MEC&F Expert Engineers : Pipeline Safety: Guidance for Strengthening Pipeline Safety Through Rigorous Program Evaluation and Meaningful Metrics

Wednesday, December 31, 2014

Pipeline Safety: Guidance for Strengthening Pipeline Safety Through Rigorous Program Evaluation and Meaningful Metrics





Pipeline Safety: Guidance for Strengthening Pipeline Safety Through Rigorous Program Evaluation and Meaningful Metrics


Oct 15, 2014
Docket Number PHMSA-2014-0086
Notice: Issuance of Advisory Bulletin
Summary: PHMSA published Advisory Bulletin ADB-2012-10 in the Federal Register on December 5, 2012, to remind operators of gas transmission and hazardous liquid pipeline facilities of their responsibilities under current regulations to perform evaluations of their Integrity Management (IM) programs using meaningful performance metrics. PHMSA is issuing this Advisory Bulletin 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 that uses meaningful metrics.


Billing Code: 4910-60-W
DEPARTMENT OF TRANSPORTATION
Pipeline and Hazardous Materials Safety Administration
[Docket No. PHMSA–2014–0086]
Pipeline Safety: Guidance for Strengthening Pipeline Safety Through Rigorous Program Evaluation and Meaningful Metrics
AGENCY: Pipeline and Hazardous Materials Safety Administration (PHMSA); DOT.
ACTION: Notice; Issuance of Advisory Bulletin.
SUMMARY: PHMSA published Advisory Bulletin ADB-2012-10 in the Federal Register on
December 5, 2012, to remind operators of gas transmission and hazardous liquid pipeline
facilities of their responsibilities under current regulations to perform evaluations of their
Integrity Management (IM) programs using meaningful performance metrics. PHMSA is issuing
this Advisory Bulletin 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 that uses meaningful metrics.
FOR FURTHER INFORMATION CONTACT: Chris McLaren by phone at 281-216-4455
or by email at chris.mclaren@dot.gov. All materials in this docket may be accessed electronically at http://www.regulations.gov. Information about PHMSA may be found at
http://www.phmsa.dot.gov.
SUPPLEMENTARY INFORMATION:
I. Background
PHMSA has long recognized and communicated the critical importance of operator selfevaluation
as part of an effective safety program. PHMSA has promoted and required the
development and implementation of processes to perform program evaluations, including the
regular monitoring and reporting of meaningful metrics to assess operator performance.
PHMSA further communicated this expectation in Advisory Bulletin ADB-2012-10, which was
published in the Federal Register on December 5, 2012. That Advisory Bulletin explicitly
reminded operators of gas transmission and hazardous liquid pipeline facilities of their
responsibilities under current regulations to perform evaluations of their IM programs using
meaningful performance metrics.
PHMSA has also recognized and emphasized the importance of operator senior management
responsibilities to fully understand and acknowledge the implications of these program
evaluations and to take the necessary steps to address deficiencies and make necessary program
improvements. As these responsibilities are so important, PHMSA requires senior executives of
operators to certify the IM program performance information they annually submit to PHMSA.

As required by the IM rules, operators must have a process to measure the effectiveness of their
programs; a process that determines whether the program is effective in assessing and evaluating
pipeline integrity and in improving the integrity of pipeline systems. Program evaluations can
help organizations make better management decisions and support continual process
improvement. These evaluations should include an assessment gauging how an operator’s
performance satisfies its identified safety performance goals.
Program and other evaluations may be conducted at different levels, including the company or
corporate level, at a system level to gauge one pipeline system's performance against that of
other systems within the organization or for selected assets with similar characteristics. Effective
program evaluations should include all aspects of an operator’s organization, not just the
integrity group.
Incident/accident investigations and abnormal operations and root cause analysis frequently
reveal that management systems and organizational program deficiencies or failures are
important contributors to pipeline accidents. For this reason, it is important that program
evaluations also identify potential organizational or programmatic deficiencies and failures that
could have the potential to lead to pipeline incidents/accidents.
Operators should take effective corrective measures addressing IM program evaluation outcomes
to improve programmatic activity as well as pipeline system performance and integrity. IM
program evaluation processes should be formally controlled by operators and be an integral part of the operator's quality control and quality assurance program. The formal process should
include management's commitment to monitor and evaluate performance metrics.
Specific sections in the Federal IM regulations that directly require the need for operator
program evaluation and the use of meaningful performance metrics include the following:
• For hazardous liquid pipelines, §§ 195.452(f)(7) and 195.452(k) require methods to
measure program effectiveness. Appendix C to 49 CFR 195 provides specific guidance
on establishing performance measures, including the need to select measures based on the
understanding and analysis of integrity threats to each pipeline segment. API Standard
1160, “Managing Integrity for Hazardous Liquid Pipelines,” also provides additional
guidance on the program evaluation process and the use of performance measures in
improving performance.
• For gas transmission pipelines, §§ 192.911(i) and 192.945 define the requirements for
establishing performance metrics and evaluating IM program performance. The gas
requirements invoke ASME B31.8S-2004, Managing System Integrity of Gas Pipelines.
Section 9 of this standard provides guidance on the selection of performance measures.
• For gas distribution systems, § 192.1007(e) requires development and monitoring of
performance measures to evaluate the effectiveness of IM programs. An operator must
consider the results of its performance monitoring in periodically reevaluating threats and
risks. Guidance from ANSI/GPTC Z380, “Guide for Gas Transmission and Distribution Piping Systems, 2012 Edition” and Section 9 of ASME B31.8S-2004, “Managing System
Integrity of Gas Pipelines” can also be used for the selection of performance measures
that can be applied to gas distribution systems.
When performing routine pipeline system inspections, PHMSA noted weaknesses in the
development and implementation of program evaluations, including weaknesses in using
meaningful metrics to identify opportunities for program improvements and corrective actions.
Additionally, NTSB Recommendation P-11-19, which was generated following the San Bruno,
CA, failure investigation, recommended PHMSA develop and implement standards for IM and
other performance-based safety programs that require operators of all types of pipeline systems
to assess the effectiveness of their programs using clear and meaningful metrics and identify and
then correct deficiencies.
In response to PHMSA’s self-identified concerns and the NTSB recommendation, PHMSA
developed a guidance document titled “Guidance for Strengthening Pipeline Safety Through
Rigorous Program Evaluation and Meaningful Metrics,” which is available at
http://phmsa.dot.gov/staticfiles/PHMSA/DownloadableFiles/Pipeline/Regulations/IMPEG.pdf.
Major topic areas addressed in the guidance document include:
Establishing Safety Performance Goals.
Identifying Required Metrics.
Selecting Additional Meaningful Metrics.

Metric Monitoring and Data Collection.
Program Evaluation Using Metrics.
The guidance document includes tables listing regulation-required metrics and other
programmatic and threat-specific metrics that operators could include in their documented IM
program evaluations.
Table 1 lists the IM-related metrics documented in pipeline operators' annual reports.
Table 2 lists the threat-specific metrics required by § 192.945 for gas transmission and
required by § 192.1007(g) for gas distribution systems.
Table 3 provides guidance for operators and inspectors to identify meaningful metrics to
help understand and measure the effectiveness of the individual program elements and
processes used in an IM program.
Table 4 provides guidance for operators and inspectors to identify meaningful threatspecific
metrics that may be required to effectively measure the performance of gas
transmission, hazardous liquid transmission and gas distribution pipeline IM programs.

II. Advisory Bulletin (ADB-2014-05)
To: Owners and Operators of Natural Gas and Hazardous Liquid Pipelines
Subject: Guidance for Strengthening Pipeline Safety Through Rigorous Program Evaluation and
Meaningful Metrics
Advisory: The Pipeline and Hazardous Materials Safety Administration (PHMSA) is issuing 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. This guidance document titled “Guidance
for Strengthening Pipeline Safety Through Rigorous Program Evaluation and Meaningful
Metrics,” is available on PHMSA’s public website at
http://phmsa.dot.gov/staticfiles/PHMSA/DownloadableFiles/Pipeline/Regulations/IMPEG.pdf,
and should be used when operators develop and perform IM program evaluations. This guidance
document provides additional specificity to several of the topics detailed in a previously issued
Advisory Bulletin, ADB-2012-10, “Using Meaningful Metrics in Conducting Integrity
Management Program Evaluations.”
Operators under the current regulations are required to perform program evaluations and use
meaningful metrics. PHMSA’s “Guidance for Strengthening Pipeline Safety Through Rigorous
Program Evaluation and Meaningful Metrics” builds on existing standards and regulations to
provide a more detailed and comprehensive description of the steps involved in program evaluations as well as the selection of meaningful performance metrics to support these
evaluations. The guidance expands and clarifies PHMSA’s expectations for operator processes
when measuring IM program effectiveness.
PHMSA inspectors will use the program evaluation guidance within “Guidance for
Strengthening Pipeline Safety Through Rigorous Program Evaluation and Meaningful Metrics”
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.
Authority: 49 U.S.C. Chapter 601 and 49 CFR 1.97.
Issued in Washington, DC, on October 09, 2014.
Jeffrey D. Wiese,
Associate Administrator for Pipeline Safety.