Pipeline Safety Insights: PHMSA warning letter could cost big $'s
In June 2024, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a warning letter to Dakota Gasification Company (DGC), highlighting critical pipeline safety compliance issues. Here are the key points: ## Key Compliance Issues **Public Awareness Program Evaluation (49 CFR § 195.440)** DGC failed to evaluate the effectiveness of their public awareness program by not comparing survey responses over time to identify trends or behavior changes. **Preventive and Mitigative Measures (PMMs) (49 CFR § 195.452(i)(1))** The company did not implement identified PMMs, specifically alternating current mitigation in a high consequence area. **Documentation of Decision-Making (49 CFR § 195.452(l)(1)(ii))** Insufficient documentation was provided to justify decisions regarding PMMs for multiple high consequence areas. ## Tips to Prevent Future Issues Nathan suggests the following tips to enhance pipeline safety compliance: - Implement robust tracking systems and track survey responses over multiple years to identify trends. Consider using machine learning and AI solutions. - Establish clear timelines, hold all involved accountable, and ensure timely implementation of identified PMMs. - Capture the rationale behind all integrity management decisions by developing a comprehensive documentation process. Remember the old saying... if you didn't document it, it didn't happen. - Conduct regular internal and third part internal audits to ensure compliance with regulations and identify gaps before official inspections. - Invest in site specific / task specific training programs and keep staff updated on evolving regulatory requirements and best practices. ##Potential Fines While no penalties were assessed in this case, non-compliance can lead to significant financial risks. PHMSA can impose civil penalties up to $266,015 per violation per day, with a maximum of $2,660,135 for a related series of violations. For LNG facilities, an additional penalty of up to $97,179 per violation may apply. Maintaining rigorous compliance programs is crucial to enhancing pipeline safety and minimizing regulatory risks. [Schedule a time with Nathan](https://calendar.app.google/bFiTt3WURVohbCEC9) to discuss potential pipeline safety compliance items and ensure your organization stays ahead of compliance challenges. Let’s work together to enhance safety and minimize risks.