Each year, enforcement actions issued by PHMSA provide a practical view into how control room requirements are evaluated across the industry. While individual cases reflect specific operational circumstances, reviewing enforcement data in aggregate helps clarify where regulatory attention has been focused and how control room programs are assessed in practice.
This blog takes a numbers-driven look at Control Room Management (CRM) enforcement actions opened in 2025. Its purpose is to establish a factual baseline of what the enforcement landscape looked like for control rooms during the year. Interpretation, lessons learned, and deeper analysis will follow in subsequent posts.
Scope and Methodology
To ensure consistency and avoid distorting trends, the analysis applied the following criteria:
- Only enforcement actions with findings explicitly related to Control Room Management under 49 CFR §192.631 and §195.446
- Each cited paragraph or subparagraph was treated as an individual finding
- For example, a single enforcement action citing multiple CRM paragraphs was counted as multiple findings
- Operator names were intentionally excluded to focus on industry-level patterns, not individual companies
- This analysis reflects enforcement actions opened in 2025 and does not include closed cases or final adjudication outcomes.
This paragraph-level approach provides a more precise picture of how often specific CRM requirements were cited in enforcement activity.
CRM Enforcement at a Glance (2025)
Based on the enforcement data reviewed (all data available via PHMSA Enforcement Data Page):
| Metric | 2025 CRM Enforcement |
| Total CRM-related enforcement cases | 15 |
| Total individual CRM findings (paragraph-level) | 94 |
| Average CRM findings per case | 6.3 |
The average reflects the fact that most CRM enforcement actions included multiple cited requirements, reinforcing that CRM findings are often programmatic rather than isolated.
Enforcement Type Distribution (Case-Level)
At the case level, CRM enforcement actions in 2025 were distributed as follows:
| Enforcement Type | Number of Cases | Share of Total |
| Warning Letter (WL) | 6 | 40% |
| Notice of Amendment (NOA) | 5 | 33% |
| Notice of Probable Violation (NOPV) | 4 | 27% |
| Total | 15 | 100% |
What the data shows:
Nearly three-quarters of CRM-related cases resulted in Warning Letters or Notices of Amendment, indicating that PHMSA frequently identified CRM issues as correctable program deficiencies rather than immediately escalating them to probable violations.
Which CRM Requirements Were Cited Most Often?
When the findings are examined at the paragraph level, a clear concentration emerges.
A relatively small subset of CRM requirement areas accounted for a significant share of findings in 2025, particularly those related to:
- CRM program definition and documentation
(primarily §192.631(a) and §195.446(a)) - Operating procedures, including normal operations, abnormal operations, and procedure review and validation
(primarily §192.631(c) and §195.446(c), including subparagraphs addressing abnormal operations and validation) - Training and qualification, including program structure, implementation, and documentation
(primarily §§192.631(e) and §195.446(e), along with related qualification requirements)
Together, citations associated with these areas represented approximately 45% of all CRM findings identified, making them the most frequently cited categories in the 2025 data set. This concentration indicates that findings most often involved requirements related to program definition, procedures, and training.
Findings Commonly Clustered Within the Same Case
Another consistent characteristic of the 2025 CRM enforcement data is that findings often appeared in groups within a single enforcement action, rather than as isolated citations.
For example:
- Procedure-related findings frequently spanned multiple subparagraphs within the same case, such as:
- deficiencies in defining required procedures (e.g., §195.446(c)(1))
- failures to follow established procedures (e.g., §195.446(c)(2))
- and gaps in reviewing or validating procedures for effectiveness (e.g., §195.446(c)(4))
In these cases, PHMSA cited not just whether procedures existed, but whether they were consistently applied and kept current.
- Training-related findings often appeared together within a single enforcement action, including:
- deficiencies in training program structure (e.g., §195.446(e)(1))
- shortcomings in training implementation or refresher training (e.g., §195.446(e)(2)–(e)(3))
- and gaps in training documentation or evaluation (e.g., §195.446(e)(4)–(e)(5))
Rather than pointing to a single missed training event, these clusters involved multiple aspects of training program design, implementation, and documentation. In several cases, procedure and training findings were cited together, reinforcing that multiple related CRM requirements can be affected simultaneously when program-level controls are not well integrated. This clustering shows that many CRM enforcement actions in 2025 included multiple related findings within the same case, rather than isolated citations.
What This Overview Establishes
Based on the data reviewed, several observations can be made about CRM enforcement in 2025:
- CRM enforcement actions frequently included multiple paragraph-level findings
- Enforcement attention was most often associated with program definition, procedures, and training
- Most CRM findings resulted in corrective enforcement actions, rather than immediate escalation
Putting the 2025 CRM Enforcement Data in Context
The 2025 CRM enforcement data shows that findings most often involved program-level elements—how control room programs were defined, supported by procedures, and reinforced through training. Rather than targeting isolated operational errors, enforcement actions frequently cited multiple related requirements within the same case, underscoring that control room management is evaluated as an integrated, system-level program.
Looking Ahead
This overview establishes a factual snapshot of how Control Room Management requirements were enforced in 2025. In the posts that follow, we’ll take a closer look at the patterns behind these findings, examining why certain requirements appear more frequently, how program-level gaps tend to surface during inspections, and what these trends suggest about control room program maturity.
More importantly, we’ll explore how operators can use this type of enforcement data proactively to benchmark their own programs, identify areas of elevated regulatory attention, and prioritize improvements before they become findings. When used in this way, enforcement data can serve as an additional reference point for understanding how CRM requirements are evaluated in practice. It becomes a practical input for strengthening control room programs and improving audit readiness over time.
For operators, understanding how CRM requirements are enforced in practice can provide valuable context for internal assessments, audits, and continuous improvement efforts.