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Safety Recommendation Details

Safety Recommendation P-15-016
Details
Synopsis: There are approximately 298,000 miles of onshore natural gas transmission pipelines in the United States. Since 2004, the operators of these pipelines have been required by the Pipeline and Hazardous Materials Safety Administration (PHMSA) to develop and implement integrity management (IM) programs to ensure the integrity of their pipelines in populated areas (defined as high consequence areas [HCAs]) to reduce the risk of injuries and property damage from pipeline failures. An operator’s IM program is a management system designed and implemented by pipeline operators to ensure their pipeline system is safe and reliable. An IM program consists of multiple components, including procedures and processes for identifying HCAs, determining likely threats to the pipeline within the HCA, evaluating the physical integrity of the pipe within the HCA, and repairing or remediating any pipeline defects found. These procedures and processes are complex and interconnected. Effective implementation of an IM program relies on continual evaluation and data integration. The IM program is an ongoing program that is periodically inspected by PHMSA and/or state regulatory agencies to ensure compliance with regulatory requirements.
Recommendation: TO THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION: Revise Form F7100.2, Incident Report Form, (1)to collect information about both the results of previous assessments and previously identified threats for each pipeline segment involved in an incident and (2) to allow for the inclusion of multiple root causes when multiple threats interacted.
Original recommendation transmittal letter: PDF
Overall Status: Closed - Acceptable Action
Mode: Pipeline
Location: United States
Is Reiterated: No
Is Hazmat: No
Is NPRM: No
Accident #: DCA14SS002
Accident Reports:
Report #: SS-15-01
Accident Date: 11/20/2013
Issue Date: 2/10/2015
Date Closed: 7/24/2019
Addressee(s) and Addressee Status: PHMSA (Closed - Acceptable Action)
Keyword(s):

Safety Recommendation History
From: NTSB
To: PHMSA
Date: 7/24/2019
Response: You previously told us that, on May 13, 2016, you published a Federal Register notice proposing changes to Form F7100.2 to collect two cycles of integrity inspection data for an incident location instead of just the most recent cycle, with the type of inspection directly correlating with the threats being evaluated. Regarding the second part of the recommendation (multiple root causes), you planned to continue to retain the ability to document and report an incident with a single predominant cause, but you proposed a new section on the form that would allow an operator to select multiple contributing factors when several threats or causes interact. We note that, on April 17, 2017, after evaluating comments that you received regarding your May 13, 2016, notice, you submitted the proposed changes to the Office of Management and Budget, which approved the revisions on April 30, 2019. You have now revised Form F7100.2 to collect two cycles of integrity inspection data for an incident location, and you have included a new part to allow the operator to select multiple contributing factors when multiple threats or causes interacted. These actions satisfy Safety Recommendation P-15-16, which is classified CLOSED--ACCEPTABLE ACTION.

From: PHMSA
To: NTSB
Date: 6/14/2019
Response: -From Howard R. Elliott, Administrator: PHMSA requests closure of this recommendation. PHMSA has revised Form F7100.2, Incident Report Form, to collect two cycles of integrity inspection data for incident location, as well as to include a new part to allow the operator to select multiple contributing factors when multiple threats/causes interacted. On May 13, 2016, PHMSA published a 60-day notice in the Federal Register (FR) to invite comments on an information collection to revise Form F7100.2, Incident Report-Natural and Other Gas Transmission and Gathering Pipeline Systems (https://www.regulations.gov/document?D=PHMSA-2015-0205-0009). On December 27, 2016, PHMSA published an additional notice in the FR (https://www.federalregister.gov/documents/2016/12/27/2016-31221/pipeline-safetyinformation-collection-activities) to respond to comments received from the May 13, 2016, notice, provide 30 days for comment, and announce that the information collection will be submitted to the Office of Management and Budget for approval. PHMSA sent the information collection to the Office of Management and Budget on April 17, 2017, and it was approved for a three-year term on April 30, 2019.

From: PHMSA
To: NTSB
Date: 4/1/2019
Response: -From Howard R. Elliott, Administrator: PHMSA is working to revise Form F7100.2. As part of this process, PHMSA received departmental approval for the Information Collection Notice in 2017 and is currently awaiting Office of Management and Budget (OMB) approval.

From: NTSB
To: PHMSA
Date: 2/21/2018
Response: You previously told us that, on May 13, 2016, you published a Federal Register notice proposing changes to Form F7100.2 to collect two cycles of integrity inspection data for an incident location instead of just the most recent cycle, with the type of inspection directly correlating with the threats being evaluated. Regarding the second part of the recommendation (multiple root causes), you planned to continue to retain the ability to document and report an incident with a single predominant cause, but you proposed a new section on the form that would allow an operator to select multiple contributing factors when several threats or causes interact. We note that you evaluated comments to the Federal Register notice and that you are currently awaiting approval from the Office of Management and Budget (OMB). Pending OMB approval, and implementation of the proposed changes, Safety Recommendation P-15-16 remains classified OPEN--ACCEPTABLE RESPONSE.

From: PHMSA
To: NTSB
Date: 11/13/2017
Response: -From Howard R. Elliott, Administrator: PHMSA continues to work to revise Form F7100.2. On May 13, 2016, PHMSA published a federal register notice in docket PHMSA-2015-0205 proposing changes to Form F7100.2 (81FR29943, https://www.federalregister.gov/documents/2016/05/13/2016-11304/pipeline-safetyinformation-collection-activities). We are proposing to collect two cycles of integrity inspection data for the incident location instead of just the most recent cycle. The type of inspections conducted directly correlates to the threats evaluated by the inspection. Regarding multiple root causes, PHMSA does not intend to alter Part G of the form, entitled, "Apparent Cause," to retain the ability to document and report an incident with a single predominant cause. A new part is proposed for the report allowing the operator to select multiple contributing factors when multiple threats/causes interacted. PHMSA has evaluated comments to the notice and is awaiting OMB approval.

From: NTSB
To: PHMSA
Date: 12/5/2016
Response: We note that, on May 13, 2016, you published a Federal Register notice in docket PHMSA-2015-0205 proposing changes to Form F7100.2 to collect two cycles of integrity inspection data for an incident location instead of just the most recent cycle. The type of the inspection conducted directly correlates to the threats evaluated by the inspection. Regarding multiple root causes, you do not intend to alter Part G of the form, Apparent Cause, to retain the ability to document and report an incident with a single predominant cause. A new part is being proposed for the report that would allow the operator to select multiple contributing factors when multiple threats or causes interact. We understand that you are evaluating comments to your May 2016 Federal Register notice and intend to ask the Office of Management and Budget to approve the proposed changes by December 2016. Pending completion of these efforts and implementation of the requested changes to the form, Safety Recommendation P-15-16 is classified OPEN—ACCEPTABLE RESPONSE.

From: PHMSA
To: NTSB
Date: 8/17/2016
Response: -From Marie Therese Dominguez, Administrator: On May 13, 2016, PHMSA published a Federal Register notice in docket PHMSA-201 5-0205 proposing changes to Form F7100.2. We are proposing to collect two cycles of integrity inspection data for an incident location instead of just the most recent cycle. The type of inspections conducted directly correlates to the threats evaluated by the inspection. Regarding multiple root causes, PHMSA does not intend to alter Part G of the form, entitled, "Apparent Cause/' to retain the ability to document and report an incident with a single predominant cause. A new part is proposed for the report, allowing the operator to select multiple contributing factors when multiple threats/causes interacted. PHMSA will evaluate comments to the May 13,2016 Federal Register notice and ask OMB to approve the proposal by December 31, 2016.

From: NTSB
To: PHMSA
Date: 7/15/2015
Response: Regarding part (1) of the recommendation, we note that you assume “the results of previous assessments” refers to the integrity assessment and any repairs and/or data gathered. We are aware that the current Form F7100.2 requires operators to report such specific information as the method of HCA identification, information regarding structures in the vicinity of the incident, the previous integrity inspection method(s), non-destructive examinations conducted in the vicinity of the incident, and configuration to accommodate in-line inspection. We note that this information is collected in the main body of the form as well as in the relevant “Cause” categories. Further, the form does not specifically ask which “Identified Threats” were being assessed; however, the type of inspection tool, which is included on the form, provides an indication of what threats an operator assessed. Regarding part (2) of the recommendation, we note that you plan to evaluate adding another Cause section to the Incident Report Form, in addition to the current Part G, Apparent Cause, which will remain in the report to specify a single predominant cause of the incident. The Additional Cause section would allow the operator to select multiple apparent causes for an incident when multiple threats or causes interacted. We note that you plan to evaluate generating a list of all possible apparent causes and consider data analysis options for the predominant and interacting causes, as well. In a May 27, 2015, e-mail, Mr. Alan Mayberry advised us that you will soon issue an initial 60 day notice in the Federal Register for the purpose of updating your incident forms to allow you to collect multiple cause factors. On June 3, 2015, NTSB staff e-mailed comments to Mr. Mayberry concerning the proposed wording in the instruction language and consistency of subcategories in Part G of the proposed update to Form 7100.2. Pending your revision of the form as recommended and as currently scheduled (by the end of October 2016), Safety Recommendation P 15-16 is classified OPEN—ACCEPTABLE RESPONSE.

From: PHMSA
To: NTSB
Date: 5/12/2015
Response: -From Timothy P. Butters, Deputy Administrator: The Pipeline and Hazardous Materials Safety Administration’s (PHMSA) mission is to protect people and the environment from the risks of hazardous materials transportation. We are committed to continual improvements to our oversight program to positively influence the safety performance of pipeline operators. PHMSA has a long history of cooperating and collaborating with the NTSB, and we take our responsibility to address all recommendations seriously. Integrity Management (IM) is a performance-based, process-oriented regulatory program developed by PHMSA in response to the Accountable Pipeline Safety and Partnership Act of 1996 (P.L. 104-304), the Pipeline Safety Improvement Act of 2002 (P.L. 107-355), and PHMSA’s oversight experience. Integrity management regulations supplement PHMSA’s prescriptive safety requirements and set systemic performance requirements for operators. IM is based on practices employed by many safety-oriented organizations, whereby safety is continually improved through an iterative process of collecting data, identifying and prioritizing risks, undertaking corrective actions, and assessing performance. We understand that successful implementation of performance-based systems for pipeline safety requires a significant operator commitment to the approach, a diverse set of skills possessed by the operator and regulator that extend beyond pipeline engineering, detailed information on pipeline system and operating conditions, and an understanding of the causes of incidents and near-incidents. For both operators and regulators, the heart of integrity management is to identify the most serious risks through an evaluation of system and incident data, to take data informed corrective action to address risk, and to evaluate program effectiveness and implement new measures based on ongoing assessments of the results. PHMSA is working to improve pipeline safety and the IM program through regulatory development and other means at our disposal. Our Notice of Proposed Rulemaking (NPRM) titled “Pipeline Safety: Gas Transmission,” updating gas transmission pipeline regulations, was recently sent to the Office of Management and Budget (OMB) for review. This NPRM will address many of the NTSB’s recommendations, and we expect it to help pipeline safety by both setting new requirements for operators to follow, and clarifying existing ones. PHMSA’s National Pipeline Mapping System (NPMS) Information Collection was published in the Federal Register on July 30, 2014. We expect the revised Information Collection to lead to improved positional accuracy and address the need for additional pipeline attribute information to support our internal risk models. We believe both of these efforts will be responsive to the NTSB recommendations made in their respective areas. In parallel with our rulemaking and information collection efforts, PHMSA utilizes a variety of non-regulatory approaches to improve pipeline safety and communications. Our public awareness, emergency response training, research and development (R&D), technical workshops, and enforcement programs have helped to advance pipeline safety. For example, since February 2014, PHMSA has conducted seven workshops and public meetings on technical topics such as R&D, cracking, class location, Safety Management Systems, and the National Pipeline Mapping System. PHMSA is also planning a risk-modelling workshop for the summer of 2015 to address the need for operators to move to more sophisticated risk models. Finally, pipeline operators, as owners of the pipeline infrastructure, are required to know and understand their pipeline system operating environments. PHMSA challenges operators to focus on performance and aim beyond the minimum compliance standards established through pipeline safety regulations, to ensure the safety of the public that lives and works around pipelines. Concur. With respect to the first item, PHMSA assumes “the results of previous assessments” refers to the integrity assessment and any repairs and/or data gathered. Form F7100.2 currently requires operators to report specific information including the method of HCA identification, information regarding structures in the vicinity of the incident, the previous integrity inspection method(s), non-destructive examinations conducted in the vicinity of the incident, and configuration to accommodate in-line inspection. This information is collected in the main body of the form as well as in the relevant “Cause” categories. The form does not specifically ask which “Identified threats” were being assessed for; however, the type of inspection tool, which is included on the form, does provide an indication of what threats an operator assessed for. With respect to the second item, PHMSA will evaluate adding an additional cause section to the Incident Report Form. Part G, “Apparent Cause,” would remain in the report to specify a single predominant cause of the incident. An additional cause section would allow the operator to select multiple apparent causes for the incident when multiple threats/causes interacted. PHMSA’s evaluation will include generating a list of all possible apparent causes and consider data analysis options for the predominant and interacting causes. We will work to include this change in the next form update scheduled for October 31, 2016.