PHMSA Compliance

PDCA Applied to CRM: Satisfy PHMSA Pipeline Regulatory Requirements

The ever-changing pipeline regulatory environment means that pipeline operators need to stay on their toes when it comes to their Control Room Management safety program. The CRM Rule (49 CFR 192.631 for the transport of natural gas and 49 CFR Part 195.446 for the transport of hazardous liquids) includes specific requirements that operators must comply …

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2021 PHMSA CRM Enforcement Actions: Section A – Do You Have a Control Room?

There are many safety programs involved in pipeline operations. Because pipeline control rooms are only one aspect of running a safe and efficient pipeline operation, it is easy to overlook the need to verify whether control room management regulations apply to your operation. Performing this review is especially critical following the recent introduction of the …

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2021 PHMSA Enforcement Actions for Control Room Management

Each year, the Pipeline and Hazardous Materials Safety Administration (PHMSA) publishes a summary of enforcement actions taken against pipeline operators whose assets are subject to federal jurisdiction. The PHMSA Enforcement Actions report represents a range of enforcement case types that PHMSA brings against pipeline owners and operators. The types of cases include Corrective Action Orders, …

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PHMSA Issues Final Rule For Gas Gathering Pipelines: Implications for the Control Room

In November 2021, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a new final rule designed to improve the safety of onshore gas gathering pipelines. The long-awaited PHMSA Gas Gathering Rule expanded federal pipeline safety oversight to all U.S. onshore gas gathering pipelines, which adds up to approximately 400,000+ miles of gathering pipelines coming …

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PHMSA Enforcement Actions: Optimize Processes and Recordkeeping to Support Alarm Management

As part of our team’s review of the 2020 PHMSA Enforcement Actions related to the pipeline control room, we identified three pipeline SCADA alarm management violations of the PHMSA Control Room Management Rule (CRM Rule). The violations were found in Section E (Alarm Management) and Section J (Compliance and Deviations) of the CRM Rule. The …

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PHMSA Enforcement Actions Review: It’s Time to Update Your CRMP

PHMSA publicly reports enforcement actions across all areas of pipeline operations, including the pipeline control room. Our team recently dug into the 2020 PHMSA Enforcement Actions related to violations of 49 CFR 192.631 and 49 CFR 195.446 control room management. We found several infractions related to missing, inadequate, or incomplete Control Room Management Plans (CRMPs). …

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PHMSA Increasing Pace of Virtual Inspections — Are You Prepared?

Earlier this year, we noted that PHMSA was planning to inspect each pipeline’s control room within the next three years. Now, during the global pandemic, PHMSA has actually increased their pace of audits through virtual inspections. The increased rate of inspections has created a greater need to ensure audit readiness. While many pipeline operators and …

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Does Your Pipeline Operation Have the Tools to Achieve Natural Compliance?

Pipeline operators have many tools at their disposal to support pipeline safety and compliance. However, we have found that many operators have not implemented the appropriate tools or have gaps in their toolset to achieve what we call natural compliance. Why is natural compliance critical? Natural compliance occurs when pipeline personnel perform their daily tasks …

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Pipeline Rupture Detection: A Path to Meet Minimum Rupture Detection Standards

In 2010, two pipeline incidents occurred, both of which had worsened impacts due to the time required to identify a rupture and isolate the incident. These two incidents led to the eventual introduction of the “Valve & Rupture Rule.” Marshall, Michigan: An operator did not detect a rupture for more than 17 hours, leading to …

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PHMSA Adding Voluntary Cybersecurity Discussion to CRM Inspections

Cybersecurity is increasingly critical in pipeline operations. In February 2020, the Cybersecurity and Infrastructure Security Agency (CISA) issued an industry-specific report about ransomware targeting pipeline operators. The report encouraged pipeline operators to review the techniques of bad actors included in the report and to ensure they have corresponding mitigation efforts in place. The goal of …

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