Controlling Risk In Documenting Your Pipeline Integrity
Transforming the way you manage critical pipeline integrity documents allows you to be prepared to show that you are in compliance and enables you to respond rapidly to audits and, if necessary, litigation requests. Having a secure, reliable means of safeguarding documents reduces your overall risk profile.
What Is Changing?
Commodity pipelines in the U.S. extend about 2.5 million miles; 25 percent of them are more than 50 years old. From 2005 to 2009, there was an average of 282 significant incidents involving U.S. pipelines, including an annual average of 51 injuries and 14 fatalities. These incidents and high-profile cases have resulted in increased regulatory oversight supported by new legislation on pipeline integrity, including documentation of Maximum Allowable Operating Pressure (MAOP).
— The Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 was signed into law in January 2012, requiring pipeline operators to confirm, through records or testing, the maximum safe operating pressure of older pipelines in populated areas. It also doubles the maximum fine for safety violations to $2 million and authorizes more pipeline inspectors.
— In addition, stronger measures are being considered at both the federal and the state level. The Los Angeles Times reports that California has taken steps to strengthen pipeline safety rules, including requiring automatic shut-off valves in vulnerable areas.
— To meet the regulatory standards for maintaining documentation on pipeline integrity, you need a way to document, maintain, and retrieve a wide variety of MAOP records: engineering records, damage reports, materials reports, geological survey records, leakage records, resolution reports, and more.
Some of these records may be in electronic format, but many, if not most, will be on paper.
Below is a small example of what must be documented, maintained, and ultimately transformed and loaded into a Geospatial Information System (GIS) or similar system. Multi-layer geologic records and legal landscapes amplify the magnitude of your documentation challenge, and when you factor in that this information is often spread across several mediums, including paper, tape, and digital information, the challenge can quickly become daunting.
Federal regulations also require that documentation be kept for a specified length of time. For example, compliance with Title 49 Part 192 (Transportation of Natural and Other Gas by Pipeline: Minimum Federal Safety Standards) requires that documentation of each test performed to meet minimum federal safety standards (e.g., §§192.505 and 192.507) must be maintained for at least five years, continuously increasing storage requirements.
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What Does This Mean for Your Business?
You need to be prepared to show your compliance with these regulations—before an incident, audit, or litigation request arises. The volume and variety of current pipeline records, as well as archived records, sitting in distributed locations increases your level of risk of incurring penalties and fines as well as the risk of permanent loss.
Here’s a real-world example. After a pipe burst, one company’s records were found to have incorrectly described the pipe as seamless. A Public Utilities Commission (PUC) ordered the utility to turn over numerous records justifying the pressure levels throughout its gas system. Because the company was unable to meet the initial deadline for turning over those records, the PUC has threatened to fine it up to $6 million. Since then, the company hasn’t been able to find many of the requested records, which the PUC is looking into as a possible violation of the law.
To enable you to avoid gaps in record-keeping and meet the time frames specified for audits or litigation requests, you need to organize your records into a comprehensive, readily accessible library. This requires identification, collection, and indexing of these distributed paper documents. You will never be able to get a complete handle on these records and control your risks without some amount of digital conversion.
You may have already invested in a Pipeline Integrity Management System (PIMS) or GIS to help you meet regulatory mandates. But how do you get the appropriate paper records into those systems so you can be prepared for an audit or litigation request?
Compliance with Title 49 Part 192 requires that documentation of each test performed to meet minimum federal safety standards must be maintained for at least five years.
Transforming Pipeline Integrity Document Management to Control Risk
Document management solutions help you organize and convert hardcopy records, whatever their size or format. Indexing, coding, and classification of converted documents facilitate rapid search and retrieval for routine maintenance, audit requests, discovery processes, and producing evidentiary data for pending litigation.
However, document management and imaging technology alone are not enough. They must be employed within the greater context of a comprehensive and legally defensible record-keeping program while meeting the needs of your daily business. This should include defined and consistently applied records management policies, especially well-defined retention schedules, and effective management of legal holds.
As such, it’s important that your organization draw upon best practices to define a program that meets your specific needs in the commodity pipeline operating businesses.
For More Information
Learn more about Iron Mountain’s standardized, centralized document management and storage capabilities that make it easy to find what you need, when you need it and give you more time and resources to commit to your strategic initiatives — as well as improving your ability to prove chain-of-custody to auditors, litigators, and regulatory bodies. Call us at 1-800-899-IRON (4766).
Document management solutions help you organize and convert hardcopy records, whatever their size or format.