

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Data Operations

Regulatory Support

Program Management

Data Operations

Risk Analysis

Standards & Rulemaking

Engineering & Research

Approvals & Permits

Field Operations

Outreach, Training, & Grants

Program Development

Office of Hazardous Materials Safety

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Data Operations

• OHMS Process on average about 18,000 incident reports per year. • Each of these reports goes through a rigorous quality control process. • The Data operations team actively seeks other sources of data PHMSA

can use to support our safety mission (Commodity Flow , production data, etc.)

2010 2011 2012 2013 2014 2015Paper Reports 6,949 6,027 5,650 6,499 6,796 5,055Online Reports 4,861 4,679 4,833 8,649 6,471 4,515XML Reports 3,829 5,053 3,752 5,365 4,844 3,247

02,0004,0006,0008,000

10,000

Num

ber o

f Inc

iden

ts

DOT 5800.1's Completed By Source 2010-2015

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Agenda Overview of Risk, Data, and Program Management • PHMSA 2021 • PHMSA’s Mission & our Role • Business Lines

SMART Form • Incident Reporting Overview • SMART form purpose and goals • Project Overview • Interactive Demonstration

Coming Attractions • Quality Management Systems (ISO 9001) • SMART form Enhancements

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Incident Report Overview

Incidents “Think before you ship!”

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What is an Incident?

An unintentional release of a hazardous material or discharge of hazardous waste; a cargo tank with a capacity of 1,000 gallons or greater containing any hazardous material that suffers structural damage to the lading retention system; or an undeclared hazardous material.

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Immediate Incident Reporting

Incidents The 49 CFR Section 171.15 requires an immediate telephonic report be filed within 12 hours of certain hazmat incidents. • A person is killed • Injury requiring admittance to the hospital • Evacuation of general public for one hour or more • One or more major transportation arteries are closed for one

hour or more • Operational flight plan is altered • Fire, breakage, spillage involving radioactive material • Fire, breakage, spillage involving an infectious substance • Release of marine pollutant in a quantity exceeding 450 liters

for liquid or 400 kilograms for solids

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5800.1 Incident Reporting

Incidents The 49 CFR Section 171.16 requires that a 5800.1 report be submitted within 30 days of discovery of any of the following: • An incident that was reported under 171.15 • An unintentional release of a hazardous material during

transportation • Release of a hazardous waste • Undeclared shipment with no release is discovered • A Specification Cargo Tank 1,000 gallons or greater containing

hazardous materials that received structural damage to the lading retention system and did not have a release

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5800.1 Incident Reporting Exceptions

Incidents You are not required to report a release of hazardous material if ALL of the following apply: • The shipment is not being offered for transportation or being transported

by air; • None of the Criteria in 171.15(a) applies; • The material is not a hazardous waste; • The material is properly classed as an ORM-D, or a Packing Group III

material in Class or Division 3,4,5,6.1, 8 or 9; • Each package has a capacity of less than 20 liters (5.2 gallons) for liquids or

less than 30 kg (66 pounds) for solids; • The total aggregate release is less than 20 liters (5.2 gallons) for liquids or

less than 30 kg (66 pounds) for solids; • The material does not meet the definition of an undeclared hazardous

material in 171.8; and • The shipment is an undeclared material discovered in an air passenger’s

checked or carry-on baggage during the airport screening process. *Additional exemptions can be found in CFR 171.16D

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How is a DOT 5800.1 Form filed?

Incidents • Paper forms can be submitted via postal mail or email using a

fillable Adobe Acrobat file • Electronic submissions can be submitted via PHMSA’S Website

utilizing the online fillable form or authorized entities using extensible mark-up language (XML) files, which is a set of rules for encoding documents in machine-readable form

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What Data Do We Collect Via the 5800.1?

• Who, What, Where, and When • Characteristics of the release:

‒ Material ‒ Packaging ‒ Hazard Communication ‒ Handling

• Consequences • Causation • Compliance and non-compliance

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Who must complete the 5800.1 Form?

• If a hazmat incident occurs, any entity in possession of the hazmat during transportation – including loading, unloading and storage incidental to transportation – must report the incident if certain conditions are met.

• The Entity having physical control of the shipment is responsible for completion and submission of DOT Form 5800.1 ‒ Carrier ‒ Shipper ‒ Facility ‒ Other

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5800.1 Form Did You Know?

Recordkeeping • You must Keep a copy or Electronic Image for Two years after the date

you submit to PHMSA. • Must be accessible through your company’s principal place of business • Must be made available upon request within 24 hours

Form Updates • A death results from injuries cause by a hazardous material • Damages or related costs that were not known at the time the report

was filed become known • Misidentification of hazardous material or packaging information • Revised estimates of damages, losses, and related costs result in a

change of $25,000 or more or 10% of original cost estimates.

Incident Reporting Processing Not so Simple

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Incident Reporting Processing

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KEY I = Paper Submission E = Online Submission X = XML Submission

Scanning (I only)

Data Entry (Select I reports)

QC1/KOFAX (I only)

Report is scanned, validated, and

uploaded to FYI or KOFAX.

Data is entered into HMIS.

Additional validation of data is

performed, including character-

to-character.

QC2 (I, E, X)

Thorough validation is conducted.

Includes analysis of data accuracy,

anomalies, business rules, and

consequences.*

Completion Phase

Incident report is made accessible in

HIP and available to the public.

*Note: For incidents involving D&Is, CTMV rollovers, and public evacuations, additional validation is performed.

Hazmat Accident

National Response Center

Un-reported Incident

Reported Incident

SMART form - BLUF

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Project Goal: Implement a new Reporting System with modernized capabilities that provide further automation and improved efficiencies and user experience for stakeholders

Current System - Abandoned / incomplete reports - Linear data processing leads to

bottlenecks - Business rules limited, leading to

conflicting data points - Multiple reports for a single incident - User Guidance is separate document

SMART form - Reduce the number of incomplete

reports - Eliminate the need for multiple reports

for a single incident - Business Rule Validations

- Not just a face lift - It is an internal and external revamp

- Improved Process Flow - Built-in Guidance (Tooltips)

Project Approach

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Agile Approach to Development 10 Week Discovery Phase Multiple requirements validation working sessions Concept discussions Gap Analysis Baseline Requirements List High Level Design Project Implementation Plan

3 Week Sprints Planned 15 Iterations (cycles) of 3 weeks each Identify priorities, build plan, implement and test Demo to elicit approval, recommendations and changes

Release FY 17

Plan

Implement

Test

Demo

Stakeholders Impacted

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SMART form Project benefits both internal and external stakeholders. Internally it provides improved process flow and automation. Externally it provides a better user

experience. All stakeholders benefit from improved data quality.

SMART Demonstration

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• Focuses on the external interface our public stakeholder will use to input incident reports.

• Accessed through the PHMSA portal • This only tells half the story as this project also

upgrades the internal interface.

SMART Demonstration

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Linear data processing that can lead to bottlenecks Improved Process Flow

X X X

SMART Demonstration

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User Guidance is a separate document

Current Form – User Guidance

SMART Demonstration

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SMART Form – User Guidance / Tool Tips

Built-in Guidance Tool tip Help – Instruction Booklet

SMART Demonstration

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SMART Form – Business Rule Validation

SMART Demonstration

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SMART Form – Business Rule Validation

SMART Demonstration

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SMART Form – Multiples / Incident Shopping Cart

Shipper

Commodity

Package

SMART Demonstration

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SMART Form – Attachments / Supplemental material Add Attachments

Soft Validation

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Hard Error Message

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SMART Demonstration

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SMART Form – Addition Enhancements

• Additional External enhancements ‒ System generated email notification (7, 14, 21 days) to

limit abandon reports. ‒ System generated email notification (11 months after date

of incident) to remind submitter of requirement to update

• Behind the Curtain enhancements ‒ Even more business rules built in ‒ Improve matching of potential reportable incidents and

NRC incidents with 5800.1 forms ‒ Process flow tracking ‒ Improve automation of some tasks

In Summary

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SMART Form … • Aligns with agency strategic goals • Reduce Government resources by decreasing processing

time • Enforces data correctness and data completeness, while

allowing users to provide as much information as possible • Is simple, comprehensive, intuitive, modern, flexible • Enhances the Internal and External user experience by

simplifying the process and improving efficiencies • Provides role based security and access through the PHMSA

portal • Integrates with other PHMSA portal based systems (Special

Permits, Case Management, HIP and so on)

What’s Next

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SMART Form (Continued Enhancements)

• Incorporation of Customer Feedback and User Testing • Increased back-end automation • Other enhancements to be determined.

International Standard Organization (ISO) 9001 Certification

• Data Operations is establishing an ISO 9001 compliant Quality Management System that will include a quality manual, standard operating procedures and business processes, process maps and responsibility matrices.

• Based on a strong customer focus, top management engagement, the process approach, and continual improvement through audits for nonconformities.

• OHMS expects this effort to improve processing times and efficiencies, resource use, stakeholder satisfaction, and data quality and consistency.

Data Visualization and Analysis

• Efforts include a website enhancements to provide a more interactive experience for stakeholders, and targeted analysis on hazardous materials topics of interest.

Questions

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