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What is Integrity Management?
 
What is Integrity Management and how does it differ from historic pipeline safety regulations?

The federal Office of Pipeline Safety (OPS) has traditionally carried out its oversight responsibility by establishing minimum standards in its regulations and enforcing them uniformly across pipelines. See 49 CFR Parts 190 through 199. However, this uniform regulatory approach does not account for differences in the risks faced by individual pipelines. For example, pipelines located in the Pacific Northwest states are susceptible to damage from geologic hazards, such as landslides, but OPS’s uniform, minimum regulations do not address this risk.

Recognizing that pipeline operators face different risks depending on such factors as location and the products they carry, OPS began exploring the concept of a risk-based approach to pipeline safety in the mid-1990s. In 1996, the Accountable Pipeline Safety and Partnership Act included provisions for DOT to establish a demonstration program to test a risk-based approach. As a result, OPS established the Risk Management Demonstration Program, which went beyond the agency’s traditional regulatory approach by allowing individual companies to identify and focus on the unique risks to their pipelines. Partly based on OPS’s experience with the demonstration program, the agency moved forward with a new regulatory approach—termed Integrity Management—to supplement uniform, minimum regulations. In a May 2000 report, the General Accounting Office (GAO) recognized the potential benefits of a risk-based approach to pipeline safety; however, they expressed concern that OPS did not have performance measures in place to demonstrate the effectiveness of the Risk Management Demonstration Program or the resulting integrity management approach. US General Accounting Office, Pipeline Safety: The Office of Pipeline Safety Is Changing How It Oversees the Pipeline Industry, GAO/RCED-00-128 (Washington, D.C.: May 15, 200).

The integrity management approach requires individual pipeline operators to develop programs to systematically identify and address risks to the segments of their pipelines that could affect “high consequence areas” where a leak or rupture would have the greatest impact, including highly populated or environmentally sensitive areas. For hazardous liquid pipelines, a “high consequence area” is defined as a population area, and area unusually sensitive to environmental damage, or a commercially navigable waterway. See 49 CFR 195.450. For natural gas transmission pipelines, OPS has developed a definition that focuses on populated or frequented areas. See 67 Fed. Reg. 1108, 1114 (Jan. 9, 2002). OPS designed the integrity management approach to achieve greater safety by allowing individual operators flexibility in tailoring their programs to the characteristics of their pipelines. This flexibility is reflected in performance-based requirements, which allow operators to determine the most appropriate processes and technologies to use in their integrity management programs, subject to OPS’s review. For example, operators may use a variety of techniques for assessing pipeline integrity and analyzing these results and other available information about the conditions of their pipelines. In addition, OPS’s integrity management program requirements include prescribed elements that provide some consistency among integrity management programs. For example, OPS requires all hazardous liquid pipeline operators to conduct a baseline assessment of the integrity of all pipeline segments that could affect high consequence areas, periodically reassess the integrity of these pipeline segments, take prompt action to address any anomalies found during the assessments that threaten the integrity of the pipeline, and develop measures of the program’s effectiveness. After September 11, 2001, OPS advised pipeline operators also to consider potential terrorist threats to their pipelines in their assessments of pipeline integrity. See Fed. Reg. 2136, 2137 (Jan. 16, 2002).

 

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