The Pipeline and Hazardous Materials Safety Administration (PHMSA) regulates pipeline safety under 49 CFR Parts 192 (gas pipelines) and 195 (hazardous liquid pipelines). These comprehensive regulations cover design, construction, operation, maintenance, integrity management, and emergency response for pipeline systems. Operators must maintain written programs for integrity management, operator qualification, damage prevention, public awareness, emergency response, and other elements. PHMSA conducts regular compliance inspections and operators are subject to civil penalties for violations. A thorough program audit evaluates whether all required written plans are in place, procedures are being followed, records are maintained, and personnel are properly qualified. This checklist addresses the major program elements common to both gas and hazardous liquid pipeline operators.
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Download Checklist (.docx)Regulatory Requirements
49 CFR Part 192 — Transportation of Natural and Other Gas by Pipeline
Part 192 prescribes minimum safety requirements for gas pipeline facilities including design, fabrication, installation, inspection, testing, operation, maintenance, and integrity management. Key program areas include integrity management programs for transmission lines (Subpart O), distribution integrity management (Subpart P), operator qualification (Subpart N), and emergency plans (§192.615).
49 CFR Part 195 — Transportation of Hazardous Liquids by Pipeline
Part 195 prescribes safety standards for hazardous liquid pipeline facilities including design, construction, testing, operation, maintenance, and integrity management. Key requirements parallel Part 192 with pipeline-specific provisions for integrity management programs (§195.452), operator qualification (§195.505), and emergency response (§195.402).
Pipeline Safety Improvement Act and PIPES Act
Federal pipeline safety law requires operators to implement integrity management programs, operator qualification programs, public awareness programs, and damage prevention measures. PHMSA enforces compliance through inspections and can assess civil penalties up to $257,664 per violation per day, with a maximum of $2,576,627 for a related series of violations.
Written Plans and Program Documentation
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Operations and maintenance plan | Written O&M procedures manual covers all pipeline operations including normal operations, abnormal operations, maintenance activities, and emergency procedures. Manual is current, reviewed periodically, and accessible to all operations personnel. Changes to procedures follow a documented management of change process. |
| Integrity management program | Written IMP exists for transmission pipelines in high consequence areas (HCAs) per Subpart O/§195.452. Program includes threat identification, risk assessment, baseline assessment plan, reassessment intervals (not exceeding 7 years for gas, 5 years for liquid), and repair criteria. Program is reviewed and updated when conditions change. |
| Distribution integrity management | If operating a gas distribution system, a written DIMP per Subpart P exists covering threat identification, risk ranking, performance measures, and continuous improvement. Annual performance reporting to PHMSA is completed. |
| Emergency response plan | Written emergency plan per §192.615 or §195.402 includes procedures for: gas/liquid leak response, fire/explosion, natural disaster, and notification of emergency responders. Plan includes contact information for local fire, police, hospitals, and the National Response Center. Plan is reviewed and updated annually. |
Operator Qualification
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| OQ program documentation | Written operator qualification program per Subpart N (§192.801-809) or §195.505 identifies all covered tasks on the pipeline system. Each covered task has defined knowledge, skills, and abilities (KSAs). Qualification methods (written exam, performance evaluation, observation) are documented for each task. |
| Personnel qualification status | All individuals performing covered tasks are qualified per the OQ program before performing those tasks unsupervised. Qualification records are current and include date qualified, method of evaluation, and evaluator identity. Requalification intervals are defined and tracked. |
| Abnormal operating conditions | OQ program includes training and evaluation for recognizing and responding to abnormal operating conditions (AOCs). AOC training covers all conditions identified in the operator’s procedures. Individuals who contribute to an incident may require requalification. |
| OQ program auditing | OQ program is periodically reviewed and updated. Contractor and subcontractor OQ compliance is verified. Records demonstrate that unqualified individuals do not perform covered tasks except under the direct observation of a qualified individual. |
Damage Prevention and Public Awareness
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Damage prevention program | Written damage prevention program includes participation in state one-call systems, pipeline marking/patrolling, excavation monitoring procedures, and public education. Operator responds to locate requests within required timeframes. Near-miss and damage events are tracked and analyzed. |
| Pipeline markers and signage | Pipeline markers are placed at required intervals per §192.707 or §195.410. Markers indicate operator name, emergency telephone number, and product transported. Markers are maintained in good condition and replaced when missing or damaged. |
| Public awareness program | Written public awareness program per §192.616 or §195.440 addresses all four required audiences: affected public, emergency officials, local government, and excavators. Communications are delivered at required intervals (annually for excavators, at least every two years for others). Program effectiveness is evaluated periodically. |
| Line patrol and surveillance | Pipeline right-of-way is patrolled at required intervals to detect leaks, construction activity, environmental changes, and encroachments. Patrol methods and frequencies are documented. Abnormal conditions found during patrol are investigated and resolved. |
Inspection, Testing, and Maintenance
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Pipeline inspection records | Records of all inspections, tests, and maintenance activities are maintained per regulatory requirements. Records include date, type of inspection, findings, and corrective actions. Leak survey records are maintained for gas distribution and transmission systems. |
| Valve maintenance | Valves are inspected and operated at required intervals to ensure they function properly. Emergency shut-off valves are tested per established schedule. Valve maintenance records are current. |
| Corrosion control program | Cathodic protection system is monitored and maintained per §192.463-492 or §195.565-589. Annual cathodic protection surveys are conducted. Atmospheric corrosion inspections are performed at required intervals. Corrosion deficiencies are repaired within regulatory timeframes. |
| Pressure testing and records | Pipeline pressure tests are documented with test medium, test pressure, duration, and results. Maximum allowable operating pressure (MAOP) is established and documented for each pipeline segment. Any pressure exceedances are investigated and documented. |
Reporting, Recordkeeping, and Drug/Alcohol Testing
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Incident reporting | Incidents meeting PHMSA reporting thresholds are reported via the National Response Center and followed up with written reports within 30 days using the appropriate form (PHMSA F 7100.1 for gas, F 7000-1 for liquid). Reporting thresholds and procedures are understood by all operations personnel. |
| Annual report submission | Annual reports are submitted to PHMSA by the required deadline (March 15 for gas, June 15 for liquid). Reports include total mileage, leak and repair data, and program information. Reports are submitted through PHMSA’s online portal. |
| Drug and alcohol testing | Drug and alcohol testing program per 49 CFR Part 199 is implemented for all covered employees performing safety-sensitive functions. Pre-employment, random, post-accident, reasonable suspicion, return-to-duty, and follow-up testing are conducted per regulations. Testing records and MIS reports are maintained. |
| Record retention compliance | Records are maintained for the periods required by regulation: life of the pipeline for design/construction/testing records, five years for operating and maintenance records, period of employment plus five years for OQ records. Records management system ensures accessibility and protection from loss. |
Corrective Actions
Common Issues and Responses
- Missing or outdated written plans: Develop or update the required written plans immediately (O&M, IMP, DIMP, Emergency, Public Awareness, OQ). Engage qualified pipeline safety consultants if internal expertise is insufficient. Prioritize plans based on PHMSA enforcement focus.
- Unqualified personnel performing covered tasks: Remove unqualified individuals from covered tasks immediately or assign a qualified observer. Accelerate qualification evaluations. Implement a tracking system to prevent gaps in qualification coverage.
- Overdue integrity assessments: Schedule the overdue assessment immediately using an appropriate method (ILI, direct assessment, pressure test, or other technology). Document the assessment plan and timeline. Notify PHMSA if required by enforcement order.
- Inadequate corrosion control: Conduct cathodic protection survey to identify deficiencies. Repair or replace rectifiers and anodes as needed. Prioritize areas with history of corrosion-related leaks or failures.
- Late or missing PHMSA reports: Submit overdue reports immediately through PHMSA’s online portal. Implement calendar reminders for annual report deadlines. Assign report preparation responsibilities with backup coverage.
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Training Management
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Incident Management
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Corrective Actions
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