Frequently-Asked Question FAQ #74

FAQ-74: Framework Compared with Fully-Developed Program

Question: What is the difference between an acceptable Integrity Management Framework and a fully developed Integrity Management Program?

Answer: The integrity management rule requires operators to develop and implement an Integrity Management Program. The Integrity Management Program Framework lays the foundation for how the operator intends to develop and implement its program. As described in 192.911, the elements of an integrity management program must include several management, analytical, and operational processes. OPS expects that a number of operators may not have fully developed these aspects of their integrity management programs at this time. OPS also recognizes that making significant, fundamental changes in operator management, analytical, and operational processes and implementing new analytical tools takes time. As such, OPS does not expect operators to have fully mature integrity management programs by the initial deadline (December 17, 2004).

As described in 192.907, OPS expects the integrity management framework to describe how an operator currently addresses each element of an integrity management program, and their plans for how they intend to improve these processes to reach a fully-developed integrity management program. (OPS expects that an operator will have an established process or procedure for any activities that are being implemented). Hence, the framework is a roadmap for developing a full integrity management program, and should include timeframes for completing intended improvements. A fully developed integrity management program would include complete, well-documented, and effectively implemented processes for all integrity management program elements defined in 192.911. During OPS inspections, each operator's performance in implementing its framework will be examined.