By Kevin A. Fritz and Craig B. Simonsen

The Pipeline and Hazardous Materials Safety Administration (PHMSA) recently published an Advisory Bulletin (ADB–2014–05) and a “Guidance for Strengthening Pipeline Safety Through Rigorous Program Evaluation and Meaningful Metrics” (Guidance). Notice of Issuance of Advisory Bulletin, 79 Fed. Reg. 61937 (October 15, 2014).

PHMSA rules require operator self‐evaluation as part of an “effective safety program.” PHMSA rules require the development, implementation, and documentation of processes to perform program evaluations, including the “regular monitoring and reporting of meaningful metrics to assess operator performance.” These rules emphasize that it is the operator’s management’s responsibility to fully understand and acknowledge the implications of these program evaluations, and to take necessary steps to address observed deficiencies and make necessary program improvements.

PHMSA’s pipeline Integrity Management (IM) regulations, 49 CFR Part 195.452, require operators to establish processes to evaluate the effectiveness of their IM programs. Program evaluation is one of the key required program elements established in the IM rules. Additionally, operator senior management is required to certify the IM program performance information submitted annually to PHMSA.

PHMSA issued this Advisory Bulletin to inform owners and operators of natural gas and hazardous liquid pipelines that PHMSA has developed Guidance on the “elements and characteristics of a mature IM program evaluation process using meaningful metrics.” The Guidance should be used when operators develop and perform IM program evaluations.

Previously, PHMSA published Advisory Bulletin ADB–2012–10, “Pipeline Safety: Using Meaningful Metrics in Conducting Integrity Management Program Evaluations,” to remind operators of gas transmission and hazardous liquid pipeline facilities of their responsibilities under regulations to perform evaluations of their IM programs using meaningful performance metrics. 77 Fed. Reg. 72435 (December 5, 2012). The new Advisory Bulletin is intended to expand that reminder by informing owners and operators of gas and hazardous liquid pipelines that PHMSA has developed guidance on the elements and characteristics of a mature program evaluation process — which must use “meaningful metrics.”

Note: the Advisory Bulletin announced that PHMSA inspectors will use the program evaluation Guidance as criteria when evaluating the effectiveness of operator IM program evaluations to assure operators are developing “sound program evaluation processes” and are developing and applying a “robust and meaningful set of performance metrics” in their program evaluations.

To ensure compliance with the updated Advisory Bulletin, businesses, owners, and operators in these industries are encouraged to review carefully their corporate policies, implementation practices, and training on these provisions.