FAQ-96: Consistency of OPS Inspection
Question: How will OPS ensure consistency in applicatiion of integrity management requirements?
Answer: The integrity management rule contains a number of management-based and performance-based requirements. Inspection for compliance with these requirements is fundamentally different than for prescriptive requirements. OPS recognizes that inspecting against these requirements will require subjective judgments on the part of inspectors, and that it is important to assure consistency in this process. Consistency is being achieved through several means.
- the inspections will be conducted using written protocols. A core team of experienced state and federal inspectors is involved in developing inspection protocols and guidance.
- integrity management inspections are performed by experienced inspectors.
- all inspectors conducting integrity management inspections, including state inspectors, will receive training specific to the rule.
- the core team intends to meet periodically during the early stages of implementing this rule to review inspection experience to be sure the appropriate level of consistency is being achieved.
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.