FAQ-238: “Process” in IM Programs
Question: What documentation must I include in my IM program to describe a "process" required by the rule?
Answer: IM program documentation should include sufficient detail that an employee with appropriate experience and training can follow the procedure/process to achieve the desired objective consistently. The procedure/process should address, as applicable:
- Who is responsible for completing the process/procedure;
- What are the objectives of the process/procedure;
- What data/information is necessary for completing the process/procedure and where it is acquired;
- How and When are the objectives of the process/procedure to be performed (detailed process/procedure steps);
- How are key steps/results of the process/procedure documented (designated format) and where is the documentation stored;
- How are process/procedure results communicated to key personnel;
- What is the method for identifying and incorporating process/procedure improvements (reviews/feedback loops)
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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