PHMSA Compliance

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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PHMSA Gas Gathering Rule: The Importance of TVC Records

In October 2019, PHMSA published Part 1 of the Gas Gathering Rule focused on pipeline safety: “Safety of Gas Transmission Pipelines: MAOP Reconfirmation, Expansion of Assessment Requirements, and Other Related Amendments.” Included in the Gas Transmission Final Rule was the introduction of new terminology to help pipeline operators validate the safety of pipeline assets that …

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Learn From PHMSA Enforcement Actions: Addressing Control Room Challenges

Earlier this year, we relayed an update that PHMSA Enforcement Actions increased significantly in 2019 compared to 2018. Our team dug into the 223 reported enforcement cases and found 14 control room-specific cases. These “inadequacies” were related to several categories of the PHMSA Control Room Management Rule (CRM Rule). In some cases, there were multiple …

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PHMSA Announces Gas Pipeline Regulatory Reform to Reduce Regulatory Burdens

On May 28, the Pipeline and Hazardous Materials Safety Administration (PHMSA) announced a proposed role for gas pipeline regulatory reform. PHMSA issued the Notice of Proposed Rulemaking (NPRM) aimed at reducing unnecessary regulatory burdens to align with recent executive orders (13771, 13777, and 13783) issued by the federal government. After conducting a review of existing …

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PHMSA Introduces Regulatory Reform for Hazardous Liquid Pipelines

On April 16, 2020, the Pipeline and Hazardous Materials Safety Administration (PHMSA) published to the federal registry a Notice of Proposed Rulemaking (NPRM) concerning liquid pipelines. The goal of the proposed rulemaking, “Pipeline Safety: Regulatory Reform for Hazardous Liquid Pipelines,” is to amend the Federal Pipeline Safety Regulations at 49 CFR parts 190, 194, and …

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PHMSA Issues COVID-19 Notice and Guidance for Pipeline Operators

In response to the COVID-19 health crisis and national emergency in our country, PHMSA issued two important guidance statements for pipeline operators. The guidance statements were issued to address continued efforts to support pipeline safety at the federal and state levels: PHMSA issued a Notice of Stay of Enforcement and Notice of Enforcement Discretion for …

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