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Avoiding Regulatory Delays Through Preparedness & Traceability
Logistical Challenges with Pipeline Expansion
As recently seen, the number of PHMSA inspections to assess compliance with federal regulation (49 CFR 192, 49 CFR 195 – Subparts C, D & E) have increased, and resulted in higher levels of scrutiny, specifically on interstate pipeline projects.
How does an operator prepare for this level of evaluation, and what if the pipeline’s jurisdiction is under multiple PHMSA regions?
In 2013, a 400+ mile pipeline, spanning 3 PHMSA regions, was able to pass all PHMSA audits by implementing three critical components to verify compliance with the code: Traceability/Compliance Plan, Implementing Proven Pipeline Technology, and Assembling the Right Team.
During early stage planning, develop a Traceability and Compliance plan outlining requirements and responsibilities. Ensure complete support and backing to execute the plan from the operator project manager. Present details of the Traceability and Compliance plan to the entire project team and showcase the technology involved.
Reduce the potential for errors or bugs by deploying proven traceability technology similar to C.A.T.S.®, which has been utilized on over 3,800 miles of pipeline construction in the last 6 years.
Involve D.O.T. Subject Matter Experts throughout project to serve as primary liaisons during meetings and dealings with all regions of PHMSA.
Utilize traceability personnel with multiple years of traceability experience on major pipeline construction projects. Successfully mitigating delays and down-time in all capital pipeline projects demand executing a complete Traceability and Compliance plan with advanced resources, an experienced team, and the cooperation between all members of the project team.
Author: Brett Vogt