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
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