Frequently-Asked Question FAQ #85

FAQ-85: Integrity Management as Part of Broader Corporate Management Systems

Question: Can pipeline integrity management programs required by Subpart O be part of broader corporate safety or integrity management systems (e.g., as described in API Publication 9100A, Model Environmental, Health and Safety (EHS) Management System)?

Answer: Pipeline integrity management programs must meet the requirements of Subpart O. As long as those requirements are met, the programs may be part of broader company management systems. Elements of existing management systems that can meet the requirements of the rule can be incorporated into the pipeline integrity management program. Alternatively, operators may decide that processes and methods used in their pipeline integrity management programs could be useful for other purposes, and may integrate them into broader company systems. OPS expects to see a description of the pipeline integrity management program that meets the requirements of the rule. OPS is willing to consider elements of broader company programs and systems as part of this program description, provided they are sufficiently complete and robust to meet rule requirements. It is the operator’s responsibility to demonstrate how such existing corporate management systems meet the requirements of the rule.