Operator compliance with pipeline safety regulations that establish minimal federal safety standards is critical to preventing pipeline accidents. Ensuring compliance involves regular inspections of pipeline operator programs and facilities and, when compliance violations are identified, the application of appropriate administrative, civil, or criminal remedies.
Federal and state pipeline inspectors conduct these compliance inspections and also conduct accident investigations and respond to public complaints concerning pipeline operations.
Federal Inspections: More than 100 full-time pipeline inspectors operate out of PHMSA’s Office of Pipeline Safety (OPS) regional offices in Trenton, NJ; Atlanta, GA; Kansas City, MO; Houston, TX; and Denver, CO. These inspectors implement a comprehensive inspection and enforcement program to verify that pipeline operators comply with pipeline safety regulations. OPS is responsible for oversight of interstate pipelines that cross state boundaries and intrastate pipeline systems in states where there is no certified state partner.
State Inspections: While the federal government is primarily responsible for developing, issuing, and enforcing pipeline safety regulations, the pipeline safety statutes provide for states to assume intrastate regulatory, inspection, and enforcement responsibilities under an annual certification. The majority of pipeline inspections in the nation are carried out by state inspectors who work for state agencies. If a state has a certified pipeline safety program, a state agency is responsible for conducting inspections of intrastate pipelines that lie entirely within a state's borders.
For more information on federal/state authorities.
Pipeline safety regulations were originally established in the early 1970s and were based primarily on industry consensus standards in effect at the time. The regulations have been updated throughout the years with the addition of several significant new regulatory programs. As these took effect, OPS implemented an inspection program for each specific new regulatory program. In 2008, OPS began pilot testing an integrated inspection process. By using data and information about a specific operator and pipeline system, an inspector can custom-build a list of regulatory requirements to be evaluated during an inspection. This data-driven process allows OPS to focus inspection resources on the regulatory provisions addressing the greatest identified risks. OPS maintains the ability to conduct the program-based inspections listed below, and has been conducting an increasing number of integrated inspections since 2008. State partners may choose to conduct integrated inspections or continue with the program-based inspections.
Standard inspections are conducted to review operator compliance with the pipeline safety regulations originally put in place in the early 1970s. Both gas and hazardous liquid pipeline safety regulations include minimum requirements for an operator to safely operate and maintain its pipeline systems. Inspectors review the operator’s documented processes, procedures and records, they observe operator employees performing work in accordance with the operators processes and procedures, and check operating records to ensure the operator’s pipeline systems are operated at or below the maximum parameters allowed by regulations. They also examine the operator’s emergency procedures to determine if the operator is prepared to respond promptly and effectively if an abnormal condition or pipeline failure occurs.
Operator Qualification (OQ) Inspections
In 2001, pipeline safety regulations were revised to require pipeline operators to document the training and qualifications of their employees. Operators are required to prepare a written operator qualification program that identifies employee positions that perform safety-sensitive operation or maintenance tasks. Employees in these positions must be trained and tested to ensure they have the necessary knowledge, skills and abilities to perform each task, as well as to recognize and react to emergencies that may arise while performing those tasks.
OPS and state inspections verify that operators have created acceptable OQ programs and identified all safety-sensitive employee positions. Inspectors also review records to verify that employees in these positions have been trained and tested. Operator employees performing operations and maintenance tasks are observed to ensure the tasks are completed in accordance with the operator’s program.
Integrity Management (IM) Inspections
In the context of pipeline operations, the term "integrity" means that a pipeline system is of sound and unimpaired condition and can safely carry out its function under the conditions and parameters for which it was designed. "Integrity management" encompasses the many activities pipeline operators must undertake to ensure the integrity of their pipeline systems. Integrity management regulations were promulgated and tailored for the different pipeline system types at different times – for hazardous liquid pipelines in 2001, for gas transmission pipelines in 2004, and for gas distribution pipeline systems in 2009. The IM regulations are tailored to each of these system types. Inspections of IM programs generally verify that an operator uses all available information about its pipeline system to assess risks and take appropriate action to mitigate those risks. Inspections include reviewing the written IM program and associated records.
A separate briefing on integrity management is available. For more detailed information, please select one of the links below: