PHMSA Gas Integrity Management
Time: 11/23/2009 11:01 PM

Frequently-Asked Question FAQ #202

FAQ-202: Protecting intellectual property in ECDA descriptions

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Question: DA vendors offer processes that include proprietary analysis techniques (similar to how ILI vendors use algorithms to classify anomalies). If my IMP written plan has to document my process for CIS/DCVG/etc. acceptance limits, how can I use vendors that wouldn’t give away their intellectual property?

Answer: Operators are responsible for assuring accurate results. OPS expects that operators will have enough understanding to assure that the process accurately identifies pipeline anomalies and sufficiently assures pipeline integrity. Operators will need to obtain enough information from their vendors to assure that they understand the capabilities and limitations of the vendor’s techniques including the tolerances of tools to be used.

These Frequently Asked Questions (FAQs) are intended to clarify, explain, and promote better understanding of the pipeline integrity management rules. These FAQs are not substantive rules and do not create rights, assign duties, or impose new obligations not outlined in the existing integrity management regulations and standards. Requests for informal interpretations regarding the applicability of one or more of the pipeline integrity management rules to a specific situation may be submitted to PHMSA in accordance with 49 C.F.R. § 190.11.
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